Green Belt Issues & Analysis
This is a summary of the key issues and analysis regarding building new homes on our Green Belt. It was originally written to help councillors understand the key issues but is now being published as a primer for residents. It complements the FAQs section of our website.
When local authorities develop their Local Plan they must follow the National Planning Policy Framework (NPPF). This was last updated by the government in December 2023. NPPF contains a methodology for calculating the local housing “requirement” called the Standard Method. It is actually an algorithm for allocating the government’s national target of 300,000 new homes p.a. to individual local authorities. It does not take into account local needs or circumstances.
According to the 2023 NPPF (para 61), “the outcome of the standard method is an advisory starting point for establishing a housing requirement for the area.” I.e it is not a binding target. It is a negotiation anchor – a tool for influencing local authorities into setting a higher local housing target than they would otherwise.
For the housing market, an unbroken chain of substitution exists across the whole Greater London Commuter Zone (i.e. people working in this zone can choose to live almost anywhere in the zone). The borough of Epsom & Ewell is part of this commuter zone. As such, our borough is not a standalone housing market. It is just a small part of a very large market.
From 2011 to 2021 the UK population grew by 6.5% [ONS] and Epsom & Ewell’s population grew by a slightly higher 7.7% [Local Plan 1.30]. The number of homes in our borough also increased by 7.7%over the same period. Epsom & Ewell is a desirable place to live so people welcomed the opportunity to move into the borough from elsewhere. We did not build all those new homes to meet local needs. The causal relationship worked in the opposite direction, the population growth was driven by the housing growth- people were drawn into our borough from elsewhere to fill those newly built homes. This is strong evidence in support of point 2 above.
The standard method calculation for our borough includes a 40% uplift due to the high house prices in our borough relative to earnings. This uplift is intended to drive down prices (to improve affordability) by increasing supply relative to demand.
This uplift will not achieve the intended purpose for 2 reasons:
A. First: The increase in housing supply will simply draw people into our borough from elsewhere in the Greater London Commuter Zone (as it did from 2011 to 2021). Remember, Epsom & Ewell is not a standalone housing market.
B. Second: Housebuilders will drip-feed new homes onto the market at a rate that maintains prices and maximizes profit. Classic land banking behaviour.The standard method uses 2014 ONS household projection numbers. More up-to-date 2018 ONS household projection numbers are available.
If the standard method calculation is carried out without the flawed 40% uplift and using the more up-to-date 2018 ONS data then this results in a new home requirement for our Borough of a little under 3,000 over the 18-year plan period.
The draft Local Plan identified previously developed (brownfield) sites that could accommodate 3,850 new homes.
In light of points 7 and 8 above, the council can comfortably accommodate our actual need for new homes using only brownfield sites.
One of the updates to NPPF in 2023 was to clarify that “there is no requirement for Green Belt boundaries to be reviewed or changed when plans are being prepared or updated” [para 145]
In light of points 1, 9 and 10 there is no need to change our Green Belt boundaries either to comply with NPPF or to meet our borough’s actual need for new homes.
“The Local Plan needs to protect our attractive and valued environment whilst reconciling the need to accommodate our development needs. The balance between protecting our environment and enabling development and supporting infrastructure is at the heart of our spatial strategy” [para 1.61 draft Local Plan]
Conclusions
Using greenfield Green Belt sites to build significantly more new homes in our borough than are actually required to meet our local needs is not required to comply with NPPF and will:
Draw people into our borough from elsewhere in the Greater London commuter zone
Not reduce local house prices
Increase the pressure on our infrastructure – roads, schools, hospitals, GP surgeries, dentists, foul water treatment, stormwater management
Harm our natural environment
Make our borough a less green and less pleasant place to live
