Cheltenham Plan Pre-Submission consultation

Pre-Submission Cheltenham Plan

12 Housing mix and standards


12.1 The Joint core Strategy (JCS) has identified housing need for specific types of dwellings but has delegated policies on meeting those needs to district plans. The policies in this section seek to provide positive support for proposals which will help meet specific housing needs. It will be noted that needs for specific, high quality student accommodation and well-designed elderly care provision are key to the future of Cheltenham.


12.2 There are three main classifications of affordable housing as set out in Annex 2 of the NPPF:

  • Social rented housing is owned by local authorities and private registered providers (as defined in Section 80 of the Housing and Regeneration Act 2008), for which guideline target rents are determined through the national rent regime.
  • Affordable rented housing is let by local authorities or private registered providers of social housing to households who are eligible for social rented housing. Affordable rent is subject to rent controls that require a rent of no more than 80% of the local market rent (including service charges, where applicable)
  • Intermediate housing is housing for sale and rent provided at a cost above social rent, but below market levels subject to the criteria in the affordable housing definition above. These can include shared equity (shared ownership and equity loans), other low-cost housing for sale and intermediate rent, but not affordable rented housing.

12.3 Housing that does not meet the above definition of affordable housing, such as ‘low cost market housing’, is not currently defined as affordable housing but may be included within the definition subject to legislative changes in future.

12.4 Affordable housing policy for Cheltenham is set out in the Joint Core Strategy (Policy SD12 refers). To complement this, Cheltenham Council is pro-actively pursuing a number of delivery methods to help secure affordable homes. For instance:

  • Working with other housing enablers such as Cheltenham Borough Homes to deliver 100 per cent affordable housing schemes on redundant small-scale Council owned sites.
  • Introducing covenants requiring specific levels of affordable housing to be provided on the sale/redevelopment of Council owned sites.
  • Using Right to Buy receipts to purchase homes on the open market in order that they can be used as affordable homes in future.
  • Exploring options, including enforcement action, to bring vacant residential properties back into use for affordable housing.

12.5 Further alternative delivery methods will be investigated by the Council in future and are likely to include:

  • Encouraging proposals that bring vacant floorspace above shops back into beneficial use, particularly for affordable residential accommodation.
  • Using compulsory purchase powers to help progress stalled sites.
  • Exploring other measures (including legislative changes) that will help tackle the issue of unimplemented planning consents.
  • Acquiring homes previously lost through Right to Buy.
  • Acquiring HMOs.
  • Acquiring sites for development, creating a mix of tenures and dwelling sizes to meet a range of needs, including specialist housing needs with associated space and design standards.
  • Acquiring smaller sites (10 dwellings or under) that would otherwise fail to trigger an affordable housing requirement through Section 106 arrangements.
  • Focussing on Section 106 sites that are failing to meet the full affordable housing obligations for viability reasons, by purchasing additional dwellings that would take the number of homes acquired up to (and potentially beyond) the full affordable housing requirement for the site.
  • Providing private rented housing (on long-term lets) in the above circumstances to support the growing demand for private rented accommodation.

12.6 Commuted sums provided in lieu of affordable housing will be used to support any or all of the above.

12.7 The aforementioned methods will assist in the delivery of the Council’s emerging Housing & Homelessness Strategy 2018 – 2023.


12.8 The number of full-time students in Cheltenham has grown in the last decade, arising principally from the development of the University of Gloucestershire. The University operates some halls of residence, and is seeking to develop more of these. The Council generally supports the provision of more purpose-built student accommodation, although proposals would need to be judged in the light of other relevant local plan policies.

12.9 The University of Gloucestershire projects that student numbers in Cheltenham and Gloucester will increase by 50% over the plan period, resulting in approximately 4,000 additional students (JCS Examination Document 118). This is expected to result in a need for 450 new private dwellings over the plan period which is accounted for within the Objectively Assessed Need (OAN). In addition to this, the University estimates the need for an expansion of purpose-built halls of residence accommodation for students to provide an additional 1,500 bed spaces across the JCS area within the plan period (Policy SD11, JCS).

