Cllr Steven McCormick (RA Woodcote Ward) Chair of Epsom and Ewell Borough Council’s Licensing, Planning and Policy Committee writes for the Epsom and Ewell Times to answer many of the questions being asked about the Draft Local Plan. The views are his own and do not necessarily reflect the position of the Council.

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Below are FAQs and items from the Epsom Green Belt group page and other sources.  

The responses below are my own view and do not reflect that of EEBC or officers.

What is the Greenbelt and why should it be protected?

The Green Belt of land encircling London has protected by law since 1938 to keep urban sprawl in check, preventing towns from merging together and promoting the recycling of derelict land.

These purposes remain as important as they ever were, but now we know that retaining these areas is also critical in slowing and reducing the impacts of climate change, reducing flooding, reducing air pollution and providing essential habitats for wildlife.

Reply 

Green belt exists throughout the country and is a barrier to prevent urban sprawl in planning terms.

• Isn’t it prohibited to build on Greenbelt Land?

Other than for very limited uses, Greenbelt Land is protected by law from development. It isn’t permitted to build housing on Greenbelt Land except in ‘Exceptional Circumstances’.

Reply

It has heavy protections but very special circumstances must be shown before development can be approved.  In our draft local plan we do not have enough housing supply with brownfield or urban developments and have had to consider including green belt sites.  

An alternative is to build higher and denser in our brownfield/urband sites.  This has a downside of likely very tall buildings and a reduction in affordable housing delivery.  

Is there any Greenbelt Land that it is OK to build on?

Some land in the Greenbelt has buildings on already, or has sites where buildings used to be. This is called ‘Previously Developed Land within the Green Belt’. Without considerable remedial work, this land doesn’t support much wildlife and is suitable for development.

• Are there exceptional circumstances that require building on the Greenbelt now?

No. The Borough can continue to meet the historical trend of growth in housing need (225 homes / year) through development of Brownfield sites only.

Every year Epsom & Ewell Borough Council, as with all other Councils nationwide, have a housebuilding target. As with many other Councils, the target has not been met each year. Whilst it would be difficult (but not impossible) to meet a 576 house target each year, this is a normal situation both in Epsom & Ewell and across the country. It is not exceptional.

The Draft Local Plan states that this is exceptional to justify their plans to build on the Greenbelt.

Reply

The historical trend is not what local plans are driven to achieve by central government.  The start point is based on the standard method, which our draft local plan achieves 52% of that need.  

Yes there is a consultation on various aspects of the NPPF but at this point in time our target remains based on the 2014 ONS data.  As is shown by the recent response from the planning inspector to MVDC it is not current policy, it is consultation and we have to progress on what we have in front of us and that which is currently law.  

Furthermore each year a council doesn’t meet its housing delivery target they have to justify to central government the reasons for this and the plans to address this.  The council runs a risk of being designated which means we loose our local planning control and a central government inspector takes over.  

Exceptional circumstances are shown via an evidence based approach to a draft local plan.  This is what we have done.  The end goal is to get a new local plan adopted and to do that it has to stand up to scrutiny and challenge.  

• Were Clarendon Park, Livingstone Park, and Manor Park built in the Greenbelt, and if so, what’s different about these proposals?

All these estates were built on the sites of the old cluster of hospitals. These were Previously Developed sites within the Greenbelt, therefore developing these sites did not have a detrimental impact on environment and wildlife.

Reply

These were sites in the green belt.  They had to prove the previously developed land situation to show very special circumstances existed to develop in the green belt.  

Further evidence was provided to support the development in the green belt of these sites.

• There’s an area of Greenbelt on the Local Plan map that isn’t on the Priority Development list of 9 sites, does this mean it is safe from development?

No. All sites bordered in green on the map have been put forward for potential development. If the Council includes any Greenbelt sites on the Priority list, all other Greenbelt sites are at risk of future development.

Any site may be included in a future iteration of the current Local Plan, could be included by the Planning Inspector in the course of their review of the current Local Plan, or could be included in future Local Plans.

Reply

As part of the process a call for sites was made which is a requirement of the local plan process.  All sites put forward by landowners and developers have to be evaluated for viability and whether they can deliver housing.

Some sites are more deliverable than others.  

