Redhill Aerodrome – Proposed New Garden Community “Redhill Garden Community”

22 December 2016 Thakeham Homes Letter of Representation - Regulation 18 Sites Consulation

Planning Policy Tandridge District Council Council Offices Jonathan Steele 8 Station Road East E: [email protected] Oxted RH8 0BT 2 Charlotte Place Southampton SO14 0TB T: +44 (0) 238 071 3900 VIA POST & E-MAIL savills.com

Dear Sir/ Madam

Local Plan: Sites Consultation – Regulation 18 Redhill Aerodrome – Proposed New Garden Community “Redhill Garden Community”

1.1. We write to you on behalf of Thakeham Homes to submit proposals for the redevelopment of Redhill Aerodrome, for a large scale residential-led new settlement in the form of a garden village (herein referred to as “the Site” or “Redhill Garden Community”).

1.2. The opportunity to redevelop the Site has only now come forward and therefore the potential for this Site to accommodate such a development has not been fully assessed as part of the Local Plan process to date. We request that the Site is considered as a residential-led allocation in the emerging Tandridge District Local Plan, in line with Part 2 of the Sites Consultation document which considers the options for New Settlements in accordance with Approach Number 6 of the Issues and Approaches document. We can confirm that the Site is in a single ownership, with a single promoter and the land is available for development now. This Site has not previously been assessed for redevelopment as it was not available. The technical evidence submitted with this representation also demonstrates that the Site is achievable, suitable, and deliverable as defined by footnote 11 of the National Planning Policy Framework (NPPF).

1.3. The part previously developed Site is located on the District boundary with Reigate & Banstead. It has the potential to deliver approximately 4,500 dwellings and a range of other uses to support a sustainable garden village settlement, including for example education, community and employment in line with Approach Number 6 of the Local Plan distribution scenarios. In addition the development proposals will enable the development of significant new infrastructure, notably an east-west road link connecting the A23 with a new junction onto the M23. This new link would benefit existing local communities and surrounding settlements, enable a new connection to the East Surrey Hospital and facilitate and enhance public transport links to Gatwick.

1.4. The delivery of a new settlement represents a positive and sustainable opportunity to meet a significant proportion of the objectively assessed housing needs of both Tandridge District and Reigate and Banstead Borough. The full benefits of the proposals are discussed further in Section 2 of this representation, all of which correspond with Coast to Capital Local Enterprise Partnership (LEP) objectives.

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1.5. Please find enclosed the following Technical Notes and documents, to be read in conjunction with this letter:

 Appendix 1: Redhill Garden Community Vision Document prepared by David Lock Associates, December 2016  Appendices 2-6: Topic Papers prepared by Mouchel (Transport, Air Quality, Noise, Flooding & Drainage, Utilities), December 2016  Appendix 7: Landscape & Visual Baseline Appraisal prepared by Davies Landscape Partnership, December 2016  Appendix 8: Initial Landscape Capacity Study prepared by Davies Landscape Partnership, December 2016  Appendix 9: Initial Green Belt Technical Note, prepared by Davies Landscape Partnership, December 2016  Appendix 10: Ecological Delivery Assessment prepared by EAD, November 2016

1.6. Please be aware that at this stage of the proposals development, any plans submitted are only to be considered as indicative concept drawings and are subject to change as further work and engagement is undertaken with key stakeholders and local communities.

2. Planning for the future of Tandridge – The Key Benefits of Redhill Garden Community

2.1. Redhill Garden Community provides a pivotal solution to ensure that development needs of Tandridge District Council (TDC) and Reigate and Banstead Borough Council (RBBC) are met in a sustainable and positive manner. The critical mass associated with the delivery of a new settlement enables the provision of new infrastructure, of a scale to benefit the wider sub-region. The opportunity is unique, and can provide for a substantial proportion of the objectively assessed housing need in a coordinated way. The delivery of the Garden Community would also demonstrate positive planning, and a commitment to the Duty to Co-operate across the relevant Housing Market Areas.

2.2. The NPPF outlines that Green Belt boundaries may be altered in exceptional circumstances through the preparation or review of the Local Plan (paragraph 83). Pressing housing needs along with a number of other factors, mean that exceptional circumstances do exist to review Green Belt boundaries in Tandridge and Reigate and Banstead. The exceptional circumstances in relation to the proposed development, are discussed throughout this representation. The NPPF is clear at paragraphs 14, 47, 157 and 182 of the need for a positive approach to plan making, to ensure a significant boost in the supply of housing, and wherever possible to meet identified development needs. This must of course be undertaken in a sustainable way, to ensure that environmental, social and economic factors are all considered. The proposed development of Redhill Garden Community will assist TDC & RBBC to meet their housing needs and achieve sustainable development in line with the objectives in the draft TDC Local Plan. Redhill Garden Community also meets the tests sets out in the NPPF, and the criteria outlined in the Department of Communities and Local Government Garden Village prospectus (July 2016).

2.3. As outlined in the SWOT Analysis (Table 7.1) The delivery of a new settlement at Redhill Garden Community would:

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 Would enable regionally significant infrastructure (notably the delivery of the A23- M23 link) assisting access to, and improving connections from communities in Tandridge and enhance accessibility to East Surrey Hospital (see paragraphs 2.6 & 4.10 – 4.18);  Promote public transport connections and enhancements from the Site, to key employment areas including Redhill, Crawley and Gatwick (see paragraphs 4.10 - 4.18);  Reduce the risk of flood risk through alterations to existing culverts and the potential creation of floodplain compensation (see paragraphs 4.32 - 4.36);  Connection of currently isolated landscape and ecological assets within the surrounding area. This proposed new community should improve significantly the ecological value of the Site. This development would create a new and rich landscape setting including wildlife corridors and recreational opportunities, transforming the ecological and landscape value of the land. A core driver will be to maintain the visual separation with South Nutfield (see paragraphs 4.13 – 4.15, 4.20 - 4.24, 4.30 - 4.39 & 6.11 - 6.18).

2.4. Overall the proposals will fulfil the three dimensions of sustainable development, economic, social and environmental, as set out in NPPF paragraph 7. A proposed development of a new garden village settlement of this scale presents an opportunity to address wider strategic issues which cannot be addressed by smaller scale development. This new community would provide for a significant proportion of the market and affordable housing required in both TDC and RBBC.

2.5. The development will create a new sustainable community with two new primary schools and a new secondary school. It will have a neighbourhood centre with convenience shopping, places to eat and drink, healthcare facilities, places for people to meet and to hold events. There will also be one or two local centres with local scale services and facilities.

2.6. The proposed development will improve strategic connections across the whole region and will act as a catalyst for delivering primary infrastructure. The proposals provide a range of benefits including:

 Improved general and emergency connections for the East Surrey Hospital to the motorway network (M23/M25), employment areas, Gatwick Airport and to existing local communities;  Improved accessibility for local communities and the wider surrounding area to the motorway network for journeys east and south;  Potential for the reduction in the use of the smaller local roads around the Site by through traffic, improving the environment for existing communities;  The potential for reliable, fast and frequent public transport links using new connections to and through the new community;  Improved public transport connection to the surrounding settlements and railway stations;  Connection of the extensive networks of public footpaths and bridleways through the Site improving access to the wider countryside.

