Planning Policy Elmbridge Borough Council Civic Centre High Street Esher Surrey KT10 9SD By email [email protected] 5 March 2020 29360002 Dear Sir or Madam ELMBRIDGE LOCAL PLAN REGULATION 18 CONSULTATION - REPRESENTATIONS On behalf of our client, Charterhouse Strategic Land (CSL) and Moore Place Holdings LLP (MPH), we write in response to the consultation of the new Local Plan prepared by Elmbridge Borough Council (EBC): “Creating our vision, objectives and the direction for development management policies 2020”, under Regulation 18 of the Town and Country Planning (Local Planning) (England) Regulations 2012. CSL and MPH are promoting the former Moore Place Golf Club, Portsmouth Road, Esher for residential development. A site location plan is included in Appendix 1. Representations have previously been submitted in relation to this site during the August – September 2019 Regulation 18 consultation which have been attached in Appendix 2. We have reviewed the Regulation 18 draft Local Plan and respond to each main point below. Housing Need Under Question 1, EBC is asking for thoughts on the key issues and challenges facing Elmbridge. One of the key issues stated is: “Providing the right types of homes to ensure housing choice to meet the needs of the community.” CSL and MPH are of the view that this issue should acknowledge the high level of housing need within the Borough and should state that Council will seek to meet this need. Paragraph 11(b) of the National Planning Policy Framework 2019 (NPPF) is clear when it states that “strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas”, unless there is a strong reason for restricting development and the impacts would significantly and demonstrably outweigh the benefits. The Office for National Statistics (ONS) places the affordability ratio in EBC at 15.8, well above both the Surrey and national averages. EBC itself, puts the affordability ratio even higher at 18.8 (x the average income). As stated in our previous representations on the August 2019 Regulation 18 consultation, in order to try and address affordability, it is crucial that EBC meets, as a minimum, its housing need. EBC currently assesses its housing need at 623 dwellings per annum, although it should be noted that the need should be based on the most up-to-date data, including using the 2014 based household projections, the most recent affordability ratios and using data for the 2019-2029 period. EBC’s critical housing need is further compounded by the results of the first Housing Delivery Test published in February 2019. EBC delivered only 62% of its housing target. In an appeal decision issued in September 2019, EBC stated that it was only able to demonstrate a housing land supply of 2.75 years (see Appendix 31). It is, therefore, critical that EBC seeks to meet its objectively assessed need in full, and this should be stated as the key issue to address in EBC’s Local Plan. The Moore Place Golf Club is an appropriate site that can be developed on to help EBC meet its housing need and should be recognised as such within the emerging Local Plan. Specialist Housing Need In addition, EBC should also recognise specialist housing need as a key issue within the Borough. The Planning Practice Guidance (PPG) identifies that the need to provide housing for older people is critical, and an understanding of how the ageing population affects housing needs should be considered in the early stages of plan-making (paragraph reference ID: 63-001-20190626). The PPG further highlights that Local Planning Authorities should set clear policies to address the housing needs of groups with particular needs, including older people (paragraph reference ID: 63-006-20190626). The current wording states that EBC will seek to meet the housing needs of ‘the community’. This statement needs to be finessed because different groups in the community can have different housing needs. It is fundamental that EBC acknowledge that the range of homes will need to include specialist housing and should highlight this through its own separate policy within the Regulation 19 version of the emerging Local Plan. Other Policies It is important that EBC ensures that all policies are in compliance with the 1 Appeal Ref: APP/K3605/W/19/3226776 3 New Road, Esher KT10 9PG 2 guidance set out in the NPPF. In particular, the Plan should have regard to policy wording which incorporates flexibility and allows for viability to be assessed. This will enable the Plan to deliver development, including housing, which is so desperately needed in the Borough. Moore Place Golf Club Moore Place extends to approximately 13 hectares and is located along the A307 (Portsmouth Road) between the main settlement of Esher and the adjacent neighbourhood of West End. The site fronts Portsmouth Road and