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

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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 1 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 2 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 3 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. 5 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.
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