POLICY BACKGROUND
National Policy Guidance
3.1 Government policy guidance on housing is set out in Planning Policy Guidance (PPG) Note 3 “Housing”, published May 2000. It emphasises a greater choice of housing and better mix in terms of size, type and location, recognising the needs of all in the community, including those in need of affordable or special housing, and creating mixed communities. Sustainable patterns of development and the better use of previously developed land, in preference to greenfield sites, are promoted, as is good design.
Replacement Structure Plan
3.2 The Replacement Structure Plan (RSP) recognises that sustainable development supports making the best use of existing land and buildings. The provision of residential development, therefore, is to be determined through a sequential approach to the choice of location, with the emphasis being the use of previously developed land within existing large urban areas, and mixed-use schemes.
3.3 Brentwood, together with the rest of South Essex, is identified in the Core Strategy, as a heavily urbanised area close to London where strong emphasis will continue to be given to safeguarding the stated purposes of the Metropolitan Green Belt and protecting the area’s natural and built environment. Further long term housing provision up to 2011 is to be strongly constrained. Brentwood’s housing provision figure for the period 1996-2011 is a further 1450 additional dwellings, which the Structure Plan expects would be capable of accommodation within existing built up areas without the requirement for development of sites currently within the Green Belt. This figure is also significantly more than the locally generated figure of 600 dwellings for the same period.
The Brentwood Community Plan
3.4 The Community Plan’s strategic objectives that are relevant to the Replacement Local Plan’s Housing Policies are set out under the headings “Housing and Social Inclusion”, which includes:
“To ensure that everyone in the Brentwood Borough has access to appropriate local housing by:
- Optimising the use of Council and privately owned land and property to produce affordable social housing
- Ensuring that sufficient land is available to meet foreseen local housing needs, recognising the need for variety and environmental sensitivity”
THE AIM AND OBJECTIVES FOR THE PLAN’S HOUSING POLICIES:
The Overall Aim
To meet the housing needs of the Borough’s population
Supporting Objectives:
- To ensure that sufficient land is allocated and available to meet foreseen locally generated housing needs
- To encourage the provision of an appropriate range of house types, sizes and tenures which best meet the housing needs of the population, particularly through increasing the availability of low cost private housing and affordable rented housing
- To encourage the retention, improvement and efficient usage of the existing housing stock and, where appropriate, the reuse and conversion of existing buildings for residential purposes
- To make best use of previously developed land and buildings, particularly in sustainable urban locations, whilst protecting the existing amenities and character of the area and minimising the development of both urban and rural greenfield sites.
- To ensure a high quality of design, layout and materials in new residential development
- To ensure that the accessibility needs of persons experiencing mobility difficulties are met in new residential development
- To maintain and improve the environmental quality of residential areas
INTRODUCTION
3.5 Brentwood’s location close to London, together with other factors such as its good road and rail links and the quality of its urban and rural environment, has resulted in the town and the surrounding villages being highly desirable places in which to live. Demand for new housing has, and will continue to be high. However, the Metropolitan Green Belt places a constraint on the availability of land for development.
3.6 The existing housing stock is predominantly recent in construction, with some 70% of private sector properties having been built since 1945 and only 15% pre-dating 1919. The standard of housing is therefore good with only 2% of properties being estimated as unfit (compared with the national average of 6.2%) with some 9% of properties being in disrepair (source: Brentwood Borough Council Housing Condition Survey 2000). Detached and semi detached properties, comprising 3, 4 and 5 bedroom family houses, generally predominate. Property prices are generally high, even for the smallest residential units.
3.7 All these factors, combined with the decline in the supply of rented accommodation, mean that first-time buyers in particular, and those on lower incomes generally, find difficulty in securing suitable accommodation within the Borough and may be forced to move out. In the long-term an increasing imbalance between the demand for and supply of housing could have wider implications e.g. the local economy may be affected if firms are not able to obtain skilled labour or key workers are unable to find accommodation. There is, therefore, a need to direct housing policies towards making the best use of land that is available for housing and to ensure that an appropriate mix of housing types, sizes and tenures is available within the Borough to meet all needs.
Residential Land Availability
3.8 In order to ascertain whether the RSP housing provision figure could be accommodated through the development of previously developed land and buildings within existing urban areas, the Council undertook an “Urban Capacity Study” (source: An Assessment of Urban Capacity. Brentwood Borough Council, June 2002), which was published as a separate technical document accompanying the Initial Deposit Draft Plan.
3.9 This study concluded that, at a base date of 1 April 2001, there was a discounted capacity within existing urban areas of between 674 and 974 dwellings that would come forward before 2011 (based on a discounted capacity figure derived from two separate density assumptions – an “average” density based on existing average densities throughout the Borough and a “high” density based on the success of new policies aimed at increasing densities, and as achieved in the most recent housing developments). However, these figures, together with the number of residential completions that occurred between 1 April 1996 and 31 March 2001, and the number of residential units on larger sites with unimplemented planning permission at 1 April 2001 (source: Residential Land Availability. Brentwood Borough Council, April 2001), were reviewed further and agreed as part of the evidence at the Local Plan Inquiry. The amended figures are set out in Table 3.1 and show that at April 2001 there was a potential supply of between 1596 and 1868 additional dwellings between 1996 and 2011. In addition, since April 2001 the capacity on large sites with and without planning permission has increased by some 420 additional dwellings (i.e. sites at Heybridge Moat House Hotel; St Raphaels Church, Warley Hospital; Farrell Ward, Warley Hospital; Hatch Road, Pilgrims Hatch; Wharf Road, Brentwood; and Beckett House, Baytree Centre).
Table 3.1: Supply of Housing in Brentwood 1996-2011
3.10 It can be concluded, therefore, that there is sufficient housing likely to come forward by 2011 to meet the housing provision figure of 1450 additional dwellings without the need to consider the release of greenfield sites either within the Green Belt or within the existing urban areas.
NEW HOUSING PROVISION
Residential Provision 1996-2011
3.11 It can be seen that the RSP provision of 1450 additional dwellings for the Borough over the period 1996 to 2011, can be more than met within areas already allocated for residential use through the development, conversion or re-use of previously developed land and buildings. Furthermore, in the light of existing rates of completion and the number of residential units with outstanding permissions on larger sites, there is likely to be a steady supply of land coming forward for residential development. In these circumstances there can be no justification for releasing land from the Green Belt for residential use (apart from the Affordable Rural Housing Issue dealt with in Paragraphs 3.40-3.43 and Policy H10 below).
