S E Plan comments form

Draft South East Plan

Comments Form

Office Use Only

Respondent No:

Comment No:

Date Received:

Acknowledged:

If you wish to comment on the Proposed Changes to the Draft South East Plan please:

· Complete all relevant details in Section A – this need only be done once irrespective of how many parts of the RSS you wish to comment on.

· Complete a separate page 2 of the form for each part of the RSS you wish to comment on. Ensure you insert your organisation name (or surname if responding as an individual) on each page 2 and complete Sections B, C & D. You may make copies of this form.

· Type or print clearly in black ink.

· Note that all comment forms will be made available for the public to read – they cannot be treated as confidential.

· E-mail or post (please do not send duplicates) the completed forms to be received by the Government Office for the South East before 5.00pm on Friday 24 October 2008.

· Alternatively an electronic consultation form is available at www.gose.gsi.gov.uk/planning/regionalPlanning

Please send all responses to:

Regional Spatial Strategy Team

Government Office for the South East

Bridge House

1 Walnut Tree Close

Guildford, GU1 4GA E-Mail: rss@gose.gsi.gov.uk

Telephone: 01483 882532

Fax: 01483 882489

Section A

Comments submitted by: Agent (if applicable):

Organisation Organisation

Surname Surname

Title/first name Title/first name

Address Line 1 Address Line 1

Address Line 2 Address Line 2

Address Line 3 Address Line 3

Postcode Postcode

E-Mail E-Mail

Tel. (day) Tel. (day)

Fax Fax

To ensure your comments are taken into account this form must be completed and received by 5.00pm on Friday 24 October 2008.

Signature………………………………………………………………. Date……………………………..

Would you like to be notified of the publication of the final South East Plan?

(Copies will be available to purchase from the Stationery Office, and will be available to download free of charge from the Government Office Website)

Comments from (organisation, or surname)………………………………………………………………

Section B

Support / oppose/ comment (please specify) Object

Proposed Change Number (e.g. Chap 1 (01)) Chapter 4 (11)

Paragraph No. - for comments on Sustainability Appraisal/Habitats Regulation Assessment Report

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Section C

To help us process your response effectively please summarise why you support or oppose the Proposed Change: DESIGNATION OF THE 3 SURREY HUBS AS ‘CENTRES OF SIGNIFICANT CHANGE’

We have doubts on the suitability of designating Guildford, Woking and Redhill-Reigate as growth hubs, as the basis for the original hub designations was as transport interchanges not as centres of housing and economic growth. All centres are constrained by limitations of transport capacity, supporting services and environmental limitations. There have been no detailed studies to justify these designations. We therefore object even more strongly to the fact that all 3 Surrey hubs have been designated as ‘Centres of Significant Change’ where even more proactive development is envisaged. (This amounts to a quarter of all such designations in the whole of the South East Region).

Redhill-Reigate is inappropriate for the proposed scale of growth because of the lack of road and rail capacity, the lack of good public transport links, the proximity of the larger existing centres of Crawley and Croydon, the narrowness of the Green Belt and Area of Outstanding Natural Beauty, and the potential lack of water. Town centre growth at Redhill is restricted by the location of the mainline railway, and the A25 and A23. Development in Reigate is restricted in the centre by the need to preserve and enhance this historic core.

No environmental capacity studies have been done to illustrate how Redhill-Reigate can be developed as a centre for Significant Change.

Section D1

If you wish to expand your response please use the space below, and attach additional sheets if necessary with your name on.

Section D2

If you are suggesting changes to the draft plan please supply revised wording of policies or supporting text as you wish to see them:

Delete references to Guildford, Woking and Redhill-Reigate as ‘Centres of Significant Change’.

Please ensure that you have written your name at the top of the page and any additional pages. Completed forms should be received in the Government Office for the South East by 5.00pm on Friday 24October 2008. Late responses will not be accepted.

Comments from (organisation, or surname)………………………………………………………………

Section B

Support / oppose/ comment (please specify) Object

Proposed Change Number (e.g. Chap 1 (01)) Chapter 4 (14)

Paragraph No. - for comments on Sustainability Appraisal/Habitats Regulation Assessment Report

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Section C

To help us process your response effectively please summarise why you support or oppose the Proposed Change: LOSS of GREEN BELT

We strongly oppose the need for Green Belt boundary changes in the 4 Surrey locations listed – namely to the North East of Guildford, South of Woking, the DERA site and possibly around Reigate-Redhill. Over the whole of the South East Region, only 5 locations are specifically listed for review and 4 of these are in Surrey. The Green Belt in all these areas performs the essential functions of preventing urban sprawl and coalescence of settlements. None of the locations mentioned is sustainable.

