Over the past few years, national planning policy and guidance has changed significantly. As a result, Epsom & Ewell Borough Council’s existing Local Plan is now out of date, which can mean that the Council is unable to adequately defend planning applications that they refuse if they are taken to appeal. The Council is in the process of producing a new one in line with current national policy and guidance. This new draft Local Plan, which will replace our existing one, must be submitted to Government scrutiny and found ‘sound’, i.e., fulfilling National requirements, to be adopted.
The Council is currently consulting on their first draft of the Local Plan – providing everyone with an opportunity to give feedback. The consultation closes on 19th March. Your response to the Local Plan questionnaire together with any comments will help the Council refine the strategy, site allocations and policies.
All consultation feedback will be reviewed and considered in the next version of the draft local plan which will again come back to public consultation around March 2024 for a further six-week public consultation phase. This version of the plan will be more detailed and include additional information on items such as infrastructure.
The aim of the new Local Plan is to help meet the borough’s future needs, making sure development is planned in a coordinated way while respecting our area’s character, environment and heritage. It is a long-term plan covering the next 15 years up to 2040 and is intended to guide and shape what can be built and where, to make sure we have the right new homes, workplaces, green spaces, transport and facilities for current and future generations. The plan can also help us address important issues, like climate change and improving biodiversity, by encouraging sustainable development.
The strategy, policies and land allocations contained within the new Local Plan will be important for determining future planning applications and for guiding investment.
WERS would encourage you to look at the draft Local Plan itself, which can be found on the Council’s website at Draft Local Plan (Regulation 18) 2022-20–0 – Epsom and Ewell Borough Council Consultations (inconsult.uk)
The documents can also be seen at the Town Hall and the borough’s libraries.
There will also be an exhibition and Council Officers available to speak to you in person at the following places:
- Monday 13 February 14:30 – 19:30 Bourne Hall, Azalea Room
- Thursday 16 February 12:00 – 17:00, Ashley Centre, Central Square
- Tuesday 21 February 14:30 – 19:30, Bourne Hall, Azalea room
- Wednesday 22 February 10:30 – 15:30, Community & Wellbeing Centre, Sefton Road
- Saturday 25 February 11:00 – 16:00, Ashley Centre, Central Square
- Tuesday 28 February 10:00 – 15:30, Community & Wellbeing Centre, Sefton Road
A quick guide to the main proposals:
- A minimum of 5400 new homes by 2040, i.e. 300 dwellings per annum (which represents 52% of the housing need according to the Government’s ‘standard methodology’ calculations)
- Development will first be directed to the most sustainable locations, making the best use of previously developed land in the urban area. In sequential order these locations are: 1) Epsom Town Centre; 2) Other centres and train stations within the urban area; 3) Principal Movement corridors within the urban area; 4) The wider urban area.
- Providing a significant number of affordable homes, both helping our young people to afford homes and supporting those at risk of homelessness.
- 3.6% of the borough’s total Green Belt released to help meet the housing needs of local people.
- Safeguarding strategic employment sites including Kiln Lane and Longmead industrial estates and encouraging new employment floorspace within Epsom town centre.
- Town centre focussed retail and leisure.
- Protection of a Racehorse Training Zone.
- Ensuring development is supported by the necessary physical, social and green infrastructure to meet people’s current and future needs.
- Supporting measures that prioritise active and sustainable travel modes.
W(E)RS assessment and views
A – comments from a Woodcote and Langley Vale perspective
W(E)RS generally supports the proposed growth strategy for the borough, which aims to provide sufficient new homes (including affordable housing) to meet our future local needs whilst respecting the environmental and policy constraints in our Borough which includes 42% of land designated as Green Belt together with other important designations such as Local Nature Reserves, Sites of Special Scientific Interest and Sites of Nature Conservation Importance.
W(E)RS also considers that there is much to commend in the Draft Local Plan with regard to supporting businesses, creating jobs, infrastructure improvements, protecting the historic environment, climate change mitigation and adaptation. The proposed designation of a Racehorse Training Zone covering much of the unbuilt parts of Woodcote and Langley Vale ward together with an associated Equestrian and Horse Racing facilities policy is very much welcomed.
It is unfortunate that, to even facilitate 52% of our housing needs, it is proposed that five Green Belt sites are removed from the Green Belt’ and allocated for housing. These areas are in the north of the Borough and close to transport networks. W(E)RS has considered these areas and concluded that, if we have to lose any Green Belt land, these are the most appropriate and are deliverable for housing. If there is no loss of Green Belt land there will be additional pressure to build at even increased densities and heights within the existing urban area to make up for the housing shortfall and the delivery of much-needed affordable housing will be much reduced.
