appendix 1. comments received from arup on reg …...land at howards lane 1. the comment requests...

Appendix 1. Comments received from Arup on Reg 18 consultation responses

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Rep No

Representor (& Agent)

Site Arup Summary Arup response Recommendation

44 Dr Jane Tilley Ottershaw East 1.Objection to the land known as Ottershaw East being released from the Green Belt, with concerns that this will result in encroachment of Ottershaw and Addlestone 2. The comment highlights concerns with the proposed allocation in respect of how this will alter the character of Ottershaw, the poor access to the site and poor road infrastructure and a lack of strategy as to how development will be sustainable. 3. Suggests that the western part of GA41 is considered for housing development, particularly a parcel of land "that faces the Otter roundabout and the heart of the village which would give us a great opportunity to improve the economic heart of the village and provide housing." This site would be more suitable as "this area directly bounds Guildford Road as it joins St Peters Way. Developing this site would allow road widening to improve traffic flow onto St Peters Way and eventually onto the M25." Further the Otter roundabout and shops on Brox Road formed the

1. The GBR identified that land at Ottershaw East be considered for release from the Green Belt. This was a recommendation to inform the preparation of the Local Plan. In terms of defining permanent boundaries for this Resultant Land Parcel, the GBR identified broad areas for further consideration in line with the scope identified by RBC. 2. The comment refers to matters of access, character and sustainability which were not relevant to the GBR. 3&4. The findings of the GBR in respect of GA28 and 41 are considered to remain appropriate. The difference between the scores for GA41 and 28 is as a result of the varying performance across them. These areas vary in scale, and while in our professional view GA41 as a whole forms a strategically important gap between settlements, parts of GA28 play a less crucial role and thus a score of 3 is attributed to the wider parcel. This assessment is in line with the published methodology. With regard to the suitability of the area in terms of economic development, this is not a matter of relevance to the GBR.

No change to the GBR


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original heart of the village so GA41 would even out development around the village centre. 4. The comment compares the scores attributed to GA28 and GA41 in the GBR, suggesting that: ‐ GA41 over scores particularly for Purpose 3 given it is bounded by the M25 and major A roads so although it is not built up, it provides no amenity for the community whereas GA28 is already used for amenity as it contains footpaths and is used by local people for leisure. ‐ GA28 has many technical constraints and non‐absolute constraints compared to GA41. 5. The comment references para 84 of the NPPF in respect of altering Green Belt boundaries as a part of the Local Plan and having been assessed against sustainability issues; and noting that the LPA should define Green Belt "boundaries using physical features that are likely to be permanent and boundaries that will not need to be altered at the end of the planning period. Ottershaw East does not clearly satisfy these principles. There

5. Noted


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is not a clear physical boundary on the identified parcel and so the boundaries may need to be altered during the period of the local plan."

69 Mr & Mrs Holdaway

Land at Howards Lane

1. The comment requests that the site be reconsidered, noting it has approximately 100ft of road front access along Howards Lane, is approximately 1.2 hectares, so suitable for more than the 10 dwellings and effectively an infill site. Reference is also made to proximity to services and facilities required to support housing development. 2. The comment is made that the "Green Belt Review does not consider in any detail concerns regarding sustainability."

1. The reference to putting the site through to Stage 4 appears to be a reference to the preparation of the Local Plan, rather than to the GBR. This area was not considered suitable for release from the Green Belt for the reasons set out in the report. It is noted that the Green Belt boundary is Howards Lane, with land to the west in the Green Belt. If this site were identified for development and released from the Green Belt it could set precedent for removal of further land in this area from the Green Belt, unless a defensible boundary (consistent with the NPPF) can be identified. However, assessing smaller parcels of land is something the Council is currently working towards. The proximity to amenities and services was not a factor for the GBR, as detailed in its methodology. 2. This is a matter that was addressed by RBC in its preparation of the Issues, Options and Preferred Options, in line



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with the requirements of the NPPF. 194 HT Mason Ltd

(Grant Consultancy)

Clockhouse Lane East

1. "If an appropriate assessment is made in respect of the site...then it would have been identified as performing little Green Belt function and the settlement boundary would be adjusted to incorporate it into the urban area in a similar way to Land West of Thorpe Lea Road (site 257)." 2. "At the time of the assessment the Council would have been unaware of the site....If a review were to be carried out in respect of this site, then a similar conclusion would undoubtedly have been made and that it also would be seen to perform little or no Green Belt function...The site comprises unsightly and sizeable built development that comprises previously developed land in residential and industrial/business uses...The site was not known about at the time of the SLAA publication in December 2015." 3. The representation includes a SA assessment which concludes that the site at Clockhouse Lane East should be identified as part of the settlement area and allocated as a housing site

1&2. The comments promote this site for development and removal from the Green Belt, noting that it was not included in the RBC SLAA or Site Selection Assessment. The land that is subject of the representation was not considered as a Resultant Land Parcel, as it was subject to significant non‐absolute constraints, as summarised in Table 7.1 and Annex 3 of the GBR. However, assessing smaller parcels of land is something the Council is currently working towards. 3. This is a matter that was addressed by RBC in its preparation of the Issues, Options and Preferred Options, in line with the requirements of the NPPF.



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with a capacity of approximately 25 units.

195 HT Mason Ltd (Grant Consultancy)

Land at Thorpe Lea Road

The comments relate to promotion of Option SS5 rather than SS3, as set out in the Issues, Options and Preferred Options, noting that "The approach adopted in SS3 seeks to deliver between 302‐383 dpa through urban sites, previously developed sites in the Green Belt, returning the village of Thorpe to settlement and releasing land in the Green Belt is, we believe, a too cautious approach to meet the pressing needs for housing within the Borough." Instead "...Option SS5 should be adopted which allows for greater flexibility and will be able to address the inevitable 'non‐delivery' of sites identified in the SS3 approach." A sustainability appraisal of the proposed site is included.

The representation promotes release of the site for housing development. There is limited reference to the GBR, which did not identify this area for consideration for release from the Green Belt, given it was subject to a number of non‐absolute constraints including flood zone 3a, Grades 1 and 2 agricultural land and open space (see Table 7.1 of the GBR). However, assessing smaller parcels of land is something the Council is currently working towards.


201 Richard Fleming Ottershaw East 1. The representation raises concern that there are serious gaps in the argument for removing Ottershaw East from the Green Belt. 2. The representation disagrees with the result for a proposal for some 500 houses, with no thought for facilities such as access, public transport, shops, capacity of schools and medical

1. Appendix 4 of the Issues, Options and Preferred Strategy document identifies Ottershaw East as an area for Green Belt release. It is unclear from the representation whether the GBR findings are being questioned or the Issues, Options and Preferred Strategy. The comment refers to matters of access, provision of shops and medical facilities,



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facilities. school capacity and accessibility to public transport which were not relevant to the GBR. 2. The GBR outlines that the purpose of the review was to "Identify broad areas, which could potentially be removed from the Green Belt to provide locations for residential or employment use, including sites for Gypsies, Travellers and Travelling Showpeople" (section 1.1.2). This information was to be used by RBC in its Site Selection Assessment which assessed all proposed sites against a range of criteria, including Green Belt, to assess their suitability for development. It was not the purpose of the GBR to consider the form and scale of development that might be accommodated.

222 Jeremy Bailes No specific site associated with response.

1.The representation states that the approach to the GBR is flawed as it "is obviously majority desktop‐based and uses a points‐based system which is a quantitative method of assessment, therefore does not include qualitative assessment based on expert local opinion." 2. GA28 should not be recommended

1. The methodology used in the GBR was developed in line with the NPPF and in discussion RBC, and corroborated through Duty to Cooperate commitments, and therefore represents a robust strategy for the assessment of Green Belt parcels. The methodology included site visits and as a consequence of this, the inclusion of qualitative data when formulating the scores for each



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for release, as this "would pose a large threat to the merging of settlements and represent a failure to consider the Franklands development nearby and its impact on the local environment and amenities/infrastructure."

parcel. It should be noted that the methodology does not aggregate scores in order to rank sites. 2. Parts of GA28 were identified for consideration for release from the Green Belt, as a part of a wider consideration of the appropriate strategy for Runnymede, set out in the Options, Issues and Preferred Options. The Franklands development is addressed in Section 8 of the GBR (see Annex 4), where it is identified as an area that does not warrant change (e.g. inclusion in the Green Belt); it was also taken into consideration in reviewing Resultant Land Parcels.

253 A2 Dominion Developments Ltd (Boyer)

Brox End Nursery Ottershaw

1. “Given the overarching Borough‐wide scale of the Arup Green Belt Review, there is a possibility that there may be smaller sites within the Green Belt, that do not fall within any of the identified RLPs, that may be potentially suitable for Green Belt release and allocation, in order to further boost the supply of housing without having a detrimental effect on the integrity of the wider Green Belt. The Council may therefore wish to consider undertaking a focussed Green Belt review of any Green Belt

1. The comment is a general observation on the approach adopted in the GBR with a suggestion that consideration be given to looking at smaller sites to contribute to meeting OAN. Assessing smaller parcels of land is something the Council is currently working towards. 2. Noted



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sites assessed with the SLAA, and which do not fall within any of the identified RLPs, against Green Belt purposes to ensure that 'every effort' is made to seek to meet the OAN and to minimise any residual unmet need (NPPF para 17)" 2. The comments support the identification of the site at Brox End Nursery, Ottershaw as a preferred site for housing, and includes a Sustainability Appraisal of the site.

272 Mrs K Taee (Stiles Harold Williams)

Land adjoining Dial House, Northcroft Road, Englefield Green, TW20 0DU

1."It is considered the Resultant Land Parcels that are proposed for release are insufficient to meet housing demand. Instead, the Council is recommended to re‐examine a number of sites from the Green Belt Review (2014) and to see potential in previously dismissed smaller sites that can accommodate a number of dwellings." "The site was not recommended for release as part of this review, however this cannot be justified as the scale of the study was not small enough to evaluate particular sites, only general areas. As a result of this, the obvious unsuitability of a large quota of Green

As stated in the representation the GBR was based on assessment of GAs, with a refinement approach to identify potential sites for consideration for release from the Green Belt. Therefore the findings of the GBR remain valid. However, assessing smaller parcels of land is something the Council is currently working towards.



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Belt land has led to the dismissal of the site west of Englefield Green..." 2. The representation sets out that the site should be re‐considered as it falls to the west of Englefield Green, bordering onto the built‐up area off Northcroft Road to the east and south. It continues to state that the site is approximately a mile from Egham Station and a bus stop connecting Egham and Heathrow Airport is some 50 metres away.

302 Susan Robinson 2 Kitsmead Lane, Longcross South Village

"It was our understanding that one of the resultant land parcels for removal from Green Belt policy was the area of the proposed Longcross South Village ‐ i.e. the defined boundary of bounded by eastern Kitsmead Lane, northern Longcross Road and Chobham Lane including the former DERA Site and all other houses within the area. We were very surprised, therefore, that it appears that the only 2 properties in this entire area which are not included in the proposed removal from Green Belt are numbers 1 and 2 Kitsmead Lane...Request that our property, 2 Kitsmead Lane, is included in the proposal to remove the area from

From satellite imagery, it has been established that the subject site is located on the eastern side of the eastern branch of Kitsmead Lane. Therefore, the site is located within an area with significant non‐absolute constraints and was not assessed further in terms of the value of the land in currently or potentially meeting the NPPF purposes of the Green Belt. As such, 2 Kitsmead Lane was not included in the Resultant Land Parcel, noting that Kitsmead Lane is a defensible boundary. However, it is acknowledged that the exclusion of these properties would appear to create an anomaly and will be considered as part of further updates to



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Green Belt Policy." the Council's Green Belt Boundary Technical Review.

395 Ottershaw Properties Ltd (Roger Hayes)

Land to the rear of 232 Brox Road, Ottershaw

The comment promotes the site to the rear of 232 Brox Road for release from the Green Belt so it can be considered for residential development. Reference is made to a number of factors include that the site is "securely bordered on all sides by mature trees and hedgerows with a five‐bar gate access across a strip of Surrey CC land to Guildford Road. The site has been cleared of dense and overgrown vegetation. In the past the site had been paddock land for the grazing and exercise of horses with a substantial barn/stable building in the centre of the site supplied with power and water. That building is now derelict."

The area referenced in the representation has not been identified for consideration for release from the Green Belt. Furthermore, the factors cited by the representation to justify its suitability for release from the Green Belt do not relate to the approach taken by the GBR.


509 Mr M May (Charles Maunders Consulting Ltd)

Lyne Hill Nursery 1."We propose that (the) site…(should) be considered as an alternative or in addition and be included in the forthcoming housing allocations as it can make a significant contribution to the housing supply and is available immediately." 2.“It is clearly brownfield land as more than 2 thirds of the site is covered with

1.Noted 2.Noted



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buildings/ structures and hardstanding."

520 Ashill Group Ltd (CBRE)

Land at Foxhills Road, Ottershaw

1."A concept plan has been drawn up which illustrates a development of c.500 dwellings and significant community infrastructure including two form entry primary school, community sports hub, a new emergency 'blue light' facility, doctors surgery and elderly care accommodation, a new SANG..., publicly accessible open space including new allotments, mixed use centre with potential for a range of uses." 2. "The site performs very well against accessibility and constraints criteria and the release of the site will not compromise Green Belt purposes." 3."Given the overall performance of the site its contribution towards delivery of housing need and delivery of significant community infrastructure is considered to outweigh Green Belt protection." "We do not support the Council's preferred spatial strategy, as the Green Belt Review has not successfully

1. Noted 2‐4 The GBR sets out the reasons for the conclusions on GA26, noting that the area was identified as a FRGA, (recognising the limited non‐absolute constraints in this area), but not as a resultant land parcel. However, consistent with the findings of Stage 1 it was concluded that if this area were considered for release then this could negatively impact the gap between Ottershaw and Chertsey which would be detrimental to the purpose of the Green Belt in this location. In particular the reference to scope for some development is addressed in Annex 4, which acknowledges that this could be compromised by the soft boundary features on western edges of both sites. While acknowledging that the promoter has completed its own Green Belt Assessment, this is not directly comparable to the GBR as it relates to the Fox Hills site only. However, assessing smaller parcels of land is something the Council is currently



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identified all the sites which have a limited contribution to Green Belt purposes." "We believe that Runnymede should review their Green Belt Study and ensure that the release of poor quality Green Belt is maximised first before turning to other authorities to accommodate unmet need." "The Green Belt Review recommended that the whole area in GA26 is retained in the Green Belt. It is unclear how the authors of the Review came to this conclusion after stating in Phase 1 that there may be scope for some development in this area and that the presence of strong boundaries (A320, B386 and Stonehill Road) could protect the surrounding Green Belt from urban sprawl; however, the authors of the Review then go on to contradict themselves saying that there are no permanent durable features." 4. The representation includes work undertaken by Landscape Visual in the form of a Green Belt Assessment of the site using the Council's

working towards.


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methodology. "The appraisal found that the site's contribution to the Green Belt purposes of checking unrestricted sprawl of large built up areas is negligible. Furthermore, the presence of existing, durable boundaries along the south‐east, north‐west and south‐west boundaries could be combined with the creation of a durable boundary along the north‐east edge of any development within the site to prevent unrestricted sprawl in the future. In addition, the study demonstrated that whilst the site contributes physically to the essential gap between Ottershaw and Chertsey Bittams, the urban fringe character of this gap compromises its efficacy in preventing the perceived merger between neighbouring settlements. It also concludes that whilst the site has a more rural character to the north‐west, its character is more influenced by the urban fringe to the southeast. This is considered to reduce the site's contribution to the Green Belt purpose of safeguarding the countryside from encroachment. Overall, the site has a limited contribution towards Green


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Belt purposes and is therefore suitable for well‐considered residential led development."

521 Orbit Developments (Southern) Limited (The Emerson Group)

Blays House and Inbucon House in Englefield Green

1. "The Council should not be relying on neighbouring authorities to deliver its own OAN. Therefore, the Council should be pursuing Option SS6 or SS7 by undertaking further Green Belt release to deliver 100% OAN for Runnymede." 2. "...The Council concluded in the Final Interim SLAA, June 2016 (ID 156) that the conversion of the existing buildings to apartments and new build development within the grounds could yield 80 new dwellings, subject to being in accordance with NPPF 89, bullet point six (i.e. national Green Belt policy). However, the Council's proposed approach towards this site in the Local Plan contradicts the SLAA's conclusion. The Local Plan proposes not only to maintain the site within the Green Belt, but also to expand the Green Belt boundaries further to incorporate a small section of the site's access road and the east wing of Inbucon House, as recommended by the Green belt Boundary Technical Review, July 2017

The comments submitted by the promoter appear to more directly relate to the Green Belt Boundary Technical Review (July 2016), rather than the GBR. As such, no change is proposed to the GBR. However, assessing smaller parcels of land is something the Council is currently working towards



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(Tile 36 and 46). Orbit strongly object this position" 3. "The site is previously developed, in a sustainable location on the edge of the urban area, surrounded by robust boundaries and adjacent to an allocated site currently being developed for housing by CALA Homes ('Virginia Gate'). Despite the current Green Belt designation, the conversion of the office buildings to residential use could occur under permitted development rights. The Council have also recognised through its SLAA that, in principle, new build development within the grounds may not have a greater impact on the openness of the Green Belt and the purposes of including land within it when compared to the existing...The Council should be looking to strengthen its Green Belt boundaries to ensure their permanence here by redefining the site as part of the urban area and allocate it for new housing."

529 Berkeley Strategic Land

Crockford Bridge Farm, Addlestone

1. To summarise, the representation sets out that the Green Belt Review considered larger areas and identified RLPs but did not consider the sustainability credentials of particular

The assessment against non‐absolute constraints found that the site is in Flood Zone 3a and open spaces, which were judged to make it least preferential for development. Further when assessed



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sites within these parcels or the suitability of these sites compared to sites located within other large areas. The representation comments that a generalised appraisal of strategic areas provides too broad a basis to understand the key factors and characteristics of smaller parcels within the Green Belt. "For example, the Land at Crockford Bridge Farm, which is located within Area 30, has high sustainability credentials." 2. “According to the Draft Site Selection Methodology and Assessment, the Land at Crockford Bridge Farm is not taken forward to Stage 6 due to the scores it received in the Green Belt Review against Purposes 1 and 2. However, there is land within Area 30 which does not fulfil these two purposes and should be identified as a RLP." 3. The representation contends that the release of the site would not undermine the five purposes of the Green Belt, as follows: Purpose 1 ‐ To check the unrestricted sprawl of large built‐up areas: Urban sprawl in this area is primarily

against the NPPF purposes it was found to perform strongly in protecting land contiguous with or within close proximity to a large built up area (Purpose 1a) and preventing the erosion of a gap in the Green Belt (Purpose 2). The representation has not submitted any evidence that these factors are incorrect, but instead relies on the scale of the GBR being too broad. . However, assessing smaller parcels of land is something the Council is currently working towards


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contained by the New Haw Road to the West of the site, the River Bourne to the North, the River Wey to the South and existing residential development to the East. These features restrict urban sprawl and none of these features would be affected by the development of this site. The site does not therefore significantly fulfil this purpose. The development of this site will provide an opportunity to create a long‐term defensible Green Belt boundary. Purpose 2 ‐ To prevent neighbouring towns merging into one another: The River Bourne is the only point of separation between the existing dwellings located to the West of the New Haw Road and Addlestone. The River Bourne, and the area of Flood Zone 3 to the south of the River, therefore fulfils this purpose by preventing New Haw from merging with Addlestone. New development on the site would not be located within Flood Zone 3 and therefore would not increase the risk of New Haw merging with Addlestone. The developable area of the site should therefore be reassessed against this purpose.


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Purpose 3 ‐ To assist in safeguarding the countryside from encroachment: The site is bounded on all sides by urbanising features such as the New Haw Road to the west, existing dwellings to the north and to the east and Crockford Bridge Farm Shop to the south. The site does not have any characteristics of open countryside and does not reflect traditional open landscape. Purpose 4 ‐ To preserve the setting and special character of historic town: No historic towns or conservation areas within close proximity of the site. Purpose 5 ‐ To assist in urban regeneration, by encouraging the recycling of derelict and other urban land: Insufficient supply of brownfield land and further releases of Green Belt land are necessary to fulfil housing requirements.

533 IQ Planning Consultants on behalf of The Chalet, Callow Hill, Virginia Water

The Chalet, Callow Hill, Virginia Water, GU25 4LD

In summary, the representation sets out that the Chalet site would be appropriate for removal from the Green Belt as it performs generally poorly against the five purposes of the Green Belt. The representation provides an assessment of the site against each of the purposes, and

The promoters own assessment against the NPPF purposes ascribes a score of 0 to Purpose 1a, recognising that the site "is not contiguous with or connected to the built up area". This broadly concurs with the assessment in Phase 1 of the GBR for GA8. GA8, within which the subject site is located, scored a 1 for


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scored as far as possible, in accordance with criteria set out in the Arup Green Belt Review Methodology and Assessment (notwithstanding this is an individual land parcel as compared to the Council's strategic review of wider Green Belt). The results of this assessment are set out below: Purpose 1 ‐ To check the unrestricted sprawl of large built‐up areas: The site, whilst close to the urban area to the east, is not contiguous with or connected to the built up area, due to the presence of Callow Hill Road, which also falls within the Green Belt. Score: 0. However, the site does provide an additional barrier for the built‐up area, which is bordered by the permanent and durable boundary of Callow Hill. Score: 1. Total score: 1/10 (Weak). Purpose 2 ‐ To prevent neighbouring towns from merging: The site lies in the less essential strategic gap between Egham and Virginia Water. Whilst the site is situated close to the urban area of Virginia Water, it would be situated approximately 1.4km from the closest southern urban boundary of Englefield Green/ Egham. In fact,

Purpose 1a due to its proximity to Englefield Green/Egham. No evidence is provided which changes the conclusions of the GBR. As has been noted before, the Arup GBR considers wider parcels of land as General Areas which may not be directly comparable to an individual site. However, assessing smaller parcels of land is something the Council is currently working towards


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the recommended RLP on Hollow Lane is situated closer to the Egham urban boundary. As part of a wider and less essential gap between settlements, a well‐defined area of release such as this site, is not considered to materially compromise the ability of the Green Belt to meet its purpose. Score: 1/5 (very weak) Purpose 3 ‐ To assist in safeguarding the countryside from encroachment: The site itself contains less than 10% built form. However, it is important to note that a highly significant proportion of boundaries of the site are defined by strong features which would prevent physical and/or visual encroachment into the wider Green Belt.... Score: 3/5 (moderate). Purpose 4 ‐ To preserve the setting and special character of historic towns: ...It is also considered that any development proposals at the site would not materially impact on the setting of this heritage asset. Purpose 5 ‐ To assist in urban regeneration, by encouraging the recycling of derelict and other urban land:... the release of this site would not directly or indirectly divert interest away from urban


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regeneration opportunities or compromise their viability.

555 Traylen Enterprises Ltd (WYG)

Multiple sites in question

1. The representation states that Runnymede must review Green Belt boundaries on a more comprehensive scale in order to ensure that OAN is being met in full in the plan period. 2. "All of the...sites have been considered by the LPA in the SLAA and rejected as being unsuitable for development in the local plan period. However, it is considered that these assessments need to be reconsidered…"

The representation promotes release of the sites for housing development. There is limited reference to the GBR, instead there is reference to the sites being rejected in the SLAA. Given there is limited information available no change is proposed to the GBR. In any event assessing smaller parcels of land is something the Council is currently working towards.


561 Belinda Davie and Robyn Close

Land adjacent to Apple Tree Farm, Trumpsgreen Road, Virginia Water

1. “In the Green Belt Review, approximately two thirds of the site was identified as Resultant Land Parcels as being suitable for the release from the Green Belt. We question why only two thirds of the land parcel is considered for removal and it is suggested that the GB boundary is moved to the tree line on the western boundary. This allows a defensible boundary to be maintained rather than an arbitrary line in a field." 2. "There is also an opportunity for this site and the neighbouring land to

1. In considering sites that might be suitable for release from the Green Belt land ownership was not a factor that was considered, given this was a strategic assessment. Further the GBR identified areas for consideration for release from the Green Belt, rather than definitive boundaries. Although the promoter has identified an alternative boundary, this in itself does not necessitate a change to the GBR. 2. Noted 3. Noted



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come forward as one comprehensive, development site. This is identified in the SLAA site ID 261." 3. "As identified at para 1.4 in the Issues and Options Consultation document, 'land, of course, is a finite resource'; this is why we believe it is important that the Council consider the evidence in the GB review and release the site, and neighbouring land, for residential development.

567 Pleydell Smithyman Ltd

Land at Squires Garden Centre, Holloway Hill, Chertsey

1. The representation sets out that the recent boundary review did not go far enough in terms of identifying Green Belt sites with development potential. 2. The representation sets out the following: This site is within the Green Belt but adjoins the built up area that forms St Peter's Hospital (also within the Green Belt). Approximately 20% of the site is previously developed land and the surrounding greenfield land which makes up the site is not sensitive in landscape and visual terms. The existing fragmented urban edge, in addition to the landform and highway routes that screen and contain views, and the existing

1. Noted 2. The representation promotes release of the site for housing development. The promoter acknowledges that the site is adjacent to St Peter's hospital, which is previously developed land in the Green Belt. There is limited reference to the GBR, which did not identify this area for consideration for release from the Green Belt. The site area was deemed unsuitable for consideration as a result of significant non‐absolute constraints, specifically the presence of a Mineral Safeguarded Area (identified in the pro forma for GA 22 in Annex 3). Noting that while there is no methodology for assessment of smaller



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previously developed elements of the site, justifies the ability of the site to accommodate development and puts this site in a much stronger position for release than many other Green Belt sites.

sites, this is something the Council is currently working towards

581 Tarmac (Paul Dickinson and Associates)

Land North of Thorpe Lea Industrial Estate

The Tarmac land at Thorpe Lea Road is proposed for release from the Green Belt as it "does not perform strongly against Green Belt purposes and makes limited contribution to this part of the Green Belt. It is not considered that the release of this land would result in negative effects to the overall integrity and function of the Green Belt." To support this position information is set out about the 11.5 hectare site on the urban fringe, including comments that it is generally poor quality and fragmented countryside with minimal strategic landscaping and is adjacent to existing development that makes a limited contribution to openness of the wider Green Belt. There are no strategic or long distance views and it is not a natural or obvious part of wider open undeveloped countryside. The nature and proximity of neighbouring commercial and residential development and generally poor

The promoter identifies the reasons the site should be released from the Green Belt, rather than challenging the findings of the GBR, concluding that release would not have a "negative effect on the overall integrity and function of the Green Belt." The area in question provides a gap between Thorpe Industrial Estate and Egham. Nevertheless, assessing smaller parcels of land is something the Council is currently working towards.



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appearance of the land means that development would have a limited visual impact in strategic terms. The area of the site within Flood Zone 2 could be used as SANG/ open space/ leisure and recreation. The representation also identifies that the site has no access constraints, legal restrictions and is immediately available with potential for 300+ homes.

597 Stellican (Martin Leay Associates)

Blay's Lane on the edge of Englefield Green, Egham, Surrey

This representation promotes the site for development, noting that it is immediately adjacent to the existing built up area and its use for much needed student accommodation would not result in unrestricted sprawl or constitute encroachment into the open countryside, would not effect actual or perceived separation between Englefield Green and Virginia Water. A review of the site against the five purposes of the Green Belt found: Purpose 1 ‐ Englefield Green is an existing built up area and the additional development on up to 4.94 ha at Blay's Lane would not result in any 'unrestricted sprawl' as the site is already well contained, bounded on

We note that this representation primarily relates to the performance of land at Blay's Lane against the NPPF Purposes. A separate, more detailed response has been provided on this as part of our review of all 'Counter Reviews'. In summary, while it is acknowledged that the site was not re‐assessed against the NPPF purposes (as it was ruled out at an earlier stage due to the presence of significant non‐absolute constraints), we would observe that the assessment undertaken is not in line with the Arup methodology for the NPPF Purposes. However, assessing smaller parcels of land is something the Council is currently working towards.



