1. What is the purpose of a Local Plan?
2. Why is Epsom & Ewell Borough Council (EEBC) producing a new Local Plan?
3. What are the stages of the Local Plan?
4. At what stage of the Local Plan process is EEBC?
5. What is the difference between the Regulation 18 Consultation and a Regulation 19 Consultation?
6. When will decisions on the content of the Proposed Submission Local Plan be made?
7. How has EBBC taken into account the feedback received during the first public consultation on the Local Plan (Regulation 18)?
8. What data and information has been used to inform the Local Plan?
9. What data does EEBC have to use in calculating its housing need?
10. What is the difference between our ‘housing need’ and ‘housing requirement’?
11. What is the current housing need in the borough today?
12. Can our housing and economic needs be met on just brownfield sites?
13. Can Longmead and Kiln Lane industrial estates be developed for housing?
14. What is the aim of Green Belt policy?
15. What are the purposes of the Green Belt?
16. Can Green Belt land be developed?
17. What infrastructure will be provided to support the Local Plan?
18. How can I ensure that I am notified when the next public consultation takes place? 
19. Has the National Planning Policy Framework (NPPF) been updated following the general election?
20. Why don’t EEBC pause the development of the Local Plan again?
21. Why are meetings on the Local Plan involving councillors not open to the public?

1. What is the purpose of a Local Plan?

The Local Plan is a critical document in shaping the future of the borough. In its final form, the Local Plan will determine where new development should go and where should be protected. This includes sites for new homes including affordable accommodation, supporting businesses, creating jobs, securing much needed infrastructure improvements, environmental protection and leisure development. 

There is far more to the Local Plan than allocating sites for development; it covers a range of matters that will benefit current and future residents of the borough, such as protecting public open spaces and retail areas, increasing biodiversity and increasing the standard of homes and commercial buildings being delivered. 

All local planning authorities have to produce a Local Plan which sets out planning policies to help achieve this. Following adoption, the Local Plan will be used to decide planning applications that come forward in the borough. 

2. Why is Epsom & Ewell Borough Council (EEBC) producing a new Local Plan?

We need a Local Plan for the borough that meets the current challenges the borough faces and shapes future development. Every council is legally required to review their Local Plan at least every five years and given the age of our current Local Plan, EEBC need to produce a new one. 

Without an up-to-date Plan in place, there is a risk that central government could intervene and prepare a Local Plan for the council that limits local involvement and decision making in the process. The borough would also be at increased risk of unplanned, speculative development due to its current shortfall in housing delivery. Adopting an up-to-date Local Plan will ensure that local people have a greater say on how their communities are developed in the future, and that we are in a stronger position to defend ourselves from unsuitable speculative planning proposals.

3. What are the stages of the Local Plan?

We have kept the process of developing the Local Plan open and transparent. The key stages below were publicised widely before and during the first public consultation, and in the autumn was updated again with estimated dates, as below.

STAGE 1	Gather evidence and early consultation (January 2022 – January 2023)
STAGE 2	Six-week public consultation on a Draft Local Plan, known as “Regulation 18” (February – March 2023)
STAGE 3	Review consultation feedback and gather further evidence to develop the Local Plan
STAGE 4	Six-week public consultation on a proposed submission Local Plan, known as “Regulation 19” (January 2025)
STAGE 5	Submission of Local Plan to the government for examination (May 2025)
STAGE 6	Public examination of the Local Plan by a planning inspector (Estimated to commence Summer 2025)
STAGE 7	Adoption of the Local Plan. It will replace the existing Local Plan and will be used to assess planning applications (Estimated to commence Spring 2026)

 

4. At what stage of the Local Plan process is EEBC?

We consulted on a draft Local Plan (Regulation 18) in February and March 2023 (Stage 2 in the above table) and following the close of the consultation the Local Plan was paused until October 2023. Following the unpause we are nearing completion of Stage 3 and Stage 4 will commence once Full Council make a decision on how to proceed with the Local Plan.  

The meeting of Full Council will take place on 10 December 2024, who will consider the recommendation(s) made by the Council’s Licensing and Planning Policy Committee at their meeting on 20 November 2024.   

