Representation to Development Management Plan Regulation 19 Consultation

Thakeham Homes February 2018

Redhill Aerodrome

Prepared for:

Thakeham Homes and Quintain Ltd

savills.co.uk Representation to Development Management Plan Regulation 19 Consultation Redhill Aerodrome

Contents 1. Executive Summary 2 2. Previous Representations 4 3. Site & Surroundings 5 4. Site Constraints & Opportunities 7 5. Pre-Submission Development Management Plan Consultation (Regulation 19) 14 6. Summary of Benefits 22 7. Conclusion 26

Appendix 1 Indicative Delivery Timeline Appendix 2 Letter from Chris Grayling Appendix 3 Indicative Masterplan

Documents included in submission:

Area of Technical Assessment (THH001_022_B) Vision Document prepared by David Lock Associates January 2018 Flooding Drainage Topic Paper prepared by WSP January 2018 Air Quality Topic Paper prepared by WSP January 2018 Landscape & Visual Baseline Appraisal & Landscape Capacity prepared by Davies Landscape Architects October 2017 Green Belt Review prepared by Davies Landscape Partnership October 2017 Green Belt Review Addendum prepared by Davies Landscape Partnership February 2018 Ecological Deliverability Assessment (EAD Ecology, November 2016) Review of Transport Feasibility prepared by WSP October 2017 Review of Infrastructure Feasibility prepared by WSP October 2017

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1. Executive Summary

1.1. This representation is submitted on behalf of Thakeham Homes the lead promoter of Redhill Garden Community, and Quintain Ltd, in respect of the Reigate & Banstead Borough Council (RBBC) Pre- Submission Development Management Plan (DMP).

1.2. Thakeham Homes and Quintain are broadly supportive of the Regulation 19 DMP in respect to the land at Redhill Aerodrome including the safeguarding of the Site under Policy MSL2.

1.3. A number of technical objections to the DMP, as currently drafted, are raised with respect to the inclusion of an Area Action Plan (AAP) as a mechanism to deliver the new settlement alongside Tandridge District Council (TDC) and the need to increase the area of safeguarded land identified under policy MSL2 and SAS1.

Redhill Garden Community Vision

1.4. A Garden Community at Redhill Aerodrome provides an unprecedented opportunity to create a highly sustainable well-planned Garden Community providing housing development, economic growth and strategic infrastructure in the heart of the Coast to Capital Corridor. The Aerodrome is also in an ideal location, able to provide sustainable connections to strategic employment locations and the wider surroundings via new and integrated public transport.

1.5. It is Thakeham Homes and Quintain vision is to create a thriving new place where local people will want to live and work. This will comprise circa 8,000 dwellings and a wide range of services, facilities and infrastructure to support new homes and businesses. At present, this includes:

A mixture of market housing for rent and build to rent, and affordable housing, consisting of a range of sizes and tenures to reflect local need including key worker housing; New highway infrastructure, including the delivery of a new junction on the Strategic Road Network (SRN) M23 and a strategic Link Road to the A23, improving the accessibility for local communities more widely across Surrey and Sussex thereby creating greater flexibility to assist in relieving existing and future congestion; Public Transport Hub, allowing sustainable, easy access and a fast connection to strategic and local employment areas including Redhill, Crawley, East Surrey Hospital and Gatwick Airport and the potential for integration of new technology vehicles; Provision of additional primary and secondary schools; New publicly accessible open spaces, including an extensive parkland through the heart of the Garden Community, landscaped for active leisure and recreation; A new District Centre providing higher order services, retail, employment space, social infrastructure, public transport hub and wider public realm and community infrastructure to serve the new community and those working within the new employment areas, all within a high street type setting; New Local Centres, providing mixed use retail services, convenience shopping, event spaces, healthcare and community facilities; A new business park providing for a range of employment opportunities; Delivery of employment and improved connections within the M23 corridor and Gatwick Diamond LEP; Dedicated storage, maintenance and landing area for the Air Ambulance close to the East Surrey Hospital and the strategic road network.

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The expansion of East Surrey Hospital, providing more bed spaces, expanded treatment services, key- worker housing and more efficient parking and access; Delivery of a Healthy Town in line with the NHS guidance, supporting health and wellbeing.

1.6. The Area of Technical Assessment includes the East Surrey Hospital (ESH) campus, which is also being promoted by the Surrey & Sussex NHS Trust and is part of the wider development of Redhill Garden Community. The Hospital Campus is being promoted for release from the Green Belt and expansion and enhancement of the Hospital (see Section 5 below). The future development at ESH will be delivered as part of a comprehensive scheme in line with emerging Policy RED9.

1.7. At present it is proposed that the circa 8,000 units would be divided between the two local authorities 55% in TDC and 45% in RBBC. The proposed Redhill Garden Community will achieve the three dimensions of sustainable development: economic, social and environmental, as set out in paragraph 7 of the National Planning Policy Framework (NPPF). For further details of the Vision for Redhill Garden Community please see the enclosed Vision Document (January 2018).

1.8. The land at Redhill Aerodrome is considered to be the only location which can realistically deliver the required quantum of housing across RBBC & TDC, including circa 4,350 units in TDC and within RBBC 3,650 units. Alongside this the Site can deliver the infrastructure needed to create a sustainable community and to provide wider benefits for surrounding communities. The development will enhance the wider area by improving accessibility to infrastructure within a commercially desirable location to enhance the regional significance and potential for employment growth. The housing market in the area has sufficient unmet capacity to accommodate the delivery of significant new homes in this location and delivery in RBBC can begin post 2027, in line with the Local Plan Review.

Tandridge District Council Emerging Local Plan

1.9. TDC has recently consulted on their Sites Consultation document (Regulation 18) as part of their emerging Local Plan, which included 4 potential Garden Village locations including Redhill Aerodrome. This consultation set out that TDC would bring forward a Garden Village via an Area Action Plan (AAP) and in the case of Redhill Aerodrome this would be via a Joint AAP with RBBC. This is strongly supported by Thakeham Homes and Quintain and the RBBC DMP should include a reference to this mechanism to allow for efficient and positive plan making to take place.

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2. Previous Representations & Supporting Information

2.1. This representation is accompanied by the following documentation:

Previous Representations

2.2. Savills, on behalf of Thakeham Homes, have previously promoted Redhill Aerodrome to both RBBC and TDC via the consultation stages of the DMP and TDC emerging Local Plan and regular joint engagement with the local authorities is ongoing.

2.3. This representation should be read alongside the previous submissions made including the following:

Introductory submissions to TDC and RBBC (September 2016) Representation to RBBC DMP Regulation 18 consultation (October 2016) Representation to RBBC SHLAA (October 2016) Representation to TDC HELAA (October 2016) Representation to Local Plan: Sites Consultation (December 2016) Representation to RBBC HELAA (January 2017) Representation to TDC HELAA Update (March 2017) Submissions to RBBC and TDC on Highways and Economics (May 2017) Submission of new Area of Technical Assessment to RBBC and TDC (May 2017) Submission of updated concept plan, flooding and landscape evidence to RBBC and TDC (June 2017) Submission of Updated HELAA to RBBC (January 2018)

2.4. Quintain have also make numerous representations to RBBC which should be read alongside this representation.

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3. Site & Surroundings

3.1. Redhill Garden Community is being progressed as part of a single promotion led by Thakeham Homes with development partners Quintain. The land subject to this representation is centred at the Redhill Aerodrome site, with a number of land parcels around the Aerodrome including the East Surrey Hospital (ESH) campus to the north west and land to the south of the Aerodrome between the A23 and M23. The area of land under consideration for development as part of the Redhill Garden community is identified within the accompanying Area of Technical Assessment. The Area of Technical Assessment extends across TDC and RBBC and has an area of approximately 626ha. The Site area is split 47% in TDC and 53% in RBBC.

