Godstone Parish Council - Formal Response to TDC on Local Plan Consultation
Local Plan: Garden Villages Consultation
Godstone Parish Council (GPC) have carefully and in considerable detail reviewed the plan with all the supporting paperwork for the garden village and based on the evidence provided cannot support the proposal. The Parish council has unanimously agreed to strongly and robustly oppose this plan using all means within their remit. We find the case for the garden village approach contains muddled thinking, lacks internal consistency and is based on unrealistic or over stated assumptions making the whole approach seriously flawed. We also believe that by accident or maybe design the information is poorly presented and difficult to follow with many key points buried deeply in wordy documents that are difficult for residents to fully understand.
We find the documents have failed to address in any valid way the key requirement to demonstrate the proposed development is sustainable approach by demonstrating that the three dimensions of The National Planning Policy Framework (NPPF) namely social, economic and environmental have been met. NPPF makes it clear meeting these dimensions is a fundamental and critical requirement of any proposed development. The NPPF also clearly states development should be restricted where it impacts on sites;
‘protected under the Birds and Habitats Directives and/or designated as Sites of Special Scientific Interest; land designated as Green Belt, Local Green Space, an Area of Outstanding Natural Beauty, Heritage Coast or within a National Park (or the Broads Authority); designated heritage assets; and locations at risk of flooding or coastal erosion.’
This demonstrates the plan to develop a garden village on a greenbelt site is not compliant with the requirements of the NPPF. Furthermore, many of the detailed studies that are required to show sustainability such as transports are being differed to a future date meaning this consultation is not taking place on an informed basis as (Tandridge District Council) TDC have yet to produce the necessary evidence base. TDC appear to be rushing headlong into decisions without the supporting evidence potentially wasting public money by pursuing non-viable options. There is also considerable concern that the developers are making major changes to what they are proposing. The recent inclusion by the Blindley Heath developers of land on the east side of the A22 without any reporting or consultation is an indication of how TDC is being led by developers.
GPC feel it is only right to advise TDC that the Parish council has received many comments from residents about these plans and there was not one that was supportive. There is considerable anger in the community with many making it clear that unless these plans are changed it is highly likely that the power of the ballot box will be used at future elections to ensure the views of the residents are fully respected. It is very clear the proposals do not have the support of the residents which is one of the requirements given in paragraph 17 of the Department for Communities and Local Government document on Locally-led Garden Villages, Towns and Cities;
‘New garden villages should have the backing of the local authorities in which they are situated. We expect expressions of interest to demonstrate a strong local commitment to delivery. They should also set how the local community is being, or will be, engaged at an early stage, and strategies for community involvement to help ensure local support.’
Currently TDC will find it very hard to demonstrate local engagement and more importantly local support. Engagement is NOT telling residents what is planned but is listening to comments and more importantly being seen to addressing these comments. We therefore would encourage TDC not to spend more money pursing an approach that is highly likely to be overturned by the electorate in the coming years.
GPC are also concerned that for a number of reasons the nature of this consultation is not fair and balanced making it potentially open to future legal challenge. There is missing information, such as a comprehensive transport study, and the way in which the website requests comments is structured towards making people give a choice as to which site should be chosen to build a garden village. It does not give the clear option to say none of the sites are appropriate or not are suitable. In this respect, it is pre-judging the situation forcing people to decide which site not if there should be any site. It also fails to make clear that in addition to any garden village further new homes will first be built in many locations across the district without explaining how these are sustainable.
We also note that at least 2 and possibly 3 of the sites do not meet at least of the one the Government criterion and possibly a second for a garden village as given in the Department for Communities and Local Government document on Locally-led Garden Villages, Towns and Cities. Paragraph 14 requires that for a garden village to be considered for Government support;
‘The garden village must be a new discrete settlement, and not an extension of an existing town or village. This does not exclude proposals where there are already a few existing homes.’
