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Response Details

Response Details
From Wrens Hill Residents Associati…
Date Started: 23 Jan 2017 15:55. Last modified: 21 Mar 2017 14:07
Status Complete
Response ID #517607

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
Key challenges are traffic congestion and other infrastructure requirements. The Green Belt is important to maintain the quality of life and for the environment.
The Council's core strategy to date has been to protect the Green Belt and this should not be eroded

To retain the quality of life for all residents in Elmbridge.
To address infrastructure requirements for Schools, Doctors, transport congestion etc.
To maintain strong protections for the Green Belt and avoid urban sprawl.
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
See answer to Qn 1 above

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
See answer to Qn 1 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 following are my principal comments on the New Local Plan:


The Council's preferred solution would give rise to major infrastructure requirements, the provision of which would be largely outside the control of Elmbridge Borough Council. Some of these could possibly be satisfied within the curtilage and plans of the proposed major areas of new housing development (eg health centres, primary schools, local shops). However others (eg roads, hospitals, secondary schools, day centres) would rely on either Surrey County Council or Central Government and there is a real risk that general commitments in these areas are not then completed within the required timescale or are scaled back or cancelled for budgetary reasons.

Consequently, I consider that the the New Local Plan should be conditional on the implementation of key infrastructure requirements before the Council is required to consider any large housing development.

In particular, the traffic problems are already severe in the southern part of Elmbridge with the main N/S routes (A244 and A245) carrying a lot of through traffic, which when combined with local traffic causes long queues, not only at peak times. Neither road could be widened without there being pinch points, so this is not a possible solution. All three areas of Green Belt proposed for development are in the southern part of Elmbridge.

The New Local Plan should specify the road improvements required to resolve this issue taking account of the additional houses proposed. To this end I suggest that Elmbridge should appoint its own traffic consultants and not rely on Surrey CC's standard modelling. Minor local road improvements are not going to solve this problem.

Several years ago there was a proposal to upgrade the A243 to a dual carriageway from the Leatherhead M25 interchange to a new junction with the A3 south of the existing Hook junction. The new dual carriageway was planned to follow the line of the existing road until north of The Star PH, then veer off slightly left through the edge of Princes Covert and round the back of Chessington World of Adventures, with a new spur into that development. This new road would then take a lot of the through traffic which currently uses the A244 and A245. A radical solution such as this is required, but would clearly rely on Central Government funding. Consequently, if it were not in place (ie already constructed) as a pre-condition for implementing the New Local Plan, it would be at risk of being cancelled, leaving us with extra houses and the same roads as at present, but totally gridlocked.

I consider that Elmbridge is being required to take an unduly large share of the housing requirement for the South East, bearing in mind that there is very little land that is neither already developed nor Green Belt. Also, compared with the South East as a whole, Elmbridge has proportionately few brownfield sites suitable for housing development and these brownfield sites should be the priority for housing development.

I also consider that there is far too much secondary retail space in Elmbridge, particularly given the trend to online shopping, and that the Council should actively encourage the re-development or conversion of secondary retail space to residential. This would bring more residents into town centres to the benefit of the remaining retailers and would create residential units with less requirement for cars.

New housing is not an Exceptional Circumstance to allow Green Belt removal.
A proper detailed assessment of brownfield sites should be the first priority.
Increased urbanisation of the more major urban areas in the borough would be better.
EBC has not demonstrated any exploration with neighbouring boroughs.
The Green Belt Review (ARUP) report fails to set out the process clearly and fairly.
The Green Belt Review (ARUP) Purpose 3 assessments incorrectly score Parcel14 and Parcel 20 too low.
Parcel 14 and Parcel 20 would not be identified as 'Weakly Performing' if correctly scored.
Planning constraints (infrastructure, traffic, etc.) make Chippings Farm unsuited for development.
It is unlikely that any more affordable housing would be available for local residents.
Traffic congestion on local roads would be a problem.
Local infrastructure is already under pressure; Option 2 would make it worse.

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
Should focus on brownfield sites.

Council would be contravening national guidelines that unmet housing needs do not justify development of Green Belt land.

Low cost housing should be built in parts of the borough where prices are lower. If they were built in the area with the most expensive housing (as proposed) they would cease to be low cost on resale and therefore not fulfil the objective.

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 roads are already congested and could not cope with increased traffic

Parcel 14 contains ancient woodlands, a great variety of nature in an ideal habitat, including a large lake

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
Why hasn't the Council done the work to identify alternatives? In particular brownfield sites in areas of the borough with a greater concentration of commercial property

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
The Council has not made the case for removing any areas from the Green Belt

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
But it is only logical and effective to build smaller housing units in or adjacent to existing urban areas otherwise they will not be affordable. Because of this the 9450 target for Elmbridge is unrealistic

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
But they should not be limited in areas that are already 4+ bedrooms

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
«No response»

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
The identification of these three areas is totally illogical and not based on any sound reasons

The local road infrastructure won't take high density development on these sites

High density development would be totally out of keeping with the surrounding area

Even high density housing would not be low cost in these areas

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
The identification of these areas is totally illogical and not based on any sound reason

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
But there should not be an overall approach. Each case should have due regard to the nature of the surrounding area

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
Provide as little as possible

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
Secondary retail space in town centres should be readily allowed to be converted to residential. There is too much such space in the borough and this will get worse with the trend to online shopping. More housing in town centres will help the prime retail core and would be particularly suitable for older residents with nearby.shops and less need for cars

17

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

total flexibility

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?