12.10 Since 2012, both Cheltenham Borough Council and Gloucester City Council have worked closely with the University to explore the provision of additional student accommodation, with a focus on expansion within existing sites. Many of these additional bed spaces have already been consented between 2011 and the adoption of the JCS, as set out in Table 5 below.

Table 5: Additional Student Bed Spaces
  Requirement Identified Supply (completions & consents) Remaining Requirement Remaining Requirement per annum
Gloucester City Council











Cheltenham Borough Council 765
Tewkesbury Borough Council 0
Total 1500 1321


12.11 Significant progress has already been made in meeting the need for student housing in Cheltenham and Gloucester. The remaining requirement for the JCS period at the time of writing is 179 bed spaces. It is expected that the remaining bed spaces will come forward through windfall development over the plan period.


The Council will work with local higher education establishments and student housing providers to facilitate the delivery of bespoke student accommodation at appropriate locations. The Council expects proposals for student accommodation to demonstrate that they support educational establishments within the Borough. Housing provision for students should be located in accessible locations, close to public transport corridors and local services and facilities.

The Council will support proposals that:

a) Provide a high-quality living environment which includes a range of unit sizes and layouts.

b) Ensure that facilities will be well managed and that there will be no detriment to local amenity or unreasonable harm caused to nearby residents or the surrounding area.

c) Demonstrate that the facility is suitable for year-round occupation and that it has long-term sustainability and adaptability.

This policy contributes towards achieving the Cheltenham Plan Vision: Theme A –objectives c, d, e, g and i


12.12 Whilst sheltered housing schemes, particularly those providing minor nursing care or assistance with basic household chores, can help to bridge the gap between older people living independently in their own homes and their requiring constant care and attention, increasing old age and infirmity may eventually lead to the decision that a residential or nursing home may be the best solution for the individual. The increasing proportion of older people in the population has led to an increase in the demand for such homes.


Housing choice for older people, and supported and special needs housing proposals for older people, should focus on the provision of high-specification care-ready accommodation. The Council will support proposals that:

a) Help to meet an identified need.

b) Demonstrate that they would not have a harmful impact on the character and amenities of the surrounding area.

c) Are accessible to local shops and easily accessible by public transport.

A proportion of a scheme providing elderly care, defined by either C3 or C2 Use Class, or for supported or special needs housing, will normally be required to contribute to affordable housing need. Schemes should demonstrate adequate external amenity space to provide a high-quality and safe external living environment for residents, including areas for sitting, socialising, gardening and active leisure pursuits.

Proposals for specialist elderly care, including dementia care accommodation, should provide adequate communal facilities, including accommodation for essential staff on site, and should reflect current best practice in the design of such specialist accommodation.

This policy contributes towards achieving the Cheltenham Plan Vision: Theme A –objectives a, b, c, d, e, g and i; Theme C - objective d.

12.13 Where proposals for elderly care provision form part of a larger development site, masterplanning should give careful consideration to the needs of the elderly. Opportunities for an active and engaged lifestyle, as well as the creation of spaces for informal social interaction, should be provided.

12.14 The JCS identifies that older people accounted for 13% of the population within the JCS area in 2011 and that this proportion could increase to 20% by 2031. It is therefore essential that a proportion of new housing in the area should be suited to the needs of older people, including specialist accommodation such as nursing homes, retirement villages and care-based housing including extra care.

12.15 The need for 1,456 C3-use retirement/sheltered market housing units and 1,011 C2-use extra care units have been addressed through the JCS OAN. However, through the examination process, the need for 1,558 C2 use non-specified ‘residential institution’ bed spaces was identified over and above the OAN for the plan period across the JCS area (Inspector’s Interim Report May 2016, Examination Document 232). A significant number of these additional bed spaces, usually made up of care home and nursing home provision, have already been constructed or consented between 2011 and the adoption of the JCS, as set out in Table 6 below. The provision of the remaining need for C2-use extra care bed spaces must be captured through the emerging Local Plans, divided between the three authorities.

