OLRG Candidates - Tandridge District Council May elections

With the help of planning and legal experts, OLRG has taken part in all three of the Regulation 18 consultations that the Council has held on the Local Plan. Our expert opinion submissions can be read in the box at the top of this page.

We would like to say a huge thank you to everyone who has kindly donated money to pay for the experts' input. Thanks also to the hundreds of residents who have copied us their emails and letters to Tandridge Council expressing their views on the Plan which have been invaluable in making our response.

* OCTOBER 2017 (GARDEN VILLAGES CONSULTATION): Our response explains that the Council's Strategy is fundamentally misconceived and contrary to the National Planning Policy Framework (NPPF) because important sustainability factors and constraints that should have been taken into account have been ignored from the very start of the process. It does not reflect the distinctive characteristics of Tandridge or the needs and priorities of residents.

There has already been an exceptionally high amount of building in the District resulting in very large amounts of inward migration. This has not brought affordable housing for local people. The vast majority of the Council's housing need figure is for more inward migration from other areas that has nothing to do with meeting local housing need.

The Council has no track record of providing infrastructure and its 'Preferred Strategy' document makes clear that infrastructure can't be guaranteed going forward either. Although the Council recognises that there is an existing infrastructure deficit, the type and availability of existing services and infrastructure provision is understated. The very limited services and infrastructure in this predominantly rural District and the consequent reliance on other districts has not been addressed.

The proposals will exacerbate unsustainable travel patterns and reliance on the car with consequent negative impacts on the environment and on communities within and outside of Tandridge District.

The District is 94% Green Belt and yet the Green Belt has either been ignored or sidelined from the start. The process has not correctly interpreted the NPPF or Planning Practice Guidance with regards to the Green Belt. This incorrect interpretation has been repeatedly used in Council documents published with each of its three Regulation 18 consultations.

The Council's Strategy is unsustainable . Expert opinion has made clear that the evidence documents on which it is based are seriously flawed and not compliant with Government Policy.

The Preferred Strategy has never been publicly consulted on. Instead, it was simply agreed on by Conservatives and Liberal Democrat Councillors.

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* DECEMBER 2016 (SITES CONSULTATION): OLRG submitted its second expert opinion response which again makes clear the Council's proposals are not fit for purpose and do not form the basis for a sound Local Plan. It can be read on the second link in the box above or click here

In addition to comments on individual site assessments, the key points the experts have made are:

* The consultation is based on an inflated and unreliable objectively assessed housing need (OAN) figure.

* The Council's documents consistently misquote the definition of sustainable development set out in Paragraph 14 of the Government's National Planning Policy Framework (NPPF) which explains that the Green Belt is a policy that indicates development should be restricted. This omission was first identified in the Collective Representation submitted last February by OLRG, 11 Parish Councils, 7 other community groups and the Tandridge branch of the Campaign to Protect Rural England. The Council acknowledged this omission in its Consultation Response. Despite that, the Sites Consultation documents once again misquote the NPPF and this once again calls into question whether there is any priority being placed on protecting the Green Belt in the Local Plan.

* The Green Belt Assessment Part 2 is flawed and has not been carried out in line with Government policy. There is an imprecise and inaccurate analysis of the Green Belt purposes performed by specific areas of the Green Belt promoted for development. The assessments unjustifiably weaken protection for the Tandridge Green Belt.

* In assessing suitability, the Council's site assessments (that is the HELAA 2016, as with the HELAA 2015), do not meet the requirements of Government guidance and omit key evidence.

* The Consultation is being conducted in the absence of any strategic planning context for the District.

* The Council has not corrected its earlier Local Plan documents despite the flaws being pointed out to it in the Collective Representation. Until they are corrected, they should not form the basis for assessing site options or for the long term planning strategy for Tandridge District.

The Council's documents have provoked a storm of criticism from across Tandridge District for their poor quality, their misrepresentation of the District and the issues it faces, and their failure to give any information about how jobs or infrastructure would be provided to support the massive amount of new development proposed or to meet the existing infrastructure deficit caused by the massive amount of new development that has already taken place - for many years, Tandridge Council has been building roughly double its housing target.

This scale of building has already put intolerable and unsustainable pressure on infrastructure such as schools, health services, roads, rail services and parking which are struggling to cope with the existing demand. Other services, such as water, landfill and cemeteries are also at full capacity.

