KRAG have a long and successful history of working to protect all communities from inappropriate development at the aerodrome.
Our mandate relates to the aerodrome and we can therefore only comment on that site in response to the consultation.
We are disappointed to hear of the tactics employed by the developer Thakeham and their consultants MPC Consultation. MPC have been calling door to door in Blindley Heath trying to induce residents to support the aerodrome proposal. A resident has indicated she was told by the caller that by supporting the Redhill proposal it would stop a garden village development in Blindley Heath. It's not clear if the resident misunderstood or the MPC representative was deliberately misleading.
Implicit in any response giving support to a garden village site is support for the TDC preferred strategy from which the garden village concept is derived. We are concerned that TDC could usurp such (implicit) support as endorsement of support of their preferred strategy.
We advise our members to resist responding positively in support of any of the sites as this could be counterproductive and undermine responses intended to defend the aerodrome site from development.
KRAG consider the proposal put forward to develop the aerodrome is inappropriate and will have detrimental effects on many communities in both Tandridge and Reigate local authorities. We are currently producing a comprehensive response this will be posted on our website. In the meantime we consider it may be useful to give an insight to some of the issues we are addressing we hope you may find this of use in submitting your individual responses.
The site is critical green belt and performs valuable green belt purposes as defined in the National Policy Planning Framework (NPPF) notably to
This was asserted by the 2014 (hard runway) public enquiry and endorsed by the High Court. The area of the site within Tandridge is designated by TDC as being within a Tier 3 area such designation confirms the area complies with Green Belt purposes. TDC adopted a Preferred Strategy which excludes development of Tier 3areas. This part of the Green Belt is the most narrow around London and will be lost if the aerodrome is developed.
The site was originally considered through TDC Economic Needs Assessment (ENA) and recommended for designation as a Strategic Employment Site with continued use and suitable for B class use and development.
TDC acknowledge that Tandrdidge District requires additional office warehousing and industrial premises. These already exist at this site which is marketed by the owners as Redhill Aerodrome Business Park and has available accommodation and on site resources for business development.
There are about 450 people employed at the site these jobs will be lost if the site is selected. 50% of the businesses are aviation related and will be lost forever. Other businesses will have to close at the site and relocate. TDC's own consultants indicate that any of jobs that do survive will be displaced out of Tandridge District. Any claimed future jobs will only come about many years in the future.
The proposer's employment statements regarding job creation are speculative; there are no guarantees of job creation and no indication of when or how they will be created or when new business accommodation will be built. Increasing the land value and building houses to make profit is the owners and developers priority.
Summed up this proposal will be at the expense of existing jobs and lose an existing valuable employment site against a speculative hope for job creation well into the future.
The proposers continue to change very basic information including the size of the site, the amount of homes and timescales for the development. It is difficult to keep track of what they actually intend to provide, where and when. The various time scales suggested are impossible to deliver. The volume of homes has risen from the original 4,500 quoted in the developer's first vision document. We consider the constant changes are merely reactive to difficulties brought to their attention and an attempt to keep TDC interested in the site as it is clear there are major deliverability issues.
Council are being asked to select this site from a changing situation when they cannot be certain what and when the aerodrome site may deliver.
All parties accept that without the provision of a new motorway junction and link road the proposal will fail. It is accepted that existing local roads are inadequate to sustain such a development and that significant work will be necessary on the local roads and in particular the Three Arch Road/A23 junction. TDC demand that included in the development there must be infrastructure including a medical centre and schools.
The proposers have made ambiguous references to funding the project. They state they do not require government grants and they will fund the junction and strategic road scheme privately by the associated housing development.
Some of the costs involved may be assessed by reference to the matter of Smart Motorway upgrades to the M23 which are due to commence in March 2018 and conclude in 2020/21 at a cost of approximately £154 million. The cost of a new junction and link road will be significantly in excess of the new Smart motorway project.
It is also interesting to note that when producing their unrealistic timetables for delivery, the proposers neglected to mention the smart motorway works which have a protocol that would generally preclude any further works for 5 years after completion this completely undermines all the timetables they have presented to date.
The complexities (legal, technical and engineering) of producing the new junction, link road, existing local road improvements and on-site infrastructure are huge individual obstacles. The issue of the new junction can be seen by reference to Highways England's list in the consultation documents.
