Local Plan: Sites Consultation Document
(This page is necessarily long. The Local Plan is too important not to comment on all aspects of the plan.)
The Godstone Village Association, (GVA), submits this response to the Sites Consultation currently open under Regulation 18. The GVA disagrees with the way in which Tandridge District Council, (TDC), is using leading questions in the Sites Consultation document, however the specific responses on the sites are as follows:
Question 1 – The Sites
BHE 014- Featherstone Open Space, Blindley Heath. This site is unsuitable for development. It is an open space that includes an existing play area. The land is an existing open space and paragraph 74 of the NPPF clearly states that existing open spaces should not be built on. It does not comply with the exceptions listed in Paragraph 89 of the NPPF and should therefore be excluded.
ENA 12 (SGOD 008) – Lambs Business Park. The site should remain an employment site, although regard should be given to providing better access to it such as to avoid Tilburstow Hill Road being used as a short cut to the A25 and M25. No further expansion should be permitted until a direct access to the A22 is provided by the owners of the site.
ENA 26 (BHE 008) – Systems House, Blindley Heath. This site should remain an employment site.
BHE 007 – Land to the west of Blue Anchor Farm, Blindley Heath. This site is unsuitable for development, it is prone to flood in a number of places, it is under the flight path to Gatwick Airport meaning that the opportunity for peaceful occupation is reduced which would not comply with paragraph 123 of the NPPF. It does not comply with the exceptions listed in Paragraph 89 of the NPPF and should therefore be excluded. There is no public transport amenities on this site meaning that it is difficult to understand how it will meet the aims of Section 4 of the NPPF in Promoting Sustainable Transport.
BHE 009 – Land adjacent to Hartley, Hare Lane, Blindley Heath. This site is proposed as a Gypsy/Traveller use for 19 pitches. Hare Lane is unsuitable for the type of vehicles typically driven by this community. There are no employment opportunities in this location which would meant that the community would have to travel outside of the area to find work resulting in increased vehicle movements in this small lane. There is no public transport amenities on this site meaning that it is difficult to understand how it will meet the aims of Section 4 of the NPPF in Promoting Sustainable Transport. The site should be excluded as a matter of urgency to allow residents of Hare Lane to continue with their lives.
BHE 010 – Land to the west of Blue Anchor Farm, Blindley Heath. This site could be suitable for limited development, however it is prone to flood in places, it is under the flight path to Gatwick Airport meaning that the opportunity for peaceful occupation is reduced. The site could only comply with paragraph 89 of the NPPF if it were to be considered for ‘limited infill’ not wholesale development.
BHE 013 – Little Haven, Byers Lane, Blindley Heath. This site could be considered compliant with paragraph 89 as limited infill. If so, it would qualify for the exceptional circumstances to allow it to be released from the Green Belt, but Byers Lane does not currently benefit from any public transport, therefore it is difficult to understand how it will meet the aims of Section 4 of the NPPF in Promoting Sustainable Transport.
GOD 001 – Godstone Reservoirs, Godstone. It is difficult to believe that this site could seriously be considered given the fact that one part of it is a nature reserve and, placing 400 units at this point on the A25 would create traffic problems that are unimaginable. It does not comply with the exceptions listed in Paragraph 89 of the NPPF and should therefore be excluded. It is surprising that this site found its way into the Sites Consultation document, given that TDC claim to have excluded hundreds of others.
GOD 004 – Land at Godstone Allotments, Godstone. Given the access issues to this site and is in such close proximity to a historic burial ground, this site should have been excluded at the outset. This site would not comply with Section 12 of the NPPF.
GOD 008 – Land behind the Hare & Hounds Pub, Godstone. Whilst this site might seem suitable from a ‘limited infill’ perspective and could therefore comply with paragraph 89 of the NPPF for exceptional circumstances, it is difficult to understand who access would be achieved.
GOD 010 – Land to the west of Godstone. These fields are exceptionally close to the M25 and to the existing haul road for the sand quarries. Paragraph 124 of the NPPF specifically states that air quality should be taken into account in planning matters and it is likely that air quality in this location is poor. The site benefits from several footpaths that have not been considered in the Sites Consultation document. None of the conditions in paragraph 89 of the NPPF could be applied to give it exceptional circumstances to be released from the Green Belt.
GOD 017 – Land to the rear of the Hare and Hounds Pub. Whilst this site might seem suitable from a ‘limited infill’ perspective and could therefore comply with paragraph 89 of the NPPF for exceptional circumstances, it is difficult to understand how access would be achieved.