Table 6: Additional C2 Bed Spaces
  Requirement Identified Supply (completions & consents) Remaining Requirement Remaining Requirement per annum
Gloucester City Council











Cheltenham Borough Council 269
Tewkesbury Borough Council 66
Total 1558 524


12.16 Around a third of the overall need for this type of bed space has been met at the time of writing. This indicates that, over the course of the whole plan period, windfall development is likely to meet the total need identified in the JCS.

12.17 There is a need for 126 units of this type within Cheltenham (JCS Examination Document EXAM 224) so this has already been exceeded. However, in order to assist in the overall delivery across the JCS, the Cheltenham Plan includes Policy HM2.


12.18 In the context of limited opportunities for housebuilding within the Borough, the retention, improvement and maintenance of the existing stock is vital. Older housing areas have well-established communities and the retention of existing housing is often the best way of maintaining community identity. Houses in the town centre also play an important role in providing accommodation close to many social, welfare and transport facilities, by contributing to the vitality and safety of the town centre, and by helping to reduce crime.

12.19 The greatest risks to the dwelling stock exist in the town centre and on its fringes where older terraced housing, much of it important to Cheltenham’s historic character, suffers from problems of poor condition and high maintenance costs. Many older houses are still in good condition, however, and even where this is not the case, improvement can often be cheaper than demolition and new construction.


Development involving the loss of residential accommodation through the change of use or demolition of existing housing will not be permitted, except where:

a) continued residential use is undesirable because of environmental conditions; or

b) there is evidence that the arrangement of the accommodation and its facilities are very poor and difficult to improve for residential use; or

c) a change of use is necessary to ensure the retention or renovation of a building of architectural or historic interest; or

d) the proposed use would be beneficial to the wider economy and the local community (Note 1) and cannot suitably be accommodated on alternative sites.

This policy contributes towards achieving the Cheltenham Plan Vision: Theme A –objectives a and c; Theme B- objective a; Theme C - objectives a, d and f.

Note 1: Services and facilities which support the economy and the needs of local communities will be considered; these may include doctors’ or dentists’ surgeries, hotels, guest houses, nursing homes, residential institutions, playgroups, children’s nurseries and other community facilities such as corner shops. Each case will be judged on its merits, taking into account its effect on the locality.

12.20 The erosion of areas which are essentially residential in character by commercial uses, except those ancillary to the residential uses, will be strongly resisted by the Council, especially within those parts of the Cheltenham (Central) Conservation Area just outside the town centre where pressures for change are greatest, and the quiet, residential environment could be seriously harmed by commercial activities. The above policy is applied to minimise the loss of existing dwellings.


12.21 The Town and Country Planning (General Permitted Development) Order 2015, as amended, grants permission for a wide range of development associated with agricultural uses of land on sites of 5ha or more. In certain cases, permission cannot be exercised unless the developer has applied for a determination from the Council as to whether approval will be required for specified details.


Permission for new agricultural or forestry dwellings will be granted only where:

a) a justified need to provide accommodation to enable farm or forestry workers to live near or at their place of work has been demonstrated; and

b) the dwelling is of a size commensurate with, and suitably located to meet, the identified functional need, and is well related to other farm buildings or other dwellings.

The Borough Council will limit by condition the occupation of that accommodation to a person solely or mainly working or last working in agriculture or in forestry, or a widow or widower of such a person, and to any resident dependants.

This policy contributes towards achieving the Cheltenham Plan Vision: Theme A –objective b; Theme C - objective b.

12.22 In making such a determination, the Council will take account of the effect of the development on the landscape and character of the area, archaeological features, listed buildings and wildlife, as well as the agricultural need of the farm. In the case of new agricultural buildings, the Council will also continue its policy of taking into account likely problems of noise, smell, effluent disposal and effect on the highways, in view of the proximity of the countryside to the urban area.


