>€¦ · from: thomas, leigh to: planning policy subject: representations on behalf of elizabeth...

From: Thomas, LeighTo: Planning PolicySubject: Representations on behalf of Elizabeth Finn Care (trading as Turn2Us) - Additional Sites and Options

ConsultationDate: 21 June 2017 15:48:11Attachments: @

Dear Sir / Madam,

On behalf of our client, Elizabeth Finn Care (trading as Turn2Us), please find a link below torepresentations made in response to the consultation on the Additional Sites and Optionsdocument.

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I would be grateful if you could provide confirmation that the representations have beenreceived.

Kind regards,Leigh

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RUNNYMEDE 2035: ADDITIONAL

SITES AND OPTIONS

CONSULTATION

REPRESENTATIONS SUBMITTED ON BEHALF OF ELIZABETH FINN CARE

TRADING AS TURN2US IN RELATION TO LAND AT MERLEWOOD, HOLLOW

LANE, VIRGINIA WATER

JUNE 2017

LONDON WEST END 2 of 17 Local Plan Representations

COLLIERS INTERNATIONAL

ELIZABETH FINN CARE TRADING AS

TURN2US


Version Control

Status FINAL

Project ID Land at Merlewood, Virginia Water

Filename/Document ID Representations to Additional Sites and Options Consultation

Last Saved 19 June 2017

Owner Leigh Thomas

Director Jonathan Manns

Approved by Jonathan Manns

Date Approved 19 June 2017

COLLIERS INTERNATIONAL SPECIALIST AND CONSULTING UK

LLP

Company registered in England and Wales no. OC392407

Registered office:

50 George Street

London W1U 7GA

Tel: +44 20 7935 4499

www.colliers.com/uk


TABLE OF CONTENTS

1 Introduction and Background 5

2 Site Context 6

3 Response to Consultation Documents

3.1 Chapter 3 – Identification of additional land use allocations 7

3.2 Chapter 4 – Amendments to allocations proposed in the issues,

options and preferred approaches document 9

3.3 Chapter 5 – Impact of additional allocations and other

amendments to the Council’s preferred spatial strategy 12

4 Conclusion 14


1 INTRODUCTION AND

BACKGROUND

Colliers International, on behalf of our client Elizabeth Finn Care (trading as

Turn2Us), are instructed to comment on the Runnymede Local Plan

“Additional Sites and Options” (Regulation 18) consultation document.

Land at Merlewood, Hollow Lane has been promoted for development by

our client throughout the early stages of emerging Local Plan preparation

and these representations are made in the context of ongoing discussions

with Officers. The site was identified as part of the larger ‘Virginia Water

North’ land parcel, which is designated for release from the Green Belt as

part of Runnymede Borough Council’s preferred strategic approach set out

in the “Issues, Options and Preferred Approaches” consultation document.

This approach has been taken forward in the “Additional Sites and Options”

consultation document.

Colliers International submitted representations on behalf of our client to the

“Issues, Options and Preferred Approaches” consultation in August 2016.

As part of these representations, our client undertook considerable technical

work on the site to demonstrate that the site is a suitable location for

residential use with no constraints to bringing forward development. In

particular, our client can demonstrate that the site no longer serves a Green

Belt function, and therefore considers that the site can provide a medium

scale development opportunity that can contribute to housing supply within

the early part of the plan. This technical work continues to be valid and the

site is considered suitable, available and achievable for delivery within the

0-5 year period of the plan.

Our client therefore wishes to engage with the Council as the Local Plan

develops, and welcomes that the “Virginia Water North” land parcel

continues to be identified for release from the Green Belt in the latest

“Additional Sites and Options” consultation document. These

representations are therefore made in response to the “Additional Sites and

Options” consultation and the accompanying Site Capacity Analysis and Site

Selection Methodology and Assessment documents.


2 SITE CONTEXT

The site comprises approx. 9.4ha of predominantly greenfield land, adjacent

to Merlewood Care Home which is located in the north of the site and is

locally listed. The site is located in a sustainable position to the north of the

Virginia Water urban area.

The site is currently accessed from Hollow Lane, which forms the northern

boundary of the site. The eastern, western and southern boundaries of the

site abut existing residential development, which comprises predominantly

large detached dwellings.

The site forms part of a larger area of land which is currently designated as

Green Belt. Figure 1 below shows the extent of the site.

Figure 1: Site Location Plan


3 RESPONSE TO

CONSULTATION DOCUMENTS

The current consultation on the Additional Sites and Options document

follows the previous consultation exercise in relation to the “Issues, Options

and Preferred Approaches” document (IOPA) that took place in August

2016.

