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Response Details

Response Details
From CPRE (Keith Tothill)
Date Started: 13 Mar 2017 10:42. Last modified: 13 Mar 2017 10:53
Status Complete
Response ID #528093

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
Yes, we agree that the document sets out the key challenges facing Elmbridge. The key challenge is we believe the pressure from Central Government to build many more dwellings but in an area where there are major constraints. Areas such as Elmbridge, around London have some of the greatest pressures for increases in dwellings. In the Borough, more than half of the demand for houses comes from the in-migration pressures from the London area as ever increasing numbers of people wish to move to this very attractive area. This pressure is continual and shows no likelihood of decreasing. To satisfy it, as the Government is attempting to do with its current policy of calculating the objectively assessed housing need and then pressurising individual Local authorities to do all they can to satisfy it, can only mean the continual erosion and loss of much of Elmbridge's Green Belt a piece at a time.
This housing demand challenge is however at odds with the premier key challenge which we have interpreted as the need to the protect the Green Belt. We consider that the Green Belt in Elmbridge needs to be fully protected, to attempt to identify so called parcels of land that are often rather artificial and which are labelled as weakly performing is subjective and superficial and the real danger is that it will only lead to more and more land being lost over time.

2

Do you consider there are other challenges that we should be addressing?

 

  • Yes
  • No
  • Don’t know

Please explain your answer
We do not consider there are any other key challenges IF we have interpreted the Consultative document correctly and the Council has accepted that the protection of the Green Belt is a key challenge.

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
We consider that the major challenge is the protection of the Green Belt in Elmbridge. The Green Belt in Elmbridge has been in place for many years and its detailed boundaries were established in the first Elmbridge Borough Local Plan in the early 1990's. Since then they have successfully protected the Borough from the encroachment of London and the need to prevent its many separate urban areas from merging. However, up to now there has not been sustained pressure on Elmbridge's Green Belt because there has been sufficient capacity within the urban areas and there have been no unjustified pressures for the Borough to accommodate the total demand for housing specially from London.
This is the first time since its inception that the Green Belt has actually be called on to actually perform the purposes that it was designed for. But it is now that the Council and Government are suggesting that parts should be lost. This seems very perverse to us. Just when it is actually needed to fulfil its long held and widely respected purpose, it is being sacrificed and weakened.

Secondly, we believe that another challenge that is more important is the need to provide additional infrastructure. Additional dwellings require enhanced infrastructure, in the form of schools, medical facilities, cultural facilities and new roads and improvements to existing roads. However, we believe that simply there is insufficient money to provide the necessary new and improved infrastructure which is vital to support additional dwellings. We enlarge on this issue at Question 31 below.

