We, the group of residents known as the HWLD Action Group, wish to formally object to Elmbridge Borough Council’s Strategic Options Consultation and the Council’s ‘preferred Option 2’, as outlined in the Consultation Document, due to the following reasons:
1. Housing targets
We are concerned about the housing targets and wonder whether the Council feels forced to seek the quickest way out to meet inflated targets. In particular:
We question whether the SHMA and OAHN are inflated, and based on aspiration rather than actual need. This is an especially poignant concern if the Council is having to consider altering Green Belt boundaries.
We question whether the Council has actively challenged the housing targets, especially when the borough has always met its targets in the past.
We question if, with public support, the Council should be reverting to Government to suggest that housing is directed to areas that are keen for development, rather than forcing extreme measures on Counties and Boroughs that are already over heated, without the space, nor infrastructure to support such high demands.
2. Brownfield sites
We question the LAA and whether the council has properly “examined fully all other reasonable options for meeting the identified development requirements”, as outlined in the recent Housing White Paper. In particular:
Making effective use of suitable brownfield sites and the opportunities offered by estate regeneration;
The potential offered by land which is currently underused, including surplus public sector land where appropriate;
Optimising the proposed density of development
3. Option 2
We feel strongly that Option 2, as outlined in the Consultation Document is not a suitable way forward for Elmbridge. In particular:
We feel that the proposal to split Elmbridge’s unmet housing targets across just three sites is neither reasonable nor acceptable. We dispute the Council’s justification for this (dense development and on-site infrastructure) since the Consultation Document does not, in any way, demonstrate that this is achievable in the three key strategic areas. Such large developments would have a detrimental effect on any local area, which is at odds with the Council’s own aim to protect the character of its towns and villages.
The method used to identify the three key strategic areas (Green Belt performance review) was fundamentally flawed, since it did not take into account existing community value, area suitability or sustainability, and as such is not a comprehensive approach upon which to base the decision to declassify and develop.
4. The Green Belt Review
We feel strongly that the Green Belt Review was fundamentally flawed and should not have been given such weight. For example:
The report states in several places that this was a desktop review, with the aid of Google Earth and Google Maps, which brings its credibility and accuracy into question.
Arup states that they used 4 employees, over 21 days, to produce this Green Belt Boundary Review. This is a cumulative total of 84 man days of effort to review 78 plots of Green Belt land, some many hectares in size. This does not give the impression that an in-depth, thorough assessment has been performed.
The photographic evidence of Area 58 is not only misrepresentative but could be considered bias.
At macro level, Strategic Area A (encompassing Parcel 58) scored 'Very Strong' in purposes 1 and 2, yet at Parcel level, this dramatically drops to 'Weak'. This feels subjective, inconsistent and unrepresentative.
The Green Belt performance review did not take into account other strengths/weaknesses of the areas, such as community value, by which measure alone, Area 58 is very strongly performing.
5. Area 58
Area 58 does not meet the criteria outlined on in the Consultation Document (ie. its Green Belt is not weak, and it is not in a sustainable location).
Area 58 should not be removed from green belt because:
Area 58 is strategically important to prevent the urban sprawl of Greater London, and in fact represents the ‘front line’ in terms of Elmbridge and wider Surrey. The private land to the East of the area directly adjoins Greater London and, whilst having been allowed to degenerate, is no less effective in the strategic role it plays as part of the Metropolitan Green Belt.
Area 58 is important in its role in visually defining the boundary between Greater London and Elmbridge. It is noticeable that when you travel from Kingston, Surbiton or Hook into Long Ditton there is a characteristic change in the type of land use. High density, multi-storey housing gives way to single storey, low density housing. The change in character denotes a lack of coalescence, showing the boundary between Greater London and Elmbridge. Developing on the Metropolitan Green Belt land will erode this boundary and create exactly what Green Belt is supposed to prevent - urban sprawl and settlement coalescence.
Area 58 does not offer a suitable location for the type of people outlined as the most in need (ie. young families and the elderly) as it is not situated near to public transport and amenities. It is therefore not a suitable location for the type of houses outlined in the exceptional circumstances, without the delivery of which, renders its removal from Green Belt needless.
Area 58 is Long Ditton’s ONLY natural green open space. Its beneficial uses are not restricted to the Council owned areas (Nature reserve, cricket club, hockey club, allotments), but also include ‘One Tree Hill’, which is well used by dog walkers, runners and schools for field trips, etc. Without Green Belt status, this area would be available for development, which would deprive the local community of this valuable asset.
Area 58 is unsuitable for development because:
Any development on Area 58 would be at odds with the Council’s own approach to ‘design and character’. Long Ditton is characterised by a ‘village feel’. The approach into Long Ditton from the A309 is distinctly rural, and Area 58 sits adjacent to the village church. The addition of any housing development would spoil this character.
Any development on Area 58 would be at odds with the Council’s own policies on sustainable transport and travel patterns, since the area is not close to public transport and existing services.
Elmbridge has a duty of care to its residents, to not put them at risk due to poor planning which over populates a village. Development of Area 58 would increase the flood risk due to reduced natural drainage and over-stretch the emergency services.
- Surrounding major roads (A3, A309 and Scilly Isles roundabout) are already congested.
- Congestion and traffic shortcuts throughout the day already compromise minor roads (for example, at the junction in Long Ditton Village, which is a hazard for local school children).
- Public transport is at maximum capacity, especially Surbiton station.
- Local primary and secondary schools are oversubscribed and unable to expand further. Whilst the Council have said that infrastructure would be considered at the next stage of the Local Plan, we feel it is extremely unlikely that Surrey County Council would grant another secondary school so close to Hinchley Wood School and so close to the County border.
- Local NHS services are oversubscribed and struggle to cope with existing demand, let alone any increase due to development.
Pollution - Area 58, right by the A3 and A309, already has very high pollution levels and there are developments in progress across the border in Tolworth that will further add to this problem.
Flooding - A number of areas within Area 58 are known to flood, including, but not limited to Rectory Lane (formerly Watery Lane!), the cemetery and Long Ditton cricket pitch. Building on the southern part of the area would increase the flood risk to all surrounding downhill areas, since the Green Belt land acts as a natural soakaway.
Nature - Area 58 contains a nature reserve. Building on any part of this area would cause fragmentation of rural habitat and a threat to wildlife.
Area 58 includes a Buddhist Centre and Special School, both of which chose this area because of the benefits provided by open space and tranquility.
6. The Consultation Document and process
We feel that the Consultation Document was written in such a way as to persuade Elmbridge residents that Option 2 was the only option. The presentation of Option 2 is comparable to a sales pitch. Options 1 and 3 were presented as unfavourable Options, despite Option 1 being the only option that sits in accordance with the Housing White Paper.
We feel that the timing of the consultation, right before the Christmas break, was deliberate. Poor communication on the Council’s part meant that most residents were not aware of the Public Consultation until mid January, and even then, public awareness was a result of resident action.
The online navigation and registration process, amount of reading required and complicated questions, rendered the consultation documents and response questionnaire inaccessible to many residents.
We, the HWLD Action Group, hope that the Council will take note of the unanimous concern raised by residents in response to this public consultation. We do hope that we can support and work with our Councillors now, and in the future, to develop a sensible, and FAIR Local Plan that will prove beneficial for our area, and Elmbridge as a whole.