General

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1. INTRODUCTION

Review consultation, which is principally aimed at identifying appropriate land for release from the Green Belt in advance of the Local District Council – Mole Valley District Council (MVDC)finalising a Land Allocations Plan (LAP) which will identify land and sites to accommodate thefuture housing need of the District up to 2026.1.2 The Green Belt Boundary Review undertaken by the Ashtead Community Forum will eventually inform the Ashtead Neighbourhood Plan, which amongst other things will allocate sites and areas of land for development. However, that document will need to be consistent with the MVDC LAP, and thus the content of this response should be read in conjunction with our submission to the MVDC Housing & Traveller Sites consultation, dated 7th March 2014.1.3 Mole Valley District Council (MVDC) has a requirement to deliver 3,760 new homes over the period 2006 – 2026. That requirement is enshrined within Policy CS2 of the adopted CoreStrategy (2009). In accordance with the National Planning Policy Framework (NPPF), MVDC is required to identify a minimum five year supply of land to meet housing need against the Core Strategy requirements. The Council’s evidence base prepared to date highlights that it will be necessary to identify further land, beyond that which already benefits from planning permission as part of this consultation to accommodate between 1,000 and 1,700 new homes, and to subsequently allocate sites within the LAP to deliver those new homes over the period to 2026.Any sites allocated within the LAP that fall within the area of the Ashtead Neighbourhood Forum will subsequently be allocated within the Ashtead Neighbourhood Plan, rather than the MVDC LAP..Ashtead is a smaller settlement with fewer facilities and for the purposes of sustainabledevelopment, consistent with Core Strategy policy CS1 development should be focused towards Leatherhead and the London Fringe.THE STRUCTURE OF THESE 2. REPRESENTATIONS

2.1 These representations have been structured as follows, to provide Ashtead Community Vision with an overall submission, but also to enable responses to each of the 10 site assessments to be easily identified:Section 3 responds to the general methodology used by MVDC, which this consultation mustbe consistent with, and our comments as to how the LAP & Neighbourhood Plan should beprogressed in terms of the justification for housing release, the appropriate amount of housingand timeframe for the document; andSection 4 responds on a site by site basis to the assessments undertaken by theNeighbourhood Forum, highlighting in each case, why we consider the site to be sensitive tofuture development in terms of sustainability, access to local services and public transport;landscape value and open nature. In addition for smaller sites we highlight the limited benefitsthat they can deliver to the District’s affordable housing need and community facilities.APPROACH 3. & METHODOLOGY

3.1 For consistency this section is almost identical to what has already been provided to MVDC in response to the Housing & Travellers Sites consultation. It details our response to the Council’s proposed methodology in terms of the assessed need for new housing across the District and then the justification for the amount of land to be released, the general

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method/criteria for appraising the constraints of sites and the approach towards Gypsies and Traveller sites. The same methodology has been used for the Ashtead Green Belt Review, following which land released from the Green Belt will be allocated within the Neighbourhood Plan to contribute to wider housing need in the District.The amount of Housing Need/Land to be released3.2 The need to plan for long-term housing need is enshrined within Paragraph 47 of the NPPF requiring that each local authority has a Local Plan that meets the full ‘objectively assessed needs for market and affordable housing’, and that they identify and update ‘a supply of deliverable sites sufficient to provide five years’ worth of housing’. Furthermore Local Authorities are required to identify a supply of specific developable sites or broad locations for 6-10 years, and where possible, for years 11 to 15.3.3 Taking these matters in turn, it is evident that MVDC have an adopted Core Strategy, underpinned by an evidence base that was objectively assessed and found to be ‘sound’ by an independent Inspector in 2008/2009. Accordingly, and in advance of updating the Local Plan, it is essential in the first instance to meet the adopted strategic housing requirement identified within the Core Strategy. That is set within Policy CS2 which sets out the Council’s requirement to provide at least 3,760 net dwellings within the District between 2006 and 2026 – if the Council cannot be deemed capable of delivering that target consistent with Para 47 of the NPPF MVDC, then there would be a presumption in favour of sustainable residential development, with potential challenges being made by way of planning applications made on green belt land. Whilst sufficient land must be identified to ensure at least 3,760 homes will be delivered by 2026, we do not believe it is essential at this stage to identify further land to go beyond that requirement and that period, provided the capacity and deliverability of each identified site is appropriate in terms of site specific constraints, capacity of local infrastructure and services and will result in a high quality design solution.3.4 Consistent with the NPPF, MVDC may wish to identify some additional ‘reserve’ sites for release from the Green Belt to meet the ‘longer term 11-15 year housing need’ and perhaps even further beyond 2026. However, the evidence base to support that has not yet been examined or subject to scrutiny. Therefore given the emotive issues that surround Green Belt release and likely level of objection to the document, we advise the Council to protect the integrity of this document from any attempt to challenge housing need beyond 2026 as ‘unsound’ in the absence of an up-to-date robust and credible evidence base. Whilst future ‘reserve sites’ could be allocated for commercial and longer housing term release, subject to identified need, in order to ensure the ‘soundness’ of this document and maximise the prospects of its adoption, we strongly encourage MVDC to only ‘release’ land based on allocations for specific housing numbers to meet the needs of this plan period – i.e. to 2026 consistent with the Core Strategy. Reserve Sites to meet future commercial and residential needs should be subject to caveats that they remain subject to Green Belt status until such time as the need is quantified within the evidence base of the new Local Plan, with no specific quantum or form of development allocated.3.5 MVDC is already unable to demonstrate a five-year housing land supply (see below) and thus it is essential to move quickly to adopt a document which demonstrates how the immediate housing need can be delivered as soon as possible. Failure to do so will allow developers to pursue applications for ad-hoc development on green sites, and even on Green Belt land, justifying ‘very special circumstances’ in the absence of a sufficient supply of housing land. That could result in unsustainable unplanned development. As such this review of housing land and Green Belt boundaries should focus principally on housing need to 2026. MVDC should then seek to prepare an evidence base to support the future housing and commercial needs beyond 2026 as part of a new Local Plan, applying quanta and form of development to sites identified as ‘reserve’ at that time.3.6 Turning to the amount of housing/land that should be identified within this document to meet the outstanding housing need to 2026; we refer to the currently identified (and adopted) 20 year housing requirement of 3,760 dwellings – which requires MVDC to deliver 188 dwellings per annum. The five-year housing land supply (April 2013 – April 2018) statement highlights the following:A total of 1,653 dwellings have been delivered between 2006 and 2013 at an average rate of completion of 236 dwellings per annum leaving a residual requirement for 2,107 dwellings over the remaining 13 years at an average rate of 162 dwellings per annum;31 dwellings remain as allocated (without planning permission) in the adopted Mole ValleyLocal Plan (2005) and the Dorking Town Centre Area Action Plan (2012);