Neither of the sites at South Godstone or Blindley Heath meets this criterion and given the proximity of Nutfield to the Redhill site the same could apply there.
TDC have also stated that as a matter of policy they do not wish to adopt the approach of developing on land on the perimeter of existing settlements. Yet they immediately contradict this policy by putting forward proposals to build on the perimeter of South Godstone and Blindley Heath. This clearly shows there is muddled thinking and in reality, there is no defined policy other than to respond to pressures from developers.
As stated in previous comments from GPC on the draft local plan we do not accept the population growth for the district is valid. The NPPF makes it clear population growth should be based on the needs of the local community not including a large in flow of population who do not work in the district. The current figure for population growth is dominated by inflow from neighbouring areas such as Croydon and surrounding London areas that has totally distorted the figures. It should be noted that the areas from where the population inflow is coming from have large amounts of brownfield land that could be developed to provide home for their local community. It is long standing that only if all brownfield sites have been exhausted should greenfield sites be considered something this plan has totally ignored. It is well known that developers prefer greenfield sites as they are more profitable for them and it would appear TDC are being driven by the potential profits of these companies.
Furthermore, the population increase postulated also does not warrant building the number of new home proposed. The average UK household size is forecast as 2.42 in 2034 which is a decline from the current figure of 2.43. Census data from the Tandridge show that the district is a very close match to the national data. In 2014 the population of Tandridge was 85,000 with 36,030 households giving an average household size for Tandridge of 2.36). Based on a population forecast for Tandridge in 2034 of 101,000 using an average household size of 2.36 would require 42,796 households. In 2014 there were 36,030 households in Tandridge so the shortfall (42,796 – 36,030) is 6,766 households NOT 9,400. Furthermore, TDC have admitted that planning approval has been given for between 1,500 and 2,000 homes that have not yet been constructed and allowing for the new homes have been built since 2014 making the true requirement around 3,000 new households 1/3 of what is proposed. If you then allow for the building that can be done on the sites that a previous draft of the local plan has identified (about 750) the shortfall become closer to 2,000. None of the developers are proposing plans for this number of new homes.
There has been much talk about how this proposal will improve the affordability of houses in the area for locals. This is a best wishful thinking and more likely outright deception to gain support for the proposal. GPC firmly believe this proposal will in reality make affordability worst for locals not improve it. Compared to local salaries earnings in Croydon and London are considerably greater locals cannot compete with these salaries. This proposal will almost certainly drive house prices in the area up because of the higher purchasing power of those with greater salaries that work in Croydon and the neighbouring London area. The leader of the TDC has gone on the record about how house prices in Tandridge are 14 times the average local salary so we need more affordable homes. As an affordable home is defined as costing 20% less simple maths will tell you the 14 times figure drops to just over 11 times and you cannot get a mortgage of 11times your salary. A pitiful and totally spurious claim that does not withstand the most basic examination and exposes the weakness of the TDC case.
GPC are also very concerned that TDC are using misinformation to support the case they are making. It is not within the gift of TDC to say that new schools and medical facilities will be built in a garden village this decision is not made by TDC and it is totally misleading to state this. All TDC can do is insist space for schools and medical facilities is allocated in the overall plan why is TDC not being open and honest about these matters? It is also very obvious the no schools will be built until there are pupils to attend them which will only be the case once the houses are built so the claim by TDC that the infrastructure will be put in place at the start of the project is unrealistic. If TDC have to resort to this amount of deception it clearly shows the desperation of the position they have created.
GPC has always recognised the need for new housing to support the local community but has equally always believed this should be appropriate and sustainable. With all the evidence above and the clear rejection of the Garden Village concept by the residents that Godstone Parish council represents we insist that you abandon your current strategy and produce a local plan that is not driven by the profit motive of developers but is acceptable to local residents showing that is both appropriate and sustainable approach.
Turning to the proposed Garden Village sites.