12.23 A house in multiple occupation (HMO) can be defined in simple terms as a shared residential property where a certain number of occupants who are not related to each other share basic amenities such as kitchen areas and bathroom facilities.

12.24 For planning purposes, small HMOs fall within use class C4, which are defined as:
“small shared houses or flats occupied by between three and six unrelated individuals, as their only or main residence, who share basic amenities such as a kitchen or bathroom.”

12.25 Larger HMOs, occupied by more than six unrelated individuals, fall within the Sui Generis use class (meaning “of their own kind”). Planning permission has always been required for proposals for large HMOs (Sui Generis use), whether this be purpose-built accommodation or the change of use of an existing property.

12.26 Whilst HMOs are an important type of housing, high concentrations can have a negative impact on the town’s communities. These negative impacts can include increased noise nuisance, anti-social behaviour or unkempt gardens. Some parts of the Borough, especially those close to the University, are becoming dominated by a high number of HMOs which are causing problems for other residents.

12.27 The Government report Evidence Gathering – Housing in Multiple Occupation and Possible Planning Responses (Department for Communities and Local Government 2008) looks at the problems caused by high concentrations of HMOs and considers the current and potential mechanisms to address these problems. Within this report, the following issues are associated with high concentrations of HMOs:

  • anti-social behaviour, noise and nuisance;
  • imbalanced and unsustainable communities;
  • negative impacts on the physical environment and streetscape;
  • pressures upon parking provision;
  • increased crime;
  • growth in private rented sector at the expenses of owner-occupation;
  • pressure upon local community facilities and;
  • restructuring of retail, commercial services and recreational facilities to suit the lifestyles of the predominant population.

12.28 A number of other local planning authorities have introduced policy measures in order to control the proliferation of HMOs in their areas. Analysis of the thresholds and percentage limits that other authorities have used to limit further HMOs in their areas has been undertaken to inform the selection of a policy approach for Cheltenham. The National HMO Lobby, a voluntary association of local community action groups which are concerned with the impacts of HMOs on their communities, has attempted to define what they view as a high concentration of HMOs, and the level above which new HMOs should be limited. The National HMO Lobby suggests that 10% of properties or 20% of the population is the ‘tipping-point’ for HMO-dominance in a neighbourhood. Whilst the HMO Lobby is an informal collection of community groups, it brings together evidence from over 50 locations around the country where there are perceived high concentrations of HMOs. Their research provides a good starting point to assess how to judge what constitutes a balanced community against Cheltenham’s own specific housing needs.

12.29 Setting a percentage threshold in Cheltenham will implement this policy by limiting the number of HMOs in communities that already contain an above average concentration of HMOs, and will also control the growth of HMOs in other parts of the Borough to prevent the displacement of the problem to other neighbourhoods.

12.30 Research carried out in 2016-2017 found that within the St. Paul’s ward there were 350 HMOs. This translates into approximately 12% of households in that ward.

12.31 The Council will keep other areas in the town at risk of high concentration of HMOs under review and will take action where necessary.


12.32 Local Planning Authorities are considering making a direction under Article 4(1) of the Town and Country Planning (General Permitted Development) Order 2015 (as amended) so that change of use by permitted development must instead require planning permission.

12.33 A change of use from a use within class C3 (dwelling houses) to a use falling within class C4 (HMOs) has been permitted development since October 2010.

12.34 The introduction of an Article 4 Direction, which may be reviewed by the Secretary of State before coming into force, will remove this permitted development right and therefore, a change of use to a HMO would require planning permission. The Council is considering issuing an Article 4 Direction to restrict HMO development in the St. Paul’s ward. This will be carried out in a separate but linked process to the Cheltenham Plan. Once in force, subject to specified statutory procedures and timescales, the formation of all new HMOs in St Paul’s will be controlled. This will result in Policy HM5 applying to applications for all HMOs in St. Paul’s.