Economic Benefits

2.7. The estimated economic benefits arising from a development of approximately 4,500 dwellings are substantial: -

 Generation of 4,476 person years of construction employment, including 2,797 person years of direct construction employment;  This is equivalent to 298 jobs over the 15 year construction phase, with 186 direct construction jobs during this time;  Generation of 2,779 jobs during the operation phase of the development, with 1,853 direct operational jobs;  A net increase of 2,197 jobs compared to the current employment uses at the Site;

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 Generation of total GVA of £146.6 million to the economy, with £127.7 million direct GVA benefits;  This represents a net GVA increase of £116.5 million compared to the current Site uses  Planning gain, secured via a Section 106-led approach, which may be in the order of circa £40 – £65 million;  Council tax of £12.3million p.a. and business rates of £837,900 p.a. could be yielded from the development by TDC and RBBC.

Promotion of Site to date

2.8. As the District is aware, Thakeham Homes has begun an ongoing process of engaging with both TDC and RBBC. To date the following has been undertaken:

 15th September 2016 - Introduction of the Site and proposed development to the Head of Planning of both local authorities. At this very early stage in the development of the proposals this document set out the proposed development, high level potential benefits of the scheme and the broad delivery timetable.  10th October 2016 – Formal submission to Reigate and Banstead Borough Council Development Management Plan Regulation 18 consultation setting out the proposed development, the impact of the proposals on the emerging plan and associated evidence base and requesting the Site is safeguarded for future residential development to be brought forward as part of the Local Plan Review.  10th October 2016 – In addition to the submission to the Development Management Plan the Site was submitted to the Reigate and Banstead Borough Council Strategic Housing Land Availability Assessment.  18th October 2016 – Submission of the Site to the Tandridge District Council Housing and Economic Land Availability Assessment.

3. Site & Surroundings

3.1. The Site is located across the administrative boundaries of TDC and RBBC with the majority of the Site (70%) within Tandridge District. The total area of the Site is approximately 228 hectares (ha) with the largest area of land concentrated on the main site of the aerodrome, with some smaller parcels of land to the north west and east of the aerodrome.

3.2. Redhill Garden Community is located to the south east of Redhill, south of South Nutfield and west of the M23 motorway corridor. The smaller settlements of White Bushes and Salfords are located to the west of the Site along the A23. The Site is north east of the settlement of Horley. The Site has an existing vehicular access from Kings Mill Lane and a further access on Crab Hill Lane.

3.3. The Site is part previously developed. The Site is currently in use as an aerodrome with runways and ancillary employment uses (most in relation to aviation). The Site includes a number of internal roads and taxiways and existing buildings which range from large industrial aircraft hangers, typically two storey in height, a single storey cafe/restaurant, aerodrome terminal buildings and air traffic control tower, and a number of workshops and office units. The largest building on Site (Bristow House) is four storeys in height. The total floorspace of the buildings on the Site is circa 350,000 sq.ft. 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 previously developed (brownfield land), provided that it is not of high environmental value”.

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3.4. The Site is relatively flat and consists mainly of mown grass, with very limited other vegetation or trees throughout. The majority of the Site is self contained and well screened from the surrounding area by mature trees and woodland and by the surrounding topography. The Site is at a lower level than the surrounding land and coupled with the existing extensive screening there are only very limited views of the Site from the surrounding area. Areas within the Site have varied landscape sensitivity and therefore some areas have greater potential for development in relation to landscape capacity (see Figure 11 of Appendix 8). Areas of the site, for example which are elevated or border South Nutfield, have lower landscape capacity (greater sensitivity), these areas will be carefully considered through Masterplanning to ensure the landscape and visual impact of the proposed development is minimised. The Masterplanning and landscape design process is iterative, and the landscape appraisal will respond to the process. The landscape work, alongside the planning background has informed an overall conclusion that the site is of low to medium sensitivity with respect of the contribution of the whole Site to the purposes of the Green Belt (see Appendix 9, Figure 3).

Site Designations

3.5. The Site is designated as Green Belt and the eastern section of the Site is within a Biodiversity Opportunity Area. There is also a Site of Nature Conservation Interest (SNCI) in the western section of the site. Although the Site itself has relatively low ecological and landscape quality, the Site is nearby to areas which are environmentally sensitive, including (these are discussed further in the Ecology Deliverability Assessment Appendix 10):

 The Surrey Hills Area of Outstanding Natural Beauty approximately 3.5km north of the Site;  The Mole Gap to Reigate Escarpment Special Area of Conservation and Site of Special Scientific Interest (SSSI) approximately 4.5km north west of the Site;  Sites of Special Scientific Interest (SSSI) at Reigate Heath and Godstone Ponds located circa 5km to the west and east of the Site.  A number of other SNCI/ Local Nature Reserve are located beyond the Site between 1–4km from the Site.

3.6. There are no listed buildings located on the Site. However there are a number of heritage assets located on the boundaries or in close proximity to the Site. These include:

 Hale Farm House – Grade II listed (ref: 1377599) to the north east;  Granary Cottage – Grade II (ref: 1029875) to the north east;  Hamme House & Garden Wall – Grade II (ref: 1377596 & 1029871) to the north;  Staplehurst Farm House – Grade II (ref: 1295057) to the north west;  Little Staplehurst – Grade II (ref: 1029001) to the North West.

4. Proposed Development – Masterplan, Components & Vision

4.1. The vision for Redhill Garden Community is to create a new large scale residential led development of approximately 4,500 new homes based on Garden Village principles and the principles set out in the Department of Community and Local Government Garden Community Prospectus. The development will not only provide a significant number of residential dwellings helping to ensure the needs of present and future communities are met but create a self contained and well balanced community with its own educational and healthcare facilities, employment and retail spaces.

4.2. This Garden Village will include public open spaces, local and neighbourhood centres and provide a range of benefits both on and off-site to local communities. New strategic roads and public transport connections will ease current congestion in local settlements not designed to accommodate the current high levels of traffic, and will encourage and allow realistic use of sustainable methods of transport. Overall this will be a sustainable community contributing to the future needs of local communities and providing benefits that no other development in the area can provide.

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Principles behind Initial Masterplan Concepts

4.3. Enclosed with this letter is a Vision Document which outlines the emerging concept Masterplan principles (Appendix 1).

4.4. The concept Masterplan for the Site (which includes 3 illustrative options) has been developed to reflect the opportunities and constraints of the Site. The guiding principles of the design are based on the Garden City principles. Whilst there is no single definition of what a Garden Village or Garden City is, there are a number of principles which are the core to such a development. Thakeham Homes and the project team have studied the Garden City Principles carefully and considered how they might be realised at Redhill Garden Community. As a result Thakeham Homes can commit to the core principles in the planning, design, development and management of the new Garden Community on this Site.

4.5. In addition to the economic benefits outlined in Section 2 of this representation, the proposed development will also provide a range of social infrastructure which will support the new community as well as improving facilities for the wider existing communities. These will be subject to further testing but these include the potential to provide:

 A new medical centre with capacity for up to 6 GP’s  Funding to support expansion of existing services at the East Surrey Hospital (through Section 106) will alleviate any additional generated demand  Two new primary schools with combined capacity for up to 840 students  A new secondary school with capacity for up to 1,120 students  Flexible, multi-use community meeting rooms and halls (up to 3) within the proposed local centre, or shared use arrangements wit proposed school facilities to allow community use  Up to 60.2ha of open space, equivalent to 5.4ha per 1,000 people, including: o 18ha of playing pitches. o 9.0ha of parks and gardens o 6.8ha of amenity space.

