A Proposal from Chris Grayling MP

Epsom and Ewell Borough Council is about to launch its public consultation for its next local development plan. The plan is an essential part of ensuring that the Borough can meet its housing needs while at the same time putting in place strict guidance for developers about what they can and cannot do locally. This can include a clear allocation of land for development, design guidelines, limits on the height of buildings and other guidance.

This note is designed to set out what I believe Epsom and Ewell should do in its local plan, explains an approach which is consistent with the Government’s objectives, and also meets what I believe are our local needs.

What government policy says:

These are the objectives of a local plan as described by Government.

a) an economic objective – to help build a strong, responsive and competitive economy, by ensuring that sufficient land of the right types is available in the right places and at the right time to support growth, innovation and improved productivity; and by identifying and coordinating the provision of infrastructure;

b) a social objective – to support strong, vibrant and healthy communities, by ensuring that a sufficient number and range of homes can be provided to meet the needs of present and future generations; and by fostering a well-designed and safe built environment, with accessible services and open spaces that reflect current and future needs and support communities’ health, social and cultural well-being;

c) an environmental objective – to contribute to protecting and enhancing our natural, built and historic environment; including making effective use of land, helping to improve biodiversity, using natural resources prudently, minimising waste and pollution, and mitigating and adapting to climate change, including moving to a low carbon economy

The current position

Epsom and Ewell has particular challenges as the smallest and most densely populated Borough in Surrey. But it is still expected to play a part in meeting the County’s housing needs.

The Borough Council has just published its Masterplan for the area, which is the document that will shape the final local plan when the process is completed. It envisages much more intensive development around the main transport corridors and centres in the area, with denser and much higher development. It is silent on the use of green belt land and other open spaces for development, though it does say that some will be needed to meet its housing plans.

The Borough has been very slow to put a new Plan in place and is currently running behind its housing goals. It is shaping its strategy on the basis of achieving the full 579 houses over a 15-year period but appears to believe that it must go for simple options quickly, and hence is pushing more difficult options into the longer term. In fact, Reigate and Banstead Council has been able to secure Inspector approval for its plan because it is more ambitious but the plan takes longer to deliver.

In addition, the National Planning Policy Framework states the following:

Strategic policy-making authorities should have a clear understanding of the land available in their area through the preparation of a strategic housing land availability assessment. From this, planning policies should identify a sufficient supply and mix of sites, taking into account their availability, suitability and likely economic viability. Planning policies should identify a supply of:

a) specific, deliverable sites for years one to five of the plan period

b) specific, developable sites or broad locations for growth, for years 6-10 and, where possible, for years 11-15 of the plan.

The key challenge in Epsom and Ewell is the constraint on space; there is a real shortage of developable land in the area. Current Government policy says that if a Council is to diverge from its housing needs assessment, it must make a strong case to do so. It must also explore with neighbouring councils the possibility that they can absorb part of the extra housing instead.

It is also the case that housing needs figures are not mandatory, and that planning to meet housing needs requires consideration of land availability and relevant constraints such as Green Belt. In this context I believe that we need to work locally on a plan that meets the 579 goal for the coming decade, but makes a powerful argument that development cannot carry on at the same rate after that. You cannot keep building for ever. As part of the governing party nationally, I am happy to make that case if and when asked to do so.

So therefore I believe that the Plan should focus on 10 years, and we should subsequently make the case to Government and the Inspectorate that the total provided for, which would amount to around 5,800 new homes, is approaching the maximum that the area can realistically absorb. But given the pressure on housing locally, the Borough should crack on and deliver the 10 year plan objective, and then review further potential opportunities in the medium term,  rather than trying to reduce its housing objectives now.

So, what should the overall future approach be?

The Borough Council’s strategy so far focuses on house building and hitting a target. I think this is the wrong starting point. The National Planning Policy Framework is about more than just numbers. It requires a plan to be respectful of the character of the area, and its economic needs. It offers protection to the green belt. And it does offer local authorities some discretion to address local limitations on what can be achieved. I think that the Epsom and Ewell plan needs to reflect the realities of the area and needs to be robust about what can and cannot be achieved.

Epsom and Ewell is predominantly a commuter area, with a typically older demographic than some areas closer to central London. In population terms it has never particularly attracted a younger demographic. Young professionals in the earlier years of their careers tend to migrate closer to central London. Many subsequently return to bring up families or often to retire here.

