Campaign to Protect Rural England

This is the submission made by the Campaign to Protect Rural England to the Inspector who is deciding on the Tandridge development plan. It's long but interesting!

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TANDRIDGE DISTRICT LOCAL DEVELOPMENT FRAMEWORK (LDF)

INTRODUCTION
The Campaign to Protect Rural England (CPRE) is a national charity which exists to promote the beauty, tranquillity and diversity of the rural countryside by encouraging the sustainable use of land and other natural resources in both town and country. The Surrey Branch of CPRE has the third largest county membership in England after Kent and Sussex with approaching 2000 paid-up supporters.

CPRE Surrey took an active participatory role in the Examination in Public of the draft South East Plan contributing to many sessions relating to environmental and land use planning policies affecting the whole County, and in particular the London Fringe and Gatwick Sub-Regions. CPRE Surrey is closely involved with current consultations on Local Development Frameworks across the county.

SUMMARY OF SUBMISSION
CPRE Surrey supports as sound the approach taken by Tandridge District Council with regard to the housing provision aspects of their LDF Core Strategy in the special and local circumstances that apply at this time and for this rural area of Surrey.
In recommending to the Inspector this view, CPRE has taken into account such additional issues as:
the uncertain priorities and conflicting messages that form a
national backdrop to the LDF process

the unknown future of the draft South East Plan and the Panel
Report on its Examination in Public

the unresolved impact of the Sub-National Review proposals
allocation of time at GOSE to other pressing priorities such as "regional hubs"
the undesirability of further delay at Tandridge
the limited manpower available for extra workload at the local authority
the increased costs attendant on withdrawal or suspension
the validity of attempting more research work for which the likely outcome is already known
PPS3 as a national policy cannot be expected to cover all genuine local circumstances that in Tandridge include the Metropolitan Green Belt covering 94% of this district of Surrey.
Local authorities such as Tandridge have had to deal with continually moving goal posts when preparing their LDFs because the untested PPS3 was only published in the middle of 1996, during the Examination in Public of the draft South East Plan. This was after work had already begun on drawing up the Tandridge LDF.
In contrast to PPS3, the national policy that applies to Metropolitan Green Belt in PPG2 has proven its value over 50 years in Tandridge and elsewhere, and has substantial democratic credibility and support as a result. This land use planning policy has been outstandingly successful in Surrey in the achievement of its objectives, which include protecting openness, preventing erosion of the countryside, stopping community coalescence and urban sprawl, controlling linear development, and encouraging urban renaissance. The Government has indicated its continued support for the Green Belt in recent parliamentary statements.
The housing supply in Tandridge has always come very largely from windfalls. This is because there are few substantial sites in urban areas and housing opportunities almost exclusively arise from redevelopment and intensification of small sites that are almost impossible to identify in advance. During the period 2001 to 2007 78% of housing completions were made on sites classified as windfall in Tandridge.
The Panel Report on the Examination in Public of the draft South East Plan confirms that "it shares the concerns expressed throughout the EiP by the Assembly and local authorities about PPS3's approach to windfalls, recognising that local authorities have managed to achieve a high rate of recycling and that it is not always possible to identify where such opportunities may emerge in advance. It therefore anticipates that quite a few local authorities in the region will be able to provide "robust evidence of genuine local circumstances that prevents strategic sites being identified", and will be able to demonstrate expected future trends in windfall delivery rates". Tandridge is one of those local authorities. Part of that robust evidence in Surrey must be the way in which the county has, unlike other parts of the South East, always exceeded its RPG9 housing forecasts in the past.
Unfortunately, the Government's commentary on the Panel Report which was expected to be published by the end of 2007 has been delayed until July 2008, and then still has to go through a 12 week consultation process. It is not therefore possible to say whether the Panel Report's recommendations will be accepted or not, nor what additional proposals the Government may present. In the meantime, local authorities have been urged to progress their work on LDFs, which Tandridge has attempted to do, against a background of an unclear forward vision, uncertain priorities, and unresolved policy conflict.
The practical guidance on Strategic Housing Land Availability Assessments (SHLAA) was only published in July 2007 approximately a year after PPS3, and long after Tandridge had started work on their LDF. Stage 10 on page 19 of this document is relevant to the windfall issue at Tandridge. It is in our view understandable that the local authority under pressure from GOSE should decide to proceed with its Core Strategy preparation and avoid further delay and cost on what could be considered an unnecessary SHLAA at this stage. There is a sound justification for this decision given the genuine local circumstances that apply and the public support of the Government and East, South East and London Regions for the Metropolitan Green Belt. PPG2 itself places emphasis on the "permanence" of the national Green Belt policy.
Although the Panel Report does indicate that a possible small scale revision of the Green Belt boundary may be justified to provide supporting residential development for Redhill, the LDF work for that "Regional Hub" is nowhere near the stage when an indication of what is involved in quantity terms can be given. Any development requirement in this context would in any case have to be located in the vicinity of Redhill itself to be sustainable and not around other locations in Tandridge such as Lingfield or Oxted for which we understand detailed plan applications have been submitted by developers in a way that CPRE finds incorrect for this exploratory meeting.
CPRE understands that Tandridge District Council have positively identified a number of sites in existing settlements that can be used for residential development. The derelict gasometer site at Oxted is an interesting example of contaminated land that could have already been cleaned up and used for residential housing. However, development that involves decontaminating land first is costly and tends not to be given priority. Funding for such purposes to overcome development delay has been made available from the Environment Agency and SEEDA in other parts of the South East (eg Kent) but not to our knowledge in Surrey. Developers are reluctant to build on contaminated land because of the extra expense they have to incur, and will favour waiting for Green Belt land if there is a possibility of it becoming available. This is why the strict application of PPG2 policy is needed to encourage the use of previously developed land within settlement areas by ensuring that the Green Belt is protected.
CPRE urges the Inspector to find theTandridge Core Strategy sound. Past experience suggests that elaborate planning proposals for housing forecasts prepared on a national basis do not fit easily into a Surrey context, where the Metropolitan Green Belt is an important quality of life priority, not only for the benefit of local residents, but primarily for the London inhabitants for whom it was first established, affording them easy access to fresh air in open countryside on their doorstep.

