The following issues are intended to help residents with their deliberations when considering the issues associated with the site. They are not meant to be exhaustive and indeed should be used with your own views and in your own words when submitting objections.

1 The land is in the Green Belt

• The Land is in the Green Belt – This Application Should Not Be Allowed
• This site is in the Green Belt, which is protected land. Any development on it must pass a very strict test — the default is no building allowed.
• The developer is trying to claim this is “Grey Belt” land — but that term is new, vague, and not officially defined. It was originally meant for things like old car parks or wasteland — not green fields like this one.
• Even the government’s new planning rules don’t properly define Grey Belt, and they weaken Green Belt protections. This needs to be challenged.
• Regardless of “Green” or “Grey”, no Green Belt land should be built on while there are Brownfield (previously developed) sites available.
• This land is also not included in the Elmbridge Local Plan for development — meaning it’s not supposed to be considered for building right now.

“Poor quality” Green Belt is incorrect

The application contains extensive reference to the 2016 Ove Arup Green Belt Boundary Review (GBBR) as justification for claiming this site to be ‘weakly performing Green Belt’. This assessment has been challenged because it is faulty.

Arup ignored their own scoring methodology to wrongly claim the site area weakly performs the purposes of the Green Belt. The 2016 GBBR has been discredited and should be removed entirely from the Green Belt Assessment Report (Pegasus Group) as a reference to justify a planning application on the Green Belt.

Conflicts with landscape sensitivity report

“The northern part of the Landscape Unit around Knowle Hill Park” [which includes The Paddocks site] “is most sensitive to development …….”

• The application has extensive reference to, and quotes from, the Elmbridge Borough Landscape Sensitivity Study carried out by Arup in 2019.
• This is a direct partial quote from Arup’s 2019 Report and is quoted in full in the Chapter D Report  from Pegasus Group: “The northern part of the Landscape Unit around Knowle Hill Park” [which includes The Paddocks site] “is most sensitive to development …….”
• Arup’s 2019 Report gave this Landscape Unit (LF1-A) a rating of Medium–High susceptibility to change arising from mixed use and residential development and a rating of Moderate-High sensitivity to change arising from the same.
• Arup defined 25 separate Landscape Units within Elmbridge and assessed every one in terms of their sensitivity to change through residential development. Of those 25 only 3 were assessed as being more sensitive than LF1-A.
• The above is clearly not consistent with a claim of weakly performing Green Belt.

2 The site is not in a sustainable location

The site is not in a sustainable location. It is situated off a narrow, winding, country lane with no access to the services necessary to support a large, mixed, community. Private vehicles will be the be the most viable method of travel for the site since bus services are very limited in routes and frequency. Indeed Surrey Highways response to the Consultation states:

“it is not in a sustainable location in transport terms. Significant mitigation measures would be required to improve access to the site on foot, by cycle or public transport. Without such measures the development would not support or encourage potential future residents to travel by means other than the private car. As such it would not meet the requirements of section 9 of the NPPF 2024, or with Surrey’s LTP4 which gives priority to sustainable modes of travel.”

Surrey Highways Consultation Response

3 Problems with access to and from the site

The Proposed Site Access Arrangements, as designed for the applicant by i-Transport, do nothing to solve the problems associated with siting a 250 home development on a country lane next to a narrow, vehicle only, railway bridge.

• The design includes 2 metre stretches of footpath around the curve of one side of the new vehicle access roads, terminating in pedestrian crossings, so that every person entering or leaving the site on foot will have to do so at exactly the same points as vehicle traffic. The eastern pedestrian crossing will be located where vehicles having crossed the railway bridge from Oxshott will be accelerating downhill on a blind bend. This is clearly an unsafe situation.
• The design has Blundel Lane reduced in width to 4.8 metres so as to accommodate a widening of the footpath to 2.0 metres, which is the opposite of what is required on a narrow country lane.
• The additional number of vehicles and cyclists needing to use the Lane, and pedestrians halting traffic to cross the Lane, is likely to result in a totally unacceptable level of traffic chaos and cannot be sustainable.
• There is no safe pedestrian access to the nearest primary school and GP Surgery which are located in Oxshott. Again, this is not sustainable.

4 Road safety and traffic management issues

The Stoke Road/Blundel Lane junction is a major issue and even the Transport Assessment accepts that traffic will be over capacity.

• The proposal to add a left turn only lane at the junction will be ineffective. There is insufficient room for the lane to be more than a few cars in length and at peak times probably more than 80% of vehicles emerging onto the Stoke Road will be turning right toward Cobham, the A3 and the M25, so a left only filter lane will have little impact.
• The proposal to move the Stoke Road bus stops appear to have safety issues and will definitely result in traffic hold ups as they will then block both carriageways.

