EBC recently responded to the Draft London Plan and wrote to Sadiq Khan – EBC’s response can be seen here – (EBC Response to Draft London Plan)
LDRA have responded to this letter and written to EBC.
Our response can be viewed here (LDRA letter to EBC) and is detailed below:
24th February 2018
Dear Councillor Randolph and Planning Committee,
I am writing, on behalf of the Long Ditton Residents Association, in regard to the proposed response, to the Mayor of London, on the Draft New London Plan (NLP). Having read the Elmbridge suggested submission*, which will be agreed at the Cabinet Meeting for Planning Services, on Tuesday 27th February 2018. We would like to encourage the removal the section entitled ‘A strategic review of the Metropolitan Green Belt’, and request a reconsideration of the view on using Green Belt land for housing development.
The statements made in that section, encouraging the Mayor of London to perform a Metropolitan Green Belt review, indicate clearly that Elmbridge Borough Council (EBC) is still favouring the strategic approach of removal of Green Belt designation to meet housing demand.
February 24th 2017 was the closing date for responses to the ‘Elmbridge Local Plan: Strategic Options Consultation’, a year ago to the day. The EBC published ‘Summary of Consultation Responses -July 2017’ which stated that 3,760 responses were received, with approximately 50,000 individual comments. On page 14 – Section 5.2, it states that the ‘vast majority of respondents’ were opposed to any amendment to the Green Belt boundaries. This makes it all the more astonishing that EBC is providing feedback encouraging the Mayor of London to review Green Belt land, as a potential for development. The only interpretation from this is that EBC has not taken the consultation seriously, and is simply ignoring the feedback and wishes of its residents.
If the Mayor of London’s planning team are viewing Metropolitan Green Belt and Metropolitan Open Land as sacrosanct, worth protecting, and valuable green infrastructure; why is EBC taking such a contrary approach, rather than supporting their position?
Additionally, this appears to be in contravention of the first priority listed in the ‘Elmbridge Council Plan 2018/19’, which states: ‘Character and Environment – We will make Elmbridge a sustainable and attractive place’. Encouraging a review of the Metropolitan Green Belt, which could risk development of the borough’s Green Belt land, hardly supports this stated priority. Also, the fourth priority listed: ‘Community Wellbeing – We will listen to all of our residents and support communities to become healthier, empowered and safe’, will not be served by ignoring the residents’ consultation feedback, risking the Metropolitan Green Belt being eroded, leading to a sprawling mass of housing development, and with increased pollution.
Furthermore, the Cabinet Minutes, from 15th November 2017 meeting, review the Borough wide short survey conducted in September 2017. They clearly state the residents’ view on green land and Green Belt to the council. On page 8, the minutes record:
– On the environment, the top response from residents, is ‘to preserve green spaces’ (74%)
– In the next 5 years, residents want EBC to be known for ‘protecting the Green Belt’
The EBC message to review all Metropolitan Area Green Belt land is in stark, and direct, contrast to the Mayor of London’s position, as the NLP states multiple times that Metropolitan Green Belt and Metropolitan Open Land should be preserved and protected. I refer to the following sections:
Page 14, Section 1.2.1 Page 15, Section 1.2.8
Page 27, Section 2.0.2 Page 62, Section 2.3.1
Page 301, Chapter 8 – Green Infrastructure and Natural Environment
The EBC statement that Green Belt reviews are in ‘many cases concluding that there are areas of Green Belt, no longer sufficiently meeting the purposes of the designation’ was not found to be the case in Elmbridge. The EBC commissioned Arup report, ‘Green Belt Boundary Review – Issue Rev C – 14th March 2016’, did not list any Green Belt land in Elmbridge as being ‘non-performing’.
In the NLP, (page 303 – Section 8.2.2), it specifically makes the position clear that even unsightly and derelict Green Belt land ‘is not, however, an acceptable reason to allow development to take place’. This is supported by the ‘National Planning Policy Framework (March 2012)’, Page 19 – Section 9, Paragraphs 80 and 81.
Suggesting that the Mayor of London commissions a review of the Metropolitan Green Belt, we believe will be a very risky strategy, as it could easily lead to areas of Metropolitan Green Belt, outside of London, being targeted and current designation rescinded. Most importantly, this then sets precedent, and developers will petition for the release of other areas of Green Belt land.
EBC has just endured a Planning Appeal for ‘Drake Park’, contesting a developer’s appeal to be allowed to develop on Green Belt land in Walton on Thames. The EBC document ‘Statement of Case on behalf of the Local Planning Authority’ (LA Reference: 2016/2217; 23rd June 2017), contains a 5 page section, (8.1 to 8.22), defending the potential and irreversible ‘harm to the Metropolitan Green Belt’. This is completely contradictory to the feedback now being provided by EBC to the NLP. This inconsistent approach and polar opposite perspective, reduces EBC’s credibility.
In summary, we do not believe that it will serve Elmbridge’s purpose, or best interests, to make comments on the Green Belt, or by encouraging a Green Belt review, in the response to the New London Plan. It is likely to adversely impact Elmbridge’s reputation with neighbouring Boroughs and County Councils, and will draw more adverse reaction from its residents. Worst of all it could open the flood gates and threaten the future for all of Elmbridge’s Green Belt land. We hope that EBC will reconsider its position.
Thank you.
Regards,
Paul Bartlett
Green Belt Officer
Long Ditton Residents Association
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