Godstone Public Meeting 8 February notes from Catherine Sayer, OLRG
Just to start with a word about OLRG. It’s the Oxted & Limpsfield Residents Group and we have in the region of 2,300 members – mostly from Oxted, Limpsfield and Hurst Green but a number from other parts of Tandridge and in the past couple of weeks that number has increased as people around Tandridge have read the information about the Local Plan on our website.
The group is only concerned with planning matters. I should just say that our aim is not to stop development but to make sure the Local Plan process is carried out properly which is not happening at the moment. We want to meet local housing need, rather than London’s need, to protect the local environment, to protect local infrastructure from being swamped by overdevelopment and achieve a reasonable and proportionate outcome for the District
We have taken advice from legal and planning experts who are helping with our consultation response and they have made very clear that the documents put out for consultation do not comply with national planning policy. In fact, they are not fit for purpose. I don’t say that lightly. I say it because we have taken advice from experts and that is their opinion.
The evidence base is flawed and contradictory and, as a result, none of the delivery strategies are sound. The need figure (OAN) is inflated and the Green Belt assessments have not been carried out according to the tests in the National Planning Policy Framework (the NPPF) and supporting guidance.
So it is of crucial importance for residents to write in to the consultation and to make your views known. We believe that unless there is a public outcry nothing is going to change.
They documents assert there is a "need" for 9,400 new houses in Tandridge District – that means 470 new houses every year which is almost 4 times the current housing requirement. The Council’s own barrister submitted a large amount of evidence to the Planning Inspectorate in 2014 to demonstrate that such high figures are inflated and unreliable. More on that later.
The vast majority of these new houses would be built on Green Belt land for a massive and sustained increase in inward migration from London and not for genuine local need. The Council is not required to provide for large amounts of inward migration at the expense of the Green Belt.
This need figure would mean a likely rise of a third in the District’s population with approximately one new house built for every four existing. This is unrealistic and unsustainable in a predominantly rural District such as Tandridge.
Tandridge has seen loss of local employment and ranks very low on all economic measures, yet the documents unrealistically assume local jobs will also rise by a third and that Tandridge will experience top quartile continuous economic growth for the next twenty years. This is clearly unrealistic.
National planning policy makes clear that Councils should act to protect Green Belt land in their Local Plans yet most of the options assume that significant amounts of Green Belt will be released for new housing. Most of the sites that have been classed as “deliverable and developable” are located in the Green Belt.
One of the striking features about these documents is that there is no vision in them for Tandridge except as a dormitory or commuter district where most people travel to work by car. This is unsustainable and in conflict with the NPPF.
Another striking thing is that the Issues and Approaches document seems to bear little relation to Tandridge and does not reflect the District’s true characteristics - its rural nature and its small settlements - or the aspirations of its residents. At times, it seems to have been written about an entirely different place.
This is important because Paragraph 1 of the NPPF states that it provides a framework within which local people and their accountable councils can produce their own distinctive local and neighbourhood plans, which reflect the needs and priorities of their communities.
None of this applies to these documents. The issues are supposed to be important matters for debate that are relevant to Tandridge, relevant to the sustainability objectives of the NPPF, and to the priorities of local residents and businesses.
The document lists a whopping 73 issues - compared to the 14 in the existing Local Plan, the Core Strategy which do reflect the characteristics of Tandridge – but many of them have little relevance to Tandridge or they are just general statements of fact or wider trends. Those trends appear to have been chosen at random as they are not of any particular significance to Tandridge and, in many cases, the evidence shows that Tandridge performs better than the average with regard to them.
For example, here’s the issue page for “Design and Safety”.
Contrary to what is implied by the wording, Tandridge has no large built up areas and is statistically a very safe and crime free part of England and of Surrey. In fact, the crime rate in Surrey is lower than the England average and within that lower average, Tandridge has one of the lowest rates of Anti Social Behaviour. So these issues are of no special relevance to Tandridge. Issue 4 is just a general statement that could apply to anywhere.
By contrast, issues that are very relevant to Tandridge and are very important to local residents have not been included such as the need to protect the countryside, the Green Belt and open spaces, the need to protect biodiversity and the need to address the existing infrastructure deficit.
Now take Natural Environment - you might think, because of the nature of Tandridge, that this would be one of the longer issue sections but it’s one of the shortest, perhaps an indication of how little weight is being given to the natural environment.
Issue 1: We could find no mention of paintballing or quad biking being an issue in the evidence base. When we looked in the business directory listings in the Tourism “Guide to Tandridge” hosted on the Tandridge District Council web-site, it included one paintball facility and one private quad bike park hosted on a diversified farm. So is that really issue number 1?
