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NameOptionTextDate
Deleted User o The methodology and assessment is subjective and completely flawed. Inconsistency with the scoring and categorisation across all the parcels of land.
o I strongly disagree with Parcel 14 (Knowle Hill Park, north Blundel Lane) being included for the following reasons:
o This parcel of Green Belt currently prevents the merger of “neighbouring” areas of Stoke D’Abernon and Oxshott.
o Cobham, Stoke D’Abernon and Oxshott are distinct ‘village’ communities – the council’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 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 The radical upgrade of infrastructure required, inc. roads, increased flooding to an already flood-prone area.
o I 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. There is verified presence of Greater Crested Newts which are protected by both U.K. and EU legislation.
iii. It is also a natural habitat for bats, beetles, adders, buzzards, deer and owls.
iv. The topography of Parcel 14 is very hilly next to Blundel Lane and the presence of a flood plain at the bottom of the hill has not been recognised or scored.
v. I believe that these are actually Absolute Constraints and need to be recognised and scored as such.
vi. Parcel 14 Polyapes is used by 1,000’s of youth groups throughout the year, inc. Scouts, DofE etc.
vii. The existing railway bridge at Blundel Lane and the nature of the road (i.e. ‘lane’) would not cope with further housing/traffic.
viii. There are no local jobs within walking distance of Parcel 14, so all new residents must travel on the local, already-congested roads or access a small railway station with a slow service to access employment.
ix. The positioning of Parcel 14 means that all new residents must, again, travel via car, or on the limited bus service (will bus service be improved?) to reach any amenities, e.g. shops, schools, GP surgeries etc, adding to the existing congestion.
x. If Parcel 14 and Parcel 20 are developed, then Fairmile Lane will be gridlocked, whilst people try to travel to find school places, access shops, jobs etc.
xi. Will existing GP surgeries increase/improve? Already we have to wait 2 weeks+ to get an appointment.
xii. On the Arup document, it details that only 6 hectares of Parcel 14 are developable.
xiii. There are numerous waterways in and around the area of Blundel Lane – will all of these be re-positioned?

• I 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 and would need to be drastically improved.
o The Green Belt Review undervalues this land which has only 4.6% built structures on it.
21 Mar 2017 11:46
Deleted User No, I disagree 21 Mar 2017 11:46
Save Cobham Green Belt (Keith… o Methodology and assessment is subjective and flawed. Inconsistency with the scoring and categorisation across all the parcels of land
o 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. It is also Rural not Urban
o Description of Parcel 14 as “semi-urban” is very subjective and patently untrue – it is semi-rural or 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 It is surrounded by a railway line that has an automatic barrier which closes every few minutes.
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. The verified presence of Greater Crested Newts which are protected by both U.K. and EU legislation.
iii. It is also a natural habitat for bats, beetles, adders, buzzards, deer and owls.
iv. 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
v. We also maintain these are actually Absolute Constraints and need to be recognised and scored as such
o Millgate have put their 45 acres in perpetuity. The developable area is not available. The Scouts and others have said their land is not available.
o Protective Covenants prevent the areas of Blundel lane being accessed.
o There is a stream and major sewage works alongside Blundel lane.
o There are mine shafts from the old brick works.
o Basically 90%+ of the developable land is out of reach for these housing purposes
• 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.
21 Mar 2017 11:14
Save Cobham Green Belt (Keith… No, I disagree 21 Mar 2017 11:14
Birds Hill Oxshott Estate Co.… It would be inappropriate for a number of good reasons for two of the three ‘key strategic areas’ to be removed from the Green Belt. Of the third, land south of the A3 including Chippings Farm and The Fairmile, Cobham, assessment reveals that significantly less than half of it could be considered suitable for removal from the Green Belt as much of this area is a Site of Special Scientific Interest and as such carries a high degree of protection from development.

Assessment of the three Key Strategic Areas:

1) Land north of Blundel Lane, Cobham

Advantages
- Existing settlement on three sides and railway on the other. When looking at a map only, without the benefit of close physical inspection, it look ideally placed for urban expansion.
- Close to railway station and village amenities in Stoke D’Abernon.

Disadvantages
- Contains ancient woodland, which would be compromised.
- Contains a designated Village Green, which would be compromised.
- Contains a Scout Camp, which provides important leisure resource for children, teenagers and young adults.
- Contains a War Memorial whose long-term open setting would be
compromised.
- Knowle Hill House retains parkland setting which would be compromised.
- Within a lower density part of Cobham.