Some sites are not viable I.e the development costs would be too much.

Some sites proposals may be amended to make them viable or deliverable.

The next stage of consultation, regulation 19, March 2024 will see a more detailed draft local plan put forward for a further six week public consultation.  

Additional sites may come forward between now and then.  

• Does the Draft Local Plan meet the need to supply affordable housing for lower paid workers and the homeless?

No. Although the plan discusses building 40% ‘affordable housing’ on Greenbelt land and 30% on Brownfield land, this housing may not actually be affordable to those in need.

The definition of ‘Affordable Housing’ in the National Planning Policy Framework is houses sold at a 20% discount to their market value. In Epsom, the average property sold over the last 12 months was £630k, to an average property sold as ‘Affordable Housing’ would cost about £510k. This is well out of reach of most people in need of housing in the Borough.

Reply

The Housing and Economic Delivery Needs Assessment (HEDNA) describes the requirement for affordable units across the plan period.  The number is circa 670 per year.  To start describing cost of housing in the way above is misleading.    There are other options, First Home scheme, social rent scheme, shared ownership schemes to help residents get a home.

Over the last 2 years the borough provided 12 affordable units.  

The borough spent approximately £1.5m on overnight homeless accommodation for our residents.  This is not sustainable.

This needs to change.

The draft local plan is seeking to deliver 30% affordable from brownfield and 40% from green field developments.  

• Is it permissible to submit a Local Plan which doesn’t meet the full housing need calculated under the government’s ‘Standard Method’, and can it be approved?

Yes. Many other boroughs have done so or are planning to do so such as Mole Valley, Elmbridge, with Worthing Council recently got its Local Plan approved by Inspector with only meeting 25% of its target.

Reply

MVDC have had a response from the planning inspector to make progress.  

Submitting a plan with numbers significantly below the target will likely yield the plan being found unsound, thrown out, forced to re-do or the planning inspector does it for us.  

Epsom has a number of 5400 of 10,368, 52% of the target.  

• I’ve been told that Mole Valley had their request to remove Greenbelt from their Local Plan rejected by the Planning Inspector, is this true, and if so how does it affect the Epsom & Ewell Local Plan?
  
  Mole Valley is in the difficult position of having originally submitted a Local Plan to the planning Inspector which included developing Greenbelt. A number of Councillors were voted out of office as a result and the new Councillors are trying retrospectively to amend the submission. There appear to be significant hurdles to doing this.

  Despite that, the Inspector has offered to pause the examination to give time for new Government legislation to be issued (see FAQ 10, below) which may support their case for a change to the submitted plan. It looks like Mole Valley has been offered a lifeline for their challenge.

  The implications for Epsom & Ewell are:
  a. It is better to exclude Greenbelt from the initial Local Plan submission to the Planning Inspector that to try to change the submission later.
  b.The Planning Inspector recognises the likelihood that changes to the National PlanningPolicy Framework will strengthen the case for excluding Greenbelt from development.

  There is no reason to push ahead with a flawed plan that destroys precious Greenbelt.

Reply –

The planning inspector responded to the request stating –

She wishes to make it clear that there has not been a change in Government policy. Rather, the Government is currently consulting on a draft NPPF. Until Government policy is changed (expected in Spring 2023), the Inspector will continue to examine the submitted Plan against current Government policy, contained in the NPPF 2021. She therefore cannot recommend MMs predicated on draft Government policy that may or may not come into effect in its draft form.

The full document can be found here – https://futuremolevalley.org/wp-content/uploads/2023/02/ED57-Inspectors-Note-23-Reply-to-Councils-Note-31-on-Removing-Green-Belt-Sites-from-the-Local-Plan.pdf

• I heard that the Government is going to abolish the mandatory housing target and no longer require Local Authorities to review Green Belt for housing. Is this true?

Yes, The National Planning Policy Framework specifically states that, with suitable justifications (such as protecting Greenbelt), the full housing target need not be met.

The government intends to implement many of its proposed policy changes by May 2023.

Policy changes include a change to emphasise that the standard method for calculating housing need is “advisory”, removal of the requirement for councils to continually demonstrate a five-year housing land supply, and new lines that stress councils are not required to revise Green Belt boundaries or build at densities out of character even if they are set to miss their house building targets.