4.6. Table 1 overleaf provides a summary of the core guiding principles.

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Table 1: Garden City Principles – Redhill Garden Community

Investment in facilities and services for the benefit of the new community – the Garden Community will include onsite facilities for education, health, welfare, community development, local shopping, recreation and leisure and local employment. Many of these facilities will be owned and managed by, and on behalf of, the whole community Strong vision, leadership and community engagement – Thakeham Homes is committed to working with existing communities and members of the new community through a range of consultation and engagement events Long-term stewardship of assets – the potential for a Community Trust owned and managed by the local community is being explored to empower residents to take responsibility for their environment and the services and facilities provided Mixed-tenure homes and housing types that are genuinely affordable for everyone – this new Garden Community will provide approximately 4,500 new homes and will include a large number of affordable homes and a wide mix of sizes and types of property. The delivery of such a large number of homes provides the opportunity to create a varied mix of homes for all members of the community. A robust range of employment opportunities in the Garden Community itself, with a variety of jobs within easy commuting distance of homes – the Site is located close to a wide range of employment opportunities within the surrounding area and in short commuting distance including Gatwick Airport, Crawley, Brighton and London. The proposed development will increase connectivity to these locations and allow for more sustainable methods of transport to them. In addition on-site employment will be provided both within local and neighbourhood centre and specialist employment areas. Beautifully and imaginatively designed homes with gardens, combining the very best of town and country living to create healthy homes in vibrant communities – This is a key principle which underpins the way in which Garden Communities are designed, in the case of Redhill Garden Community it will include:  ready access to an accessible network of natural green spaces within and around the new community  innovation in environmental performance to minimize the global impacts of development;  beautiful, well-proportioned and liveable homes using modern design and materials  provision of gardens and open spaces for every home  investment in community development to maximize the enjoyment and engagement of those that choose to live here Development which enhances the natural environment – At present the Aerodrome is a widely barren landscape with few trees, hedgerows or natural habitats. The development will deliver a much richer set of habitats across gardens and new landscaped areas and buffers.

Strong local cultural, recreational and shopping facilities in walkable neighbourhoods – there will be readily accessible services and facilities appropriate to the scale of the new community designed to be accessible from homes throughout the community within walkable neighbourhoods of approximately 60ha so that no one is more than a five minute walk away.

Integrated and accessible transport systems – walking, cycling and public transport networks connecting to key destinations will be implemented from the very beginning of the project so that the very first to the very last new residents have a wide and sustainable choice. This will become a highly sustainable community less reliant on driving by car.

A strategic approach – the plan for this new Garden Community will be a comprehensive strategy for the whole of each Council’s area and for how this new development will integrate with existing communities and deliver benefits for everyone within a wider area – new connections, new services and facilities, new accessible green space, more choice. And the plan will set out in full how this new community will be created, in stages, over an extended development period.

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Master Plan Options

4.7. In order to develop a concept Masterplan it was key to take into account of the constraints and opportunities on the Site including where key on and off site features are located and the relationships between them. The initial assessments and analysis of the Site have identified the following key factors to be taken into account at this early stage:

 The area of potential high noise impact from the M23;  The watercourses and their potential to flood;  The existing woodland on the Site and surrounding sensitive environments,  The need to create buffer areas to existing communities, having regard to areas of medium landscape sensitivity, utilising green infrastructure particularly in relation to separation from South Nutfield.  The desire to create a visual link across the Site from the more sensitive views of the Greensand Ridge to open countryside to the south  The desire to create east-west green corridor across the Site  The likely realistic locations on the new M23 junction and link road

4.8. These factors combine to determine a development capacity of approximately 4,500 new homes in an extensive green landscape, with space for all the services and facilities that the new Garden Community will need. There are options, including how the new Garden Community will connect to the strategic road network, and which will influence how the development is designed, these options relate to:

 The location of a new junction on the M23  The alignment of a new strategic road in relation to the East Surrey Hospital and connection to local road network  The route of a new strategic road through the heart of the Site; and, in relation to this  The location of Neighbourhood Centres and associated facilities

4.9. Based on the high level considerations 3 illustrative concept plans have been designed as outlined in the Vision Document (Appendix 1). These options are presented for information only as they will be updated as more detailed technical assessments are completed and stakeholder engagement is undertaken. The future detailed surveys, additional technical information and ongoing consultation with both local authorities and the local community will continue to inform the development of the proposals and will likely result in a final Masterplan which reflects elements of each of the 3 concept plans depending particularly on final chosen location of the M23 junction and link road.

Proposed Movement Strategy

4.10. By creating a new community of this size on this site the need for the new residents to travel can be minimised as the proposals can include features such as employment and retail space, education and healthcare on site, unlike smaller developments, reducing the need for residents to travel. This approach to movement is supported in the NPPF paragraphs 34 & 38 which set out that “Plans and decisions should ensure developments that generate significant movement are located where the need to travel will be minimised and the use of sustainable transport modes can be maximised” and that “For larger scale residential developments in particular, planning policies should promote a mix of uses in order to provide opportunities to undertake day-to-day activities including work on Site. Where practical, particularly within large-scale developments, key facilities such as primary schools and local shops should be located within walking distance of most properties”. The scale of the proposed development at Redhill Aerodrome provides the critical mass needed to be able to provide these facilities and services on site.

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4.11. Enclosed are technical notes prepared by Mouchel with respect of highways and other engineering matters (Appendices 2 - 6). These demonstrate that there are no technical considerations which would prevent the delivery of the development following detailed assessment and an appropriate mitigation strategy.

4.12. The overarching principles of movement within the proposed development are based on the provision of a high quality east-west road corridor across the Site to provide area wide benefits and to also serve development land parcels within the Site. This will improve accessibility to the wider area and assist in relieving congested areas for example Redhill and potentially the A23 south of the Site. The Link Road would connect with M23 to the east via a new junction on the motorway and improve connections to the East Surrey Hospital and A23. Improvements to other road corridors are being explored to enhance capacity and safety.

4.13. The Link Road will connect to public transport through enhancing existing routes and local bus services will be extended into the Site with the potential for a public transport hub within the Site. The local bus connections will be able to provide access to the local rail stations, including Redhill, Earlswood, Salfords and Horley. Nutfield rail station will be accessible from the Site via walking or cycling through South Nutfield. Cycle enhancements will likely be proposed at nearby railway stations.

4.14. There is potential for upgrade to local footpaths to bridleway status to allow for use by cyclists. Connections can be made by footpath/ National Cycle Route 21 to Redhill, Earlswood, Salfords and Horley rail stations. A new pedestrian/cycle connection to South Nutfield rail station is also being explored as part of the proposal.

4.15. The NPPF supports in paragraph 29 & 30. the need to promote sustainable modes of transport “giving people a real choice about how they travel” and “In preparing Local Plans, local planning authorities should therefore support a pattern of development which, where reasonable to do so, facilitates the use of sustainable modes of transport”.

Location of M23 Junction & Location of Link Road

4.16. At this stage the project team believe that there are two points at which a new junction could be created with the M23, one to the northeast of the Site just south of South Nutfield, and the other to the southeast of the Site where Crab Hill Lane crosses the M23.