3.2. The Area of Technical Assessment is located to the south east of Redhill, south of South Nutfield and west of the M23 motorway corridor. The smaller settlements of Whitebushes and Salfords are located to the west of the Site along the A23. The Site is north east of the settlement of Horley. Existing vehicular access is available from Kings Mill Lane and a further access on Crab Hill Lane. There are a number of other local roads within and surrounding the Area of Technical Assessment including Masons Bridge Road, Honeycrock Lane, Axes Lane and Green Lane.

3.3. The Area of Technical Assessment includes areas of previously developed land, predominantly focused at the Aerodrome itself, including a number of internal roads, taxiways and existing buildings which range from large industrial aircraft hangers (ranging between two and four storeys in height), a single storey café/restaurant, Aerodrome terminal buildings including an air traffic control tower, and a number of workshops and office units. The total floorspace of the buildings situated on the Aerodrome is approximately 350,000 sq. ft.

3.4. The development of previously developed land is supported by the NPPF in paragraph 111 which states that:

Planning policies and decisions should encourage the effective use of land by re-using land that has been previous

3.5. As outlined above the Aerodrome site itself contains a significant amount of previously developed land and in this context it is notably that an appeal decision (ref: APP/R3650/A/08/2089143) decided by the Secretary of State (SoS) at Dunsfold Aerodrome found that the area containing hangars and other buildings constituted PDL and that the wider area of the Aerodrome were associated with aviation use and were ancillary and essential to the operation of the Aerodrome and were therefore considered to be developed. The Inspector examining the Waverley Borough Local Plan referenced the 2008 appeal at Dunsfold and concluded that the Aerodrome constituted brownfield land. The Inspector also found that the large scale strategic allocation at Dunsfold would relieve the pressure on greenfield land and was a key contribute to the housing delivery of the Borough. The plan has been found sound.

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3.6. The other large previously developed area of land within the Area of Technical Assessment is the ESH, currently designated as a Major Existing Developed Site in the Green Belt. The Hospital is located in the north of the site and has existing access from Horley Road (A23) and Three Arch Road. The Surrey and Sussex Healthcare NHS Trust provides a range of emergency and non-emergency services at ESH to residents of Tandridge District, Reigate and Banstead and wider Surrey and West Sussex. In 2016/17 the Hospital cared for a total of 545,359 patients, with 25% of those from RBBC, making RBBC the joint highest catchment authority alongside Crawley Borough.

3.7. ESH is a major acute hospital with a full 24 hour/seven day Emergency Department, 30 wards, a number of outpatient clinics and various services including an onsite walk-in centre for minor injuries, operating theatres, intensive care and maternity services. The hospital currently accommodates 695 beds, including maternity and critical care. In addition to the hospital services, the site has residential accommodation for key workers. The Hospital also supports a significant number of staff both clinical and non-clinical.

3.8. The broad extent and location of the site is a key benefit, as this allows for the delivery of a significant number of new homes in both RBBC and TDC. In turn, the size of the site and its ability to deliver a large volume of residential units facilitates the delivery of significant physical, social and green infrastructure which benefits the wider surrounding area, as well as the new residential development and ensures that the Redhill Garden Community is a sustainable place to live and work.

3.9. The wider Site is designated as Green Belt and there are a number of other designations within the Area of Technical Assessment including:

Biodiversity Opportunity Area Site Ancient Woodland

3.10. Whilst there are some areas within the Area of Technical Assessment which are sensitive ecologically, the majority of the area has relatively low biodiversity ecological value or important landscape features due to the presence of particularly the Aerodrome, including closely cut grassland and the culverted watercourse, East Surrey Hospital and strategic transport corridors. This therefore presents opportunities for the Redhill Garden Community to provide significant ecological and landscape benefits/enhancements to the area for example the inclusion of high quality green spaces and mitigation measures such as landscape buffers and implementation of the Landscape & Ecology Management Plan (LEMP).

3.11. The Area of Technical Assessment is also in close proximity to a number of designated landscape or ecological areas including the Surrey Hills Area of Outstanding Natural Beauty (AONB), Mole Gap to Reigate Escarpment Special Area of Conservation (SAC) and Site of Special Scientific Interests (SSSI). As discussed in Section 6 the proposals at Redhill Garden Community provide the opportunity to protect and enhance these areas through funding, diversion of recreational pressures and community initiatives.

3.12. There are a number of designated built heritage assets located within the Area of Technical Assessment and in the surrounding area, all of Grade II listing status. Appropriate heritage archaeological mitigation strategies will be developed in consultation with the Local Planning Authorities and their archaeological advisors at Surrey County Council and Historic England. Through the design development process and the Redhill Garden Community will strive wherever possible to minimise impacts on, protect and enhance any heritage assets and their settings.

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4. Site Opportunities & Initial Assessments

4.1. The Area of Technical Assessment has been subject to a number of assessments and surveys which have confirmed that there are no apparent technical constraints which would prevent the proposed Redhill Garden Community from coming forward. Further assessments will be progressed as the proposals are developed and through the production of the joint Area Action Plan.

Transport

4.2. The key transport infrastructure proposed include a new M23 junction and A23 Link Road, the provision of which will unlock the full development potential of the site, redistribute trips, alleviate congestion on the local network and facilitate access to the wider development area. The proposed junction with M23 will facilitate the creation of a new public transport hub within the development

station and major employment areas. As well as providing access to the development parcels the Link Road and Gatwick Airport and vastly improve response times during emergency situations. The improved access will benefit existing residents using the Hospital also.

4.3. A number of highway alignments are currently under consideration for the Link Road to benefit from the existing topography and to minimise the impact on the wider landscape and setting. Local access would be provided to the proposed Link Road via the development land parcels. In addition, an area wide transport management strategy would be implemented in consultation with local communities, to incorporate a range of suitable speed, volume and safety control measures. This will ensure that connections to the existing minor roads are limited to minimise the opportunity for including through South Nutfield.

4.4. It is envisaged that the Link Road would be adopted, in due course, by the local highway authority Surrey County Council (SCC) as part of the Primary Route Network (PRN) and classified in accordance with the Department for engineered to current DfT design standards and safely located along the M23 between M25 (J8) and Gatwick (J9) to minimise the risk of traffic weaving across running lanes. Initial studies identify that there would be greater than a 3km separation distance between a new junction and the existing junctions to the north and south along M23 and therefore a new junction could be safely accommodated and constructed without compromising existing road users.

4.5. Highways England is planning for M23 to become

approximately two years. The new junction on M23 would therefore be planned to accord with the future Smart Motorway proposals for M23 between J8 (M25 J7) and J9 (Gatwick).

4.6. WSP has conducted initial assessments for the new junction and Link Road which have demonstrated that there are no overarching constraints to delivery of these elements of the scheme. In addition, the land required to deliver the new junction is within the Area of Technical Assessment.

