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Waverley Borough Council Committee System - Committee Document

Meeting of the Environment and Leisure Overview and Scrutiny Committee held on 18/04/2006

Summary & Purpose



Current national policy on affordable housing (PPG3)
Current national planning policy on affordable housing is contained in PPG3 (2000) and Circular 6/98. PPG3 acknowledges that the need for affordable housing is a material planning consideration. It states that where there is a demonstrable lack of affordable housing to meet local housing needs then local plans should include a policy for seeking affordable housing in suitable housing developments. Circular 6/98 provides more detail on the national policy for affordable housing. In particular, it sets out the site/size thresholds that the Government considers should apply in determining whether provision should be made for affordable housing. For settlements above 3,000 population, the Circular states that it would not be appropriate for local authorities to adopt thresholds below 15 dwellings or 0.5ha site area.

Update to PPG3 (Planning for Sustainable Communities in Rural Areas) January 2005
In January 2005, the Government published an update to PPG3 relating specifically to the issue of rural exception sites. It states that it is important that there is adequate housing provision in rural areas to meet the needs of local people and to contribute to delivering sustainable communities. It also states that local planning authorities should make sufficient land available either within or adjoining existing rural communities to enable these local requirements to be met. It goes on to state that all local planning authorities that include rural areas should include a rural exception site policy in the relevant DPD. It states that rural exception sites should be small, solely for affordable housing and on land within or adjoining rural communities, which would not otherwise be released for general market housing.

Draft Planning Policy Statement (PPS) 3 - Housing
The draft PPS3, which was published for consultation in December 2005, indicates that targets should be set for the provision of affordable housing. It adds that the target should take account of the anticipated levels of finance available for affordable housing, including public subsidy and the level of developer contributions that can reasonably be sought on relevant sites. It also states that separate targets should be set for social-rented and Intermediate housing where appropriate.

It also states that local authorities should set minimum site/size thresholds, expressed as numbers of homes or area, above which affordable housing will be sought. It states that the indicative national minimum threshold is 15 dwellings, but local authorities may set a different threshold or series of thresholds where this can be justified. It states that in determining minimum site/size thresholds, local planning authorities will need to take into account the level of affordable housing to be sought, site viability, the impact on the delivery of housing provision, and the objective of creating sustainable communities. It is proposed that the supporting Companion Guide to PPS3 (which is being prepared) will provide further information on this issue.

The draft PPS3 also has a section on rural housing. It also states that all planning authorities that have small rural communities should include a rural exception sites policy in relevant development plan documents. It goes on to state that, in applying such a policy, planning authorities should consider the need to meet the needs of the rural economy, and in particular the needs of households who are either current residents or have an existing family or employment connection, in order that rural communities remain sustainable, mixed, inclusive and cohesive.

Regional Planning Guidance for the South East (RPG9)
RPG9 states that the provision of affordable housing in the South East is an important component in the development of mixed and balanced communities, to help meet the housing needs of the whole population. Policy H4 deals with housing needs generally. It states that affordable housing should be provided to meet locally assessed need. The supporting text adds that development plans should include policies for securing affordable housing based on local housing strategies, which, in turn, should be based on robust and regular local assessments of need.

Draft South East Plan (SEP)
The lack of affordable housing is not just a problem in Waverley. At the regional level, the draft SEP recognises the need for affordable housing. It refers to the need for “….a significant step-change in delivery….” (see paragraph 1.6.3 of the draft SE Plan). Policy H4 of the draft SEP relates to affordable housing. It states that local development documents will set targets for the provision of affordable housing, having regard to the overall regional target that 25% of all new housing should be social rented accommodation and 10% other forms of affordable housing. In addition, one of the priorities of the Regional Economic Strategy (RES) (and the RES Review) is to secure quality affordable housing.

The Surrey Structure Plan (SSP) 2004
Similarly, the need for affordable housing is an issue in the SSP 2004. It refers to the problems that both private and public sector organisations have in recruiting and retaining key staff because of the high cost of housing. Policy DN11 of the SSP 2004 states that Local Development Frameworks will include a target for affordable housing, having regard to the objective that at least 40% of new housing provision in the County should be affordable, including housing for key workers.

