Online Response Form


List of answers to the specified question
Deleted User No 21 Mar 2017 13:15
Anthony Williamson These areas could contain development within limited boundaries 21 Mar 2017 12:55
Anthony Williamson Don’t know 21 Mar 2017 12:55
Deleted User  No – National Guidelines state that “unmet housing need is not a 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
 No – the Alternative Options paper does not demonstrate that the Council has given due consideration to other options e.g. Urban intensification, working with other councils.
 The Government White Paper emphasises that Councils need to have fully demonstrated all other options before exploring Green Belt land. Elmbridge Borough Council have not demonstrated this
 No - The Strategic Options paper has only explored 3 parcels of so called weakly performing Green Belt. The work should have been completed at a much lower level. Who is to say that the next levels of your identified weakly performing Green Belt Parcels are not more suitable and have more developable areas?
 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
21 Mar 2017 12:22
Deleted User No 21 Mar 2017 12:22
Duncan Crane My disagreement here is with both the statement of need (as explained in response to question1), the way the exceptional circumstance are defined and the subjectivity of the assessment of the different options.

The correct approach would be to consider if there are exceptional opportunities for creating successful, sustainable communities which would merit the re-designation of greenbelt or other land subject to constraints. The questions of support for amendment of the greenbelt boundary could only be considered in the context of suitable and more detailed proposals, not as a general principle as set out here.
21 Mar 2017 12:00
Duncan Crane No 21 Mar 2017 12:00
Save Cobham Green Belt (Keith… NO Government guidance in the NPPF, as Elmbridge Borough Council admits, is very clear that there must be exceptional circumstances proven in order for any existing Green Belt boundaries to be changed. The NPPF states at para 83 that “Once established Green Belt boundaries should only be altered in exceptional circumstances” and at para 79 “the essential characteristics of Green Belts are their openness and their permanence.” Savecobhamgreenbelt does not consider that the exceptional circumstances put forward by the Council are sufficient to be accepted as exceptional. Thus, it follows that there cannot be any amendments to the long established Green Belt in Elmbridge. If there ever was to be, it needs to be conducted on a ‘Sustainability’ platform and NOT on so called Weakly performing. The Community should be able to work with the Council to identify any appropriate areas with the agreement of the local community in a Local Plan. We take each of the exceptional circumstances: (1) Housing Need, (2) Housing prices and Affordability issues (3) Affordable Housing need (4) Starter homes and (5) Imbalance in Housing Mix, put forward by the Council in turn: (1) Housing Need: We appreciate that the housing need figure which has been produced by the SHMA is very large. However, it is clear that although Government would wish for this figure to be met there are clear references in Government planning guidance which state that the figure is only a starting point, local authorities do not have to meet in full housing needs and there are environmental constraints, that if existing can result in a reduction in that figure. One of the major constraint is Green Belt. What is of considerable importance to this issue of the Council attempting to prove exceptional circumstances is that the Government has been clear in Ministers Statements and in the PPG that: “Unmet housing need is unlikely to outweigh the harm to the Green Belt and other harm to constitute the very special circumstances justifying appropriate development on a site within the Green Belt” With this clear guidance on unmet housing need and Green Belt we fail to understand how the Council is attempting to use the topic of housing need as an exceptional circumstance. (2) Housing Prices and affordability issues: We accept that Elmbridge has the highest house prices in Surrey and the affordability levels are also the highest in Surrey. This is partly a consequence of the proximity to London, good communications to central London and the attractiveness of the Elmbridge’s towns and open spaces, including the continual strength of the Green Belt. These factors are unlikely to change. In- migration pressures especially from London will continue with the result that house prices will continue to rise and so will, we presume, unaffordability levels. We fail to see how building some 1700 to 2400 new homes over 20 years in the Green Belt (an average of approximately 100 per year on average, or even less if 1720 are built) will have any effect at all on reducing either the average house price in the Borough OR the unaffordability levels. 2000 additional houses over 20 years is such a small percentage of the existing stock which is at present over 60,000 (only some 3% of the total stock). Thus, in conclusion we fail to see the relevance of the Council’s exceptional circumstance regarding this issue. (3) Affordable housing needs: The Council has attempted to show that the need for affordable housing is considerable and we accept it is. However, we would say that affordable needs IS PART of general housing need, which the Government in their planning guidance has stated does not outweigh the harm to Green Belt and consequently is not a very special circumstance or exceptional circumstance. Affordable housing comes in many types and we do not accept that providing so called affordable housing, that is only some 20% or so below local average prices would do much to alleviate the real housing needs that exist in the Borough. 