The Council confirms in the Additional Sites and Options document that the

principal issue facing the Borough relates to housing, and that there is a

need to demonstrate that they have ‘left no stone unturned’ in meeting its

housing need. In seeking to do this, a number of suggestions were made

through the IOPA consultation as to how the Council would boost its housing

delivery. The IOPA confirmed that, previously, the Council’s preferred

approach to housing delivery proposed to meet between 56% and 82% of

its proportion of Objectively Assessed Need (OAN). The Council have

therefore undertaken further work in order to explore whether an increased

housing target could be justified. In this respect, the Additional Sites and

Options document confirms that, as a result of the additional evidence that

has been collated, further sites have been identified and the Borough is

much closer to meeting the OAN.

The Additional Sites and Options consultation document sets out a number

of questions relating to housing delivery. We wish to make representations

in response to the following questions:

3.1 CHAPTER 3 – IDENTIFICATION OF ADDITIONAL LAND USE ALLOCATIONS

Chapter 3 of the Additional Sites and Options document identifies land use

allocations in the Borough additional to those set out in the IOPA. We have

provided responses to the questions set out by the Council below.


1. Do you agree that the Council’s approach to identifying additional

allocations to help meet its identified needs over the plan period of the

Local Plan is robust? If not, please confirm your reasons.

We agree with the approach taken by the Council in relation to identifying

additional residential land allocations is robust. The IOPA identifies St Peters

Hospital and Blays House sites as additional allocations considered

appropriate for residential-led development. In order for the Council to

demonstrate that everything has been done to meet the OAN within the

Borough, it is essential that these sites come forward in addition to, rather

than instead of, the preferred options already identified in the IOPA. In this

regard, the “Virginia Water North” land parcel, including the Merlewood site,

should continue to be identified for release from the Green Belt in order to

deliver new homes.

As demonstrated by the considerable technical work undertaken on the

Merlewood site, included in our representations made to “Issues, Options

and Preferred Approaches” consultation in August 2016, the site is a suitable

location for residential use with no constraints to bringing forward

development. This technical work continues to be valid and is included in

Appendix A. The site is considered suitable, available and achievable for

delivery within the 0-5 year period of the plan.

A Landscape and Green Belt Appraisal of the site was undertaken previously

in order to ascertain the role that the land has in meeting the five purposes

of the Green Belt. This was submitted as part of the representations made

to the IOPA consultation. The appraisal concludes that, overall, the site’s

contribution to the functioning of the Green Belt in this part of the Borough is

low. It is considered that the removal of the site from the Green Belt and

redevelopment of the site for residential use would not significantly affect the

effectiveness of the Green Belt in the local area in fulfilling the five functions

of the Green Belt as set out in the NPPF.

A comprehensive review of the relevant transport and access issues relating

to the site was also undertaken in support of the representations made to

the IOPA consultation. In summary, the analysis undertaken demonstrated

that, in transport and highways terms, there is no reason why the site could

not come forward for residential use.

We also agree with the Council that, in addition to the St Peters Hospital and

Blays House sites, the sites identified in the Additional Sites and Options

document should be taken forward. We consider that the approach taken to

identifying these sites was robust and we support the conclusions reached

in the Council’s Site Selection Methodology and Assessment (SSMA)

document. In this respect, the preferred sites, including “Virginia Water


North”, were taken forward through each stage of the assessment process

set out in the SSMA.

We note that there were a number of sites that were considered in the

SSMA, but were not taken forward as proposed allocations. We agree that,

where sites did not meet the required selection criteria, they were

discounted. In allocating sites for release from the Green Belt where they

perform strongly against Green Belt purposes and have not been identified

through a Green Belt Review, there is a risk of the Plan being found

unsound. In contrast, the “Virginia Water North” land parcel performed

strongly against each of the selection criteria, and it is therefore appropriate

for it to be taken forward as a residential allocation.

3.2 CHAPTER 4 – AMENDMENTS TO ALLOCATIONS PROPOSED IN THE ISSUES, OPTIONS AND PREFERRED APPROACHES DOCUMENT

In addition to the new allocations recommended for inclusion in the Local

Plan, as set out in Chapter 3, the Additional Sites and Options consultation

document also proposes amendments to a number of the allocations

consulted on in the IOPA document. This is in light of the Green Belt Review

Part 2 and site capacity work that has been undertaken by the Council

following the IOPA consultation.