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4.7. The Link Road would be constructed alongside the initial development phases to ensure that this is delivered as early as possible within the development programme. An Indicative Delivery Timeline is included at Appendix 1 which demonstrates the programme of delivery for the Link Road and new M23 junction as well as residential development and other key infrastructure.

4.8. Initial discussions have been held with Highways England and Surrey County Council (SCC) as the highway authorities who maintain the strategic and local highway networks respectively. Both authorities have recognised that there is value in exploring proposals for a new M23 junction given the existing and anticipated congestion on A23 and through surrounding settlements including Redhill and Reigate. The Rt. Hon Chris Grayling wrote to Councillor Victor Broad in 2017, setting out the importance the Government places on infrastructure and that in principle the new junction on the M23 would be supported (See Appendix 2). The letter also sets out that Highways England would work with RBBC and TDC on this matter, which has led to the establishment of a Technical Steering Group including all the key stakeholders. The Terms of Reference for the Group are to drive forward the technical traffic modelling that will support the strategic economic and traffic case for a new junction on M23 and establish the benefits that a new junction will bring in stimulating regional growth to accommodate the future demand for housing across the wider region.

4.9. A detailed modelling methodology is currently being discussed with Highways England and SCC to include a number of development phases extending through the Plan period. The modelling exercise will identify the impact of traffic on the wider local road network and the improvements to the local and strategic road networks created by the proposals with the potential to reduce congestion and increase capacity.

4.10. Both Highways England and SCC are currently engaging with the Redhill Garden Community Project Team, and are willing to collaborate to complete the technical analysis to an agreed acceptable methodology to ensure that the Strategic Growth Test can be satisfied in accordance with the Department for Transport Circular 02/2013 and uphold the general principles of the agency agreement between Highways England and the Secretary of State. In this regard, funding for the highway and transport infrastructure that is required as part of the Redhill Garden Community will be developer led.

Air Quality

4.11. Through a review of the latest local authority air quality management documents, it has been established that there have been no exceedances of the national air quality objectives in recent years at Local Authority air quality monitoring sites close to the Site. The nearest Air Quality Management Area (AQMA) is over 2 km to the northwest, within Redhill Town Centre. Furthermore, the Defra mapped background levels applicable to the proposed development site predict concentrations of key air pollutants of concern nitrogen dioxide (NO2) and particulate matter (PM10) well below the respective annual mean limit values for the protection of human health.

4.12. With the M23 motorway adjacent to the east of the Redhill Garden Community, development-specific baseline air quality NO2 monitoring has been conducted to assist in the assessment of suitability for residential use. Twelve months monitoring has been conducted across 17 locations within the proposed development site and on the surrounding road network. Monitoring shows that no exceedances have been identified within the proposed development site. The highest concentration of 34.7µg/m3 NO2 was recorded along the A23. NO2 concentrations within the development site are well below the national annual mean limit value of 40µg/m3, set for the protection of human health.

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4.13. Mitigation measures broadly fall into two categories, those that reduce emissions from the development and those that will help protect the future residents from poor air quality conditions should these arise. The installation of Electric Vehicle charging points and other innovative measures such as autonomous vehicles to encourage the uptake of sustainable technologies by residents of the development. The proposed new junction onto the M23 and east-west link road will create benefits for the local and strategic road network including the potential reduction of congestion, which would provide benefits for wider air quality in the surrounding area. benefits also.

4.14. The development of a robust future proof travel plan will minimise additional traffic as a result of the development through encouraging the use of car sharing clubs and with public transport improvements enabling links to nearby employment areas and facilities by sustainable transport modes. Detailed design consideration will be considered including ventilation solutions and screening by vegetation as appropriate. The infrastructure required to ensure air quality impacts are mitigated will be funded by the development. Please see the enclosed Air Quality Topic Paper (January 2018) prepared by WSP which should be read in conjunction with this representation.

Noise

4.15. , completed in November 2016, suggest that daytime road traffic noise levels are predicted to be greater than 55 dB LAeq,16h for the eastern half of the Redhill Garden Community with the majority of the site exceeding 50 dB LNight at night. Development of the Site will include design measures to minimise the impacts of noise, including closed windows/sealed facades and screening adjacent to the main noise generators. The development of a robust travel plan will minimise additional traffic as a result of the development through encouraging the use of car sharing clubs and with public transport improvements enabling links to nearby employment areas and facilities by sustainable transport modes. The infrastructure required to ensure noise impacts are mitigated will be funded by the development.

Flood Risk

4.16. There are two watercourses within the Redhill Garden Community; Redhill Brook and Salfords Stream. Redhill Brook currently passes through a culvert beneath the existing grass runways and this acts as a constraint within the catchment and has in the past led to extensive but shallow flooding over a localised area.

4.17. -2D (Flood Modeller TUFLOW) hydraulic model of the Redhill Brook and Salfords Stream has been reviewed, updated and recalibrated to assess the fluvial flood risk to the Site. The updated hydraulic model has improved the representation of existing fluvial flood risk and provided confidence in the suitability of the model for developing flood risk mitigation options.

4.18. The 1 in 100 year return period (1% AEP) model scenario has been used to test the mitigation measures. The initial modelling assessment undertaken indicates that the potential mitigation measures could reduce the floodplain extents without having an adverse impact elsewhere along Redhill Brook and the Salfords Stream, including:

Replacement of the 400m long Redhill culvert with a remodelled open channel; Increased capacity of the existing channel and floodplains of Redhill Brook upstream of the Redhill Brook culvert and the existing channel of Salfords Stream both upstream and downstream. This also includes improvements to hydraulic capacity at Farm Road Bridge;

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Increased hydraulic capacity at two bridges on Salfords Stream: 1) Crab Hill Lane crossing located approximately 500m upstream of the confluence with Redhill Brook; and 2) Field crossing located approximately 100m downstream of the confluence with Redhill Brook.

4.19. Further enhancement measures delivered as part of the Redhill Garden Community include a flood compensation scheme in conjunction with the landscape and ecology biodiversity strategy and SUDs. The infrastructure required to mitigate the existing flood risk at the Redhill Garden Community site and the impact of the Redhill Garden Community will be funded by the development. Please see the WSP Flooding & Drainage Topic Paper (January 2018) which should be read in conjunction with this representation.

Ecology

4.20. The Area of Technical Assessment contains a number of ecological features. The eastern section of the Site is within a Biodiversity Opportunity Area (BOA) and there are five Sites of Nature Conservation stern and southern sections of the site, together with seven areas identified as Ancient Woodland. Despite this, the majority of the Area of Technical Assessment has relatively low ecological importance.

4.21. The proposed development provides opportunities to deliver significant ecological enhancements to the area including the BOA along the Redhill Brook Corridor through:

Removal of the culvert on Redhill Brook and improvements to habitats around watercourse throughout the site; Selective clearance / thinning of overhanging dense scrub along the watercourse. Improvements of existing habitats throughout the site; Creation of new habitats including new wildflower meadow, wetland and native tree and shrub planting. Creation of connected green corridors and habitats networks; Long-term management through implementation of a Landscape and Ecological Management Plan (LEMP);

4.22. The Area of Technical Assessment includes a number of SNCIs/pSNCIs and parcels of ancient woodland; therefore, careful development design will be undertaken to ensure that the impact of these sites and value of these areas is protected and enhanced wherever possible. This will be achieved, for example, through maintenance of buffers around SNCIs and ancient woodland, management of recreational access and appropriate habitat management.