Emerging policies do carry substantial weight in planning decisions, therefore at least 20 Councils have already withdrew or paused their Local Plan process, citing the upcoming policy changes. Therefore it is entirely up to EEBC if they would want to be against Central Government policy and continue pushing for large housing development on Green Belt.

Reply

The government has said they are going to consult on possibly changing the housing number calculations.   Until they do and change the law and related policies we have to proceed under the current requirements.  

MVDC has had a response from their planning inspector saying exactly that.  

Until the regulations, policy and law changes we have to use what is currently in place.  

• The roads into Epsom are already overcrowded, particularly at peak times. What are the plans to address the additional traffic from all the new housing?

According to the 2011 census, there is an average of over 1.5 cars per household in Surrey. That equates to 2,300 new cars from proposed building on the Greenbelt Horton Farm alone.

There are no obvious ways to build new roads or expand existing ones.

No infrastructure plans have been put forward to show how this increased traffic will be managed. Expect long queues!

Reply

Infrastructure is a consideration once the high level draft local plan has been published.  The council works with infrastructure delivery partners after regulation 18 to determine what new additional infrastructure may be required and needed to support the proposals.  

Infrastructure Delivery Partners rarely come to the table before a draft local plan is published.  

• It is difficult to get my child into primary school / secondary school as there aren’t enough places. If the proposed houses are built, will I still get a school place for my children?

Local primary and secondary schools are either full or near to capacity.

No plans have been put forward for building new schools or expanding existing ones. No land has been allocated for this either. There is no guarantee of a school place and no priority for existing residents.

Reply

Similar to the roads section above.  

• I see there are plans to build new sites for Gypsies / Travellers. How many will there be and where will these be located?

Regulations require Borough Councils to provide for the Traveller community. The Council has proposed putting 10 traveller sites on the Greenbelt Horton Farm site.

No explanation has been provided for why they are proposed to be located in a single area or on a Greenbelt site.

Reply

Further detail will be provided in the next stage of the draft local plan.  Comments from the consultation will be considered, the next stage of how these sites maybe implemented will be further detailed.  

• Why is the housing target so high?

The short answer is that it doesn’t need to be.

Here’s some maths to show why…

The actual population growth of the Borough over the last 10 years has been 5,798, an average of 580 people/year (Source: Draft Local Plan para 1.39).

There are 2.58 people in an average household in the Borough (Source: Draft Local Plan para 1.39).

If growth continues at this rate, there would be a need for 225 new homes to be built each year.

The target included in the Draft Local Plan is for 576 new houses per year. This is based on a ‘Standard Method’ (Source: Housing and economic needs assessment – GOV.UK (www.gov.uk)) which uses a household growth projection from 2014 as a starting point.

The more up-to-date 2018 household growth projection is considerably lower than the 2014 projections, reflecting more recent real growth figures.

This is then increased by 40%, based on the current high cost of housing in the Borough, to give an even higher housebuilding target than the inflated 2014 based figure.

As a result, the quoted housing target is more than 2.5x the need based on the historic population growth in the Borough.

Reply

The housing target is set by central government via the standard method using 2014 ONS data.  

Even with with the standard method number our draft local plan is currently showing a 52% delivery of housing supply.  5400 vs target of 10,368.

• There seem to be lots of sites within Epsom’s urban area that are vacant, run down or underutilised, could these be developed for housing instead of the Greenbelt?
  Yes.
  Some of these sites have already been earmarked by the Council for development, but many haven’t.

  The National Planning Policy Framework (which contains mandatory guidance for preparing the Local Plan) para 141 states that before concluding ‘exceptional circumstances’ exist for developing on Greenbelt, the strategy must:

  a) make as much use as possible of suitable brownfield sites and underutilised land; and
  b) optimise the density of development… including… a significant uplift in minimum density standards in town and city centres and other locations well served by public transport.’

  There are lots of sites across Epsom town / urban areas which are not being put forward for use in the Local Plan or appear to be underutilised (for instance the Council’s proposals for the town hall site don’t meet the minimum density requirements they set in policy S3).

Reply

The Epsom Town Masterplan is due to complete at the end of March and will input into the next stage of the draft local plan.  The site area will be reviewed, optimised with options coming forward to members for a steer/view.  

