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Response Details

Response Details
From Carter Jonas on behalf of BGL…
Date Started: 21 Mar 2017 10:25. Last modified: 21 Mar 2017 10:25
Status Complete
Response ID #529728

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 challenges set out from paragraphs 2.7-2.23 and summarised in Figure 5 is a robust overview.
These correctly link to the three dimensions of sustainable development set out at paragraph 7 of
the National Planning Policy Framework (NPPF).

2

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

 

  • Yes
  • No
  • Don’t know

Please explain your answer
These challenges are articulated in the form of pressures for development and this is an accurate
reflection of one aspect of the many challenges facing the Council in its preparation of the
development plan, namely the pressures for different types of floor space and sectors. It is
necessary also to acknowledge in full the environmental and social pressures that already exist in
the Borough and how these pressures have to be reconciled as an integral and essential step to
sustainably meeting the needs for future development. These pressures arise in questions such
as quality of life, access to essential services such as health and education, and so on. This is
touched upon at paragraphs 2.17-2.20, but more as a constraint to development. We consider
that this should be explained as equal parts to the challenge of how to achieve sustainable
development, thereby balancing social, economic and environmental considerations.

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
There is a shortage of housing in Elmbridge and the need is estimated to be for 9,480 homes
(market and affordable) up to 2035, approximately 500 per annum. This is the main challenge
facing the Council. We consider the pressures for other forms of development to be less significant
overall.
Meeting this identified need in the form of sustainable development is a fundamental requirement
of the development plan process, and as such, requires that social and environmental
considerations are fully acknowledged, especially in relation to social, community and physical
infrastructure.

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?
«No response»

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
Yes. Current Government guidance is clear. Councils can only amend Green Belt boundaries as
part of the preparation of a local plan and only if there are exceptional circumstances, although
there is no definition of this and it is left to each local authority to have regard to the specific
circumstances applicable to its administrative area subject to the Duty to Co-operate. Paragraph
84 of the NPPF advises that “when drawing up or reviewing Green Belt boundaries local planning
authorities should take account of the need to promote sustainable patterns of development”.
However, we note that in the recently published Housing White Paper (February 2017), the
Government has signalled that policy in relation to the Green Belt is to be amended and added to.
It advises that “authorities should only amend Green Belt boundaries only when they can
demonstrate that they have examined fully all other reasonable options for meeting their identified
development requirements, including;
- making effective use of suitable brownfield sites and the opportunities offered by estate
regeneration;
- the potential offered by land which is currently underused, including surplus public sector land
where appropriate;
- optimising the proposed density of development; and
- exploring whether other authorities can help to meet some of the identified development
requirement.”
It adds that “where land is removed from the Green Belt, local policies should require the impact
to be offset by compensatory improvements to the environmental quality or accessibility of
remaining Green Belt land”. It is suggested also that consideration will be given as to “whether
higher contributions can be collected from development as a consequence of land being released
from the Green Belt”.
On the basis the planned changes to the NPPF will overlap with the Council’s ongoing preparation
of the Local Plan, it is essential that the Council has proper regard to the likely ‘direction of travel
of policy’, although it has to be acknowledged that this is not yet policy and there may be further
changes. However, it would seem prudent to respond to the questions relating to Green Belt
reviews set out at paragraphs 1.38 and 1.39.
The Council’s response on this matter will form an important part of the preparation of the Local
Plan and we reserve BGL’s position to comment further once the Council has published details of
its approach.
In terms of the work that has been completed to support the current exercise, we note that as part
of its consideration of sustainable patterns of spatial development in the Borough, and mindful of
competing development pressures, we contend that the Council’s open-minded approach to
consideration of Green Belt land and boundaries is a sensible one. Consideration of land where
the designation is weakest, in sustainable locations and on land not affected by absolute
constraints, is a robust approach.
Moreover, the approach taken to release land for development at appropriate densities,
appropriately respects the character of Elmbridge.
We contend that given the pressures for development and constraints, the Council would have
been criticised for not undertaking such a review. However it will be important for the Council to
respond to the matters set out in the Housing White Paper at paragraphs 1.38/1.39 so that if these
are brought forward in a revised version of the NPPF, the Council will be able to save time in the
production of the Local Plan because it will already have considered and evidenced these.
Based on the identified needs, development constraints and challenges, and the findings of the
Green Belt review, we consider that the Council has demonstrated that exceptional circumstances
exist to support the suggested amendment(s) to the Green Belt boundary.
It is important that the Council provides a response to the points contained in the Housing White
Paper to provide robust justification for the review to form part of the ongoing preparation of the
Council’s spatial development strategy in the Local Plan.