3, IN SEARCH OF SOUNDNESS

The Inspector has made clear his concerns, some of which are
major, about whether the Core Strategy should be declared sound or not. These concerns result in the main from the interpretation of PPS3 and also how the findings on the Metropolitan Green Belt should be applied (paragraphs 20.64 and 20.82).

Although it may be considered that some elements of the Council's

approach could be improved, these aspects are not in our opinion

of a nature that should result in an "unsound" finding.

Indeed the Tandridge authority has sought within the special local circumstances that apply in this part of Surrey to produce a Core Strategy that is in general conformity with PPS3. This is demonstrated by the Council specifically delaying its publication so that consistency with PPS3 could as far as possible be achieved.

The Core Strategy nevertheless has to reflect local circumstances. This is not the time or place to debate changing the Metropolitan Green Belt policy. Nor is it intended at this stage to identify the individual sites for development that will be a part of a later site allocation process.

One additional feature of the district that has to be taken into account is that employment of a substantial number of its inhabitants is outside the district in London Region so the link between housing provision and local employment is not as direct as in other parts of the country.

(ii) Housing supply in Tandridge has always come very largely from windfalls. The urban areas are already heavily developed and so housing opportunities almost exclusively arise from the reuse of brownfield land, mainly through the redevelopment of small sites at a higher density. There are few large sites available. There is virtually no vacant or redundant commercial land for conversion.

Because of very high land prices, small sites continue to come forward

on a regular and it appears increasing basis. Tandridge does not have a major urban centre but a number of smaller well defined individual settlements. Older housing stock dating back to the pre war years will in our opinion be upgraded progressively as it becomes available with new higher density housing during the LDF period.

Housebuilders are now opposing the inclusion of windfalls in housing supply calculations for their own business reasons even though paragraph 59 in PPS3 includes circumstances where this can be appropriate. The Panel Report on the draft South East Plan states in paragraph 7.54 that "we share local authority concern about the uncertainty caused by PPS3 paragraph 59'particularly in Green Belt areas close to London". The case that can be made for the Tandridge approach is based on the following "robust evidence" and "appropriate local circumstances":

The Panel accepted that urban potential work undertaken by the County and its 11 Districts was a "reasonable basis" for the RSS. This allocation includes a major element of windfall estimates.
If the Panel Report's view is accepted, it seems inconsistent to change the way that housing distribution should be delivered at this time, and to penalise Tandridge for using a reasonable windfall calculation in its estimate of housing supply.
In previous plans, Tandridge relied heavily on windfalls to meet their housing requirement and this judgement was shown to be correct. Inspectors accepted this and so did housebuilders. There were no objections made to the 2001 Plan.
The 2004 Tandridge Housing Capacity study included a substantial allowance for windfalls. This document was verified and endorsed by the HBF.
Between 2001 and 2007 over 78% of all completions on small, medium and large sites were classified as windfalls. In other words, there were 1272 windfalls out of a total of 1621 completions.
From 2001 to 2007 windfall completions have exceeded the SEP requirement of 141 dwellings per annum.
There is no evidence of windfall sites declining in number; in fact past experience suggests that the reverse is true.
(iv) Of the 11 Districts in Surrey, only Epsom & Ewell has so far had its Core Strategy examined and approved as sound. Although the character of Epsom & Ewell is very different to Tandridge, it would seem desirable for there to be some consistency of approach as regards the treatment of windfalls and the Metropolitan Green Belt that would reinforce the Tandridge case. Although all District circumstances are unique, CPRE Surrey are of the opinion that paragraph 3.14 of the Inspector's Report is relevant in reinforcing Tandridge's argument:

"I note that small and medium sized windfalls have made up an important element of housing supply..over many years and that the borough has been more than meeting its annualised housing requirement in recent years, Thus past reliance on windfalls has not been misplaced. The expectation of future housing from windfalls appears a reasonable and robust expectation based on past trends..It is not realistic to identify and then allocate such numerous small sites."