4.17. In relation to the link road the design, there are benefits arising should the road to pass to the south of the main development area along the north side of the Salfords Stream. There is the potential that this alignment will have the least impact on the more sensitive parts of the Site in landscape and ecological terms. An alternative is for the road to follow a more northerly line following and crossing the Redhill Brook before passing to the north of the existing Aerodrome buildings. There are also options for a variation on the two main link road locations in relation to how the road crosses through the Site. These options are shown in the Vision Document Appendix 1.

Connection to A23

4.18. At the western end of the Site the road will connect to the local road network in order to connect to the A23, with the potential for a connection to the north or to the south of the East Surrey Hospital.

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Location of Neighbourhood Centre / Village Centre

4.19. The location of the Neighbourhood Centre/Village Centre will be determined by the final location of the link road within the Site. On the southern alignment it would be at the point where the road meets the north-south view corridor and where the view opens out across the Salfords Stream. On the northern alignment, the Neighbourhood Centre would be around the northern end of the view corridor facing over the Redhill Brook.

Landscape Capacity & Green Belt

Landscape Baseline

4.20. Appendix 7 provides the Landscape & Visual Baseline Appraisal (prepared by Davies Landscape Architects, December 2016). This provides the baseline for the initial landscape and Green Belt assessment work. The process is iterative, and will inform and be informed by ongoing Masterplanning. The Masterplan Concepts provided in Appendix 1 have been based on this initial landscape work. The Baseline outlines:

 The Study area for the Zone of Theoretical Visibility  Policy and Site context relevant for landscape  Landscape context including field boundaries and agricultural land quality  Initial Visual Assessment

4.21. The work has informed the Landscape Capacity conclusions (Appendix 8, notably Figure 11), which outlines the landscape capacity of various parcels of the Site, the landscape capacity of each parcel of land will influence the development on the site for example density of development and need for landscape mitigation. Notably Parcels A3, A5 and C (those central to the Site) have Medium to High Landscape Capacity for development and would therefore be locations more appropriate in landscape terms for higher density development. Clearly, through Masterplanning the density and location of development can be adapted as a result of the baseline conclusions.

Landscape Capacity & Strategy

4.22. Appendix 8 provides an Initial Landscape Capacity Study (prepared by Davies Landscape Architects, December 2016). This study provides a basis and further evidence which should be taken into account with respect to the Tandridge Landscape & Capacity Study (October 2016) which has not fully assessed this Site. The TDC Study includes a seven stage process into which the attached Landscape Capacity Study and further work should be taken into account. The project team are in a position to assist the ongoing work on the TDC Capacity Study through 2017, as part of further consultation and Masterplanning work.

4.23. To inform Masterplanning, the Capacity Study identifies four principal and potential parcels (A to D) and a number of sub parcels within A (A1-A5). This provides an initial conclusion based on landscape value and sensitivity. Overall, the site landscape character and sensitivity ranges from slight to moderate to substantial. This will influence the Masterplan for the site and be a factor in assessing the areas of the site most appropriate for development, the density of development and the need for landscape mitigation and enhancement. The initial Landscape Capacity Study demonstrates that landscape capacity is not a factor limiting the development of the site.

4.24. In respect of onward Masterplanning, a landscape led scheme in line with the Garden Village approach will ensure that key characteristics of the wider landscape are considered in the Masterplan and that there will be significant landscape enhancements associated with the development including mitigation measures where possible. Priorities identified at this early stage are to:

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 Ensure that the identity of South Nutfield is retained through protection and enhancement of permanent landscape buffers to the north;  Retention and enhancement of key sensitive characteristic landscape features such as hedgerows, hedgerow trees, streams and woodland;  Increased hedgerow and woodland planting to help assimilate the development into the landscape;  Reinforcement and enhancement of the existing boundaries bordering the lanes;  Minimising visual harm to receptors in the area;  Minimising the impact on the wider character;  Increase footpath and cycle access across the Site through green corridors and reconnect the existing footpath network; and  Provide an integrated and well connected green infrastructure that will: o assimilate the development into the surrounding landscape; o minimise visual harm; o maximise opportunities for biodiversity; o provide formal and informal recreation and provide a stimulating environment to live work and play.

Green Belt Review

4.25. Enclosed with this representation is an Initial Green Belt Technical Note (prepared by Davies Landscape Architects (Appendix 9). The work is an ongoing assessment to provide a critique and narrative of how both the RBBC and TDC Green Belt evidence base relate to one another and assesses the Green Belt purposes of parcels of land within this Site. The main Green Belt factors affecting the site relate to the interpretation of the NPPF defined purposes of the Green Belt (paragraph 80) and the results of the Davies Landscape Green Belt Review which identified the need to ensure separation between the Site and the settlements of Redhill and South Nutfield. The purposes of the Green Belt are:

 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;  All Green Belt land fulfils Purpose 5 – To assist in urban regeneration, by encouraging the recycling of derelict and other urban land - and it is consistent with the TDC Green Belt methodology and other Green Belt reviews that this is not assessed. However this must be weighed against wider land availability, notably the proportion of development needs which may be accommodated on previously developed/ non Green Belt land.

4.26. The Initial Green Belt Technical Note has regard to the applicable and emerging TDC and RBBC evidence base.

TDC Green Belt Assessment (Part 2) – October 2016 & Reigate & Banstead Development Management Plan (Regulation 18) Green Belt Review – June 2016

4.27. The TDC Green Belt Assessment Part 2 prepared by TDC assesses the Areas for Further Investigation identified in Part 1 of this assessment. The Site, falls within parcel GBA 029 in part 1 of the assessment and presently does not fall within an Area for Further Investigation. However, Further Investigation Areas 030 and 028 are in close proximity to the site. Following review, Area 030 has been identified as an area containing a settlement to be carried forward and considered through the Local Plan process to be inset from the Green Belt. The process of Green Belt Review assesses the contribution defined parcels of land make to the defined Green Belt purposes. The outcome of this process is that Potential Major Development Areas may be ascertained (PMDA) (in Green Belt terms only).

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4.28. The Reigate & Banstead Green Belt Review has considered sites which have been identified as potential locations for urban extensions. The review has therefore not considered this Site as at the time of production of the Study the site was not known to be available.

4.29. The present situation is therefore that the Redhill Garden Community Site has not been fully assessed by the Green Belt review by TDC or RBBC in relation to how this large part previously developed area of the Green Belt contributes to the five purposes. The Technical Note enclosed with these representations provides a baseline to inform the further evidence including:

 The majority of the Redhill Aerodrome Site has recognisable and permanent features that would allow for a Potential Major Development Area (PMDA)  Figure 1 of the Technical Note provides evidence of the 21 potential permanent features on the Site boundary. These should inform Masterplanning.  The initial assessment of GBA 029 needs to be reviewed, in light of the evidence submitted, and promotion of Redhill Garden Community. Due regard needs to be had of the evidence which indicates that through proper assessment of the relevant parcel, the majority of the Site contributes to only 1 Green Belt purpose, with some parcels nearest to existing settlements contributing to 2 purposes (see Figure 2 of the Technical Note).  Through Masterplanning, and landscape design, those areas of elevated open space, and which contribute to 2 purposes of the Green Belt (and hence of medium Green Belt sensitivity), may be kept permanently open (see Figures 2 and 3 of the Technical Note)

Table 4.1: Contribution of Redhill Aerodrome to Green Belt Purposes.

Purpose 1 - To Check the unrestricted No contribution. The Site does not adjoin the main sprawl of large built up areas; urban area of Redhill.

