At the meeting of the Epsom and Walton Downs Consultative Committee last Monday we raised resident’s concerns about the need for a better balance between mowing and cutting long grass and providing space for wildflowers and nature to help biodiversity and tackle pollution.
A new habitat management plan has now been finalised and can be found here
Development of Epsom Hospital Car Park
It has been confirmed that there is not yet a planned start date for this work. There are many pre-commencement planning conditions that have still to be submitted for approval including interim parking arrangements.
We will be keeping a careful eye on this and will be pressing for a public consultation on anything that will impact on residents.
Implications of ULEZ on visiting St Helier Hospital
St Helier Hospital is now within the Ultra Low Emission Zone (ULEZ). It operates 24 hours a day 7 days week. This means that if you choose to drive to your appointment or to visit someone in hospital, or are driven by a family member or friend, you car will need to meet the ULEZ emissions standards or you will have to pay a £12.50 daily charge.
Did you know there is funding available for community projects?
Your Fund Surrey (YFS) has funding for projects for all shapes and sizes in your area
You can find out more about how you can make in happen in your area here
Planning and housing delivery across the UK is in a woeful state at the moment and this I’m afraid is mainly down to Government ineptitude. Many of you may not be surprised about this. The Government has after all hardly shown a clear sense of direction and purpose on the economy or with health and social care so why should planning or housing policy be any different?
National planning policy has been characterised by stop-start reform over recent years. None of which has been implemented. We’ve seen a bewildering number of different housing ministers every few months and a Government that doesn’t seem capable of making up its mind about what kind of local planning system it wants or how to grapple with the desperate need for better, affordable housing.
The latest hiatus has been caused by the Government capitulating to Conservative backbenchers’ concerns over the prospect of development taking place in their constituencies. Last December this resulted in further suggested planning reforms including seemingly an embargo on Green Belt development. Sensible you may think? Well perhaps, except we are still waiting some 9 months later for the Government to confirm whether this will, in fact, be new national planning policy. This delay has caused complete confusion and uncertainty among local authorities about what their local plans should be delivering on housing. Developers don’t know whether they’re coming or going either. Dozens of Councils have now paused their local plans including, as many of you probably know, Epsom and Ewell Borough Council. This is at the very time when we need policy certainty to enable the right kind of development and investment to be encouraged.
There isn’t just confusion over the Green Belt though. A key concern for Epsom and Ewell, and other Councils, is the amount of new housing the Government requires to be provided in each area, otherwise known as ‘the objectively assessed local housing need.’ Without trying to get too technical this is based on a national formula or algorithm called the Standard Method. The problem is it is still based on 2014 data. There is more up to date and reliable 2018 based data and we will shortly have actual 2021 census data rather than just using household projections. Why does any of this matter? Well; the 2014 based household projections were a high-water mark in household projections and grossly inflate the apparent housing figures required. In Epsom & Ewell’s case the 2014 based projections result in a 30% growth in households by 2040 compared to a 8% growth using the 2018 based projections.
Why on earth is the Government still requiring local plans and housing needs to be based on out-of-date data that grossly exaggerate the local housing need? A cynical view, shared by many professionals in the field, is that it is all predicated on the Government’s manifesto commitment to build 300,000 dwellings per annum: a political target, not having any current demographic basis. The more recent data sets give lower numbers, with the sum total of all Council’s housing need figures way below the Government’s 300,000 target. Any method must surely be based on the latest data – to do otherwise undermines the methodology. Is it any wonder that Councils such as Epsom & Ewell are delaying their local plans if they are based on excessive housing targets arising out of political ideology? To make matters worse the inevitable consequence of the Green Belt uncertainty is that these huge housing targets (in Epsom’s case 10,268 dwellings for the period 2022-2040) are now seemingly expected to be built only within the existing urban areas. We must surely resist the worst excesses of high-density, high-rise development. But this seems to be what the Government, either by design or incompetence, is trying to foist onto Epsom.
I sincerely hope that common sense prevails. The Government needs to pull its finger out and provide clear and up to date policy guidance. The development of brownfield sites should certainly be prioritised and incentivised, and the Green Belt should be protected except for where it does not fulfil its strategic role of preventing urban sprawl. Regrettably, the Government’s planning reforms in the Levelling-up and Regeneration Bill currently going through parliament seem unlikely to achieve what is so desperately required, including fixing the housing affordability crisis.
So please don’t blame Epsom and Ewell Borough Council for pausing its Local Plan. Blame Government incompetence. Hopefully, Epsom and Ewell’s Draft Local Plan can be restarted once we know what is expected of us.
Tuesday was an important milestone. It was the first face-to-face Committee meeting since before the pandemic and it was great to have so many local residents give up their evening to come and talk to us. We were delighted to be joined by Simon Durrant. He was responsible for ensuring the Derby could take place safely and without disruption.
