Berkeley Homes Appeal

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Berkeley Homes has lodged an appeal against the decision by Waverley Borough Council to reject their application for 425 dwellings on a green field site (The Maples) to the South of Cranleigh High Street. This site is the size of 29 full sized football pitches.

You can view the application on the Waverley Borough Council planning portal Reference Number WA/2014/0912

The Berkeley Homes appeal is despite 300 objections lodged against the application including an objection letter by the Cranleigh Society.

We have nearly 300 new houses already granted planning permission for Cranleighs Green Fields:
Amlets Lane 125 dwellings
Crest Nicholson Horsham Road 149 dwellings
Cranleigh Brick and Tile Works 19 dwellings

Let your MP Anne Milton know that “Cranleigh says NO to Berkeley Homes”

Always include your FULL NAME AND ADDRESS in your email or letter.

Anne Milton MP anne.milton.mp@parliament.uk

Constituency Address:
17a Home Farm, Loseley Park, Guildford, GU3 1HS

PLEASE COPY IN YOUR CRANLEIGH PARISH COUNCILLORS TOO

List of Cranleigh Parish Councillors:

Cranleigh East:
Stewart Stennett – stewart.stennett@waverley.gov.uk;
Jeanette Stennett – jeanette@stennetts.com ;
Rosemary Burbridge – roburbridge@aol.com ;
Gareth Emmett – gareth@cranleighscientific.co.uk ;
Howard Wagstaff – howardwagstaff@yahoo.co.uk

Cranleigh West:
Brian Ellis – brian.ellis@waverley.gov.uk ;
Patricia Ellis – patricia.ellis@waverley.gov.uk ; 
David Gill – davidgill46@aol.com ;
Dominique McAll – domini.mcall@gmail.com 

Cranleigh North:
Mary Foryszewski – mary.foryszewski@waverley.gov.uk 

Elmbridge:
Robert Wilson – RAW@cranleigh.org

Cranleigh Rural:
Liz Townsend – liz.yourcranleigh@gmail.com

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Architect of Neighbourhood Planning comes to Cranleigh

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**PRESS RELEASE** 21 July 2015

Since setting up in October 2014 life for the Cranleigh Civic Society has been a bit of a whirlwind.

Alongside other communities across the country, Cranleigh has developers queuing up to build on its green fields.

Cranleigh is located in countryside beyond the green belt, is situated on narrow winding B roads, with no train station and a rural bus service unlike the other main settlements (Farnham, Godalming and Haslemere) identified by Waverley for development. With no green belt protection and in the absence of a local plan, we are hugely at risk from speculative development.

Neighbourhood Planning

At the Civic Society meeting on 16 July, John Howell MP, one of the principal architects of the National Planning Policy Framework (NPPF), enthusiastically stressed the importance and ability of neighbourhood planning to deliver the housing that is both needed in Cranleigh and supported by the community. However the reality on the ground feels very different.

Band Room Cranleigh Civic Society Meeting

Our neighbourhood planning group are fighting a David and Goliath battle on two fronts. On the one side there is pressure from Waverley, who do not have a local plan, and on the other side there are a growing number of planning applications for large housing estates on green fields, for which decisions will be made long before any neighbourhood plan is completed. The Localism Act seems a very distant memory.

Strategic Housing Market Assessment

The NPPF states that local planning authorities should use their evidence base to ensure that they meet the full, objectively assessed needs for market and affordable housing in their “housing market area”. This housing need is assessed through a Strategic Housing Market Assessment (SHMA).

Waverley undertook a joint SHMA with Woking and Guildford and the draft report was published in December 2014. This provisionally identified a need for housing within Waverley of 512 to 649 dwellings. These figures were subject to the Government’s 2012 based Household Projections being published. Figures from this report now project a decrease in household numbers of approximately 20,000 per year.

The SHMA also identified the housing mix required between market and affordable housing as outlined in Table 75 of the report:

West Surrey SHMA Table 75 housing mix

In addition to targets in terms of house size, the SHMA also sets a preferred mix for affordable housing of 30% intermediate and 70% social or affordable rented homes.

However housing is not being delivered in the borough in line with this key piece of evidence. In the officer’s report which accompanied the recently approved Crest Nicholson application for 149 houses on a pristine green field site off of the Horsham Road in Cranleigh.

Chantreys Horsham Road Crest Nicholson site

Waverley’s Officers noted that the provision of housing on this site did not comply with the evidence outlined in the SHMA and if this approach was repeated across the borough, they would fail to deliver the identified housing needs. They also confirmed that the affordable housing was not to meet local demand in Cranleigh, as shown in the following excerpt:

Crest Nicholson Cranleigh Waverley Officers Report

You can read the full Crest Nicholson ref WA/2014/1754 – Joint Planning Committee agenda 1 July 2015 and Officers’ Report.

