Response Details

Response Details
From Gill Money
Date Started: 16 Feb 2017 17:36. Last modified: 20 Feb 2017 09:45
Status Complete
Response ID #521706

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
Having lived in Elmbridge for 25years I understand the problems with there not being enough affordable housing, however the consultation document has missed other equally pressing problems to support quality of life that should be addressed before any more households are added to Elmbridge, particularly in the Cobham area. The road system can only just handle the existing traffic loadings - any more will bring it to a total halt; there aren't enough school and medical facilities and support for our existing elderly residents need upgrading. We also need to maintain the environment and avoid further pollution whether it arises from vehicles, surface water run off or overloaded waste systems. Also, Elmbridge has already stated previously that a central part of its core strategy is to protect the Green Belt and this should remain an absolute. The Consultation does not seem to take account of the value of green spaces for the recreation of local people.

2

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

 

  • Yes
  • No
  • Don’t know

Please explain your answer
We need to focus on maintaining or improving the quality of life for existing residents and making sure it is robust to survive into the future before we do anything about changing the Green Belt. A major issue is the road network which is already congested with surfaces in poor condition. Cobham High St is an area of poor air quality already, more traffic arising from additional development in the area will make this worse and spread the pollution further out of town as more traffic idles while waiting to pass through it. The recent Housing White Paper urges respect for the Green Belt as a vital resource for local communities to work as both 'green lungs' to help reduce pollution and to control the spread of developed areas. I am not convinced that enough effort has been put into finding creative ways to increase the density of housing in more urban areas so that the Green Belt can remain undisturbed. Another priority is to address the challenge of the ageing population in Elmbridge by the provision of accessible accommodation, support and facilities - this best delivered close to village/town centres where community groups, shops etc are located so residents do not have to travel far to reach them.

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
Ungumming the road network and the provision of more public transport that people will use along with the provision of support for those wishing to make short cycle journeys to the shops, work etc. We need to reduce existing pollution levels before we can consider adding extra vehicle movement into the area by offering more housing. Cobham and Stoke D'Abernon already suffer whenever the M25 or A3 are overwhelmed, adding two more large developments to the area is likely to bring it to a halt for large parts of the day whilst increasing noise and air pollution from idling vehicles. The Stoke Road is particularly vulnerable as it provides access to the station and only has one lane each way with a number of busy feeder roads emptying into it. Most mornings (including Saturday) there is a queue of traffic trying to get through Cobham High Street that extends out of the village, along the Stoke Road and often as far back as the Tilt. This queue is even longer on days when there is trouble on the M25 or A3.

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?
I strongly disagree. Option 2 is not the most appropriate option:
The proposed plans are not aligned with the Government's White Paper on housing as published on 07/02/2017. The Paper has clear intent to protect Green Belt land and expresses a preference for higher density and medium rise buildings and urban development on existing sites. EBC has not explained nor discussed other options in the supporting documentation. Options 1 and 3 appear to have been dismissed without providing much supporting evidence. I cannot see how 'Exceptional Circumstances' have been demonstrated. The scoring mechanism used to classify Green Belt land into strong, moderate and weak performing appears to be internally inconsistent. Background material suggests that over 50% of housing stock is for those who may or may not move into Elmbridge in the future based on assumptions of conditions that are rapidly changing, especially in view of Brexit and the Government's focus on reducing immigration.
The current housing density of Cobham, Oxshott and Stoke d'Abernon is approx. 9hph. To propose an increase to 60+hph is completely unrealistic and unsustainable in view of the existing infrastructure challenges. The impact on traffic congestion alone must be considered as discussed above.