20% below the Cobham average would not be affordable in anyone’s eyes. Those in real housing need would be unable to afford these prices, even with a 20% reduction. The only type of affordable housing that would actually alleviate true housing need (as indicated by the Council’s housing register) is social housing and social rented housing. We do not accept that large amounts of this type of affordable housing would be built in the three key Green Belt parcels. Because (1) The Government does not appear at present to see this type of affordable housing as their priority. This is clearly shown by their attitude to providing affordable housing on smaller sites. They have issued new guidance which prevents Councils asking for affordable housing on sites with 10 or less dwellings. Even when challenged in the Courts they stuck to their proposals and appealed successfully to a higher Court. If their overriding priority was to provide more social housing why would they go to such lengths? (2) -to provide true social housing requires a large subsidy and the only source of that money is from central Government. Government has and continues to reduce grants for housing. Councils are unable to build Council housing as they rely on Government financial assistance which is not forthcoming. We fail to see that just because Elmbridge is proposing to build more houses and a large number in the Green Belt that will result in greater contributions from Central Government to finance them. Thus, only limited social housing is likely to be forthcoming. Doubtless some affordable housing and even social rented housing delivered by local Housing Associations will continue to come forward (as in the past Elmbridge has seen some 369 units built between 2011-2016. However, we do not accept, given the likely lack of Government financial assistance and any great increase in assistance (probably it will continue to decrease) that more affordable housing will come forward in the years ahead on Green Belt land. (4) Starter Homes: Again, starter homes are just another part of general housing needs which guidance states should not be a reason to overturn Green Belt policy. Starter homes are certainly a component of affordable housing, but even if the Government gets anywhere near their target of 200,000 over 5 years, the numbers actually built in Elmbridge are likely to be relatively small. Thus, we fail to see the issue of starter homes can be an exceptional circumstance. Land prices around Cobham/Oxshott in particular are so high that this would preclude most Social housing. Several Developers have fed back that there would not be any social housing in their plans, even if they were to start off negotiations saying there would be. Once the Green Belt is lifted then Developers could do as they have done for the last twenty years ie Build expensive luxury homes and that is precisely what then intend doing! (5) Imbalance in Housing Mix: It is clear that Elmbridge has always built a very high proportion of 4/5 bedroom houses or 2 bedroom flats-resulting in a growing imbalance in stock with less small cheaper dwellings. Elmbridge have created the problem which it and residents are now facing into. Policy CS19 has clearly been shown to be completely ineffective. Is it actually very unlikely that even if 2000 dwellings were proposed in Green Belt areas over 20 years a great proportion of them would be smaller dwellings or non luxury 2 bedroom flats. Of course, some smaller houses would be built, BUT we do not see great numbers which would help to alter the present imbalance. To suggest that large numbers of smaller houses, enough to alter the present imbalance would be built in areas between the low density areas of Stoke D’Abernon and Oxshott and in other areas close to Long Ditton or even north of Cobham is simply unrealistic. Elmbridge has attempted through housing policies in two local Plans to prioritise smaller houses or non luxury flats -there has however been little or no success. It is unlikely the Council could be any more successful this time. Therefore, we do not see this issue as an exceptional circumstance. In conclusion, we do not find any of the Council’s exceptional circumstances arguments to be convincing and we strongly argue that the above shows that the Government not too. 21 Mar 2017 11:46
Save Cobham Green Belt (Keith… No 21 Mar 2017 11:46
Deleted User • No – National Guidelines state that “unmet housing need is not a 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 eg Urban intensification, working with other councils etc.
• No - The Strategic Paper has only explored 3 parcels of so called Weakly Performing Green Belt. The work should have been completed at a much lower level.
• No - I believe that the Council is taking the easy option in targeting Green Belt and should re-focus on brownfield sites, and increasing density within larger more established towns, e.g. Walton.
21 Mar 2017 11:46
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