Raynor's environmental disaster and lessons to learn from Elmbridge

Dear Epsom & Ewell Borough residents,

It is a hugely positive step to see that the council has recognised, in a letter to Angela Rayner, the enormity of the destruction that results from the imposition of huge housing targets in the Borough. This acknowledgment is very much at the 11th hour, but better late than never. Epsom & Ewell is already the most densely populated borough in Surrey and, as Cllr O'Donovan, Chair of the Licensing and Planning Policy stated 'You cannot squeeze a quart into a pint pot.'

The proposed mandatory housing target for Epsom & Ewell is an undeliverable 817 homes per year. This is more than four times the current rate of building in the borough (averaging 192 per year over the last 10 years) and would require building on 21 hectares of Green Belt land per year to achieve (based on the council's 40 dwellings per hectare figure). This would increase the housing in the Borough by 50% over the plan period, with the associated traffic problems and the need for schools, doctors, etc.

The Epsom & Ewell Times newspaper has already reported on the huge value of the Green Belt to the Borough, and as we have previously highlighted, ‘Once it’s gone, it’s gone forever’. 87% of residents who responded to the local plan consultation in early 2023 stated they did not want to build on Green Belt land... and it isn't necessary to either.

So what can be done about this unprecedented attack on the borough’s heritage and character?

Recognising similar challenges and resident views to Epsom & Ewell's, Elmbridge submitted a draft local plan for inspection which restricted development to brownfield only, with no Green Belt sites included. The planning inspector has formally responded in a letter setting out some significant concerns and requiring amendments.

There are some important lessons for Epsom & Ewell Borough Council to take on board from this letter:

1. The planning inspector highlighted the lack of affordable housing in Elmbridge's local plan. Like Elmbridge, Epsom & Ewell has high land values that make building affordable homes challenging. We must and we can build the significant number of affordable homes and social housing we need on our brownfield sites.

Our draft Local Plan should be more prescriptive about what affordable and social housing is required from each site. Council-owned sites submitted for development, such as Hook Road Car Park, should be 100% affordable housing, as suggested in the Core Strategy 2007 [Para 3.12.9 of the Core Strategy 2007 states: ‘The delivery of the target expressed in Policy CS9 will depend upon some sites being developed for up to 100% affordable homes, including land currently owned by the Borough Council.’] Large brownfield sites, such as the former gas works site, must deliver at least the numbers of homes and affordable housing as set out in the regulation 18 consultation. With creative thinking these sites can deliver even more.

Taking this approach to council-owned land, together with ensuring delivery of the minimum target of 30% affordable housing on other sites of >10 homes, would deliver the significant levels of affordable homes the borough needs over the plan period, well in excess of the average of 28 affordable homes per year delivered for the last 7 years.

2. Unlike Elmbridge, and in line with Kier Starmer's statements on developing car parks and disused sites ('previously developed land'), Epsom & Ewell is proposing to build on the West Park Hospital site, replacing the existing buildings and car park with new dwellings. This is clearly the right thing to do. This does not require a change to Green Belt boundaries under the current NPPF rules but could deliver over 300 homes, including at least 120 affordable homes, with ambitious planning. Developing sites like this, to their full potential, would make the best use of the land and avoid the need to build on precious green field Green Belt.

3. Planning officers in Elmbridge made the case that there are exceptional circumstances for building on Green Belt land in their borough. This was voluntary and they could equally have argued the opposite. The planning inspector highlighted the Elmbridge officers' argument and concluded that by doing this, the officers had provided important evidence supporting Green Belt development. The Epsom & Ewell planning officers are making the same mistake. There is nothing exceptional about the current situation and we should not be arguing that there is, purely to release pristine Green Belt for development.

It is important the officers are led by a strategy put together by elected councillors and are not left undirected and unchecked. Issuing statements or reports which voluntarily and unnecessarily support a path that does not align with the borough's strategy or need can be highly damaging. Case law (e.g. Compton Parish Council versus Guildford Borough Council) indicates that whether or not exceptional circumstances exist to release Green Belt for development is a matter of planning judgement. In Epsom’s case, given the high quality of our Green Belt, it is straightforward to make the judgement that there are not exceptional circumstances for its release.

4. The planning inspector referred to the accessibility of Elmbridge’s Green Belt sites being better than some brownfield sites put forward in that Borough.

The situation in Epsom is markedly different. The transport assessment here highlights that the large Green Belt sites are not sustainable. For example the report states for the green field, Green Belt Horton Farm site, that ‘Without substantial intervention and investment by providing amenities on-site or nearby, coupled with transport infrastructure and service improvements, it is not recommended that [this is] taken forward.’ Conversely, the brownfield sites are generally central and therefore far more accessible.

5. The planning inspector criticised Elmbridge for planning for fewer houses than the figure included in their own housing requirement calculation. In Epsom & Ewell, officers have failed to prepare a housing requirement calculation, despite questions being raised to councillors, a complaint being submitted by the Epsom Green Belt Group, and a Freedom of Information request highlighting the issue. Instead officers have selected plots of land, including 55.6 hectares of high performing Green Belt and calculated how many homes can be fitted on it. This does not consider the real needs of the borough and will not be accepted by a planning inspector. Various councillors and residents have independently calculated the housing requirement as between 3,000 and 4,000 homes. Analysis shows that Epsom & Ewell could deliver at least 4,000 homes on brownfield and previously developed sites and meet our housing requirement in full.

6. Finally, and very importantly, Epsom & Ewell will be submitting its plan under the December 2023 version of the NPPF. This specifically permits the council not to undertake a review of Green Belt boundaries. This option was not open to Elmbridge. The window of opportunity to use the option available in the current NPPF may close in December this year. A planning inspector should not argue against following an NPPF option, so this is a position our council should be keen to take advantage of to protect the borough from irreversible damage. Given the position set out in the council's letter to Angela Raynor, Epsom & Ewell council recognise the approaching problem and should make use of the option quickly while it can.

We need the right homes, of the right size, in the right place, at the right price. We need 3-4,000 new homes in the borough, not 15,000. The government may have veered off course with its proposals to allow all Green belt land to be developed, but Epsom & Ewell council have an opportunity to plan for a bright future for the borough. They should grab it while they can.