View Response

Response Details

Response Details
From Deleted User
Agent Deleted User
Date Started: 21 Mar 2017 14:53. Last modified: 28 Jun 2017 16:50
Status Complete
Response ID #529896

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?
On behalf of Redrow Homes and its interest at Kempton Park, Sunbury on Thames, in Spelthorne Borough, we would like to take this opportunity to submit comments to Elmbridge Borough Council's consultation on the Local Plan:
Strategic Options document. The comments are made with particular reference to the relationships of Housing Market Areas (HMA) in north Surrey and options relating to a coordinated approach between Elmbridge and Spelthorne regarding the provision of new homes against objectively assessed housing needs (OAN), generally covered by the Duty to Cooperate

Kempton Park
Redrow Homes is currently promoting land at Kempton Park for a residential led development through Spelthorne Borough Council's Local Plan process. On 10 January 2017 Redrow submitted land at Kempton Park to Spelthorne's call for sites exercise. The submission covered the entirety of the land at Kempton Park, including the operational areas of the racecourse and other associated buildings,
offering the opportunity to use previously developed land whilst acknowledging that not all of the site would be developed and that there would also be an opportunity to retain a significant area of undeveloped land within the Green Belt.

The total gross developable area now stands at approximately 230 acres and Redrow's initial capacity studies indicate that the site could provide for circa 3,000 new homes. Jockey Club Racecourses Ltd fully supports this move as an enabling measure, facilitating comprehensive re-investment in its other UK racing facilities for the
betterment of the horseracing industry. Jockey Club Racecourses Ltd remains committed to investing in racing in Surrey, including a major boost to the facilities. at nearby Sandown Park in Elmbridge. Please note that this representation is not submitted on behalf of the Jockey Club Racecourses Ltd and its interest at Sandown Park racecourse.

As background, sites in Spelthorne with planning permission, allocated in the Site Allocation DPD (2009) or identified as contributing to housing supply in the Housing Land Availability Assessment (HLAA 2008 (2014 update)) provide for less than 1,350 new homes. Recent housing completion rates within the Borough hover around 200 dwellings per annum, whilst the OAN is in excess of
552 dpa. The Kempton Park site is the largest known reasonable alternative in the borough that is being promoted for residential development. It lies adjacent to a train station and benefits from good links to the strategic highway network. The site is not publically accessible and is of low environmental value. There are no other large vacant / available sites in the borough where a known development interest for residential use has existed.

Duty to Cooperate
Spelthorne and Runnymede's Strategic Housing Market Assessment (November 2015) reveals that there is a series of inter-connected local housing markets in north Surrey and it is therefore good practice for the Councils to work alongside, "their neighbouring authorities (particularly Elmbridge, Hounslow and Woking) to better understand the issues and seek to coordinate activities".

Spelthorne is delaying progress with its local plan, having only just undertaken the call for sites, and is not therefore seeking currently to address its OAN of 552 – 757 new homes a year over the 2013-33 (contrary to the NPPF). We note that Elmbridge is similarly constrained (as Spelthorne) by Green Belt. We are concerned that, despite the opportunity that exits, Spelthorne will use its delayed
process to avoid positive discussion with Elmbridge regarding the opportunities for development which will, inevitably, reflect on Elmbridge when the local plan inspector considers the matter of Duty to Cooperate. Delay is not justification in itself for the matter to be set aside.

First, any emerging spatial strategy in the Elmbridge Local Plan should seek to meet the OAN for housing in full, to significantly boost the supply of housing, as required by NPPF Paragraph 47. Table 28 in the Alternative Development Options report (September 2016), reveals the anticipated supply of new homes, which would result from pursuing a strategy that broadly aligns with the Council's preferred Option 2 would provide 5,513-6,253 new homes, which would not meet the OAN of 9,480 new homes between 2015 and 2035 as
identified in the Kingston and North Surrey SHMA (2016). All reasonable alternatives for delivering sustainable development that are capable of significantly increasing the supply of housing in the borough, helping Elmbridge meet its OAN in full, should be considered. The failure of the Local Plan to try and meet the OAN in full, if reasonable alternatives have not been provided for, is contrary to the plan making requirements outlined at NPPF Paragraph 182 and
would ultimately result in the local plan being found unsound at examination.

In this context, we fully support the Council's approach to undertaking a Green Belt Review and determining that exceptional circumstances exist in the borough to remove land from the Green Belt, specifically that land which preforms poorly against the five purposes the purposes of the Green Belt, and allocate it for housing. This is given the significant shortfall that would arise if reliance is placed solely on previously developed land to meet needs. This approach is fully
compliant with national policy, including the provisions at NPPF paragraphs 14 and 83 (acknowledging NPPF footnote 9).

We also support the Council's commitment to contacting authorities with linkages to the Elmbridge housing market area, including Spelthorne, to enquire whether they would be able to meet some of Elmbridge's unmet housing need but only as a last resort. This should be supported by a robust testing of available and suitable land in those authorities, where it is capable of contributing to sustainable patterns of development. The outcomes of this engagement through the Duty to Cooperate should be clearly articulated in the next stage of the Local Plan.

The importance of ensuring meaningful engagement, through the duty to cooperate, in addressing unmet housing need elsewhere has been highlighted in the Housing White Paper that was published on 7 February. Paragraph 1.9 emphasises that where an authority has demonstrated that it is unable to meet all of its housing requirement, it must, through the duty to cooperate, "be able to work constructively with neighbouring authorities on how best to address the remainder". Importantly, the Government notes that this cross boundary collaboration has not been successful in some parts of the country and are proposing changes to the NPPF that Statements of Common Ground that are prepared between authorities explicitly set out, "how they will work together to meet housing requirements and other issues that cut across authority boundaries".

Importantly, examining whether Spelthorne can help meet some of Elmbridge's identified housing requirement, will help Elmbridge demonstrate that they have examined fully all other reasonable options and determined that they should amend Green Belt boundaries. This will help satisfy the proposed amendments to national policy, as set out at paragraph 1.39 in the White Paper.

Given the above, we strongly object to Option 3, which would seek to deliver development needs of the borough in full and explore opportunities to meet needs of other boroughs and districts without first understanding from those authorities that seeking to rely on Elmbridge through the Duty to Cooperate should be a last resort and they should actively and positively take the steps that Elmbridge has before this option is pursued i.e. to review Green Belt within their
own districts. Clearly we acknowledge the legal duties to cooperate, but these should only come into play if an authority has fully tested its options, through positive planning, and cannot meets its own needs within its own boundaries in accordance with NPPF paragraph 14. Spelthorne has not gone through this process and there would be a number of risks associated with pursuing this option. Principally, that it could reduce the contribution towards sustainable development within Spelthorne, including potentially the release of higher
performing areas of Green Belt within Elmbridge as opposed to land within Spelthorne.

For these reasons we would urge you to reject Option 3 and would welcome the opportunity to discuss with you the capacity at Kempton Park, if you felt that this would be helpful to your progression of the evidence base for your local plan. We trust that these comments have been useful and please do not hesitate to contact to me on should wish to discuss any element of the promotion of land at Kempton Park.

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 response»

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 response»

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.

 

«No response»

34. Files

«No files»