Spelthorne Borough Council HousingDelivery Test ActionPlan 2024
June 2025
1. Introduction........................................................................................ 3
2. The Action Plan Context................................................................... 3
3. Action Plan......................................................................................... 11
Appendix 1............................................................................................... ..25
Appendix 2............................................................................................... ..26
Appendix 3……………………………………………………………………….42
Appendix 4…………………………………………………………………….. 44
Tables
Table 4 Spelthorne – Housing DeliveryTest 2025 – Projected............................................... 22
Table 5 ImprovingDecision Making......................................................................................... 22
Table 6 Supporting WiderHousing Opportunities.................................................................... 23
Table 7 Spelthorne Housing DeliveryTest 2024 Measurement 25
Table 8 Surrey Local Authorities – Housing DeliveryTest 2024.............................................. 27
Table 9 Spelthorne’s HousingLand Supply Position 29
Table 12 Number of dwellings completed, under construction and with outstanding planning permission at 31 March 2024................................................................................................... 34
Table 14 Housing completions (net) by bedroomApril 2009-March 2024............................... 35
Table 15 Percentage of new dwellings on completed sites between 2009 and 2024 at different densityranges................................................................................................................................................... 36
Table 16 Number of affordable homes provided per year since 2009..................................... 37
Table 17 Affordable dwellings granted planning permission 2022-2024.................................. 38
Table 18 Prior approvalapplications granted April2022-March 2024..................................... 38
1.1 There is wide publicity over the national housing crisis which we are experiencing in England. The lack of supplyand pressure for new homesis felt most acutely in the South East of England. The Government is committed to building more homes as confirmed in the 2024 Spring Budget. This objective to increase the number of new homes is reflected in the revised National Planning Policy Framework (NPPF) 2024 and the continuation of the Housing Delivery Test.
1.2 The 2024 Housing Delivery Test result for Spelthorne Borough Council was published by the Secretary of State in December 2024. Spelthorne BoroughCouncil scored 61%.Thiscompares with a figure of 68% in 2023, 69% for 2021, 50% for 2020, 60% for 2019 and 63% in 2018. The figure has, therefore decreased by 7% from the 2023 figure of 68%. As a result, and in response to this, the Council has produced a sixth Housing Delivery Action Plan to positively respond to the challenge of increasing its housing delivery.The Action Plan analyses the reasons for the under-delivery of new homes and sets out actions to improve housing delivery within the Borough.
1.3 The planningpolicy context to housing deliverycontained in nationaland local plan policy is contained as Information Document 1 in Appendix 1.
1.4 An analysisof the housing delivery in Spelthorne is set out in Information Document 2 in Appendix 2. This includes the housing delivery test calculation for Spelthorne, housing land supply, need, delivery and trajectory and also planning performance.
2.1 This Action Plan is the Council’sresponse to the challenge set out in the Government’s National Planning Policy Framework to boost significantly the supply of homes and has five goals:
· To examinethe possible causesof the ‘under delivery’ of new homes in the Borough.
· To explainwhat the Councilhas been doing so far to boost housing delivery.
· To gather evidence on sites with planning permission (and sites under construction for housingdevelopment) to understand what barriers are preventing homes being built on these sites.
Housing DeliveryTest Action Plan 2024
· To build relationships with developers, landowners and agents responsible for building homes on sites that have planning permission, allowing the Council to adopt the role of an enablerof much needed residential development ensuring housing permissions are built out as quickly as possible.
· To set out what actions the Council can take to increase the rate and number of homes built in Spelthorne.
2.2 Building houses is often a complex process. Often there are other factors beyond the council’s control which explain why sites for housing do not come forwardfor development. It requires a broader approachto be taken to increase the delivery of new homes and the use of other tools available which are beyond the traditional remit of the Local Planning Authority.
2.3 The Housing Delivery Test Action Plan sets out key priorities and actions that the Councilare undertaking to improve housingsupply and delivery. The plan in itself is not a decision-making documentbut seeks to identify opportunities to improve housing provision.
2.4 Table 1 sets out the Council’scorporate documents which all play a role in the delivery of housing.
Corporate Document |
Overlap with Action Plan |
Spelthorne Core Strategy and Policies DPD Document, February 2009 |
Housing Requirement Figure – 166 dwellings per annum superseded by housing need of 631 (+20% buffer) dwellings per annum (2024). |
Emerging Local Plan |
A replacement Local Plan 2024-2039 is currently being prepared. The draft Local Plan 2024-2039 was submitted to the Secretary of State for independent Examination on 25 November 2022. The first examination hearing sessions were held in May 2023, following a pause in June 2023 these resumed in Jan 2025 and completed in Feb 2025.
Following the examination hearings the Local Plan 2024-2039 has now progressed to a Main Modifications Consultation which is live until 15 May 2025.
It is anticipated that the Local Plan 2024-2039 will be formally adopted Autumn 2025.
As a result of the examination hearings the Council is proposing through the Main Modifications to include an Immediate Review Policy which commits to producing an updated or replacement plan, which will be submitted for examination no later than two years from the date of adoption of this Local Plan 2024-2039.
The Immediate Review will consider the housing requirement for the whole Borough based on the most up to-date national guidance. The monitoring of housing delivery, including the progress and implementation of sites, will inform the review.
|
Corporate Document |
Overlap with Action Plan |
Corporate Plan 2024 - 2028 |
Identifies five priorities: · Community · Addressing Housing Need · Resilience · Environment · Services |
Asset Management Strategy 2024/25 – 2027/28 |
Covers the Council’s property holdings and investment portfolio. Identifies priorities for the Investment portfolio, Development & Regeneration portfolio and Municipal Portfolio. These include the delivery of affordable housing and the meeting community needs.
|
Housing, Homelessness and Roughsleeping Strategy 2025 - 2030 |
Strategic priorities 2025-2030: · Priority 1: Partnership Working: A multi-agency approach to tackling homelessness
|
Corporate Document |
Overlap with Action Plan |
|
· Priority 2: Identifying opportunities to address housing need
· Priority 3: Proactive homelessness prevention and an effective service response
|
Spelthorne Economic Prosperity Strategy 2023-2028 |
The Spelthorne Economic Prosperity Strategy 2023-2028 builds upon the 2017-2022 Economic Strategy and continues to focus on prioritising the key needs for business to settle, grow and thrive. It also recognises that the environment and character of the Borough are key to achieving this. The vision of this strategy is: To secure sustained growth of the local economy for the benefit of businesses and residents whilst protecting the Boroughs environment and character. |
Assessment of under-delivery
2.5 Within this section, an assessment of the ‘under delivery’ of new homes in the Borough is considered which includes the local and national issues which influence housing delivery. A range of data and sources have been used to inform this analysis. As part of this process, the Council has engaged with stakeholders to improve its understanding of the issues affecting housingdelivery. The analysis of the issueshas been used to informwhat actions the Council need to take to improve its housing delivery.
Implementation of Planning Permissions
2.6 Once planning permissions have been granted, local planning authorities have limited influence over deliverability. The timescales for implementing a planning permission are generally not considered to be a significant issue within the Borough. Under planning legislation, permission is required to start within three years from the date of the decision notice. Implementation generally occurs within the permission period. The NPPF advises at para. 81 that:
“To help ensure that proposals for housing development are implemented in a timely manner, local planning authorities should consider imposing a planning condition providing that development must begin within a timescale shorter than the relevant default period, where this would expedite the development without threatening its deliverability or viability. For major development involving the provision of housing, local planning authorities shouldalso assess why any earlier grant of planning permission for a similar development on the same site did not start”.
2.7 However, there are some instances, where developers undertake the first stages of implementing a planning permission by carrying out the demolition of buildings on site and then delay the construction of the development. This happened, for example, at the former Centrica site in Staines-Upon-Thames. A two-year time period for all residential permissions was introduced by Spelthorne on 2 January 2020. This was an initiative to establish if a change in the timescales would assist in buildingout rates. However,it did not have a positiveimpact on housebuilding in Spelthorne and has created some confusion for applicants. Some developers have stated they have needed more time, particularly if site assembly is needed and often the only way forward is to re-submit the application in full. As a consequence, the time limit was reverted back to three years following the agreement of last year’s HDTAP.
2.8 Planning Officers have continued to build relationships with developers, landowners and agents and carry on a dialogue after planning permission is granted. Pre-commencement planning conditions continue to be submitted, assessed and discharged by the officers.
Planning DecisionMaking Performance
2.9 The performance of decision makingon planning applications is not considered to be a barrier to delivering new homes. Planning applications are being processed
within the statutory timeframes. The performance for the Local Planning Authorities (LPAs)are measured on their performance based on the % of planning applications they determine within specified timescales and on the numbers of applications allowed on appeal (the ‘quality’ assessment). This is outlined as follows:
· The speed of determining applications for major development
· The quality of decisions made by the authorityon applications for major
development;
· The speed of determining applications for non-major development;
· The quality of decisions made by the authorityon applications for non- major development.
2.10 With just a few minor exceptions, non-major equates to a combination of the “minor” and “other” categories referred to above.
2.11 The qualitymeasurement is the number of appeals allowedas a percentage of the total number of applications received in the category. The threshold for quality on both categories is 10% and the lower the figure, the better the performance. The threshold for speed is 60% (majors) and 70% (non-majors) and the higher the figure, the better the performance.