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?
CPRE Surrey does not consider that Option 2 is appropriate-it is flawed. However, both Option 1 and Option 3 are unrealistic and impractical. It is incorrect and misleading for Elmbridge to include in this first public consultation these 3 Options, which attempts to steer public opinion in one direction only, by putting forward for consideration two equally and unrealistic options.
Option 1 is to maintain the Green Belt but to significantly increase densities in urban areas, develop green spaces and in order to satisfy the OAN figure of 9480 dwellings from 2015-2035 it would be necessary to build at densities of up to 300 d.p.h. or seven storeys high development. This Option is clearly not practical IF the Council is working on the assumption that the OAN figure is to be satisfied in full. We find it strange however that the Council is in this Option ONLY considering satisfying the full OAN, whilst in Option 2 it is considering only building dwellings to satisfy part of the OAN i.e. an extra 1700- 2400 dwelling above what it considers can flow from permissions and opportunity sites and windfalls.
We ask WHY IS THERE IS NOT A MODIFIED OPTION ONE, where an additional figure of perhaps 1700-2400 dwellings are found in the urban areas? We are aware that finding more urban capacity is the usual response from environmentalists and we recognise that finding "so called weak" Green Belt land is a lot easy for Council Planners than scouring the urban area and taking the brave step of suggesting higher densities and in some locations MUCH higher densities. We consider that there needs to be a "step change" in density planning. Elmbridge in the past has be far too happy to permit the traditional low density development with an emphasis on 4 bedroom dwellings. This has resulted, as the Council now recognise, in a completely unbalanced housing mix. So what is needed is a rigorous new search for additional urban sites where resulting densities would be much higher than what would now be permitted. We would suggest that developments around existing centres should comprise at least up to 4 storeys. An extensive search should be undertaken of office areas where in the right conditions residential would be an alternative use.
Option 3 is, we would suggest, also completely unrealistic, that being to satisfy the OAN figure of 9480 dwellings in full, by increasing densities where appropriate (this is agreed), and amend the Green Belt by deleting large areas regardless of any classification of assessed strength/worth. To achieve Option 3 would require very large parts of the Green Belt to be deleted and built on, which would destroy its concept and integrity, weakening it to such an extent that it would be open to even further erosion in the future.
That only leaves Option 2 to consider, which the Council are putting forward as their preferred Option. However, CPRE Surrey does not accept that this Option should be further considered either, for reasons we will elaborate on below. We do recognise that the Council has taken the courageous step in Option 2 of not attempting to satisfy or reach the full OAN. We congratulate them on this stance. Why the other two Options have decided not to do so is not really clear.
However, Option 2 attempts to identify so called weakly performing parcels of Green Belt and then to identify within these parcels areas that are not subject to constraints or ownership problems. This however leaves a large outstanding deficit in the residual figure of 5780 dwellings. Elmbridge have calculated that if the so called developable areas are actually built on some 1720 dwellings can be built (at a density of 40 dph). This reduces the residual from 5780 to 4060. A further figure of building 2460 dwellings at a density of 60 dph is, we consider most unlikely.
However, we are opposed to Option 2 as we do not consider that these three key strategic locations in the Green Belt should be deleted. We do not consider they are weakly performing, in any case we do not accept that that there are any exceptional circumstances put forward which would allow loss of existing Green Belt and further we consider that the results of building 1720 dwellings and upwards in Cobham, Oxshott and Long Ditton would be bordering on a disaster as the necessary infrastructure would not be forthcoming. To put it simply- One it would not be possible to alleviate the harm to the existing communities if these dwellings were built and two we do not consider that the huge financial costs to provide the necessary infrastructure could ever be raised by either Grants from Central Government, raising Council Tax or obtaining the money from the developers. The Surrey infrastructure Study 2016 is clear that there is a huge funding Gap in Elmbridge and even using figures that do not include the large increases in dwellings envisaged by Option 2 the deficit of some £161m is the third largest in the County and the figure as a percentage of costs is 28%, the worst of all 11 Districts. We recognise that CIL will raise some revenue, but that source has already been included in the calculations (further raising CIL is unlikely to be very successful). Further comments on the results of the Surrey Infrastructure Study is given in our response to Question 31.
We accept the SHMA has indicated a massive increase in housing demand over the next 20 years and if this figure is accepted a near doubling of annual house building, from an historic average of 200-300 dwellings a year to 474 dwellings a year would be necessary. Is this uplift really feasible given the lack of skilled labour and the reluctance of the 10 largest housebuilders to increase build rates?
We are not sure if the SHMA constituent parts with their individual conclusions are correct, or that the final figure is correct. It is clear the exercise is a complex one and the layperson cannot hope to attempt any constructive criticism. We are aware that individual housebuilders place great store on the individual SHMAs that individual Council's prepare and invest much time in criticism, in the hope that the dwelling assumptions/figures will be increased by the Inspector. Each component part is based on either a trend, an average over a specific time period which can be argued over with different figures often having as much justification as the original.
However, what is important is that Government has always insisted that the SHMA is only a starting point -giving an indication of what the unconstrained housing demand figure might be. Government guidance and the individual documents are always clear too in stressing that the exercise is a policy off figure and does not take account of the constraints existing in any Borough or District. We consider therefore that the constraints in Elmbridge make the SHMA a largely academic exercise which needs to be treated with extreme caution.
We will outline are reasons for considering that the three key strategic parcels are not weakly performing under Q6 below, and we will outline our case that there are no exceptional circumstances to support an amendment of the Green Belt under Q 5 below.
In conclusion, we cannot support Option 2 (or either the existing Option 1, as it stands and 3). What we suggest is a modified Option1, where still more emphasis is placed on the urban areas. We consider that by increasing densities in all parts of the Borough including less emphasis on matching existing character and densities, but with even greater emphasis on skilful design. We recognise this will not be popular with some residents but extreme problems require extreme solutions.

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
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."
CPRE Surrey 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.
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. 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.

(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. 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.