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
Our comments relate only to Local Area 20 and we have no comment on Areas 14 and 58.
In principle, we agree that the proposed release of land to the south of the A3 – Parcel 20 – is
appropriate for removal from the Green Belt. Positioned on the edge of Cobham and close to the
town centre and well related to existing community and social facilities, we consider this to be a
sustainable location for development. There are a number of planning permissions that relate to
the construction of additional facilities on the site and therefore part of it falls to be defined as
previously developed land (2000/0492.
We contend that the planned growth of a settlement is one of the most sustainable patterns of
development and this is acknowledged at paragraph 52 of the NPPF, where it states “the supply
of new homes can sometimes be best achieved through planning for larger scale development,
such as new settlements or extensions to existing villages and towns that follow the principles of
Garden Cities” (our emphasis).
As part of the Green Belt Review, this area has was assessed by Arup and it found that it no longer
meets the purposes of retaining land within the Green Belt. We agree with this conclusion which
reflects the opening of the A3 which has brought about a fundamental change in the character and
role of the land. If released, a defined boundary would be set using the alignment of the new A3
and this is readily recognisable and would be permanent.
We also agree with the Sustainability Assessment (SA) undertaken by the Council which scored
Option 2 (where the Green Belt designation is at its weakest, the areas are in sustainable locations
and the areas are not, or are only partially, affected by absolute constraints) as the best option (+6)
upon testing against the 16 SA objectives.

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
The land at Chippings Farm is in single ownership. In total, it extends to approximately 23 hectares
(ha).
Having regard to the guidance at paragraph 47 of the NPPF regarding the identification of
‘developable’ sites in a Local Plan, within Local Area 20, Plot 2 / Chippings Farm is:
Available – as noted, the land is in single ownership and there are no land ownership constraints
to development, and the landowner has confirmed a willingness for the land to be developed for
housing.
Suitable – it is considered that the site is suitable for housing development as a sustainable urban
extension to Cobham. It has housing on two of its sides and it is an obvious infill, with the new A3
forming a permanent and recognisable boundary to Cobham at this point.
Achievable – there are no site specific physical or environmental constraints and it could be brought
forward and delivered within 5 years.
Viable – development of the site for a mix of housing types is viable.
It is therefore suggested that Chippings Farm could be considered for future development.
It is also important to note that should Chippings Farm be removed from the Green Belt and the
proposed change to the NPPF be made requiring compensation to be made to other Green Belt
land, BGL may be able to provide environmental enhancements or wider public access. This is a
matter for further discussion with the Council.

8

Do you consider that other areas of land should be removed from the Green Belt including those that are moderately or strongly performing?

 

  • Yes
  • No
  • Don’t know

Please explain your answer
The exercise that the Council has undertaken and the findings of Arup’s analysis is robust. As
such, the removal of other areas from within the Green Belt would not be justified.

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
Yes. The Council’s SHMA demonstrates a requirement for more balance in terms of the size of
new homes being built, and specifically that there has been too much focus on the delivery of larger
homes.

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
Whilst we do agree that the delivery of homes with 4 or more bedrooms should be limited, there will
always remain a need for such sizes of housing, especially as part of larger strategic sites. It is
important that policies seek an appropriate mix of all types of housing and a prohibition on larger
units would be unhelpful.

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
This is a sensible approach to increasing densities in appropriate locations that reflect local
circumstances without harming the character of locations.

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
It is possible that the site could be developed at a density higher than 40 dwellings per hectare,
however this will have to be subject to further testing, in particular around a character and
landscape assessment, and also transport.

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
As noted, the greatest housing need is for the provision of mainly smaller units and this is likely
to result in higher densities of development on any parcel of land or site. Moreover, developing
at lower densities will increase the land that is required for development and would not be an
efficient use of 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
Yes. It is acknowledged at paragraph 3.15 that Elmbridge has one of the worst levels of
affordability in the country coupled with an under supply of affordable homes. The approach that the Council is proposing to take to secure affordable housing contributions is robust and flexible
because it allows for the specific circumstances of a site to be considered.

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
Please see response to Question 10.

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
«No response»

17

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

«No response»

18

Do you think that there are any exceptional circumstances that would support the amendment of the Green Belt boundary at Brooklands to support the further development of employment uses at this site?

 

  • Yes
  • No
  • Don't Know

Please explain your answer
«No response»

19

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

«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
«No response»

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
«No response»

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
«No response»

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
«No response»

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
The requirements of Policy CS13 and DM21 are noted and these clearly set out the
Council’s position in respect of the provision of SANGs. The amount and location of
SANGs is a matter for further consideration as part of this process.

24

Do you agree that our strategic and pro-active approach to supporting our heritage assets is appropriate?

  • Yes, I agree
  • No, I disagree
  • I don't know

Please explain your answer
«No response»

25

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

«No response»

26

Do you agree that the Council’s current approach to considering design and character is appropriate?

  • Yes
  • No
  • Don't Know

Please explain your answer
«No response»

27

If not what approach do you think we should take?

«No response»

28

Should we look at including a policy providing more detailed advice on what is required to limit the cumulative impact of small scale development on flood risk?

  • Yes
  • No
  • Don't Know

Please explain your answer
«No response»

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?

In order for development at these locations to be sustainable, the developments need to provide all
of the essential services that the development will generate a need for. The essential items are
schooling at all levels, and all appropriate medical facilities.

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.

 

«No response»

34. Files

«No files»