5 Non-Compliance with Elmbridge Design Code

The Parameter Plans Building Heights will both inform and have serious implications for reserved matters so need to be highlighted and rejected.

• The heights noted are 1.5 metres above ground level plus up to 14 metres ridge height on the lower levels, plus up to 13 metres ridge height on the higher ground level. 
• The plan shows 88 1 and 2 bedroom flats and 151 houses (3 or 4 bedrooms), which is a total of 239 residences, the remainder being 2 bedroom houses.
• Housing 88 flats will require the blocks to be 5 storeys in height. No building in the vicinity exceeds 2 storeys in height and there are no buildings of more than 3 storeys anywhere in the village. This design is entirely out of keeping with the local environment.
• The Outline Planning Application does not comply with the Elmbridge Design Code section 3 which states that “ An understanding of the context, history and character of an area must influence the siting and design of new development. This context includes the immediate surroundings of the site, the neighbourhood in which it sits and the wider setting.” The Paddocks site does not comply with this and completely ignores the surrounding neighbourhood design which is largely detached 2 storey houses (maximum of 8m height).  The existing flats in Winston Drive are also only 2 storey in height.  So the height and massing would be out of character with the neighbourhood and would be visually dominant, overbearing and inappropriate urban style in a semi-rural location. 
• The Elmbridge Design Code Checklist document submitted by the applicant also raises a number of questions that have not been addressed correctly

The Outline Planning Application Green Space documents when overlaid with the existing landscape will result in a high loss and removal of trees. This is also in contravention of the Elmbridge Design Code section 5.2.1 a which states “ Existing trees should be retained as a priority, and new trees planted to provide urban greening.”. The photograph below shows clearly the extent of the tree removal that will be required

6 Impact on the environment and loss of woodland

The Statutory requirement for 10% Biodiversity Net Gain (BNG) will not be delivered on site so the application should be rejected.

• An overlay of the site boundary on aerial photographs of the site shows the significant extent of trees and woodland that will be lost (see photo provided in section 5 above)
• The removal of mature hedgerows, shrubs and trees will destroy the established habitat for birds, insects and other valuable wildlife.
• A number of important birds use the area as natural habitat; including a pair of buzzards, falcons and owls.
• A significant portion of the woodland within the proposed development is recorded as being Habitat of Principal Importance (HPI) on MAGIC (DEFRA, 2025). We challenge why the broadleaved woodland to the northwest of the site would not qualify as HPI. The lack of ecological justification of this needs to be addressed. The presence of HPI is of material consideration. 

7 Contaminated land

The Elmbridge Planning Portal provides the history of planning applications for this site. In 1952 planning permission was granted (ref. 1952/8068) for some of the land to be used as an Esher District Council controlled tip. This is not mentioned in the application and needs to be addressed.

There may be land stability concerns determining where buildings may or may not be sited and implications for Biodiversity Net Gain and Green Spaces proposals, so this issue needs to be dealt with now and not in reserved matters.

8 Sewage and flooding risks

Blundel Lane frequently becomes flooded in parts due to surface water draining.  The current topography of the land helps to mitigate this due to natural absorption by the fields and trees.

• Sections of the land lie in Flood Risk 2 and rely on a Sustainable Drainage System to be in place to manage flooding risk. 
• Blundel Lane frequently becomes flooded in parts due to surface water draining.  The current topography of the land helps to mitigate this due to natural absorption by the fields and trees.  Once these are removed we need an absolute guarantee that surface water run off will be managed.
• The sewage system in place also needs to be guaranteed that it is sufficient to cope with an additional 250 homes. In Dec 2024 Thames Water’s response to the Scoping Study concluded  “The wastewater network capacity in this area may be unable to support the demand anticipated from this development. Local upgrades to the existing drainage infrastructure may be required to ensure sufficient capacity is brought forward ahead of the development.”
• This is unacceptable, if there is any risk that properties further down Blundel Lane would at risk of either foul sewage flooding or drain flooding this development should not be allowed.

9 No verified views included

There are no verified views included in the application which need to be produced in winter when deciduous trees have lost their leaf cover.  Below is a view of the site from the Public Footpath FP51 (near the Shetland Pony Club).  The loss of this visual amenity would be a devastating loss to the local community, and also impact the Shetland Pony Club that currently employs 60 people locally.

10 Lack of consultation

There were only 500 copies of the 4 page brochure promoting The Paddocks distributed by Mac Mic, despite there being 700 dwellings in Stoke D’Abernon.  Therefore 200 householders were denied the opportunity to comment on the plans.

The applicant only provided ‘consultation’ using online Q&A format pages on their website. A large number of local residents are elderly and not necessarily able to communicate in this way and have therefore been denied the opportunity to comment on the proposals.