Issue 2: The word “may” is contradicted by evidence. This shows that there are in fact a large numbers of areas which have been shown to be rich in biodiversity, for example, as shown in the maps that accompany the Surrey Landscape Character Assessment 2015.
Issues 3 and 4: These are statements of fact and not issues.
None of the issues that actually affect the natural environment here have been listed and this is especially wrong given that it is one of the distinctive characteristics of Tandridge and is given high priority both in the NPPF and by local residents.
Consistent with the NPPF, residents see the Green Belt as being vitally important to protecting the existing open and undeveloped character of Tandridge, particularly as it’s so close to London. Also, the Green Belt here provides opportunities for access to the countryside and outdoor recreation for the population of London and other nearby areas. Surely how to protect it is an issue – an absolutely fundamental issue in Tandridge which is 94% Green Belt. This isn’t just a minor designation here, it is a defining feature.
In the Delivery Strategies too, Tandridge’s distinctive features of open countryside, high quality landscapes, small, rural settlements and long-standing local, rural businesses, are marginalised to make way for a Tandridge that is a dormitory district where residents travel to jobs located elsewhere, mostly by car. The NPPF makes clear this is an unsustainable approach.
Regarding the Green Belt Assessments, OLRG submitted to the Council in June last year a QC’s report detailing flaws in the methodology it was proposing to use to carry out the assessments. The Council made some changes as a result but important points were not acted on and the resulting assessments are flawed.
I have brought some copies of the QCs report with me if anyone would like to see it.
To return to the need figure, known as the OAN, contained in the document by Neil McDonald. The OAN of 9,400 is inflated, unrealistic and unsustainable for Tandridge.
The Council already knows this and yet it has put out the figure for consultation and recommended the document containing it. We say the Council knows this because at a Public Inquiry in 2014 (known as the Caterham Inquiry) it spent thousands of pounds of public money, your money, employing a barrister to point out the flaws in a similarly inflated needs report from GL Hearn and also in one commissioned by the developer who brought about the Inquiry.
At the Inquiry, the Council’s barrister explained that such high need figures are the result of the very high rate of building in Tandridge Distict during the last 20 years.
The reason for this is that a number of large, redundant brownfield sites – ex MOD and NHS sites like Caterham Barracks, St Lawrence’s Hospital, Warlingham Park Hospital – became available for development and were built out at once.
The need figure assumes that this rate of building will carry on into the future despite the fact that all the sites that made it possible have now been used up. This is not a realistic assumption and projecting the past into the future in this way leads to an unreasonably inflated and unsustainable figure.
By accepting an OAN figure of 9,400, the Council has contradicted evidence from its own barrister given to the Planning Inspectorate at the Caterham Inquiry.
We are very concerned that Tandridge Council is not listening to legal advice, neither from a leading planning QC with regard to its Green Belt assessment methodology or from its own barrister regarding the OAN. This seems unreasonable behaviour.
In addition, it is worrying that the Council has used up its supply of brownfield land so rapidly.
Particularly worrying is what has happened over reserve housing land in the District. Reserve housing land is a buffer against having to build on the Green Belt and, under the NPPF, it is supposed to be held in reserve and only released via a Local Plan review, like the one happening now.
In Tandridge District, a reserve site was identified in Whyteleafe Road in Caterham and this should only have been considered for release as part of the current review and with a view to it being developed holistically to make best use of the land and so ease pressure to build on the GB.
However, this site was released by Tandridge in circumstances that remain opaque – and is now the subject of three separate planning applications which do not make best use of the site. Residents in Caterham have taken Tandridge Council to the Local Government Ombudsman over what has happened, but the Council has failed, on three separate occasions now, to reply to the Ombudsman’s questions.
Everyone is concerned about infrastructure which is struggling to cope with existing demand. There has been little new infrastructure put in place to support all the new building that has happened and there’s already a considerable infrastructure deficit.
And so we were concerned to see some of the statements in the Infrastructure documents – for example regarding GP surgeries where the Council states that it wrote to all 10 surgeries in the District but received “no responses” and therefore concluded there is no indication of any specific requirements at this present time.
Oxted Health Centre has now told several of our members they never received any letter. It would be interesting to know if the Godstone surgery received one.
