LONG DITTON RESIDENTS ASSOCIATION RESPONSE to ELMBRIDGE LOCAL PLAN STRATEGIC OPTIONS CONSULTATION (Regulation 18) February 2017

LONG DITTON RESIDENTS ASSOCIATION RESPONSE TO ELMBRIDGE LOCAL PLAN STRATEGIC OPTIONS CONSULTATION (Regulation 18) February 2017

CONTENTS: Summary of Response Main Response Issue 1: The local plan process: decisions on meeting housing needs Issue 2: Housing Supply Issue 3: Housing Targets and Infrastructure Issue 4 - The Green Belt Review and Local Area 58 – Long Ditton’s Green Belt Conclusions

Long Ditton Residents Association: Who we are The Long Ditton Residents Association (LDRA) is a non-political and non-sectarian organisation. It does not sponsor councillors on Elmbridge Borough Council. As such, it is free to represent the residents of Long Ditton.

Its aims are to preserve Long Ditton from over-development, maintain its character, improve its amenities and defend its surrounding Green Belt. Put another way, the LDRA tries to make Long Ditton a better place in which to live. It plays an active role in all planning matters that affect Long Ditton and is in continuous contact with Surrey and Elmbridge Councils on a wide variety of other issues, including traffic and recreation areas.

A Summary of our response

Elmbridge Borough Council (EBC) is currently reviewing its 2011 Local Plan and as part of this process is consulting residents on options for the proposed housing target which aims to meet Elmbridge’s ‘objectively assessed’ housing need of 9,480 to 2035 (i.e. the unconstrained assessment of housing needs). EBC has proposed three ‘options’ as part of its consultation; Option 1 would involve a significant increase in the density of development in existing urban areas and Options 2 and 3 would both involve developing areas of Green Belt. EBC has indicated in the consultation document that its ‘preferred’ approach is Option 2.

The Long Ditton Residents’ Association has undertaken widespread canvassing of views from our residents and has a number of serious concerns about the options proposed by EBC, particularly in relation to the release of Green Belt These concerns are both general and more specifically related to the area within Long Ditton identified as ‘Area 58’.

Use of the Metropolitan Green Belt to meet future housing needs

Two of the options (2 and 3) would involve the release of Green Belt within the Borough. To do this and meet the requirements of national policy (and government proposals to amend national policy later this year), EBC would have to conclude that there are ‘exceptional circumstances’. This includes demonstrating that it has exhausted all other non-Green Belt options and has worked proactively and positively with neighbouring authorities to see if they could help meet some of the unmet need. We have serious concerns about this process for the following reasons:

 The evidence base for the Local Plan Review does not clearly demonstrate that all appropriate options for meeting housing needs within existing urban areas have been explored. Furthermore, in our view, the Strategic Options document, particularly Paragraph 3.9 is misleading in the way it presents the urban concentration option (Option 1). This has been compounded by recent statements on the Thames Ditton

and West Green RA website: (http://residents-association.com/news/latestnews/417- the-good-the-bad-the-ugly) by Councillor Karen Randolph:

“Of these, the option that leaves the Green Belt entirely untouched involves more intensive development in existing urban areas, i.e. replicating what is going to happen in Kingston and other parts of London, and building upwards. Are we happy to have multi-storey blocks of flats in Thames Ditton, Hinchley Wood etc., altering the character of our area while we leave land designated Green Belt (some of which may not be particularly attractive) untouched?”

There are many examples of well-designed, high density developments that are attractive and entirely appropriate within a suburban setting – these are not tower blocks. We accept higher densities and more efficient use of land (not playing fields and back gardens!) will not fill the gap between current assessments of land availability and needs, but it could contribute more and allow EBC a better chance of having a robust housing target in the Local Plan that is below the objectively assessed needs.

 Although national policy allows local planning authorities to release Green Belt sites where ‘exceptional circumstances’ have clearly been demonstrated, this does not take into account the significant impact of a number of incremental releases on the overall integrity of the Metropolitan Green Belt surrounding London. It is acknowledged that EBC is working with neighbouring authorities as part of the ‘Duty to Cooperate’ to see if they can help meet some of Elmbridge’s needs. However, all its neighbours are very likely to be in the same position, with significant pressures on housing and very limited options for meeting these needs, especially those authorities on the edge of London. This is further compounded by the fact that the Mayor of London has made it clear that there is currently no intention to review the Green Belt as part of the London Plan Review (https://www.london.gov.uk/london-plan-full-review/overview-full-review- london-plan ). It is therefore very likely that each local authority around (but outside) London will have to meet their own needs with the result being a significant number of incremental releases of Green Belt which will seriously undermine its overall integrity and value.  As well as the implications arising from the London Plan Review, there is likely to be an impact on Elmbridge from two major infrastructure proposals within the lifetime of the Local Plan, both of which are outside of EBC’s control; Crossrail 2 and the proposed expansion of Heathrow Airport. It is therefore premature to plan for meeting all of Elmbridge’s ‘objectively assessed needs’ when these will have to be examined again within this wider context. Crossrail 2 particularly will bring with it major investment in development and infrastructure and is very likely to change the

way that this whole area is planned in the future, including any potential release of Green Belt.

The Long Ditton Residents’ Association therefore strongly objects to both Options 2 and 3 as these would have a fundamental impact on the integrity of the Metropolitan Green Belt and any release would be premature in advance of the London Plan Review and a detailed assessment of the impacts of Crossrail 2 and Heathrow expansion. We implore EBC to work together with its neighbouring authorities and the GLA to ensure that any review of the Metropolitan Green Belt is undertaken at a strategic level and within this wider context.

Potential development of ‘Area 58’ in Long Ditton

As part of the plan preparation process, EBC commissioned a review of the Green Belt from consultants Arup (http://www.elmbridge.gov.uk/planning/sdps/evidence-and-supporting- docs/ ). This designates Long Ditton’s Green Belt as Local Area 58 and concludes that, when measured against the three main purposes of the Green Belt, this area is ‘weakly performing’ Green Belt. Option 2 of the consultation document proposes that ‘weakly performing’ Green Belt is released to contribute towards the potential housing shortfall. This means that land within Area 58 could be developed to accommodate up to 2,000 new homes; this represents a new township the size of Hinchley Wood within an even smaller area.

We believe that this area of Green Belt still fulfils its primary Green Belt function, particularly in relation to separating Surrey from London, and that the conclusion of the ‘desk-top’ analysis is therefore flawed. The Green Belt within the M25 is fragmented and small parcels of land on the border, such as this, are becoming increasingly vulnerable to development, yet are probably the most valuable within a strategic Metropolitan Green Belt context.