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
CPRE Surrey has argued in Q5 that there are no existing exceptional circumstances which would warrant the removal of any Green Belt, even through the Local Plan process. We are equally adamant that none of the 3 Strategic Area at (i) Land north of Blundel Lane including Knowle Hill Park and Fairmile Park Cobham (Local area 14) and (ii) Land north of the A309 and west and east of Woodstock Lane North, Long Ditton (Local area 58) (iii) Land south of the A3 including Chippings Farm and the Fairmile Cobham. (Local area 20) should be removed from the Green Belt.
The Arup Green Belt Review document has attempted to prove that there are three large parcels of Green Belt land that according to the criteria adopted only perform weakly against the first three purposes of the Green Belt as set out in Guidance. We have reservations on parts of the document's reasoning and do not agree that the three areas (14, 58 and 20) should be declared weakly performing.
Purpose One: Checking sprawl of large built up area:
We believe that the aspect of whether a Parcel is on the edge of a distinct large built up area has been undervalued and therefore underscored by Arup. Those parcels that pass the test are just given just a PASS score. This Pass- a very important aspect in our consideration does not appear to be carried forward into any final scoring. We consider this is incorrect; it should feature strongly in the final scoring that decides how the Parcel scores overall.
Further we reject, as incomplete, the Arup list of large built up areas which excludes both Cobham and Oxshott . In the local Elmbridge context (and we are looking at the local Elmbridge Green Belt) we consider both these areas ARE major /large built up areas and must be included in that category. We see no reason for their exclusion as both Bookham and Fetcham (in Mole Valley) have been included. Certainly, neither Bookham or Fetcham are larger than Cobham or Oxshott.
Turning to the second) aspect of Purpose One –"preventing outward sprawl into open land and serves as a barrier in the absence of another durable boundary". We believe that the study in this aspect is flawed and places far too much emphasis on whether there is a durable or permanent "barrier" existing somewhere. We accept that guidance indicates that parcels can be delineated by such barriers -i.e. roads or railways but we feel that just because such a physical barrier exists somewhere then the whole parcel (that owes its existence to that barrier) should then, by Arup's 6 own criteria (on Table 4.2), be downgraded to the lowest scores (1 or 1+).
We believe that the artificial parcel of Green Belt, however large or small, but especially large, which has been created by the presence of a road or railway, should not be just dismissed as not having value in preventing sprawl into open land or serving as a barrier at the edge of a large built up area. This assumption completely downgrades a parcel's intrinsic value in preventing sprawl and can (and does) condemn large important Green Belt areas that are "on the Front line" to little or no importance under Purpose One. Looking at some of the parcels immediately adjoining the built up area and close to Greater London we feel they are unfairly undervalued by the scoring created by Arup.
Purpose 2 To prevent neighbouring Towns merging.
We agree with the Arup statements on page 4.4.2 that "gaps form the basis for maintaining the existing settlements pattern"-so vital in a Borough such as Elmbridge. We do agree that Long Ditton, Hinchley Wood, Cobham (including the area of Stoke D'Abernon,) and Hersham (and the others listed) are all valid Settlements that must be protected from merging or coalescence. We also find no fault in the 4 scores and their definitions in Table 4.4 on page 42.
However, we fundamentally do not agree with is Arup's placement/scoring of certain gaps that presently exist between settlements especially in Parcel 58 and 14. We believe their scoring is far too low and underestimates the role and importance the parcels play in preventing merging of settlements. We will enlarge on our alternate scoring with regard to the 3 parcels of land below.
Purpose 3: to assist in safeguarding the countryside from encroachment:
We accept that this purpose should be scored with regard to the type of uses either rural or urban and also an assessment of the percentage of built form existing.
We would take issue with the assessment that semi urban character should include" Publicly accessed green spaces" and "green corridors", "country parks", or "local nature reserves". In most cases we consider these are more rural in nature although each individual case would need to be considered. However, we do feel that for example the local nature reserve in the Long Ditton parcel is largely rural.
We also would suggest that the percentages of "built form" contained in Table 4.5 (to score 5 less than 3% built form, to score 4 less than 5% and to score 3 less than 10% ) are too strict. We would suggest amendments so that to score 4 the % of built form should be increased to "less than 10%" and to score 3 the % of built form should be "less than 15%". Consequently the % to score 2 should be increased to "less than 18% ".
With these relatively minor adjustments, which we believe are just as authoritative as those suggested by Arup, we feel that the scores given for Purpose 3 will be in some cases increased with justification.
We do not agree that in Parcel 20 (south of the A3), for example, where the farm complex is one or two built forms present, should be classified as an urban built form, it should as a farm buildings be reclassified as rural.
We now turn to the 3 large land parcels that the Council has identified as weakly performing and has suggested should be removed from the Green Belt. We consider that with the justified amendments argued above that these parcels ARE NOT WEAKLY PERFORMING and so there is no proven case for removal from the Green Belt.