4.23. Overall ecological features, both within the Area of Technical Assessment and in the surrounding area, are not considered to be a constraint to development.

Heritage

4.24. The Area of Technical Assessment contains a number of designated built heritage assets and there are also a number of designated assets on the boundaries and surrounding area. There may also be undesignated archaeological heritage assets of local to regional importance and undesignated built heritage assets within the area and its surroundings. Appropriate heritage and archaeological mitigation strategies will be developed in consultation with the Local Planning Authorities and their archaeological advisors at Surrey County Council and Historic England, comprising archaeological survey, investigation,

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reporting and preservation. The design concept will respect all designated built heritage assets and their settings within the Area of Search. Where non designated heritage assets are identified these will, so far as is practical be retained and incorporated in the development concept proposals to provide local context and historical grain to the new communities.

4.25. The assessments undertake to date have indicated that heritage assets within the Area of Technical Assessment are not considered to be a constraint to development.

Landscape Capacity

4.26. The landscape within the Area of Technical Assessment is significantly influenced by topography and a mature tree and hedgerow framework which defines areas of differing character, perceptions and experiences. The land uses range from the large open aerodrome to typically enclosed rural fields through to the urban edge and the motorway corridor. Potential receptors include views from the Area of Great Landscape Value (AGLV) to the north, views from the surrounding settlement edges, the local road network circumnavigating the aerodrome and Public Rights of Way.

4.27. In order to gain a thorough understanding of how these various elements interacted and contributed to the wider experiences, an initial Landscape and Visual Baseline Appraisal & Landscape Capacity study was prepared by Davies Landscape Architects (DLA.1748.LVA&CAP.RPT.09.RevC) which is enclosed within the representation package.

4.28. as a road, tree belt, hedgerow or stream and which contained similar landscape characteristics. These boundaries are also considered acceptable in defining Green Belt parcels and afford the opportunity for a comprehensive review of the potential constraints and opportunities for inclusion within the developing framework.

4.29. The assessment provided a narrative for each parcel against the following criteria:

Policy Context; Statutory and Non-statutory Designations; Access and Public Rights of Way; Landscape Character; Topography, Hydrology and Geology; Relationship to the existing Settlement; Landscape Features & Land use; Historical Landscape Character; and Aesthetics and Perceptions.

4.30. The assessment identified potential opportunities for views both into and out of the various parcels from residents, Public Footpaths, local transport networks and the elevated Area of Great Landscape Value (AGLV) to the north.

4.31. The comprehensive assessment resulted in a series of plans which identified key features, landscape buffers and experiences that positively contribute to the landscape experience. It also identified areas that have potential capacity to accept development without significantly impacting upon the most sensitive features, characteristics and views. It was agreed at an early stage within the process that any development would need to be set within the existing network of hedgerows and woodland to minimise

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wider impacts and provide a strong and mature setting to any future development. Areas that illustrated or contributed to high quality exemplar landscapes or features that were considered to contribute to the National, regional and local landscape character types would also be protected and enhanced where opportunities arose.

4.32. The final stage of the appraisal provided a strategy for each parcel and its potential to accept development and contribute to the wider Green Infrastructure. This was compiled to create an overall strategy which illustrated the potential area for development assimilated into the existing and improved landscape framework.

4.33. In summary, the appraisal identified that the landscape and experiences within the Aerodrome and along the motorway corridor were notably reduced in terms of quality, access and sensitivity and therefore being less constrained afforded a higher development capacity potential. The assessment also identified smaller areas of parcels, such as to the east of Whitebushes and surrounding the ESH, which due to urbanising influences, limited visibility, landscape and habitat features could potentially provide additional capacity. The areas which are more constrained, and so offer a lower development capacity, will be considered as part of the masterplan for proposals such as publicly accessible open space, green infrastructure, play space or sports facilities. Overall, the landscape capacity of the site is not considered to be a constraint to the delivery of proposed development without developing on areas of low capacity. The assessment also identified areas that would be included to provide enhanced connectivity and a new defensible green belt boundary to any future development.

Masterplanning

4.34. On the basis of the technical assessments undertaken an indicative masterplan for the Site has been progressed by David Lock Associates (See Appendix 3). This demonstrates that the delivery of circa 8,000 homes alongside the physical, economic and social infrastructure required can be accommodated within the Area of Technical Assessment. The key elements of infrastructure included in the new community masterplan development will include a minimum of:

2 x early years provision 2 x three form entry primary school 1 x all through school including 1 x 3 form entry primary school and 1 x equivalent scale secondary school Health Hub Local Centres District Centre including: o Retail and related services o Employment space including B1 office o Community meeting space o Leisure and recreation facilities Open and Green Space including: o Natural Green Space o Outdoor Sports including Playing Pitches o Parks and Gardens o Allotments o o MUGAs and Hard sports Areas

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o Green Corridors

4.35. The indicative Delivery Timeline at Appendix 1 shows when the key elements of Redhill Garden Community could be delivered and David Lock Associates have produced an indicative masterplan which can be found at Appendix 3. This illustrates how the proposed development can be sustainably accommodated within the Site.

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5. Pre-Submission Development Management Plan Consultation (Regulation 19)

5.1. Thakeham Homes and Quintain are broadly supportive of the Pre-Submission DMP subject to this consultation. A key element of the DMP which is strongly supported is the inclusion of the Redhill Aerodrome Area of Technical Assessment as safeguarded land under Policy MLS2 and Policy SAS1.

Cross Boundary Issues & Duty to Cooperate

5.2. In addition to comments on the Pre-Submission DMP, the following information has been provided to assist in the plan making process.

Stakeholder Engagement

5.3. Extensive consultation with key stakeholders as part of the promotion of Redhill Garden Community has been undertaken to date. This includes engagement with:

5.4. Gatwick Diamond this Group support and represent the business community in the Gatwick Diamond Area and M23/A23 corridor. This area has recently been found to be performing well above the national average on a range of economic indicators including productivity levels, share of high skilled jobs and track record of attracting foreign investment. Gatwick Diamond have given their support for the Redhill Garden Community and support this as a strategic location for new employment development, provision of road infrastructure and public transport enhancements. Gatwick Diamond demonstrated their support to for the Redhill Garden Community in their representation to the TDC Regulation 18 Consultation in October 2017 and continue to be supportive of the proposals.

5.5. Coast to Capital Local Enterprise Partnership (LEP) the Redhill Garden Community is within the Coast to Capital LEP who have been consulted on the proposals. The LEP are supporters of the provision of housing required by communities in order to support economic development and for employment development within the LEP area. Redhill Garden community is in the ideal location to make a significant contribution to the economic community, located close to existing employers and with the opportunity to deliver excellent public transport to the key strategic employment areas.

