LibDem response to Council's draft Masterplan for Epsom town centre
Epsom & Ewell’s “Draft Town Centre Masterplan Document” November 2023:
Epsom & Ewell Liberal Democrat’s response – 22 December 2023
Question 1 To what extent do you agree with the masterplan principles?
Page Ref 1 - 9
Select the most applicable option in each row.
The principles appear fine and appropriate at first glance. However we do not feel that principle 6 has been fully fleshed out in the report such as by exploring the opportunity site options for greater density. Paragraph 1.15 states the need for the town centre “to deliver an optimum level of housing…” but there is no methodology set out to define “optimum”. Greater clarity is needed on both the absolute number and the mix of new homes required.
We welcome principle 4 but do not consider the details in the rest of the document give sufficient weight to this. The A24 will still be running through the town and dominating its character.
Making roads safe for other users encourages people to leave cars at home, but it would be better if worded to recognise that car access is necessary for the foreseeable future and this requirement needs to be closely coordinated with the needs of pedestrians and cyclists.
Principle 7 we very much support, as we see it vital to combat climate change in the long term. |
Question 2 To what extent do you agree with the baseline analysis?
Page Ref 10 - 19
Select the most applicable option in each row.
pg 13 - To prioritise retail there must be a consideration to provide car park spaces. We return to this in later comments.
pg 14 - Flexible built form is a good way to support a variety of uses of buildings. An additional consideration around “active fronts and building entrances” is the benefit that comes from consistent and sympathetic planning permits around shop signages and frontages. Some of the quality of the built environment along the High Street is ruined by poor corporate logos and lack of consideration for Epsom’s heritage. Good examples of more stringent enforcement of shop frontages in heritage areas can be seen in, for example, Cambridge town centre.
pg 15 - 'quality over quantity' does not prevent well-designed apartment options from being explored, instead of townhouse developments on key sites, to utilise our space effectively.
We agree with the comments in paragraph 2.12 around the need for stronger links with the train station, and return to this point later in our comments. Introduction of green areas and infrastructure is supported. |
Question 3 To what extent do you agree with the design response?
Page Ref 19-21
Select the most applicable option in each row.
We agree with the importance of considering views of potential new developments. For example, the increased height of the Ebbisham centre and its bronze top is not well received locally.
Paragraph 2.52 is crucial, and it is important for any further work to understand what changes are feasible for both the A24 and the other major roads feeding into Epsom. Good, open, frank and constructive collaboration between EEBC and Surrey Highways is essential if any of the potential improvements in this document are to be realised.
Good design incorporates open space as well as density, such as with Lidl and potential development around Dullshot Green. Balancing the needs of housing with enjoyment of the open environment.
Recognising the Environmental Quality point in the baseline analysis, there should be a mention of biodiversity gain on our urban sites, such as by encouraging vertical planting or green roofs on our larger builds. |
Question 4 Do you think the "Character Areas" are an accurate representation of different areas of the town centre?
Page Ref 22:
Please enter any additional comments:
The Character Areas are a useful method of considering the area, but there also needs to be specific consideration of the footpaths around Epsom. In particular special attention needs to be given to the footpath along the railway line behind the Ebbisham Centre that could, with appropriate work, form an important link between the station and the potential new area 9 “Hook Road, East Street and former gas works”.
Elsewhere in the document much is made of the need for “permeable” sites and to ease the pedestrian movement between areas. We agree, but suggest that this principle is not then carried through into the analysis of each area. |
Question 5 Do you have any comments on our analysis of the character areas (please specify which ones)?
Page Ref 22 – 35:
pg 23 - The Market Square is the key pedestrian area and a key social heart of Epsom.
pg 24 - The proposal to increase the Ashley Avenue greenery is welcomed.
pg 26 - Enhance Dullshot Green at the same time as introducing more housing density.
pg 28 - We would welcome the “greening” of High Street East suggested by the “reimagining” drawing, but question whether Surrey Highways would agree with this.
pg 28 - We suggest more effort could be make to use Derby Square as an attractive link between the station and the High Street East. This is a further example of needing to consider the links between each of the Character Areas – in this case Area 4 and Area 8.
pg 33 - Agree with the assessment of the architecture of Station Approach here.
pg 34 - There is no clear overarching character to the buildings of East Street, which gives the street a less welcoming feel. Agree with it being a very car centric street and not that pleasant to cycle or walk down.