We further believe that major development in this area would have a serious detrimental impact on infrastructure which is already heavily constrained with no spare capacity, especially transport and education. There is currently no evidence from EBC that this would, or even could, be addressed as part of the local planning process.

EBC has indicated that, should this area be released from the Green Belt, much of the site would remain undeveloped as it fulfils other important recreational, open space and biodiversity functions (EBC Frequently Asked Questions: http://consult.elmbridge.gov.uk/gf2.ti/-/756418/24559109.1/PDF/- /Frequently_Asked_Questions__land_north_of_A309.pdf). However, EBC conceded at public meetings as part of the consultation, that once the area has lost its Green Belt status,

4 it would be more vulnerable to speculative development proposals in the future i.e. there are no guarantees of its long-term protection.

The Long Ditton Residents’ Association therefore strongly objects to the identification of Area 58 as ‘weakly performing’ Green Belt as this does not adequately reflect its intrinsic value in relation to maintaining a feeling of ‘openness’ and separation from adjoining areas within London. Furthermore, we seek assurances from EBC that, should they decide to pursue the release of any Green Belt to meet future housing needs, that the Green Belt Review evidence will be considered alongside all other evidence, including the Sustainability Appraisal, impact on infrastructure and delivery issues.

Our Main Response

Introduction

1 The Long Ditton Residents’ Association is grateful for the opportunity to comment on the Elmbridge Local Plan Options Consultation and is looking forward to further constructive dialogue as the plan preparation process continues. However, whilst we accept that there is a need to have an up-to-date local plan in place, we are concerned about the process EBC has embarked upon, and in particular, the options presented in the consultation document.

2 Having reviewed the evidence on which the options have been formulated and the requirements of national policy with regards to local plan-making (including the recently published Housing White Paper), we have concluded that the evidence base is not complete or robust, particularly the ‘desk-top’ Green Belt Review which we consider is technically flawed.

3 We also believe that EBC should work together with all its neighbouring authorities to escalate the impact that local Green Belt reviews around London will have on the overall integrity of the Metropolitan Green Belt. It is in everyone’s interests to ensure that this highly valued planning policy is not undermined and that any future reviews should only be undertaken at a strategic level.

Issue 1: The local plan process- decisions on meeting housing needs

4 EBC has undertaken a review of the Green Belt in Elmbridge to inform the options currently being considered. Green Belt releases have been suggested as potential options for meeting the objectively assessed housing need (of 9,480 to 2035) as a result. However, national policy (NPPF) makes it clear that this should only happen in ‘exceptional circumstances’ and after all other options have been explored through the local plan review process. The Housing White Paper confirms that there will be no change to national policy but proposes amendments to the NPPF (to be introduced later this year) to make it clear that:

“authorities should amend Green Belt boundaries only when they can demonstrate that they have examined fully all other reasonable options for meeting their identified development requirements, including:

 making effective use of suitable brownfield sites and the opportunities offered by estate regeneration;  the potential offered by land which is currently underused, including surplus public sector land where appropriate;

 optimising the proposed density of development; and  exploring whether other authorities can help to meet some of the identified development requirement.”

5 It is our view that EBC is premature in treating Green Belt as an ‘option’ for meeting long term development needs as all other ‘reasonable’ options have not yet been exhausted. Further ‘urban capacity’ work and a review of the current Land Availability Assessment (LAA) is needed to examine the following:

Use of brownfield sites / urban areas

6 The Government has been clear that authorities should give priority to using brownfield sites, particularly where these are owned by the public sector. Densities should be optimised, with higher densities in and around areas with good public transport access (where there is capacity or additional capacity can be provided). The White Paper confirms this approach and amendments to the NPPF are proposed to ensure that:

 When preparing plans, authorities have a clear strategy to maximise the use of suitable land (i.e. a full urban capacity study).  Greater weight is given to using brownfield sites for housing unless there are specific reasons for not using them e.g. flooding.  Authorities have policies to support small windfall sites and ensure that 10% of allocated sites are small (0.5ha or less) but not at the cost of open space or through ‘garden-grabbing’. The Council has already included a ‘windfall estimate’ of 800 as a contribution towards meeting needs but will be expected to allocate 10% (940) small sites in addition to this (small sites for the purposes of this will be those on land of 0.5ha or smaller, or comprising 10 units or smaller).

7 A new approach to ‘urban capacity’ is therefore needed. This should take into account small site allocations, higher density development in urban areas and better use of public sector land. On the last point, the White Paper proposes a range of measures to bring forward public sector sites which may result in additional sites within Elmbridge being identified. In terms of appropriate density, EBC should consider good examples around the Borough (and elsewhere) where high densities have been applied within a suburban setting. For example, the former Surbiton Water Works site (St James Estate) was heralded as a good example in the mid 1990s of how high density can be used on sites and still provide good design and a high level of open space. Above all, the Council should be making it absolutely clear that high density in Elmbridge terms does NOT mean tower blocks, as implied at recent public meetings.

Exploring options with neighbouring authorities

8 The Council has prepared a Duty to Cooperate Scoping Report which sets out what strategic issues it will be working with partners and adjoining local authorities on as the plan is progressed. It refers to the joint housing needs assessment (SHLA) that has been undertaken and the Local Strategic Statement (LSS) that is being prepared by all the Surrey Authorities. Cooperation on strategic matters should start at the beginning and continue throughout the process, with the aim being resolution of all strategic (cross-boundary) matters. The Duty to Cooperate is not an ‘option’ as implied by the Council; it is a legal requirement of the process. If a potential shortfall in meeting housing needs has been identified, the Council must explore all options of meeting this with neighbouring authorities. This is even more important where the loss of Green Belt is at stake (regardless of its relative value).

9 The Housing White Paper also makes it clear that this step should be taken before any decision on whether Green Belt land is needed or not. There is currently no evidence to indicate that the Council has done this. According to the Council’s Green Belt Review, there is a commitment through the Surrey LSS to ‘get a picture of Green Belt across Surrey’ but there is no indication as to what this means or when the LSS will be available. The review document also shows that close neighbours Spelthorne and Kingston are not currently intending to release any Green Belt. Spelthorne’s current plan (CS 2009) acknowledges that the Green Belt in Spelthorne is part of the Metropolitan Green Belt with a ‘strategic role in containing the outward spread of the capital and providing a belt of open land for air and exercise’. Where Kingston is concerned, the London Plan currently only supports growth that does not encroach on the Green Belt and currently, the Mayor’s SHLAA for the new London Plan is not proposing to consider Green Belt sites.

