As promised here is my report of Thursday's meeting in Oxted.
In summary the meeting reinforced my view that the threat to Tandridge as a desirable place to lives comes not primarily from developers, but from unelected officials who working within a highly bureaucratic framework imposed by Civil Servants in Westminster. The Inspector ruled out any housing developments in Oxted on the back of any decision he will take, but the risk that he either rejects the Core Strategy or changes it substantially remains and in that case developers may be better able to make the case for inappropriate housing development in the Oxted area.
The meeting was very well attended by local residents, so well attended that not all could make it into the Council Chamber and the Inspector had to spend the first two hours outlining what the purpose of the meeting was all about.
The Inspector made clear that he would NOT during the meeting allocate any individual sites, hear from any developers about sites they wished to develop, decide on any planning applications, remove land from the Green Belt, or hear public views about development in Tandridge. These words were an attempt to reassure residents that there was no immediate threat from developers in Oxted. He said that instead the purpose was to decide on whether the process to consider the Core Strategy would go forward.
The best news at the meeting was that the proposals from Village Developments for 650 homes in Oxted which they appended to their comments on the Strategy would not at any point be considered by this Inspector and were submitted completely inappropriately.
There then followed a series of very insightful questions from local residents about the process which made clear that there was still a longer term threat to the area should Core Strategy not be accepted as proposed. In response the Inspector conceded that he did have the power to change the Core Strategy (as agreed by elected councillors and reflecting the views of local people) and if he did so the the Council would have no real option to accept his changes as the alternative would be to go through an expensive and risky High Court challenge (with little chance of success) or to re-start the four year process (at great expense) needed to get to this point and (by implication - though the Inspector did not say so explicitly) that during the next four years Council's current development control policies would lose their effectiveness and risk more inappropriate developments being approved.
The changes he could make might include forcing the council to look for specific sites for housing quicker than in the plan requiring further consideration as to whether Green Belt boundaries may have to be changed.
The other slightly perverse area of discussion was about the level of consultation the Council had undertaken, with local residents (most of whom actually agreed with the Core Strategy's plans to resist inappropriate Housing Developments) saying they had not been appropriately consulted (and thus threatening the soundness of the process) while the developers present (who opposed the Core Strategy) supporting the Council in that consultation had been adequate.
The meeting then moved onto the formal agenda, where the objectors to the Core Strategy were asked to amplify on their written comments. The main objector was the Government Office for the South East (GOSE) whose objections mostly seemed to be on how the document was drafted rather than on the substance. However even GOSE conceded that that Government guidance did not really provide any solution for a district like Tandridge (which is 94% Green Belt) and despite objecting, did not offer a way out. The Inspector suggested to GOSE that they should be more helpful in their criticisms and suggest solutions rather than just the problems.
Following the meeting the Inspector issued his opinion which rather than summarise I have set out in full below:
'I still have deep concerns and reservations about certain aspects of the Core Strategy, to which I will return below. Nevertheless, I consider that I should continue with the Examination for two reasons. Firstly, because there seems to me to be a reasonable likelihood that further evidence, or the use of existing evidence that I have not yet considered, might resolve some of those concerns. And, secondly, because I detect a positive approach by your Council to the possibility of minor changes to the Core Strategy which might clear up some of my reservations.
Even so, your Council should be aware that continuing with the Examination is not a guarantee that I will ultimately find the Core Strategy to be sound. Your Council should still seriously consider the risk of the Core Strategy being found unsound if the Examination proceeds, with the consequent waste of resources both in time and money.
I agree with GOSE’s analysis at the end of the Meeting that the most credible threat to the Core Strategy is that too many changes might have to be made to make it sound. The danger is that cumulatively these changes would create a Plan so different from that submitted that its provisions would not have had the benefit of the public consultation and sustainability assessment that is required. I referred more colloquially to this possibility at the Meeting as “death by a thousand cuts”.
The main concerns and reservations that I still have are:
Housing windfalls – the lack of a Strategic Housing Land Availability Assessment means that the Core Strategy is perceived as being too reliant upon windfalls to meet the last five year part of its ten year housing land supply, contrary to the advice at paragraph 59 of Planning Policy Statement 3. Clearly, I must bear in mind and consider the constraints (e.g. Green Belt), the low housing requirement, and the validity of your Council’s argument in relation to windfall rates. In addition, there may also be evidence in the Housing Capacity Study on the prevalence of Large Sites which could be drawn out and brought to my attention.
Development management policies – their style and their placing with the Core Strategy mixed up with more important strategic policies. I welcome your Council’s positive approach to rethinking this aspect, perhaps in co-operation with GOSE.
Monitoring – I understand the realistic aims of your Council on this point, but I would welcome further consideration as to whether account has been fully taken of the advice in the Government’s LDF Monitoring: Good Practice Guide.'
In conclusion a goodish result, but one that carries a high degree of risk for Tandridge.
