Epsom & Ewell Borough Council Draft Local Plan Consultation 2023
Frequently Asked Questions
- What is the Greenbelt and why should it be protected?
The Green Belt of land encircling London has protected by law since 1938 to keep urban sprawl in check, preventing towns from merging together and promoting the recycling of derelict land.
These purposes remain as important as they ever were, but now we know that retaining these areas is also critical in slowing and reducing the impacts of climate change, reducing flooding, reducing air pollution and providing essential habitats for wildlife.
- Isn’t it prohibited to build on Greenbelt Land?
Other than for very limited uses, Greenbelt Land is protected by law from development. It isn’t permitted to build housing on Greenbelt Land except in ‘Exceptional Circumstances’.
- Are there exceptional circumstances that require building on the Greenbelt now?
No. The Borough can continue to meet the historical trend of growth in housing need (225 homes / year) through development of Brownfield sites only.
Every year Epsom & Ewell Borough Council, as with all other Councils nationwide, have a housebuilding target. As with many other Councils, the target has not been met each year. Whilst it would be difficult (but not impossible) to meet a 576 house target each year, this is a normal situation both in Epsom & Ewell and across the country. It is not exceptional.
The Draft Local Plan states that this is exceptional to justify their plans to build on the Greenbelt.
- Is there any Greenbelt Land that it is OK to build on?
Some land in the Greenbelt has buildings on already, or has sites where buildings used to be. This is called ‘Previously Developed Land within the Green Belt’. Without considerable remedial work, this land doesn’t support much wildlife and is suitable for development.
- Were Clarendon Park, Livingstone Park, and Manor Park built in the Greenbelt, and if so, what’s different about these proposals?
All these estates were built on the sites of the old cluster of hospitals. These were on Previously Developed Land within the Greenbelt. We support development on such sites within the Greenbelt either for housing or to return them to nature by removing unnecessary structures.
- There’s an area of Greenbelt on the Local Plan map that isn’t on the Priority Development list of 9 sites, does this mean it is safe from development?
No. All sites bordered in green on the map have been put forward for potential development. If the Council includes any Greenbelt sites on the Priority list, all other Greenbelt sites are at risk of future development.
Any site may be included in a future iteration of the current Local Plan, could be included by the Planning Inspector in the course of their review of the current Local Plan, or could be included in future Local Plans.
- Does the Draft Local Plan meet the need to supply affordable housing for lower paid workers and the homeless?
No. Although the plan discusses building 40% ‘affordable housing’ on Greenbelt land and 30% on Brownfield land, this housing may not actually be affordable to those in need.
The definition of ‘Affordable Housing’ in the National Planning Policy Framework is houses sold at a 20% discount to their market value. In Epsom, the average property sold over the last 12 months was £630k, to an average property sold as ‘Affordable Housing’ would cost about £510k. This is well out of reach of most people in need of housing in the Borough.
The council’s proposed policy S7 on Affordable Housing also states that quarter of the Affordable Homes will be ‘First Homes’ with a discount of 30% to market value. Even for this small proportion (under 10%) of new homes, that still equates to £440k.
- Is it permissible to submit a Local Plan which doesn’t meet the full housing need calculated under the government’s ‘Standard Method’, and can it be approved?
Yes. Many other boroughs have done so or are planning to do so such as Mole Valley, Elmbridge, with Worthing Council recently got its Local Plan approved by Inspector with only meeting 25% of its target.
The National Planning Policy Framework specifically states that, with suitable justifications (such as protecting Greenbelt), the full housing target need not be met.
- I’ve been told that Mole Valley had their request to remove Greenbelt from their Local Plan rejected by the Planning Inspector, is this true, and if so how does it affect the Epsom & Ewell Local Plan?
Mole Valley is in the difficult position of having originally submitted a Local Plan to the planning Inspector which included developing Greenbelt. A number of Councillors were voted out of office as a result and the new Councillors are trying retrospectively to amend the submission. There appear to be significant hurdles to doing this.
Despite that, the Inspector has offered to pause the examination to give time for new Government legislation to be issued (see FAQ 10, below) which may support their case for a change to the submitted plan. It looks like Mole Valley has been offered a lifeline for their challenge.
The implications for Epsom & Ewell are:
a. It is better to exclude Greenbelt from the initial Local Plan submission to the Planning Inspector that to try to change the submission later.
b.The Planning Inspector recognises the likelihood that changes to the National PlanningPolicy Framework will strengthen the case for excluding Greenbelt from development.
There is no reason to push ahead with a flawed plan that destroys precious Greenbelt.
