Epsom & Ewell’s Local Plan under the Green microscope ›

Epsom Green Belt Group Lodges Formal Complaint Against Borough Council Over Local Plan Submission

The Epsom Green Belt Group (EGBG) has submitted a formal complaint to Epsom and Ewell Borough Council (EEBC) regarding the council’s Local Plan submission, raising concerns over procedural irregularities and transparency in the consultation process.

In a detailed letter dated 14 March 2025, EGBG congratulated the council for submitting the Local Plan before the 12 March deadline, ensuring it falls under the provisions of the December 2023 National Planning Policy Framework (NPPF). However, the group identified what it describes as significant flaws in the submission, particularly concerning documents that were not made available for public scrutiny before submission.

Concerns Over Topic Papers

A key contention in the complaint is the inclusion of seven Topic Papers—covering areas such as the Green Belt, economy, housing, spatial strategy, heritage, and Gypsy and Traveller accommodation—without prior consultation or approval by councillors. EGBG argues that these documents were neither included in the consultation evidence base nor subjected to review by the Local Plan Policy Committee (LPPC) or Full Council before submission. This, they claim, violates the requirements of the Town and Country Planning (Local Planning) (England) Regulations 2012.

The group asserts that these documents were not made available to the public in accordance with regulatory requirements, including being published on the council’s website and made accessible at the Town Hall or local libraries during the consultation period. Furthermore, some Topic Papers were dated after the consultation closed, raising concerns about their legitimacy as submission documents.

EGBG has called on EEBC to take one of three actions: withdraw the Topic Papers from the submission, conduct a retrospective consultation, or submit an explanatory statement to the examiner clarifying the lack of prior consultation.

Criticism of the Consultation Statement

EGBG’s complaint also highlights alleged shortcomings in the Consultation Statement submitted by EEBC. The group argues that:

The statement underrepresents the weight of objections by counting consolidated group responses as single representations, despite EEBC’s guidance encouraging collective submissions.
The narrative summary is not impartial, as it includes the council’s views rather than an objective summary of objections.
Several key issues raised by EGBG in its formal response were omitted or misrepresented, particularly concerning specific development sites such as Hook Road Arena and Horton Farm.
The Sustainability Appraisal was described as ‘robust’ despite extensive criticisms submitted by EGBG, including claims that certain rankings were ‘misaligned’ and descriptions ‘bore little or no relation to supporting evidence.’

EGBG has requested that EEBC revise and republish the Consultation Statement to accurately reflect public concerns.

Council’s Response

When Epsom and Ewell Times approached for comment, EEBC provided a brief response, stating:

“Any complaint made to Epsom & Ewell Borough Council will be dealt with according to our Complaints Policy, published on our website: Complaint Policy V1.pdf.”

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