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Our response to the Tandridge Local Plan Consultation

Collective Reg 18 Representation

OLRG Reg 18 Representation

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Now that Jackie Wren has been elected as OLRG's Councillor for Oxted North and Tandridge, we will be pressing ahead with the priorities set out in Jackie's election statements. They are to:

* Fight to put right the Local Plan documents so that the housing need figure is accurate and not inflated.

* Fight to put right the Green Belt assessments and the site assessments so that they are carried out in line with national policy and planning guidance.

* Fight to ensure local infrastructure (the Health Centre, schools, roads, parking) is put at the centre of the Council's planning process.

* Fight to protect our beautiful Green Belt and open spaces.

* Thoroughly scrutinise the officers' work so mistakes that have been made do not happen again.

* Fight to ensure residents are listened to early in the decision-making process instead of being an afterthought.

* Put the community first and represent residents' interests.


Our three election statements can be read by clicking on the button marked 'The Local Plan'

Jackie is planning to have a monthly meeting where residents are invited to come and chat with her and OLRG about local issues that are concerning them. She will be inviting representatives from other relevant bodies who may be able to help on specific issues and encouraging better liaison to benefit residents within Oxted North and Tandridge.

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OLRG is an independent and non-political group. We stood for election because we were shocked by the poor quality of the Council's Local Plan documents which experts have made clear are seriously flawed, by the inadequate scrutiny of the planning officers' work, and by the inadequate and confusing public consultation.

We commissioned legal, planning and demographic experts to review the Council's documents. Our representation of more than 90 pages of expert evidence is supported by eleven of Tandridge District's Parish Councils, seven other community groups and the Tandridge branch of the Campaign to Protect Rural England.

It can be read on the link in the box at the top of this page - see Collective Reg 18 Representation.

It explains why the Council's work does not comply with national policy and unnecessarily puts our precious Green Belt, and our infrastructure, at serious risk.

It makes clear that the evidence base is flawed and contradictory, the housing need figure is inflated, and the Green Belt assessments have not been carried out properly. In short, the Local Plan documents are not fit for purpose for developing a sound Local Plan.

Since submitting our representation, the Council's Chief Planning Officer has insisted the Local Plan is not flawed which indicates that no notice is being taken of what the community or experts are saying.

We are concerned that the Council is now pressing ahead with 'capacity' assessments to work out how many houses can be built on each of the sites it has identified as 'deliverable and developable'. All the many Green Belt sites together with recreation grounds and open spaces are being assessed to see how much development they can take.

This is despite the Council saying that because there have been so many comments sent in to the Local Plan consultation it will take five months to consider them. We believe the fact that the Council has carried on just as before and commissioned new work based on its flawed site assessments, makes a mockery of the consultation process.

One of the many flaws in the Local Plan documents is that no account was taken - when it should have been - of the existing strains on infrastructure or of how it would cope with such a significant increase in population.

In its documents, the Council stated that it had written to all 10 surgeries in the District to ask for comments but received "no responses" and so had concluded "there is no indication of any specific requirements at this present time."

Oxted Health Centre then made clear it never received any letter from the Council's Planning Department. Therefore its views were not taken into account in preparing the Local Plan documents.

The Health Centre has now highlighted how stretched resources are, with more than 2,000 patients per full time partner. The Oxted Health Centre Patients Participation Group (PPG), which represents the 17,000 patients, has also now submitted a response to the Local Plan consultation which says health services in the area are under significant strain with the present population.

For more details of what the health professionals are saying, see the second headline.


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OUR RESPONSE TO THE TANDRIDGE LOCAL PLAN CONSULTATION

Our response to the Local Plan consultation can be read on the links in the box above

The first link has the Collective Representation which is supported by OLRG together with eleven of Tandridge District's Parish Councils, seven other community groups and the Tandridge branch of the Campaign to Protect Rural England. Its contributors are legal, planning and demographic analysis experts.