was a short nine-hole golf course with a small practice area, a small clubhouse and car parking, linked to the adjacent care home. CSL’s vision for Moore Place is to provide 300 new high-quality and sustainable homes, together with assisted living accommodation to the north of the site. The scheme can also provide accessible public open space for the wider community. Moore Place Golf Club does not meet the purposes of including land in the Green Belt – as confirmed by EBC’s emerging Local Plan evidence base – and is in a sustainable location for development (as explained in our previous representations provided at Appendix 2). The recent closure of the golf course at Moore Place follows a number of years of unprofitability and was unable to sustain further losses. Evidence in the form of a Golf Need and Viability Assessment prepared by WYG on behalf of CSL and MPH clearly demonstrates there was no over ridding need to retain the golf course given the quantity, quality, access and availability of course in the local area. Further, this evidence clearly demonstrates that the course was not viable in the long-term with no alternative golf offer likely to be viable given the existing market supply covering all bases. Accordingly, since the closure of Moore Place Golf Course there has been no impact on the provision or accessibility of courses to local residents. The site can contribute 300 high quality residential dwellings to help meet to EBC’s critical housing need, as well as delivering assisted living dwellings for the elderly. Providing specialist accommodation can help increase the supply of family housing as older residents move out of larger properties that are no longer suitable for them. The allocation of Moore Place will help to ensure that EBC can deliver their housing targets. We request that Moore Place is allocated within the emerging Local Plan for residential development as the Plan progresses through to the Regulation 19 stage. We trust our representations will be taken into account in preparing the next version of the Local Plan. CSL are keen to engage with EBC and wish to continue to be involved in further consultations on the Local Plan process moving forward. 3 Yours faithfully Sean McGrath Enc: Appendix 1 – Site Location Plan Appendix 2 – Previous representations on the Regulation 18 Local Plan consultation (between August and September 2019) Appendix 3 – 3 New Road, Esher KT10 9PG Appeal decision (Appeal ref. APP/K3605/W/19/3226776) cc: Mr O Taylor - CSL 4 Appendix 1 161000.000000 162000.000000 163000.000000 164000.000000 165000.000000 166000.000000 167000.000000 161000.000000 162000.000000 163000.000000 164000.000000 165000.000000 166000.000000 167000.000000 Appendix 2 Planning Policy Elmbridge Borough Council Civic Centre High Street Esher Surrey KT10 9SD By email [email protected] 30 September 2019 let.001.SM.AW.29360002 Dear Sir or Madam ELMBRIDGE LOCAL PLAN REGULATION 18 OPTIONS CONSULTATION MOORE PLACE GOLF CLUB, ESHER (PART OF GREEN BELT BOUNDARY REVIEW (DECEMBER 2018) REF. RSA-50) We write, on behalf of our client, Charterhouse Strategic Land Ltd, in response to the consultation of the new Local Plan for Elmbridge Borough Council (EBC) under Regulation 18 of the Town and Country Planning (Local Planning) (England) Regulations 2012. Charterhouse Strategic Land Ltd are promoting land at Moore Place Golf Club, Portsmouth Road, Esher for residential development. A site location plan is included in Appendix 1. Assessment of options The Regulation 18 options consultation document sets out five strategic options for residential development in EBC in the next plan period. The first three options formed part of the EBC’s previous regulation 18 consultation in 2016 with a two further growth options added for this round of consultation. In the 2016 consultation, EBC stated that its preferred option was option two. However, the Leader’s Forward to the latest consltation makes clear that EBC does not have a preferred option at this stage. The housing requirement for EBC is 623 dwellings per annum (dpa) which equates to 9,345 dwellings across the plan period. EBC acknowledges that it cannot ask its neighbouring authorities to help in meeting any shortfall as these authorities are also struggling to meet their own needs. EBC’s affordability ratio is 18.8, meaning that the average house price is 18.8 times the average annual salary. On average, only 282 homes are built each year in EBC, making the need for a greater supply of homes within the local area extremely acute. It is clear that despite EBC constraints, EBC needs to boost the supply of housing not only to help meet the Government’s policy ambition to deliver 300,000 homes per year, but also to help address the historic undersupply and critical affordability levels in EBC.