The Existing affordable housing policies in the Waverley Borough Local Plan (WBLP) 2002
Policy H5 of the Local Plan requires a proportion of affordable housing to be provided on new development sites. This policy only applies above certain thresholds. In the case of settlements with a population above 3,000, the current threshold for requiring affordable housing is developments involving 15 or more net new dwellings or sites of 0.5ha or larger. In settlements with a population of 3,000 or fewer, these thresholds are reduced to 5 or more net new dwellings or sites of 0.2ha or more. Where the policy applies, the requirement is that at least 30% of the number of net new dwellings is in the form of subsidised affordable housing. If the overall density of development is 40 dwellings per hectare or more, then the minimum proportion can be 25%.

Policy H6 of the Local Plan allows for the development of small-scale affordable housing schemes in, adjacent to, or very closely related to rural settlements, provided there is a genuine local need, which cannot be met in some other way. This policy applies to the majority of rural settlements in Waverley.


National policy on housing mix (as set out in PPG3)
One of the Government’s key aims is to secure mixed communities. In relation to this, PPG3 has a section relating to the type and size of housing. It refers to the fact that the majority of the projected growth in households will be made up of one-person households and states that local authorities should adopt policies that take full account of changes in their area.

It goes on to state that local authorities should take account of assessments of housing need in determining the type and size of additional housing for which local authorities should plan. Local authorities should assess the composition of current and future households in their area, and of the existing housing stock in the formulation of plans.

Draft Planning Policy Statement (PPS) 3 and housing mix
The recent Government consultations on changes to PPG3 dealt with both housing needs issues and the supply of new housing. A common theme was the emphasis on the housing market. In essence, the approach being promoted is that decisions on the amount and location of housing and the type of housing should be informed by a better understanding of the local housing market. The recently published consultation paper on the proposed PPS3 continues the theme of understanding and responding to the local housing market both in terms of the supply of housing and in relation to housing needs. In order to underpin this work, the draft PPS3 promotes Housing Market Assessments (HMAs), based on defined housing market areas. It states that the regional planning bodies (in this case SEERA) should co-ordinate a programme of sub-regional HMAs and Housing Land Availability Assessments. It is for the regional planning body to identify the sub-regional housing market areas and to identify which local authorities these include.

The draft PPS3 goes on to state that in future housing allocations by the regional planning body would be based on the identified sub-regional housing market areas. In terms of household type, the draft PPS3 states that planning authorities should have regard to the relevant sub-regional HMA when determining the overall balance between different household types to be provided for across the plan area and to ensure, for example, that housing provision is made, for example, for family, single person and multi-person households.

Regional Planning Guidance for the South East (RPG9)
In relation to general housing needs, RPG9 refers to projections indicating an increase in one and two person households. It states that these households are likely to have different needs from larger households in terms of the size, type and location of home required. It also refers to the projected increase in the proportion of households with older people and the need to be flexible in catering for various needs, such as the needs of people with disabilities. Policy H4 states that a range of dwelling types and sizes should be provided for.

The Draft South East Plan (SEP) and housing mix
The draft SEP includes a policy (PolicyH6), which relates to ‘Type and Size of New Housing’. In the accompanying text, it states that it is essential that the housing that is provided is appropriate to the needs of the community, which means that a range of types, sizes and tenures of housing will be required over the coming years, to reflect the differing requirements and circumstances of different types of household. It acknowledges the trend towards smaller households but adds that it is not the case that only one and two bedroom units will be needed in the future. It goes on to state that in order to help match provision with need, local authorities will prepare comprehensive assessments of the kind of new housing that is needed in their areas.

Both the draft SEP and the Regional Housing Strategy include maps indicating what are considered to be the local housing markets operating across the region. In Waverley’s case, the principal housing market area is considered to be the Guildford/Woking housing market. This follows the corridor of the A3 and London – Portsmouth railway line, running from Woking to Petersfield and beyond. This market area covers a substantial part of Waverley. In addition, to the west, Farnham is influenced by the Blackwater Valley housing market area. These are the two principal markets affecting Waverley. However, the map also indicates that part of the south-eastern corner of Waverley is influenced by the Crawley/Gatwick housing market area. It is recommended that where housing market areas cross administrative boundaries, the housing market assessments would be best conducted jointly between local authorities.

