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Our response to the Tandridge Local Plan Consultation

Collective Reg 18 Representation

OLRG Reg 18 Representation

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OCTOBER 13TH - LIMPSFIELD WARD BY-ELECTION - TANDRIDGE DISTRICT COUNCIL


We are delighted to announce that Limpsfield resident, Phil Davies, is standing for OLRG at the forthcoming by-election in Limpsfield to be held on October 13th.

To read Phil's first election leaflet click here

The by-election follows the resignation of Tandridge District Councillor, John Pannett, one of the two Limpsfield ward Councillors.

Having Phil as a Councillor will mean we can build on the work that OLRG's Oxted North and Tandridge Councillor, Jackie Wren, has begun to better represent residents and

* to fight to get the Council's flawed Local Plan proposals corrected and exercise close scrutiny of Council officers' work. Backed by legal and planning experts, OLRG is prepared to stand up and challenge the current approach to the Local Plan which expert opinion has made clear is seriously flawed.

* to protect our environment, in particular the beautiful Green Belt surrounding this area, and to prevent our infrastructure from being swamped by over-development.

* to fight the Moorhouse planning application for a super-sized parcel delivery depot which threatens to put thousands more vehicles on our roads and would mean an unacceptable increase in HGV traffic, noise and light pollution.

Phil moved to Limpsfield from Old Oxted over 20 years ago with his wife, Kay, and family. He has worked for many years with Titsey and Limpsfield Rotary Clubs. He was a local Venture Scout leader for more than 10 years and set up The Phantoms youth group in conjunction with Rotary.

If you are a Limpsfield resident and would like to contact him to discuss any concerns, please do email him at thedavieses@gmail.com


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On Thursday, 21st July, Oxted and Limpsfield Residents Group Councillor Jackie Wren made another plea to Tandridge Councillors to correct the Local Plan documents. Her speech can be watched on this link click here

Councillor Wren said: "This Council has been given expert advice on two occasions now that its Local Plan documents are defective, but has not corrected them."

Later, Councillor Wren commented: "I made my points but they seemed to fall on deaf ears because the debate afterwards did not address any of them which was disappointing.

No-one seems willing or able to grasp what OLRG is saying which is that leading planning, legal and demographic experts have said the Planning Department's documents are badly wrong. As a result our precious Green Belt is unnecessarily threatened. Not only that, but if the documents are not corrected, the Local Plan risks being found unsound and tens of thousands of pounds of taxpayers money will be wasted.

It is frustrating but I'm not disheartened. We expected these setbacks and are determined to get the Plan corrected in line with national policy."

Councillor Wren also raised concerns that minutes of a Planning Policy Committee held on 28 June meeting are neither fair nor accurate.

She said: "My own speech has been inaccurately summarised and comments from other Councillors raising concerns about how the Planning Department is proceeding with the Local Plan have not been included. I have asked the Chief Executive to correct the minutes but my request has been refused. I will therefore be voting against the motion to adopt the minutes."

The next key dates in the Local Plan process are:

* 15th September - now postponed until at least 31st October: Tandridge Council due to reply to the Local Plan consultation responses including the expert opinion document, known as the Collective Regulation 18 Representation, which is supported by OLRG, 11 of the District's Parish Councils and 7 other Tandridge community groups. It can be read on the first link in the box at the top of this page

* 1st October - now postponed until at least 31st October: Tandridge Council due to publish details of the Sites Consultation - effectively a consultation on the release of Green Belt sites.

* 14th October - now postponed, new date unknown: Sites Consultation scheduled to begin and due to last 8 weeks.


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On 13 June, Tandridge Council told OLRG it does not think the expert opinion document "has identified any significant flaws in the process."

The Council's Chief Executive, Louise Round, said: "OLRG Regulation 18 response (incorrect reference to the Collective Regulation 18 response) - my position and that of the Council is that of course we would not want to proceed to examination of the local plan on the basis of a document which is fundamentally flawed which is why, given the complexity of the process, we have sought external advice where that is appropriate. That external advice has supported our approach."

As a result of that statement, we asked to see a copy of the external advice the Council had received to support its view on the expert opinion document. Ms Round then said there was none and that she had been using the words "external advice" that "has supported our approach" to refer to some of the original Local Plan work done by consultants many months before the expert opinion document was submitted...

And so the Council's view on the experts' work is based solely on the opinion of its own Planning Department.

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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London's new Mayor, Sadiq Khan, has 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


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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.

The Local Plan documents claim 9,400 new houses 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.

This is 470 new houses 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.

Experts have shown that this need figure is inflated, unreliable and contrary to the National Planning Policy Framework and National Planning Practice Guidance.

In putting it forward, the Council has contradicted its own evidence given to the Planning Inspectorate at a recent Public Inquiry.

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 caused by the massive amount of new development that has already taken place - for many years, Tandridge Council has been building roughly double its housing target.

This scale of building is putting 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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OUR RESPONSE TO THE TANDRIDGE LOCAL PLAN CONSULTATION

OLRG commissioned legal, planning and demographic experts to review the Council's documents. The result can be read on the first link in the box at the top of this page - see Collective Reg 18 Representation.

It is more than 90 pages of expert evidence. As well as OLRG, it is supported by 11 of Tandridge District's Parish Councils, 7 other community groups and the Tandridge branch of the Campaign to Protect Rural England.

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.

One of the many errors 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.

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.

Soon after submitting our representation, the Council's Chief Planning Officer insisted the Local Plan is not flawed despite saying that it will take five months to consider the comments submitted to its consultation. This appears to make a mockery of the consultation process.

The Council has carried on just as before, commissioning new work based on its flawed site assessments and employing consultants to carry out "capacity" assessments to work out how many houses can be built on each site. All the many Green Belt sites together with recreation grounds and open spaces have been assessed to see how much development they can take.

The second link in the box at the top of this page has a separate representation solely from OLRG, called OLRG Reg 18 Representation. It 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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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 headline "The Story So Far". No planning application has yet been submitted for the Chichele Green Belt field but one is expected at any time.