29 August 2017
The Council is working on a new Local Plan which will set the strategy for the development of homes and businesses until 2033.
[Until 1 Sept: Let the Council know your views by 1 September by sending them to planning.policy@molevalley.gov.uk or Planning Policy Team, Mole Valley District Council, Pippbrook, Dorking, RH4 1SJ.]
The Mole Valley Green Party says:
Read our full response below :
MVEEGP RESPONSE to the Future Mole Valley consultation August 2017
1. The South East economy has resulted in the region being densely populated. This brings congestion; air, noise and light pollution; pressure on water resources; and higher risk of flooding. Local authorities have a duty to bring pressure to bear on Central Government to share the benefits and burdens of the economy fairly throughout the UK, and to ensure the economy supports the environment, and health and well-being.
2. We feel organizations such as Mole Valley District Council, Surrey County Council, and the Local Government Association, could and should do much more to influence Central Government to rebalance the UK economy.
3. However, we recognize that such an economic rebalancing will not be accomplished quickly, and that in the meantime there will be a need for additional housing in the South East. Below are the points we believe should guide MVDC in its Local Plan development in this context.
4. Some of the points may be more relevant to later stages of the Local Plan development process, so please ‘reuse’ any points from this response in later consultations as necessary.
5. The Council is right to aim for housing numbers lower than the OAN (objectively assessed needs), because of constraints in Mole Valley such as the high proportion of protected areas (including AONB).
6. A principle underpinning Local Planning and housing policies should be the reduction of inequality, including the inequality of access to resources such as green space and transport.
7. It is disappointing that a section of the consultation focusing on ageing populations is restricted to the rural villages section and talks about the negative impact of older people. It says the ageing population contributes to a loss of local facilities such as shops and pubs, and a loss of sense of community because of the reduction in participation in local sports and social clubs. Evidence for these statements should be published. They are contrary to common sense and appear ageist (surely older, retired people make more use of social clubs than younger people). The ageing population is a fact and the Local Plan should embrace the challenge this presents with a positive outlook, not present older people in negative terms. There should be a section about planning for older people, including their social as well as health needs in both old age with good health, and old age with declining and poor health.
8. Likewise, particular attention should be given in the Local Plan to the needs of younger people for whom the affordability of housing is a particular challenge in Mole Valley.
9. We are concerned that too much power has in the past been placed in the hands of private developers and led to the under-provision of affordable housing and other community benefits. MVDC should adopt a policy of ensuring all viability assessments are published for public inspection, and of requiring maximum developer profits of 15%.
10. The Local Plan should be accompanied by a delivery strategy, which sets out not only the scale and location of anticipated development, but also the likely sequence of development, and wider changes required to meet the Plan’s objectives. Both the Local Plan and its delivery strategy should be underpinned by a rigorous evidence base.
11. The Local Plan should also consider the need for and provision of green burial sites.
12. As part of the Local Planning process, a retail strategy should be drawn up, together with a retail regeneration plan which would aim to prevent high streets from domination by formula businesses and ensure fair market access for small, independent retailers, and to allow street markets and farmers markets to thrive. Consideration should be given to the introduction of Business Conservation Areas that would empower local communities to retain the character and amenity of their high streets, and bar formula retailers from certain areas, and enable the planning authority to use the planning process to influence the retail mix in the district. Fifty percent of retail floor space in any new retail development should be affordable space for local small businesses; and the Local Plan should look to encourage the pedestrianisation of shopping areas in the District’s towns and villages.
13. It is affordable housing which is needed in the district. The Council should be aiming for close to 100% of housing development being affordable (which includes affordable social/cooperative housing), and work with social housing providers and others to achieve this.
14. Consideration should be given through the Local Plan process to how to foster Lifetime Neighbourhoods, which offer everyone the best possible chance of health, well-being and social, economic and civic engagement regardless of age. The Local Plan should seek to identify deficiencies in the components of a lifetime neighbourhood in existing settlements – for example areas with little access to open space and nature - and plan for redressing these.
15. Adequate provision for Gypsy, Roma and Travellers' communities is also urgently needed, and it is disappointing that Future Mole Valley is currently silent on this.
