AS14 Land at The Pines

45AS05; AS07; AS08; AS14 are all located to the east of Ashtead and fall within Area J, which has indeed been considered to have potential for development. Site AS05 is currently occupied by Ashtead Park garden centre, and we note that planning permission was refused in 2003 for its redevelopment to provide housing. One of the principle reasons was the potential for encroachment into the open countryside, and we strongly disagree with the Forum’s assertion that ‘merging and encroachment would be minimal’. Indeed, the site directly abuts open fields to the north and would be very highly visible for some distance from Whitehatch Lane. Whilst the existing Garden Centre may provide a form of urbanising/previously developed land, it’s current impact is considerably less than what would result from residential development. A garden centre is a more appropriate use to which acts as a buffer/transition at this setting between the built up area and the wider countryside that is formed by the Green Belt. Furthermore, the Garden Centre providesemployment and a service for the residents of Ashtead. Development of the former Chalk Pit (Site AS07) which is adjacent to the Garden Centre would also result is a significant loss of trees which would need to be justified.Combined the four sites total less than 6.4 hectares, of which perhaps less than two thirds isdevelopable. The nature of local development in the immediate area is large family homes at a density of under 9 units per hectare. Development at 30 dwellings per hectare would be completely incompatible with the local character of the area and have a significant detrimental impact upon the heritage assets. If developed at a more appropriate density of 10 dwellings per hectare, combined these four sites would deliver only 30-40 dwellings in total, which would yield only 12-16 affordable units. The housing need in the District is heavily emphasised towards two and three bed homes and affordable housing. Such development would not be compatible with the local area, and given the physical constraints and obvious lack of accessibility/access to local services, the release of Sites AS05; AS07; AS08 and AS14 from the Green Belt should be resisted. There are clearly far more sustainable unconstrained locations that could deliver development tailored to local need inLeatherhead.

44Our major, general concern about this development would be the traffic implications identified above. However, if these implications were minimised in some way; the housing density restricted to a similar density that already exists in the area and the development kept in keeping with the character of properties in the surrounding area, then we could support such a development. Due to the density issue, we do not think that social housing would be appropriate on this particular site although we would like to see a contribution given to social housing in whatever agreements were made.

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34AS14The document does not make it clear that this site is adjacent to AS08.A review of a local map which indicates watercourses shows that the lake referred to as the source for The Rye. Changing from what amounts to a private lake to “an amenity” has the potential to impact on biodiversity along The Rye. This requires recognition in the assessments.

241.0The report refers to the pond on the land being half the size of

Ashtead pond. This tends to demine the importance of this feature. It is significant as the source of the Rye Brook. Building would endanger this natural water source. The value of the Pond should be considered in its own context and setting. Setting and role are more important than size.

2.0Land to the East is referred to as grazing land; this is actually the picturesque Woodcote Stud Farm.

3.0There is reference to derelict greenhouses which imply they are dilapidated, in fact these are still in use and in good condition and not at all derelict. The inference is that they are of no value please correct.

4.0The document states that there is a listed Ice house to the South East of the site which implies it is not on the site, whereas in fact it should state that there is a listed Ice house situated on the site located on the South east of the plot. This is misleading please correct.

5.0 You state “A drive from Farm Lane accesses the site and leads towards the existing house ‘The Pines’ although The Pines is not actually part of the site. There is also another small entrance from Farm Lane, without a driveway, at the far northern end of the site”. The small driveway is not a vehicular access and has never been used as such in the 20 or so years I have been a resident in this area. It is not made up as a road and has no kerbs suggesting a vehicular access. To say it is a driveway is misleading please correct. It was an informal footpath giving us access to the pond where we could fish until the present owner blocked it off. An apparently legal but antisocial act.

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6.0Under the heading relevant planning history you mention 2 planning applications related to the land in question in 1953 and 1979 both of which were refused. There have been more applications than this.

7.0Under the same paragraph you then go on to say “More recent planning history has been for domestic development associated with the existing dwelling”. I assume this refers to the current and recent modifications that have been approved at The Pines which you previously said is outside of the subject site, this is therefore irrelevant to the site in question and at worse it implies that some development has been permitted on the site when in fact The Pines is not on the site. This is grossly misleading and inaccurate and needs to be reworded to reflect the true position. A correct statement would be that a number of planning applications on the site have been refused in the past and no planning consents have been successful.