Purpose 2 – To prevent neighbouring No contribution in preventing Nutfield and South towns merging into one another; Nutfield from merging. Through Masterplanning and landscape design, the separation of the proposed development with South Nutfield will be maintained.

Purpose 3 – To assist in safeguarding the Yes. By definition, the development on areas of non countryside from encroachment; previously developed land would represent encroachment. This is the case for any Greenfield Green Belt release. The specific characteristics of the Redhill Aerodrome site are that part of the site is previously developed and therefore the relative impact on this purpose is reduced. Should TDC release land from the Green Belt it is inevitable that land which contributes to this purpose is released.

Purpose 4 – To preserve the setting and No contribution, as already recognised by the TDC special character of historic towns; Assessment.

Purpose 5 – To assist in urban Consistent with other Green Belt reviews that this is regeneration, by encouraging the not assessed, though this must be weighed against recycling of derelict and other urban land wider land availability, notably the proportion of development needs which may be accommodated on previously developed/ non Green Belt land.

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4.30. In relation to the exceptions test, as set out in paragraph 83 of the NPPF, and taking into account the need to promote sustainable patterns of development when reviewing Green Belt boundaries (paragraph 84), the release of this Site from the Green Belt as part of an allocation in the Local Plan for a new settlement, would meet these tests.

4.31. The exceptional circumstances for the delivery of this strategically important new garden community include economic and social evidence and objectives. At 94% Tandridge District has a large amount of Green Belt designated land and neighbouring authority Reigate and Banstead Borough has 70% of its land designated Green Belt. Whilst it is key to ensure the Green Belt is maintained where it fulfils the five purposes, the need to provide housing and other infrastructure in both authorities should also be given significant weight. Redhill Aerodrome is a part previously developed Site, the release of which would result in a reduction of only 0.68% of the total Green Belt in Tandridge and only 0.76% in RBBC. The Site’s release and redevelopment would therefore allow for the most important Green Belt land to be protected from development pressure whilst ensuring that the housing supply needed is provided. As outlined in Section 2, Redhill Garden Community is an unique opportunity for TDC alongside RBBC to jointly deliver a significant proportion of onward housing needs in a sustainable manner.

Flood Risk & Drainage

4.32. Enclosed at Appendix 5 is a Topic Paper provided by Mouchel related to Flood Risk & Drainage.

4.33. The Redhill Brook runs through part of the eastern area of the site and the south eastern area of the site is partially in Flood Zone 2 and 3 and in a flood warning area, with areas of surface water flood risk. The site is however not at risk of flooding from reservoirs or in the Environment Agencies Source Protection Zones (SPZ). ‘Secondary A Superficial Deposit’ aquifer status is associated with the watercourses through the site.

4.34. Redhill Brook is culverted and it is highly likely that the existing culvert, which is located within the main flood risk area, is contributing towards flooding. Culverts are often a factor in flooding problems and their removal or modification may reduce flood risk. Initial investigations have confirmed that the culvert in its current form restricts the flow of water downstream. As well as the potential for reduction in flood risk, de-culverting the Brook would also deliver potential wider benefits in terms of habitat creation.

4.35. In relation to reducing flood risk the potential for opening the culverts to create a channel in this area or diverting the culverts may reduce flood levels on the site. In order to fully assess the impact of removing the culvert both on site and further downstream, detailed hydraulic modelling of the Redhill Brook and other local watercourses is required. In addition the potential for floodplain compensation, and other positive mitigation methods are being investigated, many of which also have ecological and biodiversity benefits. The proposed development also provides opportunities to utilise SUDS such as vegetated systems which combined with significant areas of open green space will assist in managing the flood risk on site.

4.36. The Environment Agency will be consulted on the proposals once the relevant investigations and modelling have been finalised.

Ecology

4.37. Enclosed is a technical note Ecological Delivery Assessment prepared by EAD Ecology (Appendix 10). This confirms that there are no statutory designated Sites within or adjoining the Site. However there is a Site of Nature Conservation Importance (SNCI) and a Biodiversity Opportunity Area within the site. These areas will be subject to further detailed survey. The emerging Masterplan will incorporate an integrated landscape and ecological design that will ensure that the ecological value of the Site is sustained and enhanced. Key elements of the design will comprise:

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 Retention and buffering of the SNCI / woodland habitat within the Site.  Creation of green corridors that integrate retained woodland, stream corridors, hedgerows and trees to create a strong landscape and ecological framework.  Integration of new and retained habitats into extensive areas of green space, which would be attractive to new and existing residents for recreation. This would mitigate the potential risk of increased recreational pressure on designated Sites in the vicinity of the proposed development, including Mole Gap to Reigate Escarpment SAC.  Long-term management of the retained and proposed habitats through the implementation of a landscape and ecological management plan (LEMP).  Support the ecological objectives of the Biodiversity Opportunity Area, including enhancements to the steam corridor to the east of the Site.

4.38. Further ecological surveys are proposed to confirm the status of protected and notable species within the site, but the provision of appropriate mitigation and the delivery of an integrated landscape and ecological design for the proposed development could avoid significant adverse effects and could benefit a range of species. Overall, it is considered that there is the potential for net ‘biodiversity gain’ following the development.

4.39. The project team will consult with Natural England, TDC, RBBC and Surrey Wildlife Trust on the scope of the proposed surveys, assessment and emerging development proposals. This will ensure that both the approach and development accords with national and local planning policy in respect of biodiversity and nature conservation, that appropriate mitigation measures are provided, and that the integrated landscape and ecological design would maximise opportunities for biodiversity.

Air Quality and Noise

4.40. Enclosed at Appendices 3 and 4 are Topic Papers on Air Quality and Noise prepared by Mouchel.

4.41. Both TDC and RBBC undertake passive nitrogen dioxide monitoring with diffusion tubes at various locations across the two authorities. TDC’s 2015 Updating and Screening Assessment indicates that there have been no exceedances of the national air quality objectives in recent years at nearby passive monitoring sites, as does RBBC’s monitoring report. The proposed development will take into account air quality as the design process continues and further surveys are undertaken.

4.42. In relation to noise the primary source of noise on site is likely to predominantly be from road traffic (primarily M23) with some noise also from rail traffic, air traffic and other local sources such as local roads. The proposed development will therefore be designed to locate less noise sensitive uses in these areas and to include mitigation measures to ensure that noise impacts as minimised. This can be achieved through a number of design interventions, including:

 Locate dwellings (and gardens) away from the M23  Investigate potential for screening the M23  Locate non-habitable rooms on facades facing noise sources,  Orientation buildings to provide screening to gardens.

Utilities

4.43. Enclosed at Appendix 6 is a Topic Paper with respect of Utilities. This concludes that there are no high level technical utilities constraints which would prevent the site from progressing, therefore the site is available, deliverable, and suitable for a new settlement.

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5. Emerging Tandridge District Local Plan

Sites Consultation – Position on Redhill Garden Community & Other Strategic Site Opportunities

5.1. The Sites Consultation document has included Redhill Aerodrome as a potential Site for employment (ref: ENA11) under Category 3: Sites outside Further Investigation. The Site has been assessed to be an “amber” Site suitable for employment use with “a medium capacity to accommodate development landscape grounds and may be subject to exceptional circumstances test”.