The Council have set out questions in relation to this section and, where

relevant, we have set out our responses below.

6. Do you agree with the revised capacities proposed for each site in Table 3,

the amendments made to site areas and the justifications provided for the

Council’s changes in approach for individual sites? If not, please confirm

your reasons.

We support the revised capacities proposed for the preferred housing

allocations, where these changes have been based upon robust evidence.

We note that the additional evidence that has been collated by the Council

in order to justify increased housing delivery in the Borough includes the

following:


The inclusion of further allocations in the Local Plan which would

provide housing.

A reassessment of the capacity of the preferred allocation

consulted upon in the IOPA document (as listed in appendix 1 of

the IOPA document).

The adjustment of a number of the assumptions factored in to the

Council’s evidence base relating to housing supply.

Of the three additional sources of evidence, we wish to comment specifically

on the reassessment of the capacity for the preferred allocations that were

consulted upon in the IOPA document. The following sections therefore

comment specifically on the allocation of the “Virginia Water North” land

parcel, which contains the Merlewood site owned by our client. The Site

Capacity Analysis document which was produced by the Council and forms

part of the Local Plan evidence base has therefore been reviewed in detail.

Housing Density

In respect of the site capacity, we note that the Site Capacity Analysis

document identifies a total minimum capacity for the “Virginia Water North”

land parcel of 120 residential dwellings. This reflects the upper end of the

indicative capacity identified in the IOPA document, which suggested that

the site could accommodate 90 – 125 units.

A preliminary indicative masterplan was prepared for the Merlewood site by

Ayre Chamberlain Gaunt and submitted as part of the representations made

by Colliers International to the IOPA consultation. Extending to 9.4 hectares,

the Merlewood site is the largest landholding within the wider “Virginia Water

North” parcel, which covers 19.5 hectares in total. The indicative masterplan

takes into consideration the site’s opportunities and constraints, as advised

by the conclusions of the baseline studies undertaken and also included as

part of the previous representations.

It demonstrates that the site can accommodate approx. 40-50 homes, with

the majority being 4 and 5 bedroom detached dwellings. The proposals will

retain a considerable number of mature trees on the site, with the existing

pond providing a focal point for the development. The development of the

site at the upper end of the range, to provide 50 homes, would result in a

gross density of 5.3 dwellings per hectare. This is broadly in line with the

preferred capacity scenario identified by the Council for the wider land parcel

and set out at Table 3-16 of the Site Capacity Analysis document.


We therefore support the application of bespoke densities to the land parcels

identified for release from the Green Belt, as their development will be

particularly sensitive in landscape terms and densities suitable for urban

areas may not be appropriate. In order to ensure that sufficient flexibility is

provided to enable development comes forward on the site, we would also

request that the policy approach taken forward in future iterations of the

Local Plan confirms that the capacity for the “Virginia Water North” land

parcel is approximate. Notwithstanding this, the development of this site for

residential use will make a significant contribution to the delivery of larger

family homes required in the Borough.

Housing Mix

In respect of housing mix, our client agrees that the site is not suited towards

smaller units due to the characteristics of the surrounding area. It is therefore

welcomed that there is an assumption that larger units, including 5 bedroom

dwellings, will be provided (as confirmed at para 3.99). However, it is also

suggested in the Site Capacity Analysis document that 10% of the units

provided within the “Virginia Water North” land parcel should be provided as

smaller units (1 and 2 beds). The Site Capacity Analysis document confirms

that this is on the basis that the Government confirmed in February 2017,

through the Housing White Paper, that there was an intention to amend the

NPPF to introduce a policy expectation that housing sites deliver a minimum

of 10% affordable units. However, the Housing White Paper does not set out

a requirement for affordable housing to be provided as 1 and 2 bedroom

units specifically. Whilst this is likely to be appropriate in the majority of

cases, we would request that any future policies included in the emerging

Local Plan allow for more flexibility in the type of affordable housing to be

provided.

Open Space Requirement

The Site Capacity Analysis document advised at paragraph 3.96 that, given

the site topography, it is unlikely that the site could deliver green

infrastructure in the form of sports pitches, but this could be swapped for

park/gardens or natural/semi-natural greenspace. It is also suggested that

the site could incorporate allotments and would be large enough to provide

its own SANG (paragraphs 3.96 and 3.97). However, the site has varying

topography, which will impact on the developable area and may reduce the

ability to provide green infrastructure. It is confirmed at paragraph 3.98 that

this has not been factored into the capacity analysis undertaken, so we

would request that any requirements for green infrastructure taken forward


and incorporated into planning policy are considered to be indicative and

approximate to allow flexibility and ensure the site is deliverable.

