Rebecca Paul MP has warned that the Government’s proposed changes to the National Planning Policy Framework ('NPPF') - the key document which decides what can be built where and under what conditions - will result in mass development of Green Belt land across Reigate & Banstead. Of particular concern is land around local railway stations, which under the new planning regime will be stripped of almost all protection and opened up to high density development.
In response to the Government's consultation on these changes, Rebecca has submitted a detailed response raising concerns about the Government’s proposed approach to development near stations. In her response, Rebecca has made clear that she fully supports building more homes, but these must be built in the right places with the right infrastructure. Although she supports the principle of looking at land close to good public transport links first, the Government's proposals are too broad and fail to protect important green belt land around rural village stations. Consequently, the changes as drafted will be detrimental for Banstead, Earlswood, Tadworth, Kingswood and Chipstead.
The core concern is the proposal in the new NPPF which would make it easier to bring forward housing and mixed-use development within “reasonable walking distance” of certain railway stations. This not only puts green belt land at risk, but also train station car parks. The draft NPPF proposes minimum density expectations of at least 40 homes per hectare around stations, rising to 50 homes per hectare around stations defined as “well-connected”. It is important to note that under the criteria the Government have proposed, every station in the Reigate constituency would be defined as "well connected".
It is problematic that in the Government's new draft NPPF the phrase “reasonable walking distance” is not properly defined. Without a coherent definition, it will be unclear how far new development can extend, how the term "reasonable" should be measured, and whether the walking route itself must be safe.
Commenting on the Government's proposals Rebecca said:
“I support building more homes around appropriate transport hubs, provided it is done sensibly and thoughtfully. But the Government’s proposed blanket policy of building close to train stations irrespective of whether the land is green belt is especially problematic for rural areas. It assumes every station sits in the middle of a major urban growth zone. And that is simply not the case.
“In Reigate, Redhill, Banstead and our villages, many of our stations serve villages or semi-rural communities, and it would be entirely inappropriate to build a ring of dense housing around them.
“What the Government has put forward might well make sense next to a major city or town station but these rules will cause real harm if applied in villages like Chipstead, Tadworth or Kingswood.”
The proposed station development policy is especially concerning because it undermines Green Belt policy. The draft NPPF includes wording that would treat housing and mixed-use development in the Green Belt, where it is within reasonable walking distance of a suitable railway station, as not 'inappropriate development'. In practice, this means that proximity to a station will become a new route for development on land that has previously benefited from much greater protections, like green belt.
Rebecca said:
“The Green Belt around our towns and villages ensures that our villages, all with their own individual characters and identities, don't merge together into one big sprawl.
“Once that separation between settlements is lost, it cannot be restored. That is why the Government must be extremely careful before creating a national policy that would make Green Belt land around stations easier to develop. I urge Ministers to think again on this.”
To better demonstrate what the new NPPF could mean locally, below you will find an 800-metre radius around several railway stations in the constituency - 800 metres is commonly used in planning and transport discussions as a definition of "reasonable walking distance" though it is important to emphasise that the Government have not defined this distance themselves in the context of the NPPF.
In Banstead, an 800-metre radius around the station covers far more than the immediate station area. To the south, it extends across residential streets around Fir Tree Road, Green Curve, Bolters Lane and Winkworth Road, while to the north it takes in open green space. It's important to note that the open land north of the station is part of Banstead Commons so is protected from development. See map of extent of Banstead Downs here: MAPS_Banstead_Downs_HR-Revised.jpeg (1280×905). The risk therefore for Banstead is more around infill development to the south of the station.
An 800m radius around Earlswood Station highlights a different but equally important problem. This catchment area includes streets around St John’s Road, Pendleton Road, Woodlands Road and Brambletye Park Road, as well as land towards Redhill Brook, East Surrey Hospital and the surrounding green and open areas. Development here would exacerbate pre-existing concerns about the inadequate state of local roads, challenging access to East Surrey hospital and poor drainage.
The Tadworth and Kingswood map above best illustrates the concern around settlement separation. The two 800-metre station catchments sit close together - almost overlapping. The Tadworth radius covers much of the village around Station Approach, The Avenue, Ashurst Road, Preston Lane, Tadworth Street and surrounding residential streets. The Kingswood radius covers the area around Kingswood station, Furze Hill, Bonsor Drive, Waterhouse Lane, Outwood Lane and nearby open and low-density land. Some of the land around New Road, Mill Road, and Brighton Road is part of Banstead Commons and therefore protected. See maps of extent of Banstead Heath and Burgh Heath here: MAPS_Banstead_Heath_v4-FINAL.pdf and Burgh Heath - Banstead Commons Conservators
Taken together, the two circles show how a station-led policy could create pressure on the space between neighbouring villages. Here the Green Belt does not simply provide countryside in a general sense - it helps keep Tadworth and Kingswood separate and distinct.
Additionally, this new planning approach would lead to more infill development in both Tadworth and Kingswood, without adequate infrastructure. Drainage and flooding is already a pressing issue in the area and this would likely get worse.
Looking at Chipstead we see clearly why a one-size-fits-all station policy is so damaging. An 800-metre radius around Chipstead station covers not just the village and nearby roads such as Outwood Lane, How Lane, Hazelwood Lane, Doghurst Lane and Coulsdon Lane, but also a large amount of surrounding Green Belt, woodland, open land and recreational land including areas around Banstead Woods and Chipstead Downs. This is not, by any stretch of the imagination, a suitable place for high density development. It is a semi-rural village station surrounded by countryside and green spaces. Development here will change forever the character locals so enjoy. It should be noted that the land to the west of the station around Holly Lane and Park Lane is part of Banstead Commons and therefore protected from development. See map of extent of Park Down here: MAPS_Park_Downs_v2.pdf. Additionally Banstead Woods is protected by its inclusion in the Surrey Hills Landscape. See map here: SC2_Fig.20b_Chipstead.pdf
What all these examples show is that treating development around village stations in the same way as around town stations leads to poor outcomes. It's important that the Government moves away from a blanket approach that doesn't give due consideration to the needs of rural areas. In Reigate constituency, the adoption of this new NPPF will mean significant loss of green belt, densification of villages through infill, and increased pressure on already strained infrastructure. Rebecca will continue to urge the Government to think again.
