Places & Planning

Piers Mason Chief Planning Officer Tandridge District Council 8 Station Road East Oxted Surrey RH8 0BT

Date: 05 October 2017

Dear Mr Mason

RE: Tandridge Local Plan Garden Villages Consultation (Regulation 18)

Thank you for the opportunity to comment on your Local Plan Garden Villages Consultation (Regulation 18).

We acknowledge that the Council’s agreed Preferred Strategy (16 March 2017), under which your Local Plan will continue to be prepared, includes the identification and allocation of a garden village as the most sustainable option for future development. This reflects the limited capacity within existing settlements, and limited opportunities for extensions to existing settlements (which would in many cases be less sustainable than a new village with its provision of planned strategic infrastructure). This approach reflects the fact that 94% of Tandridge district is designated as Green Belt, and will no doubt form part of your case for exceptional circumstances justifying changes to the Green Belt boundaries.

We note that the current Regulation 18 garden villages consultation presents further evidence and information regarding four potential locations for a new garden village, but that as yet, no decision on a preferred location has been made.

Methodology We broadly agree with the approach of a garden village employed by Tandridge, which will be needed to meet its housing requirement above the capacity of the existing settlements and their limited expansions. We recognise that the selected approach to a new garden village is based on the Town and Country Planning Association’s Garden Cities guidance.

We support the methodology that you have used to date to assess potential sites for a new garden village. In summary, this has involved the application of key constraints (including AONB and areas of high flood risk), followed by a SWOT analysis of each, sustainably appraisal and landscape assessment.

We generally concur with your SWOT for the Redhill Aerodrome site, as presented in your “Spatial Approaches Topic Paper : garden villages consultation”. However, we suggest that

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Head of Service: Luci Mould, Places & Planning Town Hall, Castlefield Road, Reigate, Surrey RH2 0SH the “Strengths” be amended to “Part Brownfield / Part Greenfield Land” to reflect that much of the site is greenfield. We also suggest that Redhill is explicitly named as the “large settlement” referred to under strengths.

Duty to Co-operate regarding strategic issues and joint working

We welcome ongoing collaboration under the statutory Duty to Cooperate at all levels. We acknowledge the benefits of the Leaders, Planning Policy Portfolio Holders and Planning Officers from both of our Councils having been involved in discussions regarding the potential garden village site at Redhill Aerodrome that spans both boroughs, and we anticipate that this will continue.

Officers, relevant councillors and Council Leaders are agreed to work together to ensure that information and assessment work is shared in relation to this site. Several joint meetings have been held to date, and we appreciated the opportunity to discuss your process, timescales, and potential sites, including Redhill Aerodrome. We confirm the details relevant to Reigate & Banstead Borough Council set out in your Duty to Co-operate Statement update (August 2017), in particular at Sections 4 and Appendix A. We welcome ongoing liaison in this regard.

We would appreciate being kept up to date and involved as you progress your Local Plan as part of the ongoing requirements for Duty to Co-operate (DTC) in relation to strategic issues.

The potential site at Redhill Aerodrome straddles our boroughs. We trust that we will continue to work closely to ensure that our plans in this respect are, as far as possible, aligned and complementary. Should Redhill Aerodrome be jointly pursued to meet the longer term development needs of both authorities, our joint working would need to include agreement of timeframes for allocation of the site, and co-ordination of preparation of any join local plans.

We would like the following general and site-specific observations to be taken into account in terms of potential to achieve your stated key objectives for garden villages.

Comments on specific sites

We note that both Blindly Green and South Godstone were identified in your 2016 consultation, and that the two other currently shortlisted sites were put forward for consideration at that consultation stage.

We note that one of the other sites put forward at that stage, land at Chaldon, has since been removed, primarily on the grounds of sensitivity of landscape (being AONB and candidate AONB) and landscape impact. This site has also been promoted to RBBC and we are also considering it through our Development Management Plan (DMP) assessment work to identify safeguarded land for future development.

We recognise the need for the selected site(s) to be able to commence delivery within your current plan period (to 2033), and acknowledge that you will take potential delivery timescales into account in selecting site(s).

We note that Land west of Edenbridge is partly within Sevenoaks Borough, and have no observations to make on this site.

Redhill Aerodrome

As part of the preparation of our Regulation 19 Development Management Plan (DMP), we are assessing the planning merits of the land at Redhill Aerodrome, along with other sites, for a potential settlement to meet the borough’s longer terms development needs, beyond our current plan period (i.e. post-2027). We appreciate the sharing of assessment work across our two boroughs to date, and trust that this will continue. To date RBBC has not reached a view on whether or not the Aerodrome represents a suitable ‘safeguarded land’ location for Reigate & Banstead.

The majority of the Redhill Aerodrome site (approximately two-thirds) is within Tandridge district. Notwithstanding the location of flood-prone land and other absolute constraints, should you be minded to select this site as your preferred option, we would need assurances from Tandridge DC (and the site promoter Thakeham) –- that you and they would work together with us to ensure that as far as possible, housing distribution would be proportionate to the site areas between our two boroughs. We are mindful of the need to find capacity for our future housing needs. Whilst we recognise that a settlement such as is proposed at this Redhill site would need to provide for new schools, a district centre and open / recreation space, the non-housing uses on the site should be spread across the site, so that the site helps both authorities to meet their future housing needs.

Your Regulation 18 Garden Villages Consultation paper (page 39) gives the size of the site submitted for consideration for the Redhill Aerodrome as 616ha, with capacity for between 6,000 and 8,0000 new homes. It also includes a proposed new junction and link road from the M23, through the site to East Surrey Hospital and the A23.