INDIVIDUAL COMMENTS ON THE THREE PARCEL.

LOCAL AREA 58: LAND NORTH OF THE A309 LONG DITTON.
Arup has scored this area as: WEAK CPRE scores this area as: STRONG
Purpose 1: a Pass and 1 of 5. CPRE scores a PASS and at least a 3
Purpose 2: scores 1 out of 5. CPRE scores 4-5. Purpose 3: scores 2 out of 5. CPRE scores 3.
The parcel forms part of the wider area which includes Thames Ditton and Molesey that Arup agrees performs "very strongly" against the first two purposes of Green Belt.
We agree that this area is a PASS for Purpose 1, and as we have argued this should automatically be counted in the scoring process. Its position immediately adjacent to the urban area of Long Ditton, Thames Ditton and parts of the Borough of Kingston Upon Thames means that it plays a vital role in checking the unrestricted sprawl of large built up areas, in this case South West London. CPRE Surrey considers the whole Parcel performs a vital part of the "green lung" entry into this part of Elmbridge from London. We do not agree with parts of Arup's description of this parcel. It is NOT "enclosed within the large built up area of Greater London", or that Long Ditton is "part of the Greater London built up area". There is a marked change in urban character between Surbiton and Long Ditton.
More importantly we also do not agree that the Parcel scores weakly across all purposes as claimed at 6.1.8. We disagree that just because it is bordered to the south by a major road this automatically prevents the Parcel serving Purpose 1. This area is in the immediate "front line" in preventing London's sprawl continuing further south. Such emphasis on the A309 checking any further urban sprawl is, we believe, much exaggerated. If the area to the north of the main road was removed from the Green Belt and built on there would be considerable pressure to develop for housing areas immediately to the south of the road. As we have argued the presence of a road on its southern boundary should not condemn the whole area of some 67 hectares to a weakly performing status just because Arup have argued that having a durable boundary is damning. The area itself strongly performs to the first purpose of checking sprawl . The Parcel we consider should score at least at a 3.
Turning to Purpose 2 we disagree that the parcel as claimed "makes only a very limited contribution to the overall gap between Long Ditton and other areas. Para 6.1.8 only mentions this gap in the context of Long Ditton and Claygate ("little risk of coalescence".) However, NO credence is given at all to the importance of the gap east west between the major settlements of Long Ditton and Hinchley Wood. This would be very severely compromised if the land was removed from the Green Belt. We note that Arup has included both Hinchley Wood and long Ditton as large built up areas. We would rate Parcel 58 as scoring a 5 on Arup's scoring (an essential gap and where development would significantly reduce the perceived or actual distance between non Green Belt settlements.
For Purpose 3 we again question whether the parcel performs weakly as a result of fragmented configuration and previous encroachment. There are various uses in the parcel including a local nature reserve, cemetery, allotments, playing fields, private schools and to the south a large nursery. At least some are admittedly urban in nature but others are not, but Arup's score of 2 out of 5 would be easily increased to 3, if a revised just as appropriate % rating was introduced as argued above.
We must object to the conclusion at para 6.1.8 which although accepting the area is part of a strategic area one that checks the sprawl of London and prevents coalescence goes on to say that the parcel contributes to neither of these purposes "strategically" and sits as a "stand alone parcel, suffering encroachment and is disconnected to the wider countryside". We argue the area is on the front line in preventing further sprawl and needs to be considered and valued for its own sake. It contributes by its many uses and also countryside to the benefit of those living in the adjoining urban areas. We accept that a major road abuts its southern border but we feel this fact has been unfairly magnified in much of Arup's analysis. Instead more emphasis needs to be placed on the areas intrinsic value to preventing sprawl and coalescence and providing valued recreation to nearby urban dwellers.
The parcel contains valuable community assets, in the form of many types of recreational pursuits which we understand are mainly Council owned or controlled. Although the Officers have stated there is no intention to develop these areas, many things can change in a few years. We believe that removing this area from the Green Belt and the protection which that should give, is incorrect and places much additional development pressure on these areas. Money can talk and millions of pounds could well be a real attraction to a Council that is short of money now and even more in the future.
We are aware of many specific local comments concerning the importance of this Land Parcel to the Long Ditton community. Each will be strongly argued by The Association in their response to the Council and by individual residents. CPRE Surrey has not included some of these in our response but largely agrees with them. As well as incorporating many in our response see above, we would like to mention the following: The topography of the area provides important views (Oak Tree Hill, and Squires View are the most important) across parts of the Borough and beyond, for example to Heathrow. These viewpoints are well used by locals for a variety of recreational activities and require protection from development. Two existing uses in the south of the Parcel are at risk -these are the Old Manor House, now a Buddhist community and the Kisimul School a special school for children with learning difficulties. These two organisations are incumbents of historic buildings. To propose large scale development around them when they chose the location precisely for the benefit of open space that the Long Ditton Green Belt affords could seriously degrade their environment.
In conclusion, adding revised scoring from Purposes 1, 2, and 3 we assert that the parcel overall would rank as over Moderate and probably Strong. Thus, we would question strongly whether it is a candidate for exclusion from the Green Belt.