Other Considerations

We agree that the site does not lend itself to Gypsy / Traveller pitches due

to its steep topography and note this has been highlighted by the Council in

the Site Capacity Analysis (para. 3.94). The Council also confirm that local

land values and existing use values are likely to prohibit development of

Gypsy / Traveller pitches. We agree with this and do not consider that the

land parcels identified for release from the Green Belt are the most

appropriate locations, as they are more suited to delivering the much needed

housing required in the Borough.

3.3 CHAPTER 5 – IMPACT OF ADDITIONAL ALLOCATIONS AND OTHER AMENDMENTS TO THE COUNCIL’S PREFERRED SPATIAL STRATEGY

In addition to proposing additional allocations through the Runnymede 2035

Local Plan, and making amendments to the preferred allocations consulted

on at the IOPA stage, the Council is also recommending a number of other

amendments to its strategy to maximise the number of homes that can be

built sustainably in the Borough over the period of the Local Plan.

Chapter 5 gives consideration to the preferred spatial strategy for the

borough. The Council have requested that the following questions are

considered and we have set out our responses below.

7. Do you agree with the amendments that the Council has made to its

approach to increase its delivery of housing in the Borough over the Plan

period? If not, please confirm your reasons.

We agree that whilst the NPPF affords significant weight to the protection of

the Green Belt, it is considered that greater weight should be attached to

‘significantly boosting’ housing supply, where it is sustainable to do so and

is released through a plan-led strategic review of the Green Belt. We

therefore agree that, on the basis of the additional evidence that has been

gathered since the IOPA consultation in 2016, the Council approach to


increasing its delivery of housing in the Borough over the Plan period is

robust.

8. Do you agree that option SS5 (as amended) is the preferred approach for

the spatial strategy or do you think one of the other options should be

preferred? Please confirm you reasons.

The Additional Sites and Options consultation document confirms at Table

5 that the Council is closer to delivering spatial strategy option SS5, which

proposed an annual housing target of 466 dwellings per annum. This is a

considerable increase on previously preferred spatial strategy option SS3,

which proposed a housing target of 303-383 dwellings per annum.

The Council have advised that, since the close of the IOPA consultation,

additional evidence has been collated which demonstrates that a higher

housing target than was initially suggested can be realised. We consider that

the additional Green Belt Review and site capacity analysis that has been

undertaken provide an appropriate basis for the increased housing target

that is set out in the Additional Sites and Options document.

However, the fact remains that, in order for the plan to be considered sound,

it is important that the Council allocates suitable Green Belt land for housing

and it is considered that the Virginia Water North land parcel is required to

meet the vision and objectives of the Plan to 2035.


4 CONCLUSION

As set out in these representations, Elizabeth Finn trading as Turn2Us

support the principles put forward in the Local Plan in general and the

allocation of the site known as “Virginia Water North” for circa 120 dwellings.

The site is located within a sustainable location, providing the ability to

accommodate a small scale urban expansion. It is considered that the site

is developable within the first five years of the plan period and can make an

immediate contribution to the housing targets set out for the Borough.

Our client has undertaken considerable technical work on the site and can

demonstrate that the site continues to be a suitable location for residential

use with no constraints to bringing forward development. In particular,

Elizabeth Finn Care trading as Turn2Us can demonstrate that the site no

longer serves a Green Belt function and any technical issues can be

overcome.

Our client’s land at Merlewood is capable of accommodating 40-50 dwellings

and provides the opportunity to deliver much needed housing for the

Borough in the short-term.

We trust that our representations will be given full consideration through the

Runnymede 2035 Local Plan consultation process and that our details will

be included on the Council’s database to ensure we are notified of all future

stages of this document.


APPENDIX A –

REPRESENTATIONS SUBMITTED

TO IOPA CONSUTLATION

RUNNYMEDE 2035: ISSUES,

OPTIONS AND PREFERRED

APPROACHES CONSULTATION

REPRESENTATIONS SUBMITTED ON BEHALF OF ELIZABETH FINN CARE

TRADING AS TURN2US IN RELATION TO LAND AT MERLEWOOD, HOLLOW

LANE, VIRGINIA WATER

AUGUST 2016


COLLIERS INTERNATIONAL

ELIZABETH FINN CARE TRADING AS

TURN2US


Version Control

Status FINAL

Project ID Land at Merlewood, Virginia Water

Filename/Document ID Representations to Issues, Options and Preferred

Approaches Consultation

Last Saved 25 August 2016

Owner Leigh Thomas

Director Jonathan Manns

Approved by Jonathan Manns

Date Approved August 2016

COLLIERS INTERNATIONAL SPECIALIST AND CONSULTING UK

LLP

Company registered in England and Wales no. OC392407

Registered office:

50 George Street

London W1U 7GA

Tel: +44 20 7935 4499

www.colliers.com/uk


TABLE OF CONTENTS

1 Introduction and Background 5

2 Site Context 6

3 Planning Background 7

3.1 Consultation 7

3.2 Delivery 7

4 Response to Consultation Document 8

4.1 Chapter 3 – Portrait of Runnymede 8

4.2 Chapter 4 – Spatial Vision, Objectives and Strategy 8

4.3 Chapter 5 – Housing 11

5 The Proposal 14

5.1 Masterplan 14

5.2 Landscape 14

5.3 Access and Transport 15

6 Conclusion 16

APPENDICES

1 Indicative Masterplan Document

2 Landscape Appraisal

3 Transport Report


1 INTRODUCTION AND

BACKGROUND

Colliers International, on behalf of our client Elizabeth Finn Care trading as

Turn2Us, are instructed to comment on the Runnymede Local Plan Issues,

Options and Preferred Approaches consultation document. Turn2Us are a

charity fighting poverty in the UK and all care home profits are allocated for

public benefit.

Land at Merlewood, Hollow Lane has been promoted for development by

Elizabeth Finn Care trading as Turn2Us throughout the early stages of

emerging Local Plan preparation and the site has been recognised within

the Council’s Strategic Land Availability Assessment (SLAA) as being,

suitable, available and achievable for development. The site is also

identified as part of the larger ‘Virginia Water North’ land parcel, which is

designated for release from the Green Belt as part of Runnymede Borough

Council’s preferred strategic approach set out in the emerging Local Plan.

Merlewood Care Home has been serving the local community since 1947

and is to remain fully operational. However, surplus land has been

identified for development that will provide important funding for future

enhancement of the care home.

Our client has undertaken considerable technical work on the site and can

demonstrate that the site continues to be a suitable location for residential

use with no constraints to bringing forward development. In particular,

Elizabeth Finn Care trading as Turn2Us can demonstrate that the site no

longer serves a Green Belt function and any technical issues can be

overcome. Elizabeth Finn Care trading as Turn2Us therefore considers that

the site at Merlewood, Hollow Lane can provide a medium scale

development opportunity that can contribute to housing supply within the

early part of the plan.


2 SITE CONTEXT

The site comprises approx. 9.4ha of predominantly greenfield land, adjacent

to Merlewood Care Home which is located in the north of the site and is locally

listed. The site is located in a sustainable position to the north of the Virginia

Water urban area.

The site is currently accessed from Hollow Lane, which forms the northern

boundary of the site. The eastern, western and southern boundaries of the site

abut existing residential development, which comprises predominantly large

detached dwellings.

The site forms part of a larger area of land which is currently designated as

Green Belt. Figure 1 below shows the extent of the site.

Figure 1: Site Location Plan


3 PLANNING BACKGROUND

Colliers International and an associated team of consultants have been

working on behalf of Elizabeth Finn Care trading as Turn2Us to

demonstrate that the principle of residential development on land to the

south of Merlewood Care Home, Hollow Lane is sustainable and

deliverable in planning terms. These representations therefore support the

allocation of the site for residential use as part of the emerging Runnymede

2035: Issues, Options and Preferred Approaches consultation.

3.1 CONSULTATION

As part of the Issues, Options and Preferred Approaches consultation,

Runnymede Borough Council are seeking responses on key issues relating

to the delivery of the emerging plan. A response to the relevant key issues

and questions is provided in Section 4.

3.2 DELIVERY

To support these representations a suite of scoping work has been

undertaken to demonstrate that suitability of the site to support residential

development. This work includes:

Appendix 1 – Indicative Masterplan Document within Local Plan

Representations Report (Ayre Chamberlain Gaunt)

Appendix 2 – Landscape Appraisal (The Landscape Partnership)

Appendix 3 – Transport Report (JMP Consultants)

The conclusions of the supporting reports have been summarised within

Section 5, and demonstrate that the development of the site for residential

use is deliverable in technical planning terms. The site is also suitable for

release from the Green Belt, as confirmed by the Green Belt Review

undertaken by Arup on behalf of Runnymede Borough Council and the

Landscape Appraisal which has been undertaken by the Landscape

Partnership and is attached at Appendix 2.