Much of the house building in the area in recent years has been shaped around estates of family houses. This is particularly true of the old hospital sites as well as the animal husbandry site at Nescot. Typically, these houses are now occupied by commuter families.

Continuing on this path is simply unsustainable for the area. Both road and rail networks are full, and it is highly unlikely that there will be major improvements to either before the mid to late 2030s at the earliest. Crossrail 2 offers potential for the future but its progress has been slowed by the problems with Crossrail 1.

This means that during the plan period of the years up to the early 2030s, the Borough cannot expect significant uplifts to transport capacity for commuters on networks that are already full. Ten years ago there were eight 8-coach trains from Epsom to London between 0700 and 0800. Today there are twelve mostly 10-coach trains and they are still virtually full. There is little scope for the local roads to absorb significant extra traffic at peak times.

So, the local plan must be shaped around the integration of home and work, and the provision of services close to both where possible. The next generation of people living in the area must work here too and cannot commute by road or car to get there. The current Borough proposals do not do this to anything like the extent needed. Also, modern town planning puts a strong focus on smart design and being people-focused to address loneliness along with mental and physical health which includes providing outside space.  Protecting public spaces is also therefore very important.

Shaping a strategy around the people who will be living here

The local economy of Epsom and Ewell is predominantly built around smaller businesses. The two largest local employers are Atkins and Wilsons, the car retailer. But the majority of businesses are smaller retailers, professional services businesses and firms in the creative sector.

The Borough is highly unlikely in future to attract major corporate headquarters and it does not and is unlikely to have the kind of substantial office buildings that will attract major inward investors.

However, it does have one real economic opportunity that can help shape all aspects of the local plan process.

In the past few years the local art college in Epsom has migrated to full University status and as the University of the Creative Arts has become one of Europe’s leading creative universities. It has a campus of around 3,000 students in Epsom.

UCA can and should be at the heart of the Borough’s future strategy. In the way that research and technology have driven economic growth around other university towns, so Epsom’s future strategy should be as a creative hub, and a creator of new generation tech enterprises.

The Plan must therefore create the right environment to keep those creative graduates in the area, and have the right kind of commercial accommodation to enable them to start and build creative businesses. New commercial buildings or commercial floors in mixed-use buildings should be designed with this in mind.

Focusing development on turning Epsom into a creative hub, with a particular goal of being an incubator of new business growing out of the university, will also help bring the right kind of demographic change to the area.

If Epsom and Ewell ceases to be a place that twenty-somethings leave, it will help deliver the right kind of growth for the area – with a focus on young professionals and small emerging technology and creative businesses.

Where should the focus of new development be?

The Borough’s proposals involve densification along the main road arteries of Epsom and Ewell, particularly around major junctions, and in both Epsom Town Centre and around local railway stations. This involves a major change to the environment around Stoneleigh and Ewell East stations in particular, in a way that will substantially change the character of the surrounding area.

The current proposal rejects what should be the heart of the approach that the plan takes, which is to reshape the existing commercial areas of Epsom in Kiln Lane and Longmead into a modern, mixed-use area capable of providing the kind of office space and accommodation which the area will need.

I believe that these areas should be progressively and mostly redeveloped as six to seven storey blocks, with commercial/retail premises on the ground floor, small office units on the first floor and modern loft-style apartments above. This development should not cover the whole area, since some premises will need to remain in their current form. But there is the potential across the two areas for significant consolidation and the provision of substantial extra accommodation.

At present, a substantial part of the Kiln Lane area is taken up by ground level parking, either for the out-of-town shops there or for local car dealerships. This is a complete waste of the limited land available in the borough and should be replaced with multi-storey car parking or multi-level car show rooms. The principal car dealership operating in this area, Wilsons, has indicated to me that it would be willing to discuss some consolidation of their land occupation.

There are also opportunities at the bottom of Kiln Lane to consolidate some of the existing business unit locations, where large amounts of space sit in front of small retail units, largely serving the building trade. One unit, for example, houses a local dialysis centre. There is no reason why this could not be accommodated in a multi-storey residential and commercial block.

The traveller site should also be relocated and the adjoining open land at the bottom of Stones Road used for the development programme. The latter has protection because it houses a newt pond, but subject to securing necessary consents, this could be relocated to Horton Park.

On the Longmead side of the railway much of the existing development is single-storey or two-storey. Particularly at the Epsom end, there is scope for substantial redevelopment.

