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Deleted User No, I disagree 21 Mar 2017 16:03
Deleted User • NO. There should be clear other options. Urban still has huge potential as does Brownfield.
• Option 1 is far more sensible.
• An option should be to allow the Community to come up with a Plan which as a very last resort could be taking weak performing parts of say 20 Parcels instead of asking Cobham to take the majority of the pain for total Elmbridge.
• We disagree that the provision of housing is an Exceptional Circumstance that will allow the destruction of our Green Belt and heritage
• We understand that the Council’s own figures show that only 50% of the housing planned would be needed by Elmbridge residents
• Once the Green Belt has been taken away it will NEVER be regained. This will result in encroachment of countryside and removal of green spaces
• The Council has not sufficiently explained or justified why it cannot build on brownfield land and a thorough assessment of brownfield sites and Urban should be a priority
• Increased urbanisation of the more major urban areas in the borough. The Council should seek to develop social/affordable housing near to the major sources of employment and nearer to better service provision
• Opportunities should be explored near to established fast transport links with easy transport access. An example would be the fast Woking/Walton/Esher line
• Building social/ affordable housing on Parcel 20 is very unrealistic - this is one of the most expensive parts of Elmbridge and placing social/ affordable housing in this area will not meet the needs of those folks who need easy access to job opportunities and good public transport links, neither of which exist in this area
• The Council has not demonstrated that it has sufficiently explored options with neighbouring boroughs and taken into account plans from Guildford and Mole Councils.
21 Mar 2017 16:03
Deleted User No, I disagree 21 Mar 2017 15:46
Woolf Bond Planning (strvwn Brown) Yes, I agree 21 Mar 2017 15:42
Woolf Bond Planning (strvwn Brown) 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.
21 Mar 2017 15:42
Deleted User No, I disagree 21 Mar 2017 15:00
Deleted User Statement

The Esher Residents Association do not believe that the case has been made for allowing development in the Green Belt "Weakly performing areas and we cannot support any of the three options being proposed.

The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belt are their openness and their permanence.

The recently released Government white paper appears to support this and the "Weakly Performing" category of Green Belt appears to be directly undermining this central government policy.

If Brexit means Brexit, then Green Belt is surely Green Belt and it is hard to understand how any area of it can be described as weakly performing when it has prevented the metropolitan mass from overwhelming us for so many years.

Alternative Policy

There is a need for a large increase in the housing stock of the nation and we believe this is a responsibility of central government. Government should be planning a new town or towns.

The local need for housing land could be achieved in a number of ways. Although we appreciate this will require a huge infrastructure investment in roads, schools drainage and the mitigation of air pollution.

The Association believes that Elmbridge Council should look again at the urban capacity. There maybe some areas where flats could be built one storey higher without detriment to the character of the town.

We also believe that there are low density areas where it would be acceptable to increase density by the division of large housing plots.

We understand there have been suggestions for schemes to build low cost flats above certain public car parks and increasing car parking at the same time. In some areas this may be acceptable if schemes of character could be developed.
21 Mar 2017 15:00
Deleted User 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.
21 Mar 2017 14:53
James Riley No, I disagree 21 Mar 2017 14:41
James Riley New housing is not an Exceptional Circumstance to allow Green Belt removal.
A proper detailed assessment of brownfield sites should be the first priority.
Increased urbanisation of the more major urban areas in the borough would be better.
EBC has not demonstrated any exploration with neighbouring boroughs - crucial considerations
The Green Belt Review (ARUP) report fails to set out the process clearly and fairly.
The Green Belt Review (ARUP) Purpose 3 assessments incorrectly score Parcel14 and Parcel 20 too low.
Parcel 14 and Parcel 20 would not be identified as 'Weakly Performing' if correctly scored.
Planning constraints (infrastructure, traffic, etc.) make Chippings Farm unsuited for development.

Chippings Farm/Fairmile
It is unlikely that any more affordable housing would be available for local residents.
Traffic congestion on local roads would be a problem.
Local infrastructure is already under pressure; Option 2 would make it worse.
Parcel 20 is too far from the centre for sustainable development.
21 Mar 2017 14:41
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