The second link has a separate representation solely from OLRG and deals with the flaws in the settlement hierarchy assessment for Oxted, inadequate infrastructure assessment, and the problems Tandridge residents have had with the consultation process.

We would like to say a huge thank you to everyone who kindly donated money to pay for the experts' input. Thanks also to everyone who has copied us their emails and letters to Tandridge Council expressing their views on the Plan which have been invaluable in making our response.

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The Tandridge Local Plan consultation closed for comments on 26 February, 2016.

The Local Plan documents claim 9,400 new homes are needed for massive and sustained inward migration from Croydon and other London boroughs that would require building on large swathes of the Tandridge Green Belt.

Neighbouring Croydon is not releasing any Green Belt and has not carried out any assessment of its Green Belt.

The Council has listed "deliverable and developable" sites for more than 1200 new houses around Oxted, Limpsfield and Hurst Green - 980 of them are on our local Green Belt.

The documents have provoked a storm of criticism from across Tandridge District for their poor quality, their misrepresentation of the District and the issues it faces, and their failure to give any information about how infrastructure would be provided to support the massive amount of new development proposed or to meet the existing infrastructure deficit.

There is concern that there was no proper scrutiny of the documents before they were put out for consultation.

Some of the comments can be read on the Council's website click here but the posting of comments is well behind submission so many are not yet displayed. To read the comments, click on the first document Local Plan - Issues and Approaches and then on "All Comments."

There is also widespread concern that the consultation was inadequately publicised and that the little publicity there was failed to make clear the contents of the Plan. The documents are opaque and confusing, at times misleading, with important facts buried in footnotes.

In particular, many residents are concerned about the Council's incorrect paraphrasing of the requirement to meet housing need which has misled some into thinking the housing need figure has to be met even if that means building on the Green Belt. That is not correct, Green Belt is specifically mentioned in national planning policy as a reason for not meeting a need figure - for details see Part Two of the OLRG consultation response which deals with procedural deficiencies.

This response also includes a section on the Settlement Hierarchy document which persistently portrays Tandridge's settlements as larger and better resourced than they actually are. The larger and more sustainable they are made out to be, the more development will be directed towards them. Table 3 in the document gives the settlement ranking - the higher the ranking, the more new development will be directed to that location.

Oxted is ranked at number one and is erroneously portrayed by the Council as a large town with attempts made to equate it to Crawley, Redhill and East Grinstead.

In another document, Oxted, Limpsfield and Hurst Green are frequently described as an "urban conurbation." The definition of the word conurbation is 'an extended urban area, typically consisting of several towns merging with the suburbs of a central city.'


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None of the Council's options (Delivery Strategies) is compliant with national planning policy.

Options 3-6 propose large amounts of building on the Green Belt as well as open spaces and recreation grounds and require the Green Belt boundaries to be changed. These options are based on an unreliable needs figure which includes unrealistic economic assumptions that are being used to justify extensive release of Green Belt for inherently unsustainable development.

Option 2a requires building on open spaces/recreation grounds and 2b does this too, as well as relying on a blanket density of 70 dwellings per hectare with no regard for local character which in many areas is much lower than that.

The Council's documents claim 470 new houses are needed every year, almost 4 times the current housing target. It would mean a likely increase of a third in the District's population and approximately one new house built for every four existing.

This need figure is inflated, unreliable and contrary to the National Planning Policy Framework and National Planning Practice Guidance.

In putting forward this high figure, the Council has contradicted its own evidence given to the Planning Inspectorate at a recent Public Inquiry.
Government policy does not require Tandridge Council to meet the housing needs of other areas, particularly when doing so involves release of Green Belt.

This scale of building would put intolerable and unsustainable pressure on infrastructure such as schools, health services, roads, rail services and parking which are struggling to cope with the existing demand. Other services, such as water, landfill and cemeteries are also at full capacity.

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There are a vast number of Green Belt sites across the District together with open spaces and recreation grounds that the Council has listed as deliverable and developable. To see the sites near you click here and open "HELAA Appendix 3".


