Local Plan: Sites Consultation Document
Having reviewed the Sites Consultation document that is being proffered as the latest consultation under Regulation 18 for the Local Plan, the Godstone Parish Council finds the document to be unnecessarily contradictory and confusing.
The quality of the information that has been produced is, at the very least, questionable. The single most important piece of data on which the draft plan is based is the need to build 9,400 dwellings over the period of the plan. How this figure has been arrived at is far from clear. The methodology used to calculate this number is shrouded in secrecy, (comments of ‘it is very complicated, you wouldn’t understand’ have been received), and appears to be based on flawed data. If flawed data is used as the basis for the calculations, no matter how robust the methodology, the data produced as a result will be equally flawed.
The quantity of information that needs to be read and understood, (being in excess of 3,500 pages across all documents), to enable a full understanding of the draft plan is beyond the time available and patience of the average resident. This seems to be an intentional diversionary tactic as other district councils that are producing Local Plans appear to have managed to do so with far fewer documents and far fewer pages of contradictory information.
The level of communication to the residents by the TDC during the development of the draft plan has been totally inadequate and only in the later stages has any attempt at consultation occurred. Even then, there has been a very one sided approach – it has not been a consultative process, more a dictatorial explanation of what has been decided. Consultations have been condescending with statements like, “it is very complicated, we can’t explain it here” and “you wouldn’t understand, you need to be a planning expert to understand this”.
No attempt has been made to produce a simple summary document that could be read and understood by residents who for whatever reason have not accessed the thousands of pages on the TDC website. Whilst the Green Belt Assessment methodology is explained within the 3,500 pages it is certainly not understood by the average resident, nor is the criteria that defines Green Belt land. The recent ‘wrap’ that was published with the Tandridge County Border News was all ‘spin’ with very little factual evidence behind it.
The TDC has totally ignored The Godstone Parish Council and not once during the formation of the draft plan has any TDC representative formally consulted or addressed The Parish Council. This has resulted in totally alienating what could have been a valuable communication channel.
Why do we need 9,400 new dwellings? When asking this question people are repeatedly told, “because the government told us”. This is quite untrue, since all that the government has said is that every council should build sufficient new dwellings to meet the needs of the future growth in population in that district. TDC state that the number of new dwellings needed is 9,400. To arrive at that figure TDC have used a set of base data that is flawed. It is stated that the population of Tandridge is projected to grow from about 85,000 in 2014 to about 100,000 in 2034 an increase of 15,000 over the 20 year period which represents an average annual increase of 750 people. Using Historic data from the Surrey County Council the average rate of population increase over the13 year period 2001-20014, has been just less than 440 per annum. On this, basis TDC should be forecasting an increase in population of just under 9,000, not 15,000 as is stated.
Why do we need 9,400 dwellings to accommodate 15,000 People? Taking the TDC estimate of 9,400 houses, (which we will demonstrate is fundamentally flawed), and the population increase of 15,000, (which we have already demonstrated to be
fundamentally flawed), the anticipated occupancy of these new houses is 1.6 residents per dwelling. The 2011 Census data for Tandridge District show an occupancy rate of 2.43 residents per dwelling, which is further borne out by the Office for National Statistics that states in November 2015 the average occupancy rate was 2.4 residents per dwelling. Assuming that the initial estimate of an increase in population of 15,000 over the period was accurate, (which it is not), and using the ONS occupancy rate, the required number of dwellings is actually 6,250. If, however, the actual population increase is applied of 440, the number of new dwellings required is 3,666, not 9,400 as TDC consistently claims.
Taking a more accurate and sensible number of new dwellings required to be 3,666, there is a question as to where these are best located. TDC have consistently said that no decisions have been made, but they have ruled out Copthorne, Hobbs Industrial Estate, Horne, Lambs Business Park and Lingfield, so this statement is untrue. TDC has made decisions. The Sites Consultation Document makes only a passing reference to Redhill Aerodrome, but this site has been known about for some considerable time. Redhill Aerodrome is an ideal site for a new extended settlement. Its owners have already said that it is unsustainable as a business, they have put forward a scheme for a ‘New Garden Community’ and its construction would bring many benefits to the area.
As part of the Redhill Aerodrome New Garden Community, the developers are proposing a new strategic link road to the M23, (something that the area desperately needs to alleviate the over congested A25 and, to some extent, A22), it could accommodate up to 4,500 dwellings, (more than are actually needed in Tandridge, so this could be shared with Reigate & Banstead), it would create nearly 2,000 jobs, (which a new settlement in Blindley Heath or South Godstone would not), they promise new healthcare facilities, (which TDC cannot promise elsewhere), and will bring TDC up to £60.3 million in Community Infrastructure Levy. Why is TDC not taking this development far more seriously? There is an apparent desire from Tandridge District Council to ‘dump’ large numbers of new dwellings in the Parish of Godstone, rather than carry out responsible development proportionate to need and in a location that makes sense.