4 RESPONSE TO

CONSULTATION DOCUMENT

We wish to make representations on the following sections of the emerging

Local Plan:

4.1 CHAPTER 3 – PORTRAIT OF RUNNYMEDE

Chapter 3 details the issues and challenges facing the Borough over the

plan period. It is welcomed that the following weaknesses and challenges

are identified and that the Plan seeks to address them in the proceeding

chapters.

“There is limited land for housing and commercial development to

meet the community’s needs outside the Green Belt.”

“There is development pressure on the Green Belt due to a shortage

of available sites for development in the Borough’s urban areas.

4.2 CHAPTER 4 – SPATIAL VISION, OBJECTIVES AND STRATEGY

Chapter 4 sets out the spatial vision and objectives for the Borough over

the period to 2035. A variety of options are then set out for the strategy to

deliver these objectives.

The Council have requested that the following questions are considered

and we have set out our responses below.


Do you agree that Option SS3 is the preferred approach for the spatial

strategy or do you think one of the other options should be preferred

and why?

We agree that preferred approach Option SS3 is the most appropriate

spatial strategy to ensure that the vision, objectives and development

needs of the Borough to 2035 are delivered. This approach is underpinned

by information set out in the evidence base.

As set out in the emerging Local Plan, the objectively assessed housing

need for the Runnymede Borough Council area far exceeds the availability

of brownfield land in the borough. The Council cannot therefore provide a

sustainable level of housing in the borough without considering the

development of suitable greenfield sites.

The NPPF requires the Council to maintain a five-year supply of specific

deliverable housing sites on a rolling basis. In order to accommodate the

level of required growth, the emerging Local Plan seeks to allocate a

variety of sites for residential development and supports the release of

some sites from the Green Belt. The allocation of a range of sites, including

those which have been identified as suitable for release from the Green

Belt, will help to ensure that the Council’s rolling five-year housing land

supply is maintained.

We agree that whilst the NPPF affords significant weight to the protection

of the Green Belt, it is considered that greater weight should be attached to

‘significantly boosting’ housing supply, where it is sustainable to do so and

is released through a plan-led strategic review of the Green Belt. It is

considered that in selecting Option SS3 as the preferred option, the

Council has taken account of how the Green Belt in Runnymede performs

against it purposes as well as its overall function and integrity.

Indeed, the strategic Green Belt Review found that a number of land

parcels either do not or only weakly meet Green Belt purposes and could

be considered for inclusion in the urban area. The area defined as ‘Virginia

Water North, Hollow Lane’, which includes the site at Merlewood, is

identified as one of these land parcels and is included for release from the

Green Belt as part of the preferred Option SS3. In order for the plan to be

considered sound, it is important that the Council allocates suitable Green

Belt land for housing and it is considered that the Virginia Water North land

parcel is required to meet the vision and objectives of the Plan to 2035.

We have set out justification to demonstrate that the site is suitable for

residential use in the proceeding sections. Land to the north of Virginia

Water is capable of fulfilling the role of a smaller scale urban extension to


Virginia Water, and would be a logical extension to the existing urban area

without encroaching into the countryside beyond well-defined and

defensible boundaries.

In summary, the site is of a suitable size to accommodate approximately

40-50 dwellings, could be delivered without the need for major

infrastructure requirements and would help to meet the demand for

housing within years 0-5 of the plan.

The site is under the sole ownership of Elizabeth Finn Care trading as

Turn2Us who are committed to delivering a sustainable residential scheme

on site in accordance with the principles and policies of Runnymede

Borough Council.

The site lies adjacent to the existing settlement boundary and presents a

logical extension to Virginia Water. As demonstrated by the Green Belt

Review and the Landscape Appraisal undertaken by the Landscape

Partnership, the proposed residential development of the site would have a

minimal impact on the Green Belt and is located adjacent to an existing

residential area.

Development of this surplus land will provide essential funding for the

future enhancement of the care home. This is particularly important as the

Surrey Infrastructure Study (2016), undertaken by Aecom on behalf of

Surrey County Council, identifies a requirement for 26 additional nursing

care facilities and 20 residential care facilities in the period up to 2030.

When the requirement for 14 additional extra care facilities is included, this

equates to a funding gap of £31,870,000.

Other Options

We have also reviewed the other Spatial Strategy Options proposed and

agree with the Council that Options SS1 and SS2 which seek the retention

of Green Belt land are not effective as they would result in a large shortfall

in housing.