GOD 019 – Land to the rear of 44-46 High Street and south of Dumville Drive, Godstone. This land is controversial in any event. Planners would be well advised to look back at planning application 2013/43 and the suspicion then raised by residents adjacent to that site that the granting of that application would pave the way for further development at a future date. Clearly that is what is sought now. The Planning Officer at the time chose to ignore these concerns in her Officer’s Report, however, they would be very likely to come back if this site was deemed suitable for development. In any event, it does not comply with any of the conditions of paragraph 89 of the NPPF and should therefore be dismissed.
GOD 021 – William Way Builders Merchants, High Street, Godstone. This site is an operational business, however, should that business close or relocate, the site would be an ideal site for limited infill. There are issues with access as the site is at the brow of a hill, however, these could be overcome with careful consideration. The GVA considers that this site would comply with the conditions of paragraph 89 of the NPPF which would allow it to be developed.
SGOD 005 – Posterngate Farm, South Godstone. This site straddles the A22 and is prone to flood. It is completely unsuitable for development and would not meet any of the conditions of paragraph 89 of the NPPF which would allow it to be considered as exceptional circumstances. There is no public transport available at this site and it is a considerable distance from the railway station at South Godstone therefore it is difficult to understand how it will meet the aims of Section 4 of the NPPF in Promoting Sustainable Transport.
SGOD 006 – Land at King’s Farm North, South Godstone. This site is located adjacent to Tilburstow Hill Road and very close to Lambs Business Park. Assuming that Lambs Business Park (ENA 12) is to remain an employment site, the development of this site would seem inappropriate as the HGV traffic generated by Lambs Business Park is already a major issue on Tilburstow Hill Road. Since the site has a Tree Preservation Order on it, TDC would need to lift this. The GVA consider this an inappropriate site for development and cannot see how any of the conditions of paragraph 89 of the NPPF could be applied.
SGOD 009 – Lagham Park Farm, South Godstone. This site is adjacent to the railway line at South Godstone and is close to an Area of Great Landscape Value. The proposal for 285 units would not constitute ‘limited infill’ as defined in paragraph 89 of the NPPF. This site should not be developed.
SGOD 013 – Land at King’s Farm South, South Godstone. This site should be excluded for the same reasons as SGOD 006.
ENA 11 – Redhill Aerodrome. The Sites Consultation document recommends that this site should be retained as an employment site. It should not. The owners have already offered the site for development and, since it could accommodate up to 4,500 dwellings, would bring significant employment, infrastructure and transport benefits, this site should be the only site considered for a new settlement. The GVA strongly urges TDC to consider this site if it can be established that a new settlement is required.
Question 2 – The locations for a new and extended settlement
Neither the location proposed in South Godstone, nor the location proposed in Blindley Heath is suitable for a new settlement. Both sites were ruled out as part of the ‘Sites Assessment’ and should remain ruled out if a new settlement is to be considered. There is insufficient employment opportunities, insufficient transport, insufficient infrastructure, insufficient local amenities. Both sites would fail the sustainability test and both sites could not be justified for release from the Green Belt.
The government has made its position very clear, 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. TDC would do well to heed this position.
Redhill Aerodrome has been put forward with a scheme as a ‘New Garden Development’ and TDC should now abandon the two sites it has been considering in favour of a new settlement at Redhill Aerodrome. Any other option will fail on examination. Redhill Aerodrome is a sustainable option that meets the housing need, offers a range of benefits to the community and is deliverable.
Question 3 – Other areas
TDC should go back to the methodology used to calculate housing need and re-assess. The need for housing is grossly inflated and should be re-calculated before any further damage is done. Once a realistic calculation of housing need has been completed, TDC will see that the only sustainable option is the development of a new ‘garden development’ at Redhill Aerodrome.
Whilst Tandridge District Council, (TDC), is seeking comment on the sites put forward, the GVA would like to register its protest at the overall methodology adopted in preparation of the Local Plan and, in particular, the ‘spin’ that has been used to justify some of the statements made. The sites consultation document is a weighty document and cannot, as has been suggested by some TDC staff, be read in isolation since it neither identifies the needs and issues being addressed, nor any form of methodology in reaching the conclusions that have already been made. In order to have a full understanding of the issues, needs and methodologies, and some of the evidence required, the full suite of documents must be read that form the Local Plan. It is exceedingly unlikely that residents of the district will have the time, or the level of knowledge needed, to read all of these documents to understand exactly how the TDC has made the decisions that it has already made.
At meetings with the public, great strength has been given to explaining that no decisions have been made. This is completely untrue. By its own admission TDC has excluded many hundreds of sites as being unsuitable and has not included them in the latest document, it is therefore untrue to say that no decision has been made. How was the decision made to include those sites marked red that are said to be excluded from consideration? What criteria was applied to include some and show them as being unsuitable and exclude others from the document altogether?