10 There is therefore a process to go through with neighbouring authorities (which should be wider than those involved in the SHMA process i.e. it should include other Surrey Authorities and other neighbouring authorities on the edge of London) to:

a) consider whether there is scope to take some of Elmbridge’s needs;

b) ensure that the incremental release of Green Belt around London’s boundaries as part of individual local plan reviews do not undermine its overall integrity and strategic functions; and

c) undertake a wider review of the Metropolitan Green Belt across the whole area i.e. land both within Surrey and London, if needed. It is vital that the Green Belt is looked at strategically, as land within the M25 is generally the most fragmented Green Belt yet is potentially the most valuable from a strategic ‘city region’ perspective.

Issue 2: Housing type

11 The Arup identifies housing ‘needs’ by reference to an obviously high ‘demand’ for houses in Elmbridge. In seeking to explain its incursion into the Green Belt, EBC argues that it will help to deliver much needed affordable housing. However, Elmbridge has had requirements to build affordable homes in place in its existing Core Strategy (2011) planning policies, but these have made very little impact.

12 More evidence is needed to demonstrate that the proposed housing will deliver sufficient new affordable homes, not just to meet those households on the housing waiting lists (many of which do not currently reside in Elmbridge) but for the many young people and workers in Elmbridge that struggle to access the housing in an area with exceptionally high prices. This should also aim to address the Borough’s ageing population to ensure that homes are provided for those needing to move out of their homes into more appropriate accommodation, enabling them to continue to lead ‘independent lives’, and also freeing up housing stock for younger families.

13 It is also worth noting the comments of the Local Plan Inspector examining the Maidstone Local Plan with regards to impact of increasing the housing target to impact on market values. He concluded that increasing the target would not in itself deliver housing at a more affordable housing if housebuilders continued to deliver new homes at current rates. Given that housebuilders in Elmbridge will continue to base their business model on securing as much profit as possible, they are unlikely to deliver new homes at a significantly faster rate, therefore affecting their market value. (Interim Findings, December 2016 - http://www.maidstone.gov.uk/__data/assets/pdf_file/0008/134873/ED-110- Inspectors-interim-findings-on-our-Local-Plan-22-December-2016.pdf )

Issue 3 - Housing Targets and Infrastructure

14 We understand that there is significant pressure for more housing and related infrastructure, not just in the South East, but nationally. Elmbridge has consistently contributed to meeting those needs but has seen little in the way of infrastructure improvements to compensate this development. As a result, we are approaching a tipping point, after which further housing provision is likely to, at best, cause the Borough to choke and, at worst, significantly impinge upon the quality of lives for its inhabitants, intrinsically changing the character of the Elmbridge for future generations to come.

15 We do not believe that the process for setting housing targets, set by national government, is the answer to alleviating the current chronic national housing shortage. Green Belt policy was never intended as a strategic policy in isolation. The Metropolitan Green Belt was always supposed to be managed as part of a wider strategy that focused growth on the most appropriate areas e.g. through the New Towns Programme and more recent ‘regional’ growth programmes.

16 Although the Government is promoting policies to deliver growth in the north of the country (The Northern Powerhouse) it still has a responsibility to support long term growth in the South East. This must be done in a way that does not exacerbate existing infrastructure pressures, particularly in areas on the edge of London, within the M25. The London Plan review will hopefully expose the main opportunities along strategic transport corridors and ensure that London itself is doing its bit. There are opportunities to deliver large scale developments in the form of new settlements but this approach will need Central Government intervention. What the Elmbridge Local Plan clearly demonstrates is that we can no longer continue with a piecemeal approach to the long term sustainable growth of London and its surrounding areas. A proper, joined-up strategy is needed.

17 With specific regard to Elmbridge and Surrey, current infrastructure is already beyond its functioning capacity and, unless significant investment is made, will only be exacerbated by burgeoning house building targets. There is no evidence to demonstrate that the investment needed to delivery new infrastructure to expand current capacity is forthcoming (as promised in the Venn diagram on page 16 of the consultation document - ‘ensure associated infrastructure is sufficient to support any increase in development’).

18 The Surrey infrastructure Study 2016 states:

“Sustainable growth needs to be supported by infrastructure. Roads, schools, community and leisure facilities, healthcare and green space are essential for well- functioning, well-connected places and healthy communities and vital if we are to retain existing businesses and attract new ones.”

The study highlights the massive gap in funding for essential infrastructure to meet current housing targets, let alone the potential increases within Local Plans across the County. Forecast growth of 47,053 dwellings between 2015 and 2030, with an associated population increase of 60,991 people (an increase of 5%) is estimated to cost at least £5.37 billion. Taking into consideration the potential funding identified, a minimum gap in infrastructure funding of £3.2 billion remains between now and 2030.

19 These infrastructure requirements and associated costs presented represent a minimum scenario as these are based on a population forecast constrained by

planned housing sites as opposed to ONS population forecasts. ONS population forecasts for Surrey over the same 15 year period are 132% higher than the study forecasts. The estimated costs associated with the infrastructure to support population growth could therefore be increased considerably if a growth level nearer the ONS forecast was realised.

20 Clearly therefore, there is a huge funding gap which is only likely to increase, resulting in a chronic lack of infrastructure, which will impinge further on the lives of those living in Elmbridge, and the wider Surrey.

21 Turning now to the particular Infrastructure circumstances related to Local Area 58. The pressures of inadequate infrastructure are particularly felt in the north-eastern part of the borough, which abuts London and which is more densely-populated. Key impacts are as follows:

Schools

22 In Elmbridge, schools have been closed and the buildings and playing fields sold for housing. Spatial constraints within Elmbridge mean that, without intrinsically impacting the character of the Borough, there simply isn’t the space to continually expand current schools and establish new ones. Secondary school incremental provision has been delayed given the difficulty of finding suitable sites.

23 Senior school places are over-subscribed. Nowhere in the Borough is this situation more keenly felt than in Long Ditton. Children living more than 1km away from Hinchley Wood School are denied places and have to travel to other parts of the Borough (Hersham), Epsom or Kingston Upon Thames, further exacerbating problems on the already congested road network.

24 Primary schools are burgeoning and single form entry schools have been increased to three forms, in the last 10 years. The Surrey Advertiser (27th January 2017) reported that around 11,000 extra school places are needed over the next five years across the County. Surrey County Council plans to expand 11 schools to meet the increased demand for school places. Surrey County Council Cabinet Member, Linda Kemeny, commented in the article that “At a time when our funding from the government is falling, we face huge financial challenges, keeping pace with increasing demand for many of our services, including school places, adult social care and support for children with special educational needs”.