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As at March 2013, a total of 165 sites across the District had planning permission and arecapable of delivering 513 dwellings. It appears that all of these have been assumed as coming forward for delivery. In reality Authorities should apply a non-implementation rate, and for this purpose we would advise MVDC do discount 10% of the numbers, in turn ensuring that a further 50 units are added to the total number for which land needs to be released within theLAP;Using a basis advocated by the Inspector into the Dorking Town Centre Area Action Plan, the Council estimate an annual windfall allowance of 59 dwellings per annum across the District, but in order to avoid double counting apply this for only 2 years of the first 5 year supply as such this is applied for 10 years, rather than 13 – which represents a potential further 590 homes.3.7 On the basis of the above MVDC estimated that they had an existing supply of 1,103 dwellings, against a requirement to deliver a further 2,107 dwellings. The Housing & Travellers Site document advises that the number of completions had since risen to 1,720 (increase of 67) since March 2013. It also advises that planning permission now exists for 760 new homes (increase of 247) and that land is allocated for 180 new homes (increase of 149). These increases, particularly those for ‘allocated land’ need to be fully documented, as it is not clear how they have been calculated or where they have come from. The additional number also needs to be demonstrated to be ‘deliverable’ in the period to 2026, so as to ensure that the amount of housing allocated is sufficient to meet the need.3.8 Furthermore, consistent with the NPPF, MVDC must have compelling evidence to support an allowance for windfall sites as part of a five-year supply, demonstrating that sites have consistently become available and will continue to provide a reliable source of supply. Any allowance should be realistic having regard to the Strategic Housing Land Availability Assessment, historic windfall delivery rates and expected future trends. We understand that MVDC have allowed for 120 dwellings as a windfall allowance. We assume that allowance is made within the ‘allocated 180’ – to take account of the increase from the previously identified 31, but this is not clear within the document, and should be made so. As such we would encourage MVDC to plan for the full additional need to 2026 discounting only sites which have a live planning permission (i.e. one that has not lapsed), less a non-implementation rate of 10%, and those homes which have been completed. The Government is committed to the delivery of new homes for which there is an acute need, and thus consistent with the Core Strategy Policy CS2 and the NPPF the figure of 3,760 must be considered a minimum, against which windfalls can be used to top-up/exceed the requirement. Accordingly we advise that the Land Allocations Plan document should be planning to allocate land sufficient to accommodate at the very least in the region of 1,250 new homes, and more appropriate would be 1,350 (allowing for an additional 50 from non-implementation; 149 which are not documented and 100 from windfalls). The Ashtead Neighbourhood Plan shouldreflect the LAP and identify the appropriate amount of land to contribute meeting MVDC housing targets, should it not be possible to accommodate the District’s needs in sites presented to MVDC.3.9 We support the notion of a contingency and would suggest that be in the region of 10% in addition to the 1,250 – 1,350 homes which we highlight above should be planned for, amounting to an overall figure of closer to 1,400 or 1,500 homes.Delivery of Affordable Homes3.10 A further reason for not placing such a heavy reliance on windfalls, is the need to maximise the provision of affordable housing. MVDC’s adopted Core Strategy Policy CS4 seeks to ensure that 40% of all new homes are affordable. However, the Council’s most recent Annual Monitoring Report highlights that 373 affordable dwellings had been delivered to 2012 – representing only 22.6% of the total supply. It should be noted that this inherent undersupply is only anticipated to worsen. The housing trajectory highlights that only 3 sites that are yet to be developed would be required to deliver affordable housing – delivering a maximum of 60 dwellings, which would reduce the overall percentage of affordable homes delivered to under 20% - less than half of the target.3.11 The fact that windfalls are sites that cannot be identified reflects that by their very nature they are usually smaller sites of 10 or fewer units – which would not trigger the requirement for affordable homes. Allowing for a further 120 dwellings as windfalls undermines the delivery of affordable housing further, and could be argued as ‘unsound’.3.12 Based on the limitations of previous policy in terms of actual delivery rates of new affordable dwellings, MVDC should be seeking to ensure that all sites allocated will deliver

