Local Plan Consultation, January 2020
Our enormous thanks go to Anne Damerell, Secretary, Staines Town Society for her hard work in producing this balanced and very comprehensive response to Spelthorne Borough Council, Local Plan Consultation, January 2020.
Staines Town Society appreciates the efforts of SBC Planning Dept to compile this Local Plan in very difficult circumstances and wishes to comment as follows.
Policies Document
Most of the policies flow on from policies in the existing Plan, but we are dismayed to note that many of them are vaguer and have less substance than the corresponding policies in the 2009 Plan. There are fewer specific requirements which proposed development must comply with, which means that consideration of plans will be more subjective and based on generalities, allowing more wriggle room to developers.
The presumption in favour of sustainable development, which in practice means almost all development, is of course required by central government, but it is not good news in crowded areas like Spelthorne. We are relieved that it does not automatically apply to natural or heritage assets and urge SBC to decide that it does not ever apply to them.
The numbers in the table of Sources of Supply have been carefully calculated to meet the housing target required by Government – but the impact on the Borough will be appalling. In particular the concentration of development in Staines is overwhelming, with the entire central area of this modest riverside town destined to become a solid mass of tower blocks; and the threat of 1600 more units to come in the proposed ‘Staines Masterplan’. As all possible sites will already be overdeveloped, no amount of masterplanning will be able to mitigate the further damage this will do to Staines.
We are grateful for the efforts you have already made to persuade the Dept of Housing, Communities and Local Government to use the 2016 population projections, which would produce a lower housing target than the 2014 ones. We hope that you, and other local authorities in the same desperate straits, will persist. And if you manage to secure a lower figure, we ask you to drop the extra housing in the Staines Masterplan and take some of the pressure off central Staines by reducing the most extreme allocation plans such as the 900 dph planned for the Debenhams site. 900 dwellings per hectare! No other part of the borough is expected to suffer anything like this degree of overcrowding.
Spatial
Policy SP1 has good points but is rather woolly, with good intentions but no mention of any means to enforce them. It depends heavily on the Masterplan, which cannot be assessed as it has not been written and is not part of the Plan. It is not satisfactory to have an important policy defined by a document which does not exist. We recall the last attempt at a Staines Masterplan, a few years ago, which came to nothing and was quietly abandoned.
Policy SP2 applies to Ashford Shepperton and Sunbury Cross centres and again contains statements about seeking to improve and enhance them. It replaces policies TC3&5 and CO2. But Policy CO2 applies to the whole borough and requires developers to contribute to infrastructure costs – a much stronger statement. We object to the loss of CO2.
Policy SP3. How, exactly, is SBC going to ensure that the adverse impacts of Heathrow expansion are minimised? Without the details, is this any more than wishful thinking?
Policy SP4 applies to local shopping parades and is said to replace policies TC4 and CO1. It does not replace CO1, which applies to the whole borough and is about providing community facilities and resisting the loss of existing ones. We object to the loss of CO1.
The consideration of alternatives in each section is rather crude, the only alternatives being ‘have a policy’ and ‘don’t have a policy’. There is no discussion of possible alternative wordings within policies.
Policy SP6 replaces EN9 & 10 but weakens their focus on protecting landscape features and river views.
Policy SP7 does not reflect the reality of Spelthorne’s relationship with Heathrow. The expansion of the airport is not sustainable and should not be described as such. We suggest instead
Policy SP7 Heathrow Airport
The Council will work to protect residents from the adverse impact of Heathrow expansion by
a) working strategically with local authorities around Heathrow Airport.
b) end of first para, replace ‘provided that’ by ‘only if’
iii) replace by ‘refusing development that increases air, noise, light and other pollution’
c) removing all words after ‘Green Belt’.
Housing
Cynically we wonder if Policy H1 should be called ‘Homes for All who can afford them’. More seriously, the first clause should be renamed ‘Housing Requirement’ as its connection with the nature and amount of housing need in Spelthorne is tenuous. The proposed housing mix shows a more reasoned approach than the existing Plan. In clause 4, ‘expected’ should be replaced by ‘required’ in two places. We hope that clause 5 will be invoked sparingly. Allowing undersized housing is not good long-term planning: families grow, and adults and children end up trapped in cramped unhealthy environments. There will already be an excess of tiny studios from PDO conversions, which cannot be controlled.
We support the views of SCAN on the provision of accessible housing. It is very unfortunate that the current Plan does not mandate planners to require satisfactory levels of accessibility in all the recent schemes approved, and we look forward to improvement in the new Plan. The meaning of clause 11 on specialised accommodation is unclear (care homes in big blocks of flats?) and would benefit from explanation.
We object to the loss of Policy HO5 on housing density. Admittedly the case is lost in town centres, where HO5 is already widely ignored, but the provision of density limits in suburban areas outside town centres is a sensible precaution against proposals for tower blocks sticking up in residential areas.
