Category Archives: Weekly Updates

Public Consultation extended

The Public Consultation on our new Local Plan – previously due to end on 5 September – has been extended by two weeks. If you haven’t already sent in your views, you now have until 19 September to do so.

Kempton Park has been ruled out as a site for development. So far, so good.

It is vital that the Planning Inspector understands how important an issue Kempton Park is amongst the residents of Sunbury. It is so important that you express your opinion. Every single submission counts.

Please use the Representation Form provided by the Council. You can also download it from the KKG website. You can then:

a) Fill it in online, save it, and send it to localplan@spelthorne.gov.uk; or

b) Print it out, fill it in, and post it to:

Strategic Planning
Spelthorne Borough Council
Knowle Green
Staines-upon-Thames
TW18 1XB

If you support Kempton Park being excluded as a site for development, our suggestions are as follows:

* Please type “Kempton Park” into the box marked “Other (Please specify) in Question 3 of Part B.

* Please reply YES to all questions in question 4a of Part B.

* Please write your reasons why Kempton Park should NOT be developed in the box at Question 5 of Part B.

No need to write in to the Planning Inspector at length. Keep it short.

You don’t need any reminding of the reasons thousands of houses should not be built on Kempton Park. They would:

* destroy a vital section of Green Belt

*  increase the traffic load on the A308 Staines Road East, especially the pinch points at Sunbury Cross, Hampton, and the Hampton Court roundabout.

*  put unstainable pressure on all areas surrounding the estate, through extra flooding risk and pressure on overloaded infrastructure.

* permanently and negatively change the character of areas surrounding the estate.

You will no doubt have your own comments.

All the details of how to respond to the Consultation can be found at https://www.spelthorne.gov.uk/localplan

If you have any questions, please don’t hesitate to ask us at keepkemptongreen@hotmail.co.uk .

It’s time to have your say

The last Public Consultation has just over five weeks to run. 5 September is the final date to submit your opinions to the Planning Inspector who will decide on our new Local Plan.

You will have heard from councillors of all flavours that the new Local Plan is not ideal. This is not through any errors by the Spelthorne Planning team. It is entirely the fault of the massive increase in housing targets sent down from Whitehall.

Nevertheless, we can be grateful that Kempton Park has been ruled out as a site for development.

But we are not out of the woods yet. Redrow and The Jockey Club will be arguing as strongly as they can – when the Planning Inspector holds the Examination in Public – that the Kempton Park estate should be opened up for development. KKG intends to be there to argue the opposite, in support of the Local Plan.

So it is vital that the Planning Inspector understands how important an issue Kempton Park is amongst the residents of Sunbury. It is so important that you express your opinion.

You don’t need any reminding of the reasons thousands of houses should not be built on Kempton Park. They would:

* destroy a vital section of Green Belt

*  increase the traffic load on the A308 Staines Road East, especially the pinch points at Sunbury Cross, Hampton, and the Hampton Court roundabout.

*  put unstainable pressure on all areas surrounding the estate, through extra flooding risk and pressure on overloaded infrastructure.

* permanently and negatively change the character of areas surrounding the estate.

You will no doubt have your own reasons.

All the details of how to respond to the Consultation can be found at https://www.spelthorne.gov.uk/localplan

Please use the Representation Form provided by the Council.

If you support Kempton Park being excluded as a site for development, our suggestions are as follows:

* Please type “Kempton Park” into the box marked “Other (Please specify) in Question 3 of Part B.  

* Please reply YES to all questions in question 4a of Part B.

* Please write your reasons why Kempton Park should NOT be developed in the box at Question 5 of Part B.

No need to write in to the Planning Inspector at length. Keep it short.

If you have any questions, please don’t hesitate to ask us at keepkemptongreen@hotmail.co.uk

Reasons to be Cheerful #1

The draft Local Plan has been published, and Kempton Park is excluded as an area for development.

The twelve week final public consultation began last Wednesday, and will run until 5 September.