B – concerns
W(E)RS has, however, identified the following matters contained in the Draft Local Plan and its associated evidence base documents that raise potentially significant issues in Woodcote & Langley Vale ward. You may wish to include these in your response to the consultation.
With regard to Green Belt, there is a matter of great concern to WERS. The covering report to the Council’s Licencing and Planning Policy Committee on the Draft Local Plan at para 2.15 makes clear that ‘During the Local Plan consultation, we will be undertaking a call for sites exercise to identify whether there are any additional potential development sites within the borough that could be suitable and available for development. Therefore, future iterations of the Local Plan may contain sites that do not currently feature in the Local Plan.’ Most of these potentially developable other sites have already been identified in the EEBC Land Availability Assessment 2022 (LAA) largely based on sites promoted by landowners and developers through the earlier call for sites process. This includes the 5.24 hectare field between Langley Bottom Farm and Langley Vale village which is being promoted by the owners Quinton Estates and which is identified in the LAA as potentially delivering 100 dwellings.
C – The fine details
It is important to emphasise that the inclusion of sites in the LAA does not necessarily mean that these sites will be allocated for future development in the Local Plan. They would be subject to further consideration through the Local Plan site selection process and Sustainability Appraisal and Strategic Environmental Assessment (SEA) if necessary (i.e. it can be demonstrated that all reasonable options have been explored to meet future development needs). Only then, could it be concluded by the Council that exceptional circumstances exist to justify changes to the Green Belt Boundary.
What is alarming is that the Council’s Green Belt Study (which is yet to be completed) defines one of its purposes as ‘to identify defensible Green Belt boundaries for those sites identified as available through the Land Availability Assessment, with a view to potential release for development purposes in the longer term should this be necessary within the new Epsom and Ewell Local Plan 2022-2040.’ The Council’s Sustainability Appraisal into the Local Plan examines the sites included in the Land Availability Assessment and places the Langley Bottom Farm field site as fourth in a provisional list of further sites (over and above those already proposed for Green Belt release in the Draft Local Plan). The Sustainability Appraisal states that ‘The LAA does not differentiate between the 23 available Green Belt site options, in terms of their suitability for release for development. However, on the basis of the analysis set out below, it is possible to identify a tentative sequential order of preference (N.B. this is a key step and, as such, views on this order of preference are sought through the current consultation, and further work will be undertaken to inform plan finalisation.’ WERS would therefore emphasise that it is particularly important to respond to this consultation request.
The Sustainability Appraisal refers to the Langley Bottom Farm field site as: ‘The site in question comprises a single field to the south of the village, and is the only feasible location for a significant extension to the village, with a view to delivering new community infrastructure and supporting wider place-making. Also, the possibility of a new defensible Green Belt boundary can be envisaged, given woodland to the east and Ebbisham Lane to the south, which marks the northern extent of the Centenary Wood, and where there is a cluster of farm buildings with planning permission for 20 home redevelopment (ref. 20/00475/FUL).’
The Sustainability Appraisal does state that the site is clearly constrained in landscape terms, as it comprises the northern extent of the Area of Great Landscape Value (AGLV) designation within the borough and that this might eventually be included in an extension of the Surrey Hill AONB which is currently under review. Aside from environmental constraints, the Sustainability Appraisal concludes that Langley Vale is very poorly connected in transport terms, in comparison to other locations under consideration that are closer to Epsom town centre and/or a rail station.
It is for the above environmental and sustainability reasons and the fact that there is already a very clear defensible Green Belt boundary around Langley Vale village that WERS will be responding to the Draft Local Plan consultation and its associated Sustainability Appraisal document. WERS will be making the strongest objection to any potential change to the Green Belt around Langley Vale on the basis that it plays a vital part in ensuring the Green Belt continues to fulfil its role, especially in one of its stated key purposes, namely to ‘Assist in safeguarding the countryside from encroachment.’ Consequently, the Langley Bottom Farm field site should not be included in any sequential list of potential Green Belt site releases.
WERS would urge all residents who value the role and amenity value of the Green Belt to make their views known based on the above matters. If you have any further questions, please send these to John Mumford, planning advisor on the WERS Committee, at firstname.lastname@example.org