3.12 The major housing sites (i.e. sites with unimplemented planning permission, both implemented and unimplemented, or with potential capacity [at an average density assumption] for 12 or more dwellings), contributing to the RSP housing provision figure over the period 1996 to 2011, are identified on the Proposals Map, and are listed below:
1. Former Advanced Laundry, Ongar Road, Brentwood
2. Highwood Hospital, north of Copperfield Gardens, Brentwood
3. Land to the western side of Gresham Close, Brentwood
4. Land to the eastern side of Gresham Close, Brentwood
5. Land to the rear of Kings Chase, Brentwood
6. Cotswold Lodge, Hutton Village
7. Land bounded by Harts Street and Kings Road, Brentwood
8. Land rear of the Robin Hood Public House, Ongar Road, Brentwood
9. Former BT Depot, Hatch Road, Pilgrims Hatch
10. Land rear of Former Warley Hospital Site, Warley Hill, Brentwood
11. Farrell Ward, Warley Hospital, Brentwood
12. ST Raphaels Church, Warley Hospital, Brentwood
13. Former Anglia Polytechnic University Site, Sawyers Hall Lane, Brentwood
14. Former Transco Site, Wharf Road, Brentwood
15. Land at Highwood Close, Brentwood
16. Highwood Hospital, Geary Drive, Brentwood
17. Little Highwood Hospital, Brentwood
18. Former Warley Hospital Core Buildings, Warley Hill, Brentwood
19. Land adjacent 21 Eastfield Road, Brentwood
20. Pilgrims Hatch County Infants School, Larchwood Gardens, Brentwood
21. Heybridge Moat House Hotel, Roman Road, Heybridge
22. Beckett House, Bay Tree Centre, Brentwood
H1 Residential Provision 1996-2011
PROVISION IS MADE FOR 1,450 NEW DWELLINGS (NET) TO BE BUILT IN THE BOROUGH BETWEEN APRIL 1996 AND MARCH 2011. EXCEPT AS ALLOWED FOR WITHIN THE CONTEXT OF HOUSING POLICY H10 AND GREEN BELT POLICIES GB4, GB6, GB10, GB11, GB12, GB16 AND GB17 NEW HOUSING DEVELOPMENT SHALL BE PROVIDED WITHIN THE EXISTING SETTLEMENT AREAS AS IDENTIFIED ON THE PROPOSALS MAP, THROUGH THE DEVELOPMENT, CONVERSION OR RE-USE OF PREVIOUSLY DEVELOPED LAND AND BUILDINGS. SUCH DEVELOPMENT SHALL ALSO COMPLY WITH ALL OTHER RELEVANT POLICIES IN THE PLAN.
A Target and Indicator for monitoring this policy is set out in Chapter 13
Housing Land Availability Monitor
3.13 The housing supply figures set out in Table 3.1 show that there is sufficient flexibility to achieve the Structure Plan housing provision figure for the period to 2011, not withstanding the uncertainties and assumptions inherent in assessing future housing supply. Due to the relative small housing provision figure (1450 additional dwellings) and the proportion of supply that has been completed (414 units) or committed through planning permissions on large sites (611 units), it is not considered necessary to seek to programme or phase the Borough’s housing supply as recommended in the government document “Managing the Potential”. Much of the outstanding supply will come forward on smaller sites and it is considered that the larger sites, identified in the “Urban Capacity Study”, will come forward in the latter part of the plan period as a consequence of such factors as their ownership and their brownfield status.
3.14 However, in line with the government’s policy direction for the delivery of housing through the planning system based upon the “plan, monitor and manage” approach, the Council will continue to monitor housing development on an annual basis, in conjunction with the County Council and House Builders as appropriate, to ensure that a steady supply of housing land is maintained to meet the Replacement Structure Plan allocation for the Borough (source: “Monitoring the Provision of Housing through the Planning System – Towards Best Practice.” DETR,. October 2000).
H2 Housing Land Availability Monitor
THE COUNCIL WILL MONITOR HOUSING DEVELOPMENT ANNUALLY IN ORDER TO ENSURE AN ADEQUATE SUPPLY OF HOUSING LAND IS MAINTAINED WITHIN THE BOROUGH TO MEET THE PROVISION FIGURE IN POLICY H1 AND TO ENSURE THAT THE PLAN’S HOUSING POLICIES ARE BEING IMPLEMENTED.
Community Uses in Residential Development
3.15 Residential development will give rise to the demand for additional community facilities to meet the needs of new residents. The means by which developers provide for such facilities, or contribute to their provision, either on site or through a legal agreement, is dealt with in Policy CP4. However, where it has been identified that there is an existing need for additional community facilities (such as a community hall, medical facilities, shopping provision for example) within a particular area, the opportunity will be taken by the Council to incorporate, through negotiation, such facilities within new residential development proposals as part of a mixed use development. The intention will be, therefore, to provide facilities in locations that are accessible to all surrounding residents, reducing the need to travel and creating equality of opportunity.
H3 Community Uses in Residential Development
IN ADDITION TO THE REQUIREMENTS OF POLICY CP4, WHERE APPROPRIATE, THE COUNCIL WILL SEEK TO INCORPORATE THROUGH NEGOTIATION NEW COMMUNITY FACILITIES WITHIN NEW RESIDENTIAL DEVELOPMENT, WHERE A LOCAL NEED HAS BEEN IDENTIFIED.
Mixed Use Development
3.16 Whilst the opportunity will be taken to introduce community uses in to residential development proposals, the Council will also seek to achieve further residential provision as part of mixed use schemes in the Borough’s main district shopping areas of Shenfield, Ingatestone High Street and Warley Hill, particularly within areas allocated for residential and commercial uses, but also in any commercial development, if considered appropriate (see also Policy TC3 for Brentwood Town Centre). The introduction of residential development in such areas can provide much needed small unit accommodation in areas well located to public transport and other services and facilities. Residential accommodation can also benefit such areas by providing activity outside normal business hours, both adding to commercial viability and vitality and providing for a more secure feel to the commercial area.