Currently, these industrial areas, whilst contributing to the economy of the town, fall well short of the multi-purpose approach that modern planning advocates for sites within the prime footfall of the town, failing to contribute to the town centre retail, hospitality, accommodation and night time culture.   We need to maximise this prime real estate.

Alongside this, there will need to be densification in other parts of the Borough. Opportunities like the Nescot animal husbandry site, which could have been used to much greater effect, should not be missed again. Some of the most attractive parts of Epsom are made up of Victorian and Edwardian terraces and semi-detached houses. In much of London housing is terraced and not detached. Developers may want to build detached executive homes, but in future they will have to build more terraced squares rather than sprawling estates in places where housing is to be built. This is the approach that should be taken where there are limited open land opportunities in the Borough.

What about affordable homes?

Most of the social housing provision in the area is owned by Rosebery Housing Association, which is the predominant landowner on the Longmead and Watersedge estates. There is currently inadequate provision for social housing in the area, with too many families having to be placed into temporary accommodation outside the area and too many inappropriately housed – despite the growth in the Rosebery estate that has come with the redevelopment of the hospital sites.

There is an urgent need to expand the Rosebery estate, and the practical potential to do so. The Association has been working on plans to do this for some time, and currently estimates that it can increase the number of units that it rents out by around 800 – around 10% of the total requirement in the Borough for the next decade. It involves remodelling the Watersedge estate, and building on some of the garages to be found in both estates which are seldom used for their original purpose today.

This is the right strategy and should be actioned as soon as possible. It is the right way to meet some of the early years targets in the Plan. It is also an opportunity to build some employment opportunities into a redevelopment of Watersedge, with some smaller business units alongside the residential development.

How much development should be in open spaces and/or on green belt land?

It will be impossible to meet local housing needs without some building in open or designated green belt areas. But these should be very much by exception and should be concentrated on areas of land which are already partially used.

For example, the plans should include the completion of the development of the old West Park site, with the NHS services that remain – like the New Cottage Hospital, being moved to the Epsom Hospital site. Langley Bottom Farm will no longer be viable as a farm following the sale of much of its land to the Woodland Trust, and should be turned into a courtyard development of family homes within the footprint of the existing buildings. So should the burnt-out Hollywood Lodge in Christchurch Road. There are derelict plots on the very edge of the Priest Hill playing fields.

But these should be the exceptions rather than the norm. In particular, the areas that create a green lung around Epsom should be protected – including Horton Farm, the fields around Langley Vale and the farmland north of Priest Hill and College Ward.

What is the right design approach?

Design is more than attractive or contextually appropriate buildings.   Design is about retaining or establishing an identity, that our surveys show the residents prize and are distressed at losing.  Identity, for example in the High Street, is also key to attracting the style brands that our residents crave, attracting  businesses and inward investment.

The new local plan should protect the character of the area and avoid the design errors that have been made locally. Most residents refer to mistakes such as Hudson House opposite Epsom station and the new block at the end of Kiln Lane at the junction with the A24 as the best recent examples of planners failing to impose proper design rules on developers to avoid changing the character of the surrounding area.

Buildings should generally have a more contextually relevant traditional style, such as Central Walk, towards the end of Epsom’s Station Approach, or if they are to have a very modern feel, should use materials that are in keeping with the surrounding area.

A Design Policy should also include strict well-conceived, style rules for shop front construction and how they are dressed.  If upheld, it contributes to attracting brands and footfall.

How high should buildings be?

The Borough has recently changed its rules to permit higher buildings than has previously been the case. It is also now encouraging developers to build much higher. This is a fundamental mistake. Applications to build what most local residents would regard as tower blocks – such as the application that has just gone in for a twelve-storey block on a site in West Street in Epsom – must be resisted and future rules must be tight.

I do not believe that buildings locally should be higher than six or seven storeys at most, and then only if they are in a suitable location. I would support an eight-storey building in the middle of the Kiln Lane or Longmead business areas, but not, for example, alongside Stoneleigh station.

In summary

Government policy requires local authorities to shape plans that support sustainable economic growth, protects the environment and meets housing needs.

The current initial draft proposals do not deliver a vision of an integrated approach to all of these objectives, and misses the unique opportunity that Epsom has to become a breeding ground for new creative businesses.

It also involves a densification of development in smaller centres in the Borough that will be resisted strongly by local residents.

I believe that the approach set out in this paper is a better one for the area.