8.0Under the paragraph “Greenbelt Boundary Review” you state that there is a wall and a hedge along farm lane, this I assume is stated as to its importance in preserving the character of Farm Lane. The wall to the east of Farm Lane was limited in height by a planning ruling and the Leylandii were planted in defiance, reducing the amenity of the view across to the stud farm. However the fact that the hedge and the wall shield the views of the plot under consideration is of no relevance. It is the nature of the enclosure of Farm Lane in context with the Listed walls of the Nursery opposite that is very important. The listed walls also directly link and connect to the listed walls and listed Ashtead House and to the Bothys to the rear of the Old Headmasters House and therefore the continuity of these historical structures are of great value to the location. The wall on the site boundary under consideration lend their architectural form to the context and setting of the whole area. In addition this context is enhanced and extended further to the South where further listed walls surround the Park Farm a Grade 11* listed building. This is all understated in your comment on the site in context with the greenbelt and the paragraph is also misleading. I would be grateful if this was corrected.

9.0Without a new heading you then proceed to discuss The Pines with large field like lawns that lead down to an ornamental Pond. The Pines is not within the site and so is irrelevant to this document and the land you refer to as field like lawns is in fact the subject land and this is a grass field. The ornamental Pond implies it is a typical garden pond whereas in fact it is a more natural pond with earth banks and surrounded by native trees. Your description seems to be deliberately implying it is all a bit modern and manufactured whereas in fact it is a very natural looking habitat. As you say there

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are also non native species of trees but these are also surrounded by native species.

This should all be rewritten to be more truly representative of the actual setting.

10.0 The high brick walls that you refer to around Ashtead House are listed walls please check the listing documentation on MVDC planning records. This should be mentioned as this is an important feature of the area.

11.0 You conclude this paragraph with “One section is contiguous with the Epsom & Ewell Green Belt and owned by that Council. Development has already occurred along this border with Epsom Green Belt along Farm Lane and “filling-in” the remaining available spaces in the area does not appear to constitute a significant change in the merging status quo, therefore The Green Belt Boundary review considers merging in this area J3(East) to be minimal. It also considers encroachment to be minimal. With regard to setting and character the Green Belt Boundary Review considers this to be moderate”. This is so inaccurate. There is no development on the boundary, the nearest development on the Epsom and Ewell land is the Epsom Stud farm a considerable distance away and beyond this you have to go to the opposite side of Wilmerhatch Lane to see development this must be at least 500m away if not more. Your conclusion on merging needs to be seriously reconsidered. I suggest you discuss this with Cllr Tina Mountain (Epsom and Ewell) who is highly alarmed by the proposition for any change to the green belt along this boundary precisely due to the merging impact that could be created by such a move.

This paragraph needs to be reconsidered.

12.0 Access and travel issues – again reference is made to the high walls but no mention of these being listed structures.

13.0 You refer to City of London Freemans school as a “public “ school in the context it would be better referred to as a private school as it is only available to pupils who’s parents would be prepared to pay school fees. In the context your reference to public school implies accessible to everyone.

14.0 Nature conservation and Biodiversity – there are many species; deer, stoats, hedgehogs, grass snakes, there are also many birds of the Corvidae family including jackdaws, crows, rooks there are also Magpies, Jays, Woodpeckers, Yellow finches, greenfinches,

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blue tits, sparrows, etc etc that use the land and trees for nesting and as a habitat.

15.0 Your paragraph on biodiversity does not give any account of the value of this land to the wild life in the area although you do mention the fact that it provides a green corridor linking Ashtead Park to the fields to the east which themselves link eventually to The Downs.

16.0 The landscape character paragraph says very little yet makes a bold statement that the land cannot be seen except from a few houses towards Epsom. This feels like a very biased sweeping statement, there are houses along Farm Lane and in The Hilders that can see the Land, particularly if a development were to be allowed on Farm Lane and removal of the wall and hedge mentioned earlier were permitted. In any event if one accepts your statement that only a few houses can see the land this would justify its value as landscaping and so to then allow development would be a significant intrusion into this green corridor.

We do not need to be in our houses to see this land. The view is part of our regular walk to and from Ashtead Park.

17. “Final comments provided by the site promoter:

“The site is currently within the residential curtilage of “The Pines” house. The site is bounded to the North by housing and to the South by Ashtead Park Garden Centre and to the West by Farm Lane nurseries and residential development. The site could be considered infill between the housing to the North, the West and The Pines. There are no public rights of way or public access/egress to/from the site.” Editor’s note: The south eastern boundary is The Pines, which is north of the garden centre.”

The suggestion that the site could be considered as infill between the housing to the North, the West and The Pines is so contradictory in relation to the previous views expressed by MVDC planning department regarding the value and importance of preserving this piece of Ashtead as green belt and this needs to be considered. Why just include the views of the owner when actually the past history of unsuccessful planning applications related to this land have a greater relevance than the opinions of the landowner for this site.

Surely it is your duty to ensure this report is balanced by an expert opinion on such matters.