5. What is the difference between the Regulation 18 Consultation and a Regulation 19 Consultation?

The council consulted on a Regulation 18 Draft Local Plan (2022-2040) in 2023 that was a detailed Local Plan containing strategic policies (including draft site allocations) and development management policies. This was the first consultation stage where the consultation comments are considered by the Council before the plan is amended to produce a Proposed Submission (Regulation 19) Local Plan.  

The Proposed Submission (Regulation 19) consultation stage is different to the Regulation 18 stage as : 

• It is the last stage of public engagement before submitting the Draft Plan to the Planning Inspectorate for examination. 
• All responses received during the consultation period will be sent to the Planning Inspectorate. 
• Representations can only be made on the soundness and legal compliance of the Proposed Submission Local Plan. The Soundness Tests are detailed in paragraph 35 of the NPPF (December 2023). 

6. When will decisions on the content of the Proposed Submission Local Plan be made?

On the 20 November 2024, the Council’s Licensing and Planning Policy Committee (LPPC) will consider a Proposed Submission Local Plan (Regulation 19).  

LPPC will make a recommendation to Full Council who will then decide how it wishes to proceed with the Local Plan. The meeting of Full Council will take place on the 10 December 2024. It is only at this stage that a Full Council decision on the Proposed Submission Local Plan will be made, and if it is agreed, it will go forward to another six-week public consultation.  

The agenda pack for this meeting of the LPPC  has now been published and can be accessed from the following link: 

Epsom and Ewell Democracy (epsom-ewell.gov.uk)

7. How has EBBC taken into account the feedback received during the first public consultation on the Local Plan (Regulation 18)?

We received a wide range of comments on our draft Local Plan from residents, organisations with an interest in the Local Plan (including public bodies such as the Environment Agency, Surrey County Council and Historic England), community organisations and landowners. 

We have carefully considered all the comments received during the consultation on the Draft Local Plan (Regulation 18) that was undertaken in February and March 2023.  

We have prepared a Consultation Summary of the comments received during the Regulation 18 Consultation which provides a summary of the main issues raised during the consultation on the Draft Local Plan (Regulation 18), and how they have been taken into account in preparing the Proposed Submission Local Plan (Regulation 19). 

This document has been published as part of the agenda pack of the Licensing and Planning Policy Committee and can be accessed from the following link:  

Epsom and Ewell Democracy (epsom-ewell.gov.uk)

8. What data and information has been used to inform the Local Plan?

To support our Pre-Submission Local Plan we have published a full suite of evidence base, including additional evidence base documents on flooding, land availability, open space, green belt and the Epsom Town Centre Masterplan. 

The Local Plan evidence base can be accessed here: 

Evidence base | Epsom and Ewell Borough Council (epsom-ewell.gov.uk) 

9. What data does EEBC have to use in calculating its housing need?

We are required to use the Government’s ‘Standard Method’ for calculating housing need, which uses 2014 Household Growth Projections data published by the Office of National Statistics (ONS). The requirement to use this data was reiterated by the publication of the latest version of the National Planning Policy Framework (NPPF) which did not make a change. More recent data is not believed to be robust. The Standard Method generates a need of 569 dwellings per year for the borough (using 2024 as the baseline year). Changes to the NPPF in December 2023 did not result in any changes to the Standard Method itself, but confirmed that the housing need figure it generates is an advisory starting point. 

The new government consulted on Proposed reforms to the National Planning Policy Framework and other changes to the planning system in the Summer of 2024. The consultation proposed changes to the standard method inputs which if implemented would increase our housing need figure from 569 dwellings per annum to 817 dwellings per annum. The consultation also proposed removing the change made to the NPPF that states the standard method is an advisory starting point.  

The revised NPPF is expected to be published by the end of the year.  

10. What is the difference between our ‘housing need’ and ‘housing requirement’?

The ‘housing need’ for our borough is calculated using the government’s Standard Method. 

The ‘housing requirement’ is set out in the Local Plan. It takes account of the housing need figure and considers whether there are any constraints or other factors that may mean that we should plan for a different number of new homes. The ‘housing requirement’ could be either higher or lower than the ‘housing need’ figure, depending on the local context, but a lower figure (as proposed in the Proposed Submission Local Plan to be considered by Committee and Full Council) will be tested extensively during the independent planning inspector’s examination of the Local Plan. 