WITHIN AREAS ALLOCATED FOR RESIDENTIAL/OFFICES/SHOPS OR SHOPS/RESIDENTIAL AND IN OTHER APPLICATIONS INVOLVING COMMERCIAL DEVELOPMENT WITHIN THE MAIN DISTRICT SHOPPING AREAS OF SHENFIELD, INGATESTONE HIGH STREET OR WARLEY HILL, THE OPPORTUNITY SHOULD BE TAKEN TO PROVIDE NEW RESIDENTIAL ACCOMMODATION AS PART OF MIXED USE DEVELOPMENT
Changes of Use of Upper Floors
3.17 Upper floors above shops or other commercial premises frequently tend to be under-utilised, being either used for storage or in many cases not used at all. This under-use of space not only amounts to a waste of valuable resources but also tends to lead to neglect, a negative impact on the street scene and, ultimately, the deterioration of buildings. The Council, therefore, in line with government policy for making best use of existing urban land and buildings, will seek to promote greater use of such resources.
3.18 The use of such accommodation for residential purposes will be encouraged as a means of providing further affordable, small-unit accommodation. The Council is aware that it may be difficult in some cases to achieve all the standards normally required for residential use. Therefore, whilst it will be necessary to ensure that the amenities of prospective occupiers are safeguarded, a more flexible attitude may be adopted in respect of the Council's normal residential standards.
H5 Changes of Use of Upper Floors
THE CHANGE OF USE OF UPPER FLOORS ABOVE EXISTING COMMERCIAL PREMISES TO RESIDENTIAL ACCOMMODATION WILL BE ENCOURAGED, PARTICULARLY TO PROVIDE AFFORDABLE UNITS OF ACCOMMODATION, PROVIDING THE FOLLOWING CRITERIA CAN BE SATISFIED:
i) REASONABLE FACILITIES AND AMENITIES ARE PROVIDED FOR PROSPECTIVE OCCUPIERS
ii) THE DEVELOPMENT DOES NOT RESULT IN DEMAND TO REPLACE STORAGE SPACE LOST
A Target and Indicator for monitoring this policy is set out in Chapter 13
Small Unit Accommodation
3.19 The number of small households is increasing nationally due to extended life expectancy, household break up and the increasing number of young people who choose to live alone. The Replacement Structure Plan estimates that within Brentwood Borough there will be 600 locally generated households over the period 1996 to 2011. Generally, newly forming households will be small households requiring smaller units of accommodation. This need can be met by the provision of small, i.e. 1 or 2 bedroom, houses or flats, the conversion of existing large dwellings into smaller flat units or, in the case of older or disabled people, specially adapted accommodation to meet their specific needs.
3.20 However, only a small proportion of the existing dwelling stock comprises 1 and 2 bedroom units. Existing small unit accommodation can also be reduced through extensions to provide additional bedrooms or amalgamation to form larger units. A lack of small unit accommodation has and may continue to result in the loss of young economically active sections of the population and lead to an imbalance in the population structure in the longer-term. This is clearly an undesirable situation. New housing development should make a significant contribution to meeting perceived housing need within the Borough by providing for a mix of units. It is clear, therefore, that there will need to be an emphasis on small-unit provision, particularly on the larger sites. In order that, once provided, smaller units remain available, in appropriate circumstances permitted development rights to extend such properties will be removed by condition on the permission.
3.21 In the case of Hutton Mount, however, the development of a mix of units is not considered appropriate since it would be inconsistent with the character of existing development in this area, which consists mainly of large detached houses in substantial grounds.
IN A NEW HOUSING DEVELOPMENT THE COUNCIL WILL SEEK THE PROVISION OF A MIX OF UNITS ON SUITABLE SITES OF 6 UNITS AND ABOVE OR ON SUITABLE SITES OF 0.2 OF A HECTARE OR MORE, WITH AT LEAST 50% OF TOTAL UNITS BEING 1 AND 2 BEDROOM PROPERTIES, EXCEPT WHERE IT CAN BE DEMONSTRATED THAT SUCH A MIX OF UNITS WILL BE INCONSISTENT WITH THE CHARACTER OF EXISTING DEVELOPMENT IN THE AREA OR WHERE SUCH PROVISION CANNOT BE ADEQUATELY ACCOMMODATED ON THE DEVELOPMENT SITE.
WHERE:
a) APPLICATION IS MADE FOR PART DEVELOPMENT OF A LARGER RESIDENTIAL SITE IDENTIFIED ON THE LOCAL PLAN PROPOSALS MAP, OR
b) THE PROPOSED RESIDENTIAL DEVELOPMENT SITE IS CONTIGUOUS WITH ONE OR MORE OTHER POTENTIAL RESIDENTIAL DEVELOPMENT SITES,
THE AREA TO BE USED FOR DETERMINING THE APPLICABILITY OF THIS POLICY WILL BE THE LARGER SITE IN RELATION TO (a) ABOVE AND THE AGGREGATE AREA OF SUCH CONTIGUOUS SITES IN RELATION TO (b) ABOVE.
IN APPROPRIATE CIRCUMSTANCES A CONDITION WILL BE IMPOSED ON SUCH SMALLER UNITS TO PREVENT EXTENSIONS PROVIDING ADDITIONAL HABITABLE FLOOR SPACE.
A Target and Indicator for monitoring this policy is set out in Chapter 13
Single Storey Dwellings
3.22 Further to the need for small unit accommodation, there is concern with the loss of single storey dwellings in the Borough, many of which are small units of accommodation. In addition, however, they provide for the needs of the elderly or other less mobile residents. Brentwood’s population has a high proportion of elderly person’s, compared to national statistics, and it is forecast that the numbers of elderly will continue to increase, both in total numbers and as a proportion of the resident population.
3.23 Whilst it has to be acknowledged that single storey dwellings can be converted to two storeys, through the provision of rooms in the roof without, in many instances, the need for planning permission, the retention of such accommodation where permission is required is considered justifiable in order to provide for the needs of all age groups and personal circumstances.
EXTENSIONS OR OTHER ALTERATIONS TO AN EXISTING SINGLE STOREY DWELLING (INCLUDING RE-ROOFING) WILL BE RESTRICTED TO A SINGLE STOREY.
THE REDEVELOPMENT OF SITES OF EXISTING SINGLE STOREY RESIDENTIAL PROPERTIES WILL ONLY BE PERMITTED WHERE THERE IS NO NET LOSS IN THE NUMBER OF SINGLE STOREY DWELLINGS ON THE SITE.
ALL NEW SINGLE STOREY DWELLINGS AND EXTENSIONS TO EXISTING SINGLE STOREY DWELLINGS WILL HAVE A CONDITION IMPOSED REMOVING PERMITTED DEVELOPMENT RIGHTS FOR ADDITIONS OR ALTERATIONS TO THE ROOF.
