View Response

Response Details

Response Details
From Adrian Hornzee
Date Started: 14 Mar 2017 10:41. Last modified: 14 Mar 2017 10:41
Status Complete
Response ID #528358

1

Agree that the challenges set out in section 2 of the consultation document are the key challenges facing Elmbridge?

 

  • Yes, I agree
  • No, I disagree
  • I don't Know

Please explain your answer
You present a lot of numbers and pictures about additional housing and other demand. However, what the figures are actually based upon - i.e. the evidence - is simply not clear in your consultation document. It’s also not clear when these numbers were created – or whether they have been adjusted in the light of major recent changes on the national and global stage, such as the UK’s recent decision to leave the EU, which will surely have a major impact. It doesn’t seem right to consider bulldozing green belt land that has been preserved for decades to prevent urban sprawl - on the basis of questionable and unclear long term statistics.

In fact, I would argue that the proposals themselves are one of the biggest risks facing Elmbridge – i.e. unnecessarily and irreversibly losing our Green Belt land on the basis of speculative forecasts.

Key challenges which should be considered in the local plan which are not properly addressed in the consultation document:
• To retain the quality of life for existing residents in Elmbridge
• To address infrastructure requirements
• To resolve the transport congestion in our area – Cobham/Stoke d’Abernon/Oxshott have severe constraints due to enclosure by A3/M25
• To avoid further development on our Green Belt (Elmbridge has already stated previously that a central part of its core strategy is to protect the Green Belt and this should remain an absolute)
• To avoid further urbanisation and in-fill
• To maintain the environment and avoid further pollution
• To take account of the value of green spaces for the recreation of local people

2

Do you consider there are other challenges that we should be addressing?

 

  • Yes
  • No
  • Don’t know

Please explain your answer
Key challenges which should be considered in the local plan which are not properly addressed in the consultation document:
• To retain the quality of life for existing residents in Elmbridge
• To address infrastructure requirements
• To resolve the transport congestion in our area – Cobham/Stoke d’Abernon/Oxshott have severe constraints due to enclosure by A3/M25
• To avoid further development on our Green Belt (Elmbridge has already stated previously that a central part of its core strategy is to protect the Green Belt and this should remain an absolute)
• To avoid further urbanisation and in-fill
• To maintain the environment and avoid further pollution
• To take account of the value of green spaces for the recreation of local people

3

Do you consider any particular challenge or challenges that are more important than the others?

  • Yes
  • No
  • Don’t know

Please explain your answer
If you consider severity and likelihood in rating the importance of different risks and challenges then those listed below are significantly more important than the housing and other needs in your consultation document. The challenges and risks listed below are both severe and certain. They are real, serious and growing challenges right now – and the proposals in your consultation document will make them an order of magnitude worse:

• Infrastructure – schools, GPs, etc.
• Infrastructure – currently the traffic congestion and roads in Cobham/Stoke d’Abernon and Oxshott are unable to cope with current levels of traffic
• Urbanisation – increasing encroachment into the Green Belt
• Pollution – levels already unacceptably high given A3 & M25 proximity
• Erosion of environment and not protecting natural habitat
• Provision for the elderly
• Catering for the health of the current population
• Maintaining quality of life for residents

Elmbridge Council has not clearly demonstrated or evidenced in its consultation document that the housing or other challenges it presented are either severe or likely. In fact as mentioned above, the basis for these figures is not clear. Therefore they cannot be considered as important or pressing as the challenges I have listed above.

4

Agree that Option 2 is the most appropriate option?