We are concerned, too, that the Issues and Approaches document misrepresents the NPPF and so may have misled residents. In paragraph 11.0.1 it incorrectly paraphrases the requirement of the NPPF with regard to meeting need by omitting reference to the clauses in NPPF 14 and 47 specifying “unless specific policies in this Framework indicate development should be restricted”. These policies include land designated as Green Belt.
Just to close with a couple of specific points to make about Godstone and these Local Plan documents.
Firstly, South Godstone was put forward by the Council as the location for 4,000 new houses and 33,500 thousand square metres of new commercial floor space. It was identified as the place for the large urban extension or new settlement being put forward in delivery strategy 6.
You can find this in the document in the technical assessments called “Infrastructure Baseline Study: Part 2, Appendix 1” which has correspondence with the infrastructure providers on delivery strategies 2a-6.
South Godstone is identified on page 30 of the correspondence from Surrey County Council, dated 25 September 2015, which says:
No. 6: A large urban extension of 4,000 homes and 33,500 m2 of commerical at South Godstone
The issues to consider with this scenario are impact on services a large increase in population might have. According to the Tandridge Local Plan, Godstone has 3 GPs which may need to increase with the proposed development. There is likely to be an increase in cars in the areas which has the potential to cause congestion on the A22 and M25 resulting in an increase in air pollution.
Tandridge’s decision to choose South Godstone was based on expansion at Gatwick but when the Davies Commission report put this on the back burner, other possible areas for an urban extension were also included.
On 12 November 2015, Surrey County Council’s Strategic Highways Assessment Report says:
Paragraph 3.2.2 states
Originally, Tandridge District Council identified a Scenario 6 that focussed potential residential development on South Godstone in relation to a possible expansion of Gatwick airprot. However, Tandridge asked subsequently for this to be excluded from the assessment as it was considered too detailed following the publication of the Davies Commission report on airport expansion in the South-East.
In its main infrastructure report written in November, Tandridge Council state in a footnote that:
The original letter sent out to Service Provider [ed: sic]specifically asked them to consider South Godstone. However, it was considered that there were other settlements that could accommodate an urban extension or new settlement, and under consideration for reasonable alternatives, during the consultation period, this approach was extended to include all appropriate settlements. As such, an email was sent out to all service providers to inform them of this change.
We do not know which other settlements are now being considered too.
Second point: We think Godstone’s Green Belt status may be under threat in these documents. We base this on the contents of the document called Settlement Hierarchy, in particular paragraphs 7.68 to 7.74.
To give you some examples:
In para 7.68, the Council equates Godstone to Smallfield and Lingfield which are not in the Green Belt. It says of Godstone:
That is not to say that the settlement has been untouched by developmenht and infilling has enabled it to become physically denser which has impacted on the character making the majority of the settlement semi-rural in the similar way to Smallfield and Lingfield.
As such it is argued that the significance of Godstone as a key settlement in the district has been noted for some time and whilst many steps have been taken to contain it, development has continued to take place and services have continued to be delivered and accessed.
Of all settlements considered, Godstone performs highest in terms of the Strategic Road Network.....However, even if these roads were not located in the area the score would still be equal to Smallfield’s and supports the alignment of these settlements for hierarchical purposes.
Analysis shows that Godstone is a sustainable settlement that not only enables access to services for the immediate community, but which caters for some of the needs of those from elsewhere too. Godstone is considered to share similar sustainability levels to Smallfield and Lingfield as service centres for the wider locale.
Historically, two Inspectors considering the South of the Downs Local Plan have concluded that Godstone should remain in the Green Belt. One of them said:
Godstone has conservation areas, a Site of Special Scientific Interest and an Area of Great Landscape Value to constrain its future development. The retention of Godstone within the GB is also proposed to give greater protection against anticipated strong development pressures for non-local requirements attracted to the area by proximity to the M25 interchange.
The situation has not changed since 1986 except that traffic levels are higher and pressures for development even greater..
I would think those same reasons for keeping Godstone in the Green Belt exist today. In our view, these are not properly reflected in the Settlement Hierarchy which, in para 7.69, refers only to the M25 point. The content seems tilted towards removing Godstone’s Green Belt status and you may wish to comment on that in any consultation submission.
In conclusion - we have heard it said that what is happening with the Tandridge Local Plan is the government’s fault. We do not think that is true. Tandridge Council’s documents are not compliant with government policy, have not followed the principles in the NPPF to provide sustainable development and have not incorporated the protection for the Green Belt enshrined in the NPPF and in other national guidance.
Please do write in to this consultation. The more residents who do so, the more chance there is that the Council will have to listen.
8th February, 2016. Catherine Sayer, chairman OLRG