Conversions
3.24 The conversion of larger units into two or more smaller ones is one way of addressing the problems of under occupancy and the lack of small units of accommodation in Brentwood. Such conversions can provide a valuable housing resource especially to meet the needs of young first-time buyers.
3.25 The standard of conversions should be carefully controlled to ensure that adequate facilities are provided to meet the needs of prospective occupiers, to protect the general character of an area and to safeguard the amenities of surrounding residents. Proposals will need to have regard to the principles set out in Appendix 2 (Vehicle Parking Standards) and Appendix 5 (Miscellaneous Residential Design Guidance).
WITHIN THE BUILT UP AREA OF THE BOROUGH AS DEFINED ON THE PROPOSALS MAP, CONVERSION OF DWELLING-HOUSES INTO TWO OR MORE UNITS WILL BE ALLOWED WHERE ALL OF THE FOLLOWING CRITERIA ARE MET:
i) THE NUMBER OF PROPERTIES WHICH HAVE BEEN SUB-DIVIDED OR FOR WHICH PLANNING PERMISSION HAS BEEN GIVEN DOES NOT GIVE RISE TO AN OVER CONCENTRATION OF FLATS WITHIN A PARTICULAR STREET OR AREA RESULTING IN AN UNACCEPTABLE LOSS OF AMENITY OR HARM TO RESIDENTIAL CHARACTER WITHIN THAT LOCALITY
ii) THE CONVERSION DOES NOT GIVE RISE TO AN UNACCEPTABLE EXTENSION OR UNACCEPTABLE EXTERNAL ALTERATION TO THE PROPERTY
iii) WHERE APPROPRIATE, LANDSCAPING SHALL BE PROVIDED AS PART OF THE SCHEME FOR CONVERSION
iv) THE CONVERSION (INCLUDING THE PROVISION OF BALCONIES OR EXTERNAL STAIRCASES) MUST NOT GIVE RISE TO UNDUE OVERLOOKING OF ADJOINING PROPERTIES
AFFORDABLE HOUSING POLICY
Affordable Housing on Larger Sites
3.26 Affordable housing is a national issue and indeed the subject of government advice as contained in PPG3, which states that affordable housing provision is a material planning consideration when deciding planning applications involving housing. It allows for Local Planning Authorities to include policies in Local Plans seeking an element of affordable housing within larger areas of new housing development, where there is a demonstrable lack of affordable housing to meet local needs. Government advice on affordable housing provision is set out in Circular 6/98 “Planning and Affordable Housing”. The Circular sets out the criteria for establishing the threshold of sites on which it would be appropriate for the Local Planning Authority to negotiate a proportion of affordable housing. In July 2003 the Government issued a consultation paper on proposed changes to the guidance in PPG3 on affordable housing. The affordable housing policies in this Plan are considered to be in general conformity with that advice.
3.27 In order to assess the level of housing need in the Borough, the Council commissioned Fordham Research Limited to undertake a housing needs survey in 1998 (source: Housing Needs Survey. Fordham Research Ltd. December 1998). A further revised study has been undertaken in 2004, again by Fordhams, but the results and recommendations of this new study are yet to be formally considered by the Council and will be used to inform an early review of the Council’s affordable housing policies as set out in this Plan. All references to the Housing Needs Survey in this Plan refer, therefore, to the 1998 Study.
3.28 Housing affordability is, perhaps, best defined by comparing house prices or rental levels against income. The Housing Needs Survey assessed the cost of private housing, both for sale and rent, and compared these figures with income levels for different groups. The survey concluded that the discrepancy between average annual gross incomes and the lowest house prices and rent levels highlighted the inability of many households to afford market housing. In summary the Housing Needs Survey identified that total housing need in the Borough was made up of the groups set out in Table 3.2.
Table 3.2: Total Housing Need in the Brentwood Borough 1998
3.29 Whilst the total need at 1998 was 1751 households, the number of households in need will continue to increase, such that the Needs Survey estimated that by the end of the Replacement Structure Plan period, 2011, a total of between 2,500 and 4,000 additional affordable dwellings might be required to meet the need in full. Clearly, such levels of new build are unachievable, and indeed not all of the identified need will require new build housing. The Council will continue to encourage the early re-occupation of vacant properties and the conversion and re-use of suitable commercial premises (including “Living over the Shop”) to provide affordable rented accommodation. In addition, the Council will continue to implement a package of other measures, as referred to in the Council’s Housing Strategy Statement, to attempt to reduce needs to an acceptable level.
3.30 However, these measures will, at best, only provide for a small proportion of the identified need and new build will probably remain the most important element of future provision. The degree to which reliance will need to be had on affordable housing being achieved through new build on private housing developments can be judged from the fact that over the last 5 years the Council has been able to provide only 33 units through “purchase and repair” schemes or through “living over the shop” (over the same period 181 units have been purchased through “Right to Buy”). The total level of housing allocation for the Borough in the Replacement Structure Plan for the period 1996-2011 is 1450 new units. Even if all of this new housing were to be allocated for affordable housing, it still would not meet the existing requirement for the Borough. Furthermore, much of the supply of housing development land already has planning permission or consists of small sites, well below the Circular thresholds. Thus the opportunities for further affordable housing will be seriously constrained. In any event, the target for new build affordable housing in the Local Plan must be realistic in order not to deter development coming forward.
3.31 The normal threshold that the Circular advice considers appropriate for settlements above 3,000 population is 25 dwellings and above or 1 hectare or more. In Inner London the minimum threshold is 15 dwellings and above or 0.5 hectares or more. Whilst it is accepted that no part of Brentwood equates to the housing situation experienced in the area defined as Inner London in footnote 7 to the Circular, given the significant level of housing need identified in the Housing Needs Survey, the lack of any potential sites of any significant size within the Borough and the constraints of the Metropolitan Green Belt, it is considered that a threshold of 20 dwellings and above or 0.66 hectares or more is justified for the duration of this Local Plan.
3.32 The Circular also allows for a threshold below 15 units within settlements below 3,000 population. Whilst the Housing Needs Survey identified the greatest need for affordable housing to be within the town of Brentwood it also showed that there is a significant level of need beyond the urban area of Brentwood. Of the total housing need of 1751 households, some 356 households (20%) were located outside of the town. Housing sites within the villages are generally small scale and difficult to identify, generally coming forward as windfalls. Historical data on residential land sites within the villages, together with the results of the “Urban Capacity Study” would indicate that opportunities (albeit it still very limited) for achieving affordable housing would only arise if a threshold of 5 dwellings and above or 0.16 hectares or more were adopted.