Planning permission will be granted for proposals for use class C4 small Houses in Multiple Occupation or Sui Generis large Houses in Multiple Occupation in the St. Pauls Ward, provided that (based on the results of a biennial survey undertaken by the Council):

a) The proportion of HMO dwellings does not exceed 10% of all residential properties within a 100 metre radius of the application site; and

b) The granting of planning permission will not result in the creation of more than two adjacent properties in HMO use; and

c) The proposal does not have an adverse impact on the amenity of nearby properties by ensuring:

  • adequate provision for off-street parking;
  • highway safety and ease of access for emergency vehicles;
  • regard is given to Secured by Design guidance, particularly relating to occupier security, as published by the Association of Chief Police Officers (ACPO);
  • sufficient provision for waste and recycling;
  • the proposal is in keeping with the character of the area.

In exceptional circumstances, within areas that have a very high concentration of HMOs, planning permission for HMO use may be granted where it can be demonstrated that there is no market demand for continued C3 occupation.

This policy contributes towards achieving the Cheltenham Plan Vision: Theme A –objectives b, c, d, g and i; Theme C - objective a.

12.35 Policy HM5 sets a threshold whereby planning permission for an HMO can only be given where the percentage of HMOs in the area does not exceed 10%.

12.36 The Council will use a radius approach around the application site to calculate the number of residential properties surrounding a proposal to apply a threshold limit, based on the results of a two-yearly survey of HMOs in the area undertaken by the Council. Using a fixed radius will be a clear way, for both applicants and Planning Officers dealing with the applications, to assess the percentage of HMOs in an area. Assessing the concentration of HMOs by street was considered as an alternative to using a fixed-radius approach. However, as streets vary greatly in length and nature, it was considered that using the fixed radius was a more suitable and consistent approach. Using the ward boundaries to assess the percentage threshold would offer too large an area to judge if an over-concentration of HMOs has occurred in a local community.

12.37 The Council also considered assessing the number of HMOs within the search area at the point of each application, but this would unduly impede the planning application process and cause case officers to duplicate work in each case. Instead therefore, decisions will be based on the results of a biennial survey of HMOs in the St Paul’s area undertaken by the Council. This data will be available for publication on completion of each survey.

12.38 The number of properties will be calculated using the Council‘s GIS (Geographic Information Systems) mapping software. Each property has a unique location point defined on the National Land and Property Gazetteer (NLPG) and the location point of the proposed HMO will be the centre of the 100m radius. The number of residential properties falling within the 100m radius of the proposed HMO will be assessed by totalling the location points falling within that defined radius. Properties that fall partly within the 100m radius will only be included if the location point, as depicted on the NLPG, falls within this buffer.

12.39 For the purpose of this approach, dwellings that are either within purpose-built blocks of flats, or within houses that have been sub-divided into separate flats, are all counted as one single property, and only the first address point is counted. This will avoid counts becoming ‘skewed’ by a high proportion of flats in one small area, such as typically terraced streets, thus reducing the concentration of HMOs that are reported. When counting HMOs, properties that contain flats already in HMO use will only be counted as one HMO, irrespective of how many HMO flats are already in existence within the whole building. In instances where there are already several HMO flats within one dwelling, the effect of allowing further HMO uses will be assessed in relation to the impact it would have on the character of the area.

12.40 It is also important when assessing planning applications for HMO uses to ensure that further smaller concentrations, or clustering, of HMOs do not occur within the 10% threshold.

12.41 To achieve this, HMOs will not be permitted if the application property falls:

  • adjacent to two existing HMO uses, or
  • between two existing HMO uses and would therefore result in more than two HMOs in a row within a street.


12.42 The Principal Urban Area (PUA) marks the limits of Cheltenham town, being the dividing line between built-up/urban areas (the settlement) and non-urban or rural areas (the countryside), to define where planning policies apply.

12.43 A settlement boundary can serve a number of related but separate purposes such as:

  • creating an edge to existing development, thereby encouraging consolidation;
  • helping to separate communities and therefore retain their individual identities; and
  • defining the logical boundary between areas with different features and purposes, e.g. between areas with environmental or landscape designations and those suitable for development.