  • Yes, I agree
  • No, I disagree
  • I don’t know

If you disagree, please explain why and what other option would you support and why?
• The questionnaire does not provide the opportunity to select either of the other options. Neither does it provide a “do nothing” option
• Even if you had unequivocally demonstrated the need for it, provision of housing is NOT an Exceptional Circumstance to justify the destruction of our Green Belt and heritage. Consequently, speculation about future housing needs can’t even come close to being a valid justification!
• I understand that the Council’s own figures show that only 50% of the housing planned would be needed by Elmbridge residents
• Once the Green Belt has been taken away it will NEVER be regained. This will result in encroachment of countryside and removal of green spaces
• The Council has not sufficiently explained or justified why it cannot build on brownfield land and a thorough assessment of brownfield sites should be the first priority. In fact, we should not even be considering green belt until we have fully exhausted brownfield sites
• Increased urbanisation of the more major urban areas in the borough. The Council should seek to develop social/affordable housing near to the major sources of employment and nearer to better service provision
• Opportunities should be explored near to established fast transport links with easy transport access. An example would be the fast Woking/Walton/Esher line
• Building social/ affordable housing in Parcel 14 and Parcel 20 is very unrealistic - this is one of the most expensive parts of Elmbridge and placing social/ affordable housing in this area will not meet the needs of those folks who need easy access to job opportunities and good public transport links, neither of which exist in this area
• The Council has not demonstrated that it has sufficiently explored options with neighbouring boroughs

5

Do you consider the suggested exceptional circumstances are sufficient to support the amendment of the Green Belt boundary?

 

  • Yes
  • No
  • Don’t know

Please explain your answer
• No – National Guidelines state that “unmet housing need is not a justification” – and even if it was, you haven’t sufficiently justified this need (if unmet housing need is not a justification then – poorly evidenced speculation about unmet housing need doesn’t come close to being a valid justification!)
• No – the Consultation Documents state that Green Belt boundaries should only be adjusted “with the support of local people”. The Council does not have this support
• No – the Alternative Options paper does not demonstrate that the Council has given due consideration to other options e.g. Urban intensification and regeneration, working with other councils, etc.
• No - We believe that the Council is taking the easy way out in targeting Green Belt and should re-focus on brownfield sites. Consideration should be given to increasing the densities on these sites where existing infrastructure can support increased populations. Green Belt was designated as such to prevent urban sprawl and as a principle, urban regeneration and development on brownfield sites must be fully exhausted before considering developing on green belt.

6

Agree that, given the appropriate exceptional circumstances, these three key strategic areas are appropriate for removal from the Green Belt?

 

  • Yes, I agree
  • No, I disagree
  • I don’t know

Please explain your answer
• The methodology and assessment is subjective and flawed. There is inconsistency with the scoring and categorisation across all the parcels of land
• Providing infrastructure for the three identified sites is considerably more complex and expensive than linking one larger site in a logistically better positioned area. In addition, as I’ve already said we should, as a principle, exhaust brownfield sites, especially those with strong existing infrastructure, before we even consider any greenfield sites.
• I strongly disagree with Parcel 14 (Knowle Hill Park, north Blundel Lane) being included for the following reasons:
o This Green Belt currently prevents the merger of “neighbouring” areas of Stoke d’Abernon and Oxshott
o Cobham, Stoke d’Abernon and Oxshott are distinct communities – EBC’s own Flood Risk Assessment recognises them as separate entities
o The Green Belt Review scoring is wrong – parcel 14 is only 2.5% built on and therefore should be 4 or 5 not 2.
o Description of Parcel 14 as “semi-urban” is very subjective and patently untrue – it is semi-rural.
o Description of Parcel 14 as having “weak links” to the strongly performing parcel 10 is untrue and solely due to Blundel Lane and the railway line
o Previous owners of the Knowle Hill Park area had higher protection than Green Belt (via a section 52 agreement). This was removed by the Council – there is no justification for why this has changed
o Infrastructure, particularly roads would not cope
o We believe this should be subject to review and independent audit verification as insufficient weighting has been given to the points detailed below:
i. Ancient woodlands are present on Parcel 14. These need to be surrounded with buffer zones and wildlife corridors
ii. Common Land is also present on Parcel 14. I’ve received legal advice that this cannot be made available for development without an Act of Parliament
iii. The verified presence of Greater Crested Newts which are protected by both U.K. and EU legislation. Elmbridge Council itself recently wrote to local residents about the risk to their habitat following the discovery of green waste on the common land next to Littleheath Lane. I would contend that bulldozers, concrete and tarmac will present a far greater risk to them!
iv. This area is also a natural habitat for bats, beetles, adders, buzzards, deer and owls.
v. Knowles Hill Park as its name suggests is on a hill and the presence of a flood plain at the bottom of the hill has not been recognised or scored
vi. We also maintain these are actually Absolute Constraints and need to be recognised and scored as such