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 – National Guidelines state that "unmet housing need is not a justification", I don't feel that the background material has demonstrated 'Exceptional Circumstances'. The Consultation Documents state that Green Belt boundaries should only be adjusted "with the support of local people". The Council does not have my support or that of my neighbours. The Alternative Options paper does not demonstrate that the Council has given due consideration to other options e.g. Urban intensification, working with other councils. The Housing White Paper emphasises that Councils need to have fully demonstrated all other options before exploring Green Belt land. I do not feel that Elmbridge Borough Council have demonstrated this. The Strategic Options paper has only explored 3 parcels of so called weakly performing Green Belt. The work should have been completed at a much lower granularity. Who is to say that the next levels of EBC's identified weakly performing Green Belt Parcels are not more suitable and have more developable areas?
We believe that the Council is taking the easy way out in targeting Green Belt and should re-focus on brownfield sites. Consideration should be given to ways of increasing the densities on these sites.

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
I believe that the methodology and assessment used to select these sites is subjective and flawed. The scoring and categorisation across all the parcels of land is inconsistent. I strongly disagree with Parcel 14 (Knowle Hill Park, north Blundel Lane) being included for the following reasons:
o This Green Belt currently prevents the merger of the distinctly different "neighbouring" areas of Stoke d'Abernon and Oxshott
o Cobham, Stoke d'Abernon and Oxshott are distinct communities – EBC's own Flood Risk Assessment and Design Guidelines recognise them as separate entities
o The Green Belt Review scoring is wrong – parcel 14 is only 2.5% built on and therefore should be 4 or 5 not 2.
o Description of Parcel 14 as "semi-urban" is very subjective and patently untrue – it is semi-rural.
o Description of Parcel 14 as having "weak links" to the strongly performing parcel 10 is solely due to Blundel Lane and the railway line, the areas merge visually when visited;
o Previous owners of the Knowle Hill Park area had higher protection than Green Belt (via a section 52 agreement). This was removed by the Council – there is no justification in the background materials for why this has changed
o Infrastructure, particularly local roads, would not cope
o I believe this suggesting should be subject to independent audit as insufficient weighting has been given to the points detailed below:
i. Ancient woodlands are present on Parcel 14. These should be surrounded with buffer zones and wildlife corridors
ii. The verified presence of Greater Crested Newts which are protected by both U.K. and EU legislation.
iii. It is also a natural habitat for bats, beetles, adders, buzzards, deer, hedgehogs and owls.
iv. Knowle Hill Park as its name suggests is on a hill and the presence of a flood plain at the bottom of the hill has not been recognised or scored
v. These are Absolute Constraints and need to be recognised and scored as such.
I also strongly disagree with Parcel 20 (next to Portsmouth Road, Cobham) being included for the following reasons:
o Parcel 20 acts as a vital separation between Cobham and Esher and it protects against ribbon development along the Portsmouth Road (A307)
o The Common Land and Site of Special Scientific Interest in this area must be protected
o Development on such a large scale would change the character of Cobham and damage local community cohesion as evidenced in the recently published report by The Walton Charities.
o The road infrastructure couldn't cope
o The Green Belt Review undervalues this land which has only 4.6% built structures on it. This should result in a score of 3 or 4.
o The area provides a habitat for a variety of wildlife, rare birds, six types of reptiles and insects such as the silver studded blue butterfly Plebejus argus found on the Esher common SSSI site.

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
This is the responsibility of the Council and details of further options should be provided. If the Council has not fully evaluated all the other options in these three areas it clearly must do so. EBC's approach to only detail the largest three land masses is simplistic and erroneous. The actual amount of developable land is a more relevant and critical component.

In detail: Parcel 14 (Knowle Hill Park and north of Blundel Lane, Stoke d'Abernon):

• Parcel 14 topography next to Blundel Lane is steep, flood risk and was also a landfill site – so unsuitable for development without further investment
• Parcel 14 also includes a Scout Camp widely used not just by Elmbridge but also by neighbouring boroughs including Kingston. There is a Historic memorial present
• Parcel 14 has a number of Ancient Woodlands
• Parcel 14 is home to protected animal species
• Parcel 14 has a lake at the top of it and springs around the lower levels and floods regularly
• Parcel 14 has clay work mine shafts and underground bunkers used during the Second World War

