Online Response Form


List of answers to the specified question
Deleted User No 21 Mar 2017 11:46
Save Cobham Green Belt (Keith… • 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
• 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/urban sites. Consideration should be given to increasing the densities on these sites.
21 Mar 2017 11:14
Save Cobham Green Belt (Keith… No 21 Mar 2017 11:14
Birds Hill Oxshott Estate Co.… - One of the worst levels of affordability in the country coupled with an under supply of affordable homes;
- Need to deliver a better mix of new housing away from current delivery focussed on houses of four or more bedrooms; and
- The land that is being kept open for the purposes of Green Belt is no longer meeting those purposes

With the exception of the first exceptional circumstances (levels of affordability) the other reasons are considered weak and too generic. Elmbridge has exceptional circumstances by virtue of its location within the commuter belt of one of the world’s fastest growing cities, and by the fact that the entire Borough is located within the
Metropolitan Green Belt, whilst many of its built-up parts retain a special low density and green character that makes development of the scale needed difficult to deliver without adversely affecting its character and appearance. This has particular importance for the relatively few publicly-accessible green and open spaces that people can enjoy for active and passive recreation.

Suggested amendments to the reasons for exceptions should include;
- Ensuring that the Borough has available larger sites for the established need of 5,780 new homes and is capable of accommodating a better mix of new housing without compromising the established character of the Borough’s existing settlements.
- The availability of Green Belt land within the Borough that is no longer meeting its original purposes that can provide this need.
21 Mar 2017 11:06
Birds Hill Oxshott Estate Co.… No 21 Mar 2017 11:06
Deleted User We recommend that two further exceptional circumstances are added (these should be read alongside our answer to question 18).
Firstly, the economic benefits of expanding the economic role (including its retail role) of Brooklands should be added. This is clearly a crucial issue, and opportunities to amend the Green Belt are flagged at paragraph 4.32.
Secondly, the ability for the Council to meet the substantial comparison goods retail needs that exist in the Borough should be added as an exceptional circumstance, since the Council has recognised that there are limited development opportunities within town centres in the Borough to meet these needs.
21 Mar 2017 10:53
Deleted User No 21 Mar 2017 10:53
Deleted User TDWGRA does not believe that the case has been made for allowing development in its Green Belt Areas and, in particular, the land described as area 58, which, it believes, represents an outstanding example of what Green Belt was designated for in terms of two of the five purposes set out in the NPPF – notably as follows:
The government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.
Green Belt serves five purposes:
 to check the unrestricted sprawl of large built-up areas
 to prevent neighbouring towns merging into one another
21 Mar 2017 10:31
Deleted User No 21 Mar 2017 10:31
Carter Jonas on behalf of BGL… Yes. Current Government guidance is clear. Councils can only amend Green Belt boundaries as
part of the preparation of a local plan and only if there are exceptional circumstances, although
there is no definition of this and it is left to each local authority to have regard to the specific
circumstances applicable to its administrative area subject to the Duty to Co-operate. Paragraph
84 of the NPPF advises that “when drawing up or reviewing Green Belt boundaries local planning
authorities should take account of the need to promote sustainable patterns of development”.
However, we note that in the recently published Housing White Paper (February 2017), the
Government has signalled that policy in relation to the Green Belt is to be amended and added to.
It advises that “authorities should only amend Green Belt boundaries only when they can
demonstrate that they have examined fully all other reasonable options for meeting their identified
development requirements, including;
- making effective use of suitable brownfield sites and the opportunities offered by estate
- the potential offered by land which is currently underused, including surplus public sector land
where appropriate;
- optimising the proposed density of development; and
- exploring whether other authorities can help to meet some of the identified development
It adds that “where land is removed from the Green Belt, local policies should require the impact
to be offset by compensatory improvements to the environmental quality or accessibility of
remaining Green Belt land”. It is suggested also that consideration will be given as to “whether
higher contributions can be collected from development as a consequence of land being released
from the Green Belt”.
On the basis the planned changes to the NPPF will overlap with the Council’s ongoing preparation
of the Local Plan, it is essential that the Council has proper regard to the likely ‘direction of travel
of policy’, although it has to be acknowledged that this is not yet policy and there may be further
changes. However, it would seem prudent to respond to the questions relating to Green Belt
reviews set out at paragraphs 1.38 and 1.39.
The Council’s response on this matter will form an important part of the preparation of the Local
Plan and we reserve BGL’s position to comment further once the Council has published details of
its approach.
In terms of the work that has been completed to support the current exercise, we note that as part
of its consideration of sustainable patterns of spatial development in the Borough, and mindful of
competing development pressures, we contend that the Council’s open-minded approach to
consideration of Green Belt land and boundaries is a sensible one. Consideration of land where
the designation is weakest, in sustainable locations and on land not affected by absolute
constraints, is a robust approach.
Moreover, the approach taken to release land for development at appropriate densities,
appropriately respects the character of Elmbridge.
We contend that given the pressures for development and constraints, the Council would have
been criticised for not undertaking such a review. However it will be important for the Council to
respond to the matters set out in the Housing White Paper at paragraphs 1.38/1.39 so that if these
are brought forward in a revised version of the NPPF, the Council will be able to save time in the
production of the Local Plan because it will already have considered and evidenced these.
Based on the identified needs, development constraints and challenges, and the findings of the
Green Belt review, we consider that the Council has demonstrated that exceptional circumstances
exist to support the suggested amendment(s) to the Green Belt boundary.
It is important that the Council provides a response to the points contained in the Housing White
Paper to provide robust justification for the review to form part of the ongoing preparation of the
Council’s spatial development strategy in the Local Plan.
21 Mar 2017 10:25
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