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18.0 Sustainability appraisal page 5Item 1 you state that the land is of sufficient size to support a range of housing types and tenures but earlier you state “How many dwellings can the site expect to deliver? Using the MVDC indicative density of 30 per hectare, this site could potentially provide up to 60 dwellings. However, the density of existing properties in this area is about 9 dwellings per hectare”. This implies up to 18 dwellings which would not allow a mix of housing types.

Your assessment of minor positive is questionable as the number of potential dwellings would not encourage a developer to build low cost units in such allocation.

19.0 Item 2 it is difficult to see how this can be minor positive when you have said access to the site is restricted, roads are narrow and no footpaths exist.

20.0 Item 4 (there is no item 3) Flooding. The site acts as a surface run off area down to the pond and the rising of the Rye Brook to buld and increase hard landscaping on the plot would change the run off conditions reducing soakage and would lead to greater volumes of surface water at peak rainfall times. This could increase the risk of flooding on the site. The land adjacent to this plot is also known to be very saturated and never dry in the winter months.

Changes to the water courses could impact on the ecology all the way along the Ryebrook from the site to Ashtead common.

A more detailed assessment is required to assess this risk, which could be more significant.

21.0 Item 5 is confusing, why would a development here improve accessibility to all services and amenities? Improve it compared to what?

Surely the problems described with the roads and lack of footpaths in the location mean that residents would tend to use their cars to use local amenities . This would result in a negative impact.

22.0 Item 8 Air Quality. In an environmental assessment of residential development the air quality is a function of the number of increased car journeys generated by the development. A development of say 18 houses would generate new cars of say 2 per dwelling on average. In traffic engineering the number of trips per day used to assess the impact of this is 5.5 trips per day per car so

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an increase in car movement would result in the order of 200 trips. These trips have an impact on air quality by their emissions which can be assessed. Therefore the impact on an area that currently has no cars would be very significant.

Perhaps you could consider this further and review your conclusion.

23.0 Item 10 Light pollution. Reference is made to the nearby garden centre as a source of light pollution, this operates at different times to the proposed residential development and would not be lit at night to the same degree, also the plot is what is being assessed not the nearby garden centre. The impact on the plot would be severe as street lighting and houses would be lit at night. Your conclusion needs to be reconsidered.

24.0 Item 11 see item 4 above.

25.0 Comments on conclusions

The transport issues need to be mentioned in the conclusion as these are a MAJOR issue.

16Comments on Site Assessments Site Ref: AS14 Site address: Land at The Pines, Farm Lane

Objections to ACV assessment: 1. General a. The site assessments could have been written by the property owner that has put the site forward. It contains statements by the site promoter but none by nearby residents. b. This assessment totally ignores the large number of comments that disagreed with the ACV GBBR for area J. This comprised a total of 81 of the total of 115 comments made on the ACV GGBR report, and only 40% of the total survey results that agreed with the report conclusions. c. The GBBR identified the ‘Contribution to Green Belt’ as Merging: Minimal, and Encroachment: Minimal. This is clearly not the view of the 81 responses referenced above.

2. Factual detail a. The ‘pond’ referred to is the source of Rye Brook. The Leatherhead and District Historical Society records: “Present day examination of the area does show the Rye rises behind Little Park Farm House in land belonging to the Pines. The spring is a possible site of worship for Celtic water deity along with Epsom's 'Earthbourne' and Ewell ponds”.

b. There is a statement: “Development has already occurred along this border with Epsom Green Belt along Farm Lane and “filling-in” the remaining available spaces in the area does not appear to constitute a significant change in the merging status quo, therefore The Green

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Belt Boundary review considers merging in this area J3(East) to be minimal. It also considers encroachment to be minimal. With regard to setting and character the Green Belt Boundary Review considers this to be moderate.

The vast majority of the people that responded to the survey and sent in comments strongly disagreed with the GBBR assessments and conclusion. I believe this area should be re-classified as: Merging: Significant – it is adjacent to Ashtead Park and the narrow ribbon of Green Belt between Ashtead and Epsom to the north. Encroachment: Significant – this area is fundamental to prevent encroachment to other areas of Green Belt land such as the area designated AS08 – Land at Rookery Hill and Farm Lane to the west, and area AS05 - Ashtead Garden Centre to the east. Setting and Character: Moderate – the site is adjacent to listed walls to the west and Ashtead House to the south. This area comprises the east part of area J3 as illustrated in the GBBR Appendix 2 for Area J1. Comments on Site Assessments Site Ref: AS14 Site address: Land at The Pines, Farm Lane

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c. Cycle routes: the statement that there are no cycle routes is not correct. There are no formally designated cycle routes as there are very few elsewhere in Ashtead, but Farm Lane is used by a significant number of cyclists at weekends travelling between the Box Hill area and the A24.