25 All of this even before any increased development as a result of the Local Plan. Across Elmbridge alone, it has been estimated that three new junior schools and two senior schools would be needed to cater for the 9,480 extra dwellings envisaged. How and where this need would be met is not explained.

Roads

26 Maintenance of existing roads and footpaths is already inadequate. Another featured difference in character when crossing the border from Surbiton in London into Elmbridge at Long Ditton, is the marked change in road surface, the former (TFL maintained) smooth, the latter (SCC maintained) continually in disrepair.

27 Elmbridge is a car dependent Borough, with 66% more cars on Surrey's roads than in the national average. There are concerns about the traffic congestion and air pollution likely to result from significant increases in traffic around the Long Ditton area by the addition of homes, each likely to include 2 cars. This is already a problem at key junctions such as the Scilly Isles and Ace of Spades roundabouts at peak times. Under-investment in local roads means public transport is in a self-fulfilling, downward spiral as it cannot compete, thereby encouraging further car use. Road journey times are extended and growing, with congestion estimated to be costing the local economy £550m p.a. The knock-on effects of an M25 closure can, and do, impact large parts of the borough significantly, on a regular and increasing basis. Neighbouring areas are impacted negatively by the activities of Elmbridge residents passing through (mainly by car) and vice versa.

Public Transport

28 Despite investment, rush hour trains and stations continue to operate beyond capacity. Station entries at Surbiton (not the same as train passengers passing through) have doubled in the last twenty years, resulting in rush-hour entry restrictions and platform marshalling to address station crowding issues, a situation which will only get worse if yet more pressure is added by more passengers travelling through the station to and from Elmbridge. Bus services within Surrey are being cut back, rather than expanded. The 515 service hangs in the balance at the of time of writing.

Health services

29 There are no general hospitals in Elmbridge. Residents therefore have to travel to Kingston (5.5 miles – at best 21 minutes by car), Epsom (7.2 miles – at best 20 minutes by car), or Chertsey (8.7 miles – at best 27 minutes by car). At certain times of the day, a journey to any one of them from Long Ditton could take an hour each way. The only route with a bus connection is Long Ditton to Kingston (scheduled journey time 44 minutes).

30 Far from bolstering the services, there are reported plans to cut the number of major hospitals in south west London from five to four. Bed capacity at one of five South West London hospitals – Kingston, Croydon, St George’s and Epsom and St Helier – are outlined for cuts as part of the NHS’ sustainability and transformation plans (STPs). Yet, according to a report by think tank The King’s Fund, the NHS may in fact need 17,000 more hospital beds to meet the demands in care (Local Guardian on 21st February).

31 In January (13th) the Surrey Comet reported that Kingston Hospital, which serves Long Ditton, warned residents to stay away as NHS hospitals across London struggled to cope with winter pressures. Epsom and St Heliers put out similar appeals. The Nuffield Trust think tank warned in December that on the single busiest day last winter, an extra 4,390 beds had to be opened, equivalent to seven extra hospitals in one day. The trust said that ‘pressures on the NHS “pose a real threat to the smooth running of hospitals and, ultimately, to patient safety’. All this before RKB and Elmbridge has added to its projected housing stock. Healthcare facilities simply cannot support existing numbers of residents.

Drainage/flooding

32 Drainage systems are already inadequate, resulting in significant fluvial flooding by St Mary’s Church and at the bottom of Rectory Lane (formerly Watery Lane…), at the Long Ditton cricket club and graveyard. Concreting over further large areas for housing and related infrastructure can only exacerbate the problem.

Infrastructure Summary

33 Given the current significant infrastructure funding gap, and without proper provision for significant future investment in infrastructure, we would not be able to support any of the three options presented in the consultation document and would argue that EBC’s local plan housing target should be set at a level that can be accommodated within existing infrastructure capacity or within the guaranteed future capacity.

34 Of course we recognise that none of this is under EBC’s direct control and very few existing facilities could easily be extended. An already bad situation in terms of the provision of core services would be made significantly worse.

Issue 4 - The Green Belt Review

35 We have informed the council that we are undertaking a review of the Arup Green Belt study as we consider this to be technically flawed. Unfortunately, we have not been in a position to complete this prior to the consultation end as we have been waiting for some data to be provided by EBC which has informed us that it was not possible to send this information to us prior to end date. We have set out some of the

issues identified below but intend to submit our full response to the Council as soon as possible. We would like to formally put the Council on notice of our intention to do so.

36 We do not agree that the Long Ditton Green Belt (‘Local Area 58’) is either ‘weakly performing’, or that it should be re-designated. The Arup Green Belt Review document is narrow, biased and misrepresentative. Local Area 58 plays an invaluable role both in differentiating and separating Elmbridge from the Greater London conurbation, and as a much-used resource for the local community.

37 EBC has undertaken a ‘desk-based’ analysis of the Green Belt which identifies some sites that are considered to be ‘weakly performing’ when compared to other areas. review document has attempted, according to their chosen criteria, to prove that ‘Area 58‘only performs weakly against the first three purposes of the Green Belt as set out in Guidance.

38 We seriously question the validity of a report that was largely undertaken as a ‘desk- based’ exercise, with its narrowness in scope. As a result, we consider some of the judgements made to be flawed. This is clearly demonstrated by the photographs presented within Appendix 4 as representative of Local Area58.

39 In terms of the ‘weakly performing’ judgement levelled at Local Area 58, we have considered each purpose in turn:

Purpose 1 (a):

ARUP: PASS - The local area is at the edge of the Greater London large built-up area

LDRA: We would agree with this assessment but would also comment that throughout their review, Arup refer to Long Ditton as Long Ditton (Greater London). This is simply NOT the case. As they observe themselves, Long Ditton is a distinct residential area ‘at the edge of’, which is quite separate to being ‘part of’.

There is indeed a very distinct difference in character and design between Long Ditton and its nearest GL neighbour, Surbiton. You only have to drive into Long Ditton from any RBK boundary to immediately note a step change in housing type, height and density of design. Lovelace Road and the Portsmouth Road are typical examples of this, characterised by flats on the Surbiton side, distinctly morphing to houses within Long Ditton.

Purpose 1 (b): Checking sprawl of large built up area:

ARUP: ‘Scoring 1: The local area is enclosed by the large built-up area of Greater London along its northern, eastern and western edges and has weak links to the wider Green Belt to the south. The Kingston bypass (A309) creates severance.