With regard to the latest consultation document, Paragraph 1.11 of the Sites Consultation document it states, ‘Issues relating to roads, trains, access to GP care, school places and flooding, are just a few examples of infrastructure which you told us about and something the Local Plan will need to address in a proportionate and appropriate way.’ However, there is no further consideration of these infrastructure needs in the document at all. Sites are assessed and, include vague statements about strategic infrastructure is required to support the delivery of housing, but does not address specifically how this might be delivered. A lack of infrastructure, including schools and healthcare facilities, must make any site that suffers these problems, (which is all of Godstone Parish), unsustainable and therefore unsuitable for development. TDC cannot promise new healthcare facilities or a new school, so it should not encourage development where they are unavailable.
The document does not address infrastructure needs at all. Statements have been made that infrastructure requirements will only be addressed when sites have been selected. It is too late at that point and TDC know this. It is impossible to assess whether a site is suitable for development without first determining how basic transport, health and educational needs will be met. TDC claim that Surrey Highways would not look at the infrastructure needs of a proposed site until it has been decided to develop it. In Godstone there are only two roads, the A22 and the A25 that need to be considered by highways. Which sites are selected along these two roads is entirely irrelevant, the roads will still need to be considered. If TDC were serious in considering the needs of the communities, they would look at infrastructure now. There are three simple questions that need to be answered:
• Are the roads capable of supporting any additional load?
• Can a new school be built to accommodate an increase in population?
• If existing healthcare facilities are unable to cope with more demand, can new facilities be
If the answer to any of these three questions is no, the proposed development is unsustainable.
Paragraph 1.15 of the document talks about the Local Plan: Issues and Approaches document, which is one of the many documents that constitute the overall picture supporting the Local Plan. It talks about the issues facing the district and potential approaches to overcome them. This is the document that identified 72 issues, (including paintballing and sex offences being highlighted as significant issues), but only ever offered 15 strategies which did not address the 72 issues highlighted. This was a strong point made in our previous submission to the initial plan. This is also the document that put forwards a 7 different concepts to address housing needs ranging from Approach 1, ‘Do nothing’ to Approach 6 ‘A large urban extension of new settlement’, (Approach 2 had an ‘a’ and a ‘b’). No further reference has been made to Approaches 1-5 and TDC are now concentrating all their efforts on Approach 6. Why is this ? Why have TDC not communicated why they are no longer looking at Approaches 1-5?
Paragraph 1.16 of the Site Consultation document states that over 5,200 comments were received from more than 3,100 individuals. Why, if this is the case, have TDC not sought to address and answer those comments? Instead, the comments are ignored, just as all public consultation comments are ignored by TDC.
The Sites Consultation document talks about methodologies set out in the NPPF and Planning Practice Guidance, “where they exist”, but does not explain which methodologies have been used and which have been subjective assessments. Paragraph 1.18 begins, “A Local Plan must be based on robust evidence which will be able to stand scrutiny at examination …”. In this response we have demonstrated that the current figures do not stand scrutiny at any level.
The Local Plan will almost certainly fail.
The Government’s own Briefing Paper, (Number 00934), released in January 2016 states: “Unmet housing need (including for traveller sites) is unlikely to outweigh the harm to the Green Belt and other harm to constitute the “very special circumstances” justifying inappropriate development on a site within the Green Belt.” Why have TDC ignored this? Every consultation, and the Sites Consultation document itself, implies that it is Government policy that the green belt must be considered for development to meet the housing need. This is clearly and evidently not the case.
Paragraph 1.40 of the Sites Consultation document makes the claim, “A key driver for the Council in preparing its Local Plan is to ensure it can retain control over development for the long-term and ensure that any development that does take place is in the right locations and accompanied by proportionate and appropriate infrastructure.” This is not demonstrated by the fact that TDC is continuing to consider reclassification of Green Belt land to accommodate housing need which is in direct contradiction of the Government’s own briefing.
Section 2.7 and 2.8 of the document is entitled, ‘What are we seeking comments on?’. The implication of this is that TDC only seeks comments on its own terms and not on matters which it would prefer not to answer. As with all TDC Public Consultations, it does not say what it will do following receipt of comments. TDC has historically ignored all comments submitted to them as part of a Public Consultation, (such as this), or on individual planning applications. There is no suggestion in the Sites Consultation document that a) comments received in the earlier consultation have been noted or acted upon and b) that there is any more likelihood that comments will be taken into account here.
For those residents currently living near to a site listed in this document, this consultation represents an unnecessary burden. Take, for example, those living near to the land adjacent to Hartley, Hare Lane, Blindley Heath, (BHE 009). This land is being considered for a traveller site with 19 pitches. Existing residents have zero opportunity of selling their properties and the fact that there is a potential for the site to become a traveller site negatively impacts on their property value.
TDC is effectively playing with people’s lives and placing them on hold whilst it works on this flawed plan.
The Local Plan as drafted is based on flawed data and, as such, flawed data has been produced which is now claimed to be ‘evidence’. There is not a need in the district for 9,400 houses over the next 20 years and TDC should revisit their figures as a matter of urgency. Government guidelines relating to the Green Belt are that unmet housing need is not sufficient reason to release Green Belt land for development. TDC consistently claim that it is. If a new extended settlement is needed to meet future housing need, Redhill Aerodrome is the only sustainable and sensible option. TDC should stop dumping housing in Godstone Parish and withdraw both Blindley Heath and South Godstone immediately, (as they have already done with other sites under consideration for a new extended settlement). The Sites Consultation document should be withdrawn from publication in its current form until such time as the flawed evidence base has been corrected.