2.12 On those sites where planning permission was refused, the appeal performance is good. The Council’s assessment against the Government’s targets is set out in table 2:
Measure and type of Application |
Threshold and assessment period |
Spelthorne’s Performance |
Speed of Major Development |
60% (October 2022 to September 2024) |
100% N.B. The higher the % the better
|
Speed of non- Major Development |
70% (October 2022 to September 2024) |
99% N.B. The higher the % the better
|
Quality of Major Development * |
10% (April 2022 to March 2024) |
6 – 8.3%* and** N.B. The lower the % the better
|
Quality of Non-Major Development * |
10% (April 2022 to March 2024) |
1.6%* N.B. The lower the % the better |
* an additional 9 months is given to 31 December to allow for the receipt of appeal decisions.
** One appeal is being disputed with MHCLG and the outcome is awaited.
These statistics demonstrate the soundnessof decision makingby Planning Development Management (PDM) and that unsound decisions are not being made which would lead to unnecessary delays and costs to the delivery of new homes. However, close monitoring of the quality assessment for major applications is continuous due to the relatively small number of major applications received and the risk that the LPA could be the subject of Designation by Central Government. If this occurs, applicants may apply directly to the Planning Inspectorate for permission.
Housing deliverychallenges
2.13 In the 1990s, the Council used to provide traditional council housing. However in 1996, it was decided to transfer the council housing stock to what was then Spelthorne Housing Association and is now part of A2 Dominion. The main reason for the transfer of properties at the time was the need to bring the properties up to an acceptable state of repair, which was best done by an affordable housing provider. Since then, the Council has had a direct role in developing new homes, for e.g., The West Wing at Knowle Green, Benwell House, Churchill Hall and the former Bugle PH – see table 3 below. Fluctuation in the deliveryof new housing has been dictated by the economy and the availability of grant funding to subsidise affordable housing. The lack of affordable homes being provided in Spelthorne is a severe problem in Spelthorne and has become acute in recent years.
2.14 The Council’s Housing, Homelessness and Roughsleeping Strategy 2025 - 2030 contains three strategic priorities which contribute to achieving “residents having somewhere to call home, which is suitable and affordable, is fundamental to having a good quality of life and contributes directly to sustainable and cohesive communities.”
2.15 In commonwith many other local authorities in the South East, Spelthorne has a growing demand for genuinely affordable housing and is facing a number of key challenges. These include:
· Increasing numberson the Housing Register (currently over 2,600)
· Lack of availability of existing affordable housing
· High ratesof statutory homelessness
· High use of emergencyand temporary housingfor homeless households
· Increasing affordability issues (pay not keeping up with house prices)
· Affordable rented (80% of market rent)does not meet the needs of ourresidents
· Lack of new-build affordable housing (only 324 affordable units delivered via s106 agreements in last 5 years).
· Private sector landlords exiting the market due to upcoming changes in legislation, creating additional accommodation pressure
· The effectof our proximity to London
· Issues around viability of new affordable housing delivery
· Impact of immigration on housing demand in the area
· Key workeraccommodation
· Impact post COVID-19
· Wider economicimpacts in relationto housebuilding (construction costs, interest rates)
2.16 Further detailson the key challenges are contained in Information Document 3 at Appendix 3.
3.1 This sectionsets out the actions that the Councilhas already taken to increase housing delivery and the future actions required to continue this work. The Council is fully committed to working proactively to deliver the homes that Spelthorne needs, including a range of housing types and affordable housing.
3.2 It is acknowledged that the deliveryof new homes has a wider remit than just the Planning Service and requires actions to be undertaken by other Council services including the Housing Service and the Asset and Property Management Service.
What the Council has already done
3.3 The need for an up-to-date Local Plan is a corporate priority and will assist in boosting the borough’s housing supply as well as responding to housing needs, whilst balancing the objectives in the Local Plan, including Green Belt and environmental protection.
3.4 The Council submitted its draft Local Plan to the Secretary of State for Levelling up, Homes and Communities for independent inspection on 25 November 2022. As submitted, the Local Plan sought to meet the Borough’s development needs through a combination of intensifying development of brownfield land, growth within Staines–upon–Thames and releasing a small amount of Green Belt (0.7%) to provide family housing. The first three hearings were held on 23 – 25 May 2023, and a further six dates were planned for June 2023. Following an Extraordinary Council Meeting on 6 June 2023, where a motion was agreed to pause the remainder of the Local Plan examination hearings, the examination was paused.
3.5 Another Extraordinary Council Meeting was held on 14 September to consider a report which outlined three options on the future of the Local Plan. At the start of the meeting, a letter from the Minister of State for Housing and Planning was read out which outlined the Governments concerns that the Council may withdraw the emerging Local Plan from examination. This has resulted in the Government intervening in the Local Plan process under section 27 of the Planning and Compulsory Purchase Act 2004.
3.6 Following this, Councillors voted to extend the pause in the Examination timetable until the proposed changes to the National Planning Policy Framework had been published before determining the next steps. The revised National Planning PolicyFramework was published on 19 December 2023. Subsequently, at Environment and Sustainability Committee on 29 February 2024, the Committee resolved to propose to the Inspector to:
· Remove all Green Belt allocations from the LocalPlan with the exception of the two allocations that meet the need for Gypsy, Traveller and Travelling Showpeople.
· Keep all proposed flood risk sites but remove those at high risk of flooding and move some higherrisk sites to later in the Plan period (11-15years) to
allow the River ThamesScheme to be operational and effective, the design code to be completed, and subject to no resolute objection from the Environment Agency.
· Withdraw the Staines Development Framework as a core document.
3.7 The Councilwrote to the Inspector on 6 March2024 to make himaware.
3.8 In a meeting of Council on 18 July 2024 it was resolved that, in addition to what was resolved in the Corporate Policy & Resources Committee on 29 February 2024, to request a modification to add wording to the policies of the site allocations that are at risk from access and egress flooding issues.
3.9 On the 14 October 2024 SBC and the Environment Agency signed a statement of common ground (SOCG). The SOCG sets out agreement regarding what is the most appropriate modelling to be used in the Strategic Flood Risk Assessment, the Councils commitment to produce a Supplementary Planning Document or Supplementary Plan and agreed rewording of policy E3: Managing Flood Risk to be requested as a modification to the Inspector.
3.10 At a meeting on 24 October 2024 the Council resolved to:
1. Note that the Environmental Agency had signed a SoCG,
2. Agree to keep the Green Belt allocations in the Local Plan as submitted to the Planning Inspectorate on 25 November 2022
3. Agree to delegate authority to the Group Head of Place, Protection and Prosperity in consultation with the Chair of the Environment and Sustainability Committee, to undertake any further consultation required by the Planning Inspector; and
4. Agree to delegate authority to the Group Head of Place, Protection and Prosperity in consultation with the Chair of the Environment and Sustainability Committee, to prepare a main modification to the Local Plan, for the new policy on ‘Local Plan Early Review’.
3.11 Following the meeting of Council on the 24th of October the Chair of the Environment and Sustainability Committee, wrote a letter to the Planning Inspector to inform him of the outcome of the meeting and to request the resumption of the Local Plan Examination.
3.12 On 12 December 2024 the Council published the Notice of Examination Hearings resuming in January 2025 and included a series of documents on the Examination Website, providing up-to-date information for stakeholders, to support the hearings.
3.13 The Examination Hearings resumed on the 28 January 2025 and concluded on the 18 February 2025. Following this the Local Plan has now progressed to a Main Modifications Consultation which is live until the 15 May 2025. It is anticipated that the Local Plan will be formally adopted Autumn 2025.
3.14 As a result of the examination hearings, the Council is proposing through the Main Modifications to include an Immediate Review Policy which commits to producing an updated or replacement plan which will be submitted for examination no later than two years from the date of adoption of this Local Plan. The Immediate Review will consider the housing requirement for the whole Borough based on the most up to-date national guidance and monitor housing delivery, including the progress and implementation of sites to inform the review.
3.15 The adoption of the new Local Plan will support the delivery of new homes in the borough, through the allocation of development sites and the release of Green Belt for family homes. The new Local Plan projects the delivery of almost 10,000 homes up to 2039, although given the nature of the Housing Delivery Test, which takes an average of the past three years of housing delivery, it may take some time for the impact of the new Local Plan to be filter down into the results of the HDT.
3.16 The key change to consultation techniques is reaching out to our communities through digital engagement. Although traditional methods are still being used the majority of engagement is now done via online communication which has proven more effective and engaging in promoting planningpolicy consultations and opportunities to discuss major planning applications.
3.17 The Council uses its social media platforms to provide information and notifications regardingplanning consultations and schemes. The ‘Inovem’ platform has been used to consult the public on various planning consultations, including the Local Plan Regulation 19 consultation. The Council continues to write to all adjoining properties of a planning application received. Whilst this is done via traditional mail (as the email addresses are not known), all subsequent correspondence is electronic using *Idox Uniform.
3.18 The previous Housing Strategy 2020-25 set out an action plan on the delivery and monitoring of the strategy. These included enabling the delivery of more affordable homes, promoting independence and wellbeing to enable people to remain in their homes and preventing homelessness and rough sleeping. The strategy plan of actions has been delivered and the housing team analysed data which formed the basis for the new Housing, Homelessness and Rough Sleeping Strategy 2025-30. The housing service is under extensive pressure and experiences high demand for temporary accommodation and affordable housing provision. The new strategy seeks to address the affordable housing demand in the borough and to assist those sleeping rough.