5.6. East Surrey Hospital Surrey and Sussex Healthcare NHS Trust are working alongside Thakeham Homes in support of the Redhill Garden Community and the Hospital Campus is within the Area of Technical Assessment. The proposals will support the delivery of new medical related and key worker development at ESH Campus. In addition, the local level healthcare infrastructure within the Redhill Garden Community will support the Hospital helping to divert non-emergency patients within the community and the transport infrastructure proposed will improve emergency response times. The proposed development being explored at ESH includes:

Private patients hospital Rehabilitation Centre Outpatients Centre MRI Centre Expansion Key worker residential dwellings

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Care Home and/or Assisted Living GP Services Additional Car Parking

5.7. Thakeham Homes and Quintain support of emerging Policy RED9 which removes the Hospital Campus from the Green Belt.

5.8. Transport Steering Group this Group has been set up by the lead promoters and consultant WSP in order to agree and progress transport modelling and other actions required to progress the new M23 junction and Link Road, as requested by Rt Hon Chris Grayling. The stakeholders who have been involved in this process include; Highways England, SCC, West Sussex County Council, RBBC and TDC.

5.9. Tandridge District Council Thakeham Homes and their consultants have had significant recent engagement with TDC including meetings with Planning Policy Officers and presentation to Members.

5.10. This early engagement with key stakeholders will ensure that the promotion of Redhill Garden Community can be progressed in a coordinated manner with the support of these groups and taking into account their expert feedback at an early stage of development design. At this stage none of the statutory or non- statutory groups consulted have raised any fundamental constraints which would prevent this development from coming forward or raised any objections in principle to the development.

5.11. Parish & Town Councils - Thakeham has offered to meet every parish council in RBBC and TDC and have kept parish councils up-to-date through regular emails and telephone contact. Thakeham and their Team continue to be available to answer questions or provide information on the proposals wherever possible, when requested. To date, meetings have been held with the following groups:

Horley Town Council Burstow Parish Council Dormansland Parish Council Godstone Parish Council Horne Parish Council Limpsfield Parish Council Outwood Parish Annual Meeting

5.12. At each of the parish meetings Thakeham Homes has attended and members of the project team set out an introduction to the plans. Parish councillors then had the opportunity to ask questions on any aspect of the proposals. Thakeham is committed to continued engagement with local parishes, and hopes to hold more meetings with parishes as the plans progress further.

5.13. Additionally, Thakeham Homes has met with representatives of the Godstone Village Association, and has been represented at the regular meetings of the Redhill Aerodrome Consultative Committee. Efforts have

Consultation in autumn 2017. Conversations were held with hundreds of local residents in towns and

consultation.

5.14. The DMP must at Examination demonstrate that it has fulfilled the legal Duty to Cooperate on planning issues that cross administrative boundaries particularly in relation to strategic priorities (paragraph 178 NPPF). The safeguarding of Redhill Aerodrome in the DMP alongside joint working and agreement with

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TDC on the progression of a joint AAP to bring forward the Site greatly assist in demonstrating this duty. Redhill Garden Community offers a unique opportunity for both RBBC and TDC to meet their respective future housing needs and provide strategic infrastructure and employment space, creating wide reaching cross boundary benefits.

Development Management Plan Policies

5.15. As set out within the NPPF the DMP must be in accordance with legal and procedural requirements. To be considered to be sound the plan must be:

Positively prepared Justified Effective Consistent with national policy

Spatial Strategy and Delivery of Housing

5.16. The DMP covers the period to 2027 and runs alongside the adopted Core Strategy (2014) and plans for a total of 6,900 new homes between 2012 and 2027 equating to 460 dwellings per annum. The DMP allocates a number of additional residential sites alongside large strategic sites and regeneration areas to meet the needs of the Borough over the plan period, which are not subject to this representation. The housing trajectory at Appendix 2 of the Core Strategy demonstrates that up to 2027 the maximum housing delivery could be up to 7,567 units.

5.17. The long term delivery of housing in the period post 2027 can be considered at this stage, particularly in light of the Core Strategy being over five years old in 2019 and will be subject to review shortly. The identification of deliverable, developable sites or broad locations for growth in the 6-10 year period is supported by paragraph 47 of the NPPF. The NPPF also sets out that the supply of new homes can be best achieved through planning for large scale development including new settlements in line with Garden City Principles. Paragraph 85 goes on to set out that land within the Green Belt can be identified in a plan

The identification of safeguarded land at Redhill Aerodrome for future development is therefore wholly in line with and supported by national planning policy.

5.18. The safeguarding of the Area of Technical Assessment would allow for the site to be progressed via the Local Plan Review and a joint Area Action Plan to be progressed in a timely fashion allowing for delivery in RBBC in the early stages of the next plan period. Alongside the early delivery of housing would also be the additional infrastructure benefits such as educational facilities, employment and transport infrastructure which would come forward in the early part of the plan period. The timing of delivery of housing within the relevant plan periods and the required infrastructure is demonstrated within the high level delivery timeline shown at Appendix 1.

Policy MLS2 - Safeguarding of Redhill Aerodrome

5.19. Safeguarded land for development beyond the plan period the safeguarding of Redhill Aerodrome Area of Technical Assessment under reference SAS1. The safeguarding of Redhill Aerodrome is strongly supported by Thakeham Homes and Quintain. The wording of Policy MLS2 however does not include a fundamental plan making mechanism to allow for the

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progression of a Joint Area Action Plan (AAP). The AAP provides a mechanism to facilitate effective co- working between RBBC and TDC as each develop new or review their Local Plans. The Joint AAP would be a Local Development Document and once adopted form part of the statutory development plan for RBBC and TDC (known also

5.20. To ensure clarity moving forward for Thakeham Homes and Quintain and TDC as they produce their emerging Local Plan reference to the AAP should be included in Policy MSL2. On the basis of this not being included in the Regulation 19 DMP, Thakeham Homes provide a technical objection to the worded as drafted relating to this policy.

5.21. Other elements of the policy and Thakeham Homes and Quintain comments on these are set out in the table below:

Policy MLS2 Criteria Thakeham Homes and Quintain Comment No specific comments however this policy should not 1) Safeguarded Land is not allocated for preclude the necessary plan making actions which can development during this plan period take place during this plan period to ensure the timely delivery of Redhill Aerodrome

This criteria is considered to be restrictive in terms of plan making and should be reworded to reflect positive 2) Until a review of the Local Plan is completed, plan making. As discussed above at paragraph 5.15 this Safeguarded Land will be treated in policy terms criteria should include reference to a joint AAP as though it were Green Belt and policies relating progressed by RBBC and TDC and the policy should to development in the Green Belt will apply allow for sufficient flexibility to allow for a Joint AAP to be progressed alongside the Local Plan Review.

3) Any development which would prejudice the This criteria is supported by Thakeham Homes and future comprehensive development of Quintain Safeguarded Land will not be permitted This criteria does not apply to the majority of the Redhill Aerodrome Area of Technical Assessment which is 4) Existing recreational provision will be protected private land. in the plan period and in the event of future

allocations The existing lawful public rights of way will not be affected. This strongly supported by Thakeham Homes. 5) The following site is identified as Safeguarded A minor objection to the area of land identified under - Redhill reference SAS1 is lodged by Thakeham Homes and is Aerodrome discussed below.

6) In the event that the identified safeguarded land is demonstrated (as a result of further detailed Thakeham Homes and Quintain have no specific testing as part of work to prepare a future local comments on this criteria however as set out above this plan) to not be sustainable or developable then the should include reference to the Joint AAP as well as the exceptional circumstances may exist to re- Local Plan Review. designate this land as Green Belt through that future Local Plan.