Your current consultation documents do not provide a detailed site boundary for any of the potential sites, but we acknowledge that you propose that this would be set out in a later Area Action Plan. However, we note from the plans, the indicative site masterplan and other documents submitted to both authorities by Savills on behalf of site promoter Thakeham Homes, and from the garden village workshop that we attended at your offices, that the proposed site includes land in the west of the site (within Reigate and Banstead borough) that Thakeham Homes does not currently have ownership of, nor an option on. Savills’s letter to Tandridge and Reigate & Banstead’s Policy Managers 16 May 2017, advises that “…. additional land should be factored in ensuring the realisation of the main planning objectives for the new settlement.” We note that the majority of this “additional land” is within Reigate and Banstead borough, to the north-east and south of East Surrey Hospital.

The site is being promoted by Thakeham Homes under the Healthy New Towns initiative, which amongst other benefits would offer the opportunity to greatly improve access to East Surrey Hospital from the M23 strategic road network. We recognise that this would be of great benefit strategically. As the improved access to the hospital is a key element in assessing this site, the availability of this land should be clarified, as the acquisition of this land will be crucial to delivery of the scheme.

Having met with East Surrey Clinical Commissioning Group and Tandridge’s Infrastructure and Partnership Officer to discuss the potential health care issues relating to this site, we recommend that you take the CCG’s further advice regarding the suggestion in your consultation document of the three potential options for primary care facilities.

We suggest that the SWOT conclusion for Redhill Aerodrome is updated to reflect the position of this “additional land” once clarified, as we consider that implying that the land has been put forward and is now “available” may be slightly misleading to the public.

Strategic infrastructure benefits and mitigation We recognise that access to East Surrey hospital from the M23 is currently convoluted, and acknowledge the considerable strategic benefit that a new junction and access roads connecting it to the hospital would bring in terms of reducing travel time.

We confirm that both authorities are agreed that a new junction from the M23 to the site would be needed to access a new settlement here, which we understand has been estimated would cost in the region of £75 to £100m (as referred at the DtoC workshop for adjoining authorities on 9 August 2017 as part of this Reg 18 Local Plan work). Design work for this proposed new M23 junction is ongoing. Our understanding is that this will be funded by the development, which should be taken into account in account in your consideration of “land value capture” for the site, and the need to provide an acceptable proportion of affordable housing, improvements to stations and bus services, and other strategic infrastructure.

The developer has had initial discussions with Highways England and Surrey County Council as the strategic and local highway authorities. The developer advises that in principle, both highway authorities are supportive of the proposals given the congestion on A23 and through surrounding settlements including Redhill and Reigate, and the potential for the new M23-A23 Link Road to alleviate that congestion, and to provide improved access to East Surrey Hospital form the strategic road network. Conceptual junction layouts have been drawn up by the developer’s consultants, and are being investigated, taking the form of either :  a two overbridge arrangement with a circulatory carriageway above the main line and with north and south facing slip roads to facilitate all traffic movements; or  a dumb-bell arrangement, with two smaller roundabouts either side of the main carriageway linked by a single bridge.

Reigate and Banstead specific issues Local residents in Reigate & Banstead borough have raised some important issues, which we will consider in our ongoing assessment of the suitability of this site for potential allocation in the next plan period. We expect that they will also raise these issues with you in your current Regulation 18 garden village consultation. These include:

 That the implications for continued emergency vehicle access during construction should be considered and secured in advance.  That consideration should be given to opening the two blocked arches of Three Arch railway-bridge, to aid traffic flow, including access to the hospital, which is already congested.  Local residents consider that Three Arch Road from the hospital roundabout, south to Masons Bridge Road is narrow, and the width of this road may raise concerns regarding safety of movement of construction traffic and for the eventual use by site traffic. Residents have requested that this section of road be considered for widening, in order to safely accommodate increased traffic.

We request and expect that you will take into account in your further consideration of Redhill Aerodrome, both our comments and all comments made by residents, businesses and other organisations of Reigate and Banstead borough.

Timetable

As set out in our Regulation 18 DMP (August 2018), we are considering the need and potential to safeguard land to meet our housing needs beyond this plan period. For us, this would be from 2027. As noted above, we are currently considering options for land safeguarding and will publish, and consult on, the outcomes of this work in our Regulation 19 Development Management Plan in late 2017/early 2018.

Should we take the decision to safeguard land in our DMP to submission, and should this include Redhill Aerodrome, we would welcome aligning our plan processes to potentially produce a joint Area Action Plan DPD. We note that this would be the Local Plan that would remove the land within Tandridge from the Green Belt, whilst the land within Reigate & Banstead borough would be potentially taken out of the Green Belt in our Development Management Plan 2018 (although remaining subject to Green Belt-level protection until a subsequent review has been completed).

We concur with your suggestion of preparing a Statement of Common Ground for the Redhill Aerodrome site should both authorities decide to progress with this site. This could be included in the required Statement of Common Ground to be required by each authority, as proposed in the current CLG consultation “Planning for Homes”.

Should Redhill Aerodrome be selected for safeguarding for future Local Plans by both Tandridge and Reigate and Banstead, we expect that you will work constructively with us and keep us updated on your assessment work as it progresses.

We hope that you find these comments helpful. Please do not hesitate to contact me should you have any further queries.

Yours sincerely,

Luci Mould Head of Places and Planning

Direct dial: 01737 276214 Email: [email protected]