Historical note: STS argued for the retention of maximum density policies in the Surrey Structure Plan many years ago. Alan Dyer of SBC stated that this would be unnecessary as planning authorities already had powers to control density. A look around Spelthorne, and indeed many other parts of Surrey, confirms that he was wrong.
We agree with Policy H2 and hope it can be implemented more effectively than the existing HO3. Clause 2b) must not be allowed to dilute the force of ‘require’ in clause 1.
Environment
Policy E1, Green Belt, is weaker and less specific than policies GB1 (saved policy) and EN2, which it replaces. GB1 states that development in the Green Belt ‘will not be permitted’ except for specified uses such as forestry. E1 says that inappropriate development will not be approved unless very special circumstances can be demonstrated. Neither ‘inappropriate’ nor ‘very special circumstances’ are defined. This will lead to endless subjective argument by developers.
Policy EN2 forbids rebuilding in the Green Belt to a size significantly larger than the original house. Policy E1 keeps this condition in clause 3, for extensions, and in the discussion, but omits it in clause 2, for rebuilding. We object to this omission.
At the end of the guidance on air quality is the welcome statement that the air quality impact of development will be compared with the actual situation, disregarding any extant permission. This should be stated in the actual Policy E3.
The section on noise is not strong enough and omits mention of any representations to Heathrow. No amount of good design etc will reduce the adverse impact of flightpaths over the borough to acceptable levels. Again, the guidance is good, but decisions are made on the words of the actual policy.
Policy E4: we were puzzled to read of a biodiversity opportunity area defined as ‘Staines Moor to Shortwood Common’, as surely the town of Staines is in the way. However it turns out to be ‘Staines Moor and Shortwood Common’ which is much more reasonable.
Policy E4 is said to replace previous EN7 & 8. It does not replace EN7 at all, as tree protection and TPOs are not mentioned. EN8 contains specific protections which are not mentioned in E4. We object to the loss of EN7 and EN8.
Policy E5, open space, is generally welcome, but we would like to stress that non-sporty open space is also valuable, especially to an ageing population. Walking or sitting in parks and gardens, or just looking at them in passing, gives enjoyment. Clause 3 is a less specific version of current Policy CO3, but perhaps that gives it more chance of being implemented. Staines town centre will become desperately in need of open space as its population grows.
The final list of Local Green Spaces should be part of the document.
Economy
Policy EC1 states that change of use of Strategic Employment Sites will be resisted. There does not seem to be a contingency plan for the disappearance of a major employer, e.g. BP collapsing because of the switch from fossil fuels, or Shepperton Studios’ parent company deciding to relocate it.
What happens inside the Heathrow DCO zone, if the DCO is granted? Does Spelthorne still have any planning jurisdiction, over large chunks of Stanwell & Stanwell Moor? We have not found anything in the Plan that covers this point.
Policy EC2 (retail) again contains many statements of intent but few enforceable policies. Clause 7 rightly seeks to resist out-of-town shopping centres, but in practice we doubt if there will be any out-of town spaces left. As the map of Primary Shopping Areas is not included, residents are not being fully consulted.
EC3, leisure and culture. It should be made clear that Clause 1.a.iii refers to accessibility in terms of location and also to physical accessibility of the building.
Design
Policy DS1 is the current EN1 with improvements and is welcome. Clause 7 is an interesting attempt to shape high-rise development but may be overwhelmed by the sheer volume of new building to be crammed into Staines. Policy DS2 is similarly welcome.
Policy DS3 contains so many vague words like ‘seek’, ‘expect’ etc that it is virtually toothless. The sharpest comparison of policies in the current & emerging Plans is between the detailed requirements of EN6 on Conservation Areas and the 5 lines of general support in clause 6 of DS3. We object to the loss of EN5, 6 and 8.
Infrastructure
We are puzzled by clause 4 of ID1, which seems to say that only unwanted facilities should be retained. We suggest replacing ‘where’ by ‘unless’ and adding ‘and’ between the subclauses. If the stated wording is correct, it requires explanation.
Infrastructure provision is essential, not just because it is currently lacking in some places but because the planned amount of new housing will have substantial requirements. CIL may provide funds but in some places, notably Staines town centre, there is also a lack of space for it as all possible space will be crammed with housing.
Policy ID2 is not being properly consulted on as, again, it depends on a document which does not exist. The parking issue will be most acute in Staines if proposals to build on the Riverside, Bridge Street, Oast House, Elmsleigh, Tothill and Elmsleigh surface car parks are implemented. Park+Ride or similar transport for outsiders will not help local residents who find there is almost no parking left in the centre. We may wish for the general adoption of car-free lifestyles, but in reality, Staines is destined for a parking crisis, and the mechanism for dealing with it is absent from the plan. As well as the direct impact on retail, etc, of residents being unable to access the town centre, there will be all sorts of adverse knock-on effects, such as the Museum losing volunteers because they cannot park near the Museum or its store in Staines Park (loss of Burges Way parking).