3.19 The Council’sCapital Strategy states that it will help to delivertwo key goals contained in the Corporate Plan:
• To deliver much-needed housing in order to help reduce homelessness locally, increase affordable provision and help meet the overall need for additional homes.
• To regenerate our town centresso that we can contribute to the economic development of the Borough.
3.19 The Council formed its housing company, Knowle Green Estates (KGE), in 2016. KGE identified a need to promote the Council’s own affordable housing schemes, and KGE is the vehicle used to deliver them to residents. However in Autumn 2023 Spelthorne BoroughCouncil (SBC) took a decision not to undertake any directdevelopment. Nevertheless, due to historical failure by the private sector to deliver affordable homes, affordable housing continues to be a Council Corporate Priority and SBC remains focused on how it can assist in improving the supply of affordable, social and keyworker and private rental homes to address the needs of residents identified in the Council’s Housing Strategy.
3.20 The Council adopted a Development Delivery Strategy in October 2024 that will set some parameters to support the delivery of new housingon several of our sites via partnership arrangements with external organisations. Each site will be assessed individually with a bespoke delivery approach and objectives, which will be determined on the specifics of the site i.e. size, location, surrounding buildings, demographics.
Site |
App. No. |
Dwellings |
Occupation Date |
Churchill Hall, Churchill Way, Sunbury on Thames |
16/02045/FUL |
Feb 2019 3 rented dwellings |
28/09/18 |
Former Bugle PH, 73 Upper Halliford Road, Shepperton |
17/01028/FUL |
6 no. 2 bed and 2 no. 1 bed flats |
Feb 2019 |
Benwell House, Green St, Staines (now owned by KGE) |
17/01847/PDO |
7 units including 12 affordable units 22 x one bed, 35 x 2 bed |
April 2021 |
West Wing, Council Offices, Knowle Green, Staines TW18 1BX |
18/01267/PDO |
25 affordable rented residential units |
Occupied: December- 2021 - February 2022 (fully occupied). |
Improved DecisionMaking
3.16 The PlanningDM service has undertaken a number of initiatives to improve decision making and boost the timely delivery of housing. These include:
Offering more pre-application discussions to ensure issuesare addressed early.
The Planning DM Officers regularly undertake pre-application advice. In 2024 a total of 276 planning enquiries were dealt with. Early advice can help identify whether in principle a proposal is likely to be acceptable, the key planning issues and policies that need to be considered, where the applicant may need further specialist advice to help preparethe application and what changesmay be needed to any draft proposals.Such advice can save an applicant time in preparing the application and also the time taken by the Council to make a decision on it. In the case of proposals with little prospect of approval, early advice can avoid further abortive work. A good pre-application service will have a strong emphasis on front loading to reduce the time spent on decision making and use of planning conditions. This means a quicker turnaround can be achieved which subsequently can lead to the faster implementation of planning permissions for housing delivery. Some examples of development which were the subject of pre-application advice and which were amended and approved relatively quickly are: Wheatsheaf PH, Park Road, Stanwell 22/01417/FUL for 5 units,(16-18 High Street, Staines (23/01493/FUL) for 6 flats, the Renshaw development for 391 flats (22/00591/FUL), the Sunbury Cross Ex-Services Association Club, Sunbury for 47 flats (21/01801/FUL) and the Artrium, 31 - 37 Church Road Ashford for 9 flats (24/00832/FUL).
Use of Planning Performance Agreements
The Council offers planning performance agreements (PPAs) for major development proposals, which often involve a large quantum of housing units. This is one of the factors that might otherwise put developers off putting in an application in the borough. However, it gives absolutely no guarantee that the application will be recommended for approval. In previous years, the Planning DM service has received a positive take up on PPAs for larger schemes, for example, Shepperton Studios.A PPA covers pre-application advice through to the planningdecision being made. It sets out timescales within which meetings will take place and a report will be presented to the Planning Committee which gives the developer certainty around timeframes for a decision. They have enabled the DM planning officers to make use of expert advisors to assist on complex issues in the consideration of the planning. Whilst no PPAs have been agreed in the past year, officers will continue to push for these with developers on larger or complex schemes.
Revised Website
The planning pages of the website are constantly under review and recent changes have been undertaken to reflect new news, procedures and legislation. The DM service received a government grant last year to assist in improving the ICT experience. Work has been taking place on various internal changes to enable new TPOs to be processed digitally and additional work is being planned for this year. This will help residents, applicants and third parties obtain up to date information about all aspects of the Planning Service.
Consultations on Emerging PlanningProposals
In March 2022, the Consultations on Emerging Planning Proposals guidance was agreed by the Corporate Policy and Resources Committee (CPRC). This was updated and agreed by the Environment and Sustainability Committee on 18 June 2024. The guidance advises developers to undertake early engagement with the Community (including ward councillors) on the larger development proposals before submitting their applications to the Local Planning Authority. This follows guidancein the NPPF at paragraph 39 which advises that ‘early engagement has significant potential to improve the efficiency and effectiveness of the planning application system for all parties. Good quality preapplication discussion enables better coordination between public and private resources and improved outcomes for the community’. The advice in this process has been taken on board by some applicants. This process is being monitoredto assess its impact and the first monitoring report was considered by the E&S Committee in June 2024.
Presentations to Councillors on major planningapplications
Presentations to members on larger complex schemes, usually at the pre- application stage, have taken place a number of times over recent years.
These enable Councillors to view the proposals at an early stage before they are made public, to ask questions and clarify issuesand raise concerns, which need to be addressed. To avoid risk of pre-determination, Councillors do not give an opinion at the meetings. Whilst there have been none over the past year, Planning DM officers do have a procedure to make presentations to Councillors on complex planning applications after the Planning Committee agenda is made public and before the Committee meeting. This gives the Councillors an opportunity to receive a full explanation of proposals and a summary of the planning position, to ask questionsand to seek clarification on issues but not to reach a decision.
The CommunityInfrastructure Levy (CIL)
The Community Infrastructure Levy (CIL) was implemented on 01 April 2015. CIL allows the Council to raise funds from some forms of new development to contribute towards both local and strategic infrastructure, to support development in the Borough. The management of the CIL process is the responsibility of the Council’s Infrastructure Delivery Coordinator. The Council has a part time CIL administrator to resource the collection process, allowing the Infrastructure Delivery Coordinator to focus on the governance of spending the Levy and coordinating spending alongside the implementation of the Council’s new Local Plan. In 2019 the Council purchased new dedicated CIL software (Exacom) which has improved the monitoring of CIL and s106 agreements. Moving forward it will be important for the Council to ensure that adequate infrastructure is in place to support the delivery of housing. The Infrastructure Delivery Plan (IDP), which is a live document, assesses the existing infrastructure provision, the current shortfall and identifies the existing and future needs and demands for the borough to support new development and a growing population.
Considering compulsory purchase powers to unlock suitablehousing sites
The Council has the option to utilise Compulsory Purchase Powers to help unlock potential development sites. In Staines town centre the Council has worked with developers to help unlock areas of land to enable larger schemes. Developers acquired 15 London Road (adjacent to the 17-15 Berkeley Homes site) and planning permission granted to incorporate this small site into the Berkeleys’ scheme. This is currently nearing completion. Other developers were previously actively seeking to acquire 116-120 High Street (adjacent to the Charter Square development), following the Council’s engagement but the planning application was refused permission and dismissed on appeal. Part 4 of the Planning and Infrastructure Bill 2025 has introduced significant reforms to compulsory purchase powers and process in the UK. The key aim is to expedite infrastructure development and create a simpler process for land acquisition, which will enable authorities to make greater use of their compulsory purchase powers. For registered providers, these changes could allow a more efficient process for land acquisition. Once the proposals have become law, the Council will have the opportunity to a engage in compulsory purchase to assist housing delivery.
Using Brownfield Registers to grantpermission in principle to previously developed land
Spelthorne publishes an updated brownfield register annually. This identifies all brownfield sites appropriate for residential development. The register includes relevant sites that have been submitted through Spelthorne’s Strategic Land Availability Assessment (SLAA) or appropriate sites which meet the criteria. The Council will also consider in due course whether any of the sites will be moved to Part 2 of the Brownfield Register which will effectively grant permission in principle. This will need further consideration and would be the subject of a prior consultation process.
Encouraging the development of small sitesand higher site densities
The Council’s adopted Core Strategyseeks to encourage high density housing in certain locations under policy HO5. Within Staines Town Centre, development should generally be above 75dph where it is demonstrated that the development complies with the design policy EN1, particularly in terms of its compatibility with the character of the area and is in a location that is accessible by non-car-based modes of travel. Within Staines-Upon-Thames, developments have already been approved at over 300 dph (phases1A and 1B- former Majestic House Site, now known as London Square) which is complete, 15-51 London Road (Berkeleys scheme), which is under construction, the Renshaw site and the scheme at Elmsleigh Road (Fairview Homes).
Councillor Trainingon Planning Issues
Planning officers provide regular training seminars to all councillors. A full programme is delivered to councillors following the elections and regular updates are given throughout their term as councillor. Planningtraining is also given to new councillors elected part way through the four year term. The training has covered the following areas:
· Planning in the Borough contextand the role of the Planning Committee.
· Probity, predetermination and predisposition in planning
· The Planning Code
· Decision making
· Design in the planning process
· Planning enforcement and appeals
· How to approachthe determination of planning applications and pitfalls
· Green Belt (twosessions)
· Flooding
· PermittedDevelopment
· Use Classes Order
· Minerals
· County planning
· Transportation
· Planning and Infrastructure Bill 2025
Planning OfficerTraining
Planning and Enforcement Officers undertake regular training on a range of planning issues and othermatters where relevant in order to keep abreast of developments, many of these are undertaken online since Covid lockdown. This particularly relates to new legislation and procedures. This will continue to be an on-going and necessary requirement of their jobs and for some officers, their membership of the Royal Town Planning Institute.
