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Response Details

Response Details
From Adam Woodhouse
Date Started: 22 Feb 2017 10:50. Last modified: 22 Feb 2017 10:50
Status Complete
Response ID #523430

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
The consultation and proposal has not been thought through adequately and does not address key challenges including.

• To retain the quality of life for existing residents in Elmbridge
• To address infrastructure requirements, especially education
• To resolve the transport congestion in our area – Cobham/Stoke d’Abernon/Oxshott have severe constraints due to enclosure by A3/M25 and limited rail connections / frequencies
• To maintain strong protections for the Green Belt as set out in the Government’s White Paper
• To avoid further urbanisation and in-fill
• To maintain the environment and avoid further pollution
• 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 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
• To retain the quality of life for existing residents in Elmbridge
• To resolve the transport congestion in our area - Cobham/Stoke d’Abernon/Oxshott
• To retain strong protection for the Green Belt as set out in the Government’s White Paper
• How to regenerate brownfield sites over further development of green fields
• To avoid further urbanisation and in-fill
• To maintain the environment and avoid further pollution

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

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?
I object to the fact that the questionnaire does not provide the opportunity to select either of the other options or provide a “do nothing” option.

Option 1 is the most appropriate option for Elmbridge going forwards and strongly disagree that the provision of housing is an Exceptional Circumstance that will allow the destruction of our Green Belt and heritage.

This is proven by the Council’s own figures that demonstrate only 50% of the housing planned would be needed by Elmbridge residents – a situation that could be addressed by Option 1 without destruction of the Green Belt.

Once the Green Belt has been taken away it will NEVER be regained and the Government’s White Paper reinforces the requirement for councils to provide strong protection of the Green Belt and explore brownfield sights as a priority.

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 nor has it demonstrated that it has sufficiently explored options with neighbouring boroughs

The Council should seek to develop social/affordable housing near to the major sources of employment and nearer to better service provision (supported by the Government’s White Paper) opportunities should be explored near to established fast transport links with easy transport access, e.g. the fast Woking/Walton/Esher line.

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
In no way does this qualify as an exceptional circumstance for many reasons;
1) National Guidelines state that “unmet housing need is not a justification”
2) The Consultation Documents state that Green Belt boundaries should only be adjusted “with the support of local people” – which the Council does not have
3) 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.
4) Elmbridge Borough Council have not demonstrated they have fully exhausted all other options before exploring Green Belt land.
5) The Council is taking the easy way out in targeting Green Belt and should re-focus on brownfield sites.

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
I do not support the removal of any of these areas from the green belt.

The methodology and assessment used by the Council is subjective and flawed with inconsistencies within the scoring and categorisation across all the parcels of land for the following reasons;
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.
o Description of Parcel 14 as “semi-urban” is 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 with increased population and development
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, hedgehogs and owls.
iv. Knowle 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

• 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
o The Green Belt Review undervalues this land which has only 4.6% built structures on it. This would result in a score of 3 or 4.
o The area provides a habitat for a variety of wildlife, rare birds, 6 types of reptiles and insects such as the silver studded blue butterfly Plebejus argus found on the Esher common SSSI site

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
If the Council has not fully evaluated all the other options in these three areas it clearly must do so, the Council’s approach to only detail the largest three land masses is simplistic and lazy.

Parcel 14 (Knowle Hill Park and north of Blundel Lane, Stoke d’Abernon) is unsuitable for development for the following reasons:

• Parcel 14 topography next to Blundel Lane is steep, flood risk and was also a landfill site – so unsuitable for development
• 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
• Parcel 14 also has a number of Ancient Woodlands
• Parcel 14 is covered with protected animal species
• Parcel 14 has a lake at the top of it and springs around the lower levels and floods
• Parcel 14 has clay work mine shafts and underground bunkers used during the Second World War

Parcel 20 (next to Portsmouth Road, Cobham) is unsuitable for development for the following reasons:
• No part of Parcel 20 is suitable for development
• There are allotments on Parcel 20 which constrain development
• 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
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.
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 strongly object and put on the record that the nature of the questions is in our opinion manipulative and self-serving seeking to justify the Council’s recommendations and is thus not consultative but merely ticking boxes

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
Mixed houses is feasible in existing urban areas and that a more joined up thinking and cooperation across boundaries is required in order to find an optimum solution.

