Please see below some of the key points that you may wish to use when sending in further objection letters to the recent additional information received from the Property Developer regarding The Paddocks.
As always it is worth putting this in your own words rather than a straight cut and paste. The deadline given by the Council is the 2nd December, however comments will be accepted after this date.
Your Stoke D’Abernon Residents’ Association will be putting a more comprehensive objection report to the latest amendments which we sadly feel does little to address the fundamental problems that we have with this inappropriate and unsustainable development.
Reasons to object further
High level summary of reasons to object to the applicant’s additional information.
| Developer Claim | Why it Fails | Policy Conflict |
|---|---|---|
| GREEN BELT Benefits outweigh harm and engagement with council supports acceptability | Green Belt policy requires Very Special Circumstances (VSC) proven through evidence — not assumption or pre-application engagement. The claimed “Grey Belt” has no legal or policy status. Public benefit must be demonstrated, location-specific, and supported by unmet need evidence — none has been provided. | NPPF 152–158; Elmbridge Green Belt Policy |
| HABITATS Updated surveys resolve ecological issues | Surrey Wildlife Trust and other ecology consultees confirm required surveys remain incomplete or invalid (including bats, dormice, GCN, breeding birds, invertebrates). Under the Habitats Regulations, planning authorities cannot lawfully approve proposals where impacts on protected species remain uncertain. | Habitats Regulations 2017; NPPF 185–189 |
| ROAD SAFETY Revised drawings now meet LTN 1/20 and highway safety standards | Road Safety Auditor queries remain unresolved. Railway bridge constraints remain totally unresolved and proposals may significantly worsen existing conditions. LTN 1/20 requires demonstrated compliance — not indicative layouts. Revised drawings do not remove conflict risk between vehicles, pedestrians, and cyclists. There are no audits of walking or cycling routes. Road safety analysis of Stoke Road/Blundel Lane junction not provided. | NPPF 113–115; LTN 1/20 mandatory criteria; Surrey Transport Policy |
| BIO DIVERSITY NET GAIN | The Developer has had to address the policy requirement through off-site contributions as this cannot be met within the development itself. Details of these contributions have not yet been provided. | NPPF 187 |
| LOCAL CHARACTER / MERGING OF LOCAL SETTLEMENTS Negligible effect on landscape elements | The effect on local landscape features is immense. The applicant has not responded to national policy which seeks to prevent neighbouring towns from merging into one another. | NPPF 143(b) |
| COMMUNITY ENGAGEMENT The applicant refers to the Statement of Community Involvement | Lack of meaningful engagement with local Community, with focus on OnLine Consultation only. No further information is provided. | NPPF 16, 40-41 |
| DRAINAGE STRATEGY Strategy updated and detailed testing can be conditioned | Early proportional and effective engagement has not taken place. NPPF requires a workable drainage strategy before determination — not post-approval. No infiltration testing, groundwater modelling, sewer capacity confirmation, or exceedance flow mapping has been provided. Thames Water and LLFA responses remain conditional, not approving. | NPPF 161–169; Elmbridge SuDS/Drainage SPD |
Planning Portal Links
Land to the Southwest of Polyapes Scout Camp, Blundel Lane, Stoke D’Abernon (Application No. 2025/1097)
Note: Comments must be submitted by the 2nd December. Also our GoFundMe fundraising page is still live, more at https://www.gofundme.com/f/stop-the-paddocks-say-no-to-250-houses-on-blundel-lane.
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