12.44 There are a number of advantages of settlement boundaries:

  • they provide an easy-to-understand tool that gives certainty for landowners, developers and community over where development is likely to be acceptable and where is it not;
  • they can direct development to the urban area and this can help increase the viability of local services, as well as encourage new ones to establish;
  • they ensure a plan-led and more controlled approach to future development, providing a firm basis for protecting the countryside from unnecessary encroachment;
  • they can allow a presumption in favour of development of sites that are too small to be identified as formal allocations in a local plan.

12.45 JCS Policy SP2 directs new development to existing urban areas and Strategic Allocations. In order to apply this policy in the best possible way, it is necessary to have an up-to-date, accurate boundary for Cheltenham’s urban area.

12.46 The PUA is an important designation which should be as up-to-date as possible if it is to remain as useful as possible. It is good practice to use the Cheltenham Plan process to undertake a review of anomalies. There have also been some instances of recent edge-of-settlement developments which fit within the built form of the town and should be included.

12.47 Boundaries have been redrawn to include sites where land has been developed or planning permission has been granted for development over the past few years. The circumstances of each development have been investigated to consider whether or not it is appropriate to include within a revised boundary.

12.48 Officers undertook a desktop survey using GIS mapping and aerial photography together with information from the monitoring of planning applications, permissions and developments to locate any anomalies and areas where new development has taken place beyond the existing PUA. The circumstances of each development have been investigated to consider whether or not it is appropriate to include within a revised boundary.

12.49 Each alteration is listed in Table 7. They are also included on the Proposals Map.

Table 7: Alterations to the Principal Urban Area
Ref Location Area (ha) Addition / subtraction Reason
1 Swindon Village Primary School 0.26 Addition Inclusion of new school buildings
2 Jemaro, Hyde Lane GL51 9QN 0.2 Addition Inclusion of building and the creation of consistent boundary
3 81a New Barn Lane 0.15 Addition Inclusion of new dwelling and residential curtilage
4 49 & 51 Apple Orchard, Prestbury 0.09 Addition Inclusion of residential gardens and creation of consistent boundary
5 Pilgrim Cottage, Lake Street, Prestbury 0.05 Addition Inclusion of residential garden
6 Rear of Beechcroft, Bowbridge House 0.003 Addition Minor amendment of boundary anomaly
7 3 The Orchards, Glenfall Way 0.19 Addition Inclusion of residential building and garden
8 Balcarras School 0.26 Addition Inclusion of new school buildings
9 Timbercombe Gate 0.32 Addition Inclusion of new residential development
10 Timbercombe Cottage, Timbercombe Lane 0.12 Addition Inclusion of residential garden
11 Meadow House, Gadshill Road 0.32 Addition Inclusion of residential garden
12 The Richard Pate School 0.4 Addition Minor amendments to more accurately conform to building dimensions
13 Pilford Court 0.31 Addition Inclusion of new residential development
14 26 Pilford Road 0.02 Addition Inclusion of residential garden
15 Cliff House, Leckhampton Hill & Highfield, Daisy Bank Road 1.11 Addition Inclusion of residential gardens and creation of consistent boundary
16 17, 19 & The Sleepers, Merlin Way 0.18 Addition Inclusion of new residential development
17 106 Frith Lodge, Shurdington Road 0.11 Addition Inclusion of new residential development
18 4 & 5 The Spindles 0.08 Addition Inclusion of new residential development
19 Old Farm Drive, Manor End & Manor Farm Drive 1.35 Addition Inclusion of new residential development
20 Highfields, Cold Pool Lane 0.06 Addition Inclusion of new residential development
21 The Hayloft, The Reddings 0.07 Addition Inclusion of residential dwelling
22 Chestnuts Farm, Branch Road 0.04 Addition Inclusion of existing farm buildings to form consistent boundary
23 Land south east of Imber, Undercliff Avenue 0.19 Subtraction The land is not urban in character and forms part of the wider rural area