Options SS5, SS6 and SS7 include the development of Green Belt land

that has not been identified for release by the Green Belt Review, which

forms part of the evidence base for the emerging Local Plan. This

approach is therefore not considered justifiable as the Council are unable

to demonstrate through the evidence base that exceptional circumstances

exist to release such sites. This approach is considered unsound and

Option SS3 should be taken forward.


Has Runnymede considered all reasonable options or should any

other options have been considered and why?

We consider that, in respect of putting a strategy in place to providing the

level of housing development required to meet the objectively assessed

need for the Borough, Runnymede Borough Council has considered all

reasonable options.

4.3 CHAPTER 5 – HOUSING

Chapter 5 gives consideration to the detailed policies required to deliver

the Borough’s housing needs over the Plan period. The Council have

requested that the following questions are considered and we have set out

our responses below.

Has the Council considered all the relevant issues and reasonable

approaches for a strategy/policy approach? If the answer is no, what

other issues do you believe exist and/or which other approaches

should have been considered and why?

In respect of housing, we consider that, on the whole, the Council has

taken into account all the relevant issues and reasonable approaches to

identify a suitable strategy / policy approach. Further comment on each

particular issue is included below.

Do you agree with the preferred approach identified for each

identified issue or do you think one of the other approaches should

be preferred and why?

It is welcomed that the Council recognises the need to release Green Belt

land in order to meet the future planned housing growth levels, and it is our

view that the preferred options identified for the detailed housing policies

represent the best approach.

We have considered issues H1 – H4 in turn below.


Issue H1 – “There is currently an inappropriate mix of dwellings to meet the

needs of the population”

We agree that, in general, option H1/02 which seeks to ‘provide an

appropriate mix of homes using the SHMA and viability evidence’ is the

most suitable approach.

However, as noted within the emerging Local Plan document in relation to

Issue H2, a bespoke approach may be more appropriate in certain areas.

For example, the ‘Virginia Water North’ land parcel is within an area that is

characterised by larger dwellings and a Green Belt setting, so a

prescriptive policy setting out an appropriate mix of homes for new

developments across the Borough is unlikely to deliver a type of housing

that would be appropriate for the area. Notwithstanding, the development

of this site for residential use will make a significant contribution to the

delivery of larger family homes required in the Borough.

Issue H2 – “Delivering housing to ensure an effective use of land”

Option H2/01 seeks to implement a ‘minimum density policy, with bespoke

densities in certain areas, i.e. ‘commuter hubs’ in line with developing

Government policy’.

We support the application of bespoke densities in certain areas and

consider that this approach should be extended to the land parcels

identified for release from the Green Belt, as their development will be

particularly sensitive in landscape terms and densities suitable for urban

areas may not be appropriate. Indeed, the SLAA notes that, in respect of

the ‘Virginia Water North’, a lower residential density than would generally

be required is appropriate due to the character of the surrounding area.

Issue H3 – “The Council will be unable to meet affordable housing

requirements for regular and specialist housing needs”

The Council has set out that it will seek the provision of affordable housing

as far as viable and notes that further work will need to be undertaken to

determine the viability of requiring additional forms of affordable housing

and the appropriate mix.


We support this approach and consider that developers should be given

the opportunity to submit evidence which demonstrates the level of

affordable housing that can be provided without jeopardising the viability of

the development. This is in accordance with the NPPF which states that in

pursuing sustainable development, careful attention to viability and costs in

plan-making and decision-taking must be taken and that plans should be

deliverable (Paragraph 179 of the NPPF).

Issue H4 – “The Council will not be able to meet the accommodation needs

of specialist populations”

We agree that the Council should seek to meet the accommodation needs

of specialist populations, however we do not consider that the Resultant

Land Parcels identified for release from the Green Belt are the most

appropriate locations, as they are more suited to delivering the much

needed housing required in the Borough.

We therefore object to Option H4/03 which requires existing sites to be

considered in the first instance and recommend that specific sites are

identified to accommodate specialist populations which take into

consideration their specialist needs.


5 THE PROPOSAL

5.1 MASTERPLAN

A preliminary indicative masterplan has been prepared by Ayre

Chamberlain Gaunt, which is included at Appendix 1 and takes into

consideration the site’s opportunities and constraints, as advised by the

conclusions of the baseline studies undertaken.

It demonstrates that the site can accommodate approx. 40-50 homes, with

the majority being 4 and 5 bedroom detached dwellings. The proposals will

retain a considerable number of mature trees on the site, with the existing

pond providing a focal point for the development. The site will be accessed

from Hollow Lane, with an access road provided within the site.