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two sides by road and on the third side by residential development at Englefield Green. The fourth (western side) bounds attractive parkland but where there is no public access and the site would remain with the benefit of mature trees and vegetation both bounding and within the site. Purpose 2 ‐ the south‐west extension of Englefield Green over the representation site would in no way threaten the merging of Englefield Green with Virginia Water, given the intervening Registered Park and Garden land of the Royal Estate, Windsor. Purpose 3 ‐ acknowledged as a fringe site of the Green Belt and is not 'open countryside' in the sense of either being farmed or with any public access. Purpose 4 and 5 ‐ acknowledged that these purposes do not apply

602 Surrey Branch of CPRE


1."We have examined the 10 Green Belt areas that Runnymede Borough Council has proposed for development ‐ Chertsey Bittams, the south and north DERA sites, Ottershaw East, the two Row Town Central Veterinary Laboratory sites, Thorpe Lea Road North and West, and Virginia Water

The representation queries the suitability of Green Belt release across the borough, noting that all Green Belt checks the unrestricted sprawl of existing built up areas and that release in some cases may result in the loss of commercial areas. While it is agreed, and indeed set out in the GBR methodology, that an area that



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North and South. All of these areas, with the exception of the DERA sites, check the unrestricted sprawl of existing built‐up areas. The DERA sites assist in safeguarding the countryside from encroachment. In fact the Council states that the DERA South site, together with the other Green Belt sites being recommended for development, is not suitable [for development] on policy grounds given the location of the site in the Green Belt.” 2.” All of the areas also assist in urban regeneration by encouraging the recycling of derelict and other urban land. Three of the purposes of Green Belt designation as set out in the NPPF are therefore satisfied.” 3. “A fourth Green Belt criterion is to prevent neighbouring towns merging into one another. At the least, we would argue that this is presently achieved by Parcel A of the Chertsey Bittams area, which assists in the separation of Chertsey Bittams from Chertsey, by the Central Veterinary Laboratory sites which separate Row Town from New Haw, and by

performs strongly in relation to any of the NPPF purposes, is judged to perform strongly overall, the sites that have been identified for release have be subject to strategic assessment based on an agreed methodology. In light of the representation no changes are proposed to the GBR.


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Ottershaw East which assists in separating Otthershaw and Woodham. In principle, only one purpose needs to be met for an area to remain within the Green Belt."

607 Mr O F Takla (Nexus Planning Ltd)

Villa Santa Maria, St Anns Hill Road

1. The representation suggests that land at Villa Santa Maria should be released from the Green Belt to contribute to the supply of housing in accordance with paragraph 47 of the NPPF. The site is promoted as being in a sustainable location on the edge of the urban area of Chertsey and performs only weakly against the purposes of the Green Belt. 2. The representation includes further analysis in relation to the five Green Belt purposes. The results of this analysis conclude that "the site has no role when assessed against purposes 2, 4 and 5. Against purposes 1 and 3 it is clear that the site performs only very weakly. The Arup work is critical of the wider land parcel in terms of purpose 1 but as noted, the site when viewed in insolation contains clear and defensible boundaries. Furthermore, it would see a significant gap retained to the B389, it would not present ribbon development and would not

The promoter proposes release of land from the Green Belt. The area covered by the site was not taken forward given the identified non‐absolute constraints identified for RGA16 in Appendix 3. As has been noted before, the Arup GBR considers wider parcels of land as General Areas which may not be directly comparable to an individual site. However, assessing smaller parcels of land is something the Council is currently working towards. No change is proposed to the GBR review.



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result in the merging of settlements." 609 Royal Holloway

University of London (Stride Treglown)

Royal Holloway Campus south of Egham Hill

1. The University would like to see the Green Belt boundary adjusted to exclude the campus of Egham Hill. The RHUL campus is surrounded by development on three sides and is effectively infill. The development of the site is contained by tree cover. It is apparent that this has not been a matter that the Green Belt Review has sought to address. In particular potential housing sites on the edge of Egham/Engefield Green should be more fully investigated as the University needs more housing for its staff as a major employer. Egham is one of Runnymede's three major towns and there are limited site allocations in the area to provide for the population. 2. The NPPF advises that Green Belt boundaries should only be altered in exceptional circumstances and at the time of the Local Plan consultation so this should be considered now. 3. The question should be asked whether in relation to the RHUL campus the Green Belt designation is achieving the objectives of Green Belt

The representation promotes release of the site for intensification of development on the RHUL campus. The scope of the GBR, as set out in section 1.1.2 of the Report, was to "identify broad areas, which could potentially be removed from the Green Belt to provide locations for residential or employment use". While there is a difference of opinion on this approach, the GBR remains a strategic review which is what it was intended to be. Consideration was afforded to the removal of part of the RHUL campus from the Green Belt, as set out in the pro‐forma for GA8 in Annex 4 of the Report, but it was judged that there was no justification for its removal from the Green Belt given existing policies on Major Developed Sites. Further as a MDS the site benefits from greater flexibility it is questionable whether it should be released from the green Belt or whether site specific planning guidance should be prepared to support future development proposals. As such, no change to the GBR is proposed. Nevertheless, assessing smaller parcels of land is something the Council is



29

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land. The review is written in relation to housing and employment uses not this.

currently working towards.

612 Ian Cockram Land South of St Davids Drive & Roberts Way

1. The representation objects to the allocation of this site in the SLAA, as it would represent sprawl into the open countryside and have a significant impact on the openness of the Green Belt. Further, there is insufficient local infrastructure/amenities to support development and there would be increased car journeys and traffic. Development could also impact the nearby SINC (e.g. noise and light pollution). 2. Suggests GA22 would be a more appropriate location for development as it would facilitate Long Cross/DERA (GA21) and Trumps Green (GA7) both of which otherwise would impede unjustifiably on the Virginia Water community. 3. The representation quotes NPPG (para 87‐88) and concludes that the proposed allocation does not satisfy the criteria of 'Very special circumstances' and is not outweighed by other considerations.

1.This site (SLAA 22) is not identified for release in the GBR. 2. Noted 3. In amending Green Belt boundaries, Local Planning Authorities are required to demonstrate exceptional circumstances (paras 82‐86 NPPF) as opposed to very special circumstances, which are referred to in determining planning applications in the Green Belt.


618 Surrey County Highway Depot, 1.The representation raises 1‐6. The GBR was undertaken in No change to the


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Council Property Services (Vail Williams)

Lyne Lane, Lyne, Chertsey

reservations about the detail of the GBR, stating it "misses significant opportunities to make most efficient use of particularly, available previously developed land", and that is not sufficient robust to inform the Issues, Options and Preferred Options. It suggest the GBR should: ‐ go further to review the contribution that previously developed sites make to the Green Belt purposes; ‐ identify those which are clearly unnecessary to keep land permanently open and which are otherwise compromised in terms of the Green Belt function; ‐ further refine the GAs and reassess the subsequent sites; ‐ be re‐considered in the light of infrastructure and development needs assessed within the later sections of the Plan. 2. The representation promotes the highway depot site for release from the Green Belt. It criticises the approach adopted in the GBR for not being applied to smaller areas, comparing the findings for GA17 in Table 7.1 which indicate the GA is least preferential for development

accordance with the agreed methodology which was subject to review with Duty to Cooperate partners (including Surrey County Council). It is acknowledged that the scope of the GBR did not include a specific assessment of PDL and the contribution it would make to meeting the NPPF purposes, although all Green Belt was assessed. Further the GBR does not consider any exceptional circumstances, which is in line with the methodology given it is not for this part of the evidence base to determine which sites should be released, only to set out which areas might be considered for release to inform the preparation of the Local Plan. While there is a difference of opinion on the approach, the GBR remains a strategic review which is what it was intended to be. Nevertheless, assessing smaller parcels of land is something the Council is currently working towards. 7 The comment is unclear as to the meaning of the 'current status of land'. 8. The GBR was completed in December 2014, and thus cannot take into account the Issues, Options and Preferred

GBR


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due to the presence of a number of non‐absolute significant constraints across the majority of the area against site specific findings, stating "However, these later criteria are examples of where a finer grade of assessment is required over and above assessment of the large General Areas defined: the site is previously developed in nature and no loss of agricultural land would be lost; the open space land relates to the motocross facility to the north of the site; no public rights of way cross the site itself; does not contain a steep gradient across it; and in terms of the safeguarded waste and minerals site the Surrey County Council website confirms that whilst this is a material planning consideration but does not rule out alternative development." 3. The representation makes clear that it disagrees with the rationale for not including Green Belt Purpose 5 in the Green Belt Review which is based on advice from the Planning Advisory Service. 4. Furthermore, the response continues to state that the extent of

Options which set out the Council's proposed approach to development in the District based on the complete evidence base available to it. While the comment suggests that a fundamentally different approach should have been adopted by the Council, it does not recognise that the Site Selection Assessment considers sites in further detail. Also there is no recognition that a GBR is an objective and independent appraisal against the five NPPF purposes, which considers the strategic suitability of sites for possible release or inclusion, and makes recommendations for the LPA to consider in its wider plan‐making function.


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features listed at para 5.2.2 of the Green Belt Review is too limited and as a consequence many of these General Areas cover large swathes of land reflecting not the character of the area but the feature employed to define them. 5. "Further, Phase 1 does not take into account the more recent recognition at national level of the important role that previously developed land within the Green Belt can make in fulfilling the development needs area." 6. "We consider that because stage 1 of the Green Belt Review is flawed so will, as a consequence Phase 2 because it will omit potentially suitable sites from the finer grained assessment." 7. "The Green Belt Review does not consider the current status of land within the General Areas and therefore does not fully assess the potential and resulting harm of all boundary options." 8. The representation makes the case that the Green Belt Review ignores


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the recognition acknowledged at paras 4.20 and 4.26 of the Issues and Options consultation, of the presence of any exceptional circumstances which would otherwise override the requirement for permanence. The representation states that this exercise should be undertaken iteratively with the findings of the later sections of the Plan to ensure that all the development needs of the District can and are satisfactorily accommodated within the emerging Plan and this does not appear to have been done. The representation includes three examples which each demonstrate where potential opportunities for amending the Green Belt boundary have been missed. These refer to General Areas 20, 22 and 35.