Paragraph 3.27 - care is needed when interpreting occupation rates for Hook Road car park and making long-lasting decisions based on scanty information. We return to this later in our comments. |
Question 6 Do you have any comments on the public realm strategy?
Page Ref 36 – 42:
pg 37 - Delivery mopeds park on the pavement, limiting movement sometimes to single file, as well as forcing pedestrians to check on the pavement for mopeds moving. pg 38 - An increase in planting would be welcomed, both to improve the aesthetics of the town centre and for the increased cooling effects in the summer. The support of Surrey Highways is likely to be needed. pg 39 - Wider footpaths would help spill-out activity, which is one of the types of activity that gives town centre's their community aspect. In paragraph 4.13 any narrowing of vehicular carriageways will need to deal with the issues currently being caused by the Bus Stand on the High Street outside Santander. This causes significant traffic queues and resultant increase in kerb-side air pollution. This is hinted at in paragraph 4.32. pg 40 - Signage would also encourage a walking environment. pg 41 - Agree with landscaping principles. pg 43 - Under the “better accessibility and connectivity” section we would include the need to improve the network of footpaths that serve Epsom, and indeed form an integral part of its character. |
Question 7 Do you have any comments on the draft transport strategy?
Page ref 43 – 45:
South Street does not seem to be mentioned in any particular detail, the pavements are narrow to walk down and the traffic often backs up onto Dorking Rd and Woodcote Rd. This can encourage diverting down Worple Rd instead onto Ashley Rd and Church St.
The strategy doesn’t seem to address the crucial issue of the A24, with only minor tweaks being considered. If no more far-reaching or radical solutions to the constant through-traffic in the Town Centre is feasible, then any strategy is really only tinkering at the edges. |
Question 8 Do you have any comments on the targeted interventions on the A24 (Please specify, e.g. Ashley Avenue, Ashley Road, High Street, Church Street or East Street).
Page Ref 46 - 50:
pg 47 - A lot of trees are shown planted down the High Street, as well as some planted at the junction. Are these realistic or are they there just to make the proposed changes look more appealing? (This is the case with a lot of these illustrations.) The trees would be welcomed to green the area. pg 48 – There will be a need to address the blockages currently caused by the bus stand (item 2 in the aerial photo of the High Street). Further the widened footways and spill-out space (item 4 in the Illustrative plan for the High Street) will only be attractive and useful if plans are also made to address the issues caused by the large number of deliver motorbikes in this area. pg 49 – the “partial pedestrianisation’ of Upper High Street looks nice in theory but careful planning will be needed to consider how the significant volumes of traffic which currently use this road will be managed (we return to this point later in our comments). |
Question 9 Do you have any comments on proposals for either Upper High Street and/or Waterloo Road / Station Approach? (please specify).
Page Ref 51 - 52:
pg 51 - To partially pedestrianise and therefore slow down vehicle movement, we must ensure that cars have adequate parking at the periphery of the town centre to not reduce numbers that visit.
We disagree that Upper High Street is a “local approach to the town centre, rather than a strategic through route”. It is actually the continuation of Alexander Road and the main route to Banstead and Croydon. There is already frequent long tail-backs from the lights at the junction of Upper High Street and Church Street. The situation has not been helped with the new Lidl, and would be made worse if Aldi were to occupy the current vacant ex-dairy site. Partial pedestrianisation of Upper High Street would likely lead to significantly greater traffic trying to turn into Church Road at the “five junctions” and then into East Street – further exacerbating the dangers and difficulties at the pinch-point at the narrowing of Church Road just before it reaches East Street.
Pg 52 – We repeat our suggestion that any improvements around the station should also consider the footpaths serving the station, including the alleyway behind the Ebbisham Centre.
The taxi rank on the opposite side of the road to the station is underutilised, and given the need to have space for drop offs (of which there is currently only one small bay), this space could be dedicated to allow for pick ups and drop offs. |
Question 10 Do you have any comments on Public Car Parking?
Page Ref - 53:
It is good to retain carparks that are vital to keeping the town centre accessible. We should seek to reprovide lost spaces at the periphery of the town, to allow those further away to easily access the town centre and then enjoy the increased pedestrianisation. Public transport alone is not enough to be relied on. We should seek to maximise car parking opportunities to increase capacity, by decking or reprovision if surface car parking is lost. This will not only provide for our residents that require driving into the town centre, but also maintain a healthy revenue stream for the council. We doubt whether the analysis carried out in July 2023 is sufficiently robust on which to base decisions with long-lasting implications. As suggested by DLA in the Appendix, a further car-parking study is required. |
Question 11 Which is your preferred option for the following sites?