We are particularly concerned about the loss of Green Belt in the District of Reigate and Banstead. Near Redhill, the Green Belt and the Area of Outstanding Natural Beauty are at their narrowest. Any development would lead to the loss of strategic gaps, the building over of beautiful countryside and result in increased sprawl around London and the coalescence of settlements. Road, rail and transport services are already at capacity. The Government’s proposal for 11,240 extra housing is excessive. This is by no means a ‘most sustainable location’ bearing in mind the environmental impact. No capacity studies have been carried out or justification provided for the scale of development proposed, bearing in mind the harmful loss of Green Belt and impact on the quality of life for local residents.

Section D1

If you wish to expand your response please use the space below, and attach additional sheets if necessary with your name on.

Section D2

If you are suggesting changes to the draft plan please supply revised wording of policies or supporting text as you wish to see them:

In the first paragraph, as the strategic gap policy is recommended for deletion (Chapter 20 (11), after ‘supported’ add a new sentence:-

‘Its role in preventing settlements from coalescing and in avoiding sprawl around London is of particular significance in this region.’ Delete ‘and’ and make a new sentence beginning ‘The opportunity…….’

In the 3rd paragraph, delete ‘including around Redhill-Reigate’

Modifications will similarly be necessary to Chapter 20 (11)

Comments from (organisation, or surname)………………………………………………………………

Section B

Support / oppose/ comment (please specify) Object

Proposed Change Number (e.g. Chap 1 (01)) Chapter 5 (21)

Paragraph No. - for comments on Sustainability Appraisal/Habitats Regulation Assessment Report

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Section C

To help us process your response effectively please summarise why you support or oppose the Proposed Change: LACK OF SUPPORTING INFRASTRUCTURE

The changes make no clear commitment to improve the infrastructure before or during commencement of development. What guarantee is there that better management of the existing infrastructure or ‘demand management’ will work? – they have not in the past. The road and rail network cannot cope at peak periods and the public transport system is poor. Public health, social services, community facilities and the education system are already inadequate. Services have not been improved in the past to support increases in dwelling numbers. Water supply is a concern, particularly with global warming.

In addition, it is proposed that the new targets will be minimum not maximum figures, and ‘windfalls’ which make up a high proportion of new building completions, will be excluded (at least in the initial stages of the Plan period). This means the impact on the infrastructure will be greater than suggested by the proposed target of 11,240 new dwellings over the 20 year period.

Section D1

If you wish to expand your response please use the space below, and attach additional sheets if necessary with your name on.

Section D2

If you are suggesting changes to the draft plan please supply revised wording of policies or supporting text as you wish to see them:

We request that the text reverts back to the original wording:- ‘The scale and pace of development will be dependent on there being sufficient capacity in the existing infrastructure to meet the area’s current needs and the provision of new infrastructure.’

Plus the reinstatement of policy iii under the heading ‘To achieve this’ which reads ‘Development shall not proceed until the relevant planning authorities are satisfied that the necessary infrastructure required to serve the development is available or will be provided in time.’

Comments from (organisation, or surname)………………………………………………………………

Section B

Support / oppose/ comment (please specify) Object

Proposed Change Number (e.g. Chap 1 (01)) Chapter 7 (4)

Paragraph No. - for comments on Sustainability Appraisal/Habitats Regulation Assessment Report

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Section C

To help us process your response effectively please summarise why you support or oppose the Proposed Change: PROPOSED NEW HOUSING TARGETS

We strongly object to the Government’s proposed increases in Guildford, Woking, Runneymede and particularly Reigate and Banstead. In the case of the latter, the increase from 7,740, which was based on detailed capacity studies, to 11,240, a 45% increase, without any analysis of the environmental implications, infrastructure requirements and transport network capacity, is both unrealistic and unjustifiable. At this level of increase, the character of our towns and villages will deteriorate and the quality of life of local residents fail. Moreover, this is likely to be a minimum figure which excludes windfalls, compounding the problem.

We strongly disagree with the term ‘hub of all hubs’ for Redhill-Reigate. Detailed studies will show deficiencies in the mainline railway, a very congested road network, inadequate bus services and poor interchanges, a lack of services and supporting infrastructure. R&B produced high levels of housing in past years and cannot be expected to continue building at ever higher rates. The application to be ‘a new growth point’ was based on bringing existing housing proposals forward and not increasing the overall total. The area is already near capacity.

We support additional affordable housing, not the scale of market housing.

Section D1

If you wish to expand your response please use the space below, and attach additional sheets if necessary with your name on.

Section D2

If you are suggesting changes to the draft plan please supply revised wording of policies or supporting text as you wish to see them:

Reinsert the Panel’s recommended housing figure of 9,240 (which is already higher than the well justified original of 7,740) in Table H1b and Table 7. Reduce London Fringe housing requirements. Delete reference to ‘minimum’ targets in H1b. Changes also to Chap. 20 (6)