LOCAL AREA 14: LAND NORTH OF BLUNDEL LANE, KNOWLE PARK AND FAIRMILE PARK COBHAM.

ARUP has scored this area as WEAK. CPRE scores this area STRONG.


Purpose 1: Fail scores 0 out of 5 CPRE PASS scores 3. Purpose 2: scores 1 out of 5. CPRE scores 3-5. Purpose 3: scores 2 out of 5. CPRE scores 4.
For Purpose One (preventing sprawl) Arup have scored this parcel very poorly. We do not agree that as at para 6.1.1 it "fails to meet purpose One as it is not located at the edge of a large built up area". We have argued earlier that both Cobham and Oxshott should be classified as "large built up areas.". It is clear as one travels east along Blundel Lane one is leaving a substantial urban area and the open area is preventing further development along the road into Oxshott and its village core. We would therefore reclassify the parcel as a Pass, and also instead of scoring a nil by Arup we feel that it should be rescored as 3 (as the "land is connected to one or more large built up areas and bordered by permanent and consistent boundary features". Many times in the past 20-30 years there has been severe pressure by developers and /or landowners to put forward parts of this area as suitable for development usually at the Local Plan process (first in 1992). These pressures were strongly resisted by the Council on Green Belt grounds. Without continual resistance, areas facing Blundel Lane would very soon be developed with very likely low density housing. (the type of housing not needed in the Borough.)
Turning to Purpose 2 Arup argues the area meets purpose 2 weakly as it is "nearly fully enclosed within the settlement footprint of Cobham..playing a less than essential role in preventing coalescence with Leatherhead and Fetcham". This comment appears to come from someone who patently does not know the area and has been largely viewing the parcel from only a map. On the ground the situation is entirely different. The parcel is certainly NOT enclosed within the footprint of Cobham, it is a distinct entity in its own right stretching from the north along Fairmaile Lane with open views south to and beyond the office complex and to the south stretching from the edges of Stoke D'Abernon along the road east to the outskirts of Oxshott village. Removal of the Green Belt protection of this parcel would almost certainly lead to the virtual merging of Oxshott with Stoke D'Abernon and Cobham. We therefore feel that the analysis by Arup of 1 is simply wrong. The description that fits this area under Table 4.4 assessment criteria is at least a 3 ("a wider gap between non Green Belt settlements… where the overall openness and the scale of the gap is important to prevent merging."). Score 5 speaks of "an essential gap between non Green Belt settlements where development would significantly reduce the perceived or actual distances between them." It is not difficult to argue that removing Green Belt status would "significantly" reduce the actual distance between settlements.
Purpose 3- protecting the Countryside is ranked by Arup as a 2. The area is largely rural except for the large Office complex set within the open grounds of Knowle Park. The only built form in the whole land parcel is this office building and we consider the overall % of built form as described by Arup in Table 4.5 is little over 5% . This would score the Parcel between 3 and 4 (on Arup's scoring ) and a 4 in the suggested CPRE revised scoring. We do not agree with Arup's conclusion that "the countryside is highly fragmented"-there are in fact large open areas with mostly non-intrusive boundaries. The comment on "managed status" is only true in part -we would accept that the large open area of Knowle Park is somewhat managed but it still presents an attractive open park cape fully appropriate in the Green Belt.
Adding our revised scoring for Purposes 1-3 increases Arup's scoring of a FAIL and only 3 points (weak) to a PASS and at least a 9. On this basis we feel confident that Parcel 14 performs at least moderately and most probably strongly.