None of the proposed sites offers any significant level of local employment with all the developers paying little more than lip service to the creation of local employment opportunities. The NPPF requires;
‘policies should aim for a balance of land uses within their area so that people can be encouraged to minimise journey lengths for employment, shopping, leisure, education and other activities’.
The key factor here is employment; how will this approach minimise journey lengths for employment and promote a low carbon transport? Without local employment any new settlement will create large numbers of people needing to travel at peak times to get to and from work adding to the already congested roads and overcrowded transport systems.
With no significant employment locally all of the sites would become a dormitory town for those working elsewhere. However, none of the sites have the transport infrastructure to support any large-scale commuting that would be highly dependent using cars and therefore require considerable road improvements to be viable. Census data already shows that due to poor or limited other forms of transport in Tandridge about 60% of all travel to work is by car and building more homes especially focused in a small area with limited road access options would only add to this. The scale of the road improvements required would not be achieved by putting in a few controlled junctions or roundabouts as the developers are indicating in 3 of the 4 options. Extensive road widening would be needed to a large number of roads some of which are outside of the district. Increased car usage would be contrary to the Government policy contained in the NPPF requiring developments adopt low carbon transport methods. It should be noted that local stations already have significant issues over car parking and would not be able to absorb even a small increase it people wanting to park to take the train.
These points and others have already been made in the Transport & Accessibility Assessment of Potential Garden Village Locations produced August 2017 produced by TDC that exposes the flaws in all of the proposed sites. It should also be noted that the size of the development at South Godstone and Blindley Heath used for this study are considerably smaller than the number of homes the developers of these sites are proposing suggesting muddled thinking or a total disconnect between the wishes of the TDC and those of the developers. It is highly likely that had this report been available sooner some or all of the sites would have been ruled out on because of the transport issues alone.
As a Parish council, we are most familiar with the sites within the Parish. While having already alluded to the transport issues all the sites have the South Godstone and Blindley Heath sites are totally dependent on the A22 for travel both north and south. It is known from a Surrey County Council traffic survey in 2016 that during peak travel times both in the morning and the evening the road is at or above the official Dept. of Transport capacity of the road in both directions. Adding traffic lights or roundabouts to make it easier for traffic to join the road will not solve this capacity fundamental problem and adding more vehicles will make matters worse. The A22 has some natural bottlenecks in both directions that would be difficult to address. Much of the road is a single carriageway in each direction and because it passed through both South Godstone and Blindley Heath any widening of the road would be difficult and without destroying houses impossible. The options for a bypass round South Godstone or Blindley Heath are limited as this would have to use some of the land proposed for the garden village development. Even if the A22 could be widened and improved to the north the A22/M25 junction is already highly congested with long tail backs into Godstone village, the A25 junction and Caterham Hill during peak hours. Improving this junction would require considerable investment including improvements to the M25. Going south the junction at Felbridge and the A22 through to East Grinstead is already at a standstill during the morning an evening peak times. For many years there has been talk of a bypass as the road cannot be widened but these have come to nothing due to the cost and the robust resistance of the local residents. The outline plans of the developers show little more than a few controlled junctions on to the A22 and have totally ignored the fact that the A22 does not have the capacity to handle more traffic.
It is totally unrealistic to think people will use a bus service rather than a car even if the current bus service was improved. Houses will be built with garages or a parking area or they will not sell and people will own cars. Once you own a car human nature is you will drive it. There is no local train service from Blindley Heath and trains from the closest stations are already overcrowded during the rush hour. While South Godstone does have a station and it will be claimed the service that is currently very limited can be improved this ignores the problem of capacity of the rail lines into London/ Croydon. The entire southern area rail infrastructure is running close to capacity with train operators already extending platforms and using longer trains to cope. Put simply there is now only limited scope for any more growth to the capacity of the rail system. Without a major investment in the whole transport infrastructure the concept of dormitory towns in this area will not work and the garden village approach will not be viable unless it can provide employment for the majority of those who live there. From a transport prospective alone neither the South Godstone nor Blindley Heath site come anywhere close to meeting the sustainability, minimise journey lengths for travel to work and promote low carbon transport requirements as required by the NPPF.