628 CEMEX UK Properties Ltd (Barton Willmore)

Land north and south of Coldharbour Lane, Thorpe

The representation promotes release of land at Thorpe, as this "would not compromise the ability of the Green Belt in this location to fulfil its key purposes as identified in the 2014 Green Belt Review. Namely, checking urban sprawl to the north and east, and maintaining the gaps between the

The promoter proposes release of land from the Green Belt. The area covered by the site was not taken forward given the identified non‐absolute constraints identified for RGA12 in Annex 3, including Flood Zone 2, Minerals Safeguarded Area and Safeguarded Waste Site. As such, the site area was



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settlements of Egham/ Egham Hythe and Staines upon Thames, and Egham and Thorpe...The Council's evidence base indicates that the land in question could be released without conflicting with the purposes of the Green Belt." A Landscape and Visual Assessment and Green Belt Appraisal (June 2016) is provided setting out how CEMEX's land to the east of the village, north and south of Coldharbour Lane contributes to the Purpose of the Green Belt, concluding that the land makes between no and limited contribution. As such it is concluded that "the proposed development could therefore be successfully accommodated on the Sites, limited to the south western extent of the northern Site; and set within an existing and enhanced framework of mature trees and vegetation; without significantly increasing the potential visibility of development on the Sites of reducing the contribution the Sites make to the purposes or functions of the Green Belt in this locality."

deemed less preferential for development and was sifted from the RGA . It should be noted that, in the pro forma for GA12 in Annex 1, this area is identified as playing an important role in preventing erosion of the relatively essential gaps between Chertsey, Thorpe and Egham and it is therefore unlikely that the site would have been identified as a Resultant Land Parcel. Nevertheless, assessing smaller parcels of land is something the Council is currently working towards. It is noted that an independent assessment of the sites(s) was undertaken by Barton Willmore as part of their representation. A review of this has found that, although some of the details of the methodology vary from those utilised by Arup, the broad principles used in reaching the conclusions are similar to those used in the final part of the Arup study. However, as noted above, the sites in question were not re‐assessed against the NPPF purposes as they were constrained by a series of significant non‐absolute constraints and were excluded


35

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from the assessment. 646 Ashford and St

Peter's NHS Foundation Trust

St. Peters Hospital site, Guildford Road, Chertsey

The representation promotes release of the St Peter's Healthcare Campus from the Green Belt, given it is previously developed land in the Green Belt, that it has identified that proposals will come forward for more intense development (and the Review acknowledging that this would be unlikely to compromise the Green Belt given the extent of existing development), it does not provide a Green Belt function, and given the developed area directly to the east of the site does not form part of the Green Belt the incorporation of the St Peter's Campus site into the urban area is a logical step. The representations suggests the site has not been identified as a Resultant Land Parcel (RLP) considered appropriate for release from the Green Belt, as it is assumed that the site will not come forward for any uses other than healthcare. It states "Given there are plans to develop part of the site for residential use, it would be appropriate for the St Peter's Healthcare Campus to be included in the Local Plan as a Resultant Land

The assessment acknowledges that should the site come forward for more intense development then it would be unlikely to compromise the Green Belt in terms of Purposes 2 and 3, given the extent of existing development. At the time of the review the team was not aware of proposals for development at the site. Further as a MDS the site benefits from greater flexibility it is questionable whether it should be released from the Green Belt or whether site specific planning guidance should be prepared to support future development proposals.



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Parcel to be released from the Green Belt."

650 Crown Estate (Savills)

Land at Englefield Green

1."The RLPs (Resultant Land Parcels) identified in the Green Belt Review 2014 provide the starting point for the allocation of Green Belt housing sites in the Borough. However, if the full OAN is to be addressed with sufficient flexibility to respond to changed circumstances, then a more comprehensive review of Green Belt boundaries will be required to identify further suitable, available and deliverable land for a further 13,775 homes. The more comprehensive review should focus on sites on the edges of the Borough's main towns, local centres and smaller centres as defined by the settlement hierarchy...." 2. "The search for additional Green Belt sites around Englefield Green should...be focussed on Area 8. Fifteen Hectares of land owned by TCE (The Crown Estate) is located within Area 8, to the south of Englefield Green." 3. A Landscape and Visual Appraisal and Green Belt Review has been

The promoter's comment that a "more comprehensive review of Green Belt" is required is noted. The GBR undertaken involved a comprehensive review of the whole Green Belt against the NPPF purposes, combined with an assessment of land against Absolute and Non‐Absolute Constraints to identify areas that would be suitable for housing and employment development. This is set out in section 1 of the GBR Report. The promoter proposes release of land from the Green Belt. While it is acknowledged that the GBR recognised potential scope for development in the north and south of GA 8, it should be noted that this comment does not specifically relate to the promoted site and furthermore, is only relevant to the performance of the GA against Purpose 2. A more detailed commentary on smaller areas within the broader FRGA is provided in Annex 4, which confirms that the area in question should be retained in the Green Belt as a result of its performance against Purposes 2 and 3, preventing development that would compromise the openness of the gap



37

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included in the representation, which has been prepared by Barton Willmore. The sites have been assessed against the five purposes of the Green Belt. Under a 'Summary of Green Belt Review' the representation states that the "sites form a small component of the northern edge of the wider General Area 8 of the Green Belt assessed in RBC Local Plan Green Belt Review 2014 . The review acknowledged that 'there may be some scope for development of the north or south of the land parcel' thus identifying that there is potential for development in the locality. Whilst RBCs Interim SLAA (2016) includes the Sites as land parcel ID022, it does not address their specific contribution to the purposes of the Green Belt in this location, instead relying upon the general conclusion from the assessment of the wider General Area 8 that ID022 should be retained within the Green Belt." The Landscape and Visual Appraisal and Green Belt Review of the five purposes of the Green Belt concludes that "development of the sites would not limit the ability of the surrounding land to maintain the purposes of the

between Englefield Green and Virginia Water and resulting in encroachment of built development into the countryside. We feel that these conclusions are suitably reasoned and justified and would suggest that no change is made to the GBR. Nevertheless, assessing smaller parcels of land is something the Council is currently working towards


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Green Belt. Furthermore, development would be set within a robust landscape framework, with the provision of substantial new planting and Green Infrastructure, with the creation of a robust, defensible boundary to both the settlement edge of Englefield Green and that of the Green Belt."

651 Taylor Wimpey (Turley)

Land to the north of Green Lane, Chertsey

1."As noted within the supporting Preferred Policy Approach Green Belt Releases, RBC is proposing an amendment to the Green Belt boundary through removing the sites from the Green Belt including the wider parcels of sites at Chertsey Bittams (ID255), which is supported..." "The Green Belt Assessment prepared by Arup whilst favouring the wider site (ID255) for further consideration for Green Belt release, is considered to overstate the role that the site plays in meeting the function of the Green Belt when assessed against the purposes of the Green Belt..." "Arup have been instructed by many Local Authorities to undertake Green Belt reviews to inform the preparation and strategies of Local Plans.

The support of the promoter for the recommendation of the FRGA 25 for potential release from the Green Belt, and for the scale at which the assessment was undertaken is noted. With respect to the additional assessment undertaken by Turley, it should be noted that: ‐ While the commentary provided would appear generally logical, it is not clear how the identified scores produced by Turley relate to a criteria‐based scale. In the Arup assessment, the specific criteria linked to each score are provided in the methodology section for each Purpose. We believe this provides a logical, transparent and suitably robust means of assessing each parcel; ‐ Specifically in relation to Parcel A, no



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However, the structure and methodology of the Assessment varies considerably between Local Authorities and the approach to identifying the sites for potential development has not been applied uniformly." "When considering General Area 25 which specifically relates to our Client's interest and encompasses the wider area at Chertsey Bittams (ID255) which is clearly defined by the M25 and the A320 St Peter's Way, the scale of the general area is considered logical and appropriate for undertaking the Green Belt Assessment." "We have reviewed the findings of the Arup Assessment for General Area 25 alongside an independent assessment by Turley of the Green Belt function of General Area 25 and with a further review of Parcel A of the area more specifically." 2. The findings of the independent assessment are as follows: "GA 25 and Parcel A in isolation play a much lesser role in meeting the 5 functions of the Green Belt than Arup's assessment. This reinforces that releasing GA 25

methodology was provided in the Arup Study for assessing smaller areas of Green Belt quantitatively. Instead, a qualitative decision, weighing up the performance against the NPPF Purposes, impact on the wider function of the Green Belt and fit with the settlement hierarchy was made. Thus, while we acknowledge the scores it should be noted that these are not directly comparable to the Arup Study; ‐ We believe that the commentary provided by Turley in the summary table is broadly consistent with our own conclusion, evidenced in the GA 25 pro forma in Appendix 4. Nevertheless, assessing smaller parcels of land is something the Council is currently working towards. In relation to the broader comments made by Turley in relation to the methodology, we would highlight that the methodology utilised by Arup is adjusted to adapt to local context and client requirements, and the three stage process employed in the Study represents a bespoke approach which was designed to address RBC's original scope. We do not feel it would be appropriate to comment on studies


40

Rep No



from the Green Belt is both necessary and appropriate to meet the requirements of the NPPF." In summary: Purpose 1 ‐ Turley scores 2 for GA 25 and 1 for Parcel A; Purpose 2: Turley scores 1 for GA 25 and 1 for Parcel A; Purpose 3: Turley scores 2 for GA 25 and 1 for Parcel A. The Turley assessment sets out that with regard to utilities, GA 25 and Parcel A contains no high pressure gas pipes and with regards to topography, GA 25 contains steep gradients whereas Parcel A has a lower topography. "...the Arup assessment whilst supporting the release of GA 25, is not robust enough in its conclusions given it should score lower against the functions when considering the existing infrastructure surrounding GA 25 which clearly provides a permanent and defensible boundary for the future. Parcel A clearly no longer serves the purposes of the Green Belt." "It is clear that the conclusions of the Arup Assessment (reinforced by Turley's assessment...) which put forward GA 25 for further consideration for Green Belt release is appropriate and it should be taken

undertaken for other clients.