d. Flood risk: in addition to flooding in Farm lane at Ashtead House, there is significant flood risk from Rye Brook to properties immediately to the north. Rear gardens were flooded on at least 4 separate occasions in December-2013, and January 2014, and has occurred 2 to 3 times a year over the last 3-4 years. Run-off from a development at this site could severely increase flood risk to these properties.

e. Access and travel issues make no reference to the difficult junction at the end of Farm Lane to the A24.

f. There is no mention of impact on: i. Sewerage infrastructure that may not be suitable for a significant new development

ii. Narrow roads, tight bends and poor road junctions in this area. Comments on Site Assessments Site Ref: AS14 Site address: Land at The Pines, Farm Lane

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3. Sustainability Appraisal

I believe the appraisals are incorrect for the reasons given in the table below: SA Objective

Level of Compatibility Reason for change of assessment compared to ACV

ACV Assessment Local Residents Assessment 1. To provide sufficient housing to enable people to live in a home suitable to their needs and which they can afford.

Minor Positive Minor Negative This is a comparatively small site The issue of affordability is questionable in this area adjacent to large and expensive properties.

2. To facilitate the improved health and wellbeing of the whole population.

Minor Positive Minor Negative The nearest facilities are some distance away along narrow roads and sharp bends. Farm Lane does not have a footpath.

4. To minimise the harm from flooding.

Minor Negative Major Negative Potential significant increase of flood risk to properties along Rye Brook immediately to the north.

5. To improve accessibility to all services and facilities.

Neutral/ Negligible Major Negative Narrow roads, sharp bends, poor visibility at road junctions, no footpath to Ashtead village

6. To make the best use of previously developed land that is not of high environmental value and existing buildings.

Major Negative Major Negative Agreed

7. To reduce land contamination

Neutral/ Negligible Major Negative The source of Rye Brook is in the grounds of this property. This is a chalk aquifer.

8. To ensure air quality continues to improve.

Neutral/ Negligible Neutral/ Negligible Agreed

9. To reduce level of, and exposure to, noise pollution.

Neutral/ Negligible Minor Negative Affordable housing in this area will cause significant increase in noise pollution from ‘low noise levels within the residential areas adjoining the site’.

10. To reduce light pollution.

Minor Negative Major Negative No account is taken to impact on adjoining stud farm and stables immediately to the east. This will be intrusive in the wider

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landscape. 11. To improve the water quality of rivers & groundwater, and maintain an adequate supply of water.

Neutral/ Negligible Major Negative The source of the Rye Brook (chalk aquifer) is in the grounds of this property. Further development could have a significant impact on rivers and groundwater. Supply of potable water may also need to be increased.

12. To conserve and enhance biodiversity and networks of natural habitat.

Minor Negative Minor Negative Agreed

13. To conserve and enhance landscape character and features, the historic environment and cultural assets and their setting.

Major Negative Major Negative Agreed

14. To reduce the need to travel, encourage sustainable transport options and make the best use of existing transport infrastructure.

Minor Negative Major Negative Access to Ashtead station is along Farm Lane that does not have a footpath. The junction of Farm Lane with the A24 is particularly difficult at busy commuter times. Alternative access to Ashtead village via the Rookery is around narrow winding road also without footpaths.

16. Provide for employment opportunities to meet the needs of the local economy

Not applicable Not applicable Agreed

19. To increase energy efficiency and the production of energy from low carbon, renewable & decentralised generation systems

Neutral/ Negligible Neutral/ Negligible Agreed

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Comments on Ashtead Neighbourhood Forum paperGreen Belt Review22 November 2013 version 11aComments with reference to page numbers and headings:-1.0 P6 Public consultationReport notes that only 700 people responded to the surveys.The population of Ashtead in the census of 2001 was 13494.Therefore only 5% have commented and does not therefore properly represent the views of the residents of Ashtead.2.0 P6 Greenbelt CriteriaYou state that each of the sites is considered equal in terms of their importance in the prevention of urban sprawl and encouraging urban regeneration.I would argue that area J is for example much more sensitive in the context of limiting urban sprawl than say area G1 and G2. I therefore feel these criteria should be considered.3.0 P6 Survey results noted in Appendix 3You refer to the survey results in Appendix 3 on inspection these survey results provide results for Area A-I and do not include area J.Was area J included and identified in the survey as now reported upon ie as a stand-alone area made up of three pieces of land and if not the survey is not representative of the proposals now being tabled.4.0 P7 Sustainabilty CriteriaYou say MVDC identified 19 sustainability criteria but only used 9 when conducting the GBBR for the district, this criteria was followed by ACV.You then state that the other 10 criteria may ultimately be applied.What are the other 10 criteria as these may make a material difference to your conclusions when considering a local level issue rather than a district wide issue.5.0 P8 Green Belt Boundary ReviewYou state “The combined views of the residents of Ashtead and ACV on the potential for the development of ten areas of green Belt around Ashtead village.”And then assess each.However as Area J is not included in the survey results in Appendix 3 it appears that this section does not therefore represent the views of the residents.I therefore feel that Area J cannot now be included separately in the assessment, it should be included in the findings for area B as this is what the Ashtead community commented on in the survey. You are misrepresenting the views of the public.6.0 P41 Assessment of Area JContribution to green beltYou confirm that Area J was not included as separate from B in the survey. The assessment is therefore flawed and cannot be relied upon.In addition I disagree entirely that the merging impact would be minimal as the greenbelt separates the residential development of Farm Lane from the conservation area around Ashtead House and the listed walls around Ahstead House and the Bothys. At the time of securing planning for Little Park Farm the conservation officer for MVDC (if I recall correctly Mr Peter Mills) stated that the green belt land was of fundamental importance to maintain the break in residential development.

