dear sir/madam, we look forward to hearing from you in due ......elysian residences. i would be...

From: Alexandra MilneTo: Planning PolicySubject: Runnymede Pre-submission Draft Local Plan | RepresentationsDate: 22 February 2018 19:40:40Attachments: ER PSDLP reps FINAL 22.02.18-compressed.pdf

Dear Sir/Madam,

Please find enclosed representations on the Pre-submission Draft Local Plan made on behalf ofElysian Residences. I would be grateful if you could confirm receipt.

We look forward to hearing from you in due course.

Kind regards,Alex

Alexandra MilneAssociate

direct: 020 7004 1779mobile: 07711 556 895e-mail: [email protected]

DP9 Ltd100 Pall MallLondonSW1Y 5NQ

telephone: 020 7004 1700 facsimile: 020 7004 1790 website: www.dp9.co.uk

This e-mail and any attachments hereto are strictly confidential and intended solely for the addressee. It may containinformation which is privileged. If you are not the intended addressee, you must not disclose, forward, copy or take any action inrelation to this e-mail or attachments. If you have received this e-mail in error, please delete it and notify [email protected]

2006
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DP4708 Home Farm, Virginia Water

1

PRE-SUBMISSION DRAFT LOCAL PLAN 2030

REPRESENTATIONS TO RUNNYMEDE BOROUGH COUNCIL

FEBRUARY 2018

DP9 Limited

DP9 Ltd

100 Pall Mall

London

SW1Y 5NQ

Tel: 020 7004 1700


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CONTENTS

1. Executive Summary .......................................................................................................... 3

2. Introduction ....................................................................................................................... 5 3. Pre-submission Draft Local Plan ...................................................................................... 6

Policy SD2 (Spatial Development Strategy) ................................................................................. 7 Policy SD3 (Site Allocations) ...................................................................................................... 14 Policy SL1 (Health and Wellbeing) ............................................................................................. 16 Policy SL2 – SL18 (Housing Site Allocations) ........................................................................... 16 Policy SL19 (Housing Mix and Requirements) ........................................................................... 16 Policy SL20 (Affordable Housing) and Policy SL23 (Accommodating Older Persons and

Students) ...................................................................................................................................... 17 Policy SL23 (Accommodating Older Persons and Students) ...................................................... 17 Policy SL26 (New Open Space) .................................................................................................. 18 Policy EE1 (Townscape and Landscape Quality) ........................................................................ 19

APPENDIX 01: ASSESSMENT OF HOME FARM FOR GREEN BELT RELEASE AND

ALLOCATION FOR HOUSING

APPENDIX 02: REPRESENTATIONS ON PSDLP EVIDENCE BASE

APPENDIX 03: ANALYSIS OF SITES ALLOCATED WITHIN THE PSDLP

APPENDIX 04: A PRELIMINARY REVIEW OF THE CURRENT PROVISION AND

FUTURE NEED FOR SPECIALISED ACCOMMODATION IN THE

BOROUGH OF RUNNYMEDE, SURREY.


3

1. Executive Summary

1.1. This document has been produced on behalf of our client, Elysian Residences, in response

to Runnymede Borough Council’s Pre-Submission Draft of the Local Plan 2030 under

Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulations

(2012). The purpose of this consultation stage is to establish whether the Plan is sound prior

to submission to the Secretary of State for examination in public. This document primarily

responds to the draft Local Plan 2030 and the supporting evidence base.

1.2. In summary, we object to the way in which the draft Plan has been drafted.

1.3. These significant short-comings relate to four key points:

• A failure to correctly calculate the Objectively Assessed Need for the authoritative area

of RBC or draw down an accurate housing target within the draft Plan;

• A failure of the draft Plan to meet the Objectively Assessed Need (OAN) for new

housing generally;

• The failure of the draft Plan to recognise and to identify the need and provide adequate

allocations to meet the demand for specialist extra-care accommodation; and

• The need to revise the wording of some criteria-based policies relating to residential

provision, which are referred to in this document.

1.4. In our view, these short-comings result in the Plan being unsound.

1.5. Of greatest significance is the failure of RBC to provide or designate sufficient sites to

meet the OAN for housing in the borough. In our view, several factors contribute to this

failure, which include:

• A failure to draw a reliable conclusion on the housing land supply from previous

performance and delivery within the borough;

• Erroneous benchmarking of housing targets against a +9% buffer when RBC’s historic

under-delivery means a +20% buffer should be applied in accordance with the

requirements of the NPPF;

• An over-estimation of the capacity of site allocations to deliver new housing;

• Reliance without foundation on the capacity of unallocated and non-permitted SLAA

sites to deliver housing, including sites located within the Green Belt;

• Reliance without foundation on the willingness and ability of neighbouring boroughs

to accommodate an acknowledged shortfall in RBC’s provision of housing; and

• An unjustified abridgement of the Plan period to just 15 years which conceals the level

of delivery which should be expected from Plan site allocations in relation to the

identified housing needs of the borough.


4

1.6. The latter point detailed above is also in part the reason for RBC’s failure to approach its

Green Belt review in the correct way. Such a review should be a rare occurrence in the

life cycle of plan-making and, in accordance with paragraph 85 of the NPPF, should result

in the release of sufficient land to meet the identified housing need and the longer-term

development needs stretching well beyond the plan period. Whilst we welcome RBC’s

acknowledgement of this requirement and subsequent review during this Plan, its

approach to the release of Green Belt sites is considered to be particularly onerous and

fails to accommodate sufficient land for any subsequent Local Plan review. In summary,

it will force upon RBC to undertake another Green Belt review in short order, which is

contrary to the principles of sound plan-making.

1.7. RBC has not allocated enough sites for housing in its plan. We therefore consider and urge

RBC to allocate more sites and should include at the very least, the release of our client’s

site (Home Farm) from the Green Belt.

1.8. The Home Farm site would deliver a significant proportion of both the specialist housing

and general housing market required to meet the needs identified in RBC’s evidence base.

The required exceptional circumstances justifying a release of our site are present and

supporting evidence justifying a release is included as part of these representations.

Indeed, when properly analysed our site scores equal or better than several sites which

RBC has currently agreed to release from the Green Belt. Our case does not solely rely on

our site supplanting other sites which RBC has agreed to release, even though that

conclusion is warranted on proper comparative analysis. It is however, sufficient for us to

demonstrate, as this representation does, that RBC needs to release further sites from the

Green Belt and that the Home Farm site should be one of these additional releases.

1.9. In addition to the points raised above, we consider the wording of several criteria-based

policies need to be changed and updated to positively engage development and deliver the

core objectives of the draft Plan. Our proposed recommendations to the wording of these

policies is set out in this document. Ultimately, amending these policies will make

forthcoming development more sustainable and deliverable within the authoritative

bounds of Runnymede.

1.10. This document is accompanied by several appendices which provide evidence and further

detailed analysis of RBC’s draft Local Plan 2030 and the supporting evidence base. These

should be read alongside this document and forms part of our wider representations to

RBC.


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2. Introduction

2.1. These representations have been prepared to respond to Runnymede Borough Council’s

(RBC) Pre-Submission Draft Local Plan (‘PSDLP’) and associated evidence base

documents, which are currently out for consultation under Regulation 19 of the Town and

Country Planning (Local Planning) (England) Regulations 2012 (as amended). These

representations have been jointly written by SLR Consulting Limited (“SLR”) and DP9

Limited and submitted on behalf of our client, Elysian Residences (Elysian hereafter). The

purpose of this consultation is not only to provide comment on the draft policies, but also

to consult on whether the plan is sound.

2.2. Further information relating to our client and their landholding at Home Farm, Stroude

Road, Virginia Water is contained within Appendix 01.

2.3. We reserve the right to revisit the content of these representations in the context of new

national policy should it be published in advance of RBC’s Local Plan being adopted.