3.33 Apart from the town of Brentwood itself, the only other settlement over 3,000 population is Ingatestone (approx. 4,000 population). However, in terms of settlement size and character and housing site supply, Ingatestone clearly shares greater similarity with the other smaller settlements in the Borough than with the town of Brentwood. Notwithstanding Ingatestone being slightly above the Circular threshold of 3,000 population it is considered justifiable, therefore, to treat it in line with the smaller settlements in the Borough.
3.34 The Housing Needs Survey recommended that the Council should seek to negotiate a proportion of at least 30% affordable housing on new development sites. However, the Revision of Regional Planning Guidance for the South East (RPG 9) sets out a provisional indicator of between 18,000 and 19,000 affordable homes a year within the Rest of the South East area (ROSE). This would equate to some 42-44% of the total annual housing provision figure for ROSE (43,000 dwellings). PPG3 advises that estimates for affordable housing set out in RPG should be regarded as indicative and should not be presented as targets or quotas for local planning authorities to achieve. Accepting that a significant proportion of new housing will be provided on sites below the thresholds, to achieve this level of affordable housing provision would indicate the need for a figure well above 40% on sites above the thresholds. However, too high a figure will affect the economics of site development and could prevent sites coming forward. This would be particularly true for brown field sites where development costs would be higher than green field sites.
3.35 Taking account of the above and the 1998 Housing Needs Survey, a figure of 30% affordable housing for subsidised rented housing is considered justifiable. Whilst the 1998 Study excluded low-cost market housing from its affordable housing definition, the Council now accepts that increasing difficulties have been felt by key public sector workers, such as health service employees, the police, teachers and local government officers, in affording accommodation in the Borough. Such needs will vary in terms of employment numbers and sectors over time, but they may benefit from the availability of low-cost market housing in addition to subsidised rented accommodation. The Housing Needs Study suggested that any target for shared ownership accommodation should be some 5% and this can be added to the 30% for subsidised rented housing. The Council will therefore seek to negotiate for 35% of the number of dwelling units on suitable sites to be for affordable housing.
3.36 The government Circular definition of “affordable housing” encompasses both low-cost market and subsidised housing (irrespective of tenure, ownership - whether exclusive or shared - or financial arrangements). This definition was confirmed by Appendix 2 of ‘Local Housing Needs Assessments: A Guide to Good Practice’, issued by the Secretary of State in July 2000. Notwithstanding, therefore, that the 1998 Fordham research discounted the inclusion of low cost market housing, the government’s wider definition of affordable housing is adopted for the purposes of this Plan.
3.37 On all sites above the thresholds the Council will require the developer to complete a legal agreement under Section 106 of the Town and Country Planning Act 1990 which, inter alia, will ensure that: the affordable homes are provided by a Registered Social Landlord (RSL) or other provider agreed by the Council; that the housing remains affordable in perpetuity; and the proposals are financially viable for the provider to implement and provide rents at affordable levels. The legal agreement will also need to prescribe the mechanisms for providing affordable housing. This will need to be determined in each case.
3.38 It is acknowledged that the circumstances on individual sites will differ and the aim will be to achieve successful housing developments that take account, amongst other things, of the economics of site development. It will be for the applicant to justify that such issues lead to 35% affordable housing making a site unviable and, therefore, warrant a reduction in the proportion of affordable housing on a site and/or the unreasonableness of the developer funding the full cost of the affordable provision. In such cases the Council will consider the appropriateness of using other sources of funding, such as housing grant, Section 106 monies and RSL reserves for example, to maximise the affordable housing provision on a site whilst, in all cases, seeking to make the most effective use of the resources available to the Council.
3.39 The proportion of affordable housing will generally be provided on site as part of the development and should be distributed in more than one location within larger development sites providing 20 or more affordable units on site. Where circumstances dictate that this would not be appropriate or possible, the Council will agree to the affordable housing being provided part on-site and part off-site or, failing that, wholly off-site, or, exceptionally, a financial sum being provided in lieu of, and to fund affordable housing to be provided elsewhere in the Borough by the Council.
H9 Affordable Housing on Larger Sites
ON SUITABLE SITES FOR HOUSING DEVELOPMENT OF 20 UNITS AND ABOVE OR ON SUITABLE RESIDENTIAL SITES OF 0.66 HECTARES OR MORE WITHIN THE BRENTWOOD URBAN AREA, AND ON SITES OF 5 UNITS AND ABOVE OR ON SUITABLE SITES OF 0.16 HECTARES OR MORE WITHIN THE DEFINED SETTLEMENTS ELSEWHERE IN THE BOROUGH, THE COUNCIL WILL SEEK A PROPORTION OF 35% OF THE NUMBER OF DWELLING UNITS TO PROVIDE FOR AFFORDABLE HOUSING IN A MANNER TO BE AGREED WITH THE COUNCIL AND SUBJECT TO:
i) THE DEFINITION OF “AFFORDABLE HOUSING” BEING BOTH “SUBSIDISED RENTED ACCOMMODATION” AND “LOW COST MARKET HOUSING”.
ii) SATISFACTORY SAFEGUARDS TO LIMIT OCCUPANCY TO LOCAL NEEDS IN PERPETUITY
iii) SUCH ACCOMMODATION BEING PROVIDED TO THOSE HOUSEHOLDS WITHIN THE BOROUGH NOT ABLE TO AFFORD ON THE OPEN MARKET TO RENT OR BUY A DWELLING OF SUFFICIENT SIZE IN THE BOROUGH
iv) THE ECONOMICS OF PROVISION, INCLUDING THE PARTICULAR COSTS ASSOCIATED WITH DEVELOPMENT AND THE REALISATION OF OTHER PLANNING OBJECTIVES
v) THE NEED TO ACHIEVE A SUCCESSFUL HOUSING DEVELOPMENT
THIS POLICY WILL BE APPLIED TO BOTH IDENTIFIED SITES AND TO UNIDENTIFIED WINDFALL SITES.
WHERE:
a) APPLICATION IS MADE FOR PART DEVELOPMENT OF A LARGER RESIDENTIAL SITE IDENTIFIED ON THE LOCAL PLAN PROPOSALS MAP, OR
b) THE PROPOSED RESIDENTIAL DEVELOPMENT SITE IS CONTIGUOUS WITH ONE OR MORE OTHER POTENTIAL RESIDENTIAL DEVELOPMENT SITES,
THE AREA TO BE USED FOR DETERMINING THE APPLICABILITY OF THIS POLICY WILL BE THE LARGER SITE IN RELATION TO (a) ABOVE AND THE AGGREGATE AREA OF SUCH CONTIGUOUS SITES IN RELATION TO (b) ABOVE.