Simplifying conditions discharge phasedon approved sites,and standardised conditions reviewed
A review of all planning conditions was previously undertaken by senior planning officers. This has resultedin the streamlining of conditions to ensure that they meet up to date guidance on the use of conditions and to safeguard against their use where other non-planning legislation would be more appropriately employed. Conditions are constantly being reviewed and updated where appropriate to improve the planning process.
Ensuring evidenceon a particular site is informed by an understanding of viability
The Council’s Local Plan requiresall proposals of 15 dwellingsor more and all sites in excess of 0.5 hectares include to provide 50% affordable housing. Where developments fall short of this requirement, an independent viability assessment would be submittedand assessed on an open book basis. This is a complex area where specialist advice is required, and planning officers and councillors have undergone training on this.
Technology
Over the past few years, the Planning DM section has accelerated its use of technology in the processing of planning applications. This includes:
· No paper files, all processing is via the Idox UnformIT system.
· The use of Idox Enterprise for the “in-tray” process of processing the cases.
· All decisionnotices are automatically emailed to theapplicant.
· All correspondence is sent electronically (except where an email address is not available).
This is under constant review with improvements in processes as and when new procedures and legislation are introduced. So far, the government grant has been used to improve our online data, e.g., tree preservation orders (TPO) to enable the data to be easily available and for the making of TPOs to be streamlined. The use of technology has greatly assisted in processing applications more quickly by removing all paperbased files and using technology for all means of file sharing and communication (except the initial neighbour notification on planning applications).
4.1 The Council will continue to positively look for further opportunities to increase its housingdelivery and will work closelywith the relevantCouncil services and external organisations to achieve this.
4.2 As part of the new Local Plan the Council will seek to boost housingsupply and delivery. The new Local Plan will review and update existing policies to ensure sustainable development comes forward.
4.3 The StrategicLand Availability Assessment (SLAA) is a key piece of evidence for the new Local Plan and will be updated on a regular basis to ensure that the position on land supply is up to date. The Council is in the process of updating the SLAA for the current year. In line with Planning Practice Guidance, officers are proactively identifying sites, including publicly owned land and brownfield land, for development to ensure that potential supply is exhausted. The Council has an open-ended call for sites on its website whereby landowners or site promoters can submit potential development sites for consideration in the next iteration of the SLAA[1].
4.4 The SLAA informs the policies on housing in the new Local Plan and acts as the startingpoint in determining which sites will be allocated. The Council has also produced an updated housing trajectory (Jan 2025) which reflects the most up to date information available. It combines information on past completions, existing planning permissions and identified housing allocations from the new Local Plan to illustrate projected housing supply over the plan period. Moving forward the Council will work with stakeholders to ensure that suitable and available sites come forward at particular points in the plan period.
4.5 It is estimated that the five year housingland supply in the Boroughis currently 3,149 units, this equates to 4.2 years supply.
4.6 Upon anticipated adoption in Autumn 2025 the Local Plan will release a further 834 units from the Green Belt at this point it is projected the Council will then have a five-year supply of housing with the Green Belt sites being tested as part of the Local Plan examination.
4.7 Of the sites identified in the Housing Trajectory (Jan 2025), approximately 2,506 are expected to come forward within the next 5 years and 1,676 are expected to come forward within the next four years subject to planning permission being granted.
4.8 The Planning Development Management Service has recently been awarded a grant of £100,000 to enable the service to ensure improved access to planning data. Officers are currently workingwith the Department of Housing, Communities and Local Government on the programme for spending the grant. Whilst this, in itself, will not speed up housing build out rates, the improved flow of data information will assist developers and the local community in having all the relevant information easily available throughout the planning process. The officers have commenced work on the changes in collaboration with other councils and the completed work is expected around the end of 2025.
Decision Making
4.9 Table 7 in Appendix 2 shows, in the finalcolumn, the consequences resulting from the Housing Delivery Test for the current year. The consequence is shown to be a housing delivery test below the required 75%, leading to Spelthorne being required to produce an Action Plan. We will also have to apply a 20% buffer to our housing supply and consequently there will be a presumption in favour of sustainable development. T his means that planning permission should be granted unless the harm caused by the application significantly outweigh the benefits.
4.10 The term tilted balance is usedto define this passage of policy because when engaged, the tilted balance should change the ‘balancing exercise’ which the decision-taker (the planning officer, inspector or secretary of state) makes when deciding whether or not to grant planning permission; from a neutral balance where if the harms outweigh the benefits planning permission is usually withheld, to a tilted balance where the harms should significantly and demonstrably outweighthe benefits for permission to be withheld. Similarly on planning appeals, inspectors will give due regard to the presence of the presumption in favour of sustainable development. This means that on balance, a greater number of appeals may be allowed. This highlights the importance of not only boosting housing delivery but of having an up-to-date Local Plan to ensure that needs can be met through the identified supply.
4.11 The Council is also exploring and investigating the potential options for Local Development Orders (LDOs) in supporting housing delivery. LDOs are a planning tool introduced by the Government in 2004 intended to simplify and accelerate the planning process for specific types of development in defined areas.
4.12 The table below shows a projection of the numberof homes requiredand the anticipated number of homes delivered by 2024. The information set out provides a conservative estimate of delivery based on average completions over the previous three years. This does not take into account the measures proposed by the Council to boost housingdelivery, such as the Local Plan or Development Management controls. Anticipated completions are therefore expected to be higher than the very cautious estimate below.
Table 4 Spelthorne – Housing DeliveryTest 2025 projected result
No of homes required |
Total homes required |
No of homes delivered |
Total homes delivered |
HDT Test % |
Consequence |
|||||
2022-2023 |
2023-2024 |
2024-2025 |
|
2022-2023 |
2023-2024 |
2024-2025 |
|
|
|
|
611 |
618 |
631 |
1,860 |
138 |
287 |
206 |
631 |
34% |
Action Plan + 20% Buffer + Presumption |
|
Table 5 Improving DecisionMaking
Action |
Service |
Date |
To review the standard planning conditions. |
Planning Development Management |
Ongoing |
To continue to review the discharge of planning conditions to speed up the process. |
Planning Development Management |
Ongoing |
To continue to liaise with applicants following planning permission to speed up procedures and to implement service improvements especially the discharge of planning conditions, to enable an early start on site as possible. |
Planning Development Management |
Ongoing |
To review and monitor the impact of reverting back to the three year statutory time period on planning permissions. |
Planning Development Management |
Ongoing |
To continue to improve planning performance on speed of decision making (currently at 99% - 100%) |
Planning Development Management |
Ongoing |
To continue to improve planning performance on quality of decision making. |
Planning Development Management |
Ongoing |
To continue to improve the way of working in respect of planning conditions. |
Planning Development Management Environmental Health |
Ongoing |
To continue to provide ongoing Member training particularly in relation to housing delivery. |
Planning Development Management |
Ongoing |
To continue to provide on-going planning officer training. |
Planning Development Management |
Ongoing |
To continually refine the programme of improving data provision in Planning DM. |
Planning Development Management |
Ongoing |
To further refine data improvement and the programme of Enterprise measures for DM staff to manage workloads and performance, improve the use of resources and efficiency / performance. |
Planning Development Management |
Ongoing |
To continue to develop and offer a proactive pre-application service to support the delivery of sustainable development. |
Planning Development Management |
Ongoing |
Table 6 Supporting Wider Housing Opportunities
Action |
Service |
Date |
To continue dialogue with developers and landowners to build out rates and obtain information on barriers to deliver housing. |
Strategic Planning |
On-going |
To work with site promoters and other stakeholders to deliver the Local Plan and site allocations. |
Strategic Planning |
On-going |
Action |
Service |
Date |
To continue to seek to achieve the maximum amount of affordable housing. |
Planning Development Management Housing Strategy |
On-going |
To facilitate the delivery of housing on several Council sites via partnership arrangements with external organisations |
Assets |
On-going |
CIL and S106 agreements – To continue to improve processes and improve monitoring. |
Strategic Planning |
On-going. Exacom software will assist in processing information. |
Next Steps
4.13 The futureactions identified will be implemented and monitored over the next year by Planning DM, Strategic Planning, Assets and Housing Strategy. The Housing Delivery Test results will be issued for each authority on a rolling annual basis. If Spelthorne does not meet the test in future years, Housing Delivery Test Action Plans will continue to be produced by Planning Development Management.
4.14 This Action Plan will be reported to the Planning Committee for information.
4.15 The Councilwelcomes any suggestions to improve the delivery of housing in Spelthorne.
4.16 It is proposed that this plan will be made publiclyavailable on the Council’s website.
Esmé Spinks
Planning Development Manager
Jane Robinson
Interim Strategic Planning Manager
Spelthorne Borough Council, April 2025
Information Document 1
1. Planning PolicyContext
National Policy
1.1 The Government is committed to levelling up across the country, building more homes to increase home ownership, empowering communities to make better places, restoring local pride and regenerating towns and cities. The issue over housing deliveryand any possible changes to the current methodology of housing provision for local planning authorities (currently calculated at 631 dwellings per year) has been the subject of much debate in the planning press. On 11 March 2025, the Planning and Infrastructure Bill was introduced to Parliament. The Bill is a key tool in the government's plans to build 1.5m homes and proposes various reforms, including those around compulsory purchase orders, strategic planning and development corporations. It is presently passing through parliamentary procedures having passed through two readings.