Paragraph 3.19 goes on to say:

"There are clear local circumstances which give support to reliance on windfalls"

(v) The Inspector is concerned that there is too much uncertainty about delivery of housing supply in the later years of the strategy. If the case for the use of windfalls is accepted, then it is perfectly reasonable not to satisfy PPS3 completely in the years 6 to 10 and beyond.

Tandridge has demonstrated that for the first 5 years there will be a substantial over provision of housing and supply of deliverable sites. The Housing Background Paper indicates that the requirement for the 5 years is 545 dwellings. The supply for the same period is 842 so the target is exceeded by 297 dwellings

For the second 5 year period, windfalls will legitimately make up a significant part of the supply. There is no reason to doubt that just taking small and medium sites alone, the SEP will be reached and probably exceeded. In the past 5 years over 1000 dwellings were completed on large sites of which some were windfall. Thus it is very likely that there will be a further substantial contribution from this category of site. Moreover, 2 sites have been identified with a combined capacity of 130 dwellings, one of which is a reserve site with a potential capacity of 90 dwellings, which could contribute to years 6 to 10.

The Housing Capacity Survey, which was revised in April 2007, includes in addition a further 11 sites with a potential capacity of 379 dwellings, where residential development is possible in the later periods of the Strategy. CPRE Surrey assumes that Tandridge will continually update this survey as further potential large sites emerge. A more detailed and updated report will be available following the Sites Allocation DPD. CPRE Surrey considers that the Council has as required shown that sufficient land will be available for the period of the Plan.

(vi) CPRE Surrey does not believe that the Tandridge LDF should be delayed further while a Strategic Housing Land Availability Assessment (SHLAA) is carried out, for which guidance was only published in July 2007. The Tandridge Housing Capacity Survey has been updated and no doubt further potential sites will be confirmed at the Examination later this year. An SHLAA can be undertaken for the subsequent Site Allocations DPD if this is felt to be necessary. In our opinion Tandridge were right to press ahead with their CS now.

(vii) It is necessary to clarify what the Panel report actually stated in connection with the extent of any possible future Green Belt review beyond that already allowed for in PPG2.

Paragraph 20.64 of the Panel Report states:

"Smaller scale local reviews should be undertaken as required around Redhill/Reigate including in Tandridge district in accordance with Policy CC 10a"

Policy CC10a in the draft South East Plan states:

"The existing Green Belts in the region will be retained and supported and the opportunity should be taken to improve their land-use management and access as part of initiatives to improve the urban rural fringe. If there are any cases for small scale local review, these can be pursued through the Local Development Framework process"

The relevant wording on Green Belt review in these two quotations is "as required" and "smaller scale" and "small scale local". CPRE Surrey consider that there is no requirement at this time to undertake a review, as Tandridge has shown that adequate housing capacity exists within urban areas to satisfy the SEP allocation, with the inclusion of a realistic windfall allowance justified by sufficiently robust evidence. National, Regional, County, and District policy supports the Metropolitan Green Belt and PPG2. Only if there is found to be insufficient capacity of previously developed land should green field locations be considered.

Paragraph 20,82 in the Panel report states:

"If not all of the proposed apportionment can be found within the urban areas we consider that some small scale review of the Metropolitan Green Belt boundary and/or the use of reserve/safeguarded land may be appropriate in order to maximise the potential for sustainable development"

Once again the Panel emphasises that the priority for development should be urban areas and that only if there is insufficient capacity there should some small scale review of the Metroplitan Green Belt boundary be made in order to maximise sustainable development.

This rules out any possible future urban incursion into Tandridge Green Belt in connection with Reigate/Redhill except in the proximity of the "regional hub" because maximising sustainability of development is the only objective given for boundary revision, and particular care has to be taken to ensure that the urban rural fringe is "improved". The LDF for Reigate/Redhill is not at a stage where any assessment can be made as to what quantity of development if any is required outside the urban area.

Tandridge do not see a need to undertake any form of Green Belt review at this stage. They are clear that they need a "contingency" in the unlikely case that windfall sites in the quantity required fail to come forward as expected in the longer term. They have set out in Policy CSP1 and 12 the "plan, monitor, and manage" approach they intend to follow. They have indicated that reserve sites will be identified in sustainable locations in a future DPD.

CPRE Surrey supports this approach. We agree with Tandridge that no review of Metropolitan Green Belt land is necessary. We maintain that PPG2 outlines clearly how, when and where any small boundary revisions should be made. We believe that the distinctive character and identity of Tandridge as a rural area should continue to be protected and enhanced and that the Metroplitan Green Belt does an excellent job in this context.

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Submission prepared by Tim Harrold Chairman of CPRE Surrey and Keith Tothill.

29th March 2008

CPRE Surrey

The Institute, 67 High Street, Leatherhead, Surrey KT22 8AH

Tel: 01372 362720

E-mail: cpre.surrey@btconnect.com