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Response Details

Response Details
From Deleted User
Date Started: 17 Mar 2017 11:55. Last modified: 17 Mar 2017 11:55
Status Complete
Response ID #528913

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 challenge that Elmbridge BC has been set is to revise its local plan in accordance with the current National Planning Policy Framework (NPPF). Should it fail, planning decisions may be foisted upon Elmbridge by central government. This applies particularly to the enabling of greater home construction through the planning system.

To this end the council has estimated potential demand at 9,480 new households over the next 18 years, to 2035. This is an increase of 18%, or almost 1 in 5, over the existing households in Elmbridge, which are given on the council’s website as about 53,000.
Of that number, potential sites for 3,700 new households have been identified without the need for any change in the borough’s planning policy. That leaves a shortfall of 5,780 homes. To complicate matters, Elmbridge has an area of 9,634 hectares, of which 5,491 are Green Belt (57% of the borough) according to Ove Arup’s reports.

While the planning policy notes that it may not be practicable to meet the potential demand, it seems unlikely that central government would lightly accept the validity of a shortfall of nearly 6,000 on a potential demand for almost 9,500 homes.

The task is to see to what extent this demand could be met without substantial degradation of Elmbridge. This task is complicated by the fact that not only our neighbouring London boroughs but also all the other boroughs in Surrey face a similar problem. This presents a problem especially for the challenge identified as “Ensure associated infrastructure is sufficient to support any increase in development”. Much of the infrastructure in Elmbridge will be applied not for Elmbridge itself but to support other boroughs further out. Our roads will have to carry the cars of those living in boroughs further out (for example).

2

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

 

  • Yes
  • No
  • Don’t know

Please explain your answer
I think you have been set enough for the moment.

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
Without knowing all the challenges the council has been set, I could not answer this question.

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?
1. Not all of those parcels of land have been correctly assessed as underperforming

2. A Strategic Housing Land Availability Assessment has not been conducted to assess how much land within those areas might be made available for development on these parcels of Green Belt, and how many homes could actually be created. In the absence of such figures there is nothing to suggest there would be sufficient impact on the shortfall in the assessed need. The sacrifice of Green Belt could well be in vain, were this option pursued. Without an SHLAA, it is too soon to select this option.

3. Were this to be the least bad of the options described, there is clearly a need for further options. Three more are outlined at the end of this response form

To expand on point 1 -

Parcel 58 (Long Ditton) has mistakenly been included in the three areas of Green Belt. I cannot comment in any detail on the other two parcels, although on the face of it the same reasoning might well apply to parcel 20 (Fairmile).

I have lived in Elmbridge for a dozen years or so. I was born and raised in central London, moving out to Wimbledon in my mid-30s. From childhood I have driven, or been driven, out along the Kingston By-pass; then the A3, now the A3 and A309. Then and now one drives along the Kingston By-pass through the outspread suburbs of London. Suddenly one emerges from the Hook Underpass into the green fields and woods of Surrey. The change is abrupt, dramatic even. London has been stopped at the county line, and one is in the country.

Continuing along that dual carriageway one passes through Hinchley Wood, but until one reaches the old Esher Filling Station, now the Shell Garage, at the Manor Road crossroads, one is scarcely aware that one has entered HInchley Wood, because it is largely invisible from the main road. For quite some distance through Hinchley Wood it is not apparent that one has left the Green Belt. The perception is that one is still in it – high performance indeed.

The impact on my mind as a youngster, and I can hardly be alone, on emerging from the Hook Underpass was to define the essence of the Green Belt, the green girdle holding London in shape and preventing it sprawling over its neighbours. The sprawl of London ends sharply and one enters the rural county of Surrey. The Hook Underpass is a portal through which one passes to a dramatic revelation of the countryside beyond. I am now in my 60s, and the effect is just the same.

(To state what is perhaps obvious, the effect is much the same if one takes the Esher By-pass, the newer A3.)

The essential flaw in Ove Arup’s analysis of the performance of the green belt, as it applies to Parcel 58, is in their treating that parcel as a severable entity for the purpose of this analysis. As an area It may make sense for a number of valuable purposes where what matters is simply the identifiability of an area. For such useful tasks as counting the number of wild orchids, the counter needs to be clear where to stop counting. Some, any, clearly defined limit is valid. It does not matter whether the parcel is materially distinguishable from adjoining areas, so long as there is a clear and manageable limit for a piece of work.

But that is not the point here. The essence of a belt is its continuity, and in assessing the performance of any part of it one should avoid unjustified severance of it. The essential mistake in this instance is to regard the main road, the old A3, now the A309, as a boundary. It is not a boundary road. It is a radial road, a main road, radiating from London and, as such, it does not bound the Green Belt but pass through it, without severing it.