No attempt has been made to explain, in relatively simple terms, what the Local Plan is, why it is necessary and what evidence is required to support the plan. There have been lots of suggestions, both verbally and in print, that “the government says” that TDC need to have a Local Plan to build more houses to support a growing population. There have been claims that “the government tells us what the methodology is that must be used to calculate the number of homes needed”. That may, or may not be true, but where is the publication of that methodology? Where is the publication of the base data that is used in that methodology? There is far too much secrecy and slight of hand surrounding the basis of the Local Plan.
Unfit for Purpose
It is the opinion of the GVA that, in its current form, the TDC Local Plan is unfit for purpose. Much waving of the National Planning Policy Framework, (NPPF), has been made with claims that “we must comply with the NPPF and build more homes”. “The government wants us to build more homes to meet a growing population.” “We are trying to protect the Green Belt and, if we don’t build enough new homes, it will be at risk.” “If the TDC is placed in ‘Special Measures’ then the developers will win applications to develop the Green Belt on appeal.” None of these statements are entirely true and TDC knows that.
Comment is unheard
Despite TDC representatives publicly saying that they are looking for comment, they are seeking the views of the residents of the district, there is no evidence that this is true. In the Sites Consultation document it is very clearly stated that over 5,200 comments were received during the first Regulation 18 consultation on the original documents. This may be true, but there is no explanation about what has been done about those comments, no explanation about how they have been taken into account prior to this latest consultation commencing. In fact, it appears they have been ignored. The GVA has read a great many of the comments on the Local Plan portal, there don’t appear to be any that support ‘Approach 6’ of the ‘Delivery Strategies’ which was where a ‘Large urban extension’ or ‘new settlement’ was muted. Yet it now seems that this has been decided as what is needed. Boasting about the number of comments received, but taking absolutely no notice of them is hardly evidence of a fair consultation. What was the purpose of setting out the seven Approaches in Section 11 of the Local Plan: Issues and Approaches document and asking for comment? TDC has ignored the first six approaches and just opted for the seventh.
New extended settlement
Despite TDC continuously saying that no decisions have been made, this is blatantly untrue. The decision has been made to look exclusively at Blindley Heath and South Godstone and other potential options, (Copthorne, Hobbs Industrial Estate, Horne, Lambs Business Park, Lingfield and Smallfields), have all been ruled out. Clearly a decision has been made. There is scant reference to Redhill Aerodrome with a claim that it has come very late in the process. The GVA is unsure what this means. Is TDC suggesting that because, in the opinion of the officers, Redhill Aerodrome has been put forward at a late stage that they are not considering it if a new extended settlement is needed? That would be an abject failure of its duty under the NPPF.
Both South Godstone and Blindley Heath are rural settlements. Paragraph 34 of the NPPF states, ‘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.’ There is a small rural railway station at South Godstone, (and a current application to develop the only adjacent land that might otherwise be used to improve this station), and an already over-congested A22. How does TDC believe their decision to consider Blindley Heath and South Godstone meets the requirements of Paragraph 34 of the NPPF? Since there is no significant employment opportunity in either South Godstone or Blindley Heath and there are no educational facilities to support a new settlement, TDC seems to have overlooked that everyone will need to travel, mostly by car, out of any new settlement.
Rubbish in, rubbish out
The base data used to calculate the number of new dwellings needed in Tandridge District simply cannot be accurate. TDC have stated repeatedly that approximately 9,400 dwellings are needed in order to meet the ‘objectively assessed need’ and that “experienced consultants assisted” in the approach. Consultants are sometimes wrong. The size of the population in Tandridge District has grown over the period from 2001 to 2014 by just 438 people per annum, (according to the Surrey County Council website). Taking this as being the average, the forecast growth between now and 2033 would be 7,446. TDC is stating that the forecast growth is 15,000. How and why? The reason for a rise in population that is over double the current rate has not been explained. The objectively assessed housing need, according to the NPPF, is to support the existing community, not urban sprawl. TDC has consistently claimed that they are protecting against urban sprawl, but have not demonstrated this in any way whatsoever.
TDC have not provided any evidence to support their estimate of 15,000 however, even if this were true, their estimates do not hold up to scrutiny. TDC claim that 9,400 homes are needed to support a population increase of 15,000. This equates to 1.6 people per household as an average. The Department of Communities and Local Government produced a document called Household Projections: England, 2014-2039 in July 2016. This document forecasts that average household occupancy will fall from 2.35 today to 2.21 in 2039, (2.24 in 2034). TDC are basing their ‘objectively assessed’ need on average occupancy of 1.6 immediately. This is a fundamental problem in the calculations.