• Does the Borough have to build houses on Greenbelt Land to meet the housing target?

No. In fact it is only permitted to build on Greenbelt in ‘Exceptional Circumstances’.

The National Planning Policy Framework specifically states that housing targets need not be met if it would require building on the Greenbelt (para 11 note 7).

Reply

Similar to an item above.  If we are unable to deliver all our housing from brownfield or urban sites we have to consider green belt.  Some green belt sites have been put forward during the call for sites which have been evaluated.  A small number of these are considered viable at this point and could deliver housing.  

• The Ashley Centre Local Plan display states that development will be ‘Located away from areas of flood risk’. How has Horton Farm been selected for development as it regularly gets flooded?

‘Horton’ roughly translates from Old English to ‘muddy farm’. Both the Environment Agency flood maps and Epsom & Ewell Borough Council’s own 2018 Flood Risk Assessment show that Horton Farm is at high risk of flooding from surface water (because there is clay just below the surface) and in practice it is often flooded. A ‘Critical Drainage Area’ runs through the site.

The Draft Local Plan appears to ignore the flood risk assessment and only considers flooding from rivers.

If the Greenbelt Horton Farm is built on, there is a significant risk that it will result in increased flooding into West Ewell and Ewell Court.

Source: Epsom & Ewell Borough Council Strategic Flood Risk Assessment 2018, Figure 108. Brown areas are in the highest category of flood risk.

Reply

The Ashley Centre Local Plan, read the display boards showing key items of the draft local plan in the Ashley Centre.

Any site being put forward would still need to submit a full and thorough planning application which may include flood risk evaluation and mitigation.  

The draft local plan does not get into that level of detail so the statement that it ignores the flood risk assessment is misleading at best.  

• I’m told the Council has spent £1m on preparing this plan. Would it be expensive to change direction now?

The money that has been spent is largely on reports that were required to be prepared whatever direction the plan went in.

The earlier changes are made to protect the Greenbelt, the cheaper it is to make those changes.

Reply

All funds spent on the local plan have been shown in LPPC and S&R committees.  

Yes there are consultants involved to prepare reports and evidence as we don’t have that skillset;  this is not unusual and many other boroughs adopt the same approach.  

It has to be understood that there is a large body of evidence behind the local plan.  Adding or removing sites from the spatial strategy itself has a knock on of recreating that evidence.  

The decision point on changes to the spatial strategy and which sites are in or out has no relevance on cost.  The work still needs to done, the evidence still needs to be created.  

If the plan is paused then the evidence base may need to be re-worked depending on the length of pause.  

• How will developing the Greenbelt land affect wildlife?

The Greenbelt land is a vital habitat, providing food and shelter for hundreds of species of mammals, birds, amphibians and insects as well as native trees and flowers.

As an example, Horton Farm supports roe deer, bats, greater spotted and green woodpeckers, sparrowhawks, house sparrows, stag beetles, song thrushes, hedgehogs, common toads, and other priority species.

Reply

Any planning application coming forward would have to consider the environmental impact.  The updated policies coming forward in our draft local plan are up to date and current on once adopted would help structure applications coming forward.

What follow are questions I was asked at the Bourne Hall and Ashley Centre drop in sessions.  

Q:  Why aren’t residents at and around the proposed sites being communicated with?  In the same way as when a planning application is lodged, impacted households get informed.  

A: The planning application approach typically has limited effectiveness and a broad communications approach to all borough residents was selected.

Q:  Residents only just heard about this because of the Ashley Centre display boards.

A:  This was the goal of the boards in the Ashley Centre factored with social media, Borough Insight, Libraries and other outlets.  

Q:  Is this the only chance we have to input?

A:  It is stage 2 of a 7-stage process.  This is the first consultation piece.  

Q:  Infrastructure.  Where is it in the plan(s)?

A:  At this stage infrastructure delivery partners rarely come to the discussion table at such an early stage.  This is part of the motivation to get our draft local plan published to kick start those discussions.  There are sections in the draft local plan document on infrastructure but they are high-level at this stage.  

Q:  Why are we putting the green belt forward?  

A:  Based on the brownfield and urban sites that have come forward via the call for sites we are very short of our housing number target/start point of 10,000+  We either intensity our brownfield and urban sites by building higher or we consider green belt sites that have come forward.  