• Strongly disagree with Parcel 20 (next to Portsmouth Road, Cobham) being included for the following reasons:
o Parcel 20 acts as a vital separation between Cobham and Esher
o It protects against ribbon development along the Portsmouth Road (A307)
o The Common Land and Site of Special Scientific Interest in this area must be protected
o Development on such a large scale would change the character of Cobham and damage local community cohesion
o The infrastructure couldn’t cope
o The Green Belt Review undervalues this land which has only 4.6% built structures on it.

7

Do you know of any sites within any of the three key strategic areas that could be considered for future development?

 

  • Yes
  • No

Please explain your answer
• I believe that this is the responsibility of the Council and would request that details of further options be provided. If the Council has not fully evaluated all the other options in these three areas it clearly must do so.
• I believe that the Council’s approach to only detail the largest three land masses is simplistic and erroneous. The actual amount of developable land is a more relevant and critical component.
• Parcel 14 (Knowle Hill Park and north of Blundel Lane, Stoke d’Abernon) is not suitable for development for the the following reasons:
o Parcel 14 topography next to Blundel Lane is steep, flood risk and was also a landfill site – so unsuitable for development
o Parcel 14 also has a Scout Camp which is widely used not just by Elmbridge but also by neighbouring boroughs including Kingston. Historic memorial present
o Parcel 14 also has a number of Ancient Woodlands
o Parcel 14 also has areas of Common Land
o Parcel 14 is habitat for protected animal species
o Parcel 14 has a lake at the top of it and springs around the lower levels and floods
o Parcel 14 has clay work mine shafts and underground bunkers used during the Second World War

• Parcel 20 (next to Portsmouth Road, Cobham) has no areas suitable for development. Furthermore:
o There are allotments on Parcel 20 which constrain development
o The Rugby Club has a very long lease on part of the land

8

Do you consider that other areas of land should be removed from the Green Belt including those that are moderately or strongly performing?

 

  • Yes
  • No
  • Don’t know

Please explain your answer
• As I have already said, I do not consider that any land should be removed from the Green Belt. Doing so can and should only be considering in Exceptional Circumstances which have not been demonstrated. Neither has the need for the development been sufficiently demonstrated or evidenced
• I believe that urban regeneration is the way forward and that more joined up thinking and cooperation across boundaries is required, in order to find an optimum solution
• The Council has admitted it has not assessed the viability or contribution of the moderately performing sites and this seems an oversight that must be urgently corrected
• Any plan of this complexity cannot be considered in isolation and hence we fundamentally disagree with an approach that just singles out housing – without adequate consideration for infrastructure and services which always take significantly longer to develop and are already under exceptionally high levels of strain in the local area
• It is worth reiterating that housing is NOT an exceptional circumstance to remove Green Belt and does not meet with the majority support of the residents
• I must also strongly object that the nature of the questions and the absence of proper consideration of other options, is in my opinion designed to justify the Council’s recommendations and is thus not consultative

9

Do you agree that we should seek to provide more of a balance in terms of the size of new homes being built?  