Housing mix and Local Plan Policy H4
Local Plan Policy H4 affects the mix of market housing in new developments. It requires that on developments comprising three or more units, at least 50% should have a maximum of two bedrooms and at least 80% should have a maximum of three bedrooms. The Council also published Supplementary Planning Guidance in relation to Policy H4 in October 2003. Local Plan Policy H7 encourages proposals for the provision of supported housing for those with special needs.

Circular 01/2006 ‘Planning for Gypsy and Traveller Caravan Sites’
Circular 01/2006 defines “gypsies and travellers” as:-

“Persons of nomadic habit of life whatever their race or origin, including such persons who on grounds only of their own or their family’s or dependants’ educational or health needs or old age have ceased to travel temporarily or permanently, but excluding members of an organised group of travelling show people or circus people travelling together as such.”

The Circular indicates that it is necessary to conduct an assessment of gypsy and traveller accommodation needs, to inform Development Plan Documents. In terms of site provision, it states that before Green Belt locations are identified, other alternative sites should be explored.

Circular 22/91 ‘Travelling Showpeople’
Circular 22/91 states that Showpeople are self-employed business people who travel the country holding fairs, chiefly during the summer months. The Circular states that the local planning authority should consider the needs of travelling showpeople when preparing development plans and should identify existing sites with planning permission.

Draft South East Plan (SEP) Policy H6
The draft SEP Part 1: Core Regional Policies (July 2005) states in Policy H6 – ‘Type and Size of New Housing’, “that gypsies and travellers and others with specialist requirements, as relevant”, should be included in Housing Needs/ Market Assessments.

Local Plan Policy H11
The eight authorised sites are shown on the Waverley Borough Local Plan 2002 Proposals Map, and are safeguarded for Gypsies under Policy H11 – ‘Gypsy Sites’. Policy H11 specifically aims to ensure that provision is made within the Borough for the accommodation of Gypsies consistent with their needs and lifestyle having regard to the policies of the Surrey Structure Plan, other Local Plan policies, relevant legislation and Government advice.

Draft Core Strategy Policy14
The draft Core Strategy (December 2005) identifies gypsies, travellers and travelling showpeople as a specific group where accommodation issues will be addressed. This is incorporated within policy CP14 – ‘Housing Need’.

1.The provision of subsidised affordable and social housinga) Maintain current policy on site/size thresholds and the percentage of affordable housing required on qualifying sitesTried and tested approach – has delivered affordable housing;Many housing developments are below the thresholds;
Could be regarded as placing an unfair burden on developers of larger schemes;
Unlikely to deliver the overall target for affordable housing;
Evidence that developers design schemes to keep below thresholds;
b) Lower the site/size thresholds and/or increase the percentage of affordable housing required on qualifying sitesLikely to result in an increase in overall supply of affordable housing;
Would be a fairer approach;
Council better able to respond to identified needs;
Tighter control on the delivery of affordable housing.
Could have a negative affect if thresholds or required percentage of affordable housing were to adversely affect delivery of sites.Scope to reduce thresholds will not be fully known until PPS3 is published.

Could consider variable thresholds based on location, size and local circumstances.

Should affordable housing be required in connection with “enabling development”?

Lower thresholds likely to result in more cases where commuted sums are provided instead of on-site provision. This raises resource issues and the issue of the availability of alternative sites. It is also a move away from the concept of “mixed communities”.
c) Specify the mix of subsidised affordable housing in terms of rented and “Intermediate Housing” (non-rented accommodation).Clearer policy – more certainty for prospective developers;
More responsive to identified needs.
Could be regarded as being too inflexible – may not respond to local needs, availability of funding or site specific circumstances.In the current Local Plan there is an exemption whereby developments that meet a recognised need for specialised sheltered housing, on sites of less than 0.4 hectares, are not required to make provision for affordable housing. In considering options regarding the thresholds for affordable housing, the Council will also need to consider whether there is any justification for this exemption to continue.

Need to determine the approach to when it is acceptable to receive commuted sums towards provision of affordable housing and to formalise a policy on using commuted sums.