The proposed Blindley Heath site is close to a Site of Special Scientific Interest (SSSI) that is owned by GPC and the Blue Anchor Farm falls within the impact risk zone of the SSSI. Before any work could be carried out Natural England will need to be formally consulted and this appears not to have happened. The nature of the SSSI at Blindley Heath relies on the hydrology of the local area which includes much of the Blue Anchor Farm site. Some of the area is a flood plan but much of the land in the rest of area acts like a giant sponge that absorbs and holds water during the winter months when there is most rain and releases this water during the summer months as the areas dries out. Changing the hydrology on the Blue Anchor Farm site could have a highly detrimental impact on the SSSI that relies on the sponge effect of the surrounding land. If large areas are concreted over less water will be absorbed and there will be greater run off into the local streams and rivers that all feed into the river Eden. This could cause increased and more serve flooding of the SSSI resulting in permanent and irreparable damage to the site. The river Eden is already highly prone to flooding and downstream the town of Edenbridge has regular floods changing the Blue Anchor Farm site that currents absorbs and holds water to delay it entering the local rive system could have a disastrous impact on Edenbridge that could result in legal action against both TDC and the developer.
There is also concern that any development near the SSSI will add to traffic levels and hence air pollution causing damage to the site. With so many people living close by the SSSI is likely to used far more by people to walk and exercise dogs and this increase will harm the sensitive balance of the site and destroy many of the unique features of the site. As the SSSI is legally common land it is not possible to exclude people from the site and it is only it’s off the beaten track location that currently keeps visitors to a small number.
Blue Anchor Farm and the surrounding area is known to have great crested newts, bats, dormice, hedgehogs and based on the number of road kills seen a significant population of badgers all of which will be potentially harmed should any development be undertaken. Deer are also seen on a regular basis in the area and there is a large wild bird population that lives in the trees and hedgerows. It must also be noted that part of the Blue Anchor Farm site is recognised as a flood plain making it unsuitable for building on this will reduce the amount of available land and hence the number of homes that can be built. It also has been brought to the attention of GPC that some of the land the developer is proposing to use for the Blindley Heath site is not owned by the developer nor does the developer have any options to acquire it. One resident only found out the land he owns is included in the plan when he saw the details of the scheme during the recent road show. This land owner has made it very clear they will NOT be selling their land to any developer. This must cast doubt on the viability of the scheme as in the past TDC have stated that they will only consider sites that are truly available to be developed and this means the present land owner has positively confirmed the site is available. Without the developer acquiring this additional land that is owned by several people the number of homes that could be built on the Blindley Heath site will be greatly reduced and coupled with the flood plain issues would result in the site not providing the number of new homes to meet the requirements of the TDC plan.
Parts of the proposed South Godstone sites also suffers from flooding issues that would mean availability of land suitable for building homes is significantly reduced. As with the Blindley Heath site not all the land put forward for building is owned by the developer and there are very strong indications some owners will not be willing to sell their land for development. To further complicate matters part of the South Godstone site is using land that several years ago was sold off in small packages as an investment opportunity, it is believed there are several hundred owners of these packages. Attempts are being made to convince the owners of these packages of land to sell them but it is far from clear if any will. It would only require a few of the owners of these packages of land refuse to sell to ruin any meaningful development of the site.
The northern part of the site is within the impact risk zone for the SSSI site of Godstone Ponds so Natural England will need to be formally consulted, which again does not appear to be the case. There are bats, badgers, dormice, hedgehogs and deer in on the site and given the proximity of ponds and the damp conditions of the site great crested newts are highly likely to be on the site. The site also has areas of mature woodland with native trees that provide habitat for wildlife and birds. Finally, it should be noted that the site contains a war memorial to a pilot who died on the site in WW2.