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affordable housingto meet what is a very acute local need. As such we strongly advise MVDC to only allocate sites capable of delivering 15 units or more that would trigger the requirement for affordable within this document. Indeed focus should be placed upon larger housing sites that are least constrained in terms of expense (engineering operations and contamination etc.) avoiding sites where abnormal costs could render the provision of affordable housing as unviable.Housing Density & Site Capacity3.13 We note that as part of the methodology for the Housing and Travellers Sites consultation, MVDC used a blanket ‘standard’ rule of thumb across the district of an average density of 30 dwellings per hectare. We emphasise that development should be focused upon the most sustainable locations which benefit from good access to public transport and local facilities. The acute need for housing is that of two and three bedroom houses, but development should also reflect the local character of the area. For example higher density development of circa 50 dwellings per hectare could be accommodated on sites within and around Leatherhead, reflecting the general character of the town – thus sites should be assessed on the ability to deliver a high volume of good quality two and three bedroom homes. This will not only make the most beneficial use of the most sustainable sitesavailable, but also provide additional expenditure and custom to underpin the viability of thebusinesses and services within the town. In contrast, Ashtead has the feel of a ‘village’ and isgenerally characterised by larger homes, and lower building densities. A density of 50 dwellings per hectare, or indeed 30 dwellings per hectare may not be appropriate in ‘any location’ within Ashtead, and we note that the majority of sites promoted are adjacent areas of densities well below 30 dwellings per hectare, in some cases the density falls into single figures. Both the LAP and Neighbourhood Plan should reflect such variations to protect the local character as defined in the Character Area Assessment of Ashtead.3.14 Generally lower densities are more appropriate to peripheral locations, which are likely to be more reliant on the private car, or where there is only limited access to public transport and local services. In particular lower densities would be more appropriate should development be directed to the smaller settlements of Capel, Brockham and Beare Green. However, lower densities are also considered more appropriate on the sites that are being promoted in Bookham and Ashtead to reflect the less urban environment of these smaller settlements, and the more limited provision of public transport and local services.3.15 Accordingly, we would register a concern that MVDC could have adopted a more robust approach to identifying the potential capacity of identified sites – we advise that a more bespoke approach should be undertaken, which should be reflected in the Ashtead Neighbourhood Plan, to recognise that density levels will vary significantly between sites depending on their location and wider characteristics.Approach to Traveller Sites3.16 We note that the Council’s evidence base identifies a need to 2017 for 28 pitches for gypsies and travellers and 5 travelling show-people within the District. Beyond 2017 there is a further need for 16 pitches for gypsies and travellers and 2 pitches for travelling show-people. We also are aware that the Government requires Local Planning Authorities to identify sufficient land and sites for travellers as part of the Local Plan process. We would encourage MVDC, and as such the Neighbourhood Forum to consider preparing an independent plan with regard to traveller accommodation. It is a particularly sensitive subject which could result in a number of objections which could delay and undermine the process for adopting a Land Allocations Plan. The same clearly applies to the Ashtead Neighbourhood Plan, albeit the Plan should be required to make the appropriate contribution consistent with the LAP once it is adopted.3.17 We advise MVDC and the Ashtead Neighbourhood Forum to seek to identify independent sites to accommodate travellers. As written, the consultation documents proposes that each site of more than 3 hectares would be asked to/required to accommodate additional pitches. We do not believe this to be appropriate, as the uses are not particularly compatible, and would in most instances not be at all palatable to developers who will resist their inclusion. First and foremost this could create a significant level of uncertainty through the consultation and examination process that could delay the adoption of the LAP and indeed the Neighbourhood Plan, and perhaps more importantly it could impact upon the deliverability and viability of identified sites undermining both documents further and the Council’s housing supply.

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3.18 There is also a danger that some developers will see an opportunity to promote ‘less sustainable’ or ‘constrained’ sites by way of including an area for travellers. This should not in itself be accepted by MVDC or the Ashtead Neighbourhood Forum as a means to improve the ‘overall score’ of the site over and above other factors when considering its release from the Green Belt.

4. GENERAL LOCATION OF DEVELOPMENT

4.1 We have clearly stated above and in our previous submissions that the Core Strategy sets the principle basis and ‘policy hook’ against which site allocations within the LAP will be set. Adopted Core Strategy Policy CS2 states that the Council’s indicative housing trajectory shows that requirement can be met without the need to use Green Belt / greenfield land, but only until around 2016-2017. Before then the Council will prepare a Land Allocations Document which will ‘allocate housing sites in the built-up area and incorporate a review of the Green Belt boundary to ensure sufficient land is allocated to meet the District's housing requirements’. This clearly sets the policy basis for the Housing and Travellers Site Document as prepared.4.2 MVDC Core Strategy Policy CS1 specifically states that development will be first directed towards previously developed land in the urban areas of the District of Leatherhead, Dorking, Ashtead, Fetcham and Bookham. Indeed Chapter 6 of the Core Strategy highlights that Leatherhead and Dorking are the principle town centres of the District. Accordingly from a sustainability perspective they should be the principle focus of new development, which will not only allow new residents to benefit from their transport links and range of facilities, but also underpin the ongoing vitality and viability of commercial businesses within them. Ashtead, Bookham and Fetcham all have mainline stations, but with fewer services, and have smaller centres that serve the immediate local community.4.3 It should also be noted that The Core Strategy and previously the South East Plan identified the main built up areas of the Mole Valley District as part of the London Fringe Sub-Region, and that this area should be the focus for growth – accordingly the housing need identified was based on the South East Plan and thus should remain the case. Furthermore, Paragraph 6.1.10 of the Core Strategy states that in accordance with the settlement hierarchy and the results of the sustainability appraisal, development will be focused upon the built up areas of Leatherhead and Dorking. 4.4 Accordingly we believe that any significant new residential development should be only directed towards Leatherhead and Dorking. It would be consistent with the South East Plan and Core Strategy for the majority to also be directed to Leatherhead. To ensure consistency with the Core Strategy, and the Council’s defined settlement hierarchy, the secondary centres of Ashtead, Bookham and Fetcham should only be considered for development on a much smaller scale, or in the event it would not be possible to accommodate within Leatherhead and Dorking. We provide further comment below with regard to the sites promoted being promoted in Ashtead. Separate submissions have been made with regard to sites promoted in the remainder of the District and should be read in conjunction with the comments below. 4.5 It is noted that large areas of land are being promoted and considered for development in Ashtead – and that two areas – notably land at Ermyn Way (Area F) and three sites at Farm Lane (Area J) were considered to be most appropriate for release from the Green Belt. However, for the purposes of sustainable patterns of development and maximising the use of accessible locations within the principle centres of the District, namely Leatherhead and Dorking, we have emphasised that any large scale release should be focused in those principle centres – particularly given that sites are being promoted by developers which are available for development. Indeed the MVDC Consultation document highlights that all of the necessary land released for housing could indeed be allocated as extensions to the urban areas of those towns. Whilst perhaps not necessary, should MVDC seek to release land in Ashtead, it should be of a considerably smaller scale that reflects its more modest position within the hierarchy of centres. We believe that Leatherhead, in particular Site LH14 is the least constrained site and should be the principle focus for meeting the District’s housing requirements to 2026. We do not believe it is necessary to allocate any land for housing development in Ashtead, but should MVDC wish to do so, the Neighbourhood Plan should

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ensure it be of a more limited scale reflecting Ashtead’s status as a more local/secondary centre, with less frequent train services and modest shopping/local facilities. Specific comments on each of the 10 sites are provided below.