16. Provision should also be made for the development needs of refugees.
17. Consideration should be given to the needs of people with disabilities.
18. Mole Valley should support neighbouring local authorities with the housing of and provision of services to homeless people, including those fleeing domestic violence, and ex-offenders. The District has a relatively large amount of high quality green space compared to other nearby authorities, a factor which can support good mental health, and we are in a privileged position to support people with significant mental health challenges.
19. Provision should be made in the plan for co-housing and self-build and custom-build homes.
20. Housing professionals should support the planners as the Local Plan is developed.
21. It is also vital that transport planners play a part in this process, to increase the likelihood of a shift away from the use of private motorized vehicles. We find it shocking that no traffic surveys have been conducted by Surrey County Council to find out the transport needs of the drivers who regularly sit jammed on Mole Valley roads such as Westcott Road in Dorking, thereby failing to support a shift to less environmentally- and socially-harmful transport. Any Local Plan development must proceed in tandem with plans to reduce the impact of the private car and improve the non-car transport options for people in villages.
22. MVDC should consider innovative funding models, housing policies and land acquisition practices to support the objectives of the Local Plan (for example bye-laws outlawing the use of dwellings as second homes in the District; the use of compulsory purchase to assemble areas with fragmented ownership and buy the land at existing use value; the creation of Community Land Trusts; more proactive use of Empty Dwelling Management Orders).
23. Where owners of land designated for development in the Local Plan fail to bring it forward for development in a timely manner (land hoarding), the District Council should exercise compulsory purchase orders in the public interest.
24. Any development should make good use of the space available, but the quality of any development is also of paramount importance. Design should be in line with evidence-based principles approved by expert organizations such as the Design Council. Design should contribute to health and well-being – so meet the ‘Parker Morris’ space and Lifetime Homes and comfort standards so that homes are places of retreat, have good access to green space, where good-quality walking and cycling routes and public transport are the default modes of transport, where development provides for people with disabilities, is sensitive to wildlife and supports improved biodiversity and wildlife corridors, makes the most of natural resources to generate renewable energy, is zero-energy or as close as possible to ZED-standards to keep energy bills and climate impact low, is designed to avoid overheating during hot weather, supports low water usage and contributes minimally to light pollution, minimizes the loss of permeable surface and increases it where possible, complements the character of the area, and blends with the landscape. New green and blue infrastructure is not only cost-effective, it is also often good for air quality, biodiversity and health. Consideration should be given to how new developments will support greenhouse gas reduction targets. Any parking spaces in new developments should include electric car charging points. Developments should not obscure or unduly disrupt popular viewpoints from local amenities such as parks or hills or footways, and should be broadly consistent with the height of existing buildings in the local environment.
25. One of the ambitions of the Local Plan should be to identify opportunities for new flood defences.
26. Another ambition should be the greening of the Green Belt – for example, supporting it to become more biodiverse -and the Local Plan should identify steps to achieve this.
27. The Local Plan should seek to enhance the special historical character of conservation areas.
28. Developers should be required to provide freehold, commonhold or co-operatively owned homes; no leasehold should be permitted for residential development.
29. Wildlife surveys, not desk-based research, are needed to assess any sites which are proposed for development, including brownfield sites, which, because of climate change, may now provide valuable habitat, or important wildlife corridors. Adequate funding and time are needed for high-quality surveys.
30. Assessments to assist with the Local Plan process should include specific ones to focus on local ecology and ecosystems services, the historic environment, and, our changing climate. Overheating in urban areas is a problem that is set to get worse with our changing climate. The Local Plan should identify areas subject to a significant urban heat island effect and set targets for urban greening to cool the air. We recommend a housing stock condition survey is completed to assess the existing stock against the future needs of the District, and quality standards, so the Local Plan can take into account findings as necessary (for example the need to provide new rather than retrofit housing to bring homes up to necessary standards.)
31. Support for the ‘Rent a Room’ scheme may provide more accommodation, and reduce the need for development. MVDC should consider setting up a brokerage service to encourage and support more lodging.
32. Services and facilities such as schools, health centres, community centres, public green spaces, leisure facilities, shops, footways, cycle routes, public transport connections and roads must also be factored in to the Local Plan process. We appreciate that the current planning approach is to consider these elements at a later stage of the Local Plan process. But many people find this approach difficult to understand particularly given the provision of these assets is insufficient in many areas currently, before proposals for additional development are put forward.