1.2 The Government, has subsequently, reinforced its objective to significantly boost the supply of new homes and making the local authority more accountable for delivery in their area by publishing the following:
· A revisedNational Planning PolicyFramework (NPPF) December 2024
· Planning PracticeGuidance (PPG) on Housing Supplyand Delivery December 2024
· Housing and economic needs assessment, February 2025
· Planning and Infrastructure Bill, March 2025
1.3 The methodology for calculating the Housing Delivery Test is set out in the Housing DeliveryTest Measurement Rule Book 2024. It measures the number of net homes delivered against the number of homes required over a rolling three year period.
1.4 The Government is, therefore, committed to the significantly boosting the delivery of more new homes nationally through their economic and housing growth agendas. To this end they have introduced a number of measures and reforms to the planning system intended to deliver more housing, improve housing affordability and remove barriersto development. Local planning authorities (LPAs) are challenged to be more proactive in increasing the speed and quantity of housing supply to meet the identified housing needs of their local area.
.
Information Document2
2. Housing DeliveryAnalysis
2.1 The HousingDelivery Test (HDT) wasintroduced by the Government in 2018 as a monitoring tool to demonstrate whether local areas are building enough homes to meet their housing need. The HDT, which was published in December 2024 updates the previous result published in January 2023. This compares the number of newhomes delivered over the previousthree years with the authority's housing requirement. In the case of Spelthorne, the housing requirement is the minimum annual local housing need figure (631 dwellings per annum as of April 2025). The calculation is given as:
𝐻𝐷𝑇(%) =
𝑇𝑜𝑡𝑎𝑙 𝑛𝑒𝑡 ℎ𝑜𝑚𝑒𝑠 𝑑𝑒𝑙𝑖𝑣𝑒𝑟𝑒𝑑 𝑜𝑣𝑒𝑟 𝑡ℎ𝑟𝑒𝑒 𝑦𝑒𝑎𝑟 𝑝𝑒𝑟𝑖𝑜𝑑
𝑇𝑜𝑡𝑎𝑙 𝑛𝑢𝑚𝑏𝑒𝑟 𝑜𝑓 ℎ𝑜𝑚𝑒𝑠 𝑟𝑒𝑞𝑢𝑖𝑟𝑒𝑑 𝑜𝑣𝑒𝑟 𝑡ℎ𝑟𝑒𝑒 𝑦𝑒𝑎𝑟 𝑝𝑒𝑡𝑖𝑜𝑑
2.2 The HDT will be used to determine the buffer to apply in housing supply assessments and whether the presumption in favour of sustainable development should apply. The HDT has the following consequences:
· Where housing delivery over the previous three years has been less than 95% of the housing requirement, LPAs should prepare an action plan setting out the causes of under deliveryand the intended actions to increase delivery;
· Where deliveryhas 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;
· Where deliveryhas been less than 75% of the housing requirement, the NPPFs presumption in favour of sustainable development will apply.
2.3 In the 2023 HDT measurement, published in Dec 2024, there were 59 councils below 75% and consequently now face the ‘presumption in favour of sustainable development’. The 2023 housing delivery test figure for Spelthorne is 61%, meaning it now faces this consequence. This calculation is based on the data set out in Table 7.
No of home required |
Total homes required |
No of homes delivered |
Total homes delivered |
HDT Test % |
Consequence |
||||
2020-2021 |
2021-2022 |
2022-2023 |
|
2020-2021 |
2021-2022 |
2022-2023 |
|
|
|
403 |
611 |
618 |
1632 |
518 |
336 |
138 |
992 |
61% |
Presumption in favour of development |
2.4 As a consequence, Spelthorne is required to produce an Action Plan within a period of 6 months of publication of the HousingDelivery Test measurement.
2.5 Spelthorne BoroughCouncil (SBC) is responding to this challenge and has the ambition, recognised across its key strategic documents, to increase and accelerate the delivery of new housing across the district. The allocation of land to accommodate a minimum of 9,465 new homes (631 dwellings per annum) is being made through the emerging Local Plan, which completed its Examination Hearings in February 2025. Following this the Local Plan has now progressed to a Main Modifications Consultation which is live until the 15 May 2025. It is anticipated that the Local Plan will be formally adopted Autumn 2025.
2.6 As a result of the examination hearings the Council is proposing through the Main Modifications to include an Immediate Review Policy which commits to producing an updated or replacement plan which will be submitted for examination no later than two years from the date of adoption of this Local Plan. The Immediate Review will consider the housing requirement for the whole Borough based on the most up to-date national guidance and monitor housing delivery including the progress and implementation of sites to inform the review.
2.7 The PPG advises that:
“The action plan is produced by the local planning authority where delivery is below 95% of their housingrequirement. It will identify the reasons for under- delivery, explore ways to reduce the risk of furtherunder-delivery and set out measures the authority intends to take to improve levels of delivery.”.
2.8 The table on the following page sets out the position for all Surrey boroughs and districts. It can be seen that at presentsix out of the eleven authorities are required to produce a housing delivery action plan. The possible consequences are based on the following:
95% = Action Plan
85% = Action Plan + 20%buffer
75% = Action Plan + 20% buffer + presumption in favour of development
Local Authority |
No of homes Required |
Total Homes required |
No. of homes delivered |
Total Homes Delivered |
HDT Test % |
Current Consequence 2022 HDT Measurement |
||||
|
2020- 2021 |
2021- 2022 |
2022-2023 |
|
2020- 2021 |
2021- 2022 |
2022-2023 |
|
|
|
Elmbridge |
421 |
641 |
647 |
1709 |
346 |
768 |
240 |
1354 |
79% |
20% Buffer + Action Plan |
Epsom and Ewell |
384 |
577 |
576 |
1537 |
142 |
117 |
317 |
576 |
38% |
Presumption + 20% Buffer + Action Plan |
Guildford |
374 |
562 |
562 |
1499 |
857 |
738 |
704 |
2300 |
153% |
None |
Mole Valley |
226 |
339 |
339 |
903 |
244 |
248 |
217 |
709 |
78% |
20% Buffer + Action Plan |
Reigate and Banstead |
310 |
461 |
461 |
1232 |
820 |
728 |
686 |
2234 |
181% |
None |
Runnymede |
340 |
511 |
509 |
1361 |
390 |
557 |
598 |
1546 |
114% |
None |
Spelthorne |
403 |
611 |
618 |
1632 |
518 |
336 |
138 |
992 |
61% |
Presumption + 20% buffer + Action Plan |
Surrey Heath |
191 |
286 |
283 |
761 |
395 |
370 |
403 |
1168 |
153% |
None |
Tandridge |
430 |
644 |
642 |
1716 |
162 |
246 |
308 |
716 |
42% |
Presumption + 20% Buffer + Action Plan |
Waverley |
394 |
592 |
617 |
1603 |
682 |
823 |
969 |
2475 |
154% |
None |
Woking |
232 |
4346 |
361 |
939 |
176 |
386 |
649 |
1211 |
129% |
20% Buffer + Action Plan |
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 adverseimpacts or where specificpolicies in the National PlanningPolicy 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 balancetherefore increases the prospect of planning permission being granted because it ‘tilts’ the balance in favour of approving an application.
Spelthorne’s CurrentHousing Land SupplyPosition
2.11 The Council’s housing target basedon our local housing need is currently 631 dwellings per annum as of April 2024 and this comprises the basis for calculating the five-year supply of deliverable sites. In using the local housing need figure of 631 as the starting point for the calculation of a five year supply, it must be borne in mind that this does not represent a target as it is based on unconstrained need. The Council is planning to meet the local housing need figure of 631 homes per annum through its emerging Local Plan. The Strategic Land Availability Assessment and Housing Trajectory are updated regularly to consider all suitable, available and achievable land in the Borough to help meet development needs.
2.12 The Council has assessed the availability of housing in its Strategic Land Availability Assessment (SLAA) 2022. The Authority Monitoring Report (AMR) 2024 containsa housing trajectory and it is this that has been used as the baseline to inform the supply of sites.There has, however, been some updates to some of the sites and figures following consultation with the Councils Development Management and the Assets teams with the most recent Housing Trajectory being published in January 2025.
2.13 Due to the requirement set out in paragraph 79 of the NPPF to apply a buffer of 20% where there has been under delivery of housing over the previous three years, the local need housing figure is 757 (631 + 20% buffer) dwellings per annum. The effect of this increased requirement is that the identified sites only representsome 4.2 years supply and accordingly the Council cannot,at present, demonstrate a five year supply of deliverable housing sites. However, upon anticipated adoption in Autumn 2025 the Local Plan will release a further 834 units from the Green Belt at this point it is projected the Council will then have a five year supply of housing with the Green Belt sites being tested as part of the Local Plan examination.
2.14 As a result, current decisions on planning applications for housing development need to be based on the “presumption in favour of sustainable development ” approach as set out in paragraph 79 of the NPPF (2024) as referred to above.
