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Our response to the Tandridge Local Plan Consultation

Collective Reg 18 Representation

OLRG Reg 18 Representation

Green Belt Fields Green Belt Fields Green Belt Fields Green Belt Fields Green Belt Fields Green Belt Fields Green Belt Fields Green Belt Fields Green Belt Fields Green Belt Fields Green Belt Fields

Oxted and Limpsfield Residents Group is calling on Tandridge Council's new leader, Martin Fisher, to follow the example of London's new Mayor and pledge to protect the District's Green Belt and immediately halt the Council's capacity assessments which are being carried out on Green Belt land.

OLRG Councillor, Jackie Wren, recently appointed to the Council's Planning Policy Committee said: 'These assessments are to work out how many houses can be built on the very many Green Belt sites in Tandridge District that the Council has identified as deliverable and developable.

60 Green Belt sites covering more than 468 hectares are involved. By carrying out these assessments, Tandridge Council is showing its complete disregard for national policy for the protection of the Green Belt.

As well, these assessments are being carried out on Green Belt sites that the Council has identified as deliverable and developable via a process that legal and planning experts have made clear is flawed.

They are based on a Housing and Economic Land Availability Assessment (HELAA) which has not been carried out in line with national planning policy and they are assessing Green Belt sites that should not have been included in the HELAA in the first place. They will be another flawed document on top of already flawed documents and therefore the Council is spending public money unreasonably and unjustifiably by commissioning consultants to undertake this work.

I am calling on Councillor Fisher to stop them at once, to pledge to protect the Green Belt as London's Mayor has done, and to ensure the Council's flawed Local Plan documents are rewritten immediately.

OLRG has set out in its expert opinion submission how badly flawed the Council's documents are and this submission is supported by eleven of the District's Parish Councils.

I am also asking Councillor Fisher to instruct the Planning Department to correct the Council's poor quality work so that it properly assesses housing need, protects the Green Belt, addresses existing and future infrastructure constraints, and reflects the needs and priorities of the community.'

London's new Mayor, Sadiq Khan, said that he will not allow building on any of the London Green Belt and that he has instructed his planning officers to ensure his view is reflected in all planning decisions made by the Greater London Authority. He said it was vitally important to protect our precious green spaces and that must include opposing building on the Green Belt.

To read the 26 May news release from the London Mayor click here

On 13 June 2016, Tandridge Council told OLRG it does not think the expert opinion document, known as the Collective Regulation 18 Representation, "has identified any significant flaws in the process."

We then asked to see a copy of the external advice the Council had received to support its view, and were told there was none.

Papers from Tandridge Council's Resources Committee show that for the current financial year, the New Homes Bonus provides 16.5% of the Council's income, rising to almost 17% next year. The more houses the Council allows, the more money it gets.


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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, procedural deficiencies, and the problems Tandridge residents have had with the consultation process.

There is 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.

The OLRG representation also includes a section on the Settlement Hierarchy document which persistently attempts to portray Tandridge's small settlements as larger and better resourced than they actually are. Efforts are made to equate them to large towns like Crawley, Redhill and East Grinstead. The larger and more sustainable they are made out to be, the more development will be directed towards them.

In another of the Council's Local Plan documents, Oxted, Limpsfield and Hurst Green are frequently erroneously 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.'

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 for house-building 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 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.

They claim that 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.

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.


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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.


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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 last headline. No planning application has yet been submitted for the Chichele Green Belt field but one is expected at any time.