11. What is the current housing need in the borough today?

The housing target for the borough is currently that generated by the Standard Method, and we are currently underperforming in our housing delivery. The Council’s Authority Monitoring Report (AMR) identifies historic housing delivery in the borough and in the most recent monitoring year (2023/24) a total of 139 new homes were delivered of which 22 were affordable homes. This is against a target of 569 new homes. The Housing and Economic Development Needs Assessment (HEDNA), which has been developed as part of our Local Plan evidence, calculates the requirement for affordable units across the period as 652 per year. 

The Council’s housing needs register is a waiting list for households in the borough who are in need of low-cost rented accommodation.  As of January 2024, there are 1,350 households on the register, an increase of about 150 households since June 2022. This shortage of housing has implications for local residents who cannot afford to buy or rent appropriate housing and means that the council is currently spending over £1.5m each year on emergency accommodation. Without additional affordable homes being delivered in the borough, this will continue to increase in the future. 

12. Can our housing and economic needs be met on just brownfield sites?

There is insufficient land available through brownfield sites to meet the borough’s identified needs. 

Brownfield land (also known as previously developed land) is land which is or was occupied by a permanent structure.  The majority of the land within the built-up areas of the borough could be considered to be previously developed, but there is also some previously developed land in the Green Belt. Not all brownfield sites in the borough are owned by the council. 

Brownfield sites have an important role to play in meeting our development needs. However, there is not enough land available from brownfield and urban sites to meet the borough’s housing and economic needs.  

13. Can Longmead and Kiln Lane industrial estates be developed for housing?

Longmead and Kiln Lane industrial estates play an important role in offering employment in the borough and should not be developed for housing.  

Longmead and Kiln Lane are the borough’s largest employment sites, providing accommodation for a range of businesses that require industrial and warehousing type accommodation in addition to trade counter type uses. The two sites support about 130 business and 1,900 jobs, with very few vacant premises. Land such as this is becoming scarce as it is redeveloped for housing. 

Over the Local Plan period the need for this type of employment floorspace located at the sites is due to increase, so it is important that land is safeguarded for these employment uses. The ownership of the site is complex with about 20 freehold landowners as well as a significant number of leaseholders. Only a small number of land parcels have been put forward in this area for redevelopment, despite proactive engagement with landowners.  

14. What is the aim of Green Belt policy?

The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence (National Planning Policy Framework, para 142). It is important to note that Green Belt is not an environmental designation. However, within the borough’s Green Belt there is some land that is designated for its biodiversity / ecological value, including Sites of Special Scientific Interest (SSSI) e.g. or Sites of Nature Conservation Importance (SNCI) e.g. Epsom Common Local Nature Reserve and Horton Country Park. 

15. What are the purposes of the Green Belt?

The five key purposes of the Green Belt are set out in the National Planning Policy Framework (NPPF): 

a) to check the unrestricted sprawl of large built-up areas; 

b) to prevent neighbouring towns merging into one another; 

c) to assist in safeguarding the countryside from encroachment; 

d) to preserve the setting and special character of historic towns; and 

e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land. 

Our Green Belt Assessment split the borough’s Green Belt up into parcels of land and assessed these against the five Green Belt purposes with the output being a numerical score. This work demonstrates the varying quality of land designated as Green Belt in the borough. 

16. Can Green Belt land be developed?

The National Planning Policy Framework (NPPF) (December 2023) states that “once established, there is no requirement for Green Belt boundaries to be reviewed or changed when plans are being prepared or updated. Authorities may choose to review and alter Green Belt boundaries where exceptional circumstances are fully evidenced and justified, in which case proposals for changes should be made only through the plan-making process. Strategic policies should establish the need for any changes to Green Belt boundaries, having regard to their intended permanence in the long term, so they can endure beyond the plan period” (Para 145, NPPF, December 2023) 

The NPPF makes clear that it is at the discretion of Local Authorities as to whether Green Belt boundary is amended through the Local Plan process. Any changes need to demonstrate exceptional circumstances, and before concluding that exceptional circumstances exist, local authorities will need to demonstrate that the Local Plan: 

1. makes as much use as possible of suitable brownfield sites and underutilised land 

2. optimises the density of development in the urban area 

3. has been informed by discussions with neighbouring authorities about whether they could accommodate some of the identified need for development – these conversations with neighbouring authorities will continue to take place as the plan develops. 