Option c) could be used in conjunction with either a) or b)

Important to have clear definitions – for example “Key Worker” or “Essential Worker” and “Intermediate Housing”.
2.Subsidised affordable housing and exception sitesa) Maintain existing policy on exception sitesPolicy has been successful in delivering rural affordable housing;Reactive process
b) Maintain existing policy and, in addition, identify or allocated potential rural exception sitesMore pro-active;Could lead to landowners not releasing sites in the hope that the site could be developable for market housing.
c) Consider further exception sites around the main settlements (like the Wyphurst Road scheme in Cranleigh)May deliver more affordable housing around main settlements.Could result in urban sprawl;
These sites are by their nature exceptional – do they need to be allocated?
This approach would be additional to options a) or b).

Consideration of this option dependent on the Government policy that is contained in the forthcoming PPS3.
3. Planning and Market housing
    a) Maintain current policy of requiring a proportion of new private housing to have a maximum of 2 or 3 bedrooms (Local Plan Policy H4)
Contribute to addressing the imbalance in the mix of current housing stock;
Requiring a mix contributes to national objective of delivering mixed communities;
May indirectly deliver more “affordable” market housing.
Inflexible approach – does not consider local or site circumstances;
Other ways of controlling mix – why not consider size rather than number of bedrooms;
Requiring “small” units does not necessarily ensure that they will be “affordable”.
New Government policy in the forthcoming PPS3 may affect whether or not the current policy can continue.

Can/should the Council prevent extensions in order to retain the stock of smaller dwellings? – Insufficient knowledge or understanding of the market (possibly something for later Housing Market Assessment work).
    b) Do not specify the mix – leave it to the market
Much less prescriptive – developer may be better able to respond to site circumstances;High demand generally may mean that market may not deliver the mix of housing to meet the wide range of housing needs;
4. Other housing needs
4a) Housing for the elderly and other special needs groupsThe current Local Plan includes a policy that encourages the provision of supported housing for those with special needs (Policy H7). Should this be retained or developed further?Housing needs and the supply of housing for people with support needs may require further investigation – perhaps through future Housing Market Assessment work, potentially on a sub-regional basis.
4b) The accommodation needs of gypsies, travellers and travelling showpeopleSafeguard sites for travelling showpeople in the same way as sites for gypsies.Clear policy position giving certainty to Showpeople.Could lead to local opposition.Need clear criteria re: occupancy.
Identification of new sites to provide for future accommodation needs of gypsies, travellers and travelling showpeople?Pro-active – greater certainty.Little if any publicly owned land either available or suitable. Privately promoted sites tend to be very controversial.Broader picture not available until wider sub-regional/regional work completed by SEERA. At present needs of local gypsy and showman families are accommodated by making more intensive use of existing sites, leading to greater concentrations of gypsies and travelling showpeople in certain parts of the Borough. Indications are that, for the foreseeable future, needs of existing occupiers can be met within existing sites. Two unauthorised sites are subject to current appeals.

Current national policy on housing supply (PPG3)
PPG3 promotes a Plan, Monitor, Manage approach to housing supply. It states that local authorities are expected to manage the release of housing over the plan period in order to control the pattern and speed of urban growth. In Waverley’s case, the “plan period” for both the Core Strategy and the Housing DPD is up to 2018.

In relation to the allocation of sites for housing, PPG3 sets out the following criteria for assessing their potential and suitability:-
the availability of previously developed sites;
the location and accessibility;
the capacity of existing and potential infrastructure;
the ability to build communities; and
the physical and environmental constraint on the development of land.

In relation to “windfall” sites, PPG3 states that Authorities should make specific allowances for all types of windfalls in their plans. The allowance should be based on both past trends and the likely future potential as assessed in a capacity study.

Draft PPS3 and housing supply
The recently published draft PPS3 puts forward some potentially significant changes in national policy in relation to the supply of housing. These potential changes include:-

providing a greater link between housing supply and the local housing market. The draft PPS3 indicates that local authorities should collaborate on carrying out Housing Market Assessment (HMAs) for the sub-regional housing markets, which will have been identified at the regional level. Housing distribution set by the region would be based on the housing market areas rather than, at present, by local authority area.

requiring local authorities to allocate sufficient land and buildings for the next five years, with the Housing Trajectory extending a further 10 years beyond this. The draft PPS3 states that the supply for the first five years should only include an allowance for brownfield windfall sites where the particular local circumstances justify it and where sustainability appraisal indicates that allocating sufficient land would have unacceptable impacts.

the draft PPS3 states that in general local authorities should not phase land within the first five-year land supply.

the draft PPS3 does not retain a requirement for Councils to adopt the plan, monitor, manage approach to managing the supply of housing.