Urban renewal and regeneration continues to be of higher priority and we 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 close to suitable transport infrastructure.

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
Each should be evaluated on its merits, delivery of material increases in housing stock should be prioritised around brownfield sites and urban regeneration.

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
Density depends on many factors so a definitive answer is subjective. Creative design should be used to maximise the opportunity with these developments whilst providing community amenities, green spaces and infrastructure

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
Moving from the current 8 hpd to the proposed 40 or 60 is quite totally out of keeping with the current environment and capacity of the area’s infrastructure and transportation to handle.

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 totally insufficient

Parcel 20 (next to Portsmouth Road, Cobham):
• Infrastructure 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 and they should be maintained as green belt land.

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
A blanket approach to the challenge around development of affordable housing regardless of the quality of life and/or environmental impact is not appropriate. However no green belt land should be considered for development without exhausting brownfield developments 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
Brownfield sites should be developed to address the current and any future housing needs.

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 the norm in many other countries in Europe and have proven successful.

17

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

Each opportunity / proposal should be evaluated on its merits.

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
Again Green Belt land should be protected and brownfield sites developed first.

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
There should be a focus on mixed residential/retail/small business developments in these areas with a view to replicating success in other European examples.

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
There should be a focus on mixed residential/retail/small business developments in these areas with a view to replicating success in other European examples.

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
Flexible usage of urban/high street areas should be encouraged.

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
It is of the upmost importance the council protects Green spaces provide the “green lungs” to counter the increasing urbanisation and provide the residents of Elmbrige the opportunity to explore and enjoy the countryside and green spaces and to encourage plant and animal bio diversity in these areas.
Creative design should be used to maximise the opportunity around these areas.

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?

Creative and inspirational design should be used to maximise the opportunity around all areas in Elmbridge and all opportunities for commercial development close to open spaces that should be considered.

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
Any plan of this complexity cannot be considered in isolation and hence we fundamentally disagree with an approach that just singles out housing.

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?

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 which should be prioritised over the areas identified in this consultation where current infrastructure and services are already not fit for purpose.
Essential infrastructure developments that must be considered before development of the proposed areas include:
• Alternative road patterns be developed to ease existing and future traffic congestion, including improvement of rail road bridges, roundabouts and traffic lights.
• Adequate number of schools, surgeries, parks and green areas to ensure quality of life for residents.
• Parking at or near transportation links, including Stoke d’Abernon and Cobham Stations.
• 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 Strategic Consultation paper contains numerous flaws and inconsistencies. The methodology is subjective and flawed

• Entire premise of the consultation rests on the requirement to build 9480 new homes. The probability of this forecast being correct needs to be understood – is it enough to remove Green Belt status forever?

• The paper has only explored 3 parcels of so called “weakly performing” land – other parcels of so called “weakly, moderately or strongly” performing may be more suitable for development e.g. nearer to higher urban areas

• 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

• 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 my 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

• These proposals have no regard to the size of the existing settlements where the new house building is being considered and the impact on their existing communities and infrastructure. Because Elmbridge is neither a place of being or a community in its own right but a collection of very separate and different communities and settlements, any sensible housing strategy has to be broken down and as a starting point to look at each settlement / community and assess how many additional dwellings need to be accommodated having regard to the size of that settlement to Elmbridge as a whole.

• As the whole purpose of deselecting green belt land is for meeting housing need, it is a flawed process that ignores infrastructure. Green belt land in an urban or semi urban community may be more appropriate for development where there is adequate or good infrastructure than where it is in a rural or semi-rural community where there is inadequate or poor infrastructure.

34. Files

«No files»