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Response Details

Response Details
From Woolf Bond Planning (strvwn Brown)
Date Started: 21 Mar 2017 15:42. Last modified: 23 Mar 2017 08:49
Status Complete
Response ID #529912

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?
See covering letter.

We endorse the spatial strategy advocated by the Council in selecting Option 2, which provides for a proactive and positive stance to ensuring that an appropriate range of sites is identified in seeking to ensure a flexible and responsive supply of land in helping to meet identified housing needs. Accordingly, as part of the site selection criteria, we are broadly supportive of the approach towards the Green Belt release strategy, which identifies some sites for release.

However, in paragraph 3.10 the Council acknowledges that this strategy will not meet the housing needs in full and that some of the development may need to be located in less sustainable locations. Furthermore, the Council would have to rely on other Local Planning Authorities to meet residual housing needs. We are of the view that the Council should be seeking to maximize the development potential of sites such as that afforded by the subject site in helping to meet the
Objectively Assessed Need.

Five Year Housing Land Supply In the context of the five-year housing land supply position, we note the latest Land Availability
Assessment from September 2016 ("LAA") concludes that "the Council is not able to identify sufficient land to meet its housing need in accordance with the National Planning Policy Framework (NPPF)" (paragraph 6.1.1 0 of the LAA).

Accordingly, we support the early release of proposed housing allocations in order to maintain a continuous five-year supply of deliverable housing land as well as further assessment of potential
sites currently located in the Green Belt.

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
See covering letter

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
See covering letter.

Plans and particulars are enclosed in support of the proposed Green Belt release and allocation of land to the rear (east) of Claygate House, Littleworth Road, Claygate, Esher,Surrey as follows:
i. Duly completed Response Form
ii. Location Plan 16322/C07B (OSP)
iii. Site Constraints Plan 16322/COBD (OSP)
iv. Illustrative Block Plan 16322/C09C (OSP)
v. Landscape Statement No. CSN3230/01 C (CSA) (February 2017)
vi. Flood Risk and Drainage Strategy Note 035678 (Buro Happold) (February 2017)
vii. Preliminary Transport Appraisal (Motion) (February 2017)

Footnote 1 - Forming part of Area 45 as defined in the Council's Green Belt Study.

Our clients own the circa 4ha site edged red on Local Plan No. 16322/C07B, comprising the land and buildings associated with Claygate House. As shown on the Local Plan Proposals Map, the
western part comprising Claygate House is within the defined settlement area, whilst the land to the rear (east) which includes hardstanding areas and private land is currently within the Green
Belt. This boundary is clearly shown on Plan no. 16322/C09C.

The supporting plans and particulars confirm the suitability of releasing land to the rear (east) of Claygate House from the Green Belt to provide for a development of circa 77 dwellings (Plan
16322/C09C refers). In addition, the land forming the western part of the site (the non-Green Belt part) also has potential as a future development site. It has already been identified by the Council in is Housing Land Availability Document (Sept 2016) as being suitable for approximately 55 dwellings.

Given the findings in the supporting Landscape Statement that the eastern part of the site performs a weak Green Belt function, and is better related to the surrounding urban character, there is a strong planning case to support the release of the land from the Green Belt to provide for an allocation of circa 77 dwellings.

General
As summarised above, our clients have a controlling interest in land at Claygate House which is edged red on 16322/C07B attached and extends to approximately 4ha. It comprises several buildings, extensive hardsurfacing, car parking areas and ancillary land.

Approximately 2.4ha of the site to the rear (east) of Claygate House is currently located within the Green Belt. This is clearly shown on the accompanying plans; and it is this part of the site that we are promoting for development in response to the spatial options consultation. However, the western part of the site, within the defined settlement area (and not subject to Green Belt policy), is also available for development and could come forward as part of a future scheme. This redevelopment potential has already been identified by the Council, with Claygate House (the building) included in the Council's Land Availability Assessment (Sept 2016) for 55 dwellings.

On the basis of our technical appraisal, we are of the view that the 2.4ha Green Belt part of the site (comprising the land to the rear (east) of Claygate House) could accommodate approximately
77 dwellings together with associated landscaping and a means of access from Littleworth Road and/or Raleigh Drive. Illustrative Block Plan 16322/C09C is attached which shows how the site could be developed following a review of the Green Belt.

The accompanying plans and particulars have been prepared to show the suitability of releasing the land to the rear (east) of Claygate House from the Green Belt and providing for a development
of circa 77 dwellings.

There are two separate areas of the site with various development options to be considered. For the purpose of this document, and for the avoidance of doubt, it is principally the eastern part of
the site, which is located in the Green Belt, and extending to approximately 2.4 ha that is promoted for development through this spatial options consultation through a review of the Green Belt
boundary.

Access and Sustainability Technical Note
The Claygate House site has two points of access from Littleworth Road to the west; and a pedestrian/cycle link to the south.

The accompanying Transport Appraisal prepared by Motion considers the potential to create a vehicle access from Raleigh Drive/Rythe Road to the south of the site.