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3. Pre-submission Draft Local Plan

Overview

3.1 The Pre-submission Draft Local Plan 2030 (“PSDLP”) published for consultation on 11

January 2018, outlines three core objectives of the plan, namely to support local people,

enhance the environment, and improve the economy. We support RBC’s vision, including

the intention to find a housing supply that that will address the significant amount of

housing need, including specialist housing, throughout the plan period. We also recognise

that protection and enhancement of the environment is a key objective, and one which

seeks to protect the extent of RBC’s Green Belt where appropriate. As set out in the

spatial strategy (paragraph 5.9), a limited number of sites have been identified for release

from the Green Belt and will be allocated for housing.

3.2 The plan period has been reduced from 20 years as set out in the previous Plan

consultation stages, to just 15 years. We must raise concern that the authority has taken

the decision to shorten the plan period to overcome issues surrounding the OAN and

associated housing land supply. This is a short-term solution which will only cause the

issues surrounding housing to be offset until either the next plan period or the latter part

of this plan period (i.e. if a backlog occurs or housing completions fall short of the annual

housing target identified).

3.3 We also consider that, as detailed below, the Green Belt Review(s) has erred in judgement

and methodology. RBC have accepted that to meet the Objectively Assessed Housing

Need (‘OAN’) sites will need to be removed from the Green Belt, however, the sites

identified for allocation will not be sufficient to meet either the OAN or the identified

housing target contained within the PSDLP itself.

3.4 NPPF paragraph 83 explains that once established, Green Belt boundaries should only be

altered in exceptional circumstances, and at that time authorities should consider the

Green Belt boundaries having regard to their intended permanence in the long term, so

that they should be capable of enduring beyond the plan period.

3.5 The Council has not used the Green Belt Review (2014 and 2017) to release sufficient

land between the urban area and the Green Belt to meet either the identified housing need

or the longer-term development needs stretching well beyond the plan period which is

suggested under paragraph 85 of the NPPF.

3.6 The evidence base documents that have guided the site allocations have overlooked a

suitable, deliverable and developable site, namely Home Farm, Stroude Road, Virginia

Water. The details of the Home Farm site and its suitability for release from the Green

Belt and allocation for housing are discussed in details at Appendix 01.

3.7 Although the Leader’s forward to the PSDLP states that “no stone has been left unturned

in the discovery phase of this plan to ensure that the council has done their upmost in

finding ways to provide for all the types of housing”, the Plan does not identify a suitable


7

housing land supply to meet RBC’s need, and cannot be found sound whilst potential

housing sites appropriate for release from the Green Belt have not been allocated.

3.8 Our detailed responses to policies in the PSDLP are detailed below.

Policy SD2 (Spatial Development Strategy)

Overall Delivery

Demand

3.9 The accompanying representations prepared by SLR on the Council’s evidence base

documents (attached at Appendix 02) conclude that RBC’s OAN over the Plan period

should be somewhat higher than the housing need of 7,507 dwellings identified within

the PSDLP. Whilst the SHMA (2018) covers the period 2016-2030 (14 years rather than

the PSDLP period of 2015-2030), it is contended that the OAN should be in the region of

8,620 dwellings over the PSDLP plan period, as set out in the table below.

Stage Dwellings

p.a.

Total

Dwellings

Demographic Starting Point (2014-based SNPP) 415 5,810

Adjustment for suppressed household formation rates 446 6,244

Further

adjustments

Employment Need Uplift - -

Market Signals (25%) – against

Demographic Starting Point (inclusive of

affordable housing)

104 1,456

Backlog - 779

Full OAN for Housing 2016-2030 575 8,045

Full OAN for Housing 2015-2030 575 8,620

C2 Provision* (*figures not included in OAN) 13 180

3.10 Based on the expected delivery of 7,413 dwellings set out in the PSDLP over the 15-year

plan period, RBC have calculated that an average of 494 dwellings per annum will be

delivered. Paragraph 5.37 of the PSDLP recognises that from 1st April 2015 to 31st

March 2017 there was a shortfall of 472 dwellings completed, equal to a shortfall of 236

per annum. This is inconsistent with Paragraph 5.39 of the Updated SHMA (2018) which

states that there has been no under-delivery of housing in the borough. We would also

contend that there is a more significant backlog of housing delivery within RBC,

extending longer than the previous two years, given that DERA (now Longcross) was not

delivered during the previous Plan period.

3.11 The table below sets out a summary of the RBC’s Objectively Assessed Need as shown

in the SHMA and PSDLP, as well as SLR’s own calculations of the OAN. The

conclusions drawn from this table show that RBC’s SHMA has under estimated the need

for the plan period by 1,150 dwellings.


8

Table of OAN – including SHMA & RBC figures

SHMA – GL Hearn Runnymede BC PSDLP SLR Assessment

Stage Dwellings p.a.

Total Dwellings

Dwellings p.a.

Total Dwellings

Dwellings p.a.

Total Dwellings

Demographic Starting Point (2014-based SNPP)

415 5,810 - - 415 5,810

Adjustment for suppressed household formation rates

446 6,244 - - 446 6,244

Further adjustments

Employment Need Uplift - - - - - -

Market Signals – against Demographic Starting Point (inclusive of affordable housing)

83 1,162

(20%)

- - 104 1,456

(25%)

Backlog - - - 472

(2015-2017)

- 779

(2006-2016)

Full OAN for Housing 2016-2030 498 6,972 - - 575 8,045

Full OAN for Housing 2015-2030 498 7,470 500 7,507 575 8,620

C2 Provision* (*figures not included in OAN)

13 180 13 180 13 180

3.12 Due consideration should also be given to the Housing White Paper entitled ‘Planning for

the right homes in the right places’ (September 2017) which outlines a potential standard

method for calculating local authorities’ housing need. It should be noted that if the

Runnymede Local Plan has not been submitted for examination on or before the 31st

March 2018, it will need to accord with the new standard method for assessing housing

need. This standard methodology would result in an OAN of 557 dwellings per annum for

RBC.

3.13 Even if the PSDLP is submitted for examination before the 31st March 2018 deadline, the

Housing White Paper also identifies that for those authorities which have adopted their

local plan in the last five years (including those submitted for examination), “their new

annual local housing need figure should be capped at 40 per cent above the annual

requirement figure currently set out in their local plan”. As such, were the Housing White

Paper brought forward within the anticipated revisions to the National Planning Policy

Framework, RBC would need to adopt this higher standard method OAN going forward.

The failure to identify sufficient housing sites for both the PSDLP and beyond the current

plan period will only be exacerbated by the adoption of the national standard method for

calculating housing need.


9

Summary of housing need

3.14 Overall, RBC’s assessment of its housing need is unsound for the following reasons:

• The SHMA covers a period of only 14 years

• The SHMA calculations have underestimated the actual need for housing

• The shortfall from the first two years of the plan period has not been appropriately

applied

• A 20% buffer as required by the NPPF has not been applied

• Spelthorne cannot be relied on at this stage to accommodate any of RBC’s housing

need

• The need for specialist accommodation, particularly for older people, has not been

appropriately calculated and likely underestimates the required need over the plan

period (discussed in detail below)

Supply

3.15 As stated above, the plan period has been reduced to cover 15 years (2015 – 2030), from

20 years (2015 – 2035) as set out in the previous Issues and Options Stage of the Plan.

Despite the reduction in the plan period, at a strategic level, the projected 7,413 dwellings

identified in Table 2 of the PSDLP to be delivered over the revised plan period (2015 –

2030) is inconsistent with the revised OAN set out within the Strategic Housing Market

Assessment (SHMA) Update (January 2018), and housing target identified within the

PSDLP itself, which shows a need of 7,507 dwellings. The housing target of 7,413 results

in a shortfall of 94 dwellings over the Plan period.

3.16 The housing target also includes “housing from suitable SLAA sites including estate

regeneration”, which are listed in Appendix B of the PSDLP. Appendix B sets out a list

of SLAA sites which have not already been granted planning permission or proposed for

allocation, amounting to a total of 452 dwellings that RBC are counting towards the

expected housing delivery. It is noted that 13 of these sites are located within the Green

Belt (equating to 177 dwellings). It is not clear in the PDSLP how the capacity for these

sites has been calculated, nor has any evidence been provided to demonstrate how they

would come forward for housing. Their inclusion within Table 2 of the PSDLP

constitutes, to an extent, a pre-determination of the development control process. On this

basis, we do not consider it appropriate to include these sites in the expected housing

delivery estimates.