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Consultation on Development Proposals for Ashtead

We would like to make our comments to the Neighbourhood Forum regarding a number of the above redevelopment proposals with the expectation that these will be forwarded – along with other responses – to the Planning Committee at Mole Valley District Council.

Primarily, we would like to express our detailed views on three proposal in and around Farm Lane but we would also like to make some more generic comments about the cumulative impact if a multiple number of developments were approved.

General Comments

Whilst recognising the national crisis with respect to the shortage of housing and the failure of consecutive governments to address this issue, we believe that proposals for new developments need to be cognisant of the impact they will have on local amenities. Whilst individual landowners will, inevitably, make substantial and personal gains if particular sites were approved for development, it is absolutely essential for local amenities to be improved and capacity increased to take account of the population increases that new housing will bring. I am certain that many others have already referenced the existing pressures on all local nursery, primary and secondary schools; local health services – particularly primary and community health services – local roads; pavements; shops; traffic; social care and the many other services that are often provided by the local state that is having its funding not just reduced but literally slashed. Additional residents will make existing pressures intolerable.

We are not opposed to increases in general taxation to improve public services, but we also believe that if any of these sites are developed appropriate contributions should be made by developers to improve local amenities and/or to limit the impact these developments may have on the existing and future local communities. This is not about contributions to social housing but significant contributions to the range of amenities that would need to be improved and capacity increased whether it be for funding school places; supporting social care; providing amenities for families and children; dealing with increased traffic, refuse collection, road and green space upkeep and the many other services local people desperately require and on which further housing development could be a tipping point shifting the ability to ‘just about cope’ to one where local services will collapse and have a very negative impact upon the quality of life of the whole community but excessively so on more vulnerable people and those whose financial circumstances are less secure.

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Specific Comments re Developments in and around Farm Lane

We are concerned about the impact of one or more developments on the immediate surrounding area particularly in relation to the capacity of the road system to deal with yet more traffic. There are obvious limits due to the nature of the area; the conservation restrictions and the roads themselves. Farm Lane is already dangerous at the best of times particularly at the bends around Ashtead House where there are no pavements for pedestrians. Increases in traffic will both lead to an increase in car accidents; car/pedestrian accidents and car/cyclist accidents thus placing a severe restriction on the amount of traffic the new developments will generate. And with no locally available amenities, most travel will be by car.

Furthermore, Farm Lane is subject to flooding such that at times it is almost impossible to pass and the depth of water is likely to already exceed that recommended by the motoring associations for traffic to drive through. We believe that with a further conversion of open land to developed land, the run off onto Farm Lane will increase thus exaggerating an already challenging problem unless very precise action is taking as part of the development.

We also regularly experience the dangers at the junction of Farm Lane and Rookery Hill as pedestrians, as cyclists and as car drivers. Turning out of Rookery Hill is a nerve racking experience given the site lines that are not favourable. Increasing the traffic flow will do nothing other than increase both the risk and the actuality of accidents with all the implications – especially with the children and young people attending Freeman’s school.

We also believe that even without additional traffic, action needs to be taken at the western end of Farm Lane at the junction with the A24. Turning right is a dangerous experience for cars and cyclists as the traffic normally exceeds the 40mph speed limit and the bend immediately prior to this junction makes it dangerously difficult to make the turn because of limited distance in which to see the motor vehicles. Additional traffic at this junction will only increase the danger – although we believe that this could be solved by restricting the speed of traffic travelling south on the A24 to 30mph rather than the current 40mph.

Farm Land also has, for legitimate safety and transport planning reasons, a weight limit of, we believe. 3 tons and we would expect this to be observed in its totality whatever development proposals are agreed. There should be no breach whatsoever allowed if any developments are approved and the compliance with this should be monitored closely.

34Annex 1

General Comments:

It would be helpful to have a map showing all of the sites and therefore their proximity to each other. Single sites in isolation may have some impact on the Ashtead area; the cumulative effect of several sites (e.g. AS11, AS12 and AS13) also requires consideration. As

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a general point this sort of multiple site development would change the defined boundaries of Ashtead.

In making these assessments the whole of the National Planning Policy Framework’s (NPPF) at chapter 9 regarding “Protecting Green Belt land” paragraph 80 (1) should be applied. This lists the purposes of the Green Belt. The two that have been indicated in Ashtead Neighborhood Forum’s Greenbelt Boundary Review (ANFGBBR) on page 13 (2) as “applying equally to all areas around Ashtead and throughout Mole Valley” are “to check the unrestricted sprawl of large built up areas” and “to assist in urban regeneration, by encouraging the recycling of derelict and other urban land”. The first of these two (“sprawl”) is likely to be more relevant to the sites in this consultation, although consideration has to be given the second (“regeneration”).

We have added specific comment in the application of these criteria as necessary, as considerations under the do not appear to have been specifically recognized and recorded, in the same way as the other three purposes.