The Technical Note identifies that the site is located within walking distance from local services and facilities, including bus services. The train station and local amenities in Claygate are within 750m (paragraph 2.19 refers) which is a mere 1 0-minute walk from the centre of the site. Bus route K3 also serves the site with the nearest bus stop on Milbourne Lane, which is located circa 300m south of the site. The route provides local service between Esher High Street and
Roehampton Vale, stopping at several train stations and with direct connections to Central London.

The existing access serving the office buildings on site is from Littleworth Road. In order to access the remaining part of the site, considerations have been given to the provision of an additional access point from Raleigh Drive to the south of the site. The existing priority junction in this location operates with Raleigh Drive and Loseberry Road having priority over Rythe Road which gives way. This arrangement is illustrated in the appendix A of the Technical Note.

The fourth arm on this junction could be created to allow for access to land proposed to be released from the Green Belt (to the rear (east) of Claygate House). The potential of the existing pedestrian access to be converted into a vehicular access is deemed appropriate and feasible. A proposed mini-roundabout arrangement is included in appendix B of the Technical Note, while the appendix C shows a potential arrangement for a crossroads arrangement of the junction. Both options include the provision of pedestrian footpath.

To conclude, the site location is such that journeys by sustainable modes would be an attractive option to residents travelling to local facilities, or by public transport to other destinations for employment or leisure opportunities. Appropriate vehicular access can be achieved by providing a new access road into the site from Raleigh Drive to the south.

In accessibility terms, it is concluded that the site affords a sustainable development opportunity for housing development.

Flood Risk Assessment
The accompanying Technical Note prepared by Buro Happold has assesses the development potential of the Green Belt site to the rear (east) of Claygate House in relation to flood and drainage considerations.

The eastern part of the site currently within the Green Belt, to which the supporting plans and particulars principally relate, extends to approximately 2.4ha and is located within Flood Zone 1.

There is some potential for surface water flooding according the Environmental Agency water flood map, although this can be mitigated by the introduction of a suitable sustainable drainage
strategy which would also result in the minimising of the surface water flooding of the neighbouring properties.

Landscape. Visual and Green Belt Assessment
The Landscape Assessment prepared by GSA and submitted in support of this representation assesses the suitability of the 2.4ha part of the site currently within the Green Belt as having an overall medium to low landscape quality, sensitivity and value, owing to its partially developed nature and proximity to existing housing, and containment from the wider landscape to the north.

This is also supported by the Councils assessment in that it is identified in their study as forming part of Area no. 45 (The Appendix 4 - Green Belt Boundary Review Parcels - Absolute Constraints Assessment) This concluded: "the area meets the Purpose 3 weakly due to the fragmented nature of the Green Belt and the prevalence of man-made/industrial uses, in particular in the western section of the Strategic Area".

Although not specifying the Claygate House site directly, the assessment of the area refers directly to the private (now principally redundant) private open space area which is located to the rear (east) of Claygate House.

In terms of assessing the contribution to the Green Belt, the Landscape Assessment notes that the current Green Belt boundary crosses the site in an irregular and arbitrary manner, including
parts of the existing car park, the tennis court, bowls green and swimming pool. It is added that development of the site would be well contained and would allow the Green Belt boundary to be redefined along the northern boundary of the site with hedgerow and line of mature trees creating a much stronger and more defensible boundary.

The settlements of Claygate and Esher have already coalesced and development of the site
would infill land within the built up area, whilst maintaining the separation between these
settlements to the north. In this respect, the development of the site would infill partially developed
land without resulting in an extension of the settlement, and would further reinforce the logical
and natural Green Belt boundary.
An appropriately designed development would integrate well with the existing settlement edge
and would not adversely impact upon the settlement edge nor would it conflict with the five
purposes of the Green Belt as set out at paragraph 80 of the NPPF.

In the context of the Green Belt tests set out in the NPPF (Para 80 refers), development of the
site for housing would be acceptable having regard to the five Green Belt purposes as follows:
• It would not result in unrestricted sprawl of large built-up areas;
• It would not lead to coalescence;
• It would prevent more peripheral countryside locations from encroachment; and could
strengthen the Green Belt Boundary
• There is no "special" character to be preserved; and
• It would provide for a mix of deliverable homes, including helping to meet the need to
supply family sized dwellings to meet identified needs to complement higher density
schemes for flatted forms of development on previously developed land within urban
locations.

The Landscape Assessment report concludes that a sensitively designed development could
contribute to delivering housing numbers without any significant landscape and visual effects,
subject to removal of the eastern part of the site from the Green Belt.