 

  • Yes, I agree
  • No, I disagree
  • Don’t know

Please explain your answer
Whilst I can see that there will be demand across the borough for different types and sizes of housing, I don’t think that the council should be intervening to force higher housing densities into areas that lack the employment opportunities, services or infrastructure to support them. In fact, the Council should be acting to ensure that these things are in place before major new housing developments are even considered. What is built should be based on actual market demand and the ability of local employment, infrastructure and services to support that demand. It should not be based on subjective forecasts or as a matter of central or local government policy.
Where there is demand for smaller sized houses it is surely better fulfilled in urban centres of employment, with better transport links and with the infrastructure that can support it higher housing densities. More joined up thinking and cooperation across boundaries is required in order to find an optimum solution.
Urban renewal and regeneration must be the priority and I believe the Council should be seeking to further identify and invest in brownfield sites. Increased density in such areas will allow for the provision of smaller, more affordable homes.

10

Given the over delivery of homes with 4 or more bedrooms should we try to limit their delivery in future?

  • Yes
  • No
  • Don’t know

Please explain your answer
If there had been over delivery of 4+ bedroom homes we would be seeing lots of them standing empty. That is not the case. As above, what is built should be based on actual market demand and the ability of local employment, infrastructure and services to support that demand. It should not be based on subjective forecasts or as a matter of central or local government policy. We shouldn’t be seeking to force change in housing stock profile for the sake of it in areas which lack the infrastructure, services and employment to support higher population densities.

11

Should we seek to increase minimum densities at sustainable locations in the urban areas, such as in town centres and at train stations, above 40 dwellings per hectare, where this would not impact on local character?

  • Yes (If yes, what density do you think would be appropriate?)
  • No
  • Don’t know

Please explain your answer
• Yes – because infrastructure, services and employment opportunities already exist and could be far more easily extended in such urban locations to support higher population densities

• Yes – because we have to exhaust such possibilities before we seek to destroy any more of our open spaces – especially in green belt which was specifically designated to stop urban sprawl
• In terms of what density is appropriate, density depends on many factors so a definitive answer is subjective. Creative design should be used to maximise the opportunity with these developments

12a

Within the three key strategic areas we will be exploring opportunities for accommodating our development needs taking into account site constraints, land ownership, compliance with other planning policies and the need to support sustainable development.  If potential housing sites are identified within these areas, do you consider it appropriate to

a. deliver at higher densities i.e. above 40 dwellings per hectare, in order to maximise delivery?

 

  • Yes
  • No
  • Don't Know

Please explain your answer
I do not believe Parcels 14 or 20 should be developed at all. The analysis is subjective and flawed. We have to exhaust urban regeneration and brownfield site options before we seek to destroy any more of our open spaces – especially in green belt which was specifically designated to stop urban sprawl

Parcel 14 (Knowle Hill Park and next to Blundel Lane, Stoke d’Abernon):
• With regard to Parcel 14 – the semi-rural nature, the topography of the land and the existing housing in the surrounding area
• Economics of building social/affordable housing in an area that is one of the most expensive in Elmbridge is unrealistic
• Infrastructure, services and local employment opportunities are totally insufficient
• Moving from the current 8 hpd to the proposed 40 or 60 is quite totally out of keeping with the current environment

Parcel 20 (next to Portsmouth Road, Cobham):
• Infrastructure, services and local employment opportunities are totally insufficient
• Will adversely affect air quality in a heavily polluted area

12b

Within the three key strategic areas we will be exploring opportunities for accommodating our development needs taking into account site constraints, land ownership, compliance with other planning policies and the need to support sustainable development.  If potential housing sites are identified within these areas, do you consider it appropriate to:

b. Support lower density developments that maintain the open character of an area and reflects the surrounding character

 

 

  • Yes
  • No
  • Don't Know

Please explain your answer
I do not believe Parcels 14 or 20 should be developed at all. The analysis is subjective and flawed. We have to exhaust urban regeneration and brownfield options before we seek to destroy any more of our open spaces – especially in green belt which was specifically designated to stop urban sprawl

13

Agree with our approach to continue to apply Policy CS21 of the Core Strategy e.g. consider on a case by case basis whether local circumstances are sufficient to warrant the requirement of affordable housing contributions on all sites where there is a net increase in housing and where it is viable?