A comment that could apply to any or most of the subject sites it is that there is little reference to provision of housing to meet Mole Valley District Council`s(MVDC) Core Strategy Policy CS 3 (3) that covers “Balancing Housing Provision”. This explains the council’s strategy including provision of two and three bedroom properties. Furthermore in many cases there is not any obvious reference to provision of “affordable housing” as covered in Policy CS 4 (3) “The Provision of Affordable Housing”. This is, at least surprising, given that a supply of these types of housing is part of MVDC`s strategies.

Assuming that houses of the type included in the “balancing housing” and “affordable housing” policies become the chosen development at any of the sites being consulted on, the volume of housing is likely to be at the higher density end of the number of houses per hectare. This in turn will allow a greater number of residents to be accommodated, placing an increased burden on the local services and amenities. Whilst we acknowledge that this matter has been included in ACV`s appraisals, particularly in respect of schooling, transport and medical care, it is repeated here for emphasis. The inclusion of private schools in the assessments is unlikely to be an option for those with children who take advantage of affordable housing, placing further burdens on the current arrangements for education.

In that none of the developments appear to provide employment opportunities means that those who are employed outside of their homes will need to travel either locally or further afield. The natural choice will be by private car. No evidence has been presented to date as to the current capacity and whether there is any spare capacity on the roads that link with and to areas outside Ashtead.

The assessments at SA8 do not appear to recognise the increase in emissions from sources including domestic heating systems in new developments.

Application of the tests at SA 16 in many of the assessments has been reported as “not applicable” with a comment that “this is a proposal for housing”. These should be revisited as housing is unlikely to generate employment opportunities to meet the needs of the local community. Thus if there is no contribution, and the effect is not neutral, it must therefore have a negative impact. This can be demonstrated by the need to travel to take advantage of employment opportunities, with the consequential impact on “sustainability”.

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33Dear Mr Tuley and the ACV Group.We totally support the assessments made by John Longstaff in relation to sites AS14,AS08,AS07,and AS05.These are much more realistic appraisals of the proposed development sites which in our view make all these sites unsuitable for development.In addition in 2007 and published in October 2008 Mole Valley District Council made their assessment under the Strategic Housing Land Availability of various sites across Mole Valley including 2 of the areas in AS08 (Areas 1 and 2).Their conclusions are attached which states THEY DO NOT HAVE ANY POTENTIAL FOR HOUSING DEVELOPMENT (Their designations for these sites was HS101).We request again that you include these published MVDC assessments in your current assessment and they are equally applicable to ALL the sites AS08,AS14,,AS07and AS05.I bought these facts to the attention of Jack Straw from Mole Valley at last weeks meeting and he was aware of them

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28Thank you for the opportunity to comment in relation to the Site Assessment.

I read that the task of allocation of new sites for development has largely been returned to the local authority, which I consider is a disappointment considering the purpose of the Localism Act.

That said, if our voice still has a purpose, I writing with my view, based upon my being a resident of Ashtead for almost 40 years.

I feel that I cannot sit by and witness any reluctance by the residents of Ashtead to consider radical solutions to what is a local and national housing crisis. During my time in Ashtead, I have watched a sad migration of young people from Ashtead, the vast majority of whom never – or are never – to return, a fact greatly engendered by the shortage of housing or relative affordability.

Over the same period of my living here, Ashtead has undergone infill development to the extent that any more is just going to be tinkering at the edges of the housing issue.

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National statistics of new housing starts over the past 10 or so years is woeful and under-shoots every aspiration for meeting house land supply targets. Hence to have people making bold statements – often expressed in capital letters as if they were shouting – that the green belt is sacrosanct is nothing short of selfish and pure NIMBYism.

For a start, most of the land surrounding the built environment of Ashtead is not green belt, but land to which a green belt policy is applied – in legal terms, that represents a significant difference. Of that surrounding land, there are tracts which have no landscape merit other than forming buffer land. It is not properly farmed or well-husbanded and is ideal for the sort of development which will bring vibrancy to the area, not to mention valuable revenue by way of Council Tax and Business Rate.

Ashtead is not a village idyll which some of the commentators try to pretend. It is a community on the outskirts of London and is a pleasant place to live because of the community – not because of villagey houses and duck ponds. Ashtead must be prepared to play its part in shouldering its proportion of the local and national requirement for housing. So, let us have a go at the green belt land and allow for the creation of further attractive tracts of much-needed and good development.

An excellent example of recent development – albeit what will (or perhaps should be) the last of the significant infill developments – is Parsons Mead, which is almost across the road from where I live. The result there, after long delays caused by largely specious objection, is a sensitive and attractive development and built environment; it cleared up a scruffy old school site, it provided many homes which included much-needed affordable housing and, in conjunction with Ashtead Cricket Club, provided a brilliant facility for the promotion of sport for young people (not to mention a new pavilion for the Cricket Club, an organisation which plays a vital role within the community far beyond just turning up for a game of cricket at the weekend).

‘Development’ is seen by many as a dirty and abhorrent word. However, if given the chance, and if people are willing to work with (rather than against) those with the ability and the finance to make it work, it is a community-enhancing process.

So I urge us all to get our heads out of the sand, let the scales drop from our eyes and to see just what we can achieve.

Once again, thank you for this opportunity.

27No objection per se to any of the sites proposed. But am concerned about the possibility of any new houses in Ashtead without the guarantee of further nursery and school places and extension of provision of GP practice availability.