THE AFFORDABLE HOUSING WILL BE PROVIDED ON SITE AS PART OF THE DEVELOPMENT. WHERE THIS WOULD NOT BE APPROPRIATE OR POSSIBLE THE COUNCIL MAY ACCEPT THE AFFORDABLE HOUSING TO BE PROVIDED EITHER IN PART OR IN WHOLE ON ANOTHER SITE.
A Target and Indicator for monitoring this policy is set out in Chapter 13
3.40 Specific advice on providing for affordable housing in rural areas as an exception to more general restraint policies is set out in Annex B to PPG 3 (as amended in January 2005). The advice states that the issue of affordable housing does not alter the general presumption against inappropriate development in the Green Belt and that an “exceptions policy” is not meant to apply in most Green Belt areas, which are by their nature close to major conurbations where conditions are not typical of the generality of rural areas. The Council, whilst supporting this general principle, is conscious of a need for affordable rural housing within the Borough, and the limited opportunities that will arise in many of the smaller village settlements.
3.41 The affordable rural housing policy has been drafted having regard to government advice, and any sites released would be an exception to normal Green Belt policies. General market housing or the inclusion of such in mixed developments used to cross subsidise affordable housing on the same site, will not be appropriate. Any site would have to be located within the confines of an existing settlement, or exceptionally, consideration will be given to the redevelopment or re-use of an existing site where it would have no greater impact than that existing on the openness of the Green Belt and the purposes of including land in it.
3.42 It would need to be proven that the need for such housing was justifiable, socially and economically, both in the short and longer term and that no reasonable alternative accommodation already existed. In this regard, the Council will look to the Parish Councils, together with other agencies such as the Rural Community Council, to provide such evidence through, for example, specific local housing needs surveys or wider village appraisals.
3.43 It is expected that there will be few sites that satisfy this policy and therefore prospective occupiers will be restricted to long-standing residents or their dependents requiring separate accommodation or people permanently employed in an essential local service. Steps would need to be taken, through legal agreements, to ensure that such accommodation remained available for local needs, in perpetuity. Any potential site for affordable housing will be judged against Policy H10 below.
IN VERY SPECIAL CIRCUMSTANCES THE DEVELOPMENT OF SMALL SCALE LOW COST RURAL HOUSING MAY BE PERMITTED IN THE GREEN BELT WHERE ALL THE FOLLOWING CRITERIA ARE MET:
i) THE SITE IS EITHER WITHIN THE CONFINES OF AN EXISTING SETTLEMENT OR, EXCEPTIONALLY, OCCUPIED BY AN EXISTING USE AND/OR BUILDING, THE REDEVELOPMENT OF WHICH WOULD HAVE NO GREATER IMPACT THAN THAT EXISTING ON THE OPENNESS OF THE GREEN BELT AND THE PURPOSES OF INCLUDING LAND IN IT
ii) THERE IS A DEMONSTRABLE LOCAL, SOCIAL AND ECONOMIC NEED IN THE SHORT AND LONGER TERM
iii) NO OTHER SUITABLE ALTERNATIVE ACCOMMODATION IS AVAILABLE WITHIN THE BUILT UP AREA
iv) SATISFACTORY SAFEGUARDS EXIST THROUGH A SECTION 106 AGREEMENT TO LIMIT OCCUPANCY TO LOCAL NEEDS IN PERPETUITY
v) SUCH ACCOMMODATION BEING PROVIDED TO THOSE LOCAL HOUSEHOLDS NOT ABLE TO AFFORD ON THE OPEN MARKET TO RENT OR BUY A DWELLING OF SUFFICIENT SIZE IN THE BOROUGH
vi) SUCH ACCOMMODATION BEING RESTRICTED TO THE FOLLOWING CATEGORIES OF PERSON:
1) EXISTING LOCAL RESIDENTS REQUIRING SEPARATE ACCOMMODATION, OR
2) PEOPLE WHOSE WORK PROVIDES AN IMPORTANT AND NECESSARY LOCAL SERVICE, OR
3) CLOSE RELATIVES OF EXISTING LOCAL RESIDENTS WHO HAVE A DEMONSTRABLE NEED TO EITHER SUPPORT OR BE SUPPORTED BY THEM
FURTHERMORE, ANY DEVELOPMENT WOULD NEED TO COMPLY WITH THE FOLLOWING CRITERIA:
vii) THE PROPOSAL WOULD NOT HAVE AN UNACCEPTABLE DETRIMENTAL IMPACT ON OTHER PERSONS ENJOYMENT OF THE COUNTRYSIDE
viii) THE PROPOSAL COMPLIES WITH POLICY H14
ix) APPLICATIONS WILL BE CONSIDERED AGAINST THE CRITERIA SET OUT IN POLICY GB2
IN THE CONTEXT OF THIS POLICY "LOCAL" IS TAKEN TO REFER TO A PARISH OR WARD, OR IN EXCEPTIONAL CIRCUMSTANCES ADJACENT PARISHES/WARDS.
HOUSING FOR SPECIAL NEEDS GROUPS
3.44 National and local demographic changes have led to increased demands on social and health care facilities. Central Government policy promotes increased provision of accommodation within the community for the needs of older and disabled persons.
3.45 It is important to ensure that people living in elderly persons' homes and other specialised accommodation become part of the community in which they live with access to facilities, like shops, medical services, public transport, etc. However, an over preponderance of such accommodation in a particular locality may have an adverse effect on the character of the area and the balance of the community.
3.46 The type of accommodation special needs housing offers means that there is likely to be a high incidence of disability and/or immobility among residents. Proposals need to ensure that all residents and visitors are able to gain access to the building, communal areas and the individual units. Appendix 4 sets out the Council's requirements for the provision of facilities for people with a disability in new developments.
Supported Accommodation
3.47 The provision of supported accommodation allows for a degree of independence but with the assurance of help being available should difficulties arise. It may also have the advantage, particularly in regard to older people, of freeing up larger and frequently under-occupied properties.
3.48 Provision of special needs housing for sale or rent within the Borough has, since the late 1980s, developed from providing sheltered housing for older people to encompass a much wider client group in need of supported accommodation and more flexibility in the manner in which the support is provided. In addition to providing for the very frail elderly, there is a need to provide for the physically disabled, those with mental health problems, a learning disability, the vulnerable young, and others with special needs.