Q:  Why are only 90 homes in the Town Hall allocation?  

A:  The Epsom Town Masterplan is due to complete in March and will inform the draft local plan into Regulation 19.  It is expected this number would increase significantly especially given the steer from council to move to 70 East Street.  

Q:  Where does it stop?  After this local plan do we get asked for more housing by the government?  

A:  A very good question, at this point based on what we know, come 2040 we may be challenged again to deliver more housing.  

Q:  Mole Valley has paused and removed all its green belt.  Why can’t we do the same?

A:  In theory we can however Mole Valley are at a very different stage.  Pausing at this point would be to wait and see what the outcome of the consultation, mainly on housing numbers.  Our draft local plan currently proposes to deliver 52% of the housing number.  Any update on housing numbers would only beneficial to us if that number came down significantly   In the meantime we need to progress.  

The planning inspector has just replied and told MVDC that they can’t remove green belt via the major modiciations method and that a pause is possible but they should consider not protracting the examination.  

Q:  As these sites are in the draft local plan is that it?  

A:  No, the process flows through to Stage 7 and even then a planning application is still required.  

An opinion piece from Cllr Eber Kington: This week SCC announced a seven-year contract worth £96.5 million, with private company Marston Holdings Ltd, for parking and traffic enforcement. In April, SCC will be centralising parking enforcement, a service which currently is managed by Surrey’s Borough and District on behalf of the County.

Image: Cllr Eber Kington on patrol

The accompanying comments to the announcement, made by the Kevin Deanus, Cabinet member for Highways
and Community Resilience, promise much. But residents need to be aware, SCC does not have a great track
record when it comes to taking back decision making and centralising services previously provided by the Borough Council on behalf of the County.

When SCC took back the maintenance of highway verge trees the policy became one of no maintenance unless a
tree is diseased, dying or dead. And no longer will SCC automatically replace a tree lost to our urban streets.
Instead, our residents have to pay £25 just to get a location looked at. £25 which is not refundable and, as often
is the case, ends with the site being declared as unsuitable for a tree.

In April, SCC is also taking back the cutting of verges. The 6 to 8 seasonal cuts by the Borough Council, recognising
seasonal weather conditions, will be reduced a standard county-wide cut of 4. Hardly an upgrade on what has
gone before. And will SCC be pro-actively managing overhanging branches in our urban alleyways? My concern is
that SCC does not even realise it’s a job to be done.

And the abolition of Local Committees and centralisation of highway decisions. Now residents have no public
meeting to ask questions of Highway Officers, petitions are determined at SCC’s HQ in Reigate by council officials
or a SCC Cabinet Member, and road safety schemes are decided by a Cabinet Member rather than local County
Councillors.

So, what will this £96.5 million contract mean? Kevin Deanus, Cabinet member for Highways and Community
Resilience, said: “The new contract will mean that Surrey County Council can more directly and consistently
manage on street parking enforcement across the county, helping to tackle inconsiderate parking and make
parking restrictions more effective.”

We all want safe and considerate parking, and there has to be a penalty for those who do neither. But that £96.5
million contract has to be paid for somehow. Will we see parking meters introduced where currently there are 1
hour or 2 hour waiting limits? Will additional yellow lines, designed to push drivers into paid for parking spaces,
be introduced. Will the new system be flexible enough to ensure that our local primary schools are visited
regularly to manage dangerous parking and idling cars? And will Residents Parking Zone Permit charges go up
once again.

Personally, I’m not sure that SCC’s desire for consistency and effectiveness in parking enforcement also equates
to fairness in delivery and a recognition of local needs, and it won’t be just another way to make our residents
pay.

County Councillor Eber Kington

Eber Kington is a former Mayor of Epsom and Ewell. He represents the Epsom and Ewell Borough Council Ward of Ewell Court Ward and on the County Council of Surrey he serves the ward of Ewell Court, Auriol & Cuddington.

Related stories from Epsom and Ewell Times:

Private Public Parking Penalisers

A Greener Future in Partial Sight As Verges To Be Left Unmown

From Gina Miller PPC for the True and Fair Party in Epsom and Ewell.

