FAQs

What is the Green Belt and why should it be protected?

The Green Belt of land encircling London has been protected by law since 1938 to keep urban sprawl in check, prevent towns from merging together and promote the recycling of derelict land.

These purposes remain as important as they ever were, but now we know that retaining these areas is also critical in slowing and reducing the impacts of climate change, reducing flooding, reducing air pollution and providing essential habitats for wildlife.

What is the Local Plan and why does it matter?

Every council is required to have an up-to-date Local Plan. It sets out everything from where commercial, industrial and residential buildings can be constructed, to how the environment will be protected; from what roads and schools are needed, to the policies against which all development will be assessed. 

It maps out the future of the Borough and therefore will have a fundamental impact on the lives of all residents. It is critical that the right decisions are made now, as once the plan is issued, it can’t be undone. 

Epsom’s current Local Plan is very old and out-of-date. Without an up-to-date Local Plan it is difficult to defend against speculative applications to build all over the Green Belt. A new plan needs to be issued, but it needs to be the right plan; one that protects and enhances the Borough, not one that destroys it.

Isn’t it prohibited to build on Green Belt Land?

Other than for very limited uses, Green Belt Land is protected by law from development. It isn’t generally permitted to build housing on Green Belt Land. The Council therefore plans to reclassify land so it is no longer Green Belt and then build on it, citing ‘Exceptional Circumstances’ to do so. The only time they can do this is when they are issuing a new Local Plan

Are there exceptional circumstances that require building on the Green Belt now?

No. The Borough can continue to meet the forecast growth in housing requirements through development of Brownfield sites only. The current rationale behind the Council’s claim of exceptional circumstances is simply that they want to build more houses. This isn’t exceptional and it isn’t necessary.

Is there any Green Belt Land that it is OK to build on?

Some land in the Green Belt has buildings on already, or has sites where buildings used to be. This is called ‘Previously Developed Land within the Green Belt’. Without considerable remedial work, this land doesn’t support much wildlife and is suitable for development.

There’s an area of Green Belt on the Local Plan map that isn’t on the Priority Development list of 9 sites, does this mean it is safe from development?

No. All sites bordered in green on the Local Plan map have been put forward for potential development. If the Council includes any Green Belt sites on the Priority list, all other Green Belt sites are at risk of future development.

Any site may be included in a future version of the current Local Plan could be recommended for inclusion by the Planning Inspector in the course of their review of the proposed Local Plan, or could be included in future Local Plans.

Does the Draft Local Plan meet the need to supply affordable housing for lower paid workers and the homeless?

No. Although the plan discusses building 40% ‘affordable housing’ on Green Belt land and 30% on Brownfield land, this housing may not actually be affordable to those in need.

The definition of ‘Affordable Housing’ in the National Planning Policy Framework is (simplistically) houses sold at a 20% discount to their market value. In Epsom, the average property sold over the last 12 months was £649k, so an average property sold as ‘Affordable Housing’ would cost about £520k. This is well out of reach of most people in need of housing in the Borough.

The council’s proposed policy S7 on Affordable Housing also states that quarter of the Affordable Homes will be ‘First Homes’. Whilst these homes should be truly affordable, they make up only a small proportion (under 10%) of new homes, insufficient to meet the needs of local workers, first-time buyers or those on the homeless register.

The average price of a flat over the same period was £280k. Building flats, in town centre locations, could be half the price of an ‘affordable home’ in the Green Belt and so much more affordable, even before applying a discount. The Local Plan should focus on ensuring that all ‘affordable’ housing falls in the £250k-£350k price range, and is located in sustainable central, brownfield locations, rather than developing protected Green Belt land.

Is it permissible to submit a Local Plan which doesn’t meet the full housing need calculated under the government’s ‘Standard Method’, and can it be approved?

Yes. Many other Boroughs have done so or are planning to do so. Worthing Council recently had its Local Plan approved by Inspector whilst only meeting 25% of its target.

The National Planning Policy Framework specifically states that, with suitable justifications (such as protecting Green Belt), the full housing target need not be met.

I heard that the Government is going to abolish the mandatory housing target and no longer require Local Authorities to review Green Belt for housing. Is this true?

Yes, it has already happened! In December 2023, the government updated the National Planning Policy Framework. Councils can now choose whether or not to review Green Belt boundaries. They can choose not to change the boundaries, and therefore not to build on the Green Belt. There is considerable analysis within the council’s own reports which would justify this decision. 

It is Epsom & Ewell Borough Council’s choice as to whether it wants to follow Central Government policy and protect the Green Belt, or instead wants to continue pushing for large scale housing development on Green Belt land. 

The roads into Epsom are already overcrowded, particularly at peak times. What are the plans to address the additional traffic from all the new housing?

According to the 2011 census, there is an average of over 1.5 cars per household in Surrey. That equates to 2,300 new cars from proposed building on the Green Belt Horton Farm site alone.

There are no obvious ways to build new roads or expand existing ones.

No infrastructure plans have been put forward to show how this increased traffic will be managed. Expect long queues!

It is difficult to get my child into primary school / secondary school as there aren’t enough places. If the proposed houses are built, will I still get a school place for my children?

Local primary and secondary schools are either full or near to capacity.

At this stage no plans have been put forward for building new schools or expanding existing ones. No land has been allocated for this either. There is no guarantee of a school place and no priority for existing residents.