LOCAL AREA 20: LAND SOUTH OF THE A3 INCLUDING CHIPPINGS FARM AND THE FAIRMILE COBHAM.

Arup has scored this area as WEAK. CPRE scores this area as MODERATE
Purpose 1: FAIL. scores 0 out of 5. CPRE: PASS scores 1+ Purpose 2: scores 1 out of 5. CPRE scores 1-3 Purpose 3: scores 2 out of 5. CPRE scores 3-4.
For purpose One Arup states the area fails to meet Purpose One (preventing urban sprawl) as it is not on the edge of an identified large built up area. We disagree that Cobham has been excluded from this list. We believe Cobham is just as much a large built up area in the Elmbridge context as Leatherhead, Fetcham and Bookham are to Mole Valley, and thus should be included in the list of large built up areas. Thus, the parcel should be reclassified as a PASS in Arup's document. It is located immediately north of Cobham to the Esher Road and is viewed as a very largely open area stretching away north from the main road. The A3 cannot be seen as it is constructed in a cutting. Parcel 20 is essentially part of a largely open corridor that runs on one or both sides of the road all the way from north Cobham including Cobham Rugby Sports fields north to Esher Commons finally ceasing only after Claremont Gardens. We consider therefore that Parcel 20 is a vital component of this green corridor and for this purpose alone should be retained as Green Belt. We accept that the parcel is bordered to the north by the A3 and this appears to weigh very heavily in Arup's conclusions that it scores a 0. We contend however that the classifications and subsequent scoring for Purpose 0ne (in Table 4.2) over estimates the presence of the A3 which we have already observed in in cutting. Also, we believe the Parcel should be valued for its own sake and therefore has importance in preventing outward sprawl from the urban development which is already contained by the Portsmouth Road.
Turning to Purpose 2, preventing towns from merging, we accept that the parcel makes only a limited contribution to the overall gap between Cobham and Hersham.
Purpose 3 is concerned with protecting the countryside. Arup has ranked the parcel as only a 2. We believe this is too low. The description at 6.1.4 states that the area is "heavily influenced by urban developments" and other uses. We reject the statement made that uses that are directly adjacent, and therefore OUTSIDE the parcel such as residential dwellings to the west and east reduce the openness. All open parcels adjacent to an urban area have residential on their borders and we fail to understand how this reduces the openness of the Green Belt parcel itself.

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
We consider the whole of these three Green Belt areas should be retained in the Green Belt and should not be developed in the forthcoming Local Plan.

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
We do not consider that any other areas should be removed from the Green Belt as there are no valid exceptional circumstances which would overcome a proposal to alter Green Belt boundaries leading to the construction of dwellings on Green Belt land, that Government guidance states should not be developed, but should be retained as open.

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
Elmbridge has never provided a size balance of new dwellings and this needs to be corrected as much as possible through this new Local Plan, as available land is limited and it is unsustainable to continue to permit low density developments and large 4/5 bedroom dwellings on the remaining sites that will come forward. Up to now too much emphasis has been placed on providing new dwellings that accord to the size and density of those existing. The need is for smaller and cheaper dwellings in all parts of the Borough including those parts where up to now only very large dwellings have been built. Developers usually favour the construction of large houses and luxury flats for a variety of reasons not least they give greater profit, however it is the responsibility of the local Council to provide a robust counter to this and put in place clear, strong policies very much favouring smaller cheaper dwellings wherever possible. The local Council must not be passive in this by permitting in most instances the type and size of dwellings the applicant/developer wishes.

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
Most certainly. It is a waste of the limited amount of land in the Borough to continue to permit such a distorted range of house size and density. A new approach is required in this new Local Plan with rigorous new housing policies enforcing the higher densities and an emphasis on smaller cheaper houses.
It is however not just the necessity to delivery less 4 or more bedroom houses. What is required is far less emphasis on what is branded as "luxury houses" which are being presently built in quite ordinary locations. - resulting in even higher priced dwellings. At present, even 2 or 3 bedroom dwellings are built which are at the luxury end of the market. In most cases when flats have been built they are also marketed and built as luxury flats. This sort of dwelling is not what is required. Thus, in the past when the Borough dwelling completions show a large number of 2 bedroom flats (or even houses) have been built this is very misleading. Mostly what has been built are unnecessarily too expensive. The Local Authority must strictly enforce not just the size of dwellings permitted and built but the type of dwelling- with far less dwellings at the luxury (and more expensive) end of the market. This, it is recognised, will not be easy as there is constant pressure from developers to build larger more expensive houses and flats and some existing residents who do not want any new developments to comprise smaller houses.