The multitudes of issues the proposers have to resolve individually demonstrate that the site is potentially undeliverable and will at the very least make it impossible to deliver within the TDC Local Plan period to 2033.This defeats the object of the Local Plan and renders the proposal impotent.
The matter of actually funding the individual infrastructures remains opaque and questionable it is at a significant issue to overcome to assure deliverability.
Data for vehicle ownership per household indicates that in consequence of the development many thousands of extra vehicles will be thrust into the local environment. Tandridge has a very high rate of vehicle ownership and use. Various consultants and S.C.C. acknowledge the adverse effects the increase in vehicles will produce in the locality.
The proposers infer that the link road will take the pressure off local roads. This is contradicted by the observations of the consultants and S.C.C. assessment which indicates massive increase in vehicle movements on the local roads not only by residents of the development but to include the use of the link road as a through road for non-local or household traffic and associated use of the local roads as rat runs.
The Bower Hill Ridge above and just over a kilometre to the north of the Aerodrome site is a candidate area for the Surrey Hills AONB the boundary review is underway.
Most of the aerodrome site is in full view from the footpath running high along the Ridge. It is also visible from the Greensand Way passing to the north of the site. The developers propose buffering to separate South Nutfield from the development. No amount of "buffering" could conceal such a sizeable development of 8000 or more houses, associated infrastructure, a new motorway junction and several kilometres of link roads.
TDC recognised in their Landscape Assessment (July 2017) that the "new settlement is likely to have a significant impact on the rural outlook of the Greensand Way and the candidate area for the AONB".
The local landscape will be detrimentally changed. The 2017 Landscape Survey also agrees that "The rural setting of South Nutfield is likely to be affected by the potential development area".
South Nutfield has virtually no street lighting. A development of this type and size would be visible at night not just from South Nutfield, but from the whole length of the Greensand Ridge to Redhill, an effect exacerbated by the coalescence of communities which this scheme would bring. Light Pollution will be a significant factor.
Air pollution has already been recorded above national limits in some local hotspots and this will be an issue from the hugely increased traffic flows anticipated to result from this development, particularly around the motorway junction and spur.
The proposers suggest that the development will provide opportunities to develop and enhance ecology and biodiversity. The opposite is the realistic case. A key tool is connectivity (blue – water related and green – natural networks of woodland, ancient woodland and especially hedgerows). The construction of 8000 (or more) houses, construction of the associated motorway link roads cutting across the site, and the ancillary roads required will destroy rather than enhance connectivity.
This is also a precious habitat, will be at risk. Important areas of ancient woodland abut the fields the developers indicate will be motorway junction and spur. This area includes large natural ponds within the woodland and their inhabitants, including proven great crested newt colonies. The junction proposals will clearly put such a precious habitat at risk.
Much of the aerodrome area floods on a relatively frequent basis and this cannot be solved by works at the aerodrome site unless substantial flood storage and attenuation facilities are created there or further back upstream. The substantial urbanisation of the area will result in a very significant increase in the amount and rate of surface water runoff and significant measures will be required to limit runoff from the developed areas and to recreate existing flood plain which will be lost by the development. These will further substantially reduce the space available for the development. The approach adopted by Thakeham appears to be limited at present with only a vague limited undeveloped strip adjacent to the watercourses and some localised flood storage ponds. KRAG consider that the flooding extent, risk and allied issues are a significant issue.
TDC have only recently allowed the Aerodrome site to be introduced into the Garden Village process for consideration and thus have not considered the strategic flood risk assessment and the exemption process for this area in its Strategic Flood Risk Assessment Further Details Report (October 2016) as for the other three proposed garden village sites. Thus, KRAG has serious reservations about the consideration of this site for a garden village in view of the lack of inclusion of the Aerodrome in the Strategic Flood Risk Assessment by TDC and their lack of exemption considerations.
Flooding and flood attenuation issues must be considered to be a major issue which must be addressed before the site can be properly and adequately considered further.
We urge you to respond to the consultation and register opposition to the proposed development of the site. If possible arrange for relevant individual members of your household to reply TDC have indicated that composite responses from households and organisations (including our elected parish representatives) will count as one response. Please also remember the inspector will only see consultation responses. Communications outside consultation responses will not be presented to the inspector.