PROPOSALS FOR SUPPORTED ACCOMMODATION SCHEMES WITHIN THE BUILT UP AREA WILL ONLY BE PERMITTED WHERE THE FOLLOWING CRITERIA ARE MET:
i) THE PROPOSAL IS IN CLOSE PROXIMITY TO FACILITIES E.G. SHOPS, PUBLIC TRANSPORT, HEALTH AND LEISURE FACILITIES
ii) WHERE APPROPRIATE THE SCHEME SHALL PROVIDE SUFFICIENT INTEGRATED ACCOMMODATION TO ALLOW FOR THE LEVEL OF SUPPORT REQUIRED FOR THE CLIENT GROUP FOR WHOM THE SCHEME IS INTENDED
iii) THE PROPOSAL PROVIDES APPROPRIATE LANDSCAPING AND AMENITY SPACE
WHERE APPROPRIATE, A CONDITION WILL BE IMPOSED RESTRICTING OCCUPATION TO PERSONS REQUIRING SUPPORTED ACCOMMODATION.
Residential Homes
3.49 Current trends in the provision of medical and social services illustrate a movement away from large public sector facilities and institutions, such as the former Warley Hospital, to smaller units located in the community and increased private sector provision. Residential homes have been central to the Government's philosophy of “care in the community”, which aims to promote and foster community care particularly for older people, those with mental health problems and those with learning and physical disabilities.
3.50 Under the Town and Country Planning (Use Classes) Order 1987, Class C3 allows the use of a dwelling house by not more than 6 residents living together as a "single household" (including a household where care is provided for residents) without requiring planning consent. Where planning permission is required, applications will be considered in the light of the policy criteria set out below.
PROPOSALS INCLUDING NEW BUILDINGS OR A CHANGE OF USE FOR RESIDENTIAL HOMES WITHIN THE BUILT UP AREA WILL ONLY BE PERMITTED WHERE THE FOLLOWING CRITERIA ARE MET:
i) THE PROPOSAL WOULD NOT RESULT IN THE OVER CONCENTRATION OF RESIDENTIAL HOMES IN ANY INDIVIDUAL STREET
ii) THE PROPOSAL IS WITHIN AN ESTABLISHED RESIDENTIAL AREA AND WITHIN CLOSE PROXIMITY TO FACILITIES SUCH AS SHOPS, LEISURE AND HEALTH CARE FACILITIES AND, WHERE APPROPRIATE, EMPLOYMENT AND DAY CENTRES
iii) APPLICANTS WILL BE EXPECTED TO DEMONSTRATE THE SUITABILITY OF THE PREMISES TO MEET THE PARTICULAR NEEDS OF THE GROUP TO BE HOUSED, IN PARTICULAR TO PROVIDE SOUND INSULATION, MEANS OF ESCAPE AND ACCESS FOR PEOPLE WITH A DISABILITY OR SIMILAR MOBILITY DIFFICULTIES
WHERE APPROPRIATE A CONDITION WILL BE IMPOSED RESTRICTING OCCUPATION TO SPECIAL NEEDS GROUPS
FOR THE PURPOSES OF THIS POLICY RESIDENTIAL HOMES ARE:
i) NURSING HOMES
ii) COMMUNAL HOUSING FOR PEOPLE WITH A DISABILITY OR OTHER SPECIAL NEEDS GROUPS
Permanent Sites for Gypsy Travellers
3.51 Circular 1/94 “Gypsy Sites and Planning” introduced new guidance on the provision of Gypsy sites stating that they are no longer appropriate uses in the Green Belt. The criminal Justice and Public Order Act 1994 also removed the statutory duty of local authorities to provide sites for Gypsies. In December 2004, the government published a Consultation Paper on ‘Planning for Gypsy and Traveller Sites’, which is intended to replace Circular 1/94. This advice will inform a review of the Replacement Local Plan through the new Local Development Framework, introduced in the Planning and Compulsory Purchase Act 2004.
3.52 Whilst there is no permanent local authority Gypsy site within the Borough, there were, as at July 2001, 7 authorised private Gypsy sites, accommodating 7 families and 10 caravans. At that same date there were 2 unauthorised private sites within the Borough accommodating 3 families and 3 caravans.
3.53 The number and movement of Gypsies in the Borough are monitored and the Council will continue to liaise with the County Council’s Gypsy Service Manager in quantifying the need for further sites in the Borough. However, as gypsy sites are not an appropriate Green Belt use and land within the urban area remains severely limited, no appropriate locations have been able to be identified for permanent resident gypsy travellers. Further private site proposals will be considered against the criteria in Policy H13. Any application for a site within the Green Belt would need to be able to show the exceptional circumstances necessary to allow inappropriate development.
H13 Permanent Sites for Gypsy Travellers
THE COUNCIL MAY ALLOW THE PROVISION OF SMALL GYPSY TRAVELLERS SITES IN APPROPRIATE LOCATIONS WITHIN AREAS EXCLUDED FROM THE GREEN BELT, WHERE THE FOLLOWING CRITERIA ARE MET:
i) THE SITE IS WELL SCREENED
ii) SUCH ACCOMMODATION IS RESTRICTED TO GYPSIES WHO RESIDE IN OR WHO REGULARLY RESORT TO THE BOROUGH.
As a matter of clarification "regularly resort" refers to those gypsies who regularly resort to the Borough for a minimum of 3 months in any one-year.
NEW HOUSING DEVELOPMENT
Housing Density
3.54 Government advice is critical of historical levels of housing density as being unsustainable and PPG3 sets out levels of density that should be encouraged. Good design does not preclude high-density development. Imaginative design and layout can achieve more efficient use of land without compromising the quality of the environment.
3.55 Better use of existing urban land will clearly help to protect the Borough’s Green Belt. The Council will, therefore, aim to avoid any development that makes an inefficient use of land. Densities of at least 30 dwellings per hectare will generally be expected unless deemed inappropriate due to the special character of the area (e.g. a well-landscaped character, which may be considered ecologically and visually worthy of conservation), transport impact or harm to residential amenities. Densities of at least 65 dwellings to the hectare will be expected in locations with good public transport accessibility. These densities are considered to be reasonable minima, and significantly higher densities have been achieved in more recent developments.
THE COUNCIL WILL EXPECT ANY PROPOSAL FOR NEW RESIDENTIAL DEVELOPMENT TO BE OF AN APPROPRIATE DENSITY THAT MAKES EFFICIENT USE OF LAND.