5.2. The assessment of the Site found that:

 The Site has medium capacity to accommodate employment development in the wider landscape provided it is demonstrated that no adverse impacts on the landscape and settlements setting would arise. Mitigation should include height restrictions to reflect existing built form  The Site is ecologically suitable for development. If developed the pond and its surrounding should be retained.  The Site contains an area at high risk of surface water flooding  The Site should be kept for employment use and it is considered that the Site is available for expansion and intensification  Potential land contamination with Site being within Gatwick Safeguarding Zone and in proximity to land designated as Ancient Woodland and a Biodiversity Opportunity Area.

5.3. The importance of this Site for providing employment space has been considered when producing the proposals for the redevelopment of the Site. The Tandridge Economic Needs Assessment undertaken in 2015 recommends that there is a net additional need for up to 14,500sqm of office floorspace over the plan period to 2033 and that there is likely to be a decrease of between 6.5- 7.9ha of industrial land. The report identifies Redhill Aerodrome (ref: Site 11) as a potential Strategic Employment Site, the assessment however identified the Site had issues including no access to public transport or the strategic road network.

5.4. The NPPF sets out in paragraph 19 that “The government is committed to ensuring that the planning system does everything it can to support sustainable economic growth. Planning should operate to encourage and not act as an impediment to sustainable growth. Therefore significant weight should be placed on the need to support economic growth through the planning system”. The redevelopment of the Site as a new garden village settlement will include employment and retail space in the form of both a new local centre and dedicated employment areas. There is the potential for circa 6-9 ha of employment land in a strategically important location close to the motorway and the new junction.

5.5. The redevelopment of the Site will result in an enhanced quality and quantity of employment space compared to that currently on Site, which is a key aim of the proposed employment allocation of the Site in the Local Plan. The proposed development would also address the issues identified in the Economic Needs Assessment such as lack of public transport connection and limited access to strategic road networks. Therefore by considering this Site instead as a potential location for a new settlement the benefits to employment space would be realised as well as other benefits associated with such as development.

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Potential Location for a New Settlement

5.6. The Strategic Housing Market Assessment undertaken in September 2015, identified an approximate need for 470 residential dwellings per annum (dpa). This number is significantly higher than the current adopted housing target and poses a significant challenge for Tandridge to meet this need sustainably.

5.7. Part 2 of the Sites Consultation sets out two areas (Blindley Heath and South Godstone) which have been considered as potential areas which could accommodate a strategic scale development including at least 2,000 homes, supporting infrastructure, open space and 2.5ha of employment space. This is in line with Approach Number 6 of the Issues and Approaches consultation and is a category in which the proposed development of Redhill Garden Community would fall within. At this stage of the process, Thakeham Homes does not wish to express any detailed opinion on other potential new settlement options.

5.8. This approach is supported in NPPF paragraph 52 which states that: “The supply of new homes can sometimes be best achieved through planning for larger scale development, such as new settlements” and the inclusion of potential locations for a new settlement is welcomed. The approach is also consistent with Government policy to encourage locally led Garden Villages/ Cities. This type of large scale strategic development allows for the delivery of housing to be brought forward alongside essential infrastructure required to support the new and existing communities such as road infrastructure, supporting services such as healthcare facilities, education and employment space.

5.9. In a District such as Tandridge which has a low number of larger settlements (Caterham on the Hill, Caterham Valley, Hurst Green, Limpsfield, Oxted, Warlingham and Whyteleafe) which are located close together and concentrated predominantly in two locations in the north and west of the District, it would not be sustainable to rely only on these areas to deliver all the housing Tandridge requires. The development of the new settlement of Redhill Garden Community would alleviate the pressure on these and the other smaller settlements in the District to accommodate a large amount of housing. This will enable a more dispersed distribution of development. This new settlement option should be assessed alongside the remaining two identified Sites in Part 2 of the Site consultation.

5.10. The Redhill Aerodrome Site is a highly sustainable location for such a strategic development than the two areas identified in the Sites Consultation. It is part previously developed, and located next to existing major infrastructure, notably M23 corridor, and hence within the heart of the Gatwick Diamond (Coast to Capital LEP). There is no evidence that there is available land capable of supporting such a strategic development at the potential other locations, unlike Redhill Aerodrome.

5.11. Redhill Aerodrome is in a comparatively more favourable location than the two present potential options for a new settlement (Blindley Heath and South Godstone) as the proposals include a new junction onto the M23 and a strategic east west link road. Redhill Garden Community would therefore act to alleviate existing traffic. This will allow road traffic to easily access the strategic road network through Redhill Garden Community without the need to travel through the existing settlements in the surrounding area.

5.12. As set out previously the redevelopment to create Redhill Garden Community is an opportunity to create a sustainable new garden community providing housing, infrastructure, employment space, education and healthcare facilities and public open space. This redevelopment would bring significant benefits to the local communities surrounding the Site both in Tandridge and Reigate & Banstead and should be fully considered and assessed through the Local Plan process.

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6. Tandridge District – Evidence Base including Housing and Economic Land Availability Assessment (HELAA)

HELAA

6.1. Redhill Aerodrome has been included in Appendix 8 of the HELAA October 2016 as a Site to be considered within the HELAA 2017. The HELAA considers a number of factors when assessing sites for development and Redhill Garden Community is considered to perform well against these criteria.

Suitability

6.2. When assessed as a whole the Site is suitable for development, as confirmed in part by the inclusion of part of the Site as a potential employment allocation. In terms of a residential led new settlement the Site has no overarching constraints which would prevent development from coming forward and with proposed mitigation and enhancement of the Site it is clearly possible to accommodate such a development on the Site.

6.3. The Site is part previously developed, has existing access and improvements to the access (both pedestrian and car) and highways connections are proposed namely the development of a strategic link road and new M23 junction. The location of the Site allows for this to take place and allows connections by car and public transport to surrounding areas. The existing Site characteristics and features including topography would not prevent development and the proposed size of the development allows for a range of uses to be provided including employment and retail space and community facilities

Availability

6.4. We can confirm that the Site is in a single ownership. Thakeham Homes have an agreed option on the Site and are actively promoting its redevelopment. The Site is available now with all existing tenants on the Site notified of the Site’s intended redevelopment in due course. We are not aware of any legal or ownership issues or other factors in terms of availability that would limit the Site.

Achievability

6.5. Paragraph 21 of PPG (ID ref. 3-021-20140306) states that a “Site is considered achievable for development where there is reasonable prospect that the particular type of development will be developed on the Site at a particular point in time” and that this is directly linked to economic viability of a Site and the capacity of the developer to complete and let or sell the development over a certain period. Based on the experience and expert knowledge of Thakeham Homes, a successful house builder, and the wider project team, this Site is considered to be achievable in line with the guidance set out in the PPG. The scale of the proposed development will ensure economic viability and will allow for the onsite infrastructure to be provided.

Capacity

6.6. The capacity of the Site has been assessed by the Project Team based on the landscape capacity of the Site and understanding the existing constraints and opportunities, as set out in Appendices 7 & 8. As outlined in the Vision document at Appendix 1, the Site has capacity to accommodate a development of approximately 4,500 homes, two primary schools, a secondary school, retail and employment space and supporting infrastructure including the strategic link road and new M23 junction

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6.7. This protects the existing sensitive areas on the Site and provides enhancements including public open space, wildlife habitats and ecological buffers. In relation to the areas of flood risk on the Site, as previously set out mitigation and reduction in flood risk is being investigated in conjunction with the Environment Agency and this is unlikely to limit the capacity of the Site. There is the potential to reduce flood risk and enhance the developable area on the basis of flood mitigation measures to amend the areas at risk from flooding. These details should, in time, inform the Strategic Flood Risk Assessment being prepared by TDC.