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In your comments on setting although you have identified area J as 3 areas but you have conveniently combined them to discuss the impact, there are different merits of each area and these are not considered. The assessment also makes no mention of the listed walls and buildings and the setting in relation to the conservation area.7.0 P42 Assessment of area JSustainabilityYou state that this is largely a developed site which is incorrect, you should really look again at the plan as there are two nurseries that are mainly undeveloped save for the relatively small commercial premises on these areas, the rest of the land is open space. The land belonging to the Pines is a residential garden of some 4.5 acres but this is open land, the Nursery in Farm Lane is largely open land with some glass houses and a small retail shop. The nursery is enclosed by listed walls that wrap around the very tight and restricted bends in the road. The Nursery in Pleasure Pit road is more developed but would also require a change of use removing an amenity enjoyed by local residents that also provides employment in the village. It also appears that the land also includes the Bothys that are also enclosed by the listed walls which include some reference to the history of the area and are therefore of importance.I feel you have ignored these very relevant points in your assessment.8.0 P 41 FloodingThe source of the Ryebrook rises in the corner of area J3, changing the permeability of the ground around this area would have an impact on the Ryebrook with further consequences to the stream along it’s course. This would potentially have an ecological impact in the wider area.9.0 P42 Light PollutionYour comments are disputed, light pollution will have a significant impact on what is currently a very low lit area of Ashtead.

10.0 P 42 Conservation areaIn a somewhat dismissive fashion you refer to the conservation area around Ashtead house a “small”. At the time it was designated a conservation area it was obviously considered to be of some value to the area as otherwise why make it a conservation area at all. Therefore this reinforces the point of it’s setting and separation from the “1930’s/1950’s urban sprawl” ( his words not mine) that was so important to Peter Mills MVDC conservation officer as mentioned earlier.11.0 P 43 ConclusionI obviously disagree with your conclusion and feel that you have not applied the same criteria to this land as to the other plots in your report. The fact that this plot was not identified separately from Area B when the public consultations took place mean they should be considered as part of Area B and not separately.Even then you have made errors in the assessment as noted above.

12.0 FootnotesNote 1I do not believe that Farm lane Nursery and the Bothy Area is under the same ownership as The Pines and The Pleasure Pit lane Nursery.

The land is not in an already developed area and is situated between a Grade II* listed building Park farm House that also has listed garden walls and the Conservsation area

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around Ashtead house which includes Listed boundary walls, a listed Ice House is also on the land, the Bothey site is listed as are the walls surrounding that and the Farm Lane Nursery.It makes me wonder if you have even been to look at the area as your opinions are so limited.Your comments on the traffic generated are also flawed, of course the traffic generated will be a function of how many houses are permitted but given that the object of this government led fiasco is to maximise the number of dwellings that can be built we can be sure it would not be a few homes. I believe MVDC guidance allows approx 30 homes per acre. There would therefore be a substantial number of houses. According to transportation consultants that I am working with a reasonable expectation would be 1.5 cars per dwelling. Therefore the maximum density of development could create some 300-450 cars on area J.This would result in substantially more vehicle movements at peak morning and evening rush hour on weekdays which would not match the peak hour traffic generated by the Garden centres which is unlikely to be at AM and PM peak hours. You conclusion cannot be correct unless a very few dwellings were proposed and this is contrary to the aims of this process. If you feel this site is only suited to a very small development it should not be put forward as it does not achieve anything.

Note 2The site is still very much an open space and the diversity of plants are all helping to provide a habitat for various ecology and wild life enriching the area.I would suggest that it is not what one would truly class as brownfield land. It should also not be overlooked that it is a local amenity and source of employment.The comment on reduced traffic is very a very biased assumption as noted above.Note 3 This site cannot be classed as a brownfield site. The site is enclosed and wooded and as you say has exotic plant species, it must contribute to the ecology of the area and more so than some of the other areas that were considered more important.