It can therefore be demonstrated that the site is deliverable within the

beginning of the plan period and should be defined as a housing allocation

in the Local Plan for 40-50 dwellings. The failure of the Local Plan to reflect

the Site Assessment and SLAA assessments with an allocation of the site

will reduce the provision of housing in the borough in the short, medium

and long term.

Elizabeth Finn Care trading as Turn2Us has provided the indicative

masterplan included at Appendix 1 for illustrative purposes only and

welcomes the opportunity to discuss this with the Council to ensure that a

shared vision for the site is developed and delivered.

5.2 LANDSCAPE

Elizabeth Finn Care trading as Turn2Us has commissioned the Landscape

Partnership to undertake a Landscape and Green Belt Appraisal of the site

to ascertain the role that this land has in meeting the five purposes of the

Green Belt.

The appraisal concludes that, overall, the site’s contribution to the

functioning of the Green Belt in this part of the Borough is low. It is

considered that the removal of the site from the Green Belt and

redevelopment of the site for residential use would not significantly affect

the effectiveness of the Green Belt in the local area in fulfilling the five

functions of the Green Belt as set out in the NPPF.


On the basis of the illustrative masterplan produced by ACG, it is

considered that the site could be sensitively developed without causing

significant landscape or visual impacts.

5.3 ACCESS AND TRANSPORT

JMP have been appointed to undertake a review of the access and

transport issues relevant to the proposed residential development of the

site. The work undertaken is set out in the accompanying Transport

Report.

The makes the following conclusions:

The accessibility of the site by a range of sustainable transport

modes will encourage sustainable travel in compliance with

national, regional and local policy objectives.

There are no highways safety grounds that would prevent the

development of the site for residential use.

Vehicular access to the site would be taken from Hollow Lane via

a new priority T-junction to the west of the Merlewood Care Home

building.

Car and cycle parking would be provided in line with Surrey

County Council standards.

Trip generation analysis shows that the level of trip generation

would have a minor impact on Hollow Lane and would be

imperceptible once distributed onto the wider network at Callow

Hill.

In summary, the analysis undertaken has demonstrated that, in transport

and highways terms, there is no reason why the site could not come

forward for residential use.


6 CONCLUSION

Our client has undertaken considerable technical work on the site and

can demonstrate that the site continues to be a suitable location for

residential use with no constraints to bringing forward development. In

particular, Elizabeth Finn Care trading as Turn2Us can demonstrate that

the site no longer serves a Green Belt function and any technical issues

can be overcome.

Elizabeth Finn Care trading as Turn2Us therefore considers that Land at

Merlewood, Hollow Lane can provide a medium scale development

opportunity that can contribute to housing supply within the early part of

the plan. Our client supports the Strategic Option SS3 set out in the

emerging Local Plan and the conclusions of the Green Belt Review.

Our client’s land at Merlewood is capable of accommodating 40-50

dwellings and provides the opportunity to deliver much needed housing

for the Borough in the short-term.

The site is located within a highly sustainable location, providing the

ability to accommodate a small scale urban expansion with no known

constraints to its deliverability. It is developable within the first 5 years of

the plan period and should be defined as a strategic housing use

allocation in the Local Plan for circa 40-50 dwellings.

LONDON WEST END Local Plan Representations

APPENDICES

LONDON WEST END Local Plan Representations

1 INDICATIVE MASTERPLAN

DOCUMENT

WE

ARE

24.08.2016

Local Plan R

epresentations R

eport

Our ref 228_PLN_500

Applic

ant Colliers Intern

ational

Merlewood, Virginia W

ater

ACGARCHITECTS.CO.U

K

Ayre C

hamberlain G

aunt

14a London Street

Basingstoke

Hampsh

ire

RG21 7NU

+44 (0)1256 411 450

[email protected]

x

CONTENTS

01 EXISTIN

G SITE

Site Location Plan

05

Existing Site Plan

06

Existing Site Photo

s

07

Existing Site D

iagrams

11

Site A

nalysis Diagram

13

Site O

pportunities Diagram

14

02 PROPOSED D

RAW

INGS

Pro

pose

d Site Plan

16

Pro

pose

d Site Plan - U

nit Schedule

17

4

01

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G

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Representations on behalf of Elizabeth Finn Care (trading as Turn2Us) - Additional Sites and Options ConsultationPart 1 Representations_RBC Local Plan Consultation_June 2017_Part 1 Representations_RBC Local Plan Consultation_June 2017_.pdf (p.1-39)1.pdf (p.40)