16

Challenging the ACV Site AssessmentsArea J

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Main objections:Could have been written by the ‘Site Promoter’ rather than Local Residents

Sustainability Appraisals for sites in area J are largely inaccurate and inconsistent with those in other areas

Takes no account of all the comments on the ACV GBBR for Area J (see table below)

References to ACV GBBR Report contains the following ‘Contributions to Green Belt’ assessments:Criteria ACV Assessment LocalResidents Assessment

(all J area)J1 J2 J3Merging Minimal Significant MinimalEncroachment Minimal Minimal MinimalSetting / Character Moderate Moderate ModerateComments & Objections to ACV GBBR ReportItem

Description Letters/ emails Survey comments Total

1) Opposed to any green belt development

0 15 15

2) Opposed to conclusions for J

38 43 81

3) Opposed to conclusions for F (i.e. no changes to GBB)

1 2 3

4) Agree with conclusions for F (i.e. changes to GBB)

0 3 3

5) Suggesting development in areas next to M25 (A4,E, F, G, H)

2 6 8

6) Minor comments 4 1 5

Total 45 70 115

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To whom it may concern: I am writing in reference to the proposed developments in Ashtead. I have completed the online surveys and feel so strongly about this I am also taking the time to email separately and would appreciate this email being printed off and placed on your file for further consideration.

I have lived in Ashtead all my life, I have loved Ashtead with its real sense of community feeling with lovely greens to run and play in, woods to explore, light traffic causing little concern for my parents to enable me to play outside and the quiet village atmosphere. My husband has also lived in Ashtead all his life. My husband and I saved a significant amount of money to enable us to pay the premium it costs to live in Ashtead so that our children could benefit from the wonderful childhood we both enjoyed in Ashtead. I am mortified to think that this could all be changed by the proposed 500 new homes! Ashtead would loose everything that my husband and I had as children here. We already struggle to get out of our road off Barnett Wood Lane due to the increased traffic. We are both strongly concerned about the impact new houses would have on our children's school places not to mention the doctors surgeries which are stretched to the limit and not forgetting the dentists, library and train station which would become too over populated.

I understand that there is a need for more housing but we have watched Ashtead become vastly more populated in recent years with Parsons Mead developments and many others and noticed the impact this has had and we are strongly against any more houses. We take our children to see the horses in the "horses field" on Barnett Wood Lane and take them to the same field when it has been snowing, please do not develop on our childrens' play area and the pleasure our children get to see horses at the end of their road. Please do not damage their lungs with any more pollution caused from yet more traffic in our village, please do not allow more cars to park along Barnett Wood Lane so residents can commute to London.

The Mole Valley covers a large area - please dont ruin what is left of our village in Ashtead and deprive our children of the chance of growing up in the Ashtead that we knew and loved.

11I have some further general comments on the site appraisals, which I hope you can pass on to ACV.:-

1.0 Where land is green belt a sequential test is required, as no sequential testing has been considered the sustainability appraisals do not follow planning guidelines. How will this be addressed?

2.0 The sustainability appraisals include some items that are impossible to assess without knowing how many homes are proposed for each site.

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Also the column headed up level of compatibility is a strange heading to use, surely this should be impact of the proposal? then the statements major negative , minor negative, neutral, minor positive, major positive make sense. What does level of compatibility mean?

13Dear Mr Ellis,

I have seen the Site Assessments prepared in respect of the Old Chalk Pit, Pleasure Pit Road and in respect of the Ashtead Park Garden Centre, Pleasure Pit Road.

The Assessment in respect of the Old Chalk Pit mentions that the neighbouring authority Epsom & Ewell District Council objected on Greenbelt grounds to the most recent application to build on the Ashtead Park Garden Centre site, and therefore should be consulted, and further that merging is significant in this area. It is therefore surprising that neither point is mentioned in the Assessment for the Ashtead Park Garden Centre site itself. Surely both should be? Indeed the latter Assessment, in what is practically the same area, incorrectly claims that merging is minimal.

The Ashtead Park Garden Centre site Assessment does mention some of the comments of the Appeal Inspector in the recent application MO/2006/0524, but does not mention that his principal reason for holding that the Garden Centre site is a sensitive part of the Greenbelt is that any development of the centre of the site (such as then proposed) would be visible from the Epsom perimeter road formed here by Wilmerhatch Lane and the Headley Road which currently retains an open country outlook and prevents the appearance of merger between Epsom and Ashtead in this area.

The Ashtead Park Garden Centre site Assessment claims that the site can be treated as in effect a brownfield site. That clearly was not the view of the Appeal Inspector in 2006. The new building recently permitted is in the same area as the original Garden Centre buildings, and in no way affects the point that the Appeal Inspector was making.

Surely the Garden Centre Assessment should have mentioned the above points, something that it has singularly failed to do?

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I refer to Mr Beresford’s well thought out reports on the sites under review, and I am 100% in favour of all his comments . I hope that most will be incorporated in a revised ACV report , and in any event be considered by MVDC when decisions are to be reached .

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I am writing in response to your request for comments about the Site Assessments following the ACV Green Belt Boundary review.

It would appear that the Planning Minister Nick Boles is never standing still and during the past few months it is a pity that the weather did not change as many times as the directives from the Minister. I enclose a recent report from the Daily Telegraph that seems to indicate much greater emphasis upon building in towns and cities to spare further erosion of the countryside. Also there was a report this week in the Dorking & Leatherhead Advertiser following yet more comments from Nick Boles. In fact James Friend deputy Leader of MVDC is quoted as saying the housing target for the district could be reduced by as much as 400 dwellings over the next 10 years from the previous target of 1,000 new homes.

In the circumstances I appreciate the task for you and your team has not been made any easier and I must commend you for the detail and amount of information that has been put together in the report.

Looking at the individual sites I still stand by the comments in my letter of 16 January 2014 relating to those sites identified as (J) at the time, a copy of which is enclosed for the record. However I have excluded the enclosures that related to the decision notices from MVDC. Therefore I have nothing further to add in respect of Ashtead Garden Centre, Old Chalk Pit, Land at Farm Lane and Land at The Pines.

Lime Tree Cottage This site located further south along Farm Lane at the junction with Park Lane carries a common theme in as much that a previous planning application was refused. With a rural aspect bordering the Green belt of Epsom & Ewell BC and located off a narrow highway without paths, I consider any development would be detrimental to the immediate locality.