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
Government policy is to encourage and increase higher densities at sustainable locations. Some years ago, Government policy in PPG3 was to set a minimum of 30 dph.in almost all locations and sites. This was never even attempted or encouraged in Elmbridge, resulting in many development sites being built at far lower densities with a high proportion of 3,4 or 5 bedroom dwellings. This minimum density of 30 dph does not appear in the NPPF but there are good reasons why this standard should not be reinstated locally.
The figure of "above 40 dph" could mean any figure -We would suggest using a minimum of 40 dph with 50 dph being the norm wherever possible. We would also wish there to be a high proportion of social housing. We consider the term affordable is misleading and insufficient as in this sort of area affordable is not affordable to those in housing need. It is of course recognised the there is a difficulty in providing not just affordable but social housing as Government funding on which this type of housing depends has declined over the years and is now very limited.

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
However, after due consideration by the Council, IF any of these three areas are eventually removed from the Green Belt and individual sites proposed for residential development we consider that development should be at the highest density possible. This would certainly be above 40 dwellings per hectare although we are of the opinion that a figure of above 50 dph is unlikely to be possible in most locations. As we have already argued we at CPRE Surrey are opposed to building dwellings within these three strategic sites at Long Ditton, Cobham or between Stoke D' Abernon and Oxshott.

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
It would be a complete disaster if lower density housing was proposed /built on former Green Belt land. It would also be a complete betrayal of the Council's arguments and case for building on Green Belt land. The whole reason for building on Green Belt land, according to the Council is that there is an imbalance of housing type/size existing within the Borough which can be only be alleviated by building on parcels in the areas identified. In addition, an exceptional circumstance given by the Council is to provide more so called affordable housing-this type of housing is by its very nature only built at higher densities. (however, by far the greatest need is for social housing and this too is provided in higher density developments).

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
CPRE Surrey totally agrees with the approach Elmbridge is taking to continue to apply existing Policy CS21 wherever possible. There are special local circumstances existing in Elmbridge and other Surrey Districts (and other Districts outside Surrey too) i.e. so many of the sites that have come forward for permission are below the size threshold identified by the Government and also below the 10 unit threshold. The data showing this fact has been provided in the Council's various publications/at appeals and in the Monitoring Reports published each year. Without the contribution of these smaller sites the amounts of affordable housing would be very much reduced-and it is affordable housing that Elmbridge so very much needs.
Various Inspector's decision letters over the last year have shown that in many cases this approach is being supported even though the Government yet do not seem to recognise the need for a full scale review and change of heart. Only by continuing to put the case at all opportunities and support their Policies can Elmbridge and other Councils continue to lobby and pressurise the Government effectively.

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 further comment.

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
It is important for Elmbridge to retain its best strategic employment areas. They provide jobs for local people and reduce to a small extent further commuting (although we do recognise that many workers drive to work by car and are not residents of this Borough). We are aware that Elmbridge reviews its strategic employment areas to ascertain whether all are still strategic and performing their role. These reviews should be undertaken regularly in the future. It is clear that at present residential land prices are higher than most employment uses and so there is continual pressure for employment areas to be closed and then sold for residential. It is vital that these pressures are resisted on the well performing strategic employment areas.

17

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

Not applicable

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
CPRE Surrey are not aware of any exceptional circumstances that would provide for loss of Green Belt in this location.

19

Other than Green Belt what other barriers do you consider could prevent further development at Brooklands?

We are aware of the traffic congestion on local roads generated by the existing retail and employment uses but we are not qualified to comment on whether this congestion is at such a level as to prevent any further development.

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 Any proposals for improved or extended conference and hotel facilities should be treated and examined with caution as the whole area is at present contained within the Green Belt. Part of the site is built upon and is thus previously developed land. We are aware of the Government's proposals for allowing development on previously developed land in the Green Belt which goes much further than existing guidance. We are opposed to wholesale development on Green Belt land where there are limited existing buildings. The vast majority of Green Belt sites need any new development to be sensitive to the location and take full account of the "footprint" guidelines (only allowing new development on the areas that are at present developed). Preference must be given to maintaining the general openness of the area. This will require that great care is taken over the height, mass and bulk of any proposals. We consider that the complete area of Sandown Park is subject to a comprehensive study in the light of final Government guidance and a Brief produced that will guide any future development with emphasis placed on the fact that the area is within the Green Belt and also that the Racecourse is an important tourist facility immediately adjacent to Esher town centre.

