View Response

Response Details

Response Details
From Save Cobham Green Belt (Keith…
Date Started: 21 Mar 2017 11:46. Last modified: 21 Mar 2017 11:46
Status Complete
Response ID #529799

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
«No response»

2

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

 

  • Yes
  • No
  • Don’t know

Please explain your answer
«No response»

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
«No response»

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?
Savecobhamgreenbelt does not consider that Option 2 is the appropriate as it is fundamentally 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 impossible and unrealistic options. The whole so called ‘consultation’ document is flawed and the subsequent questions are highly ‘loaded’. This proposal and documentation should never have been presented to the Residents of Elmbridge and the Council should insist on Arup repaying the £30,000+ in fees, due to it’s flawed methodology and analysis. Also, the Council must take some responsibility in the manner in which this piece of Consultancy work was briefed in Arup. In our opinion and the opinion of consultancy experts and some Councillors, the information provided to Arup was woefully wrong, steering them towards the conclusions they reached in respect to Weakly performing Parcels. Quite a coincidence they came up with three large Parcels of land, mainly owned by Developers and the Council whose scoring against the 5 Purposes of Green Belt were inconsistent with the rest of their scoring methodology. Residents could be forgiven in our opinion for thinking the consultants delivered what those who commissioned them were seeking to achieve ie Large areas of potential developable land for social/affordable housing with no regards for ‘Sustainability’. 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 dph or seven storeys high development. This option is clearly a non-starter and frankly we are surprised the Council has even considered putting it forward for consultation. However, the Council should have considered a more detailed analysis of the Urban spaces and shown what could realistically be obtained from developing these areas in a sustainable way. This work has not been done and needs doing. This should have been the Council’s starting principles. The council is aware of the forthcoming mandatory requirement to compile a register of all Brown field sites. Surely this should have been done in parallel with the ARUP work to provide a balanced view of potential solutions. Throughout the consultation work Elmbridge Council have continued to let site after site be developed for the wrong types of housing. Take areas such as behind Cobham high street, Oxshott below the high street, Holly Parade, the Ministry of Defence site towards Byfleet. Quite shocking that these and other Urban sites have been used for luxury housing whilst this plan has been put forward to destroy our Green Belt! Surrey Advertiser today has a front page story about the Stompound Lane planning application (comments are open re 2017/0080). This is for 54 homes on land in Walton sold by EBC to fund the controversial sports centre project. This comprises 32 five-bedroom homes, 9 three-bedroom homes, 2 two-bedroom homes and 11 one or two bedroom apartments. How 56% of all homes built will ever be social is beyond us. How can EBC ever possibly get to 70% soial/affordable when day after day they pass planning permission for when 60% - 100% 5bed houses! EBC have created their own problem, which they are now trying to unfairly land on Residents for 20 years of poor management of the new housing stock! For three years the Council have sat on a plan from Councillor Bennison to build above car parks, however the Leader of the Council last night explained that he was not aware of the details. Quite shocking! EBC have chosen to ignore solutions for far too long. Option 3 is 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 or 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. Once the Green Belt status is lifted the flood gates open and Elmbridge Council become Judge and Jury. In all likely hood the wrong houses will be built in the wrong places and Developers will win the day again and those in real need, will loose out to the commercial gains of others. Option 2 - 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 strongly 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. No consideration has been made in respect to Bordering Borough’s. A plan to build two thousand homes at the Wisley site is with a couple of miles of Cobham town centre!! Other bordering Councils such as Woking also have proposals to build on land within meters of Elmbridge. Mole Valley has just done so at Randell’s lane. It appears all Borough’s are targeting their far borders, which in essence hits the other Borough’s as much if not more, than their own. Wisley which is actually Horsley, next to the Black Swan pub will flood Cobham with thousands of new Residents. No consideration has been made of the Cobham Free School which will open next summer. 1200 new pupils will arrive at this site which is at the top of the Fairmile Road and Portsmouth road. Incredibly, this school has been positioned within a very short walk of the American Community School. From a road and infrastructure this is madness. On top of this Parcel 20 is within meters of both the existing school and the New one!! Parcel 14 is with a mile of this. Where does the word Sustainability come into play!? We also strongly question the possible required housing numbers. Other Borough’s have pushed their original numbers down significantly, however there is no evidence that Elmbridge has done this or that the number is correct especially considering employment in the Borough, movement into the Borough and Brexit. In all likelihood the number is hugely inflated and other more specialist Bodies are commenting on this. We will outline are reasons for considering that Parcel 14 is 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 Option 1 and 3). What we suggest is that still more emphasis be placed on the URBAN areas. There are daily examples around Cobham and elsewhere where the Council has chosen to totally disregard these opportunities. 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 and creativity, something ignored by the Council so far.