Indicative Masterplan
The submitted Site Constraints Plan (Ref. 16322/COSD) indicates the extent of Flood Zones
across the wider site. The majority of the Flood Zone 1 area, and this least constrained part of
the site, comprises the eastern land parcel the subject of our representations seeking the removal
of the land from the Green Belt.
Illustrative Block Plan 16322/C09C identifies that the eastern land parcel could be developed for
approximately 77 dwellings, with access from Raleigh Drive to the south and a landscaped buffer
to the north and thus reinforcing the urban edge and creating definition for the wider Green Belt
beyond.
The scheme can provide for a range of dwelling types and tenures in order to meet identified
housing needs, including affordable housing.

To conclude, the land at Claygate House is located in a sustainable location and its allocation for
housing development following a review of the Green Belt boundaries (in so far as it applies to
Area 45) is supported by the accompanying technical studies. Moreover, the land is surrounded
by existing development on its eastern, southern and western boundary and therefore the infill
development of the site would represent a more logical settlement boundary without affecting the
character and openness of the existing Green Belt or unnecessary coalescence of settlements.

Against the above background, including on the basis of the Council's evidence base2, there are
no known constraints to releasing the eastern land parcel (to the rear of Claygate House) from
the Green Belt as a housing allocation for approximately 77 dwellings in helping to meet identified
housing needs during the early part of the plan period (following a review of the Green Belt
boundaries). In addition, the opportunity also exists to facilitate the early development of the
western part of the site either as a planning application and/or as an allocation (given the Council's
assessment of this part of the site in its Housing Land Availability Assessment (Sept 2016) as
being suitable for 55 dwellings).
On the basis of the foregoing, the entirety of the 4ha site is available and suitable, whilst
development is achievable within the current five-year period - subject to the release of the
eastern land parcel from the Green Belt.

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
See covering letter.

The key feature of the urban area in Elmbridge is the relatively low-density character within many of its settlements according to the paragraph 2.2 of the Elmbridge Local Plan: Strategic Options
Consultation (Reg 18) from December 2016.

At the same time the Land Availability Assessment form September 2016 identifies that due to the Borough's location within the Green Belt the amount of land available for development is constricted. Consequently, both of the documents highlight the high demand for property in the Borough and increasingly deepening affordability issues.

While we fully support increasing of density in urban areas, there remains an opportunity to allocate suitable and sustainable sites, such as Claygate House and its land to the rear (east), for housing development. This will help to deliver a broad mix of housing to complement higher density flatted schemes elsewhere in the Borough.

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
See covering letter.

The key feature of the urban area in Elmbridge is the relatively low-density character within many of its settlements according to the paragraph 2.2 of the Elmbridge Local Plan: Strategic Options
Consultation (Reg 18) from December 2016.

At the same time the Land Availability Assessment form September 2016 identifies that due to the Borough's location within the Green Belt the amount of land available for development is constricted. Consequently, both of the documents highlight the high demand for property in the Borough and increasingly deepening affordability issues.

While we fully support increasing of density in urban areas, there remains an opportunity to allocate suitable and sustainable sites, such as Claygate House and its land to the rear (east), for housing development. This will help to deliver a broad mix of housing to complement higher density flatted schemes elsewhere in the Borough.

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 covering letter.

The key feature of the urban area in Elmbridge is the relatively low-density character within many of its settlements according to the paragraph 2.2 of the Elmbridge Local Plan: Strategic Options
Consultation (Reg 18) from December 2016.

At the same time the Land Availability Assessment form September 2016 identifies that due to the Borough's location within the Green Belt the amount of land available for development is constricted. Consequently, both of the documents highlight the high demand for property in the Borough and increasingly deepening affordability issues.

While we fully support increasing of density in urban areas, there remains an opportunity to allocate suitable and sustainable sites, such as Claygate House and its land to the rear (east), for housing development. This will help to deliver a broad mix of housing to complement higher density flatted schemes elsewhere in the Borough.

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
See covering letter.

Policy CS21 is concerned with the affordable housing thresholds. The policy requires on-site provision on development of 5 or more dwellings and financial contributions of 20 percent of the gross number of dwellings on sites of 1 to 4 dwellings. This policy is in direct conflict with the current national planning guidance.

The Elmbridge Local Plan: Strategic Options Consultation (Reg 18) seeks to explain why Policy CS21 will remain part of the new Plan. It states that "in terms of the type of site coming forward for development in the Borough 91 % of current applications providing an increase in new homes are on sites of 10 or fewer units" (para 4.13). At the same time, only three key strategic areas within the Green Belt are considered for removal from the Green Belt (para 3.20). We would therefore urge the Council to reconsider designation of sites such as Claygate House and its land to the rear (east) of Claygate House, which can deliver a substantial amount of affordable housing while maintaining and supporting the functional and defensible Green Belt boundary.

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
See covering letter

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.

 

We trust the above comments are of assistance in producing a revised version of the Local Plan for a subsequent Regulation 19 consultation and we await confirmation of receipt of our representations in due course.

We welcome the opportunity to meet with you in order to discuss the suitability of the site as a housing allocation, including in relation to the masterplan approach, the detailed policy wording to be included in the next iteration of the local Plan as well as any phasing matters in terms of
releasing the site for development you may wish to discuss.