Note 4 Area J3The Land on either side of Farm Lane is in different ownerships.

Note 6The land is important as green belt because it links Ashtead Park and Ashtead Common to the Epsom BC greenbelt land which in turn links to the Downs. It is therefore of fundamental importance in protecting from merging.

13.0 General notes of concern.13.1 Look at the density of development that has occurred on our doorstep , the Epsom Hospital clusters, this is the nature and type of development you are inviting to happen in Ashtead. Dense development, small gardens, new roads into land that is currently green.13.2 If additional development is proposed the local schools, amenities and infrastructure will need to be assessed and enhanced.13.3 If this land is put forward the local roads will not be able to cope with a substantial increase in traffic.13.4 The risk is that a developer will only want to develop the maximum number of dwellings and is unlikely to settle for a small scale development.

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13.5 The double bends in the road around Ashtead House are not suited to a such an increase in traffic and my fear is that a new road will be cut across the land from Farm lane to Wilmerhatch Lane through The Pines plot and the Nursery plot on Pleasure Pit Road. This would then avoid the double bends being an issue but such an investment would only be supported by a large scale development.13.6 Residential developers make money by building houses, if they are encouraged by a government policy to max out the number of homes they will bit your arm off to build as many as possible. Even if this means going to planning several times and also going to appeal to the secretary of State for the Environment. We will have no control and no say on what is built, we might fight and argue and we could go on for years but in the end the planning system will allow whatever the developers can get away with. We should therefore not offer this land.13.7 Previous plans to develop the nursery site and the old stables at Ashtead House have been refused. Ashtead House application in 2006 for 8 dwellings was refused on the grounds of it being in a conservation area.13.8 If this land is offered it will then be on the radar and MVDC will have to consider it which for the reasons stated I believe would be a massive mistake for Ashtead and would lead to a change of character on one of the more interesting corners of the outlying parts of the village. Park Farm’s history goes back to the days when Samuel Pepys visited Ashtead and in this particular location the land has not changed much since those days, why spoil it now?13.9 Why are we even submitting this proposal, I do not believe the green belt can be looked at on a village/town by town basis, it was created to prevent the merging of “urban sprawl” in the governments own words. Therefore when viewed in isolation i.e. Ashtead as opposed to the whole of Mole Valley it may appear that some land could be given up, but when set against the overall context of the green belt in a whole area such as Mole Valley such proposals may not be appropriate. I am sure there will be many villages that simply have nothing that they feel can be considered for reclassification, and we should be saying the same. Having done the work that ACV has, there is nothing that says we now have to offer any land for removal from the green belt. In fact it would be more sensible to say we have reviewed the land and on balance any erosion of the green belt would be to the detriment of Ashtead.

If we offer land the only reward is a faster assessment of the revised local plan which will be Mole Valley local plan not just Ashtead, it makes absolutely no sense to offer something that is not essential and has no value to the village. All this does is accelerate the process and allows the sites that may be considered easy wins to be picked off first.

I would propose the plan is redrafted to confirm all plots considered have different merits and as such none are suitable for removal from the green belt. The two plots being offered through the ACV report do not stand out as suitable it is just by a subjective assessment that the conclusions you have reached are that there is a miniscule difference between these plots and any of the others. For all the reasons stated above if I encouraged a different group of people to review the plots I am sure we would come to different conclusions. If the land was clearly so obviously different to any other that was considered I would not have an argument but as it stands I think we are opening up a development nightmare that will do more harm to Ashtead than good and we don’t even have to propose anything according to the Government’s own internal briefing note copied below. We are under no obligation to offer anything.

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Extract copied from Parliamentary paper in House of Commons Library

Available in full at www.parliament.uk/briefing-papers/sn00934.pdf

Green Belt Standard Note: SN/SC/934 Last updated: 4 September 2013 Author: Louise Smith Section Science and Environment Section

Government policy on protection for the green belt is set out in chapter 9 of the National Planning Policy Framework (NPPF). The Government’s fundamental aim of green belt policy is to prevent urban sprawl by keeping land permanently open. The NPPF states that that the construction of new buildings should be regarded as “inappropriate” for the green belt, although there are some exceptions, which are listed. It is for local authorities to define and maintain green belt land in their local areas. The Government expects local planning authorities with green belts to establish green belt boundaries in their Local Plans. Green belt boundaries can be altered as part of the Local Plan review process. The Government has not announced any proposals to change green belt protection. In a written ministerial statement of 6 September 2012, however, it encouraged local councils to use existing laws to review the extent of green belt land in their local areas. As an incentive to use these powers, councils who review green belt land in their local plans will have their local plan examination process prioritised. This policy has been criticised by the CPRE.