Sylvacote & Avenue Cottage This is another site where the owners have sought planning permission unsuccessfully to develop the site. The arguments are similar to Lime Tree Cottage that is within the immediate vicinity. Any loss of space would be to the detriment of the area.

Chase Farm & Land South of Sandpipers It would appear that these two sites are closely associated with each other in more ways than one. I note that an application to develop Chase far was refused in 1956. Any building would be an intrusion into the Green Belt and the Surrey Hills beyond. The current boundary at the southern end of The Warren must not be eroded. Since there is no access to the land at Sandpipers it would require an amendment to the curtilage of the site ultimately to the detriment of the Green Belt and the surrounding area.

Land South of Ermyn Way We read of constant concerns about pollution and here you are suggesting a site adjoining the M25 motorway. I appreciate a precedent was established following the compulsory purchase order for dwellings on the A24 to the east of the motorway bridge before the Knoll roundabout. Subsequently a substantial residential development took place in later years once the motorway was in use.

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However I do not see that two wrongs make a right and therefore I cannot see the justification for developing this site.

Murreys Court It is noted that this site has been earmarked by MVDC for many years following a part development of what has become known as The Murreys. Any additional housing in this area will have a huge and devastating impact upon the local infrastructure and services especially as land on the Leatherhead side of the M25 in Barnett Wood Lane is under consideration for housing as a joint venture between MVDC and Merton College.

My concern with the sites identified by ACV is the fact that they are all land owner/developer lead with the exception of Murreys Court. I am not sure who is wagging whose tail! Reading the assessment of each site I find myself feeling that there is a desire to appease the wishes of the owners. Sadly I do not see sufficient evidence of challenges and counter arguments against each site. The statements are inclined towards how to agree rather than object and dismiss the submissions from the owners.

Personally I am against all the sites submitted. Ashtead is the largest conurbation in MVDC and our roads, education facilities, health and utilities are inadequate. There has been no sign of an improvement in spite of a considerable expansion over the last decade with new houses at Parsons Mead and St Andrew’s school along with all the other in fills. Where has the section 106 money gone – certainly not too much in Ashtead?

Perhaps we shall obtain protection from further comments in the enclosed Daily Telegraph article “Councils will be able to block developments in Greenfield areas if local roads and sewage systems cannot cope with the extra homes”. It goes on to say, a spokesman for No 10 policy unit said “The strengthened focus on Green Belt protection would be welcomed across the country. It is great news that the Planning Minister has listened to the calls to clarify the NPPF and is amending planning guidance to close many of the loopholes being exploited by rapacious developers.” There I rest my case.

ACV Green Belt Review

I am in receipt of your Winter newsletter asking for views on the future of the Green Belt.

From the front page it would appear that you have given considerable prominence to the areas J1, J2 & J3 located in and around the vicinity of Farm Lane. I am surprised that ACV has applied less than half the prescribed sustainability criteria and ignored previous planning applications submitted upon some of the sites in J and overlooked the strong reasons why they were refused and dismissed on appeal. Therefore I believe, as a committee, you have failed to appreciate the basic principles of the Green Belt to Ashtead in your review and in particular the importance of the sites classified as J to restrict the urban sprawl from Epsom that has previously been upheld by the Planning Inspector.

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In the original plan J 1-3 were part of area B, namely Ashtead Park. However I see from the August minutes on your website area J was hived off at the request of the owners. Surely you should be protecting the overall interests of the Ashtead community rather than the commercial benefits of the various land owners. In the circumstances I would challenge in whose interest ACV operates relative to the make up of its Forum.

It seems to me that by separating J from B you are creating a weakness in the benefits of the Green Belt. If you revisit your map of Ashtead a distinct corridor exists from Ashtead Park to the Woodcote Stud Farm and beyond, north to Chessington and south to Epsom Downs. Loss of any part of this enlarged area of Green Belt in Ashtead could have a huge impact upon the Epsom side that currently protects urban sprawl. Therefore I recommend in the strongest possible terms that ACV revisits its plan and immediately reconnects B & J into one area and delete it as a potential site for reclassification. In case you are unaware the site known as Ashtead Park Garden Centre, previously The Marsden Nursery has been the subject of numerous planning applications. Most noticeably I should refer you to application MO/2003/1285 for the erection of 47 houses that was refused and dismissed on appeal. Please find attached a copy (Item1) of the MVDC decision notice with reason (1) citing the need to preserve the Green Belt from development. Many others reasons for refusal are included that the ACV committee considers irrelevant in its assessment. A subsequent application MO/2006/0524 (Item 2) for a single contemporary designed dwelling was refused and dismissed on appeal in order to once again preserve the Green Belt that includes the adjoining Woodcote Stud Farm located over the boundary in the Borough of Epsom & Ewell. Whilst the site is used commercially the classification of a nursery is quasi agricultural and therefore not permitted for residential development and as stated above, upheld by the Inspector

Another interesting planning application in the immediate area was MO/2004/0603 for a property known at the time as “Little Park Farm” now a contemporary barn development located on the eastern side of Farm Lane on the northern boundary of “The Pines” that forms part of site J3. Prior to the current owner an application to demolish the original dwelling and erect 4 chalet bungalows was refused. Once again as per the enclosed decision notice (Item 3) citing reason (1) the preservation of the Green Belt and other reasons given being harmful to the setting of Park Farm House and increase traffic to and from access on to Farm Lane, sadly reasons dismissed within your sustainability criteria test.

Ashtead House brings to mind another planning application of interest MO2006/1462 in the immediate vicinity when Millgate Homes applied to erect 8 dwellings in the grounds of this listed house. The application was refused and as per the enclosed notice letter (Item 4) from MVDC, reason (1) stated that the development would be out of keeping with the character and setting of a Grade 11 Statutory Listed Building and detrimental to the character and appearance of the Ashtead Conservation Area.