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Rep No



forward for allocation within the Local Plan. In addition, Parcel A clearly no longer serves the purposes of the Green Belt...given there is no need to keep the land permanently open given the pressure of the M25 providing a permanent and defensible boundary and with the opportunity to bring forward new development in an accessible location which will promote sustainable patterns of growth at Chertsey South." 3. "With regards to phase 2 of the assessment , whilst Arup has reviewed the overall GA 25, we (Turley) have provided conclusions specifically relating to Parcel A to demonstrate the suitability of the site for development in isolation." A summary is provided below: Flooding‐ only a small part of the site to the south‐west is within Flood Zone 2 Biodiversity ‐ appropriate provision would need to be made of SANG as part of any development. Landscape ‐ lies outside an Area of Landscape Importance and is therefore preferential for development.


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Rep No



Historic Environment ‐ No historic assets on site. Agricultural land ‐ area contains grades 3, 4 and 5 Minerals and waste ‐ area is not within a minerals or waste consultation zone Open space ‐ contains open space although this could be formalised through new development for use by existing and future residents Public rights of way ‐ subject to a public right of way which is along the west and northern boundaries

652 Hamlin Estates (DLP Planning)

No specific site associated with response.

1. The GBR methodology is weak, fundamentally flawed and inconsistent with the NPPF. 2. The GBR seeks to minimise changes to boundaries as opposed to taking the long term housing needs in the Borough. These aspects and objectives should underpin the overall Strategy of the GBR. 3. It is inconsistent with the NPPF by taking the stance that land should be released from the Green Belt only in exceptional circumstances, whereas a proper review should consider the form and function of the Green Belt in

The methodology used in the GBR was developed in line with the NPPF and RBC guidance, and corroborated through Duty to Cooperate commitments, and therefore represents a robust strategy for the assessment of Green Belt parcels. In regards to the NPPF, para 83 states that "once established, Green Belt boundaries should only be altered in exceptional circumstance, through the preparation and review of the Local Plan". This stipulation alongside other guidance in the NPPF was fully considered when considering land for release. Further, the GBR was not premised on "seeking to minimise Green Belt boundary changes", as suggested in



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the context of the long term housing needs of the Borough. 4. The consideration that 30% of the Borough is at risk of flooding has not been properly factored into the GBR. 5. The GBR should be reviewed to include the long term housing needs of the Borough so that more land can be released.

the representation; it was an independent review of the sites in line with the published methodology. The influence of flooding has been considered in Phase 2 of the GBR, as an absolute constraint.

676 Kitewood Estates (CgMs)

Wey Manor Farm, New Haw

1. The GBR methodology is flawed. It looks at General Area's which are too large in size and therefore has not adequately considered sustainable sites of a smaller nature for release. 2. There should be a more detailed study of smaller edge of settlements sites for release, in particular to consider the 12.8 hectare site at Wey Manor Farm, New Haw, taking into account the master plan scheme and up‐to‐date information. 3. The reason the Wey Manor Farm site was not favourably considered for release from the Green Belt was due to the fact that it was only considered as part of this larger site (GA31).

RGA31 was not taken forward given the identified non‐absolute constraints, noting that the site in question was identified as within a Minerals Safeguarded Area, adjacent to a safeguarded waste site, a natural and semi‐natural urban green space, and partly within Flood Zone 3a (refer to GBR Appendix C). As has been noted before, the Arup GBR considers wider parcels of land as General Areas which may not be directly comparable to an individual site. However, assessing smaller parcels of land is something the Council is currently working towards.



44

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4. The RGA was retained in the Green Belt due to the number of non‐absolute constraints. Only a few of these were shown to affect the proposal site. If the proposal site had been considered further it would have been recognised as the part of the RGA closest to the urban area, in a highly sustainable location and not constrained by the absolute or non‐absolute constraints which applied to the wider area. The proposals for the site ensure that the non‐absolute constraints are avoided. 5. Development of the proposal site would not result in unrestricted sprawl of a large built up area; the merging of neighbouring towns; encroachment into the countryside and it is not close to any historic towns. The site serves little purpose in terms of its function within the Green Belt.

680 TREG Consulting (ECA Architecture and Planning)

Land west of Ten Acre Lane, Thorpe

1. The Green Belt Review has been given significantly more weight than other parts of the evidence base which is unjustified. 2. The Arup Green Belt Assessment has not assessed the site at Ten Acre

1. Arup is unable to comment on whether the GBR has been given more weight than other evidence base documents. 2‐6. The approach to identifying GAs was set out in the GBR methodology and complied with the guidance in the NPPF



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Lane in detail and states in para 7.5.2 and Table 7.1 that the site is within an area which should be considered further as to whether there is any land that could be released from the Green Belt. 3. The response supports the village of Thorpe returning to the urban area and gives detailed comments on the Thorpe Village Boundary Options (TH1‐TH6) in the Issues, Options and Preferred Approaches Consultation document. 4. Alternative assessment of Thorpe Village and Site 42, Ten Acre Lane. Purpose 1: For openness, it should be scored a 2, as Thorpe Village and Industrial Estate comprise as urban areas. For sprawl, it should be scored a 2 because the motorways provide durable boundaries and Thorpe Village is not a LBUA. Purpose 2: It should be scored a 1 as there is already ribbon development surrounding Thorpe Village and on Ten Acre Lane. Purpose 3: It should be scored a 2 because Thorpe Village and Industrial Estate comprise as urban areas.

in relation to defensible boundaries. While this does result in some large areas, it allows functional areas of Green Belt to be assessed. Further it cannot be assumed that had smaller areas been identified that they would have been contiguous with the promoters land ownership/the area identified for release, and therefore it cannot be automatically assumed that this route would have resulted in the sought outcome. The area in question was assessed to perform strongly against Purpose 1 and moderately strongly against Purposes to and 3, reflecting the function of this area of Green Belt. The findings of the stage 1 assessment are considered to remain valid, noting that the promoters own Green Belt assessment downgrades the scoring against Purpose 1. Nevertheless assessing smaller parcels of land is something the Council is currently working towards. 7. The GBR did not identify that the Ten Acre Lane site should be considered further as to whether there is any land that could be released from the Green


46

Rep No



5. The parcels assessed are overly large and have a diverse character making assumptions incorrect. Absolute constraints are based on incorrect information, as they relate to the GAs rather than more refined areas. 6. The assessment puts undue weight on other absolute constraints which are not relevant to the Green Belt and therefore dilutes the purpose of this study. 7. The representation includes an assessment of the GBR, which states "Paragraph 7.5.2 and Table 7.1 confirms that the Ten Acre Lane site (42) is within an area which should be considered further as to whether there is any land that could be released from the Green Belt taking into account flooding, historic buildings and agricultural land grading. However, this has not been undertaken in the study and there is no clear reason why. It is therefore not clear whether this evidence is sufficiently robust to dictate future housing policy in the Borough."

Belt, the statement related to the wider RGA12. Further assessment of FRGA12 identified that the area should be retained as Green Belt, this was informed by an assessment against the NPPF Purposes, as detailed in Annex 4.


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Rep No



682 M&G Real Estate (Terence O'Rourke)

Land at Great Grove Farm, Ottershaw

1.Land at Great Grove Farm should qualify as exceptional circumstances and be removed from the Green Belt as it performs poorly against the purposes of the Green Belt. 2. Runnymede Borough Council did not assess the individual merits of this land in their GBR, only drawing conclusions while considering the site as a whole. Assessment of South West corner of 41: The site is adjacent to the village of Ottershaw and therefore not considered for Purpose 1 which only looks at the LBUA of Addlestone, Chertsey and Egham (P1 ‐ 0). The site has limited contribution to Purpose 2 given its location at the north east of Ottershaw. It would provide a more balanced settlement, and would not result in extension of settlement beyond its existing limit in the east with a marginal extension to the north therefore preventing merging. Essential gap maintained between Ottershaw and Chertsey South (P2 ‐ 0). For Purpose 3, using the more recent ONS urban dataset from 2011 as opposed to the one from 2001, it is

1. It was not the purpose of the GBR to determine whether exceptional circumstances could be demonstrated. 2‐7. The area in question forms the south western part of GA41, to the north of Ottershaw. Therefore, any comparison with the GBR should be considered in light of the different areas, which inevitably would result in different outcomes. Nevertheless assessing smaller parcels of land is something the Council is currently working towards. The query as to not testing the three purposes of the Green Belt not being revisited when each RGA is assessed is challenged. As set out in the methodology, a qualitative assessment of smaller areas of land in the FRGAs against the NPPF Purposes was undertaken to identify Resultant Land Parcels. This assessment considered the performance of RLPs against NPPF purposes 1‐3, but also their role in terms of the wider function of the Green Belt as well as strategic fit with the settlement hierarchy. Although site photographs are not provided each site was visited to



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found that the urban area extends north from Ottershaw across the B3121. Site consists of urban fringe/built development such as garden centre, car park, storage areas, recycling facility, industrial sheds, masts, residential properties and a riding school. Our review found the area as having between 10‐25% built form. Site could be released without impacting on P3 (P3 ‐ 3). 3. The evidence base (including the GBR) needs to be updated in consideration of this proposal. 4. Refined GA41 was not assessed correctly and was of lower sensitivity, therefore has the potential for release. GA41: 0 for Purpose 1. At least a 3 for Purpose 2 as it is a largely essential gap where there may be some scope for development but where the overall openness and the scale of the gap is important to restrict settlements from merging. A 3 for Purpose 3 as the refined GA contains between 10‐25% built form. The variations in character across the site mean that any general

supplement the desk top assessment, therefore the report was not based solely on desk top analysis. The 2001 dataset was favoured over the 2011 data. Following an active comparison between the two datasets, it was considered (and agreed) that the 2011 data was not fit for purpose in terms of the assessment being carried out as it over‐estimated the urban extent of settlements. With regard to the gap in topographical data, for areas where no data was available a neutral assessment was made in relation to the constraints assessment. Comments are made at 3.8 of the GBR Assessment submitted by the promoter that there are errors in how the non‐absolute constraints have passed through from map 7.2 to Map 8.1, a review of the mapping shows that the areas align, noting that the choice of colour does not make this the easiest review. Further the assessment was completed in accordance with the agreed methodology. 8 & 9. This approach is consistent with the GBR methodology.