LDRA: The assessment is erroneous:

Firstly, the local area is not ‘enclosed’, it is not possible to be so on three sides out of four. We would argue it is the separation of the local urban areas rather than enclosure that is evidence of the key role the parcel is playing.

Secondly, the built-up areas abutting the parcel on two sides are NOT part of ‘Greater London’. Hinchley Wood to the west and Long Ditton to the Northern border are neither part of the GLA.

Thirdly, we contest that being bordered to the south by a major (A309) automatically prevents the parcel serving Purpose 1.

We believe that the artificial ‘parcel’ of Green Belt which has been created by the presence of a road, should not be dismissed as having no value in preventing sprawl into open land, or serving as a barrier at the edge of a large built up area.

Arguably Local Area 58, Long Ditton, located on the edge of Elmbridge, is one of the few areas left that still fulfils the original purpose of the Metropolitan Green Belt, separating London from the surrounding areas. Anyone driving down the A3 knows when they have left London and entered Surrey because of this piece of land. It is of strategic importance as a ‘front line’ in preventing London’s sprawl.

This assumption by Arup completely downgrades the intrinsic value of its position in preventing the sprawl of Greater London, condemning the total 67 hectares, to a minimum score of 1.

Purpose 2 – To prevent neighbouring Towns merging

Green Belt Boundary Review, Arup: Scoring 1: ‘The local area forms a small part of the gap between the settlements of Long Ditton (Greater London) and Claygate.’

In respect of the general gap, the local area is less essential, making only a very limited contribution and the overall gap is of sufficient scale and character that development here is unlikely to cause the merging of these settlements, neither physically nor visually' (Review of Absolute Constraints, Appendix 4).

LDRA: We strongly contest this assessment as subjective and therefore erroneous

Firstly, Long Ditton is NOT part of Greater London

Secondly: We agree with the Arup statements on page 41, section 4.4.2 that "In addition to the clear function of this purpose in preventing towns from merging and therefore protecting existing gaps between towns it also forms the basis for maintaining the existing settlements pattern” (Arup, 14 March 2016)-so vital in a Borough such as Elmbridge. It is also acknowledged in this paragraph that there is no guidance over what constitutes towns but we disagree that the assumption.

Arup refer to the local area providing a ‘small part of the gap between Long Ditton and Claygate’. But, this parcel of Green Belt represents a far more obvious and important gap, east west which Arup gives completely ignore. Local Area 58 provides is the gap standing in the way of a much more obvious merger, that of Long Ditton and Hinchley Wood, and in turn with Hook (part of the greater London built-up area).

We also agree that Long Ditton and Hinchley Wood are valid Settlements, both of which Arup include as ‘large built up areas’ that must be protected from merging or coalescence, we would add to this that of Hook, in bordering RBK. As such, the general gap is in fact ‘essential” in its role of maintaining existing settlement patterns, and that removal of this parcel from the green Belt and subsequent development would severely compromise these settlements. Any development within the plots along the A309 Kingston Bypass would significantly reduce the perceived or actual distance between non-Green Belt settlements.

We therefore fundamentally disagree with Arup’s scoring, believing it to be far too low, underestimating the role and importance that this parcel play in preventing the merging of settlements. We conclude that the scoring should have been a 5, not a 1.

Purpose 3: to assist in safeguarding the countryside from encroachment:

ARUP: Score 2: 7.5% of the local area is covered in development

The overall character of the area is piecemeal. While a significant percentage of the parcel remains open, the sense of rurality is reduced by a number of built developments and areas of managed land. These include artificial sports pitches, allotment gardens, Long Ditton Cemetery, a garden centre and several nurseries. The Kingston by-pass to the south of the parcel, is another major urbanising influence and reduces tranquillity.

Much of the rest of the parcel consists of poor quality scrubland and shrub land, interspersed with pony paddocks. Views across the local area are limited and there is little connectivity to the wider countryside, neither physically or visually.

The combination of urban fringe land uses and poor quality open land contributes to a semi-urban character (Review of Absolute Constraints, Appendix 4).

LDRA: This purpose has been scored with regard to the overall character of the areas either rural or urban and includes an assessment of the percentage of built form existing.

Firstly, on the basis of the scoring alone the parcel measured by Arup as 7.5% would score a 3 as it contains less than 10% built form. In addition, we would suggest that the percentage of ‘built form’ of 7.5% is highly likely to be erroneous (awaiting GIS evidence base, requested from EBC 16th Feb 2017). If it isn’t then the inclusion of

16 glasshouses, which are arguably farm buildings and would surely be deemed to be rural in their nature should have been excluded. Also, have the temporary structures in the Creative Living display at Squires been included?

There are actually very few so called ‘built developments’ within the 67 hectare parcel. It is not clear whether the report refers to historic buildings: The Manor House, St Mary’s Church and Kisimul residential school for special children, all of which pre- date Green Belt designation. Or, whether it refers to the land owned by EBC with specifically designated green belt uses of cemetery, leisure, sporting and other public amenity purposes, which are all to be encouraged in the NPPF.

With a ‘significant percentage of the parcel remaining open’ (which reflects the quantitative analysis of scoring at least a 3) the Arup analysis has subsequently 'downgraded' the parcel based on 'desk based' map analysis of character. We would argue the reverse of Arup’s negative slant, that rather than being ‘semi-urban’, the parcel is in fact ‘semi-rural’.

The difference between these classifications are hugely significant to the conclusions as they led to area 58 been classed as weakly performing, which would not have been the case had it scored a 3 in the assessment Looking through the analysis of all areas in appendix 4 there is in fact little consistency between the quantitative score and the evaluation of character and whether it is weakly performing and so is not a robust assessment. We suggest someone needs to have another look through these to explain how it is possible that these have been consistently scored and provide an objective assessment between parcels. There is considerable subjective judgement implied in reaching the conclusions on the three areas.

Indeed, how these scores relate to the NPPF's essential characteristics of Green Belt of openness are highly questionable. Green Belt is not an environmental policy to protect high quality landscapes and so the subjective judgements of the quality of the landscape are irrelevant and the scoring should not have taken this into account. We also cannot find Area 20 at all in the appendix (should be around page 255/340). The methodology is fundamentally flawed by this aspect alone. Appendix 4 states for area 58 that 'The combination of urban fringe land uses and poor quality open land contributes to a semi-urban character' but the guidance is clear that it is the fact that the land is open rather than its quality is the approach to Green Belt designation under NPPF guidance that should be considered.