Page Ref 54 - 72
Select the most applicable option in each row.
| |||
| Option 1 | Option 2 | Option 3 |
Ashley Centre and Global House | ( ) | (YES ) |
|
Hook Road and Southern Gas Network | ( YES) | ( ) | ( ) |
Town Hall, Hope Lodge and Epsom Clinic | ( ) | ( ) | ( YES) |
Please enter any additional comments, including alternative suggestions (please be specific).
Ensuring we focus on delivering units on brownfield reduces the strain on delivering on our greenfield sites, and should be generally favoured.
Paragraph 5.2 mentions the legally defined “affordable” housing. We suggest that the actual need in the Borough is for social housing, and in particular 2-3 bedroomed homes and apartments for families needing social housing.
It would help to have unit numbers indicated for each of the options.
SA2 not ambitious enough, with a dwellings per hectare of 56 minimum this is hardly ambitious. This is a key brownfield site and option 3 which is there to show an apartments-focused scheme, is not given indicative unit numbers. This makes it challenging to select an option as whilst we want more housing units on our brownfield, we cannot make decisions with incomplete information. The accompanying diagram only shows development in a small section of the site. Is this intentional for the apartments option? Or is it an oversight?
We have slight concerns over the 8-storey nature of Options 1 and 2 for SA4 (Ashley Centre and Global House) and would need further details before fully supporting this approach. Views 18 and 25 in Appendix 1 are not in themselves appealing, and we note the slight negative comments in paragraphs 5.7. Views from Rosebery Park should also be considered.
Ensure quality in building such as by demanding an energy efficiency standard higher than the national minimum, and quality in enjoyment of the area by ensuring that 10% new biodiversity on large developments is carried out.
The more we increase units on our urban areas, the less pressure there is to release land for greenbelt development to meet the needs of our borough. |
Question 12 Please indicate which your preferred options would be for the following site.
Page Ref 73 - 76:
Select the most applicable option in each row.
| ||
| Option 1 | Option 2 |
Depot Road and Upper High Street | ( ) | (YES ) |
Please enter any additional comments including for suggested alternatives.
Again, there is no option that explores a high density of unit delivery. The current highest, option 2, only has a dwellings per hectare of 81.
Comments on density and social housing are the same as previous.
We support maintaining car parking space via decked parking.
More information is needed on the potential car-parking facility mentioned on page 74, as this facility is important for both retail and the evening economy. |
Question 13 Do you have any comments to make on appendix A: Townscape and Heritage Views?
A18, view 13, highlights the lack of character that East Street currently has.
We agree that it would be inappropriate to build a high (8+ storey) tower on the Gas Works site.
Note our earlier comments on the options for Ashley Avenue. |
Question 14 Do you have any comments on Appendix B: Stage 1 baseline report?
Paragraph 3.14 referencing the bus layover in Ashley Avenue is important but should also apply to the bus stand on the High Street. We agree with the comments in paragraph 3.36 but note that the draft Masterplan does not seem to address the issue of people walking. More emphasis should be placed on improving the quality and safety of the extensive existing footpaths. Paragraph 3.51 notes the required car-parking capacity but the actual options set out in the main document are not clear about the potential capacity for each option. We agree with the conclusions in paragraphs 3.67 and 3.68 that a more detailed and robust study into car-parking is carried out, ideally not during the summer holiday period. We agree with the sentiments in paragraph 4.6 and 4.14 and suggest that more is made of the need for this creative and experiential trips within the various Options. |
Question 15 Are there any general comments you'd like make about the Draft Masterplan?
To incentivise shopping trips to the town, there could be free parking for 2 hours (potentially as a scheme in tandem with local businesses)
Have a display that allows businesses on a week rotation to advertise themselves and show their projects. Could place in the Ashley centre.
There is not enough discussion about the need for electric charging points, either with on street charging or in council car parks.
The air quality at congested points should be monitored with the aim of reducing nitrogen dioxide levels.
The importance of a coherent, attractive parade needs more attention in the Masterplan. Strong and harmonious buildings can be ruined by insensitive shop-frontage. The Masterplan should be stronger in requiring an Epsom-focused look to all frontage, rather than having bland corporate logos along the main roads. |