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It would appear that your team has failed to recognise the importance of listed buildings in the area namely, Park Farm House, Ashtead House and the garden wall running along Farm Lane. In fact I am aware from previous planning applications that the MVDC Conservation Officer stated that the Green Belt between Park Farm House and Ashtead House was of fundamental importance to maintain the break in residential development between the two listed properties.

The location and topography of J2 would appear to be unsuitable for residential development being an extinct chalk pit that has become something of a land fill over the years. Also I am informed by a local resident that it is a haven for wild life that includes nesting owls and a wide variety of birds.

Whilst I appreciate the need to find and create land for residential development I am of the opinion that your recommendations for the area in and around Farm Lane has not been thought through with sufficient consideration to planning history and efforts made in the past to protect this area of Green Belt from unscrupulous developers. It seems to me that ACV has played into the hands of the Dipre family who must be rubbing their hands with glee. Therefore I am surprised that your newsletter fails to make reference to previous planning applications on the sites for the benefit of less informed readers which leads me to believe that inadequate research has taken place relative to this important piece of information. If on the other hand you were aware of the planning history why have you not explained this in your newsletter?

I commend you for undertaking the role of developing a Local Plan with worthy intentions but as an unelected body ACV has delivered a statement of intent with far reaching consequences. What consideration has been given to the impact of potentially upwards of 300 homes off Farm Lane, generating owners of over 400 vehicles using narrow lanes without pavements already used as “Rat Runs” In this respect I challenge your theory that there would be less traffic movements than currently taking place at Ashtead Park Nursery. Clearly an inadequate survey has been undertaken early morning and late afternoon/evening to identify traffic movements currently that would escalate out of control should a mass housing development take place. In addition the recent spell of weather has highlighted flooding and an inadequate drainage system.

To summarise, I am totally against your recommendations as published that I feel lack credibility over your interpretation of the Green Belt in its present form that we need to secure for posterity if we are to benefit in Ashtead and protect ourselves from urban sprawl. Therefore I further recommend that you should reconnect plots B & J and remove this enlarged area of Green Belt from reclassification. The Council and Inspector have proven to be supportive in protecting Ashtead from urban sprawl and therefore on this occasion I regret to say that I have more confidence in MVDC caring for Ashtead than the recommendations put forward by AVC.

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Consultation on Development Proposals for Ashtead

We would like to make our comments to the Neighbourhood Forum regarding a number of the above redevelopment proposals with the expectation that these will be forwarded – along with other responses – to the Planning Committee at Mole Valley District Council.

Primarily, we would like to express our detailed views on three proposal in and around Farm Lane but we would also like to make some more generic comments about the cumulative impact if a multiple number of developments were approved.

General Comments

Whilst recognising the national crisis with respect to the shortage of housing and the failure of consecutive governments to address this issue, we believe that proposals for new developments need to be cognisant of the impact they will have on local amenities. Whilst individual landowners will, inevitably, make substantial and personal gains if particular sites were approved for development, it is absolutely essential for local amenities to be improved and capacity increased to take account of the population increases that new housing will bring. I am certain that many others have already referenced the existing pressures on all local nursery, primary and secondary schools; local health services – particularly primary and community health services – local roads; pavements; shops; traffic; social care and the many other services that are often provided by the local state that is having its funding not just reduced but literally slashed. Additional residents will make existing pressures intolerable.

We are not opposed to increases in general taxation to improve public services, but we also believe that if any of these sites are developed appropriate contributions should be made by developers to improve local amenities and/or to limit the impact these developments may have on the existing and future local communities. This is not about contributions to social housing but significant contributions to the range of amenities that would need to be improved and capacity increased whether it be for funding school places; supporting social care; providing amenities for families and children; dealing with increased traffic, refuse collection, road and green space upkeep and the many other services local people desperately require and on which further housing development could be a tipping point shifting the ability to ‘just about cope’ to one where local services will collapse and have a very negative impact upon the quality of life of the whole community but excessively so on more vulnerable people and those whose financial circumstances are less secure.

Specific Comments re Developments in and around Farm Lane

We are concerned about the impact of one or more developments on the immediate surrounding area particularly in relation to the capacity of the road system to deal with yet more traffic. There are obvious limits due to the nature of the area; the conservation restrictions and the roads themselves. Farm Lane is already dangerous at the best of times particularly at the bends around Ashtead House where there are no

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pavements for pedestrians. Increases in traffic will both lead to an increase in car accidents; car/pedestrian accidents and car/cyclist accidents thus placing a severe restriction on the amount of traffic the new developments will generate. And with no locally available amenities, most travel will be by car.

Furthermore, Farm Lane is subject to flooding such that at times it is almost impossible to pass and the depth of water is likely to already exceed that recommended by the motoring associations for traffic to drive through. We believe that with a further conversion of open land to developed land, the run off onto Farm Lane will increase thus exaggerating an already challenging problem unless very precise action is taking as part of the development.

We also regularly experience the dangers at the junction of Farm Lane and Rookery Hill as pedestrians, as cyclists and as car drivers. Turning out of Rookery Hill is a nerve racking experience given the site lines that are not favourable. Increasing the traffic flow will do nothing other than increase both the risk and the actuality of accidents with all the implications – especially with the children and young people attending Freeman’s school.

We also believe that even without additional traffic, action needs to be taken at the western end of Farm Lane at the junction with the A24. Turning right is a dangerous experience for cars and cyclists as the traffic normally exceeds the 40mph speed limit and the bend immediately prior to this junction makes it dangerously difficult to make the turn because of limited distance in which to see the motor vehicles. Additional traffic at this junction will only increase the danger – although we believe that this could be solved by restricting the speed of traffic travelling south on the A24 to 30mph rather than the current 40mph.

Farm Land also has, for legitimate safety and transport planning reasons, a weight limit of, we believe. 3 tons and we would expect this to be observed in its totality whatever development proposals are agreed. There should be no breach whatsoever allowed if any developments are approved and the compliance with this should be monitored closely.

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