‘Views across the local area are limited’. This is quite plainly incorrect. Arguably there are few sites in Elmbridge that enjoy the topography that hosts One Tree Hill and Squires ‘Panoramic Viewpoint’. We can only assume that google earth did not afford the same appreciation of the actuality, and did not extend to the views enjoyed by thousands each year looking out across the southern aspect to see faraway places such as the Wembley Arch and planes taking off from Heathrow. We would agree that

17 the northern view across to Claygate is impacted by the A309 Kingston Bypass, though given the topography much of the road is shielded from view looking from One Tree Hill and the road also predates the Green Belt designation.

Built in 1927 the Kingston Bypass (A309) stretches from the Robin Hood Gate of Richmond Park to the outskirts of Esher. Interesting to note that its construction immediately attracted developments of housing where access was easiest and that the Restriction of Ribbon Development Act 1935 came too late to prevent this private housing, which is apparent where the A3 winds through New Malden and Tolworth, and where the architecture includes concrete to art nouveau apartments, Mock-Tudor gabled houses and gabled Arts and Crafts movement-inspired houses. Hardly a planning triumph!

Given that the two largest landholdings within Area 58, those of Ditton’s Nurseries and Hillpark Nurseries (Durose Estate), abut the A309 and are both owned by developers who appear to be keen to cash in on their piece of Metropolitan Green Belt, it is therefore likely that development would once again be ‘Ribbon’ in its nature. (This assumes that the Council are true to their word in their ‘intention’ not to build on their land in the North of the parcel. And that the incumbents of the historic buildings sandwiched between the northern and southern land holdings, i.e. the Buddhists at the Manor House and owners of the Kisimul residential school for special children, do not feel that any reduction in open space around their locations would be reason to quit.)

The likely incidence or ribbon development, has proved to be a constraint in assessing other areas within the body of evidence. Presumably this is because, as was the case in the 1920s and 1930s when such developments generated great concern, when the increase in motor car ownership meant that houses sold easily even when they are remote from shops and other services. Such developments are attractive to developers because they do not have to waste money or plot space constructing roads.

This practice became seen as an inefficient use of resources and a precursor to urban sprawl, so a key aim for the United Kingdom's post-war planning system was to halt ribbon development. It led to the introduction of green belt policies.

The resulting towns and cities are often difficult to service efficiently. Often, the first problems noticed by residents is traffic congestion, as people compete to move along the narrow urban corridor while ever more people join the ribbon further along the corridor. Urban consolidation is often a solution to encourage growth towards a more compact urban form and which is why the NPPF is trying to encourage sustainable development.

Fast forward to 2017, where Elmbridge is highly car dependent. It surely does not make sense to encourage development here? Add to that Air Quality, and the exacerbation of the increase in traffic, already inevitable from current housing projections in Elmbridge, let alone increased ones, and let alone the astronomical developments taking place just across the border, in RBK, within the GLA. We need to preserve this space, not only for us, but for them.

In addition to this, though using road boundaries for parcel definition might be convenient when doing a 'desk based' map assessment it does not follow that amending the boundary to a road is sensible as we would argue that it would not provide permanence for the boundary of adjacent parcels. Perhaps those defining the original green belt boundaries had this in mind and this is why they are currently bounded by properties rather than road edges Indeed we can foresee that changing the boundary in area 58 would put additional pressure on area 34, as roads have two sides and the pressure would inevitably increase once there was ribbon development across one side of the road to take other sites in area 34. This would certainly not meet the requirement for any amended Green Belt boundaries to be permanent and endure beyond the plan period. We would suggest that in fact these two parcels should have been considered as one rather than be falsely separated in this way, to ensure the strength of the green belt was in this location was retained.

Local Area 58 – Long Ditton’s Green Belt 40 Given all the above we do not believe that the Arup, or the Council, has properly evaluated, or presented, the community value of Local Area 58, which includes strategic panoramic views, is well used for Allotments, Cemetery, Cricket, Hockey, Wildlife Garden, Nature Reserve and One Tree Hill (Tobogganing, Running, Dog Walking, Relaxation, School seasonal studies). It also included a residential special school for children and a Buddhist centre located at the ‘Old Manor House’. Enhancement of the Green Belt by local authorities is something that the NPPF advocates including providing access, opportunities for sport and recreation, retain and enhance landscapes, visual amenity and biodiversity. The use of area 58 is actually a great positive for Elmbridge in the way it has encouraged access to this area and this should be celebrated not destroyed.

41 Had the assessment of this area been more objective and performed using any other, more reasonable, criteria that valued its importance to the local community, then it would have surely scored a resounding 5. Arguably, you would be hard pushed to find a piece of Green Belt that has been so wholeheartedly, and increasingly, used for public amenity. All whilst still maintaining its openness. As one of the more densely populated areas in the Borough, and one which has among the fewest opportunities to access green space. Its loss would therefore have a disproportionate effect on its residents.

42 The Green Belt in Long Ditton, and to many neighbouring wards and settlements, offers amenity to the local population in a different way than other local open spaces does. It’s semi-rural nature and openness, make it VERY special to this area.

Dittons Nurseries – a large land holding abutting the A309. Owned by a known, and resident, developer who has used right of way access across a private road, to the detriment of the residents who live there.

Hillpark Nurseries (including land to the west to Severn Drive and One Tree Hill to the Goats Lane extent). Another large landholding (33acres?) abutting the A309. Otherwise known as the Durose Estate, an absentee landlord based in Derbyshire. Also developers. The Rose Nurseries are on a leasehold which the incumbents have run for decades, and are intent to continue to do so. Any change to the status of the land could lead to a loss in employment. A doggy daycare business has already been given notice.

PLEASE NOTE THAT THE MAP ON PAGE 30 OF THE STRATEGIC OPTIONS CONSULTATION (Regulation 18) DOES NOT ASSIGN THIS LANDHOLDING ANY NUMBER.

THIS UNFORTUNATE ERROR RESULTED IN A MISREPRESENTATION TO THE PUBLIC OF THE POTENTIAL EXTENT OF DEVELOPMENT WITHIN LOCAL AREA 58.

THE MAP NUMBERING GIVES THE FALSE IMPRESSION THAT THE PRIVATE ‘DUROSE’ LAND HOLDING (WHICH INCLUDES ONE TREE HILL) IS PART OF NUMBER 11 ‘LOCAL NATURE RESERVE’, IT IS NOT.

WHILST THE COUNCIL HAS RESPONDED TO THE LDRA BY PROVIDING A MAP OF OWNERSHIP, WE ARE CONCERNED THAT THE VAST MAJORITY OF LOCALS ARE UNLIKELY TO LOOK AT THIS SEPARATE MAP, PUBLISHED SUBSEQUENTLY, AND COULD STILL THEREFORE NOT QUITE REALISE THE EXTENT OF THE LIKELY DEVELOPMENT.

