The Inspector examining the Epsom & Ewell Local Plan 2022 to 2040 has proposed a substantial package of Main Modifications. The Epsom Local Plan changes would add 16 site allocations and increase the plan’s identified housing supply from 4,914 to 6,052 homes.
Twelve of the proposed additional allocations are within the existing urban area. Four are on land currently within the Metropolitan Green Belt, including major proposals at Priest Hill and Downs Farm.
On 22nd September 2026, Epsom & Ewell’s Licensing and Planning Policy Committee voted to recommend that Full Council authorise at least six weeks of consultation on the Inspector’s Main Modifications. The consultation has not opened yet, and the dates remain to be fixed.
What has the Epsom Local Plan Inspector proposed?
The council submitted its Local Plan for examination on 10th March 2025. The Inspector was appointed on 1st April 2025 and the examination has since tested whether the submitted plan is legally compliant and sound.
The latest committee papers contain a schedule of the Inspector’s proposed Main Modifications. These are changes the Inspector considers necessary for the plan to be capable of being found sound.
Among the most substantial changes are 16 additional site allocations, comprising 12 urban sites and four sites currently designated as Metropolitan Green Belt.
Planning Geek explains the wider process in our guides to Local Plans and Local Plan examinations.
Four proposed allocations are currently in the Metropolitan Green Belt
The four Green Belt allocations proposed by the Inspector are:
- Cuddington Glade Residential Care Home, at least 70 bedrooms
- Land off Cuddington Glade, at least 45 homes
- Priest Hill, at least 275 homes plus approximately 1,000 square metres of commercial or community floorspace and a landscaped station square
- Downs Farm, at least 530 homes north of College Road, together with an employment hub, specialist school provision of up to about 2.5 hectares and public open space
For Downs Farm, land south of College Road is proposed for open space, playing pitches and walking and cycling improvements towards Epsom Downs station.
These are proposed plan allocations. They are not planning permissions. Any subsequent development would still have to follow the development management process unless another statutory route applied.
For the underlying policy distinction, see Planning Geek’s guide to Green Belt and grey belt.
Housing supply rises from 4,914 to 6,052 homes
The proposed Main Modifications increase the identified housing supply over the plan period from 4,914 to 6,052 homes.
The minimum plan requirement would also rise from 4,700 to 6,012 homes.
Those figures matter because they substantially narrow the gap between the submitted plan’s requirement and the housing which the modified plan is expected to identify.
The Inspector proposes a stepped housing requirement
The modified plan would use a stepped requirement rather than applying one annual figure across the whole plan period.
For 2022/23 to 2025/26, the requirement reflects actual completions, averaging around 152 homes a year. For the remaining years, 2026/27 to 2039/40, the proposed requirement is 386 homes a year.
The effect is to recognise what has actually been delivered in the early years while setting a materially higher annual requirement for the remainder of the plan period.
Planning Geek analysis: stepped requirements can be important at examination because they affect how the overall housing requirement is distributed through time. Here, using actual completions for the first four years does not change what was delivered in those years; it changes how the plan’s annual requirement is expressed across the plan period. The Inspector still has to be satisfied that the resulting strategy and housing trajectory are justified, effective and capable of supporting a sound plan.
Affordable housing and Green Belt policy also change
The Main Modifications include a significant change to Policy S6 on affordable housing. MM62 would require at least 50% on-site affordable housing on the specified Green Belt release allocations SA31 to SA35 and SA48 to SA51, and on other Green Belt sites developed for housing in accordance with national policy, where the policy threshold applies.
The qualifying threshold is schemes of 10 or more self-contained units, or sites of 0.5 hectares or more. The modification schedule shows this as an increase from the submitted 40% requirement for these sites. Greenfield sites within the defined urban area remain at 40%, while the policy sets 30% for other qualifying sites.
The consultation, if authorised, will be on the proposed Main Modifications rather than a fresh consultation on every part of the submitted plan.
The Racehorse Training Zone policy is being rewritten
There is also a notable change for Epsom’s racing and equestrian sector.
The Inspector asked the council and the Jockey Club to prepare common ground explaining the different roles and needs of the Racecourse Area, Racehorse Training Zone and Racehorse Movement Corridors. The proposed modification to Policy DM8 now gives more detail on the training industry, training yards and infrastructure needed to support the movement of racehorses.
The proposed wording would resist the loss of racehorse training yards unless evidence shows no realistic prospect of the use continuing or being re-established, with at least 24 months’ marketing by a recognised agent specialising in the racing-sector property market. It would also require proposals affecting Racehorse Movement Corridors to address racehorse safety and supports schemes which improve safety for horses, pedestrians and other road users.
For Planning Geek’s wider material on rural and horse-related development, see agriculture and equestrian planning.
Design and Green Belt policies are also modified
The schedule contains wider changes to design and Green Belt policies following the examination. These are not merely editorial tidy-ups: the Inspector’s role is to identify modifications needed for legal compliance or soundness.
That distinction is worth keeping in mind. A Main Modification is not the council casually rewriting a plan after submission. It sits within the statutory examination process and must itself be consulted on before the Inspector can complete the examination.
The committee has recommended consultation
The Licensing and Planning Policy Committee considered the modifications on 22nd September 2026. It voted 6 to 3 to recommend that Full Council authorise a statutory public consultation of at least six weeks on the Inspector’s proposed Main Modifications, Policies Map changes and the accompanying Sustainability Appraisal and Habitats Regulations Assessment addenda.
The committee did not alter the Inspector’s package of 12 urban and four Green Belt allocations. The proposed rewrite of Policy DM8 covering the Racehorse Training Zone also remains in the modification schedule. At this stage the council cannot simply rewrite the Inspector’s Main Modifications unilaterally.
The consultation has not yet started. The next scheduled ordinary Full Council meeting is 8th December 2026, although the committee’s decision notice does not say whether the Local Plan recommendation will be dealt with then or at an earlier extraordinary meeting. Consultation dates therefore remain to be confirmed.
What happens next?
If Full Council approves the recommendation, the council will open a statutory consultation for at least six weeks. Representations will be limited to the proposed Main Modifications, Policies Map changes and accompanying appraisal documents, rather than reopening the submitted Local Plan as a whole.
After the consultation closes, all representations will be sent to the Inspector. She will consider them before finalising her examination report and recommended Main Modifications. The plan would then return to Full Council for a final adoption decision.
If Full Council declines to authorise the consultation, the examination cannot progress to the Inspector’s final report on the current basis and withdrawal would again become the issue before councillors.
The practical Local Plan lesson
Planning Geek analysis: the Epsom case shows how much a Local Plan can change during examination without becoming a completely new plan.
Additional allocations, a higher housing requirement, a stepped trajectory and rewritten development management policies can all be introduced through Main Modifications where the Inspector considers them necessary. But the public must then have a proper opportunity to comment on those proposed changes before the examination concludes.
That is why the current status matters. These remain Inspector-proposed Main Modifications, not adopted policy and not yet a live statutory consultation. The committee has recommended consultation, but Full Council still has to authorise it.
Sources and documents
- Epsom & Ewell committee report, Local Plan 2022 to 2040 Main Modifications Consultation
- Appendix 1, Schedule of Inspector’s Proposed Main Modifications
- Epsom & Ewell Licensing and Planning Policy Committee, 22nd September 2026, agenda and decisions
- Epsom & Ewell Local Plan examination page
Updated 24th September 2026: This article has been updated after the Licensing and Planning Policy Committee recommended that Full Council authorise at least six weeks of consultation on the Inspector’s proposed Main Modifications.
Created: 16th September 2026
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