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17.0 The report refers to the pond on the land being half the size of Ashtead pond. This tends to demine the importance of this feature. It is significant as the source of the Rye Brook. Building would endanger this natural water source. The value of the Pond should be considered in its own context and setting. Setting and role are more important than size.

18.0 Land to the East is referred to as grazing land; this is actually the picturesque Woodcote Stud Farm.

19.0 There is reference to derelict greenhouses which imply they are dilapidated, in fact these are still in use and in good condition and not at all derelict. The inference is that they are of no value please correct.

20.0 The document states that there is a listed Ice house to the South East of the site which implies it is not on the site, whereas in fact it should state that there is a listed Ice house situated on the

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site located on the South east of the plot. This is misleading please correct.

21.0 You state “A drive from Farm Lane accesses the site and leads towards the existing house ‘The Pines’ although The Pines is not actually part of the site. There is also another small entrance from Farm Lane, without a driveway, at the far northern end of the site”. The small driveway is not a vehicular access and has never been used as such in the 20 or so years I have been a resident in this area. It is not made up as a road and has no kerbs suggesting a vehicular access. To say it is a driveway is misleading please correct. It was an informal footpath giving us access to the pond where we could fish until the present owner blocked it off. An apparently legal but antisocial act.

22.0 Under the heading relevant planning history you mention 2 planning applications related to the land in question in 1953 and 1979 both of which were refused. There have been more applications than this.

23.0 Under the same paragraph you then go on to say “More recent planning history has been for domestic development associated with the existing dwelling”. I assume this refers to the current and recent modifications that have been approved at The Pines which you previously said is outside of the subject site, this is therefore irrelevant to the site in question and at worse it implies that some development has been permitted on the site when in fact The Pines is not on the site. This is grossly misleading and inaccurate and needs to be reworded to reflect the true position. A correct statement would be that a number of planning applications on the site have been refused in the past and no planning consents have been successful.

24.0 Under the paragraph “Greenbelt Boundary Review” you state that there is a wall and a hedge along farm lane, this I assume is stated as to its importance in preserving the character of Farm Lane. The wall to the east of Farm Lane was limited in height by a planning ruling and the Leylandii were planted in defiance, reducing the amenity of the view across to the stud farm. However the fact that the hedge and the wall shield the views of the plot under consideration is of no relevance. It is the nature of the enclosure of Farm Lane in context with the Listed walls of the Nursery opposite that is very important. The listed walls also directly link and connect to the listed walls and listed Ashtead House and to the Bothys to the rear of the Old Headmasters House and therefore the continuity of these historical structures are of great value to the location. The wall

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on the site boundary under consideration lend their architectural form to the context and setting of the whole area. In addition this context is enhanced and extended further to the South where further listed walls surround the Park Farm a Grade 11* listed building. This is all understated in your comment on the site in context with the greenbelt and the paragraph is also misleading. I would be grateful if this was corrected.

25.0 Without a new heading you then proceed to discuss The Pines with large field like lawns that lead down to an ornamental Pond. The Pines is not within the site and so is irrelevant to this document and the land you refer to as field like lawns is in fact the subject land and this is a grass field. The ornamental Pond implies it is a typical garden pond whereas in fact it is a more natural pond with earth banks and surrounded by native trees. Your description seems to be deliberately implying it is all a bit modern and manufactured whereas in fact it is a very natural looking habitat. As you say there are also non native species of trees but these are also surrounded by native species.

This should all be rewritten to be more truly representative of the actual setting.

26.0 The high brick walls that you refer to around Ashtead House are listed walls please check the listing documentation on MVDC planning records. This should be mentioned as this is an important feature of the area.

27.0 You conclude this paragraph with “One section is contiguous with the Epsom & Ewell Green Belt and owned by that Council. Development has already occurred along this border with Epsom Green Belt along Farm Lane and “filling-in” the remaining available spaces in the area does not appear to constitute a significant change in the merging status quo, therefore The Green Belt Boundary review considers merging in this area J3(East) to be minimal. It also considers encroachment to be minimal. With regard to setting and character the Green Belt Boundary Review considers this to be moderate”. This is so inaccurate. There is no development on the boundary, the nearest development on the Epsom and Ewell land is the Epsom Stud farm a considerable distance away and beyond this you have to go to the opposite side of Wilmerhatch Lane to see development this must be at least 500m away if not more. Your conclusion on merging needs to be seriously reconsidered. I suggest you discuss this with Cllr Tina Mountain (Epsom and Ewell) who is highly alarmed by the proposition for any change to the green belt along this boundary precisely due to the merging impact that could be created by such a move.