Deliverability & Developability

6.8. The proposed development of Redhill Garden Community is deliverable and an indicative deliverability timeline has been included in the Vision document (Appendix 1).

6.9. The Site can come forward either alongside or soon after the plan making process, in order that housing may be delivered toward the end of the five year period. As a new settlement enables the delivery of a large range of house types and tenures, the opportunity exists to accommodate a range of housing needs, which may accelerate delivery, once key infrastructure is enabled.

6.10. The range of infrastructure proposed will require the ongoing liaison of key stakeholders. The positive plan-led approach of RBBC and TDC will ensure that appropriate strategic direction and certainty is provided.

Landscape Capacity and Sensitivity Study 2016, Tandridge District Council

6.11. The Landscape Capacity and Sensitivity Study 2016 assessed this Site and found that the Site had medium landscape capacity for development. As outlined, updated evidence has been provided by the Technical Team in Appendices 7 & 8.

6.12. The TDC Capacity Study outlines that in terms of visual sensitivity, the Site has weak boundary vegetation and has a large visual envelope. The Site buildings are visible from South Nutfield to the north and it has intervisibility with the Greensand Hills and can be clearly seen from the Greensand Way above Brays Farm. The Site is clearly visible across Redhill Aerodrome to the east, including views from Crab Hill Lane and housing along this. There are views of the Site across Kings Mills Lane. Along the west there are views from Kings Mill Lane which forms the boundary and from the fields around Staplehurst Farm. Overall the visual sensitivity is judged to be Substantial.

6.13. In relation to Landscape Capacity the Site is described as being “inconsistent with local settlement patterns, this Site has a resultant moderate sensitivity, although on the high Site. However due to low designation value Site ENA11 is judged to have an overall moderate value leading to a medium landscape capacity for employment development. This Site would potentially be suitable in landscape terms for employment proposals but would need to demonstrate no adverse impacts on the setting of the existing landscape and settlement. Mitigation would need to include buildings which do not exceed the height of those already present. Other evidence relevant to the Sites suitability for development should also be considered”.

6.14. The TDC evidence on landscape (as well as Green Belt) should be revisited and updated in light of the evidence submitted with this representation.

Site Based Ecology Assessment 2016, Tandridge District Council

6.15. The TDC ecology assessment for Site ENA11 found that:

 Ecologically Suitable - The Site has few habitats of value, and any habitats of value appear capable of being avoided by development;

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 Aerodrome complex with parking, hangars, runways and other buildings, Ecological suitable for development with retention of pond and surroundings  Therefore are no ecological constraints on allocation or continued use of the Site.  Area a is suitable for continued use but area B has slight local value due to the presence of a pond and links o the landscape to the west of the Site so should be retained leaving a developable area of 6.13 ha

6.16. The assessment concluded that “There are no ecological constraints on allocation or continued use of the Site”. The Site was split into two main areas with Area A being considered suitable for continued use and Area B being of “slight local value”. The assessment found that there is a “Core Nature Area” to the west of the hangar buildings and a stepping stone corridor to the west.

6.17. Whilst the Landscape Capacity and Sensitivity Study and Ecology Assessment have assessed only part of the wider Redhill Aerodrome Site and have assessed the Site in relation to an employment use, this initial evidence demonstrates that the Site is suitable for development particularly when considered in the context of the ecological and landscape mitigation and enhancements proposed as part of the wider redevelopment of the Site.

6.18. In progressing the further work outlined in the Appendix 10 Ecological Deliverability Assessment, consideration of the emerging TDC evidence base will be had.

7. Spatial Approaches Site Consultation Topic Paper

7.1. The Spatial Approaches Site Consultation Topic Paper has carried out a high level assessment of Redhill Aerodrome in relation to its potential for the development of a new settlement in the form of a SWOT analysis. This assessment has concluded that the Site should “no longer be considered” however in light of the information contained within this representation in relation to the redevelopment for a new settlement the issues identified in this SWOT analysis can all be addressed.

7.2. In light of the proposed development including mitigation and enhancement proposals, the SWOT Analysis below has been produced to demonstrate an updated analysis (Table 7.1) overleaf.

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Table 7.1: Alternative SWOT Analysis to Inform a Revised Spatial Approaches Paper

Strengths Weaknesses  Close proximity to M23 and A23 which provide  Flood Zone 2 & 3 on eastern section of the Site connections between the M25 and the south currently coast.  Areas of potential surface water flooding currently  Located between three major transport corridors on Site providing various route options  Surrounding cycle and pedestrian routes in local  Close to Nutfield railway station opportunity for area are disjointed enhanced pedestrian and cycle facilities to the  Currently limited services and facilities on site station  AONB candidate area to the north of the area  Numerous local footpaths and strategic cycle  Large SNCI to north of A25, and smaller Site to routes in the surrounding area south (Furzefield Wood)  Linkages to Fastway bus service  Biodiversity Opportunity Area extends through  Close to strategic employment areas at Gatwick area Airport and Salfords with good sustainable travel  SNCI to north‐east of Site opportunities  Potential loss of employment premises  Access to services and facilities of large settlements in neighbouring Borough – sustainable travel connections and highway links to Redhill and Reigate will be enhanced. Services and facilities will be provided within the development to reduce the need to travel to the wider area.  Part previously developed land  Limited onsite constraints including topography and ecologically protected areas  Site is not within the AONB  Vast majority of site area is located within an area of good existing air quality  The majority of the site is located within Flood Zone 1 and therefore at low risk of flooding from fluvial (watercourse) sources

Opportunities Threats  A unique opportunity to develop a new self  Coalescence with Redhill, Reigate and South contained settlement can deliver a wide range of Nutfield services and facilities on-site due to the critical  Potential for sensitive receptors introduced in mass of the development. the eastern extent of the site to experience  Provision of a new junction onto the M23 poor air quality and high noise levels due to providing direct access to the Strategic Road proximity to the M23 motorway Network  Provision of a new link road connecting the Site and A23 to the M23 and M25  Link road will provide an enhanced route to East Surrey Hospital and to Gatwick Airport.  Expand the public transport network in the area through a new public transport hub within the local neighbourhood  Potential for improvements to other local road networks  reduce “rat running” traffic through surrounding villages  Potential for improvements to cycle and walking

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infrastructure improvements  Reduce pressure for large scale development in existing settlements and the Green Belt elsewhere in the District  Notable extent of the area falls within neighbouring Boroughs boundary allowing for effective cross boundary co-operation  Increase amount and quality of employment space  Provision of 2 primary schools and a secondary school  Provision of retail space in local centre and other community facilities such as healthcare  Improve biodiversity on the Site  Improve connectivity of network of public footpaths and bridleways through the Site  Increase in public open space  Decrease in flood risk through potential de- culverting of the Redhill Brook, mitigation and locating sensitive uses away from areas of flood risk  Management of specific areas of surface water flood risk through a suitable designed surface water drainage system (SUDS)  Site located in close proximity to existing settlements

7.3. There are a number of elements of the SWOT analysis carried out in the Topic Paper which require clarification. A number of the weaknesses and threats identified can be overcome through the design of the proposals on the site and are clarified and discussed in the table below.

Weaknesses

No Available Land – we can confirm that the Site is available, fully assembled and in single ownership with a single promoter. An updated HELAA representation was made in October 2016.