I see there are plans to build new sites for Gypsies / Travellers. How many will there be and where will these be located?

Regulations require Borough Council's to provide for the Traveller community. The Council has proposed putting 10 traveller sites on the Green Belt Horton Farm Site.

No explanation has been provided for why they are proposed to be located in a single area or on a Green Belt site.

It is important to build homes. How many does the borough need and where should they go?

It's really important to build new homes in the Borough. The majority of these should be truly affordable to people in the Borough, including those who want to get onto the property ladder and those who are currently struggling to find homes. These should be in the most sustainable locations, near public transport hubs, shops and amenities. These locations are in and around the town centre and are all brownfield sites.

Is there enough space in brownfield locations to meet the housing requirements?

• The latest 2018 government data indicates households growing from 31,694 households in 2022 to 34,117 households in 2040, an increase of 2,423 households, or 135 homes/year.

• The existing brought-forward housing need from the homeless register of 850 equates to an additional 47 homes/year. 

• This totals 3,273 homes or 182 homes / year. 

• Compare this to the available brownfield (and previously developed) sites, identified by the council, for 3,864 homes, nearly 600 homes more than needed. 

• There is no need to build on Green Belt land to meet this need.

Why is the Council’s housing target so high

Firstly, there is no government housing target. It is expected that councils establish a housing requirement for the area. The housing requirement is expected to be ‘informed’ by using a Standard Method calculation as an ‘advisory starting point’. The Standard Method provides a deliberately artificially inflated figure. The council have not used this, but neither have they calculated a housing requirement themselves. A realistic target is the 3,273 homes calculated above, which can be easily accommodated on brownfield sites.

There seem to be a lot of sites within Epsom’s urban area that are vacant, run down or underutilised. Could these be developed for housing instead of the Green Belt?

Yes. Some of these sites have already been earmarked by the Council for development, but many haven’t.

Para 146 of the National Planning Policy Framework (which contains mandatory guidance for preparing the Local Plan) states that before concluding ‘exceptional circumstances’ exist for developing on Green Belt, the strategy must:

a) make as much use as possible of suitable brownfield sites and underutilised land; and
b) optimise the density of development… including… a significant uplift in minimum density standards in town and city centres and other locations well served by public transport.’

There are a lot of sites across Epsom town/urban areas which are not being put forward for use in the Local Plan or appear to be underutilised (for instance the Council’s proposals for the Town Hall site don’t meet the minimum density requirements they set themselves). The Council has also failed to put forward its own brownfield land for development, instead giving up protected Green Belt land. 

The Draft Local Plan stated that development would be ‘located away from areas of flood risk’.  Is the Council keeping to this?

No, several of the proposed Green Belt development sites are at high risk of flooding from surface water (because there is clay just below the surface). Both the Environment Agency flood maps and Epsom & Ewell Borough Council’s own 2018 Flood Risk Assessment show these risks, but the Council has proposed these sites anyway.  If these sites are built on, there is a significant risk that as well as flooding the new housing, there will be increased flooding in surrounding areas.

How much Green Belt has been put forward for development?

The Green Belt sites that the Council has prioritised for development in the Draft Local Plan total 57 hectares (the total area is 66 ha, but some is to be used for playing fields). This is the equivalent of 140 football pitches.

Of this, 5 ha is at West Park Hospital and is classified as ‘previously developed land’ (as it already has buildings on), which should be prioritised for development in line with Government guidance.

Over 50 ha allocated for development in the draft local plan is protected, ‘high-performing’ (i.e. excellent quality) Green Belt land.

The Council has stated that this is ‘only’ 3.6% of the Green Belt, however this number is misleading.

Large parts of the Green Belt can’t be built on because:

• They already contain housing estates. e.g. Clarendon, Livingstone, Manor, Noble Parks, etc.

• They contain existing businesses such as David Lloyd Leisure, the Epsom Racecourse, etc.

• They contain critical infrastructure such as roads, pavements, etc. which can’t have houses on.

• They contain Local Nature Reserves or Sites of Special Scientific Interest (like Horton Country Park and Epsom Common).

• They contain cemeteries and golf courses.

Once these areas are excluded, the 57 hectares of Green Belt proposed to be developed is around 7% of the remaining available Green Belt land, over a period of only 15 years. This is an alarming rate of destruction!

No Green Belt needs to be built on. None should be built on.

How will developing the Green Belt land affect wildlife?

The Green Belt land is a vital habitat, providing food and shelter for hundreds of species of mammals, birds, amphibians and insects as well as native trees and flowers.

Once built on, the Green Belt land is effectively permanently lost to nature. 

How can I help stop the destruction of the precious Green Belt?

a. Spread the word. Tell your friends, colleagues, club mates and relatives about the Draft Local Plan and let them know the Green Belt is under threat.

b. Lobby your local councillors. Let your councillors know that saving the Green Belt is key and ask them to commit to doing so. You can find your local councillors here: Epsom and Ewell Democracy (epsom-ewell.gov.uk)

c. Make a donation to the group to help fund publicity and legal action (details coming soon).

d. Sign the petition to save the green belt: Petition · Keep Epsom and Ewell Green Belt! · Change.org

Useful Government Documents

Please download these latest guidance documents from the Government.