21a

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

  • Yes
  • No
  • Don't Know

Please explain your answer
CPRE Surrey are very much in favour of still focussing new retail development within the towns and villages (although this may not preclude the very occasional edge of town or even out of town development where it can be clearly shown no harm will come to the existing centre's vitality and viability.)
We consider that so called "changing consumer habits" are NOT driving retail out of town, in fact the reverse is more likely. The large weekly shop at one superstore is being, to some extent, replaced with smaller more frequent trips and the growth potential appears to be for a wider choice of smaller stores in or on the edge of town. Towns and villages are still adjusting further to the 24-hour centre with more uses and residential units being built in them. This trend needs to be encouraged further.

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
Yes, the primary shopping areas as largely set out in the current Core Strategy should be protected for retail uses. There may however in the light of experience, since the Core Strategy was adopted be some minor adjustments. Without this continued Policy, the vital retail uses which need to be clustered together in the town and village centres will be threatened by business and financial services which are often able to outbid financially conventional shop uses.

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
Although we consider that the primary shopping frontages in the Borough's centres should be protected for retail uses there may be a very few nonretail uses, including doctor's surgeries, dentists and libraries that in exceptional circumstances could be permitted. It is most likely that in each centre very few instances would come forward and some would not have to be on the ground floor. Examples of a library being proposed on ground floor premises would be rare. However, as the scheme at Dorking has shown it can be a success which adds vitality to the centre. The number/type of individual uses that could be treated as an exceptional circumstance would need to be carefully considered before inclusion and then each specifically included in any revised policy for each individual centre.

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
All open spaces need to be reappraised again to consider they meet the selected criteria for protection and then given the level of protection and included as Local Green Spaces in the new Local Plan.

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
CPRE Surrey has no further comments

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 comments

25

If not, what approach do you think we should take?

No comments

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?

We have previously argued that because of the need for further dwellings in the urban areas, that the existing requirement to make sure that all new development is built with due regard to the character and design (and therefore density) can be relaxed. That does not mean that design standards are relaxed or there is a rush to the bottom. Indeed, with higher densities there is a need for even more attention to be paid to design.

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
More detailed advice on this important topic, especially the need to take full account of the cumulative impact of small and smaller scale developments on the risks of flooding is of great importance.

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 further comment

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?

We do not agree that there should be new communities amounting to over two thousand dwellings in the three, so called key strategic locations.
Indeed, it is the lack of infrastructure of all types that is one of our objections to these proposed new developments in Long Ditton, Cobham and Oxshott/Stoke D'Abernon. Existing communities are already suffering from a lack of important infrastructure ranging from school provision both primary and secondary, medical facilities, (hospitals, doctors, dentists etc.), drainage, maintenance of existing roads and footpaths and inadequate roads, junctions etc. resulting in heavy traffic congestion especially at peak travelling times in the morning and evening. We do not see how planning for hundreds or even thousands of new dwellings (depending on the density adopted) can ever be safely or satisfactorily be provided in the three proposed locations OR how anything approaching adequate infrastructure ever be provided and paid for.
We have previously referred to the Surrey Infrastructure Study 2016 which clearly shows how there is a huge funding gap-the second largest in the county after Guildford BC. Even on the population/dwelling figures used (which do not take account of the proposed increases envisaged in Council favoured Option Two), the cost for the infrastructure envisaged amounts to £224m.The funding gap, after deleting secured and expected funding (which totals some £63m) is £161m. The secured and expected funding is only 28% of the total cost. This 28% figure is the lowest in the County.
This huge funding gap, which the Study states is "a minimum scenario" is a massive problem. The gap is only likely to increase, resulting in a chronic lack of infrastructure, which will likely result in severe problems for those parts of Elmbridge adjacent or close to the proposed three Key locations.

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?

Please see comments above. We see the major problem being the inability to raise the necessary finance to provide the required essential infrastructure. It is very unlikely that central Government will be able to provide the required revenue, with continual pressure on central Budgets and even less central government money being granted to local Government. We do not believe that sufficient money will be raised from the developers. They may well pay for some road improvements in the immediate area (which will be totally insufficient Borough wide) and some land or even buildings for medical and educational purposes. However, their contributions will not cover anywhere near what is required to staff and run these services.

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.

 

PLEASE SEE ATTACHED DETAILED RESPONSE FOR QUESTION, 4, 5, 6 -