OLRG stood for election in 2016 because we were shocked by the poor quality of the Tandridge Local Plan documents which experts have made clear are seriously flawed, by the inadequate scrutiny of the planning officers' work, and by the inadequate and confusing public consultation.

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* FEBRUARY 2016 (ISSUES AND APPROACHES CONSULTATION): OLRG commissioned legal, planning and demographic experts to review the Council's documents. The result can be read on the third link in the box at the top of this page - see Collective Reg 18 Representation.

It is more than 90 pages of expert evidence. As well as OLRG, it is supported by 11 of Tandridge District's Parish Councils, 7 other community groups and the Tandridge branch of the Campaign to Protect Rural England.

It explains why the Council's work does not comply with national policy and unnecessarily puts our precious Green Belt, and our infrastructure, at serious risk.

It makes clear that the evidence base is flawed and contradictory, the housing need figure is inflated, and the Green Belt assessments have not been carried out properly. In short, the Local Plan documents are not fit for purpose for developing a sound Local Plan.

No account has been taken of the existing strains on infrastructure or of how it would cope with such a significant increase in population.

In its documents, the Council stated that it had written to all 10 surgeries in the District to ask for comments but received "no responses" and so had concluded "there is no indication of any specific requirements at this present time."

Oxted Health Centre then made clear it never received any letter from the Council's Planning Department. Therefore its views were not taken into account in preparing the Local Plan documents.

The Health Centre has now highlighted how stretched resources are, with more than 2,000 patients per full time partner. The Oxted Health Centre Patients Participation Group (PPG), which represents the 17,000 patients, has also now submitted a response to the Local Plan consultation which says health services in the area are under significant strain with the present population.

The Council's options (Delivery Strategies) are not compliant with national planning policy. Options 3-6 propose large amounts of building on the Green Belt as well as open spaces and recreation grounds. These options are based on an unreliable needs figure which includes unrealistic economic assumptions that are being used to justify extensive release of Green Belt for inherently unsustainable development.

Soon after submitting our representation, the Council insisted that the Local Plan is not flawed despite saying that it will take five months to consider the comments submitted to its consultation. This appears to make a mockery of the consultation process.

And in June 2016, Tandridge District Council told OLRG it does not think the expert opinion document "has identified any significant flaws in the process."

The Council's Chief Executive, Louise Round, said: "OLRG Regulation 18 response (incorrect reference to the Collective Regulation 18 response) - my position and that of the Council is that of course we would not want to proceed to examination of the local plan on the basis of a document which is fundamentally flawed which is why, given the complexity of the process, we have sought external advice where that is appropriate. That external advice has supported our approach."

As a result of that statement, we asked to see a copy of the external advice the Council had received to support its view on the expert opinion document. Ms Round then said there was none and that she had been using the words "external advice" that "has supported our approach" to refer to some of the original Local Plan work done by consultants many months before the expert opinion document was submitted...

And so the Council's view on the experts' work is based solely on the opinion of its own Planning Department...

* The fourth link in the box at the top of this page has a separate representation solely from OLRG, called OLRG Reg 18 Representation. It deals with the flaws in the settlement hierarchy assessment for Oxted, inadequate infrastructure assessment, procedural deficiencies, and the problems Tandridge residents have had with the consultation process.

There is widespread concern that the consultation was inadequately publicised and that the little publicity there was failed to make clear the contents of the Plan. The documents are opaque and confusing, at times misleading, with important facts buried in footnotes.

In particular, many residents are concerned about the Council's incorrect paraphrasing of the requirement to meet housing need which has misled some into thinking the housing need figure has to be met even if that means building on the Green Belt. That is not correct, Green Belt is specifically mentioned in national planning policy as a reason for not meeting a need figure.

The OLRG representation also includes a section on the Settlement Hierarchy document which persistently attempts to portray Tandridge's small settlements as larger and better resourced than they actually are. Efforts are made to equate them to large towns like Crawley, Redhill and East Grinstead. The larger and more sustainable they are made out to be, the more development will be directed towards them.

In another of the Council's Local Plan documents, Oxted, Limpsfield and Hurst Green are frequently erroneously described as an "urban conurbation." The definition of the word conurbation is 'an extended urban area, typically consisting of several towns merging with the suburbs of a central city.'

In another of the Council's Local Plan documents, Oxted, Limpsfield and Hurst Green are frequently erroneously described as an "urban conurbation." The definition of the word conurbation is 'an extended urban area, typically consisting of several towns merging with the suburbs of a central city.'