Sustainability and the NPPF

In addition officers state in the Crest Nicholson site report that; ”Cranleigh is one of the more sustainable parts of the Borough”. However this is not supported by Waverley’s own evidence base.

The NPPF splits the concept of sustainability into three pillars; social, economic and environment. In Waverley Borough Council’s own Sustainability Appraisal of the Waverley Local Plan Part 1 Interim SA Report (September 2014) it states that housing need is not focused in this part of the borough and that a significant amount of housing will not provide socio-economic benefits to the Cranleigh community, it also raises concerns about infrastructure. However Cranleigh is still considered as appropriate for high growth as it is ‘relatively unconstrained environmentally’. This lack of constraint refers to green belt and Areas of Outstanding Natural Beauty (AONB).

However there is no weight given within the NPPF to environmental constraints alone when assessing suitability of an area or site, and Waverley in applying such significance to this one pillar seemingly contradicts the golden thread of sustainability that runs throughout the NPPF.

Read the full Waverley Sustainability Appraisal Part 1 – Interim SA Report September 2014 FINAL

Waverley Sustainability Appraisal part one

Protecting Cranleigh

So far approval has been granted for nearly 300 dwellings on green field sites despite hundreds of local objections (Amlets Lane, Horsham Road and Cranleigh Brickworks). We will undoubtedly be faced with more applications for unsustainable development over the next few months. Promises of minor improvements to our immediate roads (signs and traffic lights) do not deal with the bigger issue of traffic congestion on the A281. We have spoken to Surrey Highways who have confirmed that there are no planned major improvements to the wider road network.

Waverley recognises that Cranleigh is different to the other 3 main settlements in that we still have a ‘village feel’ and that this will be threatened by significant development. We think that the character and spirit of Cranleigh is worth protecting. This is what has attracted people to live here in the first place and continues to attract people to Cranleigh. This would undoubtedly be threatened by the approval, in quick succession, for vast housing estates, adding a minimum of 1,300 houses, another 3,120 residents (27% increase in population) and a minimum of 2,100 cars to our road network.

This is NOT sustainable. If you would like to help to protect Cranleigh against urban sprawl then please add your voice to ours and join us. Together we really can make a difference.

Also write to our Waverley Councillors asking them to speak up and protect Cranleigh. The NPPF and Waverley’s saved policies can provide protection to Cranleigh if used consistently.

When emailing please do include your FULL NAME and ADDRESS. Thank you.

Brian Ellis: brian.ellis@waverley.gov.uk

Patricia Ellis: patricia.ellis@waverley.gov.uk

Mary Foryszewski: mary.foryszewski@waverley.gov.uk

Jeanette Stennett: jeanette.stennett@waverley.gov.uk

Stewart Stennett: stewart.stennett@waverley.gov.uk

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McCarthy & Stone Application REFUSED

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We are delighted that the planning Officers of Waverley Borough Council have decided to refuse the application by McCarthy & Stone for this huge apartment block on the Horsham Road and that the residents of Penwerris will keep their homes. We would like to thank everyone who wrote and objected to this application.

You can read the full details on the Waverley Planning Portal Ref WA/2015/0495.

Horsham Road front elevation

McCarthy &Stone Cranleigh

You can read more about this application here.

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Knowle Park Initiative Cranleigh Withdraws Planning Application

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Rather confusing article regarding the withdrawal of the planning application for 265 houses by the Knowle Park Initiative was reported in last week’s Surrey Advertiser.

There is nothing ‘undemocratic’ in the way Waverley Borough Council’s Head of Planning, Matthew Evans has chosen to handle this application.  After all planning is not a democratic process but a Quasi-Judicial one.

You can read the full article here on getsurrey.co.uk : http://www.getsurrey.co.uk/news/surrey-news/planning-application-cranleigh-homes-withdrawn-9639797

The Head of Planning is within his right to refuse a planning application within his delegated powers (to act on behalf of the Council) and not waste time and resources assessing it via a Joint Planning Committee, if he deems the application to be in conflict with the Council’s Policy.

See below an extract from Waverley Borough Council’s Scheme of Delegation to Officers April 2015:
Waverley Borough Council delegated powers to Planning Head

This application still has an Environment Agency (statutory consultee) Objection against it on 2 grounds:-

Firstly that the Sequential Test information submitted with the application demonstrated that there are sites (plural) which are available and are less at risk of flooding that could accommodate 265 dwellings. For Sequential Test purposes, these dwellings do not have to be contained on one single site.

Secondly the EA has determined the following:

Environment Agency objection statement to Knowle Park Initiative

NPPF Point 103 referred to in the Environment Agency’s objection is copied below:
NPPF Point 103

Waverley planners will be aware that if they brought this application to the Joint Planning Committee and it was granted permission against their recommendation to refuse, Cranleigh Residents could take the decision to a Judicial Review, and as the application fails on matters of both national and local policy, and a statutory consultee objection, it is highly likely that they would succeed in getting the decision overturned and Waverley would then be liable for the costs. It is the Officers’ responsibility to safeguard the council from such action.

