Home Truths #3

Sites at risk from Local Plan delay

We have already seen that the housing target of 611 dwellings per annum for this Borough, sent down from Whitehall, is not going to be reduced.

( see https://keepkemptongreen.com/2022/03/10/home-truths-1 )

We have also seen that there are sanctions for not meeting this target, and for not having a Local Plan in place, showing how the Borough is going to meet that target of 611 per annum.

( see https://keepkemptongreen.com/2022/03/19/hometruths-2 )

So far, two sites have fallen foul of this lack of a Local Plan.

One site, the Old Telephone Exchange in Staines, was already earmarked for development under the draft Local Plan. However, the planning application – brought forward early by Inland Homes – was rejected by the Spelthorne Planning Committee on the grounds of bad design and lack of on-site parking. Nevertheless, the Planning Inspector hearing the developer’s Appeal granted their application, because we do not have a Local Plan.

The other site, the Bugle site, had been assessed by the two Arup studies into our Green Belt as “Strongly performing Green Belt” which makes “an important contribution to the wider strategic Green Belt”. Nevertheless, the Planning Inspector hearing the Appeal granted the application, because we do not have a Local Plan.

The Bugle site is one of the sites listed in the table (click here) from the Preferred Options documentation, part of the existing Local Plan that is being delayed by party-political game-playing at the Council. We have outlined it in red on page 81 . *

This list comprises those sites which have been considered for development but excluded from the Local Plan, for various reasons (shown in the table).

All of these sites – Green Belt and Brownfield – are now at risk. So long as we have no Local Plan, it is now open season for developers, knowing full well that the Planning Inspectorate will tilt a decision in their favour.

Groveley Road, anyone. Tadmor Close, perhaps. Kempton Park? There are sites in Ashford, Laleham, Shepperton, Staines, Stanwell and Sunbury – 75 of them, in all. Take your pick.

Check the list for a site or sites in your area, and then ask your local councillor why they are at risk. (You know the answer, of course. It’s because we do not have a Local Plan.)

It is all very well to portray oneself as a defender of every bit of Green Belt, at the same time devoted to stopping all high-rise development. Those two can’t be achieved together, unless the housing target changes. It’s just simple arithmetic. And that housing target is not going to change, full stop. (A subject to which we will return next week.) And finally, if the targets don’t change, you can’t just ignore them – as we have seen, there are serious consequences.

So this is gesture politics, and is already having precisely the opposite result.

Talk about shooting oneself in the foot…

* All the Preferred Options documents can be read at



HomeTruths #2

Created with GIMP

The tilted balance

Every year Spelthorne Council (and every other Planning Authority in England) has to show how much housing it is delivering compared to the target handed down from Whitehall, and other measures of the Council’s planning performance. The Council’s annual report to Whitehall is known as the Housing Delivery Test Action Plan. The latest report (published in November 2021, based on the test conducted in January 2021) can be viewed at:


The test compares the number of new homes delivered over the previous three years with the Authority’s housing requirement. In the case of Spelthorne, these are as follows:

2019       63%

2020       60%

2021       50%

2022       69%

There are sanctions for this under-delivery:

  1. Where housing delivery over the previous three years has been less than 95% of the housing requirement, Local Planning Authorities should prepare an action plan setting out the causes of under-delivery and the intended actions to increase delivery;
  2. Where delivery has been less than 85% of the housing requirement, a 20% buffer should be applied to the supply of deliverable sites for the purposes of housing delivery assessment;
  3. Where delivery has been less than 75% of the housing requirement, the NPPFs presumption in favour of sustainable development will apply.