Notable extent of the area falls within neighbouring Boroughs boundary – this is not considered to be a weakness as through the Local Plan process Local Authorities must demonstrate that they have cooperated with neighbouring authorities. Therefore cross boundary discussion and agreement on the proposals for Redhill Aerodrome should be achievable. The site may be allocated through a single or joint local development plan document in liaison with RBBC.

Small waste Site and historic landfill Sites to south, with notable waste and minerals Sites to the north of the A25 – there are two historic landfill Sites approximately 1-2km to the south of the Site which were last in use in 1990 and 1976. Approximately 2-3km to the north of the Site are historic landfill Sites which have not operated since 1990 or earlier. All of the historic landfill Sites are far enough from the Site to prevent any direct impacts on the proposed development. The Redhill Landfill Site is also to the north of the Site however this is also highly unlikely to impact on the proposed development and does present an opportunity for waste from the proposed development to be disposed without the need for significant transportation.

Access to the area from Tandridge difficult, No railway station or line, No direct access to Strategic Road Network – The proposed development of the site as a new settlement has the potential to provide significant improvements to the existing access to the wider area, strategic road network and to railway stations and other public transport connections. The provision of a new junction onto the M23 and a new link road will

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a provide direct access to the strategic road network and improve connectivity of the local road network. There are four railway stations within a 3.5km radius of the Site. Nutfield (1.6km), Salfords (2.0km), Earlswood (2.6km) and Redhill station (3.4km), public transport connections and pedestrian and cycle connections will be enhanced to these stations to ensure sustainable travel is available (See Appendix 2).

Ancient Woodland scattered around surrounding area, AONB Candidate area to the north of the area, large SNCI to north of A25 with smaller site to south (Furzefield Wood) – the impact of the proposed development on the surrounding ecological or landscape sensitive areas has been carefully considered by the Project Team and the proposed development will be designed to minimise impact on any sensitive areas. Ongoing technical assessments will continue to inform this process to ensure that the proposed development has limited impact on any sensitive surrounding areas.

Close to existing settlements – the site is close to the settlement of South Nutfield and the design of the proposal will ensure that there is no coalescence with this settlement through provision of a buffer to the north of the site (please see indicative concept Masterplan options, Landscape Capacity assessment and Green Belt Analysis – Appendix 1 & Appendices 7-9). The proximity of existing settlements provides an opportunity to improve connectivity locally and utilise the existing services and facilities at existing settlements for example railway stations.

No services or facilities – the existing site has limited services and facilities itself and is currently poorly connected to existing services and facilities in nearby settlements. The development of a new garden community at the site provides the opportunity to provide all of the services and facilities which the new residential will need due to the size and critical mass of the proposed development. Therefore whilst currently the site lacks these features they will be provided through the proposals including employment and retail spaces, healthcare and education.

Threats

Increase in Flood Risk – the primary cause of the flood risk on the Site is being investigated by the Project Team and is highly likely to be due to the culvert located onsite. Mitigation methods including removal of the culvert are being investigated and will ensure that the proposed development does not increase flood risk on or off Site. The proposed scheme will also include mitigation for example SUDS to reduce flood risk (as outlined in the Topic Paper, Appendix 5).

Landowners want Site to be used for employment only – as confirmed in this representation the Site is being actively promoted for redevelopment as a new garden settlement and is not only for employment use.

Coalescence with Redhill, Reigate and South Nutfield – the potential for the coalescence of existing settlements has been carefully considered, and forms a key drive for onward Masterplanning (see Appendix 7 & 8). The proposals include areas of landscape buffering which will ensure that coalescence does not take place.

Potential for sensitive receptors introduced in the eastern extent of the site to experience poor air quality and high noise levels due to proximity to the M23 motorway – this threat has been identified by the project team through initial assessments and will be carefully considered through the design of the proposals. The location of less sensitive receptors in areas with the potential for noise or air quality issues will be considered as well as design features which limit the impact of these factors (see Appendix 4).

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8. Summary Conclusion – Redhill Garden Community

8.1. Redhill Garden Community is a unique opportunity for TDC and also RBBC, to deliver a new settlement to address a substantial proportion of housing needs, and enable significant new infrastructure. It must be considered fully and robustly through the production of the emerging Local Plan. The analysis contained in the Topic Paper and with respect of the potential for the development of the Site must therefore be revisited, in order that the Site is considered fairly as another potential new settlement option.

8.2. The NPPF makes clear that “Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to rapid changes” (paragraph 14) and that the key aim of Local Plans is to achieve sustainable development and achieve economic, social and environmental benefits. The NPPF specifically sets out that “The supply of new homes can sometimes be best achieved through planning for larger scale development, such as new settlements or extensions to existing villages and towns that follow the principles of Garden Cities. Working with the support of their communities, local planning authorities should consider whether such opportunities provide the best way of achieving sustainable development. In doing so, they should consider whether it is appropriate to establish Green Belt around or adjoining any such new development” (Paragraph 52). Redhill Aerodrome offers the opportunity to deliver a scale of development which can be self sustaining with new infrastructure and the services and facilities required to support a new community.

8.3. The NPPF also outlines a requirement for positive planning, co-operation with neighbouring authorities, allocation of sites for development and indication of broad locations for strategic development and to significantly boost the supply of housing. By working positively alongside RBBC to enable this strategic development to come forward, TDC will be able to ensure that they meet the needs of their communities in conjunction with RBBC needs.

8.4. The review of Green Belt boundaries at the time of Local Plan production is permitted by the NPPF. The exceptional circumstances required to allow for review and amendment to Tandridge’s Green Belt boundary’s has been triggered by the increased housing needs, as evidenced in the emerging SHMA. As evidenced, the majority of the Site only contributes to one of the four defined and assessed purposes of the Green Belt. The Site also has significant landscape capacity for development, with limited impact on the wider landscape character or its visual amenity

 Enable the delivery of development on land which is part previously developed and which when considered within its own defensible boundaries only meets one of the four purposes of the Green Belt as defined by the draft TDC evidence base;  Deliver much needed housing including early delivery in the plan period as well as consistently throughout the plan period;  Would protect more sensitive ecology and environmental designations in the rest of the District, for example the protection of the Area of Outstanding Natural Beauty (AONB), and areas of better quality Green Belt;  Would enable regionally significant infrastructure (notably the delivery of the A23- M23 link) assisting access to, and improving connections from communities in Tandridge and enhance accessibility to East Surrey Hospital;  Promote public transport connections and enhancements from the Site, to key employment areas including Redhill, Crawley and Gatwick;  Reduce the risk of flood risk through alterations to existing culverts and the potential creation of floodplain compensation;  Connection of currently isolated landscape and ecological assets within the surrounding area. This proposed new community should improve significantly the ecological value of the Site. This development would create a new and rich landscape setting including wildlife corridors and recreational opportunities, transforming the ecological and landscape value of the land. A core driver will be to maintain the visual separation with South Nutfield.

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8.5. This representation and accompanying technical reports outlines a robust vision, and case for the allocation of this Site to allow a new settlement to come forward. The Site is available and readily assembled for development. It is suitable for development and it is deliverable in the plan period, with none of the technical information or assessments undertaken to date indicating that the Site cannot accommodate such a development. The potential benefits, and for mitigation proposals, must be provided due weight by TDC in reaching an appropriate planning balance, and in making its positively planned decisions for the District Plan.

Yours faithfully,

Jonathan Steele Director

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