Assessment of De-designation from the Green Belt and Development against the 5 purposes of Green Belt as set out in Paragraph 80 of the NPPF (see Table in attachment).

Summary
This site is wholly unsuitable for removal from the Metropolitan Green Belt, and is considered to perform the functions of Green Belt well.

The level of developable land within the total site is considered to be minimal. This means that the local planning authority has greatly exaggerated the potential for housing delivery. The north east corner of the site is dominated by a designated Village Green that contributes greatly to the established character along Littleheath
Lane. South of this, the existing pond and woodland provide a welcome oasis and an important wildlife resource, as acknowledged by Elmbridge Borough Council in the form of various information boards along the banks of the pond.

Knowle Hill House is situated in the northwest corner of the site. This is currently being converted into apartments alongside 5 large detached houses on the former car parking area. These are advertised as set within 45 acres of secluded private woods
and parkland.

The southwest corner of the site is home to the Scout War Memorial. Development would threaten local character and the Scout camp.

Paragraph 2.23 of ‘Nature Nearby’ – Accessible Natural Greenspace Guidance (2010) published by Natural England states that Natural England promotes ‘Nature Nearby’, which is the provision of good quality natural green spaces close to where people live, so that they can experience and enjoy different ecosystems.

It is considered that should this land be de-designated as Green Belt there would be not enough developable land within it to make any impact in addressing the housing needs of the Borough, whilst its loss would be widely felt, and for good town planning reasons.

2) Land south of the A3 including Chippings Farm and The Fairmile, Cobham

Advantages
- Bounded by existing settlement and the A3, when looking on a map represents logical area for expansion.
- Within a higher density part of Cobham and relatively close to local amenities.

Disadvantages
- Around half of the total site area is designated as a Site of Special Scientific Interest (SSSI) and Village Green. These important designations significantly reduce the potential of the site to accommodate new homes.

Assessment of De-designation from the Green Belt and Development against the 5 purposes of Greenbelt as set out in Paragraph 80 of the NPPF (see Table in attachment).

Summary
Of the three sites, we consider that this is the only one appropriate for removal from the Green Belt. It can be divided into three main character areas and, as such removal should only apply to the central open portion which is not covered by any special designation and whose open setting is already compromised by the existing
farm buildings and the Fairmile Hotel.

The eastern part of this key strategic area sits within the Esher Commons which were designated in 1995 as a Site of Special Scientific Interest. Sites of Special Scientific Interest are the country's very best wildlife and geological sites. Such land is protected by law to conserve their wildlife or geology. SSSIs support rare plants and animals that now find it difficult to survive in the wider countryside and consent is needed from Natural England about any planned activity on an SSSI.

3) Land north of the A309 and east and west of Woodstock Lane North, Long Ditton

Advantages
- Established settlement on three sides, with main road on the other. When looking at a map only, without the benefit of close physical inspection, it look ideally placed for urban expansion.
- Easy access to A3 providing quick links into London.

Disadvantages
- Green Belt in this location helps retain some form of separation between the established settlements of Long Ditton and Hinchley Wood.
- Site is home to Surbiton Hockey Club and Long Ditton Cricket Club, which provide important, successful and very well-used leisure resources. If these are retained the level of land available for development is reduced significantly.
- Site is home to Long Ditton Cemetery and which would limit further the level of land available for development, whilst development around it could compromise its existing setting.
- Site is home to Kisimul Special School which provides important educational resource for students with learning difficulties. If this were to be retained, the level of available land for housing development would be reduced further.
- Part of the site is a Local Nature Reserve, popular with local people and home to a mixture of animals and habitats.
- The setting of the historic St Mary’s Church, a Grade II Listed Building, would be compromised.
- The existing parkland setting of the Manor House would be compromised.
- The large number of existing uses suggest that the land is in multiple ownerships. It will be time consuming and difficult to assemble the land needed for the delivery of housing within the timeframe required.
- Certain parcels of land have viewpoints over the countryside to the south and towards urban areas near and far. Local people come here regularly and in large numbers for quiet recreation. This activity and unique views would be compromised by development.

Assessment of De-designation from the Green Belt and Development against the 5 purposes of Greenbelt as set out in Paragraph 80 of the NPPF (see Table in attachment).

Summary
The Land to the West of Woodstock Lane North is an important and popular local leisure and active and passive recreational resource. It is highly valued by local people as outlined within Policy DM17 of the Elmbridge Development Management Plan 2015.

The centre of this strategic site is designated as a Local Nature Reserve called Stokes Field. Local Nature Reserves are described by Natural England as areas for both people and wildlife. They are places with wildlife or geological features that are of special interest locally. They offer people special opportunities to study or learn about
nature or simply to enjoy it.