All the Local Plan documents can be viewed at:

https://www.spelthorne.gov.uk/localplan

The Local Plan itself is at:

Draft Local Plan 2022 – 2037

Kempton Park is only mentioned in passing in the above document, because it is not scheduled for development. That is because it was rated as well-performing Green Belt in two Green Belt Assessments, which can be viewed here:

https://www.spelthorne.gov.uk/Greenbeltassessment

We are going through all these documents in depth, and will get back to you with what we find.

You will have plenty of time to submit your thoughts on the draft Local Plan, and it is very important that you do.

If you would like to hear more, Ann Biggs, the Spelthorne Strategic Planning Officer, will be giving a presentation at the LOSRA AGM at 8pm on Wednesday 22 June.

https://www.losra.org/docs/LOSRA-AGM-news2022.pdf

Another step forward

Spelthorne Council met last evening to decide whether to send our draft Local Plan to what is known as the Regulation 19 Consultation. This will be a final Public Consultation, during which everyone in Spelthorne can have their say about the Plan.

There were fears beforehand that the vote would be extremely tight. As it happened, the meeting was run swiftly and efficiently, and there were no wrecking amendments. The motion to send our Local Plan forward to the next stage succeeded. By our calculation, the vote was 26 votes in favour vs 8 against.

The Public Consultation will run from 15 June 2022 to 5 September 2022 – so, twelve weeks, which is double the statutory requirement. Once the Consultation documents are available we will publicise details as to where to find them.

Submissions by the public will be collated and sent, together with the draft Local Plan, to the Planning Inspector who will preside over the Examination in Public of the Local Plan. That public hearing is crucial to the protection of Green Belt, at Kempton Park and elsewhere in the Borough.

So, two things:

  1. Please use the Public Consultation as an opportunity to send your views direct to the Planning Inspector.
  2. We are now entering an intensely legal process. Any contributions to our Fighting Fund will be most welcome.

Please, no more Groundhog Days…

First, a heartfelt thanks to those who came to listen to Joglaresa in St Mary’s Church at the end of April. Also to those who bought tickets even though they could not attend on the night, and to those who have donated to KKG subsequently. Altogether, a pleasing boost to our Fighting Fund.

We are now one step closer to getting our new Local Plan over the line. At its last meeting, the Local Plan Task Group referred our draft Local Plan to be considered by the Environment and Sustainability Committee. At a meeting on 26 April, that Committee resolved to refer the draft Local Plan to a meeting of the full Council for a final decision. The meeting will take place this Thursday, 19 May. It will be up to the Councillors to decide whether to send the draft Local Plan to what is known as the Regulation 19 Consultation. This will be a final Public Consultation, during which everyone in Spelthorne can have their final say about the Plan.

A number of things should be borne in mind:

1. Strangely, it appears to some that it is only Staines which is bearing the burden in the draft Plan. But that ignores other places in the Borough where sites have been earmarked for development , and the significant threat (by our NOT having a Local Plan) to many other sites – in Staines, and everywhere else – which would otherwise be protected in our Local Plan.

(See https://keepkemptongreen.com/2022/03/29/home-truths-3/)

The truth is that the unfortunate situation we are in (just like Boroughs the length and breadth of England) makes it necessary to address the targets sent down by Whitehall. We simply cannot ignore them. And the burden will fall on everyone in this Borough, one way or another (in addition, we might add, to the huge cost to every Council Tax payer across this Borough of the year-long appeasement moratorium on development in Staines – £939 000 – which could have been far better spent elsewhere, such as reducing the increase in everyone’s Council Tax).

2. There has been claim and counter claim in the press about the importance of those Whitehall housing targets. The Secretary of State, Michael Gove, said that the 300 000 per annum target wasn’t the be-all and end-all of planning policy. That claim was quickly denied by No 10, and Mr Gove has back-pedalled since. The truth is that those statements, and any other political statement likely to emerge on this subject, make not a single jot of difference to planning policy. Planning policy only changes when it is altered by an Act of Parliament, or a Regulation issued by the Whitehall department. The targets, most uncomfortable as they are, therefore remain, until specifically changed by legislation in one form or another.