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5.22. In terms of the amount of land to be safeguarded as part of MLS2 and SAS1, as previous stated by Thakeham Homes, the proposals for Redhill Garden Community do not include developing the wider area. As set out above and shown in the indicative masterplan a significant proportion of the Area of Technical Assessment will remain or become open space, new or improved habitat for wildlife and connected green infrastructure. It is likely that parts of the Area of Technical Assessment will not be subject to any change as part of the proposals. The Area of Technical Assessment has been safeguarded in order to allow for detailed assessments to be undertaken to give both RBBC and TDC flexibility moving forward. This flexibility will ensure all necessary infrastructure is provided and the most appropriate defensible boundaries can be utilised.

Area of Technical Assessment & Safeguarded Land

5.23. The land identified at Redhill Aerodrome, under reference SAS1, must be updated to reflect an amended site area which now includes a parcel of land to the south of the settlement of Whitebushes, herein referred . The additional land has an area of approximately 9.6ha. This land has been included in the Area of Technical Assessment as it may be required as part of the detailed masterplan to deliver primary physical infrastructure, public transport services or connections and/or green infrastructure. By including this area within the Area of Technical Assessment this allows it to be considered as part of the options for the development of the Site. This area of land should be included within the safeguarded area identified under SAS1.

5.24. This area will be included in all ongoing assessments undertaken on behalf of Thakeham Homes and Quintain by the consultant team. Initial appraisal has found that in terms of Green Belt contribution the key feature of this area is to maintain the separation of Whitebushes and Salfords. This role would be retained and enhanced through inclusion of this area in the masterplan for Redhill Garden Community ensuring this area remained open.

5.25. This is considered to be a minor technical objection to Policy MLS2 and the land identified within this policy under reference SAS1. The Land south of Copsleigh Avenue is important to the development and testing of masterplan options for Redhill Garden Community and will need to be considered as part of the AAP. Thakeham Homes and Quintain therefore request that the Proposals Map be updated accordingly in line with the Area of Technical Assessment submitted with this representation.

Release of Land from the Green Belt

5.26. The safeguarding of Redhill Aerodrome Area of Technical Assessment and release of land from the Green Belt for the delivery of a new Garden Community is essential to ensuring that RBBC meet their long term development needs. It is also key to ensuring that TDC meet more immediate housing needs in their District.

5.27. The NPPF sets out at Paragraph 83 that Green Belt boundaries should only be altered in exceptional circumstances through the review of a Local Plan. Alongside the Safeguarding Policy in the DMP and Local Plan Review, the Joint AAP would undertake a detailed review of the Green Belt boundaries in this area alongside the Masterplan proposals. This would result in the exact boundaries of the Green Belt release coming forward as part of the AAP, which when adopted would be become a statutory development plan document.

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5.28. The Inspectors Report into the submission version of the Core Strategy, found that the Plan would need to recognise that some loss of Green Belt land to housing development will be necessary, in certain sustainable locations, to meet as far as is practicable the needs of the borough a to meet housing and employment needs was not wholly convincing and that development of some land outside the urban area would be unavoidable (para 16). Despite major modifications to the now adopted plan, the Inspectors Report at paragraph 46 goes on to given the limited capacity of suitable and deliverable greenfield land outside the Green Belt, the only option available within the borough to meet the bulk of the housing shortfall is land currently in the Green Belt

5.29. The Inspector at paragraph a more strategic and longer term assessment -85 of the NPPF (para 49). Overall, whilst the Inspector found the Plan sound, following main modifications, the Inspector required a number of actions to be included in the DMP including a Green Belt Review.

5.30. The Green Belt Review, dated June 2016, reviewed land within broad areas of search, detailed boundary anomalies and washed over villages and land this does not however cover all of the Redhill Aerodrome and wider site.

5.31. Davies Landscape Architects have produced a Green Belt Review which assesses the broad Area of Technical Assessment specifically and the conformity of parcels of land within this area with the Green Belt purposes. A Green Belt Review Addendum covering the additional Land south of Copsleigh Avenue has also been included as part of this representation. As with standard Green Belt Review methodology and in line with RBBC and TDC Green Belt reviews four of the five purposes have been assessed:

Purpose 1 - To check the unrestricted sprawl of large built up areas. Purpose 2 To prevent neighbouring towns merging into one another. Purpose 3 To assist in safeguarding the countryside from encroachment. Purpose 4 To preserve the setting and special character of historic towns

5.32. The Green Belt Review splits the Area of Technical Assessment into 11 parcels (A-K) and found that in line with RBBC methodology:

1 parcel scored 1 indicating a high contribution to the Green Belt purposes (parcel A) 3 parcels scored 3 indicating a medium contribution to the Green Belt purposes (parcels B,C & J) 4 parcels scored 4 indicating a low contribution to the Green Belt purposes (parcels D,E,G & K) 3 parcels scored 5 indicating the lowest contribution to the Green Belt purposes (parcels H, F, I & J)

5.33. Parcel A is considered to make the highest contribution and is outside of the Area of Technical Assessment and is not included within the indicative masterplan due to its sensitivity and contribution to the Green Belt purposes. This area would not be proposed to be removed from the Green Belt as part of the development of Redhill Garden Community. Due to the extent of the land included in the Area of Technical Assessment, the masterplan for the development can be flexible and ensure a landscape led approach to ensure that sensitive areas in landscape and green belt terms are sensitively incorporated into the Redhill Garden Community.

5.34. The Green Belt Addendum found that the Land south of Copsleigh Avenue makes a moderate contribution to purposes 1 and 3 and lesser contribution to purpose 4. Overall the highest value this land

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parcel has is to separation between Salford and Whitebuses. This will be carefully considered through the development of the proposals to ensure that the separation is maintained and defensible boundaries enhanced wherever possible.

5.35. It is clear from the Green Belt Review that the land parcels within the Area of Technical Assessment are not meeting all of the purposes of the Green Belt and this contributes to the Exceptional Circumstances for release of the Site from the Green Belt, to be progressed as part of the Joint AAP. The land parcels within the Area of Technical Assessment which do not contribute fully to the purposes of the Green Belt have been targeted for development in the indicative masterplan. This alongside other opportunities and constraints on the Site have shaped the development of the masterplan.

5.36. Alongside the Area of Technical Assessment land parcels not contributing fully to the purposes of the Green Belt, there are a number of benefits of the proposals at Redhill Garden Community which cumulatively amount to exceptional circumstances which must be taken into account and justify the removal of land from the Green Belt including:

Housing Need as set out above Redhill Garden Community is a significant opportunity to delivery housing in RBBC within the next plan period including early in 2027. In addition the Site can deliver housing in early phases within TDC assisting in meeting their short and longer term needs; Affordable Housing in addition to the need to deliver wider market housing, RBBC is known for its high house prices with average prices of £372,299 with a poor affordability ration of 11.49 and a high need for affordable housing. The Redhill Garden Community includes significant numbers of affordable housing including specialist tenures such as key worker supporting East Surrey Hospital. Transport Infrastructure the development of Redhill Garden Community facilitates the provision of extensive transport infrastructure funded by the development. This includes the delivery of the new junction onto the M23 and Link Road to the A23 which are significant infrastructure projects with the potential to have wide ranging local and regional benefits. In addition the provision of a public transport hub within the site and enhancement of the bus services to key employment locations and transport nodes are key benefits of the scheme. Education Provision the Redhill Garden Community will deliver a number of primary schools to meet the demands of the new community alongside an All Through School providing secondary and higher education services which has the potential to include provision for the wider community. The education provision to be delivered as part of the scheme including the All Through School is detailed further in the Indicative Delivery Timeline at Appendix 1. Provision of Public Open Space the majority of the Area of Technical Assessment is made up of the Redhill Aerodrome site and other private land. There are a number of existing public rights of way within the Area of Technical Assessment however these are typically fragmented and isolated by the Aerodrome. The benefits of the Redhill Garden Community will be two-fold, firstly providing new connections through the development to the existing rights of way to provide joined up routes and increase user enjoyment. Secondly the development proposals include significant areas of publicly accessible open space. These features of the development will provide benefits to the new community and wider residents of both RBBC and TDC. Biodiversity Enhancements much of the Aerodrome part of the Area of Technical Assessment is of low ecological due to the current activities and management on site, and in particular the requirement for the site to retain low level cut grass at all times for operational safety reasons. The Redhill Garden Community will improve the biodiversity in the area by providing new open spaces and diverse habitats, including the creation of new wetland habitat through de-culverting of the Redhill Brook and provision of SuDs.

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Employment Provision & Economic Development Redhill Garden Community will provide onsite employment at the local and district centre including provision of B1 floorspace alongside B2/B8 floorspace in the proposed employment area close to the M23. The provision of this employment floorspace in a strategic regional location coupled with the improvement transport infrastructure, also delivered by the proposals, will provide employment for the new community itself but also support the regional economy within the Gatwick Diamond and Coast to Capital LEP.

5.37. The benefits of the Redhill Garden Community are considered further in Section 6 below.

5.38. A planning appeal at the main Aerodrome site in relation to an application for a hard runway was dismissed by a Planning Inspector in January 2014. Objectors have incorrectly raised the potential of a precedent between this decision and subsequent Court of Appeal decision with the current proposals being promoted to RBBC and TDC. The Appeal fundamentally hinged on whether the proposals demonstrated Very Special Circumstances (VSC) outweighing harm to the Green Belt and other any other harm in line with the NPPF.

taken into account in the VSC assessment. Whilst relating to Green Belt and the Aerodrome site, these decisions are not considered to be relevant to or set a precedent in regard to the safeguarding of the site under MLS2 where the relevant test to be deployed in proper plan making is one of exceptional circumstances.

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6. Summary of Benefits

6.1. A new Garden Community at Redhill Aerodrome has a number of a wide reaching benefits for both RBBC and neighbouring TDC as well as having wider positive regional implications. Alongside the delivery of significant market and affordable housing on a scale unprecedented in the area, the proposals are infrastructure led and will deliver physical, social and green infrastructure that can only be realised as part of this strategic scale development.

Delivery of housing

6.2. RBBC is planning for the delivery of at least 6,900 homes between 2012 and 2027, equating to an annual average provision of 460 homes per year. Through the DMP allocations this level of development is likely to be achieved. As set out in the Inspectors Report on the Core Strategy, this level of development does not meet the full objectively assessed need of the Borough. The ability of Redhill Garden Community to deliver approximately 3,600 units (45% of the development) including the ability to deliver within the early stages of the next plan period from 2027 is a significant benefit.

6.3. The proposals will deliver both market and affordable housing alongside specialist tenures such as key worker development and Build to Rent. The level of housing to be delivered allows for the significant infrastructure proposed on the site to be viably delivered.

Strategic & Local Road Network and Public Transport

6.4. The provision of a new junction on the M23 is a key infrastructure item and one that is integral to wider regional infrastructure provision to accommodate planned housing growth in RBBC post 2027 and in TDC up to 2034. The proposed M23 junction and link road to A23 will create greater flexibility between the SRN and the local road network and thereby reduce congestion and improve journey time reliability. With the application of an area wide Traffic Management Plan (TMP), there is the added advantage of re - around the Area of Technical Assessment including those on the A23 such as Salfords, Whitebushes and Reigate.

6.5. The proposed improvements to access to the SRN and reduction in congestion will provide benefits to the East Surrey Hospital and bluelight services allowing faster response times. This includes improved access to the air ambulance service which will be located within the Redhill Garden Community in a strategic location to the east of the proposed junction on M23.

6.6. The proposed junction on M23 and link road to A23 will facilitate the creation of a new public transport hub within the site key transport nodes such as Gatwick Airport, Redhill station and major employment areas in the wider district. The provision of better public transport connections has the additional benefit of influencing behaviour to increase public transport usage. This and other appropriate measures will be incorporated within a bespoke development Travel Plan, with the primary objective of achieving a sustainable modal shift and less reliance on the use of private vehicles.

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Cycling and Walking Infrastructure

6.7. There are numerous local pedestrian and cycle routes within and around the Area of Technical Assessment. The footpath and cyclepath network is currently isolated by Redhill Aerodrome and there are opportunities to provide a more integrated network. Connectivity for pedestrians and cyclists on secure routes away from the principal roads will give direct access to key transport nodes such as rail stations and main bus stops. Local footpaths on the main desire routes can be upgraded to bridleway status to allow for use by cyclists. Connections would be made to the NCR21 for access to Redhill, Earlswood, Salfords and Horley railway stations. A new pedestrian/cycle connection to South Nutfield railway station would also be created to provide sustainable access to the Redhill to Tonbridge railway line. Enhanced cycle parking provision will be provided at stations to encourage intermodal connections. This is in line with the major improvements to Redhill Railway Station currently being progressed.

6.8. Footpaths along the main desire routes towards Nutfield, Earlswood, and Salfords will be maintained and enhanced through the development. Cycle route connections will also be made with the Surrey Cycleway on Ma Bridge Road and Axes Lane/Green Lane for cycle trips across the County. The improvements made would complement those proposed as part of the SCC Greater Redhill Sustainable Transport Package which focuses on improving walking and cycling connectivity between Redhill, Reigate, Merstham and Horley and is identified to receive CIL funding of £370k in 2020/2021.

Healthcare & East Surrey Hospital

6.9. The East Surrey Hospital campus is included within the Area of Technical Assessment and would be a major beneficiary of the proposed Link Road, facilitating faster response times to Gatwick Airport and the wider area in the event of an emergency by providing a variety of routes including more direct route and shorter travel distances. Emergency vehicles are currently delayed by the congestion on A23 towards/from Gatwick and on other local roads for example the level crossing at Reigate. Connecting the Hospital directly to M23 via the Link Road would facilitate emergency vehicles using M23 rather than A23 and therefore

6.10. The development of the Hospital for medical related development including key worker accommodation, is included in the DMP which is supported by Thakeham Homes and Quintain. The improvements to the Hospital will create significant benefits to the communities within the Borough who are the highest users of the hospital alongside Crawley Borough and wider region. The healthcare hub to be provided within the District Centre will also relieve pressure on the hospital for non-emergency and minor healthcare needs of the new community.

6.11. The Redhill Garden Community will be designed in line with the NHS Healthy New Towns initiative aiming to deliver integrated public healthcare and wellbeing within new development from the earliest stage. Thakeham Homes and Quintain are committed to ensuring the Redhill Garden Community provides for a healthy place promoting wellbeing and good health, providing access community activities, providing greenspaces to promote physical activity and easy access to appropriate healthcare facilities.