3.17 SLR have undertaken a site capacity analysis of the housing site identified in the PSDLP,

and the table E7 in Appendix 02 to these representations demonstrates that the capacity

of several of the identified sites is somewhat lower than asserted by RBC.

3.18 A comprehensive overview of RBC’s housing supply over the plan period in comparison

to Table 2 in the PSDLP is provided below:


10

Table of Supply (Comparable to Table 2 In PSDLP)

Runnymede BC – PSDLP SLR Assessment Difference

Component Dwellings Notes Dwellings Notes

A) Housing Required 2015-2030

7,507 No clarification provided why this does not accord with

SHMA

8,620 Based on SLR review of OAN +1113

B) Homes Completed 2015/16 to 2016/17

565 - 565 - 0

C) C2 Completions (÷3) 2015/16 to 2016/17

-4 - -4 - 0

D) Estimated supply from existing planning permissions (5 net and above)

507 - 507 - 0

E) Windfall estimate for sites 1-4 dwellings

256 SLAA states 298 298 Figure has been swapped with F – in accordance with SLAA

+42

F) Prior Approvals 298 SLAA states 256 256 Figure has been swapped with E – in accordance with SLAA

-42

G) Contribution from C2 older accommodation (÷3)

191 - 191 - 0

G) New Settlement at Longcross GV

1,718 - 1,786 Figure taken from SLR review of Site Capacity Analysis

+68

H) Other strategic allocations 3,534 Figure taken from SLAA which does not accord with RBC Site

Capacity Analysis and gives the higher capacity figures for

all sites

3,382 Figure derived from SLR review of Site Capacity

Analysis & SLAA

-152

I) Traveller accommodation on allocations

35 - 35 - 0

J) Housing from suitable SLAA sites including estate regeneration

452 Appendix B of PSDLP 275 Excluding sites within Green Belt (-177 units)

-177

K) Underdelivery (non-implementation) of 15% for sites non allocations not started (C3 only)

-139 PSDLP figure taken from SLAA -775 15% should be applied to all C3 sites not under

construction, including allocations, given that RBC has a proven non-implementation

record of 22% against non-windfall sites

-636

L) Total B-K 7,413 - 6,516 - -897

TOTAL SHORTFALL (AGAINST OAN OVER THE PLAN PERIOD) – LOWER END – EXCLUDING CHANGES TO ROWS J & K

94 - 1,291 Lower end figure derived from SLR review of OAN &

Site Supply alone

+1,197

TOTAL SHORTFALL (AGAINST OAN OVER THE PLAN PERIOD) – HIGHER END – INCLUSIVE OF CHANGES TO ROWS J & K

94 - 2,104 Higher end figure excludes Green Belt sites (Row J) and

includes a non-implementation % applied to

all sites (Row K)

+2,010

3.19 The table above shows a significant difference between the housing supply that RBC is

contending will be available over the plan period, and SLR calculates that RBC’s have

underestimated their supply by 2,010 dwellings in total.

3.20 It is noted that the Council suggests that any shortfall in housing could be resolved

through the Duty to Co-operate, and intimates that Spelthorne Borough Council (SBC)


11

could assist with any shortfall as their Local Plan comes to fruition. However, given that

no formal agreement is in place, and in fact SBC have not been willing to sign a Statement

of Common Ground regarding the Duty to Cooperate given that they are still compiling

evidence to support their own Local Plan, we must highlight that Runnymede Borough

Council should be seeking to ensure sufficient sites are released/allocated to meet their

full housing target rather than assuming that an adjoining authority could assist in the

future. Further, given RBC’s significant housing need, it is unlikely, even if SBC agree

to meet some of RBC’s shortfall, that all of RBC’s housing need could be met through

the Duty to Cooperate.

Summary of supply

3.21 In summary, the housing supply identified in the PSDLP is insufficient for the following

reasons:

• The housing target set out in Table 2 does not meet the OAN of 7,507 (which

itself is underestimated)

• The capacity of identified sites is over estimated and, in some instances, entirely

inconsistent with either an extant planning permission or one which is currently

being determined

• The sites in Appendix B have been counted towards available supply without any

evidence to demonstrate their capacity or deliverability

• The reduced plan period will jeopardise RBC’s ability to provide housing beyond

the plan

• The 5-year supply does not adequately account for the shortfall in the first two

years of the plan period, nor the required 20% buffer

3.22 In this context, it is clear that additional housing sites need to be identified to meet a

shortfall that we have estimated is 2,104 dwellings over the plan period, and we suggest

that additional provision is encouraged to meet this target and reflect a realistic housing

target which takes into account a 20 percent buffer within the housing land supply to meet

local housing needs. Housing at the Home Farm site can be delivered the immediate-term

and has capacity for circa 400 dwellings and should be seriously considered for inclusion

in the Local Plan given the critical under delivery of housing. In additional, the provision

of specialist older persons’ accommodation operated by Elysian will release underused

family housing back into the market and free up market housing accommodation across

the borough, as well as result in wider social benefits including lowering health care and

social care costs.

Five-year housing need and supply

3.23 Paragraph 47 of the NPPF requires local planning authorities to identify and update

annually a supply of specific deliverable site sufficient to provide five years’ worth of

housing against their housing requirements with an additional 5% buffer to ensure choice

and competition in the market for land.


12

3.24 The PSDLP asserts that “the annual supply over the next five years will ensure that the

shortfall in housing provision during the first two years of the Plan period is made up

and also incorporates a buffer of 9% to allow choice in the market”. It states that a total

of 3,212 dwellings are expected to come forward as part of the rolling five-year housing

land supply between 2017 – 2022.

3.25 In January 2018, during the consultation period for the PSDLP, RBC published a paper

entitled “Five year housing land supply. Current position” (the ‘Current Position paper’),

which states that the “trajectory that supports the draft Local Plan” suggests that the

Council has a five-year housing land supply of 3,407 dwellings. It is not clear where the

3,407 figure is derived by comparison to the 3,212 figure set out in paragraph 5.378 of

the PSDLP.

3.26 However, when the shortfall of 468 dwellings from the first two years of the plan period

is added to the five-year need (which RBC are calculating as 2,470, based on the Local

Plan target of 494dpa over five years), the need increases to 2,938dpa. We would note

that the stated OAN, however, is 7,507 dwellings over the plan period, not the 7,413

“Local Plan target” RBC assert, so the baseline five-year need should be 2,502, which

would mean an actual five-year need of 2,970 when the previous two-year shortfall is

applied.

3.27 Further, RBC recognise in the Current Position paper that it is a persistent under deliverer

of housing, and so the 20% buffer as required by paragraph 47 of the NPPF should apply,

which results in a 5-year need of 3,564 dwellings. This calculation is summarised in the

following table:

RBC 5-year housing need

OAN 2-year shortfall 20% buffer Total

7,507 (plan period)

2,502 (5-year)

+ 468

x 1.2

3,564

3.28 The Council recognises that it is some way short of being able to demonstrate a five-year

housing land supply, which is apparent from the calculations above. Now is the time to

remedy that failure through the plan process and identification of additional housing sites.

Delivery of Specialist Housing for Older People

3.29 As outlined within the SHMA 2018 Update, circa 515 specialist housing units for older

people are required over the plan period to meet the identified need. This figure represents

over a doubling in the need for specialist housing units in 2015 (247 units). The 2018

figure is calculated based on information from the Housing LIN, in association with the

Elderly Accommodation Council, which indicates that 170 units of specialised

accommodation (other than registered care home places) are required per thousand people


13

aged over 75 years. Paragraph 7.14 of the SHMA says that “in reality, most additional

specialist housing can be expected to be within the extra-care category” which is a type

of provision more closely aligned with specialist C2 accommodation. Table 76 of the

SHMA shows a per annum need of 13 bed spaces for C2 registered care accommodation

for the period 2016-2030, this only covers a 14-year plan period amounting to a total of

182 spaces.

3.30 Table 77 of the SHMA shows that there is projected to be a significant increase in the

number of people living in Runnymede with dementia (up 43%) and a 37% increase in

the number of people with mobility problems in the period to 2030.

