In response to the new NPPF being released in December, many councils such as below are racing against deadline and working tirelessly to submit their local plans before the new regulation kicks in: https://www.stalbans.gov.uk/news/council-speeds-its-local-plan-process

EEBC can submit the Local Plan just before the deadline, if officers work hard and councilors call an extraordinary Council Meeting ASAP to start Regulation 19 Consultation.

Sadly and frustratingly, councilors, led by Chair of Licensing Planning & Policy committee, Peter O’donovan are gambling on the fate of future of EEBC by doing nothing. Peter claims that he does not believe government will release the NPPF on time, and he also did not feel residents care about the issue.

Therefore, if you care about Epsom’s future, if you don’t want the council to waste multi-million pound to rewrite a new Local Plan with 817/yr of housing requirement, please write to the councilors ASAP. It’s best if you could address them separately. 

Please find below some clear facts which can be used for your email response.
 
1. Cost
According to the official minutes of the LPPC meetings, the increase in the Local Plan budget authorised in March 2021 and November 2023 totalled £1.371m. This was in addition to the original budget, the figure for which has not yet been provided, despite a Freedom of Information (‘FoI’) request to find out. The total budget must, therefore be well over £2m, but we can only speculate how much.
 
Of the £1.371m increase, £741,583 was reallocated from a Government ‘New Homes Bonus Grant’. The Government guidance for these grants is that the money should be spent ‘in line with local community wishes’.
‘The Government expects local councillors to work closely with their communities – and in particular the neighbourhoods most affected by housing growth – to understand their priorities for investment and to communicate how the money will be spent and the benefits it will bring. This may relate specifically to the new development or more widely to the local community. For example, they may wish to offer council tax discounts to local residents, support frontline services like bin collections, or improve local facilities like playgrounds and parks. This will enable local councillors to lead a more mature debate with local people about the benefits of growth, not just the costs.’
According to the FoI response on this topic, there is no record of any consultation with local communities before allocating the funds to developing the Local Plan… which 87% of residents who replied to the consultation are not in favour of.
 
2. New Target
If the Local Plan is not submitted in time (according to the draft Labour NPPF, this means within 1 month of the publication of the NPPF, scheduled for December 2024), so by early Jan 2025, the new targets, for 817 dwellings per annum (dpa) will become mandatory. The Local Plan consulted on in Jan 2023 only included 300 dpa (which is already significantly higher than the 181 dpa in the Core Strategy 2007), so a significant re-write would be required to meet a 817dpa target.
 
3. Fast track Timeline
It is obligatory, under Regulation 19 of The Town and Country Planning (Local Planning) (England) Regulations 2012, to consult on the updated Local Plan proposals. Under Government guidelines, the consultation must last a minimum of 6 weeks. The earlier this starts, the earlier it will be completed. It is currently scheduled to start not directly after the full council on 10 Dec, but a month later in mid-January 2025.
 
Cllr O’Donovan says that he has worked with officers ‘to try and find a way to bring the consultation forward but this is not feasible’.
The only information about this unfeasibility appears to be contained in an Epsom & Ewell Times newspaper article which states:
‘The LPPC will debate the Local Plan and make a recommendation to full Council, who will make the final decision on how it wishes to proceed with the Local Plan. This process is required by our constitution.’
It is not clear where, in the constitution, it sets out this process. It appears reasonable that the Full Council would need to approve the Local Plan before it is issued for examination, and that (possibly a subset of) councillors should review the Local Plan before if is issued for consultation. Any authority delegated to the LPPC can be withdrawn in order to skip this first step of the LPPC debate, currently scheduled for 20 November. Skipping this step would cut 3 weeks from the timetable. It would also be technically possible to bring the 20 November date forward to enable earlier approval.
It is also notable that St Albans council started their Local Plan consultation in advance of full council approval in order to shorten the overall project timetable. It may be that this council could do the same if they were motivated to do so.
Many of the evidence documents have already been completed, but have not been published. Publishing supporting documentation early allows councillors (and interested residents) to review it well in advance of any approval meetings. No steps have been taken to date to publish any evidence.

In summary, there appear to be multiple ways in which the timeframe could be abbreviated to facilitate submission of the Local Plan to examination in Jan 2025, if councillors and officers wanted to maximise the possibility of avoiding (or delaying) the new targets.
 
4. With respect to the planning officers, at least 2 of the staff involved in preparing the Local Plan are contractors, as set out in the minutes of the LPPC meetings (a significant part of the budget increases was to cover extending their contracts; some figures for this are available in the minutes). Spending years developing a Local Plan and then further months rewriting it is unlikely to be the best use of their time, for which we pay their salaries.
 
5. Based on the Regulation 18 Local Plan’s housing density of 40 dwellings per hectare on greenfield sites, the 817 dpa target would require 20.5 hectares of Green Belt to be built on every year. For context, that is the size of 50 football pitches every year. The council issued a letter to Angela Rayner expressing the view that this would be destructive to the borough, so it would seem reasonable to expect them to pursue every avenue, and take every opportunity, to avoid this destruction. At the moment they have only written a letter to Ms Rayner and submitted a response to the Government’s NPPF consultation. Individual residents have done as much; we would expect our council to do more.
 
In the Epsom & Ewell Times, Cllr O’Donovan also stated ‘We understand that a significant number of responses have been submitted to [the NPPF] consultation and that there may be delays in the revised NPPF being published by the government.’
A large number of responses were indeed submitted to the consultation, however Matthew Pennycook has subsequently stated that this should not affect the timeframe for publishing the final NPPF in December 2024.

The new government has committed to building 1.5m new homes in this parliament and any significant changes to the NPPF proposals would put this is jeopardy.
As the current Local Plan timetable does not have the Local Plan being submitted until May 2025, the government’s NPPF publication would need to be delayed by at least 4 months for the council’s strategy to work. This is highly unlikely.
The council, and Cllr O’Donovan, should not be betting the future of the borough on a hope that the NPPF publication is delayed by over 4 months, or that what is published significantly differs from what was consulted on.
 
The council has already wasted 3.5 months since the NPPF consultation was launched, only they are responsible for this; other councils have taken steps to mitigate the risk whereas ours appears to have done nothing.
 
Mailing List as below:

Cllr Peter O’donovan: po’donovan@epsom-ewell.gov.uk

Other Councillors: