Woldingham Association

Size: px

Start display at page:

Download "Woldingham Association"

Franklin Bond
5 years ago
Views:

Regulation 18 Sites Consultation Representation Representation on the 2016 Regulation 18 Sites Consultation for the Tandridge Local Plan Part 1 from the Submitted to Tandridge District Council on 20

1 Regulation 18 Sites Consultation Representation Representation on the 2016 Regulation 18 Sites Consultation for the Tandridge Local Plan Part 1 from the Submitted to Tandridge District Council on 20 Dec Introduction and Summary This document is the s response to the Tandridge District Council Statement of Consultation Local Plan: Issues & Approaches (Regulation 18) October 2016 (2016 TDC Statement of Consultation). This response highlights where our previous comments either do not appear or where we disagree with the 2016 TDC Statement of Consultation regarding the Green Belt Assessments, Infrastructure, Settlement Hierarchy and Approach 2b. This Representation should be read in conjunction with our 2015 Regulation 18 Representation and the absence of comment in either representation should not be seen as agreement. By way of introduction, the was formed more than 100 years ago to protect and preserve Gilford s original vision of. The continues to own many of the roads and verges in and around and for many years was the de facto Parish Council until a formal Parish Council was created in We have been active in planning and planning policy for many years, and regularly make submissions to planning policy consultations and also individual planning applications. We have also participated in planning policy and Appeal hearings as well as Public Inquiries. Page 1 of 11

2 Regulation 18 Sites Consultation Representation 2.0 Green Belt Assessments WA response: Although it is not clear, we interpret the above (and Responses 830 and 831) as meaning that the 2015 Green Belt Assessments will not be amended where that land is no longer under consideration for allocation in the new Local Plan. We disagree with this approach because robust and accurate Green Belt Assessments are crucial to ensuring that the Green Belt is protected in the future. This is because in the event that TDC is not able to demonstrate a five-year housing land supply, we understand that planning applications would be considered using the balancing exercise in NPPF paragraphs 14 and 47. Unless the assessments are corrected, any future balancing exercise would use Green Belt Assessments which significantly under-state the importance of the parcels to the Green Belt, which puts these parcels at greater risk. The risk is reduced when the assessments are amended to show that the parcels fulfill the Green Belt purposes as explained in more detail in our 2015 Reg 18 Representation. Given the above, we believe that corrected Green Belt Assessments are essential to ensuring that the Green Belt is protected. Retaining the existing Green Belt around is the top priority of local residents as shown by the Neighbourhood Plan survey results. Page 2 of 11

3 Regulation 18 Sites Consultation Representation WA Response: We disagree with the responses in the 2016 TDC Statement of Consultation regarding the parcel assessments for, and note that some of our comments also appear to not have been included. We respond to the Council s response and summarise the comments on the parcel assessments in our 2015 Reg 18 Representation as follows: 1. The parcel assessments conclude that purpose 1 is fulfilled, albeit moderately. We believe that purpose 1 is fulfilled unequivocably, and that moderately is not supported by evidence because: i) the Green Belt Assessment Report and Appendix A: Historic Assessments explain that the Green Belt in the north of the district, where is located, is part of the Metropolitan Green Belt. However, this history has not been applied either consistently or correctly to either the Strategic or individual parcel assessments. For example, GBA003 is included in Strategic Area A whose assessment correctly concludes in paragraph B that the Green Belt within this area has been effective in meeting this purpose. ii) The fundamental aim of the Metropolitan Green Belt is to check the unrestricted sprawl of London. Three of the five Green Belt purposes were defined at that time and so would have been taken into account when the land Page 3 of 11