The Local Nature Reserve at Stokes field was designated in 1999, it is described by Surrey County Council as An urban fringe site with a variety of habitats including woodland, grassland and scrub. It also has a pond. Plant species of note include crab apple, cuckoo flower and pyramidal orchid.

To its south, the land increases in height quite steeply providing open views across the Green Belt, Hinchley Wood and Bushy Park beyond.

It is accepted that parts of the ‘key strategic area’, including the Hockey Club pitches and floodlights are urban in character and that portions of the site including the garden centre and school are already built on. However, the hockey club and garden centre are both uses appropriate to the Green Belt and the structures are also
appropriate to it, as is made clear by paragraph 80 of the National Planning Policy Framework (‘NPPF’).

Despite this, the character of the area is open and the existing uses are all highly successful. The removal of the land upon which these facilities stand from Green Belt designation would not solve the short term pressures for providing land for new housing within the Local Plan timeframe, as it would rely on the individual landowners closing
the existing successful uses and re-locating them, prior to developers submitting individual planning applications for their separate parcels of land. Re-location locally must be very doubtful considering the enormous increases in land values that have taken place since the various facilities were first established.

Paragraph 74 of the NPPF is clear that Existing open space, sports and recreational buildings and land, including playing fields, should not be built on unless:
● an assessment has been undertaken which has clearly shown the open space, buildings or land to be surplus to requirements; or
● the loss resulting from the proposed development would be replaced by equivalent or better provision in terms of quantity and quality in a suitable location; or
● the development is for alternative sports and recreational provision, the needs for which clearly outweigh the loss.

This further illustrates that the removal of this land from Greenbelt designation would not provide land for housing.

The openness of the Green Belt here is an important reason for people wanting to live in or visit the area. If this is taken away the whole character of the area will change and residents’ lives and leisure activities compromised.

Paragraph 123 of the NPPF states that Planning policies and decisions should aim to:

● identify and protect areas of tranquillity which have remained relatively undisturbed by noise and are prized for their recreational and amenity value for this reason.

It is clear that the sites this site should be given greater protection not see its existing protection removed. Part of the land to the east of Woodstock Lane is currently used for Equestrian activities and Policy DM19 of the Elmbridge Local plan notes that such activities are
popular in the borough offering opportunities for outdoor recreation and promoting healthy communities. It is noted that there are currently seven licensed riding establishments within Elmbridge, all of which lie within the Green Belt.

Paragraph 2.23 of ‘Nature Nearby’ – Accessible Natural Greenspace Guidance (2010) published by Natural England states that Natural England promotes ‘Nature Nearby’, which is the provision of good quality natural green spaces close to where people live, so that they can experience and enjoy different ecosystems.

Conclusions

The basic concept of the Green Belt was established back in 1902 by Ebenezer Howard in his seminal publication ‘Garden Cities of Tomorrow’.

Howard notes on page 17 that human society and the beauty of nature are meant to be enjoyed together and supplement each other.

On page 16 of his text, Howard notes that the country provides beautiful vistas, lordly parks, violet scented woods, fresh air, sounds of rippling water; but too often one sees those threatening words “Trespassers will be prosecuted”. The Green Belt at Stokes
Field and Fairmile Park provides these benefits without the threatening sign. In line with Howards vison.

Whilst we agree that Green Belt land is not always worthy of its designation as protected land and in exceptional circumstances if it is failing to meet the criteria set out in paragraph 80 of the NPPF, barely any of the ‘key strategic sites’ so poorly considered by the local planning authority before embarking on this exercise, could be considered appropriate for removal from the Metropolitan Green Belt to enable the provision of new homes.

Paragraph 81 of the NPPF states that local planning authorities should plan positively to enhance the beneficial use of the Green Belt, such as looking for opportunities to provide access; to provide opportunities for outdoor sport and recreation; to retain and enhance
landscapes, visual amenity and biodiversity; or to improve damaged and derelict land.

Whilst paragraph 70 states: To deliver the social, recreational and cultural facilities and services the community needs, planning policies and decisions should:
● guard against the unnecessary loss of valued facilities and services, particularly where this would reduce the community’s ability to meet its day-to-day needs;

Through suggesting, the de-designation of all three of these sites in full, which contain opportunities for outdoor sport and passive and active recreation and biodiversity, illustrates a failure of the Borough Council to plan positively for the beneficial use of the Green Belt. It illustrates a lack of understanding of the role and function of
successful Green Belt land and a failure of the Borough Council to plan positively for healthy communities, as required within section 8 of the NPPF.