The sites include:

OXT 006 Chichele field, Oxted (150 houses)

OXT 007 Stoney field beside St Mary's Church, Oxted (250 houses)

OXT 025 Holland Road, Hurst Green (165 houses)

In addition, "Green Belt areas for further investigation" have been identified - to see the map of where, click here and open "Green Belt Assessment Appendix F". It is unclear what this means or why these areas are being investigated but residents will get no opportunity to comment on the findings of the further investigation. As the OLRG response to the consultation makes clear, this is unreasonable and does not meet the requirements for community consultation.

The Green Belt assessments have not been carried out in accordance with national guidance. In addition, there are numerous factual errors and inconsistencies in them.

Fears have been expressed that because the Council is so short of money, building on the Green Belt is welcomed in order to keep itself going as this Surrey Mirror article explains click here

The Local Plan documents were approved for public consultation on 10 December 2015 by all but one of the Councillors on the Planning Policy Committee despite widespread criticism from residents and some other Councillors.

Caterham Councillor, Clive Manley, the only member of the Planning Policy Committee to vote against the documents being put out for consultation, said they were "seriously flawed." He said the housing need figure (OAN) was "inflated" and it was "wrong" to put it before the public.

He said the Council had been advised at a meeting with the Housing and Planning Minister Brandon Lewis MP and officials from the Department for Communities and Local Government (DCLG), not to publish an OAN figure without also publishing a figure taking account of constraints such as infrastructure and the Green Belt. But this advice had been ignored and doing so put the Green Belt at great risk from speculative planning applications.

OLRG also attended the DCLG meeting and can confirm the position Councillor Manley has set out.

Woldingham Councillor, Sally Marks, said, "there is a fundamental issue on whether small towns and rural or semi-rural Surrey communities should be expected to absorb such migration out of London that has nothing to do with genuine local need."

She was also concerned at the "lack of contact" with the current consultants who were appointed after the Council terminated a contract with the previous consultants. She said the current consultants who were "alleged to be more expert in considering the dimension of in-migration from London", had been appointed without any consultation with Parish Councils or with the public.

There is more detail about what happened over this matter, and the questions it raises, in OLRG's consultation response.

Lingfield & Crowhurst Councillor, Liz Lockwood, also attacked the OAN figure emphasising that the Council's own barrister had said that "an OAN based on unreliable evidence is itself unreliable and that past trends of over-inflated delivery will make the future projections over-inflated."

She spoke of her concern about how the Green Belt parcel assessments had been carried out, saying: "I do think we are going to rue the day with some of the results in the parcel assessments."

Councillor Lockwood made her worries clear in this 29 December article in the East Grinstead Courier click here

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OLRG is taking part in the Local Plan process with the aim of protecting the local environment, of protecting local infrastructure from being swamped by overdevelopment, of meeting local need rather than London's need, and of achieving a reasonable and proportionate outcome for Tandridge District.

Membership is free. Join now by emailing oxted.residents@btinternet.com

OLRG has 2,500 members - the larger it is, the stronger our voice. Please do join and encourage others to join. All you need to do is email oxted.residents@btinternet.com or write to: Oxted & Limpsfield Residents Group, PO Box 233, Oxted Post Office, Station Road West, Oxted, RH8 9EH.

Most members are from Oxted & Limpsfield, but there are others from across Tandridge and anyone in the district is welcome to join. OLRG is a member of the National Organisation of Residents Associations.


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Ring Bark

NB: This picture shows one of the trees on the Chichele field in Oxted that was deliberately destroyed by developers. Ten large old trees, including a number of mature oaks, were ring barked. Men with chainsaws cut away the bark ensuring that the trees would slowly die. Very many people expressed their disgust at this behaviour.


For more details see "The Story So Far" on the fifth headline. No planning application has yet been submitted for the Chichele Green Belt field but one is expected at any time.