Doing the right thing

By Gina Miller, Prospective Parliamentary Candidate for Epsom and Ewell, Leader of the True & Fair Party

Epsom and Ewell’s Labour and Liberal Democrat branches must answer a simple question. Do they want to unseat Conservative Chris Grayling at the general election or would they prefer – yet again – to stand and lose?

The two parties have tried and failed to defeat Grayling across six general elections over 21 years. This is despite his record in the House of Commons, which includes, as transport secretary, bringing train delays and cancellations across the rail network affecting commuters right here in Epsom & Ewell. Despite Mr Grayling being told by the Supreme Court that he acted beyond his powers as Lord Chancellor, bypassing parliament and restricting legal aid to the most vulnerable in society. Despite two-thirds of residents feeling that Mr Grayling is not the strong advocate for their constituency that all MPs should and must be.

Neither party has come within 10,000 votes of the Conservative candidate since the seat was formed in 1974. That’s 14 general elections, 28 failed attempts – and heavy losses – between them.

Rather than charging towards electoral doom for the 29^th and 30^th times, Labour and the Liberal Democrats must stand aside at the next election. Epsom and Ewell needs a candidate the majority of voters can coalesce around. Someone who has a record of success in business, who has successfully challenged ministers’ abuse of power in court, and who will promote the potential we have in Epsom and Ewell.

My candidacy is not driven by right and left, but right and wrong. Straightforward political reforms to root out corruption at the heart of our democracy, such as banning paid lobbying by MPs, compulsory weekly surgeries to help residents and putting the ministerial code into law. I want to see stronger anti-corruption and ethics laws across central and local government, police, regulators, and the NHS.  These types of reforms are backed by voters across the political spectrum, good people who are aghast at the sleaze and disregard for the law, honesty and integrity in parliament and our public institutions. Epsom and Ewell residents can vote for me knowing that I will represent them no matter their natural mainstream party affiliation.

Our voting system needs to change so that every vote counts, but, until then, political parties must be pragmatic. The Liberal Democrats will not win here. No one doubts the party’s skills at by-elections, which date back to the early 1960s and Eric Lubbock’s remarkable win in Orpington. But those successes have never been repeated on a national scale. Pouring resources into a single seat cannot be replicated 600-plus times all at once, as they have to be at a general election if you are a national party.

My True & Fair Party, which is concentrating its resources in a handful of seats, is pragmatic. We haven’t stood in Esher and Walton against Dominic Raab, even though his actions in government make him a natural opponent for us. We respect that this is a constituency that the Lib Dems really can win, particularly with an impressive candidate in Monica Harding.

We ask the Lib Dems to extend us the same courtesy. They have failed to defeat Grayling six times. This is despite a political record of buying a Brexit boat from a firm with no ships  and ditching mandatory housebuilding targets that would help young people, including right here in Epsom and Ewell.

No one doubts Labour’s resurgence under Sir Keir Starmer. There is little doubt that his party will take back seats lost to the Conservatives under Jeremy Corbyn. Yet his predecessor failed so badly in 2019 that even a commanding polling lead will not translate into a huge majority.

The unfair quirks of our electoral system mean that, in many seats, all this lead will mean is the party might regain second place. That’s certainly the case in Epsom & Ewell, where Labour was nearly 21,600 votes behind Grayling in 2019. That’s a number Labour cannot overturn, particularly in a seat where the voters were savvy enough to never fall for even Tony Blair’s electoral charm.

Labour has failed to defeat Grayling six times, despite outdated views about gay couples and banning books for prisoners that are completely out-of-kilter with the good natured people of Epsom and Ewell.

Conservative voters who admired Thatcher, Major or even Cameron, but have been let down by the scandals of the economic failures of the May, Johnson, Truss and Sunak years won’t vote Labour or Liberal Democrat. They might, however, vote for a party not bogged down by any tribal history and a candidate who can actually win if only the Lib Dems and Labour stand aside.

Those parties have been given more than enough opportunities. We all know what will happen if they stand again – they will lose. It’s time for the Lib Dems and Labour to answer my initial question and give someone else a chance to properly represent Epsom and Ewell.

Gina Miller.

The Local Plan of Epsom and Ewell Borough Council should specify a minimum requirement of 40% of affordable housing in each new housing development of 10 or more units (Use Class C3) of which at least 25% will be reserved for social rent and comply with the vacant building credit.