Whilst also reducing the ability of the existing community to meet its day to day needs, without compensating for the additional residents.

At a local level Policy DM20 (Open Space and Views) of the Elmbridge Development Management Plan 2015 notes that;
The open space within Elmbridge is essential to its character and contributes to the quality of the landscape and the network of green infrastructure. It is very important to local people, who
enjoy the visual benefits, wildlife habitats and the recreation function it provides.

The sites at Fairmile Park in Cobham and Stokes Field in Long Ditton are particularly important in this regard.

The Elmbridge Open Space and Recreation Assessment (2006) states that the proposed standard for the provision of natural greenspace is 9.4 ha of natural greenspace provision per 1,000 / population, and that the Borough as a whole will meet this target in 2026. It will be difficult to meet such a target through the designation of land which currently provides this function.

The removal of these entire sites from the Green Belt would also increase future hostility towards Green Belt developments on more suitable sites and make it more difficult for the Borough to meet its housing targets.

It is our view that two of the three ‘key strategic areas’ are completely inappropriate candidates for removal from the Green Belt, whilst the other has not been identified properly, with large parts of it wholly unsuited to development. We would recommend that Elmbridge Borough Council conducts a full audit of all its Green Belt land with full
regard to relevant planning factors to identify smaller, targeted pockets of land that could deliver the housing needed within the Local Plan timeframe.
21 Mar 2017 11:06
Birds Hill Oxshott Estate Co.… No, I disagree 21 Mar 2017 11:06
Deleted User After reading the documents Elmbridge Green Belt Boundary Review, I came to the conclusion area 58 was unfairly treated weakly performing for “purpose 3” assessment criteria and should have been treated moderately performing for this purpose.
This would mean area 58 should not have been considered for amendment its green belt status and therefore, should not be considered for development and I intend to give you evidences to support my claim.

See document attached explaining my view.
21 Mar 2017 11:03
Deleted User No, I disagree 21 Mar 2017 11:03
Deleted User I strongly oppose the plans for Area 58 for the following reasons:

• Area 58 is not a weakly performing area as suggested in your report written by Arup – the Green Belt in Area 58 provides a split in our local towns and areas. All the benefits of the Green Belt will be lost if we start to even build on a small proportion of it – our towns will all join up and we will be part of the sprawl of London.
This buffer between our towns brings social, environmental and economic benefits whilst giving locals a chance to tap onto natural capital on their doorstep – it is a cherished asset.
Green Belts stop urban sprawl and it provides countryside for almost 30 million people in the country – take this away little by little and we are taking away the countryside for our children, grandchildren and future generations.
• With the inevitable climate change, Green Belt areas have an increasingly important role in stopping carbon and preventing flooding. Taking away our Green Belt area adds a huge amount of extra pollution to our already polluted area. Increasing many health risks and putting another strain on our already stretched NHS.
• The loss of our valuable and well used amenity for our children and local residents means more obesity and sedentary life styles.
• Loss of a valuable and educational nature reserve means children do not experience the wonderful outdoors and much wildlife, flora and fauna. Our Green Belt is used by many schools and local groups, it houses sports facilities and open spaces – once the whole area has been declassified there is no reason that the complete space will not be built on and we have all lost our open space for ever. We all deserve a right to LOCAL open spaces.
• Locals will have to travel further afield for open spaces – causing more pollution and congestion.
• There will be a loss of local jobs and places of employment – there are many successful businesses and schools within the area.
• There is a lack of space within Area 58 for all the necessary community infrastructure that will be needed for such a huge development – most importantly schools and GP surgeries. This will mean our already stretches schools will be put upon to provide even more school places. Will this mean losing all of their current outside space for extra classrooms – not sitting with the governments guidelines for cutting down on childhood obesity by providing space for PE and outside play. Will children lose the outside space at school as well as the Green Belt?? Or, will local children be expected to travel to other areas within the borough for school – meaning more cars on the road and more pollution – not an environmentally friendly solution or helpful for our already busy local roads.
• There will be an overloading of existing, already stretched infrastructure – extra congestion on our already busy roads will mean traffic taking shortcuts making the local roads dangerous for children, especially near our local schools. Proposed houses are not near any means of public transport, therefore at least two more cars per house added to our local area.
• Better options do exist
• The council has to uphold the governments promised protection of the Green Belt areas and look at other more sensitive and appropriate options.
21 Mar 2017 10:58
Deleted User No, I disagree 21 Mar 2017 10:58
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