Simon opened by saying how pleased he was to have the opportunity to talk to residents about the Derby. He apologized that it had not been possible to let residents know in advance about the different arrangements the racecourse had to put in place to deliver a safe race and avoid it being disrupted.
He thanked us for our understanding and took on board comments about simple changes that would have made a difference for residents. Simon gave us a fascinating insight into the challenges they faced this year and the actions they took to mitigate the risks as they arose in the lead-up to race day. Among them was a discussion with Animal Rising to try to stop them disrupting the world-famous race. He also confirmed the cost of all the additional security had been met by the Jockey Club.
We then had a very lively debate reflecting the national discussion about whether disrupting events and people’s everyday lives was the only way to get attention for urgent changes to the way we live.
Simon also explained changes to entertainments on race days in recent years. The cost and availability of bands post-Brexit and the pandemic meant it was no longer viable to host live bands.
Residents thanked Simon for attending the meeting and for his excellent and really informative presentation. They welcomed, in particular, the Jockey Club’s commitment to working in partnership with local communities.
The meeting moved on to discuss management of the Downs and roadside verges. There was agreement on the need to balance mowing and cutting long grass with providing space for wildflowers and nature to help biodiversity and tackle pollution.
In response Cllr Steve McCormick acknowledged that Surrey County Council hadn’t got that balance right this year and would be making changes for the future. As Chair of the Epsom and Walton Downs Conservators he also committed to discuss the feedback about the maintenance of the Downs at their next meeting.
There were then short updates from Cllr Bernice Froud and Cllr McCormick.
They thanked residents for their support in getting them re-elected as Councillors for a further term. They could often get quicker answers or solutions to residents’ problems with Council matters. They wanted residents to keep in touch about concerns and contact them about issues they couldn’t resolve.
Cllr Froud highlighted the huge number of initiatives being led by the Community and Wellbeing Committee to reduce the high levels of homelessness in the area. Private rented accommodation is at a premium and temporary accommodation for families is among the biggest threats to a sustainable Council Budget. She also said the borough currently has the highest suicide rate in Surrey and the committee was focused on ways to reduce this.
Cllr McCormick talked briefly about his Borough and Council remits and his roles in relation to licensing and planning and in particular the local plan.
The meeting then turned to residents’ questions. They were many and various including:
Residents also urged the Society to prioritise ways to engage and support young people living in the ward.
Post Election Council News Update from Cllr Liz Frost on her Council roles including Environment Committee, Allotments Working Group, Health Liaison Panel and more.
Are the young trees on your road struggling and need watering?
Why not join the Watering Wednesday Campaign?
And/Or become a local tree champion. Find out more from the Epsom & Ewell Tree Advisory Board.
Surrey County Council and four outer London Boroughs have been successful in obtaining a Judicial Review on some aspects of the expansion of the Ultra Low Emission Zone by the Mayor of London.
More information is in the link below as reported by Leatherhead Living.
Local Plan.
Thank you to those who responded to the Council’s consultation on the draft Local Plan, which has now closed. As I said in my previous update, you were being consulted on a draft, based on the evidence of a comprehensive library of evidence looking at the borough’s situation, resources, and the requirements of the Central Government. Without complying with their unrealistic housing targets – or at least showing robust evidence as to why we were not – the Government would find the Plan ‘unsound’ and not approve it. Not having an up-to-date Local Plan makes us vulnerable to having the Council’s refusal of planning applications overturned, as happened with the Langley Bottom Farm proposal. It is for this reason that we need to press on with the Local Plan process.
Feelings have been running high amongst residents about the contents of the draft, and last night a special Full Council meeting was held on a motion that, apart from the work on analysing the results of the consultation, the Plan process is paused. The reasons included to undertake further work on the brownfield sites and consider further options that do not include using any green belt land. This was supported by the majority of Councillors.
Council officers will assess the responses, which would have formed further evidence for the next stage of compiling the Plan (regulation 19). However, this cannot progress at the moment as the draft Local Plan is now paused. It is a long and complex process.
Enforcement actions.
The Borough Council’s teams have been acting on anti-social behaviour and environmental matters. This includes asking drivers to turn off engines when waiting, e.g. outside schools, and making more frequent visits to ‘hot-spots’ for litter and other ASB.
Queen’s Green Canopy.
Last week we held a brief ‘tree planting’ ceremony on the Downs as part of the late Queen’s Green Canopy events – which King Charles extended till the end of this month. It was a very windy day, but our new English Oak tree was duly ‘planted’ by the Mayor and we hope will flourish.
Covid bench.
Today marks 3 years since the first pandemic lockdown here in the UK. The borough has installed Covid memorial benches in each ward to enable people to have a quiet place to sit and reflect on the events that had such a lasting impact on our lives. In this Ward, the benches are on the Woodcote Millennium Green (behind Epsom Hospital) and by the Top Car Park on the Downs. This morning we laid flowers on the benches in an act of remembrance.
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.
Housing Numbers
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.
Green Belt
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.
