The Long Ditton Residents Association have formerly responded to Elmbridge Borough Council.
(Our response can VIEWED HERE)
Our main concern is that the Council has prematurely treated Green Belt as an ‘option’ for meeting long term development when Government policy is clear that Green Belt release should only even be considered after all other options have been exhausted.
The Council has undertaken a comprehensive review of the Green Belt in Elmbridge to inform the options currently being considered. Green Belt releases have been suggested as potential options for meeting the objectively assessed housing need (of 9,480 to 2035) as a result.
However, national policy (National Planning Policy Framework) makes it clear that this should only happen in ‘exceptional circumstances’ and after all other options have been explored through the local plan review process. The Housing White Paper (Feb 2017) confirms that there will be no change to national policy but proposes amendments to the NPPF (to be introduced later this year) to make it clear that:
“authorities should amend Green Belt boundaries only when they can demonstrate that they have examined fully all other reasonable options for meeting their identified development requirements, including:
* making effective use of suitable brownfield sites and the opportunities offered by estate regeneration;
* the potential offered by land which is currently underused, including surplus public sector land where appropriate;
* optimising the proposed density of development; and
* exploring whether other authorities can help to meet some of the identified development requirement.”
This process should be applied before coming to the conclusion that there are exceptional circumstances for releasing Green Belt. Options 2 and 3 of the Council’s consultation are therefore premature as other ‘reasonable’ options have not been fully explored. In order for the Council to even consider Green Belt, further ‘urban capacity’ work that goes beyond the Land Availability Assessment, is needed.