Labour are asking that the Local Plan specifies a minimum amount of both affordable housing and social housing for rent. Our targets are quite low with many councils providing more however, other councils don’t have such a low bar as their starting point. Epsom and Ewell have the lowest percentage of social housing in the county.

In the last 3 years the affordable homes built in the borough were: –

2019-2020 15%

2020-2021 3%

2021-2022 6%

If Covid was a factor in this its even more important for even more homes to be rapidly built in the borough to catch up and, it’s very clear indeed, many more affordable homes must be built to make the strategy deliverable.

I think that the Homeless and Rough Sleeping Strategy, for those who don’t have much homelessness in their ward, clearly explains the cost of homelessness for an individual, a family and society. There’s also the financial cost to the borough of just under £2m and to society as the health and well being impact of homelessness increases the demand for health and social care resources.

I hear of individuals living in overcrowded accommodation. I have families who live separately during the week, often with grandparents, so the children can attend schools which meet their need. Many people are living out of borough losing contact with their known and trusted support networks.

Building affordable homes – I recall just two units, as part of a development, coming to planning recently and they were not of a good standard space or amenity wise and affordable housing should not be substandard housing so on the advice of the officers it was rightly refused.

I constantly hear that providing affordable homes as part of a development is unviable. Well, why not tell developers to open their books as they must do in Brighton and the council can check their calculations.

I see application after application being refused or deferred and Epsom needs to be building homes of a good standard that residents can afford to live in, settle in and raise their families.

The Homeless and Rough Sleeping Strategy recognises that residents are unable to access affordable homes, and this is a main causal factor for homelessness in the borough.

At the briefing on the Homeless and Rough sleeping Strategy some of us attended a graph showed a clear dip in homeless numbers which was when the Hollymoor Lane development became occupied. A development of affordable and social housing, environmentally friendly, with solar panels and EV points, and built to a good standard.

The borough needs more developments like this

The Labour group welcomes the action plan to increase availability of affordable accommodation and welcomes the action to build homes and identify appropriate council owned sites.

However with soaring rents, S21 evictions happening again coupled with the lack of social housing we do fear numbers of homeless people will increase.

Epsom and Ewell council needs to ensure and facilitate building affordable homes. Currently it is changing from a NIMBY borough to a BANANA borough. Build Absolutely Nothing Anywhere Near Anyone.

It needs to change. The council should identify appropriate sites and continue to engage with Housing Association and responsible developers to get homes built.

Affordable Homes for residents need to be built and they need to be built now.

Councillor Kate Chinn – Labour Court Ward

Tim Murphy’s opinion piece on Epsom and Ewell’s Local Plan. An up-to-date Local Plan is a necessity. It indicates to those proposing new developments or conversions to properties just what they are allowed or not allowed to do. It is also the yardstick by which locally elected councillors assess whether a particular planning application should be permitted.

The current Epsom and Ewell Local Plan was approved as long ago as 2007. It does not meet the requirements of the most recent planning legislation. In particular, it is failing to deliver the type of housing that is needed locally – affordable and in close proximity to a range of retail and social facilities and public transport. By contrast, the current Plan has been very largely successful in protecting the Borough’s much valued Green Belt from inappropriate development. Two reports commissioned by the Council have confirmed that our Green Belt is performing as it should against the five criteria set out in planning legislation.

A new draft Local Plan is very likely to be discussed by the Council’s Licensing and Planning Policy Committee on 21 st November. The preparation of the Plan has been overshadowed by a quite unrealistic housing target of nearly seven hundred new homes to be provided every year in the Borough.

Where does this target come from? It is set by central government and is based on outdated projections about how fast our number of households will grow in the future. Astonishingly, the number is so high because it incorporates what is known as an ‘affordability’ uplift – because house prices locally are so high, it is assumed these will fall markedly as more houses are built. There is no evidence that this is how our housing market operates.

Our councillors have a choice to make. They can try to meet most, and maybe all, of the centrally-determined housing target. The Borough has only limited built-up areas that would lend themselves to redevelopment for housing so, inevitably, extensive areas of our Green Belt would be sacrificed. Judging by the type of housing that has been approved over the past few years in the Borough on what are called greenfield sites, it is unlikely that the homes that are provided will meet local needs.