The southern part of parcel 58 is an open hillside, sloping down to the A309. The northern part, where the land flattens out at the top of the hill, is not visible from the road. It appears that none of the land in the northern part of parcel would be released by its owners for development. This leaves only the forward edge of the slope available for development, the only part of the parcel that is clearly visible from the road. If there was development on that part of the current Green Belt, it would be ostentatiously visible from the road.

Instead of passing through the Green Belt, the traveller would be met with a flow of housing down the hill to the northern side of the road : at which point, it must surely be nonsensical to attempt to prevent development south of the road on parcel 34 (or parcel 27, although that seems to be out of borough, but the new A3 is also a radial road).

For an assessment of the performance of Green Belt land, parcel 58 should not be treated separately from parcel 34 on the south side of the A309. (Because of the potential complications with parcel 27 being out of borough, it may be better not to mention it further, although it remains in mind).

Parcel 58 is an artificial entity. Its land is an integral part of the Green Belt and Ove Arup were mistaken in assessing its performance in isolation from its adjoining areas.

To expand on point 2 –

It remains unclear to what extent, if any, the owners of the land on these parcels would be willing to release their land for development.

Paragraph 159 of the NPPF indicates that the council ought to prepare a Strategic Housing Land Availability Assessment to establish realistic assumptions about the availability, suitability and the likely economic viability of land to meet the identified need for housing over the plan period. A Land Availability Assessment has been conducted, but only in respect of the currently available land. As a result we have no indication of the number of households that the release of underperforming land might produce. It is impossible to gauge whether their release could make a significant contribution to easing the shortfall. Unless they can make a substantial contribution, their sacrifice would be in vain.

The associated guidance makes the point that “The Framework makes clear that, once established, Green Belt boundaries should only be altered in exceptional circumstances, through the preparation or review of the Local Plan.” Paragraph: 044 Reference ID: 3-044-20141006

If there are exceptional circumstances which justify the release of “underperforming” Green Belt land for development, they surely would have to include the release of that land making a quantified and substantial contribution to resolving the unmet housing need. For that to be established, there first needs to be a Strategic Housing Land Availability Assessment covering the parcels of Green Belt land proposed for release. Without one, that option cannot be evaluated; and if it cannot be evaluated, there is no sound basis for recommending it.

Summary

Of the three (and only three) parcels identified as possible to release for development from the Green Belt as underperforming, one of them has been mistakenly assessed by the consultancy as a distinct and severable entity, so mistakenly letting it be identified as underperforming.

That mistake, particularly in confusing a radial road as a boundary for the purpose of this exercise, might also invalidate the analysis of parcel 20 at Fairmile, although I have not examined that parcel in any detail. I cannot comment at all on the analysis of the last parcel, 14, between Cobham and Oxshott.

This leaves at most two Green Belt parcels, totalling only 126.6 hectares, available for consideration. As yet there is no evaluation of how much of that land might be made available for development and how many homes could be fitted on there.

Option 2 is not yet fit to be selected.

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
Not without a Strategic Housing Land Availability Assessment to establish whether there would be sufficient benefit to be gained from sacrificing the Green Belt.

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
See above

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
(Apart from the cemetery, which presumably will need expanding one day.)

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
«No response»

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
If significant progress is to be made towards meeting the assessed need for homes, it would seem that densities must increase, and to do that one probably needs more flats, more terraced houses and smaller gardens.

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
Is there a glut of unsellable or unsold 4+ bedroom houses? If not, it is hard to say that there is an over-delivery of them. If they are the dominant type of house being built, it suggests that the demand for other types of houses is insufficiently strong to persuade builders to increase their supply. To what extent should the council seek to distort the market?

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
If there is to be a significant impact on the assessed need, we may need to contemplate approaching central London densities of 250 dwellings per hectare.

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
As I strongly disagree that this is a viable option, this question rather hypothetical. However, as conducting a Strategic Housing Land Availability Assessment on the Green Belt land in question should be a precursor to selecting any option to pursue, clearly this is one factor that she be included within that assessment.

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
See above, but would that not make the sacrifice of this Green Belt land in vain?

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
There seems to be little difficulty in selling the housing in Elmbridge, so it must be affordable. If there is a need or desire for subsidised accommodation, it would be reasonable to press employers to provide more hostels, nurses’ homes, section houses, etc., to house their less well paid employees.

(Extracting these sorts of payments does suggest a highwayman with delusions of Robin Hood.)

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
(Hasn’t a non-travelling traveller lost his raison d’etre?)

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
I disagree in part, because it seems to me the creation of places of employment is more important than defining the nature of the employment to be provided. I am also uncomfortable with barren working zones devoid of any residents to deter night-time mischief.

