The Godstone Village Association prepared a response to the Draft Local Plan that Tandridge District Council issued in the first Regulation 18 consultation early in 2016.
The response was as follows:
TDC LOCAL PLAN CONSULTATION _ ISSUES & APPROACHES 2015 (REG 18)
The documents are too complex with too many pages for residents to understand and make appropriate comments.
There is a strong sense of misrepresentation felt by many of the public on the documents. There are 72 issues identified as of sufficient importance to be considered but there are only 15 objectives to address them. There is very little emphasis in the Objectives on addressing the issues identified.
The draft Local Plan is disjointed and does not take into consideration some very important policies such as the Green Belt Assessment and the Open Spaces Assessment, but these will be fundamental in the final delivery of the plan
The Green Belt Review leaves most of the areas of land considered ‘to be further assessed’. The Green Belt Review Methodology is flawed and the division of the district into 45 artificial parcels means that the importance of the Green Belt in determining the character of Tandridge District is given insufficient and fragmented attention with most of the areas of land to be further assessed. The Council’s stated objective of protecting the Green Belt in Tandridge is not confirmed by the Local Plan documents and Green Belt assessment parcels numbers GBA014, 015, 016, 026, 027, 031, 033 and 036 should all remain within the Green Belt.
TDC should monitor air quality particularly in the areas adversely affected by the M25 and the A25.
To assist residents to respond to the Consultation the GVA gave the following responses to the questions asked.
Question 1; What do you think about the issues?
Response: Generally the issues facing TDC are agreed BUT insufficient attention has been paid to the issue of Air Quality in areas such as Godstone which is adversely affected by pollution from the A25 which passes through the centre of the village and the close proximity of the M25 and its Junction 6. An exceptional number of HGV’s pass through the village adversely affecting it’s attraction to visitors and shoppers.
An east-west bypass for the village is essential for the health and wellbeing of residents and to protect this historic village.
Employment needs to be encouraged in the Godstone area.
Broadband needs to be improved throughout the area.
Question 2: What do you think about the objectives?
Response: There are only 15 objectives to deal with 72 issues, the response to Objective 13 should refuse all future development in areas of even medium Flood Risk. The response to the design and safety/climate change should include monitoring and improving Air Quality in all settlements close to the M25/A25. There should be an objective to provide an east-west bypass for Godstone from the M25 at Junction 6. Under Objective 10 the reference to’ higher density where appropriate’ should be deleted.
Question 3: What do you think about the vision?
Response: The vision for the next 20 years whilst supported is weak and generic. There is nothing not to support in it, but it offers nothing to indicate the strategy of the future.
Question 4: What do you think about the Delivery Strategy?
Response: Option 2a is preferred Housing Option provided there is no building on recreation grounds or public open spaces. It is considered that Options 3-6 allow too much housing for this area and would involve building on inappropriate Green Belt land which must be preserved. Open spaces and recreational grounds (including allotments) must be safeguarded or alternative provision made.
Question 5: What do you think about each of the policy approaches?
It is agreed that existing employment sites should be retained where commercially viable. Small employment sites should be encouraged. Retain Core Strategy Policy (CSP) 22.
It is noted that the Ivy Mill Lane, Godstone site is unsuitable and should not be agreed under any circumstances.
This village should NOT be identified as a Local Centre until such time as there is an east-west bypass from Junction 6 of the M25 north of the village taking the existing heavy traffic out of the village centre. The current traffic flow through the village and lack of car parking make its identification as a local centre not viable.
It is suggested that amending CPS23 be adopted taking into account the Tandridge Retail and Leisure Study and incorporating the merging Caterham Town Centre Plan.
Health and Wellbeing:
The Open Space Assessment Standards should be adopted but the Right of Way network referred to in CPS13 should be protected.
CPS Policies 18 and 19 should be adopted subject to amendment to agree Code 4 Insulation Standards and should seek to require standards in excess of Building Regulations where appropriate.
1.4 Natural Environment:
The CPS Policy 20 should be amended.
The proposal is supported that Tandridge District Council develop a Heritage Policy but without a review of Conservation Areas.
12.4.21 GREEN BELT:
The current housing Approach 2A is supported. There is strong objection to the possible building on land in the north of Godstone and Posterngate Farm at South Godstone and Blue Anchor Farm at Blindley Heath. Godstone should remain a defined village in the Green Belt. It should not be designated a Semi-rural Service Settlement and the proximity of the M25 and the A25 running through it should not count as 6 points in the hierarchy scoring. There has been double counting of ‘convenience shops’ and ‘comparison shops’ in the scoring. The Green Belt must be maintained between Godstone, South Godstone, Blindley Heath and Bletchingley.
It is noted that there are no Options at this stage but that this will be dealt with in the next version of the Local Plan document.
It is noted that all infrastructure matters such as transport, water, waste, energy, telecommunications, utilities, household waste, health, social care, education and flood risk will be looked at once development sites have been identified and will be seen in the Surrey County Council Infrastructure Study which is based on the 2008 Core Strategy figures and will, therefore, need updating site by site. See the next version of the Local Plan.
It is noted that ‘wait and see’ policy is being adopted.
Question 6: Are there any other comments?
Response: The unnecessary complexity of the documents, the number of appendices, and the sheer volume of information make this consultation unreasonably difficult for people to understand and comment on.
- The monitoring of air quality in areas of high pollution (e.g. Godstone)
- There are no targets for monitoring progress at this stage.
- No reference to the urgent need to take traffic from the M25 J6 going west to Redhill out of Godstone Village
- There is no provision in the current timetable for any revision following the second consultation
- The comments submitted under this Consultation will be taken to TDC’s Planning Policy Committee in due course as a Statement of Consultation.
- There will be a Consultation on the TDC Local Plan (Regulation 19 Version) in the Autumn/Winter 2016 according to the TDC’s timetable