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
Urban regeneration should be the way to deal with the housing shortage and more joined up thinking and cooperation across boundaries is required in order to find an optimum solution. Elmbridge cannot deal with this issue in isolation.
• EBC has has not assessed the viability or contribution of the moderately performing sites and this oversight should be corrected
• Any plan of this complexity cannot be considered in isolation and hence I fundamentally disagree with an approach that just singles out housing, the location of jobs and transport links must all be included to create a single well planned whole
• Housing alone is NOT an exceptional circumstance to remove Green Belt and does not meet my support
• I am finding the questions in this form difficult to answer as they seem to be driving me towards only one conclusion - that three areas of Green Belt must be removed. I want to see other options discussed more openly, even if it slows the process.

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
However I believe smaller sized houses should be feasible in existing urban areas and that a more joined up thinking and cooperation across boundaries is required in order to find an optimum solution. Urban renewal and regeneration continues to be high priority and the Council should be seeking to further identify and invest in brownfield sites. Increased density in such areas will allow for the provision of smaller, more affordable homes and mixed development of combined home/studio/workshop units. We should mix homes and workplaces to reduce commuting and therefore pollution.

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
We already have plenty as confirmed in EBC's forward look study.

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
Too many site specific aspects will apply to be able to give a general answer here. Creative design must be applied in order to maximise density whilst retaining a liveable environment.

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
Parcel 14 (Knowle Hill Park and next to Blundel Lane, Stoke d’Abernon):
Because of the semi-rural nature, the topography of the land and the existing housing in the surrounding area a lower density will probably have to apply unless flats are built. It seems that the economics of building social/affordable housing in an area that is one of the most expensive in Elmbridge is unrealistic, especially as there will have to be a heavy spend to ensure that the local infrastructure of roads, mains services etc will be able to cope with the additional loads. Moving from the current 8 hpd to the proposed 40 or 60 is totally out of keeping with the current environment

Parcel 20 (next to Portsmouth Road, Cobham):
Here the road infrastructure is totally insufficient and the traffic congestion that will probably ensue is likely to adversely affect air quality in an already heavily polluted area.

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 explained earlier, I don't believe that the Green Belt should be released for housing.

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
A single simple approach to the challenge of providing sufficient affordable housing regardless of the quality of life and/or environmental impact is not appropriate. Each area is different and there needs to be some careful thinking and research behind the proposed development of each site in the Borough.

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
Improve existing sites and maximise their use before seeking others.

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
We need to ensure that there is sufficient housing for elderly and vulnerable groups to maximise churn from existing under occupied properties. We also need to try to find a way of ensuring that the families of existing Elmbridge residents have preferential treatment over incomers to the Borough.

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
Other countries manage to build very effective mixed developments where residential/retail/small businesses are alongside each other. This has many advantages in reducing travel times, improving social integration and reducing pollution.

17

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

We need to be flexible and open minded when considering mixed developments. Local employee accommodation should be offered to reduce travel needs and the resulting congestion and pollution.

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
Many people work on the commercial sites at Brooklands and surrounding areas commute through Cobham, Weybridge, the A3 and M25 - anything that can be done to reduce these journeys must be welcome.

19

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

the lack of public transport that is reliable and frequent enough to be useful and encourage people to leave their cars at home.

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
It's a good venue, but transport links need attention due to the congestion that arises when there's an event on.

21a

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

  • Yes
  • No
  • Don't Know

Please explain your answer
We should make sure that we have mixed residential/retail/small business developments, they are the norm in many other European countries and prove very successful. They are likely to draw talent into the area and help future proof it with new businesses.

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
As in Q21a, we need to look at mixing developments to encourage smaller businesses where there is capacity to 'live above the shop/workshop'. This is how towns and villages originally evolved and will reduce commuting and the resulting pollution/parking problems as well.

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
Given the state of our high streets, we need to consider flexible use of the property that's already there.

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
We need the 'green lungs' that these spaces provide to counter increasing urbanisation. The use of imaginative design around these areas should help to protect them and integrate them into the local scene.