Letters of support hold no weight when a planning application falls foul of matters of planning policy and the broader National Planning Policy Framework (NPPF).

The “less popular applications” referred to in the article, which have been heard by the joint planning committee, were not deemed contrary to policy by Officers and did not hold the sustained objection from a statutory consultee.

The article goes on to explain that to bring this application to a Joint Planning Committee…
Waverley Borough Council call-in policy for local councillors

In this case the Ward Councillors who could potentially call this in are Brian Ellis or Patricia Ellis.

If a councillor does try to ‘call it in’ they would break with convention and would be acting against the advice of the Head of Planning and the Environment Agency. Both Brian and Patricia Ellis have been very vocal about maintaining the village feel of Cranleigh, protecting its green fields and flooding issues. They have a track record of objecting to large scale green field development to date (Amlet’s Lane, Berkeley Homes & Crest Nicholson). It would seem totally contrary to their actions to make such a dramatic gesture and call this application in on behalf of this developer against Officers’ advice.

You can add your support by emailing them to request them not to call this application in, but to align themselves with the Planning Officers’ recommendation and let it be handled and refused under delegated powers.

Brian Ellis brian.ellis@waverley.gov.uk
Patricia Ellis patrica.ellis@waverley.gov.uk

If the developer really believes that the Head of Planning at Waverley Borough Council is acting in an ‘undemocratic’ way in recommending this application for refusal they are totally within their right to take this further on to the Court of Appeal.

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Cranleigh Conservation Area Review

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Cranleigh Society and Conservation Area Review

As part of the work to shape a vision for the future of Cranleigh village, the Cranleigh Society has been in consultation with Waverley Borough Council, local historians, representatives of Surrey Archaeological Society and representatives of Cranleigh History Society with a view to completing an assessment of the current Conservation Area in the village. The purpose of the assessment is to determine whether the Conservation Area is fulfilling its role of safeguarding the heritage and design assets of the village centre and whether the area covered needs to be amended.

The current conservation area is indicated by the blue line in the image below.

Map of Cranleigh Conservation Area in High Street

Consideration has been given to the three scenarios below with regard to the future of the Conservation Area:

  1. That its extent should be reduced
  2. That its extent should remain as present
  3. That its extent should be expanded

Following this initial assessment:
In regard to Point 1) it was determined that there was no case for reducing the extent of the area covered. The Conservation Area policy has been fairly successful in limiting damage to the natural and built heritage within its bounds.

In regard to 2) it was noted that the current boundary introduced anomalies into the protection offered to the Conservation Area that might be best resolved by:-

3) an expansion of the Conservation Area boundaries, to allow inclusion of properties on the south side of the High Street and areas of Cranleigh Common to the west of the High Street. This would allow the removal of the current anomalous position, whereby one side of the High Street is covered by the Conservation Area but the south side is not. It would also allow for a number of Buildings of Local Merit to be included in the boundary of the area.

Our findings were shared with the Waverley Borough Council working party tasked with reviewing the Conservation Area. The working party has made progress with these proposals and others and will be presenting a draft review for consultation in the not too distant future.

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CREST NICHOLSON HORSHAM ROAD GRANTED

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5 October 2016 UPDATE – Detailed Permission Granted.


24 August 2016 UPDATE – Detailed Planning Permission deferred by Joint Planning Committee


July 2016 UPDATE – Detailed Planning Permission Joint Planning Committee Date 24 August 2016 at Waverley Borough Council


JUNE 2016 UPDATE – Cranleigh Society Objects to application for Full Planning.


JULY 2015 UPDATE The Secretary of State has upheld his decision NOT to request an Environmental Impact Assessment for the Crest Nicholson, Horsham Road, The Chantreys site.


Original Post:
Waverley Borough Council Joint Planning Committee granted permission to the planning application for 149 dwellings on the Crest Nicholson Horsham Road site in Cranleigh on 1 July 2015. The public gallery was full of concerned Cranleigh residents, including members of the Cranleigh Society.

Liz Townsend and Malcolm Terson spoke on behalf of residents.

It was a close decision, with many Councillors expressing their concerns for building on this beautiful green field, in the end the vote was 9 to 10 with the Chair of the meeting casting the deciding vote.

Environmental Impact Assessment

The Cranleigh Society informed the committee that during the first scoping stage of this application the Secretary of State (SoS) had issued a screening direction dated 25 August 2014 stating that an Environmental Impact Assessment was not required. The SoS_sreening opinion Horsham Road stated that (extracted paragraph below):

Paragraph from Secretary of State Screening Direction 25 August 2014

However as the other planning applications referred to in the letter were at an early stage the SoS decided that it was inappropriate to consider cumulative impacts with this proposal.