RESIDENTIAL DENSITIES WILL BE EXPECTED TO BE NO LESS THAN 30 DWELLINGS PER HECTARE NET UNLESS THE SPECIAL CHARACTER OF THE SURROUNDING AREA DETERMINES THAT SUCH DENSITIES WOULD BE INAPPROPRIATE.
DENSITIES GREATER THAN 65 DWELLINGS PER HECTARE NET WILL BE EXPECTED IN TOWN AND DISTRICT CENTRES OR OTHER LOCATIONS WITH GOOD PUBLIC TRANSPORT ACCESSIBILITY.
A Target and Indicator for monitoring this policy is set out in Chapter 13
Hutton Mount
3.56 Hutton Mount is an attractive residential area of over 80 hectares that is characterised by the number of large detached houses generally occupying spacious plots. The low density-residential development is set within well-landscaped gardens served by attractive tree-lined private roads. Generally the dwellings, which are of individual styles, are set well apart, and it is the generous distance between buildings which is a significant factor in contributing to the character of the area.
3.57 The low (pre-dating planning control) density of the estate stems from the original building scheme which specified a 60ft. (18.3m) minimum plot frontage with a covenant restricting development to one dwelling per quarter acre plot. In subsequently drafting a policy for the area, the Council considered that it was important to retain these standards, which had been adhered to over time and resulted in the attractive character of the area.
3.58 Notwithstanding, therefore, the desire to increase densities generally to make best use of previously developed land; this mature, well-landscaped and spacious residential area has a distinctive character, which is worthy of retention. Over recent years there has been increased pressure for infill development and there is a danger that this character will be eroded if new development is allowed to proceed without careful regard being paid to its compatibility with the existing properties in terms of plot size, frontage, etc. Similarly, the minimum distance required between an extension and the boundary of the property will be greater than elsewhere in the Borough and will apply to both single and two-storey extensions (see Appendix 5).
WITHIN HUTTON MOUNT ANY NEW DEVELOPMENT SHALL REFLECT THE CHARACTER AND DENSITY OF THE SURROUNDING AREA AND SHALL HAVE:
a) A MINIMUM NET PLOT SIZE OF 0.1 HECTARES PER DWELLING
b) BUILDING LINE FRONTAGES OF NOT LESS THAN 18.3M
c) NO PART OF ANY BUILDING SHALL BE CLOSER THAN 1.2M TO THE PLOT BOUNDARY
IN THE CASE OF INFILL DEVELOPMENT INVOLVING THE SUB-DIVISION OF EXISTING DWELLING PLOTS, THE PLOT REMAINING WITH THE EXISTING DWELLING(S) WILL BE REQUIRED TO MEET THE CRITERIA FOR NEW DWELLINGS.
Lifetime Homes
3.59 Factors such as increasing life expectancy and the government’s care in the community policies will increase the need for adaptations to residential properties to accommodate the needs of the frail and disabled. The Joseph Rowntree Foundation document “Building Lifetime Homes” lists a set of design standards for new residential properties that, if incorporated into the original design, help to ensure that the home is flexible, adaptable and accessible. The benefits of providing, for example, level thresholds and wider doorways, however, are not restricted to the elderly and those with mobility problems but also families with young children. Such properties meet the varying needs of a household as they change over a lifetime and can accommodate the majority of adaptations that may be necessary with maximum ease and minimum cost.
THE DESIGN AND LAYOUT OF ALL NEW RESIDENTIAL PROPERTIES SHOULD SEEK TO INCREASE THEIR FLEXIBILITY, CONVENIENCE, SAFETY AND ACCESSIBILITY SUCH THAT THEY ARE ABLE TO PROVIDE FOR, OR BE EASILY ADAPTED TO, THE CHANGING NEEDS OF HOUSEHOLDS AND/OR AN OCCUPIER’S MOBILITY. TO THIS END, THE “LIFETIME HOMES” DESIGN STANDARDS SET OUT IN APPENDIX 4 SHOULD, WHERE APPROPRIATE, BE INCORPORATED INTO ALL PROPOSALS.
MINOR RESIDENTIAL DEVELOPMENT
3.60 As their family circumstances change, people's requirements in terms of housing will also often change. In order to meet these requirements some will move house, whilst others may choose to adapt their existing property to fit their changing circumstances by, for example, extending the property or utilising the roof space or adjoining garage to provide additional living accommodation.
3.61 The Council will consider such minor residential development proposals against the core policies. However, additional and more specific policy considerations are set out below for dormer windows and satellite dishes and further informal planning guidance is provided in Appendix 5.
Dormer Windows
3.62 Conversion of the loft space to provide additional habitable accommodation normally requires some facilities to provide natural light. This can be achieved through the installation of windows in the gable end or flush to the roof pitch but more usually through the installation of dormer windows which have the added advantage of providing more space and head height. In certain circumstances, dormer windows can be installed without planning consent being required. Where such consent is required, however, careful consideration will be given to the scale and design of the dormer in relation to the roof in which it is to be installed and the street scene generally. Poorly designed dormer windows can appear incongruous and detract from the appearance and profile of the property.
DORMER WINDOWS WHICH ARE OUT OF SCALE AND POORLY RELATED IN DESIGN TO THE ROOF IN WHICH THEY ARE TO BE INSTALLED WILL NOT BE PERMITTED. THE DESIGN AND SCALE OF A DORMER WINDOW SHOULD REMAIN A SUBSIDIARY RATHER THAN DOMINANT FEATURE OF THE ROOF, BE SET IN FROM ANY WALL OF THE PROPERTY AND BE BELOW THE RIDGE HEIGHT.
Satellite Dishes
3.63 Satellite dishes are an increasingly common feature attached to the outside of a dwelling. Given certain requirements relating to their size and location, planning permission may not be required for the installation of a dish. However, whilst the design of a dish can reduce its obtrusiveness, they have the potential for adding clutter to the street scene and detracting from the appearance of the building. A dish should be sited, therefore, in a manner and location, which, so far as is practicable, minimises its impact on the property itself, neighbouring properties and the street scene in general. Where permission is required, a dish will not be permitted on a chimney or in a position where any part of the dish protrudes above the ridge height.
3.64 A block of flats should always have a communal dish (or aerial) where a cable network is not available. Similarly, developers will be required to provide a communal satellite dish (or communal aerials for terrestrial television and radio) in order to reduce such clutter in the street scene.