Hill House Tattenham Corner Road Epsom KT18 5PP

Click here to see map for location of Hill House at Tattenham Corner

26/00989/FUL Demolition of dwelling and outbuildings. Erection of 3no. detached houses, provision of parking and associated access, landscaping, refuse and cycle store.

This application demolish an existing dwelling and its outbuildings next to the race course to replace them with three detached houses in part of the Green Belt on the Epsom Downs. The proposals raise a number of interlinked planning issues discussed at length in the response submitted using the comment facility on the EEBC Planning website as below:-

“I am writing on behalf of the Epsom Civic Society. The ECS makes the following representations.

Development in the Green Belt and the delivery of housing.

The proposals raise a number of interlinked planning issues. The site lies within the Green Belt and consideration is required as to whether the site comprises “grey belt” land and whether the proposal would be inappropriate development in the Green Belt, having regard to the NPPF.

For the purposes of plan-making and decision-making, ‘grey belt’ is defined as land in the Green Belt comprising previously developed land and/or any other land that, in either case, does not strongly contribute to any of purposes (a), (b), or (d) in policy GB2.

  • a. Check the unrestricted sprawl of large built-up areas;
  • b. Prevent neighbouring towns merging into one another;
  • d. Preserve the setting and special character of historic towns.

While the applicant asserts the land may be considered as “grey belt” it remains within the Green belt where further tests as to the appropriateness or otherwise of development apply.

The NPPF states at GB7 (Development which is not inappropriate in the Green Belt)

1. The following categories of development are not inappropriate in the Green Belt, and therefore should not be regarded as harmful to the Green Belt or be required to demonstrate very special circumstances:

  • e. The redevelopment of previously developed land (including a material change of use to residential or mixed-use including residential), which would not cause substantial harm to the openness of the Green Belt;
  • g. Development where all of the following apply:
    • i. The development would utilise grey belt land and would not fundamentally undermine the purposes (taken together) of the remaining Green Belt across the area of the plan;
    • ii. There is an evidenced unmet need for the type of development proposed;
    • iii. The development would be in a sustainable location, with particular reference to policy TR3 of this Framework
  • h. Residential or mixed-use development which would:
    • i. Be within reasonable walking distance of a well-connected station (applying the definitions in the glossary at Annex B)

The ECS considers that the proposals fail to fulfil NPPF objectives as follows.

It is considered that the proposals would materially increase the bulk and massing of buildings on the site. It may be judged that the harm caused to the openness of the Green Belt would be substantial, thereby failing 1e.

Alongside Green Belt policies the NPPF sets out overarching objectives including L3 – Achieving Appropriate densities. The NPPF requires that development proposals should make efficient use of land, taking into account factors including the identified need for different types of housing and other development, local market conditions, and transport accessibility. Given the more flexible approach to accommodating development within the green belt tensions requiring careful resolution will inevitably arise between those policies seeking to maintain and protect the openness of the green belt with those that are supportive, under identified conditions, of new development including housing.

If the Council agrees with the applicant’s assertion that the land may be defined as “grey belt” and that it is in a sustainable location being close to a well-connected station (GB7 h(i)), then a further test, whether there is evidenced unmet need for the type of development proposed, needs to be applied alongside . The ECS considers that this is an area where tension arises between maintaining openness and making efficient use of land. The ECS acknowledges there is a need for housing. However, whether this warrants giving such weight to endorsing dwellings the size of those proposed and whether there is evidenced unmet need, as opposed to simply a commercial market for larger dwellings, warrants further examination. If the Council is minded to support development then the ECS would strongly urge the Council to give further and careful consideration as to whether alternative and more discreet forms of development would resolve the tensions between the objectives of the NPPF noted above.

Design and appearance.

As at 26th October the Council’s web site is not displaying elevations to any of the proposed dwellings. The ECS would request that they are notified when the elevations appear and that further time is provided for comments to be made.

Trees.

As at 26th October the Council’s web site is not displaying the trees constraints plan. The ECS would request that they are notified when the drawing appears and that further time is provided for comments to be made.

Access.

The site lies on the fringe of Racehorse Movement Corridors with access to plot 3 achieved only through crossing one such corridor. The draft Local Plan in the supporting text to policy DM.8 acknowledges that there is the potential for conflict between racehorses and other road users along parts of some routes. DM8 states that “any proposals, regardless of the type of development, should demonstrate that it they will not adversely affect the Racehorse Movement Corridor, as defined on the Policies Map, in terms of the safety of racehorses travelling between training yards and the training grounds and the racing stable yards by virtue of the traffic generation from or the design of the development and provide mitigation where there is an impact.

The ECS remains to be persuaded that adequate consideration has been given to fulfilling the above requirements and would question whether the requirements of the policy can in fact be met simply by attaching a condition in the event that the Council is minded to support the proposals.