 

  • Yes, I agree
  • No, I disagree
  • I don't know

Please explain your answer
I’m not that familiar with CS21, so I can’t see with certainty that I agree with it in full. However, what I can say is that a blanket approach to the challenge around development of affordable housing regardless of the quality of life and/or environmental impact is not the right way to go. Each area is different and there needs to be some accurate science behind the proposed development of each site in the Borough

14

Are there any other aspects of Government policy which you think we should consider with regard to meeting the accommodation needs of non-travelling Travellers?

 

  • Yes
  • No
  • Don't Know

Please explain your answer
«No response»

15

Do you consider there to be any other specific housing needs that are an issue within Elmbridge and that we should seek to address as part of the new Local Plan?

 

  • Yes
  • No
  • Don't Know

Please explain your answer
«No response»

16

Do you agree that the Council should seek to protect our most important and strategic employment areas from redevelopment to uses other than offices, warehousing and factories?

 

  • Yes, I agree
  • No, I disagree
  • I don't know

Please explain your answer
• Mixed residential/retail/small business developments are very viable and effective
• Mixed residential/retail/small business developments are the norm in many other countries in Europe and have proven successful.
• Mixed residential/retail/small business developments are likely to draw the required talent/labour resources to the strategic employment areas in the Borough and do so in a more affordable manner.

17

If not, what degree of flexibility do you consider would be appropriate with regard to alternative uses in such areas?

«No response»

18

Do you think that there are any exceptional circumstances that would support the amendment of the Green Belt boundary at Brooklands to support the further development of employment uses at this site?

 

  • Yes
  • No
  • Don't Know

Please explain your answer
«No response»

19

Other than Green Belt what other barriers do you consider could prevent further development at Brooklands?

«No response»

20

We will seek to maintain our broad support for tourism related development as set out in the Core Strategy. However, to recognise the importance of Sandown Park Racecourse as both a sporting and exhibition venue should we:

Encourage the redevelopment of Sandown Racecourse to provide improved and extended conference and hotel facilities?

  • Yes
  • No
  • Don't Know

Please explain your answer
«No response»

21a

Maintain our policy of focussing new retail development to town and village centres?

  • Yes
  • No
  • Don't Know

Please explain your answer
«No response»

21b

Continue to protect primary shopping areas from other uses as set out in the current Core Strategy?

  • Yes
  • No
  • Don't Know

Please explain your answer
«No response»

21c

Consider allowing other important uses in primary high street shopping frontages such as doctor’s surgeries, dentists and libraries?

  • Yes
  • No
  • Don't Know

Please explain your answer
«No response»

22

Should the Council continue to give a high level of protection to all open spaces and designate those spaces that meet the criteria for Local Green Spaces?

 

  • Yes
  • No
  • Don't Know

Please explain your answer
«No response»

23

Do you agree with our approach to biodiversity and mitigating the impact of new development on the Thames Basin Heaths habitat?

 

  • Yes
  • No
  • Don't Know

Please explain your answer
«No response»

24

Do you agree that our strategic and pro-active approach to supporting our heritage assets is appropriate?

  • Yes, I agree
  • No, I disagree
  • I don't know

Please explain your answer
«No response»

25

If not, what approach do you think we should take?

«No response»

26

Do you agree that the Council’s current approach to considering design and character is appropriate?

  • Yes
  • No
  • Don't Know

Please explain your answer
«No response»

27

If not what approach do you think we should take?

«No response»

28

Should we look at including a policy providing more detailed advice on what is required to limit the cumulative impact of small scale development on flood risk?

  • Yes
  • No
  • Don't Know

Please explain your answer
«No response»

29

Do you consider the existing policies seeking to reduce the impacts of new development with regard to delivering more sustainable travel patterns outlined above are still appropriate?

  • Yes
  • No
  • Don't Know

Please explain your answer
«No response»

30

Are there other approaches we should consider?