4 Regulation 18 Sites Consultation Representation in the parcel was included in the Metropolitan Green Belt. This is also explained in Paragraph B of Appendix B: Strategic Green Belt Assessments [ed: emphasis added]: The Greater London Plan 1944 set out the concept of the Metropolitan Green Belt and recognised the need to prevent the conurbation of London sprawling out...the main reason for the Green Belt and where the boundaries were drawn around settlements in the north of the District was to contain the sprawl from London and resist coalescence. iii) The parcel assessments also correctly conclude that the parcels are open and that there has been minimal change since they were included in the Metropolitan Green Belt, so the parcels also exhibit permanence. and permanence are the essential characteristics of the Green Belt. Openness iv) The conclusions made in the parcel assessments and in Response 799 and 800 extracted above appear to imply that topography and landscape features such as woodlands are sufficient to contain sprawl. However, when the Metropolitan Green Belt boundaries were drawn there was a requirement to only include land which it was deemed necessary to keep permanently open. Therefore, the assessment undertaken at that time must have concluded that, even considering the existing topography and landscape features, the Metropolitan Green Belt designation was necessary to keep the land permanently open and also that the land fulfilled the purposes of the Metropolitan Green Belt defined at that time. v) All of the above confirms that the parcels are effective at containing sprawl and so unequivocably fulfill purpose The assessments conclude that purpose 2 is not fulfilled. We believe that this is not supported by evidence because little has changed since the Metropolitan Green Belt was designated, and London have not merged, and settlements near, such as Warlingham and Caterham, have also not merged with. Therefore, the parcels fulfill purpose 2, both in the context of London as well as more locally. Page 4 of 11

5 Regulation 18 Sites Consultation Representation 3. The assessments conclude that purpose 3 is not fulfilled. We believe that this is not supported by the evidence base because the description of the parcel (paragraph D.4.14) correctly states that little has changed and also that the parcels contain some large expanses of countryside. This means that the parcel has been effective at safeguarding the countryside from encroachment and so fulfills purpose The assessments conclude that purpose 4 is not fulfilled. We believe that this is not supported by evidence because page 32 of the Green Belt Assessment Report states The Green Belt provides the rural character of a statement with which we wholeheartedly agree. The adopted Neighbourhood Plan, previous Local Plans (1992 and 2001, 2008), and currently adopted Supplementary Planning Documents all describe as a historic village (first recorded in the Domesday Book) with special character. Given the above, we conclude that purpose 4 is also fulfilled. 5. The assessments conclude that purpose 5 is not fulfilled. We believe that this is not supported by evidence because the parcels are located in the Metropolitan Green Belt, and so purpose 5 is fulfilled when considered in the context of London. There are also examples of regeneration in the inset area of in the form of small redundant commercial premises being converted into residential accommodation. Therefore, the parcels also fulfill purpose 5. In conclusion, we believe that the 2015 Green Belt Assessments considerably weaken the protection of the Metropolitan Green Belt around compared to the situation before these assessments were published and so we believe that the Metropolitan Green Belt around may now be at greater risk. Therefore, we believe that correcting the Green Belt Assessments is essential to a robust and consistent evidence base that is capable of successfully defending the Green Belt in the future. Page 5 of 11

6 Regulation 18 Sites Consultation Representation 3.0 Infrastructure WA Response: The above comments do not address our 2015 Reg 18 Representation and some of our other comments also appear to not have been included. Our 2015 Reg 18 Representation explains that the Infrastructure Studies are not an accurate audit either of existing capacity in nor future infrastructure capacity issues because: much of the limited infrastructure that exists in is privately owned, funded or maintained, and so outside the scope of the infrastructure Page 6 of 11

7 Regulation 18 Sites Consultation Representation providers identified in the 2015 Infrastructure studies, the 2016 Duty to Cooperate Scoping Statement Update and noted in the above extracts, the infrastructure is also inherently small scale -- consistent with the rural character and history of -- and often limited by physical constraints, e.g. topography. These -specific factors have long been recognised in Tandridge Local Plans from 1992 which have all concluded that is not an appropriate location for development (see our 2015 Reg 18 Representation). The importance of infrastructure as a constraint is recognised in both the NPPF and the Planning Practice Guidance, and so we believe that these -specific infrastructure factors should be recognised in the future alteration to the Settlement Hierarchy by moving to the category of unsustainable locations for development (see TDC response number 640 in the following section). 4.0 Settlement Hierarchy and changing the status of Page 7 of 11