This flexibility remains within the NPPF to reflect that Green Belt authorities all have their own unique characteristics, challenges and requirements, and that Local Plans must still address competing and conflicting demands for land. 

There are examples of Green Belt land being used for development in EEBC because they were shown to meet very special circumstances, such as the Clarendon Park, Livingstone Park and Manor Park developments. In addition, a development in Langley Vale was rejected by EEBC but this was overturned by the planning inspector who permitted the development to take place due to the acute housing need in the area; this is an example of where speculative development has succeeded in the absence of an up-to-date Local Plan. 

17. What infrastructure will be provided to support the Local Plan?

 EEBC consulted a wide range of organisations on the Draft Local Plan that are responsible for infrastructure provision in the borough, including highways, education, health and water supply and disposal. We have continued to engage with infrastructure providers in developing the Proposed Submission Local Plan to ensure that proposals are supported by suitable infrastructure.  

We have published an updated Infrastructure Delivery Plan which can be located on our evidence base webpage: 

Infrastructure & social | Epsom and Ewell Borough Council (epsom-ewell.gov.uk)

It is normal practice for infrastructure delivery partners to engage in more depth at the later stages of the Local Plan process (such as consultation on the Proposed Submission Local Plan) when further evidence and information is available for their consideration.  

18. How can I ensure that I am notified when the next public consultation takes place? 

The next public consultation on the Local Plan (Regulation 19) is expected to be in early 2025 (subject to approval by Full Council) . If you would like to be kept updated when future consultations are taking place, please visit https://epsom-ewell.inconsult.uk/(link is external), enter your details via the 'Register' tab, and we will notify you when future consultations come forward.  

We will also be keeping our webpages up to date and updating this FAQ document as necessary.  

19. Has the National Planning Policy Framework (NPPF) been updated following the general election?

No, however the Government has recently consulted on some proposed changes to the NPPF and other changes to the planning system. The consultation closed on the 24 September however the consultation material can be accessed from the following link: Proposed reforms to the National Planning Policy Framework and other changes to the planning system - GOV.UK (www.gov.uk) 

The Council’s Licencing and Planning Policy Committee approved the Council’s response to the consultation on the 24 September and the response can be accessed from the following link: Epsom and Ewell Democracy (epsom-ewell.gov.uk) 

The updated NPPF is due to be published by the end of 2024.  

20. Why don’t EEBC pause the development of the Local Plan again?

We need to progress the Local Plan to ensure we have an up-to-date plan in place against which to determine planning applications in the borough.  

The previous government have committed to changes to the planning system through legislation, although further consultation is required and additional (secondary) legislation. The new government have confirmed that they are proposing to introduce this new system, although the date by with plans need to be submitted by to be assessed against the current system is proposed to be delayed.  

A more pressing matter will be the implications of the revised NPPF (one published) and the details on the transitional arrangements that will apply for Local Plan to be examined against the current (December 2023) NPPF. It is therefore important that we continue to progress our Local Plan to Regulation 19 consultation stage as soon as practically possible. . Any further pauses to the Local Plan, will mean that we will be without an up-to-date Local Plan for longer. 

The risk of going for longer without an up-to-date Plan in place is that central government could intervene and prepare a Local Plan for us that would limit local involvement and decision making in the process. 

In addition, without an adopted Local Plan, the borough would be at increased risk of unplanned, speculative development due to our current shortfall in housing delivery. 

By continuing to progress the Epsom and Ewell Local Plan (2022-2040), we can ensure that our residents have a greater say on the future development of the borough, and that we are in a stronger position to defend ourselves from unsuitable speculative planning proposals. 

21. Why are meetings on the Local Plan involving councillors not open to the public?

As part of the development of the Local Plan during Stage 3, it is important that councillors can discuss items in relation to the development of the Local Plan outside of public committee meetings, which are referred to as Member Briefings. 

Member Briefings are normal practice and occur on a broad range of topics. It is important to note that these information briefings are not meetings of the Council or a Committee and have no decision-making powers, and therefore there’s no right for public access under the Local Government Act 1972. 

When it comes to the development of a Local Plan, the fact these briefings were due to take place has been mentioned publicly numerous times at Committee and Full Council.