Regional Planning Guidance for the South East (RPG9)
Policy H5 of RPG9 relates to housing provision. It states that within the context of improving the quality of urban living, full use should be made of the opportunities for increasing housing development within urban areas. The accompanying text states that local authorities should base policies for the release and development of land on a sequential approach as set out in PPG3.

The draft South East Plan and housing supply
The draft South East Plan promotes the use of detailed ‘Housing Delivery Action Plans’. It states that these should not identify individual sites for housing, as this should be done through Local Development Plan Documents (such as the Housing DPD). Housing Delivery Action Plans should set out the overall strategy for ensuring that housing allocations can be met, having regard to the outcome of urban potential studies and housing market assessments. They should identify potential and existing barriers to new housing delivery and set out the actions that need to be taken to overcome these barriers. The draft SEP states that new housing provision should be phased within Local Development Documents (such as this DPD) to ensure that identified needs can be delivered in a planned fashion and to ensure that it does not overload the capacity of local infrastructure.

The Surrey Structure Plan (SSP) 2004 (Policy LO6)
Policy LO6 of the 2004 SSP, which sets out the housing requirements for each district, also states that authorities should adopt a ‘Plan, Monitor, Manage’ approach, with appropriate phasing policies in Local Development Frameworks (LDFs). In the section of the SSP explaining how Policy LO6 will be implemented, it states that, inter alia, authorities will ensure that there is sufficient housing to meet the annual average requirement for at least 5 years; and will phase the release of housing sites, having regard to the provision of adequate infrastructure and services and the availability of previously developed land within the urban areas.

Waverley Borough Local Plan Policy H2
This policy is a phasing policy, which relates to large windfall sites that are of a predominantly open nature (including sites with a large area of garden land). In essence, if the housing land supply in the area, relative to the SSP 2004 requirements, is greater than 5 years + 20% (i.e. at least 6 years), the Council may refuse permission on the grounds of prematurity. This policy was included in the current Local Plan with the endorsement of the Local Plan Inspector, who considered it to accord with PPG3.


1. Phasing housing supplya) Maintain current policy (Local Plan policy H2) which allows for the phasing of the release of large sites that are of a predominantly open nature, when the current land availability is the equivalent of at least 6-years supply based on the Structure Plan requirement.Phasing where necessary will allow better management of the release of land, to ensure a consistent supply of housing over plan period;
May encourage sites to come forward in more appropriate locations.
May prevent sites coming forward that could contribute affordable housing;
The existing phasing policy is limited in application. The phasing criteria only based on size and openness of the site. Does not address issues like sustainability or availability of infrastructure.
It will not be possible to determine the most suitable approach until the new Government policy is published in the forthcoming PPS3.
b) Develop new criteria for phasing, based on other factors, such as sustainability and the availability of infrastructure.Phasing where necessary will allow better management of the release of land, to ensure a consistent supply of housing over plan period;
May be more in line with current policy as it could address issues such as sustainability, accessibility and the availability of infrastructure;
A more qualitative approach.
Could become too prescriptive.
c) No phasing of housing supplyPotential for increased supply of housing overall, which, depending on the size of the developments, may also deliver an overall increase in the supply of affordable housing.Would not allow for the management of the release of land over the whole plan period;
May prevent the most suitable sites coming forward;
Potential oversupply in short term could affect long-term land supply.
2. The role of windfall sitesa) Continue current approach (i.e. allow windfalls to contribute to meeting the Structure Plan requirement)This approach has enabled Council to meet (and exceed) the Structure Plan housing requirement;
Would be difficult to identify enough individual sites to replace an allowance for windfalls;
More difficult to manage the release of land for housing;
Many windfall sites are small and currently do not contribute towards affordable housing or other infrastructure requirements
It will not be possible to determine the most suitable approach in relation to the role of windfall sites until the new Government policy is published in the forthcoming PPS3.

Could carry out further research on the role that windfall sites play.