PRIOR TO THIS DETAIL BEING CONFIRMED, THE PUBLIC HAD BEEN GIVEN THE IMPRESSION THAT THE ONLY PIECE OF LAND IMPACTED, IF THE AREA IS DECLASSIFIED IS “Just the bit from Woodstock Lane up towards the Cap in Hand”.

The Old Manor House - a privately owned enterprise, Shinnyo-En , are a Buddhist community, for whom tranquillity and open space is important

Kisimul School – a privately owned residential Special School for children with learning difficulties or challenging behaviour. These children benefit from open spaces surrounding them, not built up areas.

These two organisations are custodians of historic buildings within Long Ditton.

To propose large scale development around these facilities, when their incumbents chose the area precisely for the benefit of the open space that Long Ditton’s Green Belt affords, could make their position within our community untenable. The potential repercussions of this are unthinkable, and would be to the detriment of all who live here.

Conservation Area & Site of Archeological Importance – The land around St Mary’s Church and the Manor house is a conservation area. There is also a site of archeological importance. We are aware the ancient Parish of Long Ditton predates the Doomesday Book.

‘Travellers’ – there is a static ‘traveller’ community, located just the other side of the A309, many of whom attend the local school in Long Ditton. There is a second static site, just over the border into Hook abutting the A309 on the north side (0.5 miles). We are concerned that any further provision in this area might lead to unrest amongst a community that is otherwise relatively settled. Good relations with the travellers have been fostered with the local schools and it does not take much to upset the balance of these important relations.

Squires Garden Centre – privately owned enterprise is thriving and has expanded its outdoor canopies (used in the built form calculation by Arup?) and extended their café in the last 12 months. It is a favourite amongst locals and in particular the older generation who are able to exercise their independence, walking from the café to events put on for them at St Mary’s Church. The organisers of the church functions are most concerned that this will no longer be the case, if development is allowed.

‘Squires View’ - includes a wildflower meadow (see nature below), willow sculptures and a pathway leading up to a panoramic view point.

‘One Tree Hill’ the strategic views from the top are very special, the full panoramic aspect from the top stretches for miles, towards Bedfont Marshes, Wembley Arch and Terminal 5 at Heathrow. The hill is used daily by runners, dog walkers and walking groups (including the Elmbridge Healthy Walks Programme). Schools visit for seasonal studies, run by the EBC Rangers. Families toboggan during snowy winters. The proximity of Stokes Field and shared entrance at one of the access points through at the very end of the lane also has meant that many local people think that One Tree Hill is actually part of Stokes Field. There are no boundaries between these apart from the hedgerows that enhance the biodiversity.

Stokes Field – is a recognised ‘nature reserve’, a SNCI (Site of Nature Conservation Importance) that is designated by the Surrey Nature Conservation Liaison Group as

21 being of county or regional wildlife value. The loss or damage to such sites would greatly reduce the diversity of wildlife in the area. They also contribute to the overall ecological network in the Borough.

As one of only 6 a designated Local Nature Reserves (LNR) in Elmbridge, established by Elmbridge in consultation with English Nature under the National Parks and Access to the Countryside Act 1949. The LNR designations provide opportunities for educational use and public enjoyment, as well as protecting wildlife or geological and physiographical features of special interest.

It is tended by the Council’s countryside management team and is a much loved and well used forested area, used by locals for dog walking, walking, running etc. Stokes field has a cemetery designation, under covenant. The cemetery has been extended in recent years and, over time, is likely to need more space still. As a result, assurances from the Council that Stokes Field is protected does not quite cover the extent of the actuality.

This makes the area surrounding the nature reserve, and one tree hill, even more important. Indeed the fact that 'no constraints' are recorded in the assessment of area 58 within Arup’s appendix 4 given, that local nature reserves are not included as a category, is evidence that our assumptions would be correct if Green Belt protection is removed. Whether or not Stokes Field would be protected, its setting would be irreversibly destroyed should the land at One Tree Hill be developed including the use of the access road along Goats Lane (otherwise shown as Bankside Drive on google earth), which is currently a lane with restricted access blocked by a locked barrier for limited access only. It is this lane approaching Stokes Field and the surrounding land in One Tree Hill that makes this place and its setting particularly special and semi-rural in its feel.

Nature - both one Tree hill and Stokes Field are used by the local school for seasonal studies, watching the impact of the changing seasons on nature, tree studies, pond dipping and bug hunting. The wildlife walk set up by the Surrey Wildlife Trust, in association with Squires Garden Centre, includes a wildflower meadow with thirteen indigenous varieties Surrey Wildlife Trust. This is a unique place and educational resource for the local area that must be protected.

Trees and Wildlife - natural habitats would be disrupted and disturbed ; Local flora and fauna at significant risk of damage during and post construction. Area 58 has a number of TPOs across the site.

Biodiversity in the area would be negatively impacted, permanently, with the removal of woodland, grassland and scrub. As well as being a local nature reserve this area is also a Site of Nature Conservation Importance (SNCI) an area designated locally for their wildlife importance. This area is also a habitat for endangered Stag Beetles, which are often sighted in the area as this area. You will find a variety of species of birds including Treecreeper, Nuthatch, Whitethroat, Chiffchaff and Blackcap as well as Woodpeckers. Woodcock has been flushed from dense vegetation around the small pond in hard winters, and Bullfinches often call from the hawthorn scrub below the hill. The hill itself has the potential to be a decent spot for migration watching, and has produced both Redstart and Tree Pipit around the rose fields at the top of the hill, as well as Red Kites and regular sightings of Buzzard drifting over the A309. Previous records of interest have included Ring Ouzel, Spotted Flycatcher and seldom reports of Barn Owls in the winter.

The site is also rich with other wildlife. Butterflies include those typical of grassland/wasteland sites - healthy colonies of both Essex Skipper and Small Skipper in the overgrown rose fields, and sightings of Brown Argus from time to time in late summer. The wet meadows are notable in early spring for a considerable population of the nationally-scarce moth, Mompha jurassicella, and is one of the only known breeding sites for the species in Surrey. Other scarce moths recorded there include the likes of Commophila aeneana, Caloptilia leucapennella, Small Yellow Underwing, Burnet Companion, Six-spot Burnet and Cinnabar, while Roesel's Bush Cricket can be seen in the overgrown rose fields without much difficulty.