If the forecast growth was to be more accurately assessed at 7,446 between now and 2034, and the actual projected occupancy taken at the worst example from the Department of Communities and Local Government at 2.21, the number of homes needed would actually be 3,369, not 9,400 as TDC states. The numbers produced by TDC are fundamentally wrong and this is one reason that the plan is not fit for purpose. It is hardly surprising that there is so much suspicion surrounding the Local Plan when numbers are so obviously wrong.
National Planning Policy Framework
Aside from the issue surrounding the population growth estimates put forward by TDC, the fact that no comment has been seen to contribute or influence the process of creating the Local Plan, the fact that decisions have been made not to include some sites in the Sites Consultation document and others excluded without explanation as to why, the fact that the estimates of housing need are vastly exaggerated by TDC, there is the issue of protecting Green Belt Land. TDC have repeatedly said that they are creating a Local Plan to protect the Green Belt and have said how difficult their job is because 94% of Tandridge District is Green Belt, but the current approach suggests the opposite.
Paragraph 79 of the NPPF states, ‘The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.’ The fact that TDC wish to develop so much of this land would suggest that it is ignoring the NPPF.
TDC will be familiar with paragraph 80:
Green Belt serves five purposes:
- to check the unrestricted sprawl of large built-up areas;
- to prevent neighbouring towns merging into one another;
- to assist in safeguarding the countryside from encroachment;
- to preserve the setting and special character of historic towns; and
- to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
Current documents do not explain how TDC believe it complies with paragraph 80.
TDC will also be familiar with the government’s position regarding Green Belt development, “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.” Building a new settlement on Green Belt land to meet an unjustifiable housing need, is hardly supported by this.
TDC will be familiar with paragraph 100 of the NPPF which begins, ‘Inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at highest risk, but where development is necessary, making it safe without increasing flood risk elsewhere.’ It is widely known and acknowledged that both the proposed site at South Godstone and the proposed site at Blindley Heath suffer with flooding. In Blindley Heath the new development constructed recently has led to problems with run-off both in terms of surface water and sewage. Any additional housing will compound this problem further.
Paragraph 154 states, ‘Local Plans should be aspirational but realistic. They should address the spatial implications of economic, social and environmental change. Local Plans should set out the opportunities for development and clear policies on what will or will not be permitted and where. Only policies that provide a clear indication of how a decision maker should react to a development proposal should be included in the plan.’
There can be no doubt that the TDC Local Plan is aspirational in its current form, but it is entirely unrealistic. The number of dwellings needed is grossly exaggerated and the two proposed sites for new settlements are unsustainable and not compliant with the NPPF or government policy on Green Belt land.
Paragraph 157 of the NPPF states, ‘Crucially, Local Plans should:’, amongst the bullet points listed it goes on, ‘be based on co-operation with neighbouring authorities, public, voluntary and private sector organisations’. There is no evidence whatsoever that TDC are co-operating with anyone. Parish Council state there has been no co-ordination with them, (and their comments not taken into account), certainly organisations such as the GVA have not been included in any co-operative way and the only private sector organisations that anyone is aware of TDC speaking to have been developers.
The owners of Redhill Aerodrome have said that the site is unsustainable as a business without a hard surface runway, which they now know they will not get. As a consequence, a scheme has been put forward for a ’New Garden Community’. It is said that this site could accommodate up to 4,500 dwellings. This far exceeds the actual needs of Tandridge District. An added bonus is that, as part of their prospectus, they propose to construct a new junction onto the M23 which would result in a very much needed relief for the over-congested A25 and would enable lorries to access sites such as Mercers Farm without needing to leave the M25 at Junction 6 and pass through the villages of Godstone and Bletchingley.
Redhill Aerodrome is an obvious choice for a new settlement. It is not a location that is close enough to another village so as to cause undue harm to a village environment, it is closer to Redhill, Horley and Gatwick, all of which have significantly higher employment opportunities, it will be more accessible with additional public transport that is promised, it promises a strong neighbourhood infrastructure and the owners want to offer it for development. TDC should stop any further consideration of inappropriate sites in South Godstone and Blindley Heath and should concentrate their efforts on this site which more than meets their realistic housing needs.
The Local Plan as drafted is flawed. The estimates of population growth are wrong, (based on evidence from the last 13 years). The estimates of housing need are wrong, (based on recognised occupancy levels). The Local Plan as drafted does not comply with the NPPF and is unfit for purpose.