Woodcote (Epsom) Residents’ Society (W(E)RS) response to the Epsom and Ewell Consultation Draft Local Plan 2022-2040
W(E)RS has responded to the Questionnaire and but also wishes to submit this covering statement.
W(E)RS considers that there was much in the Draft Local Plan to support. The aim of providing sufficient new homes (including affordable housing) to meet our future local needs whilst respecting the environmental and policy constraints in our Borough is laudable but as so often is the case with these things – the devil is in the detail, especially when it comes to suggested Green Belt release and more intensive urban redevelopment. Other proposals in the Draft relating to supporting businesses, creating jobs, infrastructure improvements, protecting the historic environment, climate change mitigation and adaptation are less controversial and can be broadly supported. Similarly, 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.
W(E)RS has expressed reservations about the scale of residential development being sought. We fully acknowledge that there is a serious housing shortage in the Borough, as elsewhere, and indeed a particular problem with affordability given the disconnect between house prices and household incomes and the woeful delivery in recent years of ‘affordable’ housing almost entirely down to unhelpful Government policy and guidance on this matter. However, the housing need figure generated by the Government’s standard method calculation of 576 dwellings per annum (or 10,368 dwellings over the Local Plan period) is questioned as it is based on out-of-date 2014 base Household Projections. More recent household projections indicate that in all reality the borough’s population will be much lower than claimed which translates through into around 7,000 fewer households requiring dwellings than the 2014 base projections would suggest. A consequence of this is that there should be less pressure to build on areas of Green Belt and to such high densities within the existing urban area.
This is a matter of great concern to W(E)RS. The covering report to the Council’s Licencing and Planning Policy Committee on the Draft Local Plan stated 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 (LAA) 2022 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.
The Council’s Sustainability Appraisal into the Local Plan examines the sites included in the LAA 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).
W(E)RS objects 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.
Residential Amenity and Character Concerns
W(E)RS objects to the proposed dramatic decrease in the minimum requirements for private garden space from the existing 70 sq m for 3 bedroom dwellings to 20 sq m under proposed Policy DM1. With increased emphasis on homeworking and the probability of future Covid style epidemics we believe there needs to be sufficient outdoor space to meet the needs of its occupiers designed into new residential environments. Such low minimum amenity standards will merely serve to encourage back-land development and sub-division of plots in a way which would be often harmful to the character and appearance of established residential areas.
For the same reason W(E)RS also objects to the revised density guidance in the Draft Local Plan which proposes that the existing maximum density policy of 40 dwellings per hectare (dph) designed to maintain and enhance the visual character of the Borough be replaced by minimum densities in the urban areas of 40 dph or 60 dph near to movement corridors such as Dorking Road.
Local Open Space
There will inevitably be more development pressures, especially for housing within the existing urban areas. W(E)RS considers it important that this Draft Local Plan safeguards those green areas of particular importance to local communities which may otherwise be under pressure for housing. Government guidance advocates the designation of Local Green Spaces through the local plan process in circumstances where such areas ‘hold a particular local significance, for example because of its beauty, historic significance, recreational value, tranquillity or richness of its wildlife.’ W(E)RS accordingly proposes that a Local Green Space policy is introduced and designation of appropriate sites on the Proposals Map following local consultation.
Built Environment and Design
W(E)RS wishes to make representations about the inadequacy of the draft Plan’s policy guidance on what high quality design will comprise. Whilst it is acknowledged that detailed design guidance can often be provided in design briefs and design codes for particular redevelopment W(E)RS requests that there should at the very least be a height guidance policy within the Local Plan. This aspect of development is often the most controversial as we have recently experienced with the Guild Living and Multi-storey Car Park schemes at Epsom Hospital in addition to high rise schemes being advocated in Epsom town centre and Stoneleigh. The effective setting aside of the previous DM13 Building Heights policy was, in the view of W(E)RS a key factor in unacceptably high-rise developments being proposed over recent years. This must be discouraged in the new Local Plan through a replacement buildings height policy which would give some degree of clarity to developers and landowners as required by Paragraph 127 of the NPPF.
WERS Response to Draft Local Plan linked below.