- What is the purpose of a Local Plan?
- Why is Epsom & Ewell Borough Council (EEBC) producing a new Local Plan?
- What are the stages of the Local Plan?
- At what stage of the Local Plan process is EEBC?
- Why are meetings on the Local Plan involving councillors not open to the public?
- How is EBBC taking into account the feedback received during the first public consultation on the Local Plan (Regulation 18)?
- Have any decisions been made about the policies and site allocations to be included in the next version of the Local Plan?
- Has a Spatial Strategy been confirmed?
- When are these decisions on Local Plan content going to be made?
- What data and information has been used to inform the Local Plan preparation?
- What data does EEBC have to use in calculating its housing need?
- What is the difference between our ‘housing need’ and ‘housing requirement’?
- What is the current housing need in the borough today?
- Can our housing and economic needs be met on just brownfield sites?
- Can Longmead and Kiln Lane industrial estates be developed for housing?
- What are the purposes of the Green Belt?
- Can Green Belt land be developed?
- What infrastructure will be provided to support the Local Plan?
- Why don’t EEBC pause the development of the Local Plan again?
- What further opportunities will there be for local residents to feed back?
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 (We are here) |
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”
|
|
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. (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 now at Stage 3 of reviewing consultation feedback and gathering further evidence to develop the Local Plan. The recent publication of the revised National Planning Policy Framework and Planning Policy for Travellers published by the government in December 2023 are being considered.
5. 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.
6. How is EBBC taking 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 land owners.
We are currently considering all the comments we received during the consultation on the Draft Local Plan (Regulation 18) undertaken in February and March 2023. Alongside the next version of the Local Plan, we will publish a Consultation Statement which will provide a summary of the main issues raised during the consultation, and how they have been taken into account.
7. Have any decisions been made about the policies and site allocations to be included in the next version of the Local Plan?
No decisions have been made on policy wording or site selection for the Local Plan at this stage. We continue to follow the government’s framework for developing a Local Plan, and are considering the comments received during the consultation on the Draft Local Plan. We are also working on the detailed evidence base that’s needed to produce the next iteration of the Local Plan, known as the Proposed Submission Local Plan (Regulation 19 Local Plan).
8. Has a Spatial Strategy been confirmed?
The aim was to confirm a Spatial Strategy to submit to Surrey County Council for transport modelling by the end of January 2024. A Spatial Strategy sets out the proposed amount of development in the borough, where it is proposed to go, and when. The outcomes of the transport modelling would then inform the Transport Assessment of the Proposed Submission Local Plan. Following member briefings in early 2024, a Spatial Strategy was not able to be confirmed and therefore options are being considered.
9. When are these decisions on Local Plan content going to be made?
Once the evidence base is developed and complete, a recommendation will come to the Licensing and Planning Policy Committee (LPPC) on a Proposed Submission Local Plan that will include site allocations. This is expected to be in November 2024.
LPPC will then make a recommendation to Full Council who will then decide how it wishes to proceed with the Local Plan. It is only at this stage that a Full Council decision on the Local Plan will be made, and if it is agreed, it will go forward to another six-week public consultation.
10. What data and information has been used to inform the Local Plan preparation?
To support our Draft Local Plan consultation in January and February 2023 we undertook and published a wide range of evidence under topic themes, available to view here:
Evidence base | Epsom and Ewell Borough Council (epsom-ewell.gov.uk)
More evidence is currently being gathered and will be published on our website once complete.
11. 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 573 dwellings per year for the Borough. Recent changes to the NPPF have not resulted in any changes to the Standard Method itself, but have confirmed that the housing need figure it generates is an advisory starting point.
Our draft Local Plan that went out to public consultation proposed meeting only just over half of the boroughs housing need (52%) generated by the Standard Method over the Local Plan period (2022-2040).
12. 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 ours currently is in the draft Local Plan) will be tested extensively during the independent planning inspector’s examination of the Local Plan.
13. 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 (2022/23) a total of 317 new homes were delivered of which 67 were affordable homes. This is against a target of 575 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 £2m each year on emergency accommodation. Without additional affordable homes being delivered in the borough, this will continue to increase in the future.
14. 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. We have a range of brownfield sites that landowners have put forward as available for development which are all being considered in the next stage of the Local Plan, however there is not enough land available from brownfield and urban sites to meet the borough’s housing and economic needs.
15. 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. The Draft Local Plan proposed that both sites be “designated as Strategic Employment Sites, to be afforded the highest protection and safeguarding for Employment-Generating Uses.”
16. 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.
17. Can Green Belt land be developed?
The recent updates to the National Planning Policy Framework (NPPF) state 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:
- makes as much use as possible of suitable brownfield sites and underutilised land
- optimises the density of development in the urban area
- 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.
18. 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 are continuing to engage with infrastructure providers as we develop the Local Plan to ensure that proposals are supported by suitable infrastructure. It is normal practice for infrastructure delivery partners to engage in more depth at the later stages of the Local Plan process when further evidence and information is available for their consideration.
19. 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 government have committed to changes to the planning system through legislation, although further consultation is required and additional (secondary) legislation. To submit our Local Plan under the current system, we need to submit our plan to the government by the 30 June 2025. Any further pauses to the Local Plan, will mean that we will not meet this deadline and 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 work and adopting an up-to-date Local Plan, 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.
20. What further opportunities will there be for local residents to feed back?
The next public consultation on the Local Plan (Regulation 19) is expected to be in early 2025. If you would like to be kept updated when future consultations are taking place, please visit https://epsom-ewell.inconsult.uk/, enter your details via the 'Register' tab, and we will notify you when future consultations come forward.