Spelthorne’s under-delivery therefore means that a 20% buffer should be applied to our annual five year supply target, from 611 to 733, and also that a presumption in favour of development will apply, until the target is reached. This is known as the “tilted balance”. The explanation is worth quoting in full:

“2.9 Where there is a presumption in favour of development, the “tilted balance” applies where the balance is skewed in favour of sustainable development and granting planning permission except where the benefits are ‘significantly and demonstrably’ outweighed by the adverse impacts or where specific policies in the National Planning Policy Framework (NPPF) indicate otherwise. The “tilted balance” also applies where there is the absence of relevant up to date development plan policies or where the local authority does not have a five year housing land supply which is presently the case for Spelthorne.

2.10 The tilted balance therefore increases the prospect of planning permission being granted because it ‘tilts’ the balance in favour of approving an application.

Note the section in bold above. Not only is there a “tilted balance” because of the under-delivery of dwellings against the target, but also because Spelthorne does not have a valid Local Plan.

The dangers of a delay to implementing our new Local Plan could not be put more starkly. Without a Local Plan, development will beat more risk of approval, with less power to Spelthorne Council.

And if you think we are being alarmist, it is already happening.

This is what the Planning Inspector said in his conclusions to the Appeal lodged by the developers of the Old Telephone Exchange site in Staines, at paragraph 76:

“76. The benefit of providing homes in an area of under-delivery of housing and where there is not a five-year supply of housing land, adds significant weight in favour of the scheme.”

There you have it. A Brownfield site given permission for development in terms of the “tilted balance”, because Spelthorne does not have a Local Plan. Although the “tilted balance” does not apply to Green Belt sites, the lack of an up-to-date Local Plan, and the absence of a five year housing supply makes these sites vulnerable to approval, particularly on Appeal.

This is what the Planning Inspector said in his conclusions to the Appeal lodged by the developers of the Bugle Nurseries site, at paragraph 61:

“61. In terms of Appeal B, I have found that this would not constitute inappropriate development within the Green Belt. The proposed development would contribute 31 dwellings towards the existing housing stock within the Borough, where there is no 5-year land supply.”

We hear that developers are queuing up to take advantage while they can.

Home Truths #1

Why the Spelthorne housing target is not going to be reduced …

The overall target

Since 2017, the government has had a housing target for England of 300 000 dwellings per year. It has never been achieved, but it is obviously in the interests of the construction industry that this target is as large as possible.

This overall target of 300 000 dwellings per year is not going to be reduced. There is too much political capital invested in it.

Source: Transparency International; Companies House, Electoral Commission

The geographical distribution

The question then becomes, where are these 300 000 dwellings going to be built?

The new Standard Method of calculating the housing requirement, which local authorities must follow in drawing up their Local Plans, was introduced in September 2017. Using that method, Spelthorne’s housing requirement was set at 611 per year – a massive increase from the previous target of 166 per year.

There was widespread dissatisfaction with the new increased figures across the country. So in August 2020, Whitehall began a consultation about a change to the Standard Method, which was intended to shift the requirement to build away from those areas from which the complaints had emanated. Spelthorne would have been a beneficiary of this revised Standard Method. The annual requirement, had it been implemented, would have fallen from 611 to 489 per year – still a very large increase from 166, but not quite so bad. Not everyone was so fortunate, however. The target for Elmbridge Council, just across the river from us, went up even more under the revised methodology.

There were even more complaints countrywide about the revised Standard Method, and it was shelved in December 2020.

It is highly unlikely that there will be any future England-wide changes to the Standard Method.

Spelthorne’s target therefore remains 611 dwellings per year.

Spelthorne as a special case

There is a view among some Spelthorne Councillors that somehow a special plea to Whitehall will result in our housing target being reduced. A special exercise in “Visioning” was undertaken last year, at some expense in time lost, and money spent, to try and reinforce this view. But attempts at special pleading are nothing new. Attempts to persuade Whitehall have been going on for more than 3 ½ years, since July 2018. All the related correspondence can be read at:

It would be marvellous if these targets were suddenly reduced, but so far these repeated approaches by Spelthorne to Whitehall have had no effect whatsoever. It is a mystery to us as to why people think that YET another attempt will be successful.

And all the while the clock is ticking.