Five Year Supply Position |
|
Need April 24 – March 29 = (5 x 631) = |
3155 |
Buffer at 20% = (3155 x 1.2) = |
3786 |
Annual need including 20% buffer = |
757 |
Projected 5 year supply = |
3149 |
Housing supply (3149 / 3786 * 5) = |
4.2 years of supply |
Spelthorne's HousingPerformance
2.15 A large proportion of the existing housing stock was built between 1920 and 1970. A very high proportion is owner-occupied and comprises mainly detached, semi-detached and terraced housing. The 2021 Census indicates that approximately 13% of the stock is social housing managed by Registered Social Landlords (RSLs) with a similar amount of private rented accommodation. Some 2% of the stock is vacant.The Housing completions (net) by sector April 2009-March 2024 is set out in Appendix 4 Table19.
2.16 House prices have continued to fluctuate. Table 10 illustrates changes in annual average (median) house prices over the last eleven years according to latest available data. Data on house prices is derived from actual sale prices which can show significant variation over time, particularly when the total volume of sales is small. The information should therefore be seen only as a guide to relative movement in house prices by type.
2.17 All affordable housing for rent is managed by RSLs and for each scheme granted planning permission the Council initiallyhas 100% nomination rights for first lets with 75% thereafter. One important contextual indicator relating to the achievement of affordable housing policies is the size and composition of the Housing Register. Since 2009 the Council has operated a Choice Based Lettings scheme which significantly extends the opportunities for families on the Housing Register.
Type of Dwelling |
||||
|
Detached |
Semi- detached |
Terraced |
Flat/Maisonette |
March 2013 |
£413,453 |
£288,940 |
£235,190 |
£167,183 |
March 2014 |
£452,436 |
£316,491 |
£257,380 |
£182,821 |
March 2015 |
£516,173 |
£361,784 |
£293,173 |
£208,525 |
March 2016 |
£592,566 |
£414,053 |
£333,480 |
£234,909 |
March 2017 |
£621,268 |
£430,119 |
£346,341 |
£249,377 |
March 2018 |
£626,016 |
£436,594 |
£350,260 |
£248,872 |
March 2019 |
£623,430 |
£366,785 |
£346,192 |
£242,583 |
March 2020 |
£622,124 |
£436,085 |
£348,964 |
£238,159 |
March 2021 |
£650,856 |
£454,713 |
£366,415 |
£241,539 |
March 2022 |
£720,721 |
£498,707 |
£394,531 |
£258,075 |
March 2023 |
£791,193 |
£521,984 |
£413,094 |
£262,032 |
March 2024 |
£744,681 |
£496,331 |
£397,435 |
£267,250 |
% change 2013-2024 |
80% |
72% |
69% |
60% |
Source: http://landregistry.data.gov.uk/app/ukhpi/explore2
![]() |
2 The average house prices figures used within the Housing Delivery Test Action Plan are taken from the UK House Price Index which is on the Land Registry Government website (http://landregistry.data.gov.uk/app/ukhpi/explore). Here you can source a variety of house price statistics, such as the average house price by property type e.g. detached houses / flats and maisonettes and percentage change (yearly) by type of property. The average prices above are at the average for the whole Borough.
2.18 The housingtrajectory (Table 11) shows housingcompletions for the last seven years and anticipated delivery for the next 15 years to 2039/40. It combines information on past completions, existing planning permissions and identified housing sites from the Strategic Land Availability Assessment 2022 to illustrate projected housing supply going forward into the new Local Plan period. Table 11 is based on monitoring information collected in 2023/24 with monitoring data for 2024/25 in the process of being formalised and will inform the next iteration of the plan.
2.19 Net completions for the previous seven years are recorded and broken down into four categories – conversions, change of use, small sites with fewer than 5 dwellings(net) and large sites of 5 or more dwellings (net). Data on housing completions by bedroom are set out in Table 11. Data for projected completions in future years is recorded on the same basis in Table 11.
2.20 Anticipated completions for the year 2024/25 are 203[HB1] . Anticipated completions for the year 2025/26 are 837.
2.21 For the period from 2024/25 to 2039/40 the estimatednet annual completions are based on the following components:
· Dwellings under construction
· Dwellings with planning permission (unimplemented)
· Allocations
· Sites of 5 or more dwellings identified in the SLAA 2022.
· Estimates for dwellings providedby conversions, changeof use and from small sites (fewer than 5 units net)
2.22 Given the past trends in the Borough’s implementation rates of planning permissions it has been assumed that most remaining unimplemented permissions will be completed over the next five year period from 2024. However, a small non-implementation factor of 5% has been applied on a precautionary basis to allow for permissions which expire.
2.23 Another component of the trajectory is based on estimates and is made up of four elements. The first, dwellings provided by conversion of existing residential properties into smaller units, is calculated from the average annual net provision over seven years. The second element derives from the change of use from non- residential property to residential, such as a shop to a dwelling. Again, the estimate is based on the annual average net provision over a seven year period. Traditionally this was always a small componentof the overall total. However,the significant increase in large office to residential conversions as a consequence of the Government’s relaxation of planning controls has significantly increased this source of supplywhich is now estimated separately. It is not known how long this trend will continue, so whilst the trajectory takes account of known schemes, the longer term estimate for this source of dwelling supply remains cautious having regard to current levels of provision.
2.24 The fourth element relates to new build dwellings on sites delivering fewer than fivedwellings (net). This is the threshold for sites considered to be too small to be reliably identified in the SLAA. Currently there is no evidence from completions data to suggest that this source of new housing is likely to decline over the plan period and the estimate of 43 units per annum is taken from the SLAA and Housing Trajectory Jan 2025. This is based on the average annual net completions figure for the last twelve years and is included in the trajectory in years 5-10 and 10-15.
2.25 The final component of supply is that providedby the Housing Trajectory Jan 2025.Every site of 5 or more dwellings listed in the study is assessed on a likely implementation date based on the criteria of whether a site is developable and deliverable over the next fifteen years broken down into three five year periods.
2.26 At the time the Local Plan was submitted for Examination, the Council was planning to meet the Local Housing Need derived from the standard method for calculating housing need. The Council was unable to meet its housing needs in the urban area alone, so the release of a small amount of Green Belt was proposed. The Local Plan which was submitted for Examination included a 0.7% release of Green Belt alongside making an efficient use of brownfield land and maximising densities in sustainable locations.
2.27 The number of dwellings completed, under construction and with outstanding planning permission at 31 March 2024 is shown in Table 12.
|
Conversion/ Change of Use |
Small sites (less than 0.4ha) |
Large sites (0.4ha or greater) |
Total dwellings – all sites |
Gross Completions (2023-24) Losses (2023-2024) |
130 7 |
96 12 |
80 0 |
306 19 |
Net Completions |
123 |
84 |
0 |
287 |
Units under construction |
38 |
157 |
1314 |
1509 |
Units not started on sites under construction |
0 |
0 |
0 |
0 |
Units with outstanding planning permissions (net) |
35 |
141 |
31 |
207 |
Total units outstanding |
73 |
298 |
1345 |
1716 |
(Source: In house monitoring)
.
Year |
Schemes approved in year |
Units approved in year |
Starts this year |
Total under construction |
2023-2024 |
54 |
577 |
490 |
1509 |
2022-2023 |
57 |
632 |
1125 |
1319 |
2021-2022 |
58 |
443 |
172 |
345 |
2020-2021 |
52 |
242 |
212 |
538 |
2019-2020 |
63 |
756 |
138 |
982 |
2018-2019 |
69 |
998 |
270 |
1092 |
2017-2018 |
89 |
1085 |
821 |
1010 |
2016-2017 |
54 |
654 |
411 |
476 |
2015-2016 |
68 |
581 |
381 |
439 |
2.28 Table 13 shows the rate of approved residential schemes in Spelthorne since 2015-16. This highlights the Council’s rate of approval and also shows the number of units started each year by developers. Starts each year are generally much lower than the number of approvals, indicating that whilst the Council is positively responding to the challenge of boosting its role in housing delivery internally, externalfactors which are beyond the control of the Council will influence the decision to implement a scheme.