- I heard that the Government is going to abolish the mandatory housing target and no longer require Local Authorities to review Green Belt for housing. Is this true?
Yes, The National Planning Policy Framework specifically states that, with suitable justifications (such as protecting Greenbelt), the full housing target need not be met.
The government intends to implement many of its proposed policy changes by May 2023.
Emerging policies carry substantial weight in planning decisions, therefore at least 20 Councils have already withdrawn or paused their Local Plan processes, citing the upcoming policy changes.
It is EEBC’s choice as to whether they want to follow Central Government policy, or instead wants to continue pushing for large scale housing development on Green Belt land.
- The roads into Epsom are already overcrowded, particularly at peak times. What are the plans to address the additional traffic from all the new housing?
According to the 2011 census, there is an average of over 1.5 cars per household in Surrey. That equates to 2,300 new cars from proposed building on the Greenbelt Horton Farm alone.
There are no obvious ways to build new roads or expand existing ones.
No infrastructure plans have been put forward to show how this increased traffic will be managed. Expect long queues!
- It is difficult to get my child into primary school / secondary school as there aren’t enough places. If the proposed houses are built, will I still get a school place for my children?
Local primary and secondary schools are either full or near to capacity.
At this stage no plans have been put forward for building new schools or expanding existing ones. No land has been allocated for this either. There is no guarantee of a school place and no priority for existing residents.
- I see there are plans to build new sites for Gypsies / Travellers. How many will there be and where will these be located?
Regulations require Borough Councils to provide for the Traveller community. The Council has proposed putting 10 traveller sites on the Greenbelt Horton Farm site.
No explanation has been provided for why they are proposed to be located in a single area or on a Greenbelt site.
- Why is the housing target so high?
The short answer is that it doesn’t need to be.
Here’s some maths to show why…
The actual population growth of the Borough over the last 10 years has been 5,798, an average of 580 people/year (Source: Draft Local Plan para 1.39).
There are 2.58 people in an average household in the Borough (Source: Draft Local Plan para 1.39).
If growth continues at this rate, there would be a need for 225 new homes to be built each year.
The target included in the Draft Local Plan is for 576 new houses per year. This is based on a ‘Standard Method’ (Source: Housing and economic needs assessment – GOV.UK (www.gov.uk)) which uses a household growth projection from 2014 as a starting point.
The more up-to-date 2018 household growth projection is considerably lower than the 2014 projections, reflecting more recent real growth figures.
This is then increased by 40%, based on the current high cost of housing in the Borough, to give an even higher housebuilding target than the inflated 2014 based figure.
As a result, the quoted housing target is more than 2.5x the need based on the historic population growth in the Borough.
All of the Council’s assessment of required house building in the Local Plan is built from this inflated figure which is why they have struggled to find space for it all away from the Greenbelt.
- There seem to be lots of sites within Epsom’s urban area that are vacant, run down or underutilised, could these be developed for housing instead of the Greenbelt?
Yes.
Some of these sites have already been earmarked by the Council for development, but many haven’t.
The National Planning Policy Framework (which contains mandatory guidance for preparing the Local Plan) para 141 states that before concluding ‘exceptional circumstances’ exist for developing on Greenbelt, the strategy must:
a) make as much use as possible of suitable brownfield sites and underutilised land; and
b) optimise the density of development… including… a significant uplift in minimum density standards in town and city centres and other locations well served by public transport.’
There are lots of sites across Epsom town / urban areas which are not being put forward for use in the Local Plan or appear to be underutilised (for instance the Council’s proposals for the town hall site don’t meet the minimum density requirements they set in policy S3).
- Does the Borough have to build houses on Greenbelt Land to meet the housing target?
No. In fact it is only permitted to build on Greenbelt in ‘Exceptional Circumstances’.
The National Planning Policy Framework specifically states that housing targets need not be met if it would require building on the Greenbelt (para 11 note 7).
- Part of the Horton Farm site appears to be on the Horton Cemetery. Isn’t this protected?
Horton Cemetery is where deceased residents of the Epsom Hospital Cluster were buried. Home – Friends of Horton Cemetery
This strip of land is excluded from, but directly adjacent to, the proposed development of Horton Farm. There are no plans to build on the cemetery, although without further protection it is at risk of being an unofficial recreation ground for the new estate.
- The Ashley Centre Local Plan display states that development will be ‘Located away from areas of flood risk’. How has Horton Farm been selected for development as it regularly gets flooded?
‘Horton’ roughly translates from Old English to ‘muddy farm’. Both the Environment Agency flood maps and Epsom & Ewell Borough Council’s own 2018 Flood Risk Assessment show that Horton Farm is at high risk of flooding from surface water (because there is clay just below the surface) and in practice it is often flooded. A ‘Critical Drainage Area’ runs through the site.