Northern Area of Parcel 58 i.e. the land owned by the Council is very highly used:

Surbiton Hockey Club This is a world class facility, well located for accessibility, on K3 bus route, which is operated by Transport for London.

Using the hockey club car park, as one of the two photographs, to represent Area 58 in the Arup report is shameful, and we are concerned that to anyone that does not know the area that this could create a false impression of the actuality.

The hockey club, is a perfect example of how to use Green Belt, to maintain its openness. Floodlighting has been sympathetically installed and does not impinge on neighbouring houses.

Surbiton Hockey Club hockey club ladies produced 3 Rio gold medals in 2016, including winning goal scorer Hollie Webb. The success of the Olympics, both London and Rio, in raising the profile of the sport cannot be underestimated. A large number of children,

23 inspired by sporting heros and heroines, are able to easily access the club which runs weekday sessions running under floodlight.

Sugden Road Allotments – is a thriving facility. It is a well tended and much loved amenity.

Long Ditton Cricket Club – our very own Oval

In short, area 58 provides an important setting contributing to the character and strong sense of place, particularly for entrants to and those leaving Elmbridge. It makes a unique contribution to the overall character of the area, as the first hint of what the Borough has to offer and the last taste of openness. It must not be needlessly destroyed.

Photographic evidence

The two photos attached to this assessment may appear to have been included with an unusual emphasis on the state of the hockey club car park, asphalt and road materials, none of which is in any way relevant to, or reflective of, the Green Belt nature of the area. This may be Arup’s Re‘view’ however we would like to present and alternative, residents view.

Green belt review study - conclusions 43 We strongly object to the conclusions of the Arup report that, whilst accepting the area is part of a strategic area, one that checks the sprawl of London and prevents coalescence, the report concludes that the parcel contributes to neither of these purposes “strategically” and sits as a “stand alone parcel’, suffering encroachment and is disconnected to the wider countryside”.

44 We argue the area is on the front line in preventing further sprawl and needs to be considered and valued for its own sake. It contributes by its many uses and also countryside to the benefit of those living in the adjoining urban areas. Strategically, area 58 sits alongside the principal road gateway into Elmbridge, and indeed Surrey, for travellers from Greater London. Without it, Elmbridge would just merge imperceptibly into the sprawl of London.

45 We accept that a major road abuts its southern border but we feel this fact has been unfairly magnified in much of Arup’s analysis. The fact that area 58 is bounded by development on three sides makes it all the more important not to allow it to be merged into a part of suburbia. The whole point is that its openness contrasts strongly with the built form surrounding it. Instead more emphasis needs to be placed on the areas intrinsic value to preventing sprawl and coalescence and providing valued recreation to nearby urban dwellers. Overall, under a more objective assessment, we firmly believe that Local Area 58 should be deemed to be Strongly performing.

Conclusions

46 The Councils 'preferred Option 2' is premature as the Council has not demonstrated the ‘exceptional circumstances’ required to release Green Belt, as required by national policy and as re-confirmed in the Government’s recent Housing White Paper published in February 2017). Much more work is needed to assess urban capacity of the Borough and to explore opportunities for meeting housing needs with surrounding local authorities, particularly given that over 50% of Elmbridge’s housing needs are a direct result of people moving from London.

47 We are concerned that the necessary infrastructure to support development on Area 58 will not be forthcoming. EBC cannot rely on the County whose funding gap is significant, therefore continued development as suggested will adversely impact the lives of current residents.

48 Strategically, the Long Ditton Green Belt, epitomises the function of preventing the urban sprawl of Greater London, out into Surrey. It sits alongside the principal road

gateway into Elmbridge, and indeed Surrey, for travellers from Greater London. It provides a clear visual indication of the transition from the London conurbation to the more green and open environment of Elmbridge. It plays its part in preventing the Greater London sprawl out into Surrey, and local settlements merging (Hook, Long Ditton and Hinchley Wood). These critical roles are not reflected in the Arup report which assesses this area as ‘weakly performing’ Green Belt.

49 Should this north-eastern corner of the borough becomes indistinguishable from its built-up neighbour, the distinctive character of the borough would be irrevocably lost, and the quality of life for all concerned would be greatly diminished. Such an approach does not sit easily with the social, environmental and economic agenda which requires us to act sustainably so that future generations do not inherit an asset in a worse condition than that in which we inherited it.

50 We do not believe that the Council has properly evaluated, or presented, the community value of Area 58. The LDRA is opposed to building on Green Belt anywhere in Elmbridge, to sacrifice it would be detrimental, short-sighted and irreplaceable. Once lost, Green Belt is gone, forever.

51 Conservative and Lib Dem manifestos have long preached the importance of preserving the Green Belt as a guarantee of green spaces for the health and wellbeing of the urban communities. Should Area 58 be declassified and subsequently developed, not just Long Ditton, and its surrounding Elmbridge neighbours, but also Surbiton, Chessington and Hook will have lost an important green ‘lung’.

52 Should other Surrey Boroughs offer up Green belt as an ‘easy option’ we are concerned the integrity of the MGB will be compromised. Better for the Government to openly debate and decide where it stands on the subject, than to unhinge their electoral pledge ‘by the back door’?

53 LDRA is committed to defending the Green Belt by reaching out both to EBC and to our local MPs. The MP for Kingston and Surbiton, James Berry, is leading a campaign against Option 2. Our own local MP has been pointing to this being a matter for local democracy. We do not agree that the process being followed resembles local democracy at its best. We have however encouraged local residents to respond to the consultation, which has been challenging in the timescale, to make it clear to their elected representatives, at all levels, the extent of their opposition.

54 The Council rightly argue that they must progress with the plan as quick as possible given the risks associated with an out of date housing target and the lack of a five-

year land supply. The Council must explore ways of managing the local plan review that will not prematurely jeopardise valuable Green Belt, or place unacceptable stress on an already stressed infrastructure system within the Borough, particularly given the significant issues this area will have to face in the not too distant future e.g. the London Plan review, Crossrail 2 and Heathrow expansion.

55 A pause to consider what these options are and to undertake further technical work, including a comprehensive assessment of the (realistic) urban capacity of the Borough, will ensure that a robust, deliverable plan is taken forward and will allow time to digest the implications of the White Paper and consequential changes to national policy, and of the Neighbourhood Planning Bill. It will also allow time for more dialogue with the Greater London Assembly, Royal Borough of Kingston and Surrey Authorities to consider what the strategic implications are of meeting development needs in the wider area, for the Metropolitan Green Belt and for infrastructure.

Long Ditton Residents Association

February 2017