3.31 The SLAA identifies nine sites expected to come forward before 2022 which have a

collective capacity for 460 bed spaces. However, not all of these sites are allocated for

specialist older persons’ accommodation in the PSDLP, so cannot reasonably be relied

on to deliver the necessary accommodation. In addition, the necessary element of

dementia and mobility care is not specified on any site allocation within PSDLP. In this

respect, the projected delivery of specialist accommodation for older people is not

adequate to meet the borough’s needs.

3.32 This position is further exacerbated by the St Peter’s Hospital, Chertsey site (PSLP

SL13/SLAA site 231) which is currently identified within the PSDLP to provide a 70 bed

C2 unit as part of its wider redevelopment. However, from reviewing the current planning

application at the site (application ref. RU.17/1815) it is apparent that the 70 bed C2 unit

will not be brought forward, whilst the proposals will also result in a net loss of 13,217m2

of existing C2 floorspace.

3.33 Section 6 of the PSDLP addresses the need to support local people, and includes a

discussion of Runnymede’s aging population and the need to provide specialist

accommodation for older people. Similarly, the need to provide this type of

accommodation is assessed in the SHMA, which projects the per annum need for specialist

housing for older people during the plan period to be 37 units per annum.

3.34 Contact Consulting have undertaken a preliminary review of the current provision and

future need for specialised accommodation in RBC (Appendix 04), and consider that

within the current stock of specialised accommodation in RBC there is a deficit in

provision for older home owners who wish to move from their existing home whilst

retaining their tenure of choice.

3.35 Contact further set out that in relation to the future need for accommodation with care, the

SHMA uses an escalator calculation based on current provision which an instrument for

analysing future need which may be met by an increase in Registered Care beds or Extra

Care places. However, the equivalence is more complicated than a simple transfer of

numbers from one style of provision to the other. We therefore consider that the

calculation within the SHMA is not robust enough to adequately estimate the need.

3.36 Taking account of the existing specialised housing stock and, having noted the relatively

low levels of provision of Registered Care beds in the area, Contact conclude that current


14

supply is below what is likely to be required by the existing population of older people

resident within Runnymede. The evidence presented in the Strategic Housing Market

Assessment and reflected in the brief treatment of these matters in the Local Plan, are

likely to lead to an underestimate of need and provision that does not reflect the diversity

of need, aspiration and circumstance among the older population of Runnymede.

Summary

3.37 In light of the above, it is our view that the proposed number of new dwellings and site

allocations currently identified in the plan do not adequately address the borough’s

housing needs, both for housing generally and for specialist older persons’

accommodation with an element of care. Of note, the inconsistencies between timeframes

in the SHMA (2016 – 2030) and PSDLP (2015 – 2030) means that an additional year of

supply should be added in order to adequately calculate the total OAN over the plan

period, which in additional to the previous shortfall of 472 dwellings over the 2015 –

2017 period, would equate to 592 additional dwellings over the lifetime of the plan (2015

– 2030).

3.38 We consider that the proposed spatial development strategy is contradictory to Paragraph

14 of the NPPF which states that Local Plans should meet Objectively Assessed Needs

(OAN), in addition to Paragraph 50 which outlines that local planning authority should

plan for a mix of housing based on current and future demographic trends as well as the

needs of different groups of people. As such, we would encourage the Council to review

its available land supply in order to identify further sites that could accommodate both

residential and specialist elderly care accommodation. This need is compounded by the

projected increase of 49% of residents aged 65+ years over the next 20 years.

Policy SD3 (Site Allocations)

3.39 Policy SD3 of the Pre-Submission Draft Local Plan (PSDLP) details a summary list of

23 sites to be allocated for housing and employment related development within the

authoritative bounds of Runnymede Borough Council. Further detailed information

relating to the requirements for each site are outlined within the site-specific policies

provided within the latter sections of the Draft Plan (Policies SD10, SL2-SL18 and IE7-

IE10).

3.40 These site-specific policies are reviewed in more detail within these representations and

within Appendix 03. With regard to the proposed site allocations, it should be noted that

Longcross Garden Village is a strategic allocation for a new garden village settlement and

is therefore dealt with within the ‘Sustainable Development’ policies of the PSDLP

(Policy SD10); Byfleet Road, New Haw is an employment allocation and does not seek

to make provision for any housing; and Addlestone East, Addlestone West, Egham

Gateway East and Egham Gateway West are all employment allocations within the urban

areas of Addlestone and Egham but do seek to include some provision of housing by way

of mixed use redevelopment.


15

3.41 Whilst we do not raise an objection in principle to the sites identified for allocation within

Policy SD3, it is contended that the capacity of particular sites has been over estimated

and that insufficient sites are proposed for allocation to meet either the OAN or the

housing target set within the PSDLP.

Site Capacity

3.42 From reviewing the Site Capacity Analysis Review, it is contended that the sites currently

identified for allocation will deliver in the region of 4,499 dwellings, 153 C2 bed spaces

and 35 Gypsy and Traveller pitches. This is some 84 dwellings and 70 C2 bed spaces

lower than that proposed within the PSDLP. Furthermore, the proposals at the St Peter’s

Hospital site will also result in a net loss of 13,217m2 of existing C2 floorspace.

3.43 A technical review of the various evidence base documents which support the draft local

plan and detailed comments regarding the various site allocations are contained within

Appendix 02.

3.44 Given this likely shortfall in supply, and the increase in the OAN as outlined within

section 4.11 above, it is duly contended that additional sites should be allocated to meet

the housing need within RBC.

Home Farm, Virginia Water

3.45 From undertaking a review of the Site Selection Methodology and Assessment, as well

as the Green Belt Reviews Part 1 and 2, it is contended that the Home Farm Virginia

Water site should be allocated for development to assist the Council in meeting the

identified OAN. It is also contended that the Home Farm site is a more suitable Green

Belt release than a number of other sites which are already proposed for allocation within

the PSDLP. SLR’s review of the Green Belt Review(s) methodology and a Comparative

Landscape Capacity and Green Belt Appraisal is contained within Appendix 02.

3.46 In accordance with the NPPF, the ‘Housing and Economic Land Availability Assessment’

Planning Practice Guidance (March 2014) is clear that local planning authorities should,

through their Local Plans, meet objectively assessed needs “unless any adverse impacts

of doing so would significantly and demonstrably outweigh the benefits, when assessed

against the policies in the Framework taken as a whole, or specific policies in the

Framework indicate development should be restricted” (Paragraph 044). Such policies

include those relating to land designated as Green Belt. The NPPF also makes it clear

that, once established, Green Belt boundaries should only be altered in exceptional

circumstances, through the preparation or review of the Local Plan. Indeed, in

undertaking a Green Belt Review, the NPPF clearly details that authorities should release

sufficient land to satisfy themselves that Green Belt boundaries will not need to be altered

at the end of the development plan period.

3.47 As outlined above, the PSDLP details that the proposed site allocations will not achieve

the currently identified housing target. Furthermore, paragraph 5.10 of the PSDLP

identifies that there is a “lack of suitable, available and achievable sites in the existing


16

urban area” and that “any unmet housing need from Runnymede is unlikely to be met in

neighbouring or nearby Local Authority areas”. Given that the Duty to Cooperate

process has not yielded a formal agreement for any housing need to be accommodated

within an adjoining authority, it is contended that the Green Belt Review and PSDLP has

failed to release sufficient land for development in seeking to meet the identified OAN.

Policy SL1 (Health and Wellbeing)

3.48 We agree with the broad principles of the Policy to encourage health and wellbeing of

RBC’s residents, including new provision of accessible communal facilities in major

developments for all ages.

3.49 We note that Paragraph 6.5 of the Local Plan recognises the need to deliver activities for

older residents (65+ years) that promote and maximise well-being. We support the

findings from the Active People’s Survey by Sports England and the Council’s aspirations

to develop initiatives which engage older people, and also note, as set out above, that

there is a significant projected increase in health issues facing Runnymede over the plan

period, particularly those facing elderly residents, namely dementia and mobility

problems. We encourage the council to reconsider the wording of Policy SL1 to reflect

the valuable role C2 schemes can play in delivering the initiatives and integrating older

persons’ well-being and care in particular into living arrangements.