Those hoping for the cavalry to come charging over the hill to reduce the housing targets are doomed to disappointment. In the last week, a meeting of Strategic Planning Officers from across the country with Whitehall officials could not extract a single answer on the issue of housing targets. The repeated questions to the officials were repeatedly ducked. That does not sound to us like a bugle call from the cavalry.

3. Our local Plan has been debated for going-on 100 hours in the various forums of our Council, before we even get to the meeting on Thursday. Everything that could possibly be said about it has already been said.

In the best of all possible worlds we would not be arguing like this over our new Local Plan. But we do not live in the best of all possible worlds. We have to make the best of a thoroughly undesirable situation. We have to get this Local Plan through to the Regulation 19 Consultation. If we think the Local Plan puts us in a bad situation, just think about what things would be like without a Local Plan: open season for developers to do as they please.

We sincerely hope that all Borough Councillors will do the right thing on Thursday evening.

Vote the draft Local Plan through to Regulation 19.

Please, no more Groundhog Days…

Home Truths #4

Housing market arithmetic

The government’s target of building 300 000 dwellings each year has been around for a number of years. It was first announced in the Autumn Budget of 2017. It was included in the Conservative Party election manifesto in 2019. Since then it has been referred to – approvingly – by any number of Cabinet ministers, most recently in the last two weeks when the Whitehall department said it was not going to reduce the 300 000 target, nor change the standard method for calculating each Borough’s contribution to this overall target.

We can take it, then, that the government is wedded to this policy. It is not going away.

If one adds up the housing targets of all the Local Planning Authorities, after taking account of the adjustment for the pandemic, and the 20% buffers applied to those LPAs not meeting their housing targets,

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

one gets a number that is very close to 300 000.

Thus, each LPA’s contribution is important in achieving the total. Spelthorne’s housing target is 611 dwellings per annum, which is a very high target compared with the target under the previous Local Plan of 166 per annum. But we are not alone. Other Boroughs’ targets have also risen by very large amounts.

A small number of Spelthorne Councillors want a second plea to be made to Whitehall to have the Spelthorne target reduced. (The first approach was rejected by the Department in 2020.) In addition, they want Spelthorne to produce a Local Plan that ignores this housing target completely.

The problem is, if Spelthorne were to have its housing target reduced (which is extremely unlikely to happen) then it would require some other Borough to make up the difference, in order to maintain the 300 000 total. The same applies to just ignoring the Whitehall target in a new Local Plan. As far as the Department is concerned, the dwellings have to be built somewhere, if not in Spelthorne. It really is a case of 2 minus 1 equalling 2.

But in reality they will force Spelthorne to adhere to its target, one way or another. They are already starting to do so, through the use of the “Tilted Balance”, putting all sites in the Borough at risk:

(see  https://keepkemptongreen.com/2022/03/19/hometruths-2/ and https://keepkemptongreen.com/2022/03/29/home-truths-3/ )

You can see why these plans to change and/or ignore the housing targets are doomed to failure. Central government won’t allow it, and other Boroughs won’t accept our deficit being shifted onto them, especially given that 71% of Boroughs are so far achieving their targets. Spelthorne is one of the minority that are not.

The only way to protect what we have – whether Green Belt or Brownfield – is to have a Local Plan which addresses this problem of very high housing targets, and provides as much protection as is possible, within the law. We cannot ignore the problem, or hope it will be shifted elsewhere.

We already have such a Local Plan, which gives the best protection possible. It is up to the Spelthorne councillors to adopt that plan, put it forward to its final public consultation, and remove this Borough from the free-for-all limbo in which it has languished for the last few years.

p.s. Don’t forget the Joglaresa performance on Friday 29 April. A musical evening that you will never forget. Contact us at keepkemptongreen@hotmail.co.uk to book your seat. Details below:

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

https://spelthorne.gov.uk/article/19901/Preferred-Options-Consultation-documents

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:

https://www.spelthorne.gov.uk/article/19626/Housing-Delivery-Test-Action-Plan-2020

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.