Road infrastructure

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
But road infrastructure must first be improved

21a

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

  • Yes
  • No
  • Don't Know

Please explain your answer
But allow retail space to be converted/redeveloped as residential

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
See answer to Qn 21a above

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
Plus residential

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
Very important, particularly if more houses are to be built

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
And larger scale developments

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
Clearly the road infrastructure would ne cope with a large number of additional houses. It is unlikely that any road improvement plans by Elmbridge BC or Surrey CC would be sufficient to deal with the impact of 9450 extra housing units. A major building programme, such as the above mentioned relief road along the route of the A243, would be needed. This should be constructed before the Council's obligations to provide additional housing come into effect as otherwise there is too much risk that Central Government commitments in this regard will not be met.

30

Are there other approaches we should consider?

  • Yes
  • No
  • Don't Know

Please explain your answer
See answer to Qn 29 above

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?

Development should be concentrated along the main line from Woking to Waterloo so as to minimise road usage and maximise the use of public transport

Schools, medical centres, hospital capacity (Epsom and Guildford, but also expansion of Cobham)

Better bus services

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.

 

I went to the drop-in session in Cobham, which was of limited value. Instead, it would have been more helpful to have had a presentation followed by questions and answers, with Officers and Councillors available to answer questions. That way we would all have had the benefit of knowing matters of concern to residents and hearing the answers. Also many local residents are totally unaware of the New Local Plan whereas, if the consultation process had been delayed until after the Council Tax mailing, details could have been included in that mailing.

I don't think that your tick-box questionnaire with a lot of Yes/No and Agree/Disagree questions is a satisfactory way of soliciting views on this matter. It would have been much better to have sought comments, including on specific questions. I appreciate this would have resulted in far more analysis being needed by your staff, rather than tick-box returns from a market research organisation. The tick-box approach largely indicates the extent of agreement or disagreement with the Council's preferred solution and discourages the putting forward of a different approach and new ideas.

In summary, I feel your approach was designed to minimise disruption to the process on which you are already set, rather than genuinely to get as much feedback as possible from residents.

Additional comments received via email dated 21.02.207, sent to Ray Lee, Strategic Director:
I was at the public meeting yesterday evening at St Andrews Church, Cobham regarding the new Local Plan and was concerned by a number of matters.

In the presentation on behalf of the Council and again in answering a question from the floor, your colleague stated that the determination of the number of residences required in Elmbridge is based on methodology stipulated by the Government. Later in the meeting (only because it was pointed out from the floor) you admitted that the recent White Paper states this existing methodology is not fit for purpose and that the Government will be consulting on options to replace it with a new methodology from April 2018. It seems unsatisfactory and misleading that, knowing full well that the existing methodology is to be scrapped, your colleague nevertheless gave quite the opposite impression, and I gathered that you are already in discussion with Goverment officials regarding the impact of this matter on the preparation of the new Local Plan. The housing requirement thrown up by the current methodology is fundamental to the whole preparation of the Plan and the threat to the Green Belt, and I think it reflects badly on the Council that you were not totally open regarding this matter in your presentation.

Various statistics were produced at the meeting regarding the current percentage of existing development of the two parcels of Green Belt under discussion, claiming that these percentages are well below (less than half) the levels quoted by the Council, which I understood were either in some way related to Ove Arup's calculations of housing requirements or were fundamental to the question of whether these parcels of land could be removed from the Green Belt. Your colleague was asked to explain this difference and admitted that he was unaware of the reasons for this difference and of whether the figures quoted at the meeting were correct.

We were told at the meeting that Ove Arup's calculations of Elmbridge's housing requirement of some 9,500 new residences runs to 100 pages. Clearly it would be impossible for the average Elmbridge resident to carry out any analysis of this and we are therefore totally reliant, as I suspect are our Councillors, on the Council's officers going through Ove Arup's calculations with a fine tooth comb to see in what ways they can be attacked. Has this level of due diligence been carried out?

At the meeting it was pointed out that the Technology Revolution is likely to result in fewer people needing to commute daily to London and that this would have an impact on housing needs in Elmbridge and indeed other commuter areas. The Consultation Paper does not seem to have taken any account of this.

The White Paper seems to require Council's to produce a five year plan, so why is Elmbridge producing a 20 year plan. Is this a case of gold-plating?

Generally, I thought the Council's Presentation at the meeting was lacklustre and negative, almost as though the Council's officers feel they are reluctantly having to hold the ring in a dispute between Central Government and residents. There seemed to be a resigned acceptance of the 9,500 figure forced upon us and little imagination in finding alternatives to using the Green Belt to satisfy housing requirements. For instance, the Technology Revolution is rapidly moving shopping online and away from the high street and there will be a much lower future requirement for town centre retail space. So why not decide to have just the prime central retail core in each town designated for retail space and designate all other retail space as secondary and open to market forces for redevelopment as very high-density residential, ie blocks of flats, which incidentally would give rise to less road traffic than a comparable number of residences in the Green Belt.

34. Files

«No files»