Policy SL2 – SL18 (Housing Site Allocations)

3.50 Whilst we do not raise an objection in principle to the sites identified for allocation within

Housing Site Allocation Policies SL2-SL18, it is contended that the capacity of particular

sites has been over estimated and that insufficient sites are proposed for allocation to meet

either the OAN or the housing target set within the PSDLP.

3.51 As identified within Appendix 03 of these representations, a number of these sites have

either achieved or are in the process of gaining planning permission. From undertaking a

review of the Site Capacity Analysis, it is contended that the proposed site allocations

will accommodate up to 4,499 residential (Class C3) units, 153 Registered Care bed

spaces (Class C2), 35 Gypsy and Traveller pitches and 77 student bed spaces. This is 84

residential (Class C3) and 70 Registered Care bed spaces (Class C2) lower than the site

capacities identified within the PSDLP.

3.52 A reduction in the capacity of the proposed site allocations would further increase the

shortfall against the housing target contained within the PSDLP.

Policy SL19 (Housing Mix and Requirements)

3.53 The proposed housing mix sets refers to the SHMA as the guiding document for setting

the baseline mix of dwellings. Based on Table 60 of the SHMA 2018, the following

housing mix is proposed for new residential developments:


17

Size

Additional

households 2016 –

2030

% of Total Mix

1 bedroom 313 7%

2 bedrooms 1,174 27%

3 bedrooms 1,776 41%

4+ bedrooms 1,075 25%

Total 4,339 100%

3.54 The housing mix shown in policy SL19 will contribute towards meeting the overall

housing need across the borough, however, the mix as shown is prescriptive and does not

account for potential differences in the housing market and demographics in different

areas. We support the recognition that evidence may be provided to demonstrate where

this mix is not feasible or viable, but the wording of Policy SL19 should allow flexibility

for new residential development, or set out an acceptable range, to reflect differing

markets across the borough. This will allow development to make a meaningful

contribution to the housing needs of Runnymede.

Policy SL20 (Affordable Housing) and Policy SL23 (Accommodating Older Persons

and Students)

3.55 Paragraph 5.26 of the updated SHMA (2018) acknowledges that the affordability of

housing in Runnymede has worsened more than other areas. The proposed policy

demonstrates a pragmatic approach and reflects the need to balance affordable housing

provision against other objectives of the Plan. In terms of affordable housing sought from

C3 residential development we support the Council’s viability-based approach, but

consider that this policy should clearly exclude C2 development from this requirement.

3.56 Similarly, Policy SL23 (Accommodating Older Persons and Students) should exclude

proposals for specialist older people’s accommodation from affordable housing

requirements.

3.57 In our experience, specialist older accommodation, including C2 accommodation referred

to in Paragraph 6.57, is not justified for an affordable housing contribution, which is

significantly outweighed by the baseline costs associated with delivering extra-care

accommodation, including extensive medical services. We therefore consider that the

distinction between C2 and C3 units be further considered and clarified in the Local Plan

to allow flexibility beyond the “front door test”, discussed below.

3.58 Paragraph 6.57 of the draft Local Plan, states “Care developments containing units with

their own front door will be considered as dwellings in accordance with the DCLG

definition and classified as C3 land use and will be subject to Policy SL20.”

3.59 However, as detailed in the SHMA 2018, the majority of specialist housing for older

people is expected to be within the extra-care category. Extra-care is defined by the

Housing Learning and Information Network (LIN) (referred to in the SHMA) as:


18

“housing with care primarily for older people where occupants have specific tenure rights

to occupy self-contained dwellings and where they have agreements that cover the

provision of care, support, domestic, social, community or other services.”

3.60 The provision of such services is closely aligned with C2 use, and this principle has been

upheld in recent appeal decisions, including Pegasus Life vs. East Devon District Council

(Case Ref: APP/U1105/W/17/3177340), where PINS concluded that self-contained extra

care (C2 Use Class) accommodation provided more than traditional dwelling houses (C3

Use Class), within which, independent living formed part of a wider range of communal

facilities linked to an expected way of life. To this end, PINS concluded the following:

“There is a clear functional relationship between the residential units and the wider

assisted living complex and facilities in this case, which are interdependent on one

another…All of this leads me to conclude that the proposed development is properly to

be considered a C2 use.”

3.61 The wider text included within Policy SL23 (Accommodating Older Persons and

Students) sets out that specialist accommodation for older people will be supported where

it:

• meets local commissioning priorities of the NHS and its partner authorities or a

demonstrable established local community need; and

• is readily accessible to public transport, shops, local services, community facilities and

social networks for residents, carers and their visitors.

3.62 We would welcome clarity as to the extent of information the Council would require to

demonstrate an “established local community need”. Support for specialist housing

should not be directly tied to the NHS commissioning priorities and, in light of the

significant need identified in the SHMA for both C2 and C3 accommodation across the

borough, Policy SL23 should provide support for developments which seek to provide

specialist older persons’ accommodation and which will in turn free up housing elsewhere

in the borough.

Policy SL26 (New Open Space)

3.63 We welcome the flexibility set out within this policy to negotiate open space provision on

a site-by-site basis, however, as the ability to consider the provision of open space on a

site-by-site basis is premised on the most up to date Open Space Study, we would

encourage the council to provide assurance that the Study will be regularly updated,

otherwise to allow individual applications to demonstrate that an appropriate amount of

open space is being provided with regard to the wider area and site-specific circumstances.


19

Policy EE1 (Townscape and Landscape Quality)

3.64 This policy is informed by Runnymede’s Urban Character Appraisal, including the

Virginia Water Urban Area Characterisation. This study was undertaken in 2009 to

inform the Council’s former LDF Core Strategy and responding to the UK Government’s

regional and national housing policy requiring Local Planning Authorities to formulate

policies which provided guidance on the design of urban developments. In general, the

characterisation study is now out of date, with a number of developments superseding the

character study for the area. We note that much of the study has been conducted in areas

accessible by the public, which has inhibited analysis of areas with older architecture in

well-wooded ground of behind boundaries. We would encourage the Council to apply the

findings of this study flexibly and consider post-2009 development when considering

future development proposals, and suggest that the policy wording incorporate an ability

for development proposals to be accompanied by their own character appraisals to

demonstrate the adequacy of their designs.

APPENDIX 01

PROMOTION SITE

HOME FARM

Introduction

These representations are made on behalf of Elysian Residences who have acquired a parcel of

land known as Home Farm on the eastern side of Stroude Road (“the site”), which comprises

a landholding of approximately 40 acres to the north of the St Ann’s Park development off

Sandy Lane, within 400m of the town centre and is surrounded by development on three sides.

The northern part of the site is subject to an extant planning consent (RU.15/1899), and RBC’s

planning committee has recently resolved to grant application ref. RU17/1728, which is an

application for the same proposals previously granted, but with a revised access arrangement.

Previous representations have been made on behalf of Elysian Residences on Runnymede’s

Additional Sites and Options consultation, which took place in the summer of 2017, and

presented the case for Home Farm’s release from the Green Belt and allocation for housing in

the emerging Local Plan.

The previous representations assessed the site in terms of its performance against the NPPF’s

Green Belt functions and in the context of RBC’s Green Belt Review (2014) and Green Belt

Review 2 (2017), as well as the staged selection methodology used by RBC to inform the site

selection process. We do not intend to replicate the entirety of those representations here, but

have reiterated the key points to demonstrate why the Home Farm site should be released from

the Green Belt and allocated for housing development.

The purpose of this document is to provide details of the site to demonstrate that it is a) suitable

for release from the Green Belt, and b) deliverable as a housing site. Elysian has acquired the

site with a view to providing a high-quality housing development that will provide both

specialist older persons’ accommodation as well as market housing, both of which will

significantly contribute to RBC’s housing supply without negatively impacting on designated

areas.