Site Allocations Document
There are no good choices in the situation which the DCLG has forced us into. We appreciate the efforts of the SBC planners in compiling a list of least bad choices – but the results are still dreadful. At the MP’s public meeting on 17 January there was a wave of public feeling about loss of Green Belt sites and the impact on local communities, resulting in Mr Kwarteng promising to speak to ministers and try to get the housing target reduced ‘to save your Green Belt’.
Everyone will hope that his and your efforts succeed and the 603 target is substantially reduced, by using 2016 population projections or otherwise. But to use all this relief on Green Belt sites would be reverting to Option 3 (put it all on Staines) when in fact Option 4 (combination) was the agreed option. We ask you to take a balanced view and remove the worst choices in all categories, reducing the highest densities in Staines and dropping the extra 1600 houses from the Staines Masterplan.
Response on the allocation sites in Staines
ST4/001, Jewson’s yard in Moor Lane, and ST4/004, 96 –104 Church Street, have already been agreed as housing, and the proposed densities are tolerable in residential areas.
ST2/006, Hy-ten and Jewson’s in Gresham Road. Hy-ten has been a nuisance, very noisy at unsocial hours, for many years, and the neighbours would probably be delighted to see it go. The proposed density is greater than ideal, but on balance this will be an improvement.
The four SCC sites ST1/028,29, 30,31, Leacroft, Burges Way, Fairways and Wyatt Road provide various useful community services which should not be lost. The suggestion in ST3/004 that they might be relocated to the Oast House seems unlikely as SCC no longer owns the Oast House. The proposed densities at Leacroft and Wyatt Road are too high for their neighbourhoods.
ST3/004 Oast House and car park. The ‘old vacant buildings’ referred to are Grade II Listed and form one of the very few complete brewery complexes left in SE England. The complex includes the unlisted Malt House on the right of the entrance, which has a remarkable slate malting floor. Though sadly neglected by SCC in recent years, the complex is worth preserving. We argue strongly that the Oast House buildings should be kept and converted to residential, and not demolished. This would imply a lower total density and we therefore object to the proposed density of 193 dph.
If the Oast House car park is built over, what site remains for parking for the proposed Light Rail service?
We object to the cumulative effect of the proposals for the remaining Staines sites, forming a huge high-rise block in the town centre, turning the streets into canyons between buildings rising to the aircraft safety limit. If the flats sell (they may not, of course, if they are at market prices which we cannot afford, leaving the town with a huge bulk of ghost towers, which is pretty silly) there will be a huge influx of people into the town centre, causing massive congestion and infrastructure problems. The town will be Croydonised and its character irretrievably changed. It is accepted that these areas will be developed as housing; but the amount is far too great. The text admits the adverse impact of this concentration of development but gives no reason to believe that these problems can be managed.
ST4/010 Riverside car park, and ST4/011, Thames Lodge Hotel: This would be a dreadful waste of a beautiful riverside site. 400 dph implies a massive block towering above the riverside. The Majestic flats looming darkly over the High Street have density 318 dph, and this would be worse.
ST4/019 Debenhams site, 250 flats at 900dph. This is the worst over-development of all, nearly three times the Majestic density. Is it even possible, given the aircraft safety limit? There certainly won’t be more than a smear of amenity space, and the flats will be tiny, to fit them all in.
We object to this overdevelopment of the prime site in the town.
There are no good choices in this consultation, but some are worse than others.
ST4/009. The Elmsleigh Centre was indeed allocated for housing in the 2009 Plan, but for 95 flats, not 650. To fit them all in must mean the closure of the Elmsleigh and Tothill car parks over the shops, and building over the Elmsleigh surface car park, and the text only mentions retail and residential. There is no mention of the bus station, which must be retained and not diminished if a modal shift of transport is to be achieved. We object to the overdevelopment of this site.
ST1/037. Thameside House (BUPA building) This site seems to have lost the piece of car park associated with it in recent plans. We object again to overdevelopment: 500 dph is far too much and implies another tower block. In addition, we regret the loss of the current rather elegant building.
ST3/12 Telephone exchange. In this case the existing building will not be much missed, but again 250 dph is too much and we object to this contribution to the central massif.
ST4/002 Bridge Street Car park. The previously consented scheme attracted 175 objections and was widely hated, with its proposed 12 storey tower like a lost lighthouse. At first sight the allocation for 75 units looks good news, but it becomes clear that the hotel + flats would be just as massive and unsuitable for a sensitive riverside location at the entrance to the town.
We have considered the sites rejected for Allocation, and request that you reconsider ST2/008, the derelict tinware factory in Langley Road. It is currently an eyesore and source of danger. Any proposed industrial use would be out of place in a residential road. Residential development, perhaps in conjunction with ST1/031, would be beneficial, and we suggest that allocating the site might provide a useful prod to the landowner to make use of the site.
“The places we live should provide us with access to everything we need for a good quality of life and be designed with people in mind.” ( CPRE England. ) Not a possible outcome for Spelthorne, unfortunately.
Recent Comments