Previously-developed sites
33. MVDC is right to look first for previously-developed sites to meet housing need. The South East is densely populated in comparison to many other parts of the UK; a relatively high proportion of land area is already taken up by development; and the protection of the farmland which remains will support the provision of low food-mile produce and the creation of community farm projects.
34. MVDC needs to be proactive in searching out suitable previously-developed land and not just wait for developers to come forward. The Council should proactively approach British Telecom about the building in Dorking which is out-of-keeping with the character of the town, and, larger than is now needed by BT because of technological advancements.
35. It should also make good use of small sites, which are often overlooked or undervalued by land availability assessments.
36. We agree with the concept of looking to make better use of urban areas first, but also agree that there must be a limit to the amount of development here in order that the quality of life is not reduced.
37. Consideration should be given to the redevelopment of town centre sites to make better use of the space and to provide high-quality housing which meet the criteria above (at paragraph 24).
38. Existing publicly-accessible green space should be protected: easily accessible green space in urban areas is vital for health and well-being of urban communities, particularly those of limited mobility and low income. Because of this, reallocation of recreation land and open space should be ruled out. Moving publicly-accessible green space from central areas to areas on the edge of the urban spaces, would make it less accessible, and widen further inequalities between higher and lower socio-economic groups.
39. MVDC should further investigate the ‘stack and wrap’ technique of converting surface-level parking into multi-storey structures with flats above, which we believe could provide high-quality affordable housing in central locations close to public transport and other amenities. Careful design would be needed to ensure vehicle emissions are vented so as not to endanger public health, and in order that structures blend in to the townscape (unlike Church Court which draws the eye when Dorking is viewed from the North Downs). Similarly, consideration should be given to adding further storeys to existing developments. Any ‘stack and wrap’ developments or addition of storeys to existing buildings should be broadly consistent with the height of buildings in the area, and not obscure or disrupt popular viewpoints.
40. We recognize that the evidence shows there is a small over-supply of commercial and retail land, and we agree that the reallocation to housing of this protected employment site over-supply should be considered.
Greenfield Release
41. Although, as mentioned above, we believe it is imperative that the economy is rebalanced in order that the benefits and burdens of the economy are more equally shared across the UK, we recognize that in the short-term, additional development is needed in Mole Valley, and that Greenfield Release may play a part in the mix of solutions.
42. We agree that land designed as Area of Outstanding Natural Beauty, High Landscape Value, Special Protection Area, Special Area of Conservation, Sites of Special Scientific Interest, Ancient Woodland, common land and High Nature Conservation Importance should not be identified in the Local Plan for development.
43. The character of the Green Belt should be protected, and changing the boundaries of the Green Belt should happen only in very exceptional circumstances for example in cases where the site in question would not now be designated as Green Belt, and only to provide affordable housing for key workers.
44. Where there is land which carries none of these special designations, which is outside the area subject to high levels of aircraft noise, and which is close to a railway station or the railway line, we suggest consideration is given to working with s to explore the idea of an eco village , which could provide the types of affordable-housing and Lifetime Neighbourhood development to the standards mentioned above in paragraph 24, which is well connected to the rail network and would put less pressure on existing road infrastructure such as the A24 and A25 than would developments in areas presenting more challenges for the use of sustainable transport. It would also allow for some bigger-scale green infrastructure, such as combined heat and power generation, ground-source heat pumps, reed bed water recycling, sustainable urban drainage systems, and anaerobic digestion of waste for the village. The same tests would be required, as mentioned above, including full wildlife surveys, not desk-based research, to ensure these areas have not become important wildlife sites or are likely to do so with the acceleration of climate change. We question the statement that the construction phase would need to happen over a number of years, and suggest that MVDC aims to work with a group of private, cooperative, charitable and publicly-owned companies building on small parcels simultaneously, in order that the housing is provided quickly, that the settlement establishes itself as a social unit more swiftly, and to spread eco-building expertise across a range of developers.
45. We do not favour and are likely to oppose extensions to the urban area which risk adding to the traffic pressures already experienced in our urban spaces, and which could not be achieved in most cases without development of the Green Belt. However, village extensions for affordable housing should be permitted if there is proven local support and identified village need, and development is in keeping with the character of the area. Use of Community Land Trusts should be considered for this kind of development.