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.” Savecobhamgreenbelt 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. If there ever was to be, it needs to be conducted on a ‘Sustainability’ platform and NOT on so called Weakly performing. The Community should be able to work with the Council to identify any appropriate areas with the agreement of the local community in a Local Plan. 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. 20% below the Cobham average would not be affordable in anyone’s eyes. 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. Land prices around Cobham/Oxshott in particular are so high that this would preclude most Social housing. Several Developers have fed back that there would not be any social housing in their plans, even if they were to start off negotiations saying there would be. Once the Green Belt is lifted then Developers could do as they have done for the last twenty years ie Build expensive luxury homes and that is precisely what then intend doing! (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. Elmbridge have created the problem which it and residents are now facing into. 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 and we strongly argue that the above shows that the Government not too.

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
NO Savecobhamgreenbelt 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 Parcel 14 should not 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 very strong 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. It appears that the scoring system has been rigged to come up with three large Parcels. 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 of Parcel 14, we feel they are unfairly undervalued by the scoring created by Arup. One side of Blundel lane is scored as weak and the other side separated by a lane is strongly performing. We will illustrate how ridiculous this is by providing photographs. Another key point is that the Arup report says that Parcel 14 no longer meets the Purposes of the Green Belt. We find this quite incredible as in 1980 EBC required Octagon Ltd to enter into a Section 52 agreement with the Council to give even greater protection above the Green Belt status as a condition for developing the Cargill offices on Knowle Hill Park. What has changed from the higher level of Green Belt status versus today. Allow us to explain. Elmbridge Council gave away the section 52 agreement in 2015 to Cargill’s in exchange for a payment to convert the offices to residential. In turn Millgate paid EC over £2m in exchange for not building social/affordable homes on Knowle Hill Park in 2015/16. Why did the Council legal representatives wrongly communicate this to the Resident and Heritage members six months after the Section 52 had been given away? Was the £2million pounds actually spent by EC building affordable homes? Purpose 2 To prevent neighbouring Towns merging. Stoke D’Abernon sits in between Oxshott and Cobham. The next settlements are Leatherhead and Fetcham. Apparently Stoke D’Abernon does not exist for the GBBR and therefore scored 1. Yet, many of Elmbridge Council’s reports recognises Cobham, Oxshott and Stoke D’Abernon as very separate communities! Take for example the Flood Risk Assessment reports and the 2012 Design & Character Supplementary Planning Document supplementary Guide! Stoke D’Abernon is mentioned in the Doomsday book. It has the oldest Parish in the area. SDA has a Grade 1 Church with Saxon origins and is the oldest in Surrey. An historic place that regularly brings visitors as does the walks around the Green Belt. It is the home of the world recognised music School. Woodlands Park Hotel is also of historic interest as are many of the homes. It is the Headquarters of Chelsea football club known throughout the World. It has it’s own pub, village halls and a unique and special community who care for one another. It also has it’s own Scout site, which attracts over 1500 Scouts a year, plus its own war memorials. It has it’s own lake on Parcel 14 with it’s own angling club. It has it’s own Cricket club and recreational facilities but the Arup report recognises none of this. The list goes on. The scoring by Arup of 1 against this Purpose is beyond any reasonable logic 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 on the north of Parcel 14 is largely rural as it the rest of the Parcel. In fact the Elmbridge Community report of 2102 clearly describes the area as Rural and some areas by Water Lane as Semi Rural, which is precisely what it all is! 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 possibly too low. However, even accepting this, how can Parcel 14 be scored at 2 when basically only 2.5% is built upon. Arup's criterion clearly states a score of 4 would apply for a built form of less than 5% and/or a strong unspoilt rural character - if it had both P14 would score 5 which of course it has! This in itself ‘rubbishes’ the Arup report in respect to Parcel 14. Parcel 14 is one of only three anomalies with less than 3% built upon in 70+ Parcels and scores the incorrect score of 2. This has to be amended and this point alone would move Parcel 14 into Moderate performing. We consider that with the justified amendments argued above that Parcel 14 is NOT WEAKLY PERFORMING and so there is no proven case for removal from the Green Belt. In fact is very STRONG performing Green Belt. LOCAL AREA 14 LAND NORTH OF BLUNDEL LANE, KNOWLE PARK AND FAIRMILE PARK COBHAM. ARUP has scored this area as WEAK. SCGB scores this area STRONG. Purpose 1: Fail scores 0 out of 5 SCGB PASS scores 3. Purpose 2: scores 1 out of 5. SCGB scores 4. Purpose 3: scores 2 out of 5. SCGB scores 5. 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 large 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”. The other side of the lane is scored Strong, separated by a train line and Lane! 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 is 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, like an Arup consultant. 