Ecology

6.12. The majority of the Area of Technical Assessment is currently of low ecological importance. The Redhill Garden Community will greatly improve the biodiversity value of the area and high-level assessment undertaken to date indicates that significant adverse effects on designated sites, habitats and species

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could be avoided. The proposals are considered to be capable of being undertaken in full compliance with emerging Policy NHE2.

6.13. Furthermore, the provision of an integrated landscape and ecological design for the development would provide extensive areas of public open space that could divert recreational pressure, arising both from the development and existing residents in the area, from the SAC and other statutory sites. This has the potential, therefore, to benefit these important ecological areas.

6.14. The development design would ensure that SNCIs and pSNCIs would be retained and buffered from development. These sites would be integrated into the landscape and ecological design, and implementation of positive management of these sites could be achieved through a site-wide Landscape and Ecological Management Plan (LEMP). Detailed survey of pSNCIs would be undertaken to confirm their nature conservation importance and provide protection and enhancement of these areas if required.

6.15. The integrated landscape and ecological design and implementation of the LEMP would protect and enhance the Biodiversity Opportunity Area along the Redhill Brook Corridor. The provision of new habitats, such as native woodland planting, wildflower meadow and wetland habitats, and species-specific measures such as inclusion of bird and bat boxes within the development, could provide a net gain in biodiversity. This would be complemented by the removal of the culvert on the Redhill Brook.

6.16. Further detailed surveys will be undertaken to confirm the presence of and status of protected and notable species within the site, and suitable mitigation measures can be implemented if required through the detailed design of the masterplan. Overall, in accordance with emerging Policy NHE2, it is considered that the development can avoid significant adverse effects on features of biodiversity importance, including designated sites, and provide significant benefits in and protection of the most important ecological features.

Flood Risk

6.17. There are two watercourses within the Redhill Garden Community; Redhill Brook and Salfords Stream. Redhill Brook currently passes through a culvert under the existing grass runways which acts as a bottleneck within the catchment causing an extensive floodplain at the confluence of Redhill Brook and Salfords Stream. WSP has conducted assessments on site and updated and recalibrated the Environment ulic model and this indicates that potential mitigation measures could reduce the floodplain extents without having an adverse impact elsewhere along Redhill Brook and the Salfords Stream. This includes replacing the Redhill culvert with an open channel, increasing the capacity of the existing channel of Redhill Brook and Salfords Streams.

6.18. The mitigation measures will therefore reduce flood risk within the Site and the surrounding area and other mitigation measures to reduce the impact of the Redhill Garden Community on flooding will also be provided, including a flood compensation scheme in conjunction with the landscape and ecology biodiversity strategy and SUDs. These proposals will also have wider biodiversity benefits, as set out in Section 6.

Education Infrastructure

6.19. The Redhill Garden Community will provide a range of social infrastructure for the new community including primary and secondary schools. The proposed educational infrastructure will ensure that educational needs of children living at the Garden Community will be met and will also provide additional education

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services to the wider community in an area for secondary and higher education. The delivery of the primary and secondary schools also assist in establishing a strong sense of community and the capacity of these schools will increase to provide places for children as the Garden Community expands. Thakeham Homes are committed to providing land and buildings to meet all of the education needs of this growing population.

Economic & Employment Provision

6.20. The Redhill Garden Community includes a number of Local Centres and a larger District Centre to meet the day to day needs of the new residents including retail and in the District Centre to also provide business and employment floorspace. Also proposed is a strategic employment area close to the M23 and the new junction which will provide B1/B2/B8 floorspace. The employment provision will be in a regionally strategic location within the Gatwick Diamond and Coast to Capital LEP.

6.21. The delivery of circa 8,000 new homes at Redhill Garden Community alongside the educational, community and employment development set out above will deliver significant economic benefits to the area including:

More than £160m in CIL and social and educational infrastructure also secured through S106 Agreements; £1.2m in Business Rates based on 9ha of B class employment space; Delivery of 3,800 on and off site jobs; Delivery of an additional 290 construction jobs per annum; £190m Gross Value Added; £21.8m in Council tax increase;

6.22. The Redhill Garden Community presents a significant opportunity to deliver employment space in a strategic location on the M23/A23 corridor. This is supported by the wider business community in the region including the Gatwick Diamond LEP.

6.23. Thakeham Homes are committed to ongoing engagement with both Local Authorities to continue to develop the policy position and infrastructure delivery for the Site. This will facilitate the development of a comprehensive new Garden Community at Redhill Aerodrome, delivering economic, social and environmental benefits.

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7. Conclusion

7.1. As is demonstrated throughout this representation and its supporting documents, the Redhill Garden Community presents an unprecedented opportunity to deliver circa 8,000 new homes, physical, social and green infrastructure alongside retail and employment floorspace as part of a sustainable new settlement. As set out the proposals include a new junction on M23 motorway, a Link Road, public transport hub, primary and secondary education, district and local centres, employment space, healthcare provision and specialist air ambulance space, retail, employment and open green space.

7.2. The proposals for the Redhill Garden Community are currently being developed informed by ongoing technical assessments and in consultation with key stakeholders. The proposals are being developed within an Area of Technical Assessment to allow for sufficient flexibility in the masterplan.

7.3. Redhill Garden Community will meet the longer term housing needs of RBBC post 2027 and the more immediate need within TDC key to meeting the needs of both local communities. The safeguarding of Area of Technical Assessment under Policy MLS2 is therefore strongly supported by Thakeham Homes as this will allow the proposals to continue to develop and progress through the plan making process.

7.4. Thakeham Homes and Quintain have put forward two minor technical objections to the DMP related directly to Policy MLS2 and SAS1:

1. Need for the inclusion of a reference and mechanism for the Joint Area Action Plan within Policy MLS2 to allow for this to form part of the future plan making process alongside the emerging RBBC Local Plan Review and TDC Local Plan. This will provide flexibility and allow for effective cooperation between the two local authorities; 2. within the area safeguarded under SAS1 in order for this area of land to be included in future assessments and design development and considered for physical infrastructure, public transport connection or green infrastructure;

7.5. Redhill Garden Community will facilitate wide scale on and off site benefits as set out in Section 6, meeting the three dimensions of sustainable development as set out by the NPPF. There are clear Exceptional Circumstances which justify the safeguarding of the Area of Technical Assessment and release of land form the Green Belt.

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Appendices

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Appendix 1.0 Indicative Delivery Timeline

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Ì¿²¼®·¼¹» Í»½±²¼ Ý±³³«²·¬§ Ô±½¿´ Ð´¿² Ð»®·±¼æ îðïè ¬± îðíí Ø¿´´ Í»½±²¼ Ð®·³¿®§ Í½¸±±´ øÐ¸¿•» ïô ïÚÛ÷ Óîí Þ«•·²»•• Ð¿®µ ¿ª¿·´¿¾´» ø´¿¬»•¬÷ Ì¸®±«¹¸ Ô·²µ º±® ×³°®±ª»¼ Ó»¬®±¾«• Í»®ª·½»

Appendix 2.0 Letter from Rt Hon Chris Grayling MP

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Appendix 3.0 Indicative Masterplan

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Jonathan Steele Ruth Bryan Director Senior Planner

[email protected] [email protected]

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