The Draft Local Plan appears to ignore the flood risk assessment and only considers flooding from rivers.
If the Greenbelt Horton Farm is built on, there is a significant risk that it will result in increased flooding into West Ewell and Ewell Court.
Source: Epsom & Ewell Borough Council Strategic Flood Risk Assessment 2018, Figure 108. Brown areas are in the highest category of flood risk.
- The Council has stated that it is ‘only’ proposing to build on 3.6% of the Greenbelt, is this correct?
The council has not provided a calculation of this number. The Greenbelt sites they have prioritised for development in the Draft Local Plan total 57 ha (the total area is 66 ha, but some is to be used for playing fields). This is the equivalent of 140 football pitches.
3.6% is a misleading figure. Large parts of the Greenbelt can’t be built on because:
– they already contain housing estates. e.g. Clarendon, Livingstone, Manor, Noble Parks, etc.
– they contain existing businesses such as David Lloyd Leisure, the Epsom Racecourse, etc.
– they contain critical infrastructure such as roads, pavements, etc. which can’t have houses on.
– they contain Local Nature Reserves or Sites of Special Scientific Interest (like Horton Country Park and Epsom Common).
– they contain cemeteries.
Once these areas are excluded, the 57 hectares of Greenbelt proposed to be developed is around 7% of the remaining available Greenbelt land, over a period of only 15 years. This is an alarming rate!
NO Greenbelt needs to be built on. None should be built on.
- I’m told the Council has spent £1m on preparing this plan. Would it be expensive to change direction now?
The money that has been spent is largely on reports that were required to be prepared whatever direction the plan went in.
The earlier changes are made to protect the Greenbelt, the cheaper it is to make those changes.
- How will developing the Greenbelt land affect wildlife?
The Greenbelt land is a vital habitat, providing food and shelter for hundreds of species of mammals, birds, amphibians and insects as well as native trees and flowers.
As an example, Horton Farm supports roe deer, bats, greater spotted and green woodpeckers, sparrowhawks, house sparrows, stag beetles, song thrushes, hedgehogs, common toads, and other priority species.
Once built on, the Greenbelt land is effectively permanently lost to nature.
- How can I help stop the destruction of the precious Greenbelt?
a. Spread the word. Tell your friends, colleagues, club mates and relatives about the Draft Local Plan and let them know the greenbelt is under threat.
b. Lobby your local councillors. There are local elections coming up in May 2023; let your councillors know that saving the greenbelt is key and ask them to commit to doing so if they want your vote. You can find your local councillors here:
Epsom and Ewell Democracy (epsom-ewell.gov.uk)
c. Sign the petition to save the green belt:
Petition · Keep Epsom and Ewell Green Belt! · Change.org
d. Respond to the consultation (see FAQ 20)
- How do I object to the plans to build on Greenbelt?
There is a 50 question on-line questionnaire:
Or respond by e-mail to localplan@epsom-ewell.gov.uk
The questions that most directly impact the greenbelt are:
8. Do you support Policy S4 “Development in the Green Belt”?
15. Do you support Site Allocation (SA) 6, Horton Farm?
16. Do you support Site Allocation (SA) 7, Land at Chantilly Way?
17. Do you support Site Allocation (SA) 8, Land adjoining Ewell East Station?
18. Do you support Site Allocation (SA) 9, Hook Road Arena?
There are many other relevant questions such as 36 on landscape character, 37 on biodiversity, 38 on trees, woodlands and hedgerows, 39 on flood risk, etc. so do consider the rest of the questionnaire too if you have time.
Useful links
Standard method for housing need: Housing and economic needs assessment – GOV.UK (www.gov.uk)
List of Councillors by Ward: Epsom and Ewell Democracy (epsom-ewell.gov.uk)
Epsom population data: Epsom and Ewell Demographics | Age, Ethnicity, Religion, Wellbeing (varbes.com)
Draft Local Plan transport analysis: Epsom and Ewell Local Plan (arcgis.com)
Epsom wards: New political map for Epsom & Ewell Borough Council | Epsom and Ewell Borough Council (epsom-ewell.gov.uk)
Epsom Ward map for May 2023: contractMapping
Epsom Council maps: Epsom and Ewell Borough Council | (epsom-ewell.gov.uk)
Becoming a councillor: How we make decisions (epsom-ewell.gov.uk)
Affordable housing: can you buy below market value? – Which?
Local Plan potential development sites: iShare Spotlight Focus (astuntechnology.com)
Keep Epsom & Ewell Green Belt 
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