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 new Residential apartments 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. Residents for years have asked for a foot path that will enable Residents to walk from Stoke D’Abernon to Oxshott where the local school is however this has been constantly refused and no one can therefore do so as the blind railway bridge is a major safety hazard with another disaster waiting to happen. We therefore feel that the 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 Millgate new apartment complex set within the open grounds of Knowle Park. Why would Arup possibly describe it as semi Urban is beyond us unless they were trying very hard to get to a required end result. All of the Elmbridge reports refer to it as Rural or Semi Rural as stated above. ( 2012 Community report). The only built form in the whole land parcel is the apartments and we consider the overall % of built form as described by Arup in Table 4.5 is less than 2.5% . This would score the Parcel s 5 (on Arup’s scoring ) and a 5 in the suggested CPRE revised scoring. We do not agree with Arup’s conclusion that “the countryside is highly fragmented” as there are in fact large open areas with mostly non-intrusive boundaries. 45 acres of Knowle Hill Park that up until recently had cows grazing all over it. 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 parks and horse stables fully appropriate in the Green Belt and has public footpaths around it. It also has a beautiful lake, many protected wild life species and a major Scouts facility. Parcel 14 also has many Ancient Woodlands, Common Ground and a tremendous amount of ‘Protected Species’ all over it. These include Greater crested Newts, Bats, Buzzards, Adders, Beetles, Deer have returned, Badgers to name but a few. The top of Knowle Hill is an Aquatic and Wildlife Paradise. Studies of the Greater Crested Newt Colonies have been taking place over many years and this site should now be classified as SSI. In addition, Parcel 14 now has the following factor. Millgate have declared that their 45 Acres will not be released for the any Development and have been put legally ‘in perpetuity’. The Scout Trustees have declared that their site will remain and is not for development. This therefore means that over 85% of the land is not ‘Developable’ and arguably 100% when the protected species, Ancient woodland, topography and Common land is taken in to account, not to mention the various land covenants. The Blundel lane part of Parcel 14 is also a Flood Plain and this has been conveniently missed off the Arup report! After all, it is on Knowle HILL and surrounded by WATER Lane! From a sustainability perspective Parcel 14 has an automated train barrier in the north with a main line to waterloo that closes every few minutes. Off Blundel lane it has a river and main sewage, as well as a very narrow bridge over the railway line with no pavements! Much of the land has very strict Covenants on it especially the land just off Blundel lane. 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 10 and in more probability a 12. On this basis we feel confident that Parcel 14 performs at a Strong level and any independent review would endorse this. Summary and Conclusions. - Elmbridge Council should have initially done substantially more work on the Urban and Brownfield opportunities and should not be allowing the limited luxury housing on these sites to continue - The Arup reports should never have been Briefed in the way they were - SCGB do not think any of the three Options put forward are suitable - SCGB have clear strategies as to how EC should solve the Housing needs that they have in essence created, however, the first focus has to be a far better Urban plan and Brownfield investigation - Exceptional Circumstances have not been proved - The Council does not have the support of the Local Community on Parcel 14 in particular - Arup have grossly incorrectly scored Parcel 14. It is Strongly performing and not Weak as the consultants suggest, measured against their own ARUP methodology. - Parcel 14 has over 65 hectares of land and 6 hectares of land, mainly around Knowle Hill Park was identified as potential Developable. - Millgate Homes who own 45 Acres have declared that their land is not up for Development and has been put ‘in perpetuity’ from any future building. Millgate are a highly ethical, quality and trusted housing developer and should be highly praised for their actions and conduct in this unfortunate matter. Unfortunately the same can not be said of other Developers we have encountered. - Over 85% of the available total hectares are out of play as far as any development housing is concerned and arguably 100%. - We have enclosed a map which is designed to illustrate the above point. - There has been little mention of Sustainability however the areas around Parcel 14 need substantial sustainability resources now, without any future homes. Take a walk along Water lane and you will see. Do not take any children or pets as the lorries are a major hazard! - Surrounding area has less than 8hph, how would 40-60 look? - Parcel 14 is within 20 metres of the next Parcel separated by a road. This Parcel was rightfully scored as Strongly performing. We strongly argue that these two Parcels are one and the same and should Not have been split as Arup chose to do to fulfil their Brief. - Land costs are so high that the social/affordable home model can not work which has been the case for 20 years, hence the reason there is none - Existing Urban areas would offer the Council and Residents far greater sustainable housing opportunities than any small bits of Parcel 14. Our observations and recommendations are that no Green Belt status changes should take place on this Strongly performing area. Although our focus has been on Parcel 14, in agreement with the other organisations who are opposed to the three Options, we also strongly object to any Green Belt removal until all other options have been properly explored and we like to help the Council to do that vital work. As a Community we really do recognise the challenges which Elmbridge Council are facing and would be prepared to work closely alongside them to find solutions with our energy, problem solving and motivation. Our motivation is that our children, friends and elderly need sustainable and appropriate homes. We really do care, as like the hard working Council staff, we have families and friends who need looking after, unfortunately we sincerely believe this approach via the Arup report, it’s methodologies and options should not have been done and the three Options should not have been proposed to the Residents of Elmbridge. After all, Elmbridge’s logo is ‘Bridging Communities’ and not ‘Breaking Communities!’