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This paragraph needs to be reconsidered.

28.0 Access and travel issues – again reference is made to the high walls but no mention of these being listed structures.

29.0 You refer to City of London Freemans school as a “public “ school in the context it would be better referred to as a private school as it is only available to pupils who’s parents would be prepared to pay school fees. In the context your reference to public school implies accessible to everyone.

30.0 Nature conservation and Biodiversity – there are many species; deer, stoats, hedgehogs, grass snakes, there are also many birds of the Corvidae family including jackdaws, crows, rooks there are also Magpies, Jays, Woodpeckers, Yellow finches, greenfinches, blue tits, sparrows, etc etc that use the land and trees for nesting and as a habitat.

31.0 Your paragraph on biodiversity does not give any account of the value of this land to the wild life in the area although you do mention the fact that it provides a green corridor linking Ashtead Park to the fields to the east which themselves link eventually to The Downs.

32.0 The landscape character paragraph says very little yet makes a bold statement that the land cannot be seen except from a few houses towards Epsom. This feels like a very biased sweeping statement, there are houses along Farm Lane and in The Hilders that can see the Land, particularly if a development were to be allowed on Farm Lane and removal of the wall and hedge mentioned earlier were permitted. In any event if one accepts your statement that only a few houses can see the land this would justify its value as landscaping and so to then allow development would be a significant intrusion into this green corridor.

We do not need to be in our houses to see this land. The view is part of our regular walk to and from Ashtead Park.

18. “Final comments provided by the site promoter:

“The site is currently within the residential curtilage of “The Pines” house. The site is bounded to the North by housing and to the South by Ashtead Park Garden Centre and to the West by Farm Lane nurseries and residential development. The site could be considered infill between the housing to the North, the West and The Pines.

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There are no public rights of way or public access/egress to/from the site.” Editor’s note: The south eastern boundary is The Pines, which is north of the garden centre.”

The suggestion that the site could be considered as infill between the housing to the North, the West and The Pines is so contradictory in relation to the previous views expressed by MVDC planning department regarding the value and importance of preserving this piece of Ashtead as green belt and this needs to be considered. Why just include the views of the owner when actually the past history of unsuccessful planning applications related to this land have a greater relevance than the opinions of the landowner for this site.

Surely it is your duty to ensure this report is balanced by an expert opinion on such matters.

26.0 Sustainability appraisal page 5Item 1 you state that the land is of sufficient size to support a range of housing types and tenures but earlier you state “How many dwellings can the site expect to deliver? Using the MVDC indicative density of 30 per hectare, this site could potentially provide up to 60 dwellings. However, the density of existing properties in this area is about 9 dwellings per hectare”. This implies up to 18 dwellings which would not allow a mix of housing types.

Your assessment of minor positive is questionable as the number of potential dwellings would not encourage a developer to build low cost units in such allocation.

27.0 Item 2 it is difficult to see how this can be minor positive when you have said access to the site is restricted, roads are narrow and no footpaths exist.

28.0 Item 4 (there is no item 3) Flooding. The site acts as a surface run off area down to the pond and the rising of the Rye Brook to buld and increase hard landscaping on the plot would change the run off conditions reducing soakage and would lead to greater volumes of surface water at peak rainfall times. This could increase the risk of flooding on the site. The land adjacent to this plot is also known to be very saturated and never dry in the winter months.

Changes to the water courses could impact on the ecology all the way along the Ryebrook from the site to Ashtead common.

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A more detailed assessment is required to assess this risk, which could be more significant.

29.0 Item 5 is confusing, why would a development here improve accessibility to all services and amenities? Improve it compared to what?

Surely the problems described with the roads and lack of footpaths in the location mean that residents would tend to use their cars to use local amenities . This would result in a negative impact.

30.0 Item 8 Air Quality. In an environmental assessment of residential development the air quality is a function of the number of increased car journeys generated by the development. A development of say 18 houses would generate new cars of say 2 per dwelling on average. In traffic engineering the number of trips per day used to assess the impact of this is 5.5 trips per day per car so an increase in car movement would result in the order of 200 trips. These trips have an impact on air quality by their emissions which can be assessed. Therefore the impact on an area that currently has no cars would be very significant.

Perhaps you could consider this further and review your conclusion.

31.0 Item 10 Light pollution. Reference is made to the nearby garden centre as a source of light pollution, this operates at different times to the proposed residential development and would not be lit at night to the same degree, also the plot is what is being assessed not the nearby garden centre. The impact on the plot would be severe as street lighting and houses would be lit at night. Your conclusion needs to be reconsidered.

32.0 Item 11 see item 4 above.

33.0 Comments on conclusions

The transport issues need to be mentioned in the conclusion as these are a MAJOR issue.

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