Could consider developing criteria based policy for the consideration of windfall sites.
b) Allocate more specific housing sites and regard windfalls as extra.Would be a more pro-active approach, with the identification of more individual sites.Many windfall sites are small and do not contribute towards affordable housing or other infrastructure requirements;
Potential oversupply in short term – could affect long term land supply.
c) Allocate more specific sites and develop a policy to limit the supply of windfall sites.Would be a more pro-active approach to managing the release of sites;
More likely to deliver the most appropriate sites.
Difficult in practice to identify and allocate sufficient sites in advance, given character of the area;
Potential to stifle the market.
3. Infrastructure and services
    a) Maintain existing policy (i.e. the general policies in the Local Plan – D13 & D14)
Flexible approachDifficult to address the range of infrastructure and service requirements, particularly in the case of small sitesNeed to ensure consistency within Waverley and with neighbouring authorities.

Could provide the strategic framework within the Housing DPD, with the detail being contained in a separate LDF document.
    b) As the Council is proposing to develop separate policy on infrastructure and planning obligations generally no need to include a policy in the Housing DPD
Infrastructure is not just an issue for housing. Need to have a policy to address the infrastructure requirements for a range of different types of development.Would have a less direct link to the specific requirements associated with new housing.
    c) Link choices about phasing and density of housing to an assessment of infrastructure and services
Would be tailored to the specific impacts of housing and would inform choices about site selection etc.Potential duplication with other planned policy documents.


National planning policy on the Location of Housing (PPS1 & PPG3)
Planning Policy Statement 1 (PPS1) sets out the Government’s overarching policy on planning. It refers to the role that planning has in facilitating and promoting “….sustainable and inclusive patterns of urban and rural development.” It also identifies four aims of sustainable development:-
social progress which recognises the needs of everyone;
effective protection of the environment;
the prudent use of natural resources; and
the maintenance of high and stable levels of economic growth and employment

In relation to the location of development it refers to the need for plans to bring forward sufficient land for housing, and other uses, in appropriate locations, taking into account such issues as accessibility and sustainable transport needs. It also identifies the need to improve access for all to jobs, health, shops, leisure etc. by ensuring that development is located where everyone can access services or facilities on foot, bicycle or public transport.

It also states that plans should promote the more efficient use of land through higher density, mixed use development and the use of suitably located previously developed land and buildings. PPS1 also promotes good design. It states:- “Design which is inappropriate in its context, or which fails to take the opportunities available for improving the character and quality of an area and the way it functions, should not be accepted.”

Planning Policy Guidance Note 3 (PPG3) sets out the current national policy on planning for housing. In terms of the location of development it advocates a sequential approach, with priority being given to previously developed land and buildings within urban areas, followed by urban extensions and finally new development around nodes in good public transport corridors.

In terms of density, PPG3 states that local authorities should:-
avoid developments which make inefficient use of land (those less than 30 dwellings per hectare (dph) net);
encourage housing development which makes more efficient use of land (between 30 and 50 dph net; and
seek greater intensity of development at places with good public transport accessibility such as city, town, district and local centres or around major nodes along good quality public transport corridors.

Draft Planning Policy Statement 3 (PPS3)
In terms of the location of housing, the draft PPS3 states that the priority for development is still brownfield land. However, to be considered this must be developable (i.e. available, suitable and viable). As part of the consideration of how to meet housing requirements, the draft PPS states that local authorities should review all their non-housing allocations (such as land allocated for industry) and consider whether some of this land could be more appropriately used for housing or mixed-use development.

In terms of density, local authorities are advised to develop density policies for their plan areas. The draft PPS3 includes an annexe that contains a table of indicative density ranges for specific types of location. These indicative densities range from 30-40 dph in areas defined as “rural” to above 70 dph in areas defined as “City Centre”. It goes on to state that the density ranges for each area should be based on a range of considerations, including an assessment of the characteristics of the area; the level of public transport accessibility; and the need to use resources efficiently and minimise environmental impacts.

In the section in the draft PPS3 on design, there is some discussion on the development of existing residential land and the role of garden land. It states that the approach to developments such as the redevelopment of existing housing and gardens should be developed as part of the wider strategy/policies for individual neighbourhoods. It adds that although residential gardens are defined as “brownfield” land, this does not necessarily mean that they are suitable for development. However, local authorities will need to have regard to the positive contribution that intensification can make, for example in terms of minimising the pressure on greenfield sites.