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
«No response»

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
«No response»

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
«No response»

11

Should we seek to increase minimum densities at sustainable locations in the urban areas, such as in town centres and at train stations, above 40 dwellings per hectare, where this would not impact on local character?

  • Yes (If yes, what density do you think would be appropriate?)
  • No
  • Don’t know

Please explain your answer
«No response»

12a

Within the three key strategic areas we will be exploring opportunities for accommodating our development needs taking into account site constraints, land ownership, compliance with other planning policies and the need to support sustainable development.  If potential housing sites are identified within these areas, do you consider it appropriate to

a. deliver at higher densities i.e. above 40 dwellings per hectare, in order to maximise delivery?

 

  • Yes
  • No
  • Don't Know

Please explain your answer
«No response»

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
«No response»

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
«No response»

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
«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
«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
«No response»

24

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

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

Please explain your answer
«No response»

25

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

«No response»

26

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

  • Yes
  • No
  • Don't Know

Please explain your answer
«No response»

27

If not what approach do you think we should take?

«No response»

28

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

  • Yes
  • No
  • Don't Know

Please explain your answer
«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?

«No response»

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.

 

SAVECOBHAMGREENBELT would collectively like to comment on the Council’s consultation on their Strategic Options Consultation. Our Group comprises of several hundred members of highly concerned Residents and Families from Stoke D’Abernon, Cobham and Oxshott and a Core Team of ten Residents. Our Team works closely with the other major Organisations who are also opposed to these proposals such as CRPE, Residents Associations, Chambers of Commerce, MP’s and Cobham Heritage. We have used most of these Groups materials and findings to input into our own findings and this report. Our Group has a particular focus on Parcel 14, just as there are other teams particularly focussed on Parcel’s 20 and 58. Therefore much of this communication will specifically focus at the top line of why we think Green Belt is not the correct solution and secondly why Parcel 14 specifically is not. Although we appreciate the difficulty that the Council finds itself in concerning the requirement to provide additional housing whilst at the same time take due regard of the Borough’s environmental and infrastructural constraints, we strongly disagree with the preliminary decisions that the Council has arrived at in opting for Option 2 and proposing the removal from the Green Belt of the three land parcels at Stoke D’Abernon , Cobham North and Long Ditton. The Green Belt is a long established successful policy that for many years has served the Borough of Elmbridge and its Residents well. It has prevented the spread of London into the Borough from the Royal Borough of Kingston upon Thames, Mole Valley and Guildford. This has enabled the many individual communities of Elmbridge to remain largely separate by preventing merging and also preventing the loss of countryside, especially in Stoke D’Abernon. So, as we get into the detail of our Case, we start with the Statement that the way in which the Arup Reports were Commissioned were Flawed from the outset, with the wrong principles, information and direction provided to the Consultants in the first instance. The results were very much in line with the Counsel’s briefing principles.