|
|
Total Dwellings (Gross) |
|
|
Losses (ii) |
|
|
|
Net Completions |
|
|
|||||
Year |
1 bed |
2 bed |
3 bed |
4 bed |
Total |
1 bed |
2 bed |
3 bed |
4 bed |
Total |
1 bed |
2 bed |
3 bed |
4 bed |
Total |
Running Total |
2009-2010 |
77 |
166 |
26 |
27 |
296 |
2 |
36 |
43 |
4 |
85 |
75 |
130 |
-17 |
23 |
211 |
211 |
2010-2011 |
70 |
112 |
19 |
11 |
212 |
3 |
21 |
43 |
6 |
73 |
67 |
91 |
-24 |
5 |
139 |
350 |
2011-2012 |
53 |
91 |
90 |
28 |
262 |
3 |
43 |
52 |
5 |
103 |
50 |
48 |
38 |
23 |
159 |
509 |
2012-2013 |
66 |
98 |
38 |
20 |
222 |
2 |
6 |
42 |
2 |
52 |
64 |
92 |
-4 |
18 |
170 |
679 |
2013-2014 |
66 |
98 |
19 |
15 |
198 |
2 |
2 |
1 |
2 |
7 |
64 |
96 |
18 |
13 |
191 |
870 |
2014-2015 |
79 |
172 |
48 |
34 |
333 |
42 |
8 |
8 |
10 |
68 |
37 |
164 |
40 |
24 |
265 |
1,135 |
2015-2016 |
89 |
166 |
71 |
29 |
355 |
2 |
6 |
31 |
8 |
47 |
87 |
160 |
40 |
21 |
308 |
1,443 |
2016-2017 |
98 |
189 |
50 |
37 |
374 |
6 |
11 |
8 |
2 |
27 |
92 |
178 |
42 |
35 |
347 |
1,790 |
2017-2018 |
108 |
111 |
36 |
32 |
287 |
8 |
12 |
6 |
11 |
37 |
100 |
99 |
30 |
21 |
250 |
2,040 |
2018-2019 |
164 |
92 |
33 |
21 |
310 |
3 |
4 |
8 |
6 |
21 |
161 |
88 |
25 |
15 |
289 |
2,329 |
2019-2020 |
122 |
98 |
20 |
8 |
248 |
1 |
6 |
11 |
2 |
20 |
121 |
92 |
9 |
6 |
228 |
2,557 |
2020-2021 |
294 |
327 |
30 |
5 |
656 |
0 |
6 |
7 |
4 |
17 |
294 |
32 |
23 |
1 |
639 |
3,196 |
2021-2022 |
92 |
114 |
4 |
0 |
210 |
0 |
0 |
5 |
0 |
5 |
92 |
114 |
-1 |
0 |
205 |
3401 |
2022-2023 |
90 |
48 |
7 |
5 |
150 |
0 |
4 |
4 |
4 |
12 |
90 |
44 |
3 |
1 |
138 |
3539 |
2023-2024 |
165 |
101 |
18 |
22 |
306 |
1 |
4 |
12 |
2 |
19 |
164 |
97 |
6 |
20 |
287 |
3,826 |
2009-2024 (i) |
1633 |
1983 |
509 |
294 |
4419 |
75 |
165 |
281 |
68 |
593 |
1558 |
1814 |
228 |
226 |
3,826 |
27,875 |
(i) Period coveredby the Spelthorne Core Strategyand Policies DPD.
(ii) Losses of residential units (through redevelopment, conversion and to other uses) are accountedfor in the year in which a development is commenced on the site.
2.29 From 2009 to 2024 the average density for all completed schemes was 79 dwellings per hectare. Table 15 shows that therehas been a notable increase towards higher density development over the past three years.
Year |
Sites completed in year |
Number of dwellings on completed |
Average density of completed sites |
% of dwellings completed at different density ranges |
||
|
|
sites |
|
<35 |
35-75 |
>75 |
2009-2010 |
40 |
235 |
63 |
3% |
67% |
30% |
2010-2011 |
38 |
272 |
64 |
7% |
52% |
41% |
2011-2012 |
33 |
260 |
39 |
7% |
89% |
4% |
2012-2013 |
38 |
146 |
44 |
18% |
42% |
40% |
2013-2014 |
27 |
242 |
55 |
6% |
44% |
50% |
2014-2015 |
42 |
307 |
65 |
18% |
11% |
71% |
2015-2016 |
28 |
176 |
76 |
6% |
42% |
52% |
2016-2017 |
46 |
440 |
51 |
19% |
55% |
26% |
2017-2018 |
44 |
296 |
50 |
29% |
27% |
44% |
2018-2019 |
48 |
459 |
66 |
57% |
8% |
35% |
2019-2020 |
35 |
230 |
71 |
7% |
23% |
70% |
2020-2021 |
58 |
513 |
134 |
9% |
8% |
83% |
2021-2022 |
12 |
137 |
190 |
2% |
5% |
93% |
2022-2023 |
23 |
150 |
148 |
6% |
2% |
92% |
2023-2024 |
40 |
306 |
95 |
4% |
3% |
93% |
Total |
552 |
4,169 |
79 |
|
|
|
Source: In housemonitoring
Affordable housing
2.30 The overall provision of affordable housing has declined in recentyears A few years ago, there was an increasing trend for developers to seek to reduce on- site provision of affordable housing on the grounds of viability and / or to promote off-site provisionor an in-lieu financial contribution. However, in more recent years, the level of s106 affordable housing has declined to the extent it is now a severe problem in Spelthorne and does not meet the needs of our residents. Indeed in 2023/24, there were just 43 newly built affordable housing completions in the Borough (see table 16 below). A number of larger schemes have recently been granted planning permission with significantly lower proportions of on-site provision than Policy HO3 seeks to achieve. In addition, the conversion of offices to residential under the “prior approval” regime has prevented the negotiation of affordable housingin a significant number of schemes.
Year |
Affordable dwellings completed (gross) |
Affordable dwellings lost in year |
Affordable dwellings completed (net) |
Rent |
Shared Ownership* |
Other/not specified |
|||
|
Gross units |
% |
Gross units |
% |
Gross units |
% |
|||
2009-10 |
99 |
54 |
45 |
64 |
65 |
35 |
35 |
0 |
0 |
2010-11 |
96 |
44 |
52 |
84 |
87 |
12 |
13 |
0 |
0 |
2011-12 |
144 |
59 |
85 |
101 |
70 |
43 |
30 |
0 |
0 |
2012-13 |
63 |
20 |
43 |
51 |
81 |
12 |
19 |
0 |
0 |
2013-14 |
44 |
0 |
44 |
44 |
100 |
0 |
0 |
0 |
0 |
2014-15 |
16 |
43 |
27 |
8 |
50 |
8 |
50 |
0 |
0 |
2015-16 |
138 |
14 |
124 |
82 |
59 |
56 |
41 |
0 |
0 |
2016-17 |
46 |
0 |
46 |
46 |
100 |
0 |
0 |
0 |
0 |
2017-18 |
9 |
0 |
9 |
5 |
55.5 |
4 |
44.5 |
0 |
0 |
2018-19 |
6 |
0 |
6 |
6 |
100 |
0 |
0 |
0 |
0 |
2019-20 |
0 |
0 |
0 |
0 |
0 |
0 |
0 |
0 |
0 |
2020-21 |
177 |
0 |
177 |
22 |
12 |
155 |
88 |
0 |
0 |
2021-22 |
104 |
0 |
104 |
0 |
0 |
104 |
100 |
0 |
0 |
2022-23 |
0 |
0 |
0 |
0 |
0 |
0 |
0 |
0 |
0 |
2023-24 |
43 |
0 |
43 |
43 |
100 |
0 |
0 |
0 |
0 |
Total |
985 |
234 |
751 |
556 |
59% |
429 |
46% |
0 |
0 |
Source: In housemonitoring
* It shouldbe noted that the sharedownership dwellings do not meet the housing needs of those on the housing register.
|
Number of sites |
Total Dwellings (gross) |
Affordable dwellings granted pp |
Affordable dwellings as % of all dwellings granted pp |
All schemes |
60 |
207 |
13 |
6% |
Schemes above 15 unit threshold as defined in Policy HO33 |
3 |
58 |
0 |
0% |
Source: In housemonitoring
2.31 The conversion of offices to residential under the “prior approval” regime has prevented the negotiation of affordable housing in a significant number of schemes. In the year to 31 March 2024, only one dwelling was granted through prior approval applications from 1 application. (Table 18).[ES2] [WL3] [LW4]
Application No |
Address |
Date Approved |
Number of dwellings |
23/01273/PDO |
Office 6A (First Floor) Araby Corner, 6 High Street, Shepperton, TW17 8DN |
14/12/2023 |
1 |
The Brownfield Land Register
2.32 The NationalPlanning Policy Framework(NPPF) requires councilsto encourage the effective use of land by reusing land that has been previously developed (brownfield land), provided that it is not of high environmental value. All sites included on the register have been provisionally assessed as meeting the NPPF definition of previously developed land.
2.33 To be included, sites must also meet the following:
![]() |
3 As per national planningguidance (NPPF 2021) this is now appliedto schemes of 10 units or more.
1. at least 0.25 hectares in size or capable of supporting at least five dwellings;
2. "suitable" for residential development;
3. the land is "available" for residential development; and
4. residential development of the land is "achievable".
2.34 Spelthorne updates its Part 1 Brownfield Register annually. The Register provides up-to-date and consistent information on sites that are considered to be appropriate for residential development as long as they meet the criteria set out in Town and Country Planning (Brownfield Land Registry) Regulations 2017. Registers are in two parts, Part 1 comprises all brownfield sites appropriate for residential development and Part 2 those sites granted permission in principle. The Part 1 Brownfield Land Register includes sites that have planning permission or are allocations in the adopted Local Plan. The register includes relevant sites that have been submitted through Spelthorne’s Strategic Land Availability Assessment (SLAA)or appropriate sites which meet the criteria.
2.35 The Brownfield Land Register does not affect the status of sites that already have planning permission or are allocated in the adopted Local Plan for development. The inclusion of other siteson the register does not give them any formal status, or grant permission in principle, or in any sense infer that planning permission will be granted for development. The Brownfield Land Register will be subject to periodic review and through ongoing refinement furthersites will be added whilst others may be removed.
The New Local Plan
2.36 The current review of the Council’s Local Plan has identified a need to create around 631 housing units each year over the next 15 years. The Council submitted its draft Local Plan to the Secretary of State for Levelling up, Homes and Communities for independent inspection on 25 November 2022. The Local Plan seeks to meet the Borough’s development needs through a combination of intensifying development of brownfield land, growth within Staines–upon–Thames and releasing a small amount of Green Belt (0.7%) to provide family housing.
2.37 The first three hearingswere held on 23 – 25 May 2023, and a furthersix dates were planned for June 2023. Following an Extraordinary Council Meeting on 6 June 2023, where a motion was agreed to pause the remainder of the Local Plan examination hearings, the examination was paused.