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 Thames Basin Heaths are a tiny fragment of a landscape that is not replicated anywhere else, it is our duty to protect and enhance it.

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
These assets are part of our unique identity and need to be maintained in an appropriate surrounding environment.

25

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

These assets are part of our unique identity and need to be maintained in an appropriate surrounding environment.

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
We need more imaginative responses to the unique character of our areas when the design of new developments is considered.

27

If not what approach do you think we should take?

Local groups have many resources to offer to help planning in their areas. Creative design should be used to maximise the opportunities that exist, including commercial as well as residential.

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
The River Mole is an integral part of Cobham's surroundings and from time to time makes its presence felt by flooding. These floods often shut off access along the A245, the major Southern access to the town. Any further development in the area must consider run off and flood planning, especially as one of the parcels proposed includes part of the flood plain and will directly feed into it.

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
Congestion never seems to lessen and we still don't see that many school buses around. The Chatterbus is rarely full. How are we going to get people out of their cars and into buses/onto bikes etc? The arrival of the Free School will be a good test of EBC's policies and it's effect could be used as a case study for managing future congestion.

30

Are there other approaches we should consider?

  • Yes
  • No
  • Don't Know

Please explain your answer
Managing school traffic with out of area parking and shuttle buses? Improving cycle routes - perhaps more shared pavements where the roads are narrow and pedestrian traffic low (ie: most pavements in the Cobham area!).

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?

Current infrastructure is not fit for purpose in any of the proposed areas. We need alternative road patterns to ease congestion; school and medical facilities need upgrading with increased placement numbers available. Transportation links and associated parking will need attention, cycle routes should be provided and a footbridge over the railway on Blundel Lane all need consideration. There should be a policy to locate development by fast transport links and near job opportunities - this tends to push development back into urban areas such as Walton, but should reduce commuting and therefore congestion pressure overall.

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?

Most of the points listed above and elsewhere in this form - it would be more useful to offer a consultation on this per development proposal so that comments can be site specific and therefore more efficient.

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.

 

• The Strategic Consultation paper contains numerous flaws and inconsistencies. The methodology is subjective and flawed.
• Entire premise of the consultation rests on the requirement to build 9480 new homes. The probability of this forecast being correct needs to be understood – is it enough to remove Green Belt status forever?
• The paper has only explored 3 parcels of so called “weakly performing” land – other parcels of so called “weakly, moderately or strongly” performing may be more suitable for development e.g. nearer to higher urban areas
• No consideration is given with the proposals for the Cobham & Stoke d’Abernon proposals of access to jobs and employment. There are limited employment opportunities in the immediate area as opposed to exploring options in Walton or Weybridge
• The discussion in the options paper focusses on the economics of building lower cost housing on areas of Elmbridge (parcels 14 and 20) that are focused on high value homes. How would EBC fund the development of Social housing on such expensive sites?
• Elmbridge strategy does not support the stated EU requirement which seeks to preserve and enhance the quality of life of its residents, both current and future. In our opinion Elmbridge proposals directly contradict these EU directives, or whatever will replace them once the UK leaves the EU.
• Timing of this consultation being launched just prior to Christmas, the lack of information provided to local residents and the length and complexity of the questionnaire seem to lead to the conclusion that the Council is simply going through a process and not seriously open to any challenge from local residents
• These proposals have no regard to the size of the existing settlements where the new house building is being considered and the impact on their existing communities and infrastructure. Because Elmbridge is neither a place of being or a community in its own right, but a collection of very separate and different communities and settlements, any sensible housing strategy has to be broken down to this level and as a starting point to look at each settlement / community and assess how many additional dwellings need to be accommodated having regard to the size of that settlement to Elmbridge as a whole.
• As the whole purpose of deselecting green belt land is for meeting housing need, it is a flawed process that ignores infrastructure. Green belt land in an urban or semi urban community may be more appropriate for development where there is adequate or good infrastructure than where it is in a rural or semi rural community where there is inadequate or poor infrastructure.

34. Files

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