The remainder of this document is structured as follows:

1. Promotion site details

2. Proposed masterplan

3. Background to Elysian and aspirations for the site

4. Assessment of the site in context of Green Belt reviews and performance against NPPF

functions

5. Assessment of the site against RBC’s staged site selection methodology

6. Physical considerations and emerging policy

7. Summary

1. Promotion site details

Site location

1.1 The Home Farm site, which is approximately 15.82ha (40 acres) in area, is located on

the north-eastern edge of Virginia Water. The site is located within 400m of the

designated town centre and is bound by development along its northern, southern and

western sides. Site access is currently taken from Stroude Road and is shared with

properties at 507 and 509 Stroude Road. The extent of the promotion site is depicted

within the Site Location Plan attached to this appendix.

1.2 The site is located to the east of Stroude Road, from which access is currently gained,

and St Ann’s Park development located off Sandy Lane. The site is bound to the south

by a park and leisure complex associated with St Ann’s Park and residential properties

located along Sandhills Lane. Beyond Sandhills Lane is St Annes Heath Junior School

with associated sports pitches, residential properties, the Waterloo to Reading railway

line and the M3.

1.3 Further residential properties and Hillcrest Stables bound the site to the north, beyond

which is an area of allotments and Oak Tree Nursery. Finally, the site is bound to the

east by Ancient Woodland, some of which is located within the bounds of the promotion

site, and further residential properties. Beyond these residential properties to the east

are Longside Lake and the M25.

Site description

1.4 The promotion site itself constitutes a mixture of both previously developed land and

greenfield land, historically within an agricultural use. However, the agricultural

capacity of the site is redundant and it has been severely neglected for many years.

1.5 The area within the north of the site was previously utilised as a pig farm and there are

a range of vacant and dilapidated buildings totalling a footprint of approximately 2,306

sq m. There are three existing houses within this area of the site:

• Jasmine Cottage - a detached single storey 1960s dwelling with associated garages

and outbuildings. This property has a clearly defined residential curtilage and is

located in the very north of the promotion site, approximately 30m from the farm

gate entrance;

• 1 Home Farm Cottage - a semi-detached, 2-storey cottage constructed at the turn

of the century, with associated outbuildings. This property does not have a clearly

defined residential curtilage.

• 2 Home Farm Cottage - a semi-detached, 2-storey cottage constructed at the turn

of the century, with associated garages and outbuildings. This property does not

have a clearly defined residential curtilage.

1.6 In addition to the above, there are a number of significant outbuildings which are largely

sited around the original farm cottages.

1.7 Within the south of the site, there are remnants of a number buildings associated with

the site’s historic agricultural use. Reasonably substantial stables are still present close

to the southern site boundary, whilst there is a range of hard standing and derelict

structures presumed to have been former livestock pens and storage buildings. The

majority of these former agricultural buildings are now in a state of disrepair and are

overrun with undergrowth.

1.8 The site is bound along its northern, eastern and southern edges by mature trees and

hedgerow which have been poorly managed for a number of years. This poor

management, along with the previous ad hoc agricultural activity, has resulted in some

damage to the adjoining woodland, part of which is also designated as Ancient

Woodland. As such these areas of the site would benefit from some careful

arboricultural management and improvements.

Existing designations

1.9 The site is currently designated as lying within the Green Belt, whilst an Area of

Landscape Importance lies to the west of the site. Areas of Ancient Woodland are

located within the north eastern and eastern confines of the site, forming a landscape

buffer to these edges of the site. The site is primarily located within Flood Zone 1 with

a low risk of flooding, with small areas within the south-eastern confines of the site

lying within Flood Zones 2 and 3.

1.10 The site lies within a Mineral Safeguarding Area and is also within the 5km of the

Thames Basin Heath Special Protection Area (‘TBHSPA’). There are Sites of Nature

Conservation Importance within 600m of the site (Trumps Mill SNCI, Riverside

Walk/The Bourne and The Dell), and sites of National/International Importance nearby,

including Longside Lake South West Waterbodies SPA.

1.11 Finally, the site is not identified as the best or most versatile agricultural land in the

Agricultural Land Classification produced by Natural England.

2. Proposed masterplan

2.1. The principle of residential development at the Home Farm site has been established

as acceptable through the permission granted in 2016, and recent resolution to grant

for an amended scheme, for the demolition of the site’s existing outbuildings and

construction of 10 residential units. Following these approvals, the site’s owners have

reviewed its development potential and by incorporating an additional parcel of

adjacent land within the same property ownership (and so deliverable) have developed

proposals to provide a significant amount a residential accommodation that will

contribute to Runnymede’s housing delivery targets.

2.2. Architects have been instructed to consider a masterplan for the site that preserves as

much land within the Green Belt as possible whilst maximising the opportunity to

development the space within the centre site, mitigating any impact on areas of flood

risk, minerals, or ancient woodland, and preserving a visual landscape buffer. A

masterplan study for the site demonstrates that the Home Farm site can deliver circa

400 residential units. The proposed density would be around 50 dwellings per hectare,

which represents a sensible density for a site of this size. Indeed, paragraph 124 of the

2015 SLAA indicates that any future development sites should have an absolute

minimum density of 30dph.

2.3. The new masterplan would be brought forward by Elysian Residences to develop and

operate specialist accommodation for the elderly, providing accommodation

specifically designed for older people looking to downsize and who want a solution

which offers them fully integrated care and the benefits of living in a community with

active management. Elysian’s model is to provide apartments for the over-65s who

suffer from chronic conditions, designed so that they would benefit from living in a

supportive environment.

2.4. This model has unique and positive social impact as a result of integrated healthcare

and helping to release under-occupied family houses with the local area, and gives

local elderly a housing option to keep them local. It allows older people looking to

downsize to vacate properties that would be more suitable as family residences,

thereby creating a more balanced housing market and releasing larger housing units

back into the market. At the current rate of development, and given the locational

specifics of Virginia Water, Elysian estimate that each specialist accommodation unit

brought forward would release one standard unit back into the market.

2.5. The proposed masterplan would deliver significant benefits to both the site itself and

wider area, as set out below:

• Significant provision of housing

• High quality development and improvement on existing dilapidated built

structures

• Improved access arrangements

• Improvements to existing Green Belt land and Ancient Woodland

• Potential to provide public open space and relieve pressure on the Thames Heath

SPA

2. Elysian

2.6. Elysian Residences is a UK company whose sole business is the development and

operation of assisted / independent housing with integrated care. The company aims to

provide older people with an aspirational and fulfilling lifestyle, providing a supportive

dynamic environment which minimises the impact of limitations as residents grow

older.

2.7. Elysian Residences’ developments are specifically designed for older people looking

to downsize. Their design is of a high quality and aspirational so residents want to

move into them, with over 20 design features which enable each residential unit to

adapt over time to meet residents’ limitations and healthcare needs, with integrated

nursing care at every community. The Elysian Residences business model does not

require any public subsidy.

2.8. Communal social and care facilities are provided to keep residents physically,

mentally, and socially stimulated and promote a longer period of health. On-site care

provided by Elysian means that residents would not be required to move again due to

deteriorating health. A key driving principle of the model, is that residents cannot avail

themselves of the full active supported lifestyle if they stay in their apartments; they

need to use the full facilities in order to get the benefits, including the extensive

healthcare provision (through to end-of-life care), socialisation, staying physically,

intellectually, and emotionally as active as possible, to stave off the increasing

limitations of ageing. This structure to senior living is recognised to have material

health benefits (see Successful Aging by the MacArthur Foundation 1998). As an

example, full service, 3-meal per day, 7 days a week restaurant service will ensure that

residents get proper nutrition and socialisation – residents will have a minimum usage

that they will pay for, to ensure that the extra communal facilities and onsite health

care are used regularly, to the betterment of the health and wellness of all the residents.

2.9. The increased operating set-up helps to ensure that elderly residents get the most out

of the entire community facilities and services, which have been shown in other

countries to lead to greater longevity, and a decline in the usage of public health

services by approximately 30% as a result of living in actively managed communities

with integrated healthcare. In terms of operational expertise, the project will be

operated jointly by Elysian and One Eighty Leisurecare, a U.S. company with

approximately 40 years of expertise in operating elderly housing communities with

integrated healthcare and specialist elderly facilities.