Regional Planning Guidance for the South East (RPG9)
Policy H5 of RPG9 deals with housing provision. The accompanying text refers to local authorities making proposals for high quality intensive residential and mixed use development on land close to town centres and at points of good public transport accessibility, or where public transport services can be improved as part of a planned approach.

The draft South East Plan
Policy H3 of the draft South East Plan relates to the location of housing. It identifies the target, across the region, of at least 60% of additional housing being on previously developed land. It goes on to state that the new housing required to meet district requirements - whether on previously developed land or on greenfield land – should be in sustainable locations, which have the necessary infrastructure, services and community provision, or where provision is planned. It adds that housing developments should generally be in locations that are, or can be, well served by a choice of transport modes, with higher densities in or near locations well served by public transport.

Surrey Structure Plan 2004
This contains a general policy on the location of development (Policy LO1). This also states that new development will be located primarily within existing urban areas on previously developed land.

Waverley Borough Local Plan 2002
Policy M1 is a general policy regarding the location of development. It states that the Council will seek to ensure that development is located so as to reduce the need to travel, especially by private car. Policy H4 deals with both housing density and housing mix. In terms of density it follows the guidance in PPG3 (see above).

There are many other policies in the Local Plan that affect choices about the location and density of housing. For example, policies for the Green Belt and the Countryside indicate a general presumption against new housing outside identified settlement boundaries. Within the developed areas, policies are less about the principle of development and more about detail. There are various policies that affect the type and density of development within settlements. In particular, policies D1 and D4 are general policies on environmental impact and the design and layout of development. Within identified rural settlements there is a general policy (RD1) that determines whether development is acceptable and if so, in what form.

There are also locations within the developed parts of the Borough that are subject to area-specific policies that seek to protect the distinct character of those areas. For example, Policy BE3, which seeks to protect the semi-rural character of specific parts of Farnham.

The Draft Core Strategy
As explained above, the overall strategy for the future location of development, as set out in the Council’s draft Core Strategy is to locate new development primarily on previously developed land in sustainable locations in Farnham, Godalming, Haslemere and Cranleigh.


1. Sustainability and the location of developmenta) Continue current approach (I.e. do not use specific sustainability/accessibility criteria when making decisions about sites)Flexible approach;
Housing numbers are being delivered;
Sustainability issues can only have a limited effect on decision making on density and site suitability
b) Develop criteria to assess the sustainability of sites and use these to inform decisions about site selection, phasing and density.Would ensure that this issue has more prominence in decision making on the suitability of sites and on density issuesLess flexible – may be less scope to respond to other site specific issues;Need to provide clear definition of sustainability.

Could consider site specific sustainability criteria for allocated sites.
2. The density of new housinga) Continue current approach to density (i.e. apply the PPG3 density requirements without identifying specific density zones).Quite a flexible approach;
Housing numbers are being delivered.
Less certainty/clarity;
Difficult to include density considerations when assessing the suitability of some sites.
The approach that the Council takes on this issue will be dependent on the Government policy that is contained in the forthcoming PPS3

Important to consider other issues like delivery of affordable housing and open spaces/green spaces.

Infrastructure issues could also inform decisions about density.
b) Develop density policies further by setting density ranges for all areas, based on criteria such as character and accessibility.Would provide more certainty of what is required. Subject to the criteria used, should assist in ensuring that development is appropriate for its locationCould be regarded as being too prescriptive and less able to respond to specific site circumstances
3. Housing design and the issue of character
    a) Continue with current policies (including retention of existing character areas)
Flexible approach;
Delivers housing numbers; gives protection to the existing “character areas”
May not be providing adequate controls in relation to housing development, particularly in existing residential areas.These options are not mutually exclusive.

The approach that the Council takes on this issue will be dependent on the Government policy that is contained in the forthcoming PPS3

Would need to ensure that whatever approach is followed, the overall housing requirement can be met.
    b) Develop policies on design to enhance the protection for all locations (linked to setting density ranges for different locations)
Would enhance protection for all areasCould be regarded as being inflexible;
Could have an impact on overall supply
    c) Designate new or enlarged “character areas”
May provide added protection to certain parts of the BoroughIdentifying additional “character areas” or enlarging existing “character areas” could have the effect of moving the pressure for development to other locations with possible adverse consequences;
Unless criteria are strictly defined, the identification of further areas may dilute the overall value of these designations.