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Rep No



assessment of GA41 or its Refined GA would be wholly inappropriate to apply to the south west of the site as illustrated by Great Grove Farm Development Potential Study. 5. Openness of the Green Belt is a characteristic not a purpose and has therefore been incorrectly applied as a factor in determining the performance of the site. 6. The methodology used for Phase 1 of the GBR is robust and has been used in the GBR assessments submitted. 7. The robustness of the study in terms of assessing the availability of land that could be released from the Green Belt is questioned. A key flaw is not using the assessment criteria of the three purposes when assessing each Refined General Area, as it contradicts with the purpose of study to establish land of whatever size for release. There is a lack of evidence to back up conclusions: no site photographs, limited commentary that does not reflect the complexity of GA41. The report appears solely desk


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based using OS maps and aerial photography. Uses 2001 ONS data on urban area as 'the most up to date' when there is 2011 data available on urban areas. In para 5.12.7 it states that the topography data does not cover the whole Borough which may have led to incorrect evaluations of sites. There appears to be inaccuracies in the parts of General Areas that have been taken forward for further assessment. For example an area of land identified as affected by significant non‐absolute constraints in GA25 has not been removed from the Refined GA map 8.1. For GA28, a small area is described in Annex 4 that could form a natural extension for development. It is agreed that this should be removed from the Green Belt however as a site it is not developable as it already contains 10 large properties sort within mature woodland and the remainder of land is affected by significant non‐absolute constraints which is SANG. The refined General Areas should have undergone the same detailed analysis as the stage 1 assessment. This is not shown to be done as in para 8.2.1 it states that "At this point it was necessary to


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consider again the value of the land in currently or potentially meeting the NPPF purposes of the Green Belt'. 8. The GBR has incorrectly assessed GA41 against all 3 purposes: Purpose 1: The assumption that there is no defensible boundary to the east of the site is incorrect, site visits conducted by Terence O'Rourke indicate that there is a watercourse, a ridgeline and a protected woodland with a TPO that create durable/permanent features. The RGA does not border with any LBUAs so the scoring in Annex 4 is incorrect as it does not assess the RGA. Purpose 2: The RGA would not lead to a merging of Addlestone and Chertsey South. The gap between Ottershaw and Chertsey South could be maintained by only developing on part of the Refined Area. When comparing the assessment of GA28 with that of 41, there is inconsistency. 28 scored a 3 against purpose 2 despite the narrow gap between Addlestone, Ottershaw, New Hall and Woodham, and the review states that there may be scope for development that will


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not lead to coalescence. GA41 has a wider gap between settlements but scored differently and it is not clear why. Purpose 3: Using more up‐to‐date data from ONS found that 41 has between 10‐25% built form. The urban edge of GA28 is similar to the urban edge to the south of GA41, and for 28 there are areas given for release for development despite the reduction of the essential gap. Photos taken on site visits illustrate the land uses located in 41. 9. The GBR states that development of GA41 would have to be sympathetic to 4 grade II listed structures. This is incorrect as there are only 3 Grade II listed building within 100m, with a fourth located at least 0.5km away. The site is not a significant part of the setting to any of these listed buildings and is unlikely to affect through a change to setting.

692 Mr Steve Mickiewicz (OSP Architecture)

1. The response seeks the removal of the Charnwood Nurseries site in New Haw for residential development. The proposed site does not contribute significantly to the purposes of the

The promoter proposes release of land from the Green Belt. It is noted that the promoter does not disagree with the methodology for the GBR or its implementation, but seeks to



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Green Belt and would not harm the purposes of the Green Belt, as set out below. 2. Purpose 1: Site already supports several large buildings. Residential development would include landscaping to bookmark the end of development in this location to ensure no further sprawl. 3. Purpose 2: Site already supports large buildings so residential development would not result in towns merging or demonstrable change from the current impact of the site. 4. Purpose 3: Despite nursery use being classed as an agricultural use, the site is covered by development including large buildings. The site is linked to the residential development to the south. The site would not encroach on the countryside for this reason and would ease pressure of encroachment in other areas. 5. Purpose 5: The nursery is vacant and unviable so residential development here is preferable to other vulnerable areas.

demonstrate that, as a standalone site, it does not perform against the NPPF Purposes. As has been noted before, the Arup GBR considers wider parcels of land as General Areas which may not be directly comparable to an individual site. However, assessing smaller parcels of land is something the Council is currently working towards.


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707 Alison and John Knight


1. The removal of the land south of Roberts Way is supported as outlined in the Green Belt Technical Review 2016. 2. Suggest that consideration is given the remove developed land between Lambly Hill and Pinel Close, Stroude Close, Virginia Water 3. However the removal of Virginia Water North and Virginia Water South from the Green Belt is unsuitable. 4. Do not support removal of Virginia Water North ‐ is not a deliverable site due to mattes of access and density, which would mean there would be limited housing gain. 5. Do not support removal of Virginia Water South as this would have a significant impact on the open landscape, and there are problems concerning access and traffic impact. 6. Land at Stroude Farm should be considered for release due to its potential as a development site ‐ close

In regard to the release of Virginia Water North and Virginia Water South, the issues raised in the response are planning matters taken into account in both the preparation of the Local Plan (SLAA and Site Selection Assessment) and subsequently at planning application, as opposed to Green Belt matters. The additional evidence submitted in relation to the performance of Stroude Farm against the NPPF Purposes through a separate representation by Boyer is noted. A separate response has been provided on this as part of the review of all 'Counter Reviews'. While the GBR identified potential scope for development in the south‐west of GA 9, this related solely to the assessment against Purpose 2 and it should be noted that the GA met Purposes 1 and 3 moderately. Additionally, it should be noted that a number of Significant Non‐Absolute Constraints were identified throughout the GA, including in the area where the site is located. In line with the published methodology, while a small area in the north of the GA was taken forward for further assessment, the



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to amenities, previously developed land, suitable for mix of housing type.

remaining area (including Stroude Farm) was discounted from further assessment. However, assessing smaller parcels of land is something the Council is currently working towards.

712 David Rosseau Row Town West, Old Road

1. It is inappropriate to release land from the Green Belt in order to satisfy housing need, based on guidance from the NPPF and PPG. 2. The assessment of GA28 in the GBR and the recommendation of the Plot B/Row Town West, Old Road land parcel for release is flawed. The parcel has been chosen for release due to factors unrelated to the Green Belt, because it as an easily developable site. 3. GA28 scored highly across the purposes and therefore should qualify for protection. 4. By not assessing the land parcel in its own right against Green Belt purposes, its value has been overlooked. 5. The resultant Green Belt boundary is weak if the land parcel is released, it

The decision to release land from the Green Belt for housing purposes is at the discretion of the Council through the Local Plan process. Following assessment in the SLAA the Council has determined that the site is suitable for consideration for development. The methodology used by Arup in the GBR (2014) was developed in line with the NPPF and in discussion RBC, and corroborated through Duty to Cooperate commitments, and therefore represents a robust strategy for the assessment of Green Belt parcels. The methodology included site visits and as a consequence of this, the inclusion of qualitative data when formulating the scores for each parcel. In summarising the overall performance of GAs, the three identified sites (GA 24, 29 and F) perform particularly strongly, scoring 5 against three out of four Purposes. This is not to say that other GAs, as a whole, did not also score strongly. Note though that in



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is not an infill site and the land parcel should not be released.

reaching a conclusion on the strength of Green Belt, no summing or aggregation of scores is made. In reference to the consideration of release for GA28, Arup recommended consideration of small sub‐areas of the parcel for release which, when considered alone, score weakly against Green Belt purposes. All Resultant Land Parcels were judged to perform less strongly against the NPPF Purposes than the wider GAs; the detailed assessment for the area in question is set out in the pro forma for GA28 in Appendix 4. The site in question was then considered in further detail (with respect to defensibility of boundary features) through RBC's SLAA process.

