First Published: 21/06/2020
Working with other local Residents’ Associations in Elmbridge, FEDORA has had frequent communications with senior officers of Elmbridge Borough Council (Council), including the Council leader and Chief Executive, concerning the way that the Elmbridge Local Plan is being developed. We have sought to do this throughout in a constructive manner but many of our concerns have not yet been addressed.
We recognise the challenges that the Council now faces in responding to not only the real needs of Elmbridge residents but also the housing targets set by central government, which bear no relation to those needs. These challenges are exacerbated by past failings to use the Council’s full resources to meet past building targets that were more reasonable and in particular the need for affordable housing.
In our most recent communications with the Council we have made the following points:
- We are grateful for the responses to our previous letters at what we know is a busy and difficult time for the Council. However, the responses do not address all of the concerns of the local community and do not adequately respond to all of the ten points originally raised. We have written again with further constructive observations and in the light of the changed circumstances resulting from Covid-19.
- The Council needs to be transparent on its position of key issues. Comments made in its Options Consultation Statement 2019 raise particular concerns. These suggest that the results of an extensive public consultation may not be respected on the grounds that they might not be representative. This seems to imply that the Council proposes to default to a preconceived position on the content of the draft Local Plan and proposes to rely on Examination in Public by an Inspector to resolve the current divergence of views. The Council’s decision not to disclose the instructions given to, and full advice received from, a senior QC regarding its position on process (that councillors must “Wait for Officers’ Evidence”) further undermines public confidence.
- There needs to be a more robust challenge to the housing requirement figures published by central government. The Council’s comments suggest these are mandatory when, in fact, they are merely the starting point for any assessment. In addition, these were developed some years ago on the basis of population projections which the ONS recognised as overstated prior to COVID-19 and may be more so now. We note Councillor Selleck’s letter of 7th May, 2020, to the Minister of Housing, Communities and Local Government on the subject but consider a stronger challenge is required.
- COVID-19 will have wide-ranging implications for future housing volumes and types and the necessary supporting infrastructure. We appreciate that there is uncertainty at present on what these will be but this is no reason to ignore this important issue. Some implications such as the likely changing needs of those working from home and adequate space are highly relevant and need to be incorporated in the emerging Local Plan.
- The Council should follow Government best practice in “Guidance on Plan Making” by publishing documents for public consultation as they are produced. This is currently not proposed for important evidence documents such as Housing Assessments and the Infrastructure Delivery Plan. The Council’s proposed approach of waiting and delivering all evidence, along with the draft Local Plan, to the formal Examination in Public by the planning inspectorate with no prior public scrutiny adds to the sense of lack of transparency. Deferral of the Local Plan’s development would make it easier for the Council to comply with this important Government guidance.
- Delivery of infrastructure is key to all aspects of plan development and needs will have changed as a result of Covid-19. The Government paper Planning for the Future (published in March 2020) recommends infrastructure first which is an obvious conclusion that we support. The Council needs to ensure that plans reflect this need. It is also important that appropriate incentives are developed for public and private bodies to deliver what is required. These incentives do not exist at the moment.
- The Council’s thinking needs to address the issue of density better than it does at present. In particular we are concerned that whilst both the 2019 National Planning Policy Framework and Planning for the Future recognise that density is a key component of character, at a local level the Council has taken a completely opposing stance in its September 2018 Development Management Advice note. This states that "The Council does not accept that smaller units and higher densities detrimentally affect the character of an area”. In addition, the terminology used, particularly “urban area”, is confusing and not consistent with the differing areas within the borough. The Council must develop a policy on density which accords with national guidance and is sufficiently flexible to reflect the characteristics of different parts of the borough. In particular, Planning for the Future recommends ‘gentle density increases’ in residential suburbs rather than the Council’s current crude approach designed to meet housing delivery targets.
- The approach to the provision of Affordable Housing must reflect the real needs of the local community. Incentivising the building of expensive luxury flats in areas such as Cobham, Stoke D’Abernon and Oxshott in order simply to meet housing targets does nothing to meet the needs of families who need affordable homes. The Council’s own finances supplemented by its currently under-utilised Affordable Housing funds should be at the heart of an appropriate policy.
- We also believe that more effort is required to invoke the Duty to Co-operate with other councils. Any plan which does not properly address this may not be accepted by the Inspector. It is regrettable that more was not done to work with Guildford regarding the potential over-supply of housing at the former Wisley Airfield site, particularly given that this proposed development will draw heavily on Elmbridge resources (notably in the Cobham and Downside areas). We understand it may be late for this development to contribute to Elmbridge’s housing needs, but the existence of that development and the infrastructure required should feature in the emerging Local Plan. More work needs to be done by the Council with other boroughs in Surrey to help share the housing load.
FEDORA will seek to continue dialogue with the Council officers and Councillors to ensure that they are made aware of the views and legitimate concerns of residents. We hope that these will be listened to and reflected in the drafting of the Local Plan.
21 June 2020