2.38 Another Extraordinary Council Meeting was held on 14 September to consider a report whichoutlined three optionson the future of the Local Plan. At the start of the meeting, a letter from the Minister of State for Housing and Planning was read out which outlined the Governments concerns that the Council may withdraw the emerging Local Plan from examination. This has resultedin the Government intervening in the Local Plan process under section 27 of the Planning and Compulsory Purchase Act 2004.
2.39 Following this, Councillors voted to extend the pause in the Examination timetable untilthe proposed changesto the National Planning Policy Framework have been published before determining the next steps. The revised National Planning Policy Framework was published on 19 December 2023. Subsequently, at Environment and Sustainability Committee on 29 February 2024, the Committee decided on options regarding Green Belt allocations, flood risk sites and the Staines Development Framework, and wrote to the Inspector on 6 March 2024 to consider the decisions.
2.40 The Staines Development Framework was also consulted on alongside the Local Plan. The aim was to provide a structure to shape and transform the town centre. The Development Framework was an important element of the new Local Plan as it set out the opportunities for Staines to deliver new homes, commercial activity and vital infrastructure. At the E&S Committee on 29 February 2024, a decision was made to recommend to the Inspector that the SDF be withdrawn as a Core Document.
2.41 In a meeting of Council on 18 July 2024 it was resolved that, in addition to what was resolved in the Corporate Policy & Resources Committee on 29 February 2024, to request a modification to add wording to the policies of the site allocations that are at risk from access and egress flooding issues.
2.42 On the 14 October 2024 SBC and the Environment Agency signed a statement of common ground (SOCG). The SOCG sets out agreement regarding what is the most appropriate modelling to be used in the Strategic Flood Risk Assessment, the Councils commitment to produce a Supplementary Planning Document or Supplementary Plan and agreed rewording of policy E3: Managing Flood Risk to be requested as a modification to the Inspector.
2.43 At a meeting on 24 October 2024 the Council resolved to:
1. Note that the Environmental Agency had signed a SoCG,
2. Agree to keep the Green Belt allocations in the Local Plan as submitted to the Planning Inspectorate on 25 November 2022
3. Agree to delegate authority to the Group Head of Place, Protection and Prosperity in consultation with the Chair of the Environment and Sustainability Committee, to undertake any further consultation required by the Planning Inspector; and
4. Agree to delegate authority to the Group Head of Place, Protection and Prosperity in consultation with the Chair of the Environment and Sustainability Committee, to prepare a main modification to the Local Plan, for the new policy on ‘Local Plan Early Review’.
2.44 Following the meeting of Council on the 24th of October the Chair of the Environment and Sustainability Committee, wrote a letter to the Planning Inspector to inform him of the outcome of the meeting and to request the resumption of the Local Plan Examination.
2.45 On 12 December 2024 the Council published the Notice of Examination Hearings resuming in January 2025 and included a series of documents on the Examination Website, providing up-to-date information for stakeholders, to support the hearings.
2.46 The Examination Hearings resumed on the 28 January 2025 and concluded on the 18 February 2025. Following this the Local Plan has now progressed to a Main Modifications Consultation which is live until the 15 May 2025. It is anticipated that the Local Plan will be formally adopted Autumn 2025.
2.47 As a result of the examination hearings, the Council is proposing through the Main Modifications to include an Immediate Review Policy which commits to producing an updated or replacement plan which will be submitted for examination no later than two years from the date of adoption of this Local Plan. The Immediate Review will consider the housing requirement for the whole Borough based on the most up to-date national guidance and monitor housing delivery, including the progress and implementation of sites to inform the review.
Appendix 3
2 Key challenges
The key challenges set out in the following section have been identified as areas for the Council to overcome and to positively address any current barriers to housing delivery. In addressing these challenges, the Council will seek to maintain its high standards and will not compromise on the quality of housing delivered. In addressing these challenges, the Council will have regard to its corporate priorities and will seek betterment for the community.
Increasing numbers on the Housing Register: Over the past threeyears, the number of applicants on the Council’s Housing Register has grown by 79%.
Lack of availability of existing affordable housing: In 2017/18 there were eleven applicants for every social housing vacancy.
High rates of statutory homelessness: There is an average of 116 households for whom we have a duty to provide accommodation per year, with one in five households approaching us due to the termination of a privatesector tenancy.
High use of emergency and temporary housing for homeless households: The average occupancy of temporary accommodation at the end of each quarter from 2021/22 to 2024/25 is 130 households. See Table H4. For example, the average costto the Council to accommodate one homeless household in emergency housingis approximately £20,000 per annum
Increasing affordability issues: ratio of the median house price to the median wage in the area evidences a year-on-year rise over the past four years, with Spelthorne outpacing the ratios for both the South East and England. Lack of new-buildaffordable housing: The net increase of provision over the past five years has been a mere 321 units – with only 43 units provided in the past two years. In planning terms, affordable housing can only be secured with schemes of 15 houses or more (policy HO3) and many applications are for a lower number of dwellings than this. In addition, each application (for 15+ units) which is not policy compliant with policy HO3, is required to provide a viability assessment on an open book approach which is undertaken by an independent advisor appointed by the LPA. Due to the rising costs in recent times, several of the applications have been able to demonstrate that providing affordable housing is non viable. The Council is currently exploring other ways (other than s106 agreements) to secure the much needed affordable housing.
The effect of our proximity to London
As well as the evident demand for affordable housing from local residents, there is also considerable pressure from London. The cost of housing in London is even higher than in Spelthorne, and London boroughs are actively placing homeless households from their boroughs into Spelthorne, as well as ‘block booking’emergency accommodation facilities within Spelthorne for their homeless people, placing further demand on the already strained private sector.
Key workeraccommodation
Whilst housing affordability is a significant issue in general, it acutely affects key workers, who help to run the essential local services such as schools, hospitals, doctor’s surgeries and fire stations. According to Government statistics releasedin 2011, the latestrecords available, the medium income for employees within Spelthorne is £31,457, which is in line with the Surrey average. However, the starting salaries for essential local workers is much less. We know anecdotally that key worker staff are moving further and further away from Spelthorne into Hampshire and Berkshire and commuting to work. This means that when they look for theirnext promotion they are more likely to look in those areas; this is another factor leading to loss of workforce. Whilst some key workers are being recruited from London, one of the main factors which will keep them in Spelthorne is availability of affordable housing.
|
|
Total Dwellings (Gross |
) |
|
Losses (ii) |
|
|
Net Completions |
|
|
|||
Year (Apr-Mar) |
Private |
RSL |
Public |
Total |
Private |
RSL |
Public |
Total |
Private |
RSL |
Public |
Total |
Running Total |
2009-2010 |
197 |
99 |
0 |
296 |
29 |
56 |
0 |
85 |
168 |
43 |
0 |
211 |
211 |
2010-2011 |
116 |
96 |
0 |
212 |
29 |
44 |
0 |
73 |
87 |
52 |
0 |
139 |
350 |
2011-2012 |
118 |
144 |
0 |
262 |
43 |
60 |
0 |
103 |
75 |
84 |
0 |
159 |
509 |
2012-2013 |
159 |
63 |
0 |
222 |
32 |
20 |
0 |
52 |
127 |
43 |
0 |
170 |
679 |
2013-2014 |
154 |
44 |
0 |
198 |
7 |
0 |
0 |
7 |
147 |
44 |
0 |
191 |
870 |
2014-2015 |
317 |
16 |
0 |
333 |
25 |
43 |
0 |
68 |
292 |
-27 |
0 |
265 |
1,135 |
2015-2016 |
217 |
138 |
0 |
355 |
33 |
14 |
0 |
47 |
184 |
124 |
0 |
308 |
1,443 |
2016-2017 |
328 |
46 |
0 |
374 |
27 |
0 |
0 |
27 |
301 |
46 |
0 |
347 |
1,790 |
2017-2018 |
278 |
9 |
0 |
287 |
37 |
0 |
0 |
37 |
241 |
9 |
0 |
250 |
2,040 |
2018-2019 |
304 |
6 |
0 |
310 |
21 |
0 |
0 |
21 |
283 |
6 |
0 |
289 |
2,329 |
2019-2020 |
248 |
0 |
0 |
248 |
20 |
0 |
0 |
20 |
228 |
0 |
0 |
228 |
2,554 |
2020-2021 |
479 |
177 |
0 |
656 |
17 |
0 |
0 |
17 |
462 |
177 |
0 |
639 |
3,196 |
2021-2022 |
106 |
104 |
0 |
210 |
5 |
0 |
0 |
5 |
205 |
0 |
0 |
205 |
3,401 |
2022-2023 |
150 |
0 |
0 |
150 |
12 |
0 |
0 |
12 |
12 |
0 |
0 |
138 |
3,539 |
2023-2024 |
263 |
43 |
0 |
306 |
19 |
0 |
0 |
19 |
244 |
43 |
0 |
287 |
3,826 |
2009-2022(i) |
3,434 |
9485 |
0 |
4,419 |
356 |
237 |
0 |
593 |
3,182 |
644 |
0 |
3,826 |
27,875 |
(i) Period coveredby the Spelthorne Core Strategyand Policies DPD.
(ii) Losses of residential units (through redevelopment, conversion and to other uses) are accountedfor in the year in which a development is commenced on the site
[HB1]@Waters, Laura we have 816 in the trajectory in Table 11 - should we update this?
[ES2]@Waters, Laura this only show 1 affordable dwelling, not 22.
[WL3]I'll check and update this table
[LW4]@Spinks, Esme double checked 2.32 and table 18 which are now correct