What guarantees will be in place to ensure that such significant increases in population will be matched by more educational and medical facilities and better transport provision? Alternatively, as in neighbouring Elmbridge, our councillors could decide not to meet the housing target but rather prioritise the provision of those types and sizes of housing most needed locally, including affordable homes, on existing built-up areas so that no valuable Green Belt need be lost.

The comprehensive redevelopment of existing commercial estates to incorporate a significant element of new housing should be a component of this way forward. Excellent design standards will be essential. Recent statements by our new Prime Minister and the Secretary of State for Communities, Michael Gove, support this approach.

What will our councillors decide?

Tim Murphy

Tim Murphy has worked as a Chartered Town Planner in local government in London, and as an environmental specialist both with WS Atkins and Partners, the Epsom-based engineering consultants, and the European Bank for Reconstruction and Development (EBRD) where he was responsible for examining the environmental and social impacts of the EBRD’s investments in Eastern Europe. Since retiring, Tim chaired the Surrey Branch of the Campaign to Protect Rural England (CPRE) for several years, and he is currently Chair of CPRE’s South East Region and heads up CPRE’s Epsom and Ewell local group, campaigning to protect the local Green Belt and other open areas.

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David King, Chair of Epsom Common Association writes:

In my opinion several aspects of this BBC report are, at the least, questionable.  I am not competent to comment on the important housing issues raised, but have serious concerns regarding the section discussing development on the Green Belt.  Although not named in the BBC report, this clip was recorded on the the edge of Epsom Common at Woodcote Side.  The small part of the Common shown, grass and a highway ditch, was disparagingly described as “technically Green Belt land” by a representative of LandTech, a software company providing products for property developers. 

Those recording the clip could not have missed the noticeboard headed “Epsom Common Local Nature Reserve” just feet out of shot, but chose to ignore the significance.  They also chose not to show the mature woodland immediately behind the camera.  The implication that the land shown was suitable for housing development was clear.  By contrast, Natural England (the government body that advises on the natural environment) describe Epsom Common as a “nationally important wildlife site”; so clearly development would be a disaster for biodiversity. 

Given its various designations: Registered Common Land, Local Nature Reserve, Site of Special Scientific Interest or Site of Nature Conservation Interest, as well as Green Belt, I hope that the Common is not at risk of development, but that ultimately depends on the will of politicians.

Even if the Common is safe from development, the suggestion made in the BBC report that Epsom & Ewell “could meet all of its annual housing need by by developing just 1% of the Green Belt in the Borough” does raise a more insidious threat.  This statement means precisely what it says: at a typical outer London housing density of about 40 dwellings per hectare, 1% of the Borough’s Green Belt would provide space for just one year of central government’s imposed target of 577 houses per annum. 

Of course not every piece of Green Belt is sacred and everyone must have a decent home, but we do have to be intelligent how we achieve this essential goal.  After a few years development at the pace suggested in the BBC report, much of the rest of the green space in the Borough would have been built over.  This would leave Epsom Common increasingly isolated, with many animals and plants unable to survive, having lost the essential freedom to move to and from adjacent land that previously also had space for nature.  To quote a 2011 government White Paper: “We should be thinking not of isolated spots of green on a map of England but of a thriving green network linking wildlife sites with farmland, forestry and urban parks and gardens…”  I should also note that an independent report by W.S. Atkins for the Borough Council in 2017 found that “Metropolitan Green Belt land within Epsom and Ewell is, on the whole, highly performing” and “continues to play a vital role in preventing urban sprawl”.

As well as damaging biodiversity, which government is legally obliged to improve, large scale development of green land (whether “Belt” or not) will also exacerbate the catastrophes of climate change and reduced food and water security that threaten both human society and much of life on the planet.  The beneficial effect of open space to the physical and mental well-being of local (and often not so local) people would also be reduced.  The value of the Common to many became particularly clear during the pandemic when it was exceptionally busy.  Although some areas of Green Belt do not have good public access, an issue that could – with political will – be tackled, the more London is allowed to sprawl, the harder it will become for its population to visit and benefit from extensive natural spaces.

David King, Chair – Epsom Common Association

8th September 2022