  • Yes
  • No
  • Don't Know

Please explain your answer
«No response»

31

What do you consider to be the essential infrastructure items required to support new communities e.g. the potential development of the 3 key strategic areas?

New communities require sufficient access to: healthcare, schools, employment opportunities, rail, road, parking, sporting and leisure facilities, retail facilities. All of these are already stretched to the maximum in Oxshott and the surrounding area.

Surely it is far more economical and less damaging to the environment to extend the infrastructure we already have in urban centres – than to build it almost from scratch in small town/village settings or on green belt.

• Opportunities should be explored near to established fast transport links with easy transport access. An example would be the fast Woking/Walton/Esher line
• Providing infrastructure for the three identified sites is considerably more complex and expensive than linking one larger site in a logistically better positioned area in an existing urban centre
• Current infrastructure and services are already not fit for purpose.
• I completely disagree with the premise that the proposed areas should be developed. There is not clear and compelling evidence of the need and there are no Exceptional Circumstances to justify development of green belt land. Even if there were such exceptional circumstances, the following essential infrastructure would need to be in place before any development could even be considered feasible or sustainable:
o Alternative road patterns be developed to ease existing and future traffic congestion, including improvement of rail road bridges, roundabouts and traffic lights.
o Adequate number of schools, surgeries and green areas to ensure quality of life for residents.
o Parking at or near transportation links, including Stoke d’Abernon and Cobham Stations.
o Improvements of bus services in area offering alternative to travel by car.

32

What smaller infrastructure improvements do you think could be made within your local area to address some of the negative impacts arising from new development?

«No response»

33

We recognise that there may be other issues or options we have not considered that you would like to raise. If there are we would like to hear these and consider them as part for this consultation. Please use this space to write anything else you would like us to consider.

 

• The methodology of the Strategic Consultation paper is subjective and flawed. The basis for scoring the parcels (e.g. the GBBR score for parcel 14 of 2 out of 5) does not stand up to scrutiny, as I have mentioned in my answers above
• Entire premise of the consultation rests on the requirement to build 9480 new homes. It is not clear what this number is based on - or what is the probability of it being correct. It is also not clear when it was conceived or if it has taken account of recent global and national developments (e.g. Brexit). If, as I mentioned earlier, ‘housing need’ is not an Exceptional Circumstance to justify development of the green belt – then poorly evidenced speculation on housing need surely doesn’t even come close to providing a justification!
• The paper has only explored 3 parcels of so called “weakly performing” land – and as mentioned above their classification as ‘weakly performing’ is subjective and doesn’t stand up to scrutiny. Other parcels of so called “weakly, moderately or strongly” performing may be more suitable for development e.g. nearer to higher populated urban areas.
• Green belt should not be considered for development until all opportunities for urban regeneration and brownfield development have been exhausted. The Green Belt is there for a reason. We must preserve it to prevent urban sprawl or very soon we will have no green spaces or natural habitat left in the South East.
• No consideration given with the proposals for the Cobham & Stoke d’Abernon proposals of access to jobs and employment. Limited employment opportunities in the immediate area as opposed to exploring options in Walton or Weybridge
• Economics of building lower cost housing on areas of Elmbridge (parcels 14 and 20) that are focused on high value homes. Risk if Green Belt is removed that Millgate Homes (current owners of 45 acres of parcel 14) will look to build more high-end (4+ bedroom) homes and pay the Council off as they have done on the existing building. What makes the Council think this would change in the future?
• Elmbridge strategy does not support the stated EU requirement which seeks to preserve and enhance the quality of life of its residents, both current and future. In our opinion Elmbridge proposals directly contradict these EU directives
• Timing of this consultation being launched just prior to Christmas, the lack of information provided to local residents and the length and complexity of the questionnaire seem to lead to the conclusion that the Council is simply going through a process and not seriously open to any challenge from local residents

34. Files

«No files»