738 Blackfield Land (NLP)

Land off Norlands Lane, Thorpe

1. There are other parcels of land in the Green Belt that have not been adequately assessed in detail which do not meet the five purposes of the Green Belt. 2. The GBR is high level. The GBR was limited in that it mapped broad general areas and discounted areas in terms of 'absolute constraints'. A fine grained review of Green Belt sites that could be released for development

The representation challenges the scale at which the assessment was completed, arguing that if smaller sites had been assessed then the site in question would have been identified for release from the Green Belt. Taking each in turn, the approach to identifying GAs was set out in the methodology and complied with the guidance in the NPPF in relation to defensible boundaries, while this does result in some large areas, it allows functional areas of Green Belt to be



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should be undertaken to identify more suitable sites that could be released to meet housing shortfall. 3. Land at Norlands Lane (ID 220) should be assessed through a more detailed review of the Green Belt boundaries. 4. The GBR was limited in that it assessed only the boundary line between the urban area and the Green Belt. 5. Functional flood plains were included which did not allow for update topography or consider the forthcoming drainage relief channel for the River Thames. Land that is not in the flood plain or contaminated but which could be developed safely has been excluded wrongly. 6. The Council's spatial strategy should allow for sites which do not perform strongly against Green Belt purposes to come forward for housing. 7. The GBR identifies the land adjacent to the Thorpe Industrial

assessed. Further it cannot be assumed that had smaller areas been identified that they would have been contiguous with the promoters land ownership/the area identified for release, and therefore it cannot be automatically assumed that this route would have resulted in the sought outcome. Nevertheless, assessing smaller parcels of land is something the Council is currently working towards The methodology used by Arup in the GBR (2014), including the identification of absolute constraints, was developed in line with the NPPF and in discussion RBC, and corroborated through Duty to Cooperate commitments, and therefore represents a robust strategy for the assessment of Green Belt parcels. The area in question forms much of the gap between Thorpe and Egham Hythe (part of Egham), which was identified as a "largely essential gap" in the GBR, and is open in character and largely free of development. It is therefore judged to perform an important role in terms of NPPF Purposes 2 and 3. Furthermore, the site in question was identified as constrained by a number of absolute and significant non‐absolute constrained, as


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Estate is not geographically remote and could be excluded from the Green Belt as it does not affect Purpose 1 and 2 of the relevant Parcel.

set out in the relevant pro‐formas in Appendices 2 and 3, which would make the site less preferential for development. The scope of the GBR was not limited to 'assessing only the boundary line between the urban area and the Green Belt' and did not preclude weaker areas of Green Belt in other locations, but it should be noted that in identifying resultant land parcels consideration was given to the "strategic fit with the existing settlement hierarchy" (para 8.2.1). Noting that the comments regarding the Council's spatial strategy are not directly related to the GBR, it is assumed that RBC would take into account a wider range of factors to inform the selection of preferred sites for allocation in the Local Plan.

751 Re‐Creo (WYG) Land north of Green Lane, Addlestone

1. Land north of Green Lane is suitable for release from Green Belt, making it no different to other Resultant Land Parcels identified in the GBR. 2. The GBR review did not incorporate

The inclusion of a Comparative Green Belt Assessment as part of the representation is noted. A separate response has been provided on this as part of the review of all 'Counter Reviews'.



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an assessment as to whether the sites it identified for release could provide sustainable development. 3. Prepared an accompanying Comparative Green Belt Assessment, which assesses the site in the context of the Arup GBR and sustainable development ‐ this has been prepared in accordance with the methodology adopted by Arup in its review of the Green Belt. 4. The site which has now been refined to address issues raised by relevant constraints/purposes of GB (the refined site proposal has had regard to the conclusions of the GBR), should be considered for inclusion in the urban area, given the refined site addresses the concern in relation to Purpose 2 of the erosion of the gap between Addlestone and Chertsey, and concerns regarding Purpose 1 and 3, through the design to reinforce the already considered durable and permanent boundaries preventing sprawl, and in the process ensuring that the development would not be visible from the elevated A317 nor encroach upon the countryside.

(Council note: Counter Reviews were submitted to the Council following publication of the Arup Green Belt Review. The Arup response to these is published separately on the Runnymede Borough Council website) The comments in relation to the key considerations in relation to Purposes 3 are noted, it should be highlighted that this is not consistent with our approach. The methodology used in the GBR was developed in line with the NPPF and RBC guidance, and corroborated through Duty to Cooperate commitments, and therefore represents a robust strategy for the assessment of Green Belt parcels. Resultant land parcels were identified based on performance against the NPPF purposes and level of constraint against a range of different strategic constraints. The representation refers to sustainability which was not relevant to the GBR, but which would all be subject to full consideration as part of the wider site selection process undertaken by RBC. The area in question (GA 40) was assessed as performing strongly against Purposes 1 and 3 and moderately


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5. The fact that there is no existing developments within the refined area for GA40 is consistent with many other of the Resultant Land Parcels and therefore is not a reason for not releasing the site. 6. The main characteristic that assists in safeguarding countryside from encroachment is the containment of development by clear boundaries and providing for development on land that is well related to the urban area and these purposes are met by the current proposals. 7. Steeply sloping topography is a significant non‐absolute constraint for GA40, giving it a poorer score than other Resultant Land Parcels. By not building on this area, the topography and now retained vegetation ensure that development of 40 would not be visible from beyond any part of this boundary. 8. On Purpose 2, the potential to erode the gap between Chertsey and Addlestone has been overcome by retaining and designating the whole of

strongly Purpose 2, reflecting the function of this area of Green Belt. The findings of the stage 1 assessment are considered to remain valid, noting that the promoters own Green Belt assessment downgrades the scoring against Purposes 2 and 3. However, the representation relates to smaller area than that considered in the GBR and includes site specific proposals that set out a revised proposed Green Belt boundary. Accordingly revised scoring is identified; this scoring is not comparable to the GBR as it considers different areas. Furthermore, relating to the assessment undertaken in Annex 4, the FRGA (broadly in line with the identified site) was judged to be important in preventing the physical merging of Addlestone and Chertsey. This gap is very small in scale and any substantial development of the eastern part of GA40 would substantially erode the gap. Along with land to the north, this area provides an open break in the built form between these settlements which the Green Belt is important to maintaining.


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the north‐east of the site as an undeveloped natural habitat area, which also links it to GA39. 9. The site sits within the Arup 'Further Refined General Area'. 10. Gives overview of Arup's findings on GA39/40.

A decision was reached to undertake the assessment independently of knowledge on development sites, on the basis that we were commissioned to identify broader areas which could potentially be removed from the Green Belt and to ensure the independence and objectivity of the study.

755 DEFRA (Montagu Evans)

APHA Weybridge 1. DEFRA land holdings in Runnymede: majority fall into the designated Green Belt. 2. Two of DEFRA's land ownerships have been identified for release which is supported (Parcels A and B). 3. The Council's advisors should consider the following areas to remove from the Green Belt to aid the delivery of residential/employment opportunities: Parcel D: north east corner falls within Green Belt but serves no function and is assumed to have been missed by the advisors, re‐evaluation is requested. Land to west of Parcel B: Parcel B is to be removed from Green Belt and used for housing and this questions the role of this land. This site should be

The support for the findings of the GBR in relation to two of the resultant land parcels in GA28 is noted. The additional areas identified for consideration were all assessed against the NPPF Purposes as part of GA 28 and we would disagree with the statement that 'obvious areas that serve no Green Belt function have not been considered'. Arup's approach to the consideration of areas that serve no Green Belt function and should therefore be considered for release is set out in Sections 8.1‐8.2 of our Report. Land not covered by an absolute constraint or a significant non‐absolute constraint was identified for further analysis in the FRGAs, whereby its value in relation to the NPPF purposes, functionality with relation to the Green Belt and strategic fit with the existing settlement hierarchy was assessed on a



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removed from the Green Belt in order for DEFRAs access track to be used as a defensible boundary for the Green Belt. The site should be reconsidered by the Council's advisors and released. Grange Farm: This area appears not to have been considered by the Council's advisors when assessing the role and function of the Green Belt. The landholding is read as part of the urban environment to the south and the build element clearly serves no Green Belt purpose. 4. We support the identification of part of our clients site for release from the Green Belt, but believe that there are obvious areas that serve no Green Belt function that have not been considered. Until such time as these are reviewed the evidence base will be unsound and could undermine the robustness of the Local Plan.

qualitative basis. A key aim of the Study, as set out in para 1.1.2,was to "identify broad areas, which could potentially be removed from the Green Belt to provide locations for residential or employment use". Taking each in turn: the small area of parcel D, identified in the representation, is constrained by significant non‐absolute constrained, as identified in the relevant pro‐forma for GA 28, and was therefore not considered suitable for release; the land to the west of Parcel B was adjudged as making a stronger contribution to NPPF Purposes 2 and 3 than the identified resultant land parcel, being of a more open and less enclosed character and forming a key part of the narrow, essential gap between Addlestone and New Haw/Woodham, and was therefore not recommended for possible release; similarly, it was judged that an intensification of Grange Farm would further erode the overall openness and scale of the gap between Addlestone and New Haw/Woodham, and was not recommended for possible release. We believe that these justifications are


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sound and reasoned. Furthermore, there appears to be an implicit challenge as to the scale at which the assessment was completed, arguing that if smaller sites had been assessed then the site in question would have been identified for release from the Green Belt. Given the team were not aware of land ownership or site promotion when the Study was undertaken, it cannot be assumed that had smaller areas been identified that they would have been contiguous with the promoters land ownership/the area identified for release, and therefore it cannot be automatically assumed that this route would have resulted in the sought outcome. We note that, subsequent to our Study, RBC undertook a Technical Review of Green Belt Boundaries to consider "any minor amendments required to make the Green Belt boundary more logical and/or defensible"; we would suggest that comments in relation to minor Green Belt revisions (e.g. parcel D) are likely to be more pertinent to this study.

appendix 1. comments received from arup on reg …...land at howards lane 1. the comment requests...

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