This boils down to general agreement provided there is sensible flexibility.

17

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

Set the general expectation with which developers should comply, unless they can both justify a better proposal and persuade the planning committee of its significant advantages.

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
This is superficially attractive, but I know insufficient to go beyond the superficial at this location.

19

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

This may be painfully literal, but it would be a great shame to lose any more of the famous banked bends.

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
On the face of it, this seems worth exploring. However, access to Sandown Park is not brilliant for large events. There is also a Jockey Club proposal to sell Kempton Park for development, which would mean transferring the Kempton Park meetings to Sandown Park. This would lead to more frequent congestion on the roads into Esher, not least on Boxing Day.

Should that scheme go ahead, is there scope for a good chunk of our shortfall being accepted by that council as a quid pro quo, within the duty to co-operate?

21a

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

  • Yes
  • No
  • Don't Know

Please explain your answer
A thriving high street leads to a healthy community.

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 the next answer

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
It occurs to me that many businesses that were accustomed to take place in offices on the floors above shops, such as solicitors, accountants, etc., may need ground floor access to meet access requirements for the disabled. In moderation these conventional high street services, along with banks (please!) and, in particular moderation, building societies, estate agents, restaurants, cafes, bars and pubs, should be accommodated provided that the practical retail aspect of the high street remains dominant.

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 would be nice. To what extent is it feasible?

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
This sounds good, but every ecological measure taken seems to end up very expensive and dangerously counter-productive. Diesel fuel, smart meters, wood-burning stoves, biomass power generation spring to mind before exercising the slightest depth of thought. Beware of the worthy – in this area, no good deed goes unpunished.

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
This is attractive on the face of it, but there do seem to be so many designations for restricting the use of land that there is a danger of turning a borough, every borough, into a control freak’s paradise, with everyone so tied up in knots that they can do nothing at all beyond a desperate wriggle.

25

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

Beware of piecemeal restrictions. All proposals for restricting the use of land should be viewed holistically, so that the fresh blood of change has a chance to circulate.

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
A general “Yes”. Is the council able enough to allow the occasional eclectic development of quality, without setting precedents which opens the gates to a flood of weird applications of indifferent quality?

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
Looking around, one gets the feeling a bit more guidance would help. Walking the Thames Path of late, it is noticeable how few houses are raised significantly, where one would have thought it would be both safer and more desirable to have a substantial space for non-critical storage under the house and the house well clear of any floodwater.

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
More than enough. Public transport in the borough is not going to provide convenient transport all around the borough, when people actually choose to travel. Zero-parking controls are readily circumvented. With cycle paths, one only has to look at the fiasco of the cycle path along Portsmouth Road in Kingston to realise that, without a great deal of care, they can do more harm than good.

Looking around, many of those cars are hobby cars, sitting in the garage most of the time while the daily runabout is used instead.

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?

Water supply, drainage and sewerage
Gas, electricity, telecommunications (including high-speed broadband)
Postal services
Refuse collection
Roads, both access and main
Parking space, for residents and visitors
Rail, tram, bus, taxi and river boat services
Convenience store and café/bar/other sociable place to gather
Police, fire and ambulance services
Doctor, dentist, vet, phsio- and other therapists
Play areas and recreation grounds
Nurseries and schools

Are there still obligations to provide such things as allotments and public baths?

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?

Smaller !
The pressure substantially to increase the number of homes available is not uniquely our problem. Not only our neighbouring London boroughs but also all the other boroughs in Surrey face a similar problem. Much of the requirement for more infrastructure in Elmbridge will be not for Elmbridge but to support other boroughs further out. As just one example, by the time they reach Elmbridge’s stations, the trains will already be full to bursting with the extra population of the boroughs further down the line.

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.

 

1. Most of the undeveloped land in Elmbridge is Green Belt, or otherwise constrained. Can we look at redeveloping underperforming built space, some of which seems distinctly drab and uninspiring? Can redevelopment co-operatives of the owners of individual properties be set up and be effective for redevelopment? Does one need to look at compulsory purchase orders?

2. Between Molesey and Walton there are two large storage reservoirs. Presumably Thames Water has significant problems with water loss through evaporation. Could they be interested in a high density development on stilts over those reservoirs, to create a Venice of the 21st century?


3. Is there one part of Surrey where a new town (? city) could be built, where the combined housing assessments for all its boroughs could be met in the one place, with economies of scale in meeting the infrastructure requirements. Maybe it could be achieved on the Milton Keynes model, with developments radiating out from multiple villages, but planning theory and practice will have moved on since then. This option seems to put the duty to co-operate in the proper light.

34. Files

«No files»