2.10. Elysian Residences’ developments provide a solution to two of the largest short-term

and long-term problems facing the UK, namely:

Housing Crisis

• Lack of family housing which impacts upon economic growth, as both workers

and companies are pushed outward due to a lack of affordable housing options;

• Over the past 10 years, the UK has delivered just over a third of the housing that

it needs to keep up with population growth. A very small percentage of this

housing would be suitable for older people looking to downsize;

• There is a need to release under-utilised owner-occupied homes which could

reduce the cost of family housing;

• If just 5% of the older population living in under-utilised, owner-occupied housing

downsized, it would equate to 10 years of additional supply of family homes, at

the current rate of development; and

• Whether the elderly downsize at 70 or 90 years of age can have a significant

impact on family housing supply.

The financial impact of an ageing population

• The over 65s in the UK currently make up 36% of healthcare expenditure and 66%

of hospital bed usage;

• The proportion of older people in the UK is growing – in 2016, there were an

estimated 308 people of a pensionable age for every 1,000 people of a working

age. By 2037, this is projected to increase to 365 people. The lack of suitable

private housing for older people with integrated care will require significant

increases in the cost of health and social care budgets; and

• Supportive housing with integrated care has been shown in other countries to

result in reductions in healthcare costs of 30-40% as a result of integrating

healthcare services into private housing.

2.11. From the 2011 Census, Runnymede is understood to have a resident population of

80,510 of which 16.8% (approximately 13,526) are 64 years old and above.

Furthermore, 23,775 households within the Runnymede Borough Council area are

currently under occupied (i.e. the number of bedrooms exceeds the number of

residents), this equates to 72.7% of households. Whilst relatively comparable to the

percentage of under occupancy within England (72.6%), this highlights the current

issues faced by the UK housing market.

2.12. Contact Consulting has been instructed to review the supply and demand of elderly

extra care provision in Runnymede and have found that provision of Extra Care is

extremely limited and, when viewed in the context of lower than average provision of

Registered Care beds, especially those offering Personal Care, it is clear that current

provision is not matched to need in the existing population of older people, let alone

adequate to meet rising need as the number of older people in Runnymede increases.

2.13. It is on this basis that Elysian Residences wish to promote the Home Farm, Virginia

Water site for development to meet both the Housing Needs of Runnymede Borough

Council and the demographics of its population. Further information regarding the

development aspirations for the Home Farm site is contained within Section 3 of this

document.

2.14. Elysian Residences’ development aspirations for the Home Farm site include a

significant provision of elderly extra care, as follows:

• Significant communal areas and facilities carefully designed to keep the over 65s

healthy, active and living as independently as possible;

• A medical centre and dementia care facility staffed 24-hours a day, which adapts

to residents’ needs as they age and designed to include resident-facing areas,

healthcare spaces, and back-of-house operational functions;

• The design of the facilities is tailored so that residents can live in a non-

institutional environment, but with a 24-hour nursing care on-site, providing both

healthcare and social care;

• Various services will be available, including the following activities: fitness

classes, physical therapy, on-site restaurant (with nutritionists), cognitive

computer exercises (to ward off dementia), arts and crafts and other social

activities;

• A doctor and specialists will attend on-site regularly during business hours;

• Privately provided preventative care will reduce pressure on the NHS and local

council; and

• On-site management and healthcare professionals are employment generating,

creating local career opportunities.

2.15. It is also envisaged that the site could accommodate a large proportion of market

housing as well, likely in the southern portion, which would be complemented with

open space, child play space, and access to improved Green Belt areas.

3. Green Belt

3.1. To support these representations, and to demonstrate the merits of removing the site

from the Green Belt, SLR has reviewed the methodology uses for both the Green Belt

Review (2014) and Green Belt 2 Review (2017). Detailed comments resulting from

this review accompany the PSDLP representations at Appendix 02, but the main

findings are summarised as follows:

• The parcels of land assessed in Green Belt Review (2014) were too large to allow

useful conclusions to be drawn.

• The methodology does not take account of landscape character. • The definitions of Purpose 1 and Purpose 3 of the Green Belt are flawed.

• There is an inconsistency in the list of settlements used in the assessment of

Purpose 1 and Purpose 2.

• There is no clear explanation of why some sub-areas have not been included

within the summary of recommended areas provided in Green Belt Review Part 2

(2017).

3.2. For the purposes of the Green Belt Review (2014) the Home Farm site was included in General Area 9 which is a large area of 344 hectares that extends from the eastern

edge of Virginia Water to the M25, and from the B389 in the south to the southern

edge of Egham in the north. When assessed against the NPPF Green Belt purposes

this sub area was recommended for continued retention within the Green Belt in its

entirety. General Area 9’s performance against these criteria is set out below:

Purpose Criterion Score Assessment Criteria Commentary

1 Protects open land contiguous to

or within close proximity to a

large built up area.

3 Connected to a large built-up area and

protects open land from urban sprawl.

1 Prevents sprawl of a large builtup

area where development would

not otherwise be restricted by a

durable boundary.

1 Provides an additional barrier for a

large built-up area, which is bordered

by prominent, permanent and

consistent boundary features.

2 Prevents development that would

result in a merging of or

significant erosion of gap

between neighbouring towns and

villages or between villages

including ribbon development

along transport corridors that link

settlements.

1 Less essential gap, which is of

sufficient scale and character that

development is unlikely to cause

merging between settlements.

3 Protects the openness of the

countryside and is least covered

by development.

3 Contains between 10% and 25% built

form and/ or possesses a largely rural

open character.

3.3. The need to assess smaller land parcels was addressed in Runnymede’s Green Belt Review 2 in 2017. This review considered sites from the SLAA to take forward for

potential allocation. Home Farm was assessed as sub-area 65, a parcel of 21.9 ha, and

received the following scores:

Purpose Criterion Score Assessment Criteria Commentary

1

Prevents the outward, irregular

spread of a large built up area

into open land, and serves as a

barrier at the edge of a large

built-up area in the absence of

another durable boundary.

0

The sub-area is not physically or

perceptually connected to a distinct

large built-up area.

2

To prevent neighbouring towns

from

merging

3

The sub-area forms part of the wider

gap between Virginia Water and

Thorpe, maintaining the overall

openness and scale of the gap.

Although the role of the sub-area is

reduced somewhat in visual terms by

a heavily wooded area in the east, the

gap has been comprised physically

and perceptually by existing ribbon

development along Sandhills Lane.

3

Protects the openness of the

countryside and is least covered

by development.

3

5% of the sub-area is covered in built-

form. The sub-area is largely rural in

character. The site feels quite

contained overall with not much of a

view into the wider countryside

beyond the tree lines to the east.

Scattered farm buildings throughout

and noise from nearby roads detract

from the sense of rurality.

3.4. For purpose 1 above, Virginia Water was not considered as a large, built-up area so Home Farm was not assessed as being a barrier to urban sprawl. The sub-area was

also recognised as part of a larger gap between Virginia Water and Thorpe where

further development could be acceptable so long as the settlements are restricted from

merging. Overall, the sub-area was considered to be moderately performing and the

review concluded that the loss of this sub-area would harm the wider strategic Green

Belt by promoting encroachment into an open, sensitive area of countryside.

3.5. SLR have undertaken a Green Belt review in relation to the Home Farm site, which is detailed in Appendix 02 of the PSDLP representations. The conclusions of this review

are summarised as follows:

NPPF Green

Belt Purpose

Assessment Conclusion

To check the

unrestricted

sprawl of large

built-up areas

The site is bounded by prominent residential

development along Stroude Road and further residential

development along Sandhills Lane. Further built form is

present along Hurst Lane, although this is not visible

within the site. Approximately 3,306 sq m of the site is

covered by existing buildings and in addition, consent

has been granted for 10 dwellings with associated

garaging following demolition of the three existing

dwellings. Existing and consented buildings are largely

contained within the western edge of the site but the

eastern edge of the site is largely open and bounded by

well-established woodland. The eastern edge of the site

is therefore considered to more effectively perform the

function of checking unrestricted sprawl; the presence

of both existing and consented built form and an

elevated, prominent settlement edge to the west have

already created a perception of urban sprawl in this

location and consequently undermine its ability to

perform this Green Belt function.