8 Regulation 18 Sites Consultation Representation WA response: While we acknowledge Response 981 that recognises the AONB and AONB candidate areas as constraints and Response 640 that services are basic, we continue to disagree with the conclusion in the 2015 Settlement Hierarchy that is a sustainable location for development. As explained in our 2015 Reg 18 Representation, the Settlement Hierarchy methodology ignores important sustainability factors when considering, and so we believe that the conclusions in the Settlement Hierarchy are neither robust nor consistent with the NPPF. The conclusions also do not reflect the inherently limited infrastructure in. Due to the absence of both day to day essential services and local employment, residents have no choice but to travel by car to access a food shop of any size, a chemist, comparison goods, secondary education, health care, and most services and employment. There is no scheduled bus service, and the Council s response recognises the relative inaccessibility of the train station due to topography and distance. Therefore, reclassifying as sustainable further exacerbates unsustainable travel patterns, which page 63 of the 2015 Settlement Hierarchy explains is contrary to the NPPF. Page 8 of 11

9 Regulation 18 Sites Consultation Representation WA response: This statement appears to confirm the assertion made in our 2015 Reg 18 Representation that the previous classification of as a detached built up area is being changed to sustainable rural settlement. We believe that another consequence of the proposed change is that the Green Belt around will also now be subject to rural exception schemes which has not been the case in any previous Local Plan. This conclusion is based on past correspondence between the Parish Council and TDC which explains that rural exception scheme policies currently do not apply because is a detached built up area as explained in our 2015 Reg 18 Representation. We understand that the current categorisation of as a detached built up area recognised the fact that the central part of is inset from the Green Belt but also that has not been considered an appropriate location for development in previous Local Plans due to limited infrastructure and absence of local essential services and employment. We believe that the proposed change is not justified because the evidence base shows that continues to have an absence of local day to day essential services and employment and no scheduled bus service, and so residents are reliant on the car to access both day to day essential services and employment. In addition, continues to have inherently limited and small scale infrastructure. All of this means that is neither a sustainable nor appropriate location for development, and we believe that these contraints also apply to development under rural exception schemes. Page 9 of 11

Regulation 18 Sites Consultation Representation 5.0 Approach 2b WA response: We disagree that higher density in has a part to play in meeting development needs in Tandridge.

10 Regulation 18 Sites Consultation Representation 5.0 Approach 2b WA response: We disagree that higher density in has a part to play in meeting development needs in Tandridge. As explained in our Reg 18 Representation, the proposed density of 70 dph is much higher than the existing density of and so we believe that introducing it would destroy the existing character of. In addition, higher density development in would: be contrary to the recently adopted Neighbourhood Plan which requires that plot sizes remain at 0.2ha or above. be contrary to TLP Part 2 DP8 which seeks to maintain existing plot sizes. result in buildings dominating the landscape which is the complete opposite of the essential characteristic of that all of the adopted Supplementary Planning Documents recognise and support. introduce a high density, urban pattern of development which would be detrimental to the character of which numerous Inspectors have described as spacious and sylvan in planning Appeals. not be deliverable because accommodating the increase in density in would not be possible because of limited, privately owned infrastructure which only has capacity for low density development. Page 10 of 11

11 Regulation 18 Sites Consultation Representation 6.0 Conclusion We believe that the evidence shows that is not a sustainable location for development because the absence of local services and employment and the lack of scheduled bus service means that residents have no choice but to rely on the car for day to day living and employment, which is unsustainable and contrary to the NPPF. also has inherently limited and small-scale infrastracture. These -specific factors have been recognised in Local Plans since 1992 as limiting development, and we believe these remain valid constraints under the NPPF. is also adjacent to the AONB and AONB candidate areas which TDC recognises to be a constraint. We believe that the 2015 Green Belt Assessments for the parcels incorrectly under-state the importance of these parcels to the Green Belt and so these parcel assessments should be amended to show that the parcels fulfill all of the purposes of the Green Belt as explained in our 2015 Reg 18 Representation. This would help to ensure a robust evidence base which we believe is crucial to defending the Green Belt in the future. Page 11 of 11

Review of the Plaistow and Ifold Site Options and Assessment Report Issued by AECOM in August 2016.

Review of the Plaistow and Ifold Site Options and Assessment Report Issued by AECOM in August 2016. Our ref: CHI/16/01 Prepared by Colin Smith Planning Ltd September 2016 1.0 INTRODUCTION 1.1 Colin Smith