The site partially

performs this Green

Belt function,

particularly along its

eastern edge.

To prevent

neighbouring

towns merging

into one another

The site forms part of the wider gap between Virginia

Water and Thorpe. The M25 and Longside Lake site are

present within this gap creating clear physical

separation between the two settlements.

The site is also located between Virginia Water and the

smaller settlements of Thorpe Green, St Ann’s Heath

and Stroude, located to the east of the site, and

connected to Virginia Water by existing

residential development along Sandhills Lane. Well-

established woodland belts along the northern and

eastern boundaries of the site, restrict inter and intra-

visibility with Thorpe and associated smaller

settlements to the east, preventing any perception

of coalescence with these settlements. The eastern edge

of the site provides a defensible, open, buffer against

the merging of settlements. The eastern edge of the site

is therefore considered to more effectively perform the

function of preventing neighbouring towns from

merging.

The site partially

performs this Green

Belt function

particularly along its

eastern edge.

To assist in

safeguarding the

countryside from

encroachment

As has been noted, the site is strongly influenced

by existing prominent, elevated, residential

development along Stroude Road and further

residential development along Sandhills Lane, as

well as, noise and movement associated with traffic

passing along these roads. There are also buildings

within the site, as well as permission for ten dwellings

with associated garaging following demolition of the

three existing dwellings. There is therefore already a

strong sense of visual encroachment over the majority

of this site. The eastern edge of the site comprises some

open grassland and woodland, and therefore more

strongly performs the Green Belt function of

safeguarding the countryside from encroachment.

The site therefore

partially performs

this Green Belt

function, particularly

along its eastern

edge, as there is

already a strong sense

of visual

encroachment along

the western edge of

the site which is

strongly influenced

by existing,

prominent and

elevated development

which compromises

its ability to perform

the functions of the

Green Belt.

To preserve the

setting and

special character

of historic towns

There is no intervisibility between the site and a historic

town. Whilst it is noted that there is a listed building in

close proximity to the western boundary of the site,

there is no intervisibility between the site and this

building or any other areas or buildings designated for

historic reasons.

The site does not

perform the Green

Belt function of

preserving the setting

and special character

of historic towns.

3.6. Overall, the Home Farm site only partially performs three of the four NPPF Green Belt

functions assessed, particularly in the eastern part of the site. Local policy functions

have also been considered and it has been assessed that the site partially performs one

of the local functions of the Green Belt (to retain attractive landscapes, and enhance

landscapes, near to where people live).

4. Staged site selection methodology

4.1. RBC have produced a Site Selection Methodology and Assessment (SSMA), which

assesses the sites considered within the SLAA (January 2018) as to whether they are

deliverable and suitable. The assessment of suitability is intended to take into account

absolute constraints which cannot be overcome, even if mitigation is proposed, non-

absolute constraints which could be overcome.

4.2. A full review of the SSMA, prepared by SLR, is provided alongside the PSDLP

representations at Section 10 of Appendix 02.

4.3. The SSMA sets out an 8-stage process with sites being ‘dropped out’ at each stage if

the Council’s assessment concluded it did not pass the criteria detailed within that

particular stage. With regard to the Home Farm Site (SLAA site no. 212), the site was

considered to pass the criteria contained within Stages 1-4.

4.4. The Stage 5 assessment relates to the ‘assessment of sites within the Green Belt

Review’. The Home Farm site was discounted at this stage because it “is considered

to be Medium-high performing but moderate performance against Green Belt purposes

and is considered to play an important role in preventing encroachment into a sensitive

area of countryside. Greater weight attached to protection of the Green Belt.”

4.5. In contrast to the above rationale, SLR has undertaken an independent review of the

Green Belt Review(s) and assessment of the Home Farm site against the 3 Green Belt

purposes, and concludes that the site is considered to only partially perform these

functions due to the strong influence of urban development to the west and south and

the presence of existing built form within its boundary as well as consent for further

development. It is noted that the eastern edge is more open and densely wooded and

as such development would be restricted to the western part of the parcel. It is noted

that SLAA site 34 was split on the basis that the southern edge was influenced by urban

form and dense woodland was considered an attribute that would restrict outward

growth for SLAA site 60. As such, Home Farm should have been taken forward to

Stage 6 with SLAA site 34 and 60.

4.6. Stage 6 considers the performance of each site against the findings of the Sustainability

Appraisal. The SSMA methodology identifies that only where a site is appraised as

having significant negative effects which cannot be mitigated or reduced and/or

balanced by positive effects will a site not be taken forward to Stage 7.

4.7. If the Home Farm site had been taken through to Stage 6, SLR consider that the

following assessment would apply: From the review of absolute and non-absolute

constraints contained within Stages 1-5, as well as the development proposals for the

provision of a mixture of Class C2 and Class C3 residential units and associated

biodiversity improvements and enhancements to the Ancient Woodland, the site

perform well against the Stage 6 sustainability objectives identified. Accordingly, the

site should be taken forward to Stage 7.

4.8. The Stage 7 assessment considers the deliverability/developability of the sites and their

availability. The SSMA identifies that all sites would be recommended for allocation

unless it is considered that issues over availability/viability are unlikely to be resolved

by the time of publication of the PSDLP.

4.9. In terms of deliverability, The Home Farm site is within single ownership, is available

for development within the short to medium term of the Local Plan period and, from

our client’s own assessment, is entirely viable. The Home Farm site would, therefore,

pass Stage 7 and be taken forward to Stage 8.

4.10. Finally, Stage 8 relates to site capacity and is undertaken through the completion of

the Site Capacity Analysis report by the Council. The Home Farm site has a total site

area of 15.82ha, of which approximately 7.55ha would be utilised for built

development. The site would be able to accommodate the following levels of

development across the market housing and specialist housing provision:

• Elderly Care / Memory Loss Care - 150 units

• Apartments – 160 units

• Terrace Housing – 55 units

• Semi-detached Housing – 35 units

• Detached Housing – 15 units

4.11. Less than half of the site area would actually need to be released from the Green Belt.

The existing areas of ancient woodland along with their associated buffer, as well as

other parcels of currently undeveloped land, could remain in the Green Belt and be

improved as part of any development at the site.

4.12. The findings of the staged assessment above demonstrate that there is no reason why

the Home Farm site should not be allocated for housing development in the PSDLP.

The release of part of the site from the Green Belt is clearly justified, and there are no

absolute or non-absolute constraints that would inhibit its development.

4.13. Considering RBC’s significant housing need, and its inability to identify a supply of

housing for the plan period, it is clear that additional sites need to be allocated for

housing in the PSDLP. Further, the Council has not used the Green Belt Review (2014

and 2017) to release sufficient land between the urban area and the Green Belt to meet

either the identified housing need or the longer-term development needs beyond the

plan period, which is suggested under paragraph 85 of the NPPF.

4.14. In this context, the Home Farm site should be released from the Green Belt and

allocated for housing.

5. Physical considerations and emerging policy

5.1. The PSDLP contains policies which set out considerations relevant to development at

the Home Farm site in relation to physical constraints such as ecology, biodiversity,

and open space. Proposed Policy EE9 covers a broad and comprehensive range of

areas relating to the protection of biodiversity and geodiversity. The National Planning

Policy Framework includes paragraphs relevant to Local Planning Authorities

(section 11, paragraphs 109 – 119). LPAs are required to set out a strategic approach

in their Local Plans for the ‘creation, protection, enhancement and management of

networks of biodiversity and green infrastructure’ (paragraph 114).

Biodiversity, geodiversity, and nature conservation

5.2. Proposed Policy EE9 describes the hierarchy of important sites that would need

particular attention during planning applications. These include direct and indirect

effects to both statutory and non-statutory wildlife sites (Sites of Special Scientific

Interest, Special Protection Areas, Special Areas of Conservation, Ramsar sites,

National Nature Reserves and Local Nature Reserves) and other fe

dear sir/madam, we look forward to hearing from you in due ......elysian residences. i would be...

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