Since August 2014 Amlets lane site was approved for 125 dwellings, with work expected to commence soon. On 22 June 2105 the Eastern Planning Committee granted full permission for the Cranleigh Tile and Brickworks site, resulting in 70 HGV traffic movements a day to and from the site for a minimum of 5 ½ years in order to carrying building waste to create a cap for the considerable pollution on the site.

In the light of this new situation, the Cranleigh Society believe that there was a realistic prospect that the Secretary of State could come to a different conclusion with regard to the need for an EIA.

A screening decision must be lawful at the date of any planning permission. Unless a screening direction is referred back to the Secretary of State, there is a real risk that permission may be granted for development which is likely to have significant environmental effects without those effects being properly considered, contrary to Article 2.1 of the EIA directive.

We have asked the Secretary of State to intervene and request a deferment of a decision on WA/2014/1754 until he has reviewed the implications of the change of circumstances and decided whether an EIA is now applicable for this site. This is currently being considered by the Secretary of State.

Five Year Housing Supply

The council states that as it currently can not demonstrate a five year supply of deliverable housing sites, for housing applications, in so far as Policy C2 is a housing supply policy, under paragraph 49 of the NPPF, this policy must be considered out of date.

We asked Councillors to consider recent observations that there would be an oversupply of housing should deliverable green field sites be included in the recently published 5 year housing supply report. Also no robust evidence exists to suggest a number of green field sites should not be included in the five year supply.

We would also reiterate that in the case of Crane v SoS, Justice Linblom was clear with regards to the weight given to out of date policies in the absence of a five year supply:

“neither paragraph 49 of the NPPF nor paragraph 14 prescribes the weight to be given to policies in a plan which are out of date. Neither of those paragraphs of the NPPF says that a development plan whose policies for the supply of housing are out of date should be given no weight, or minimal weight, or, indeed, any specific amount of weight. One can of course infer from paragraph 49 of the NPPF that in the Government’s view the weight to be given to out of date policies “for the supply of housing” will normally be less, often considerably less, than the weight due to policies which provide fully for the requisite supply. …In Grand Union Investments Ltd. (at paragraph 78) I endorsed a concession made by counsel for the defendant local planning authority that the weight to be given to the “policies for housing development” in its core strategy would, in the circumstances of that case, be “greatly reduced” by the absence of a five-year supply of housing land. However, the weight to be given to such policies is not dictated by government policy in the NPPF. Nor is it, or could it be, fixed in the case law of the Planning Court. It will vary according to the circumstances, including, for example, the extent to which the policies actually fall short of providing for the required five-year supply, and the prospect of development soon coming forward to make up the shortfall.
But in any event, however much weight the decision-maker gives to housing land supply policies that are out of date, the question he has to ask himself under paragraph 14 of the NPPF is whether, in the particular circumstances of the case before him, the harm associated with the development proposed “significantly and demonstrably” outweighs its benefit, or that there are specific policies in the NPPF which indicate that development should be restricted. That is the critical question. The presumption in favour of the grant of planning permission in paragraph 14 is not irrebuttable. And the absence of a five-year supply of housing land will not necessarily be conclusive in favour of the grant of planning permission.”

With other significant sites in the local area coming forward, it could be reasonably argued that there are sufficient deliverable sites that are reasonably available within the plan period, as defined in NPPF (footnote 11):

“To be considered deliverable, sites should be available now, offer a suitable location for development now, and be achievable with a realistic prospect that housing will be delivered on the site within five years and in particular that development of the site is viable.”

Planning permission is not a requirement for a deliverable site, indeed Footnote 11 of the NPPF specifically does not preclude sites where planning permission has not yet been granted.

In view of the reasonable existence of deliverable sites the lack of a five year supply of housing should not be given such significant weight and policy C2 can be applied in its normal form.

Waverley Borough Council policy C2

Location

Cranleigh village experiences regular flooding and was cut-off by flood water on Christmas Eve 2013, pressure on the sewage system also resulted in seepage into homes, including 17 houses adjacent to this site. In this singular event 56.8mm of rain fell on Cranleigh (source EA measurement taken between 10:30 on 23/12/13 and 05:15 on 24/12/13).

Based on recorded flood levels, it is estimated that the magnitude of flooding on this occasion was greater than the modelled 1% (1 in 100 year) annual probability flood plus an allowance for climate change and only 56mm lower than the modelled 0.1% (1 in 1,000 year) annual probability flood.

The site consists of sloping agricultural fields which are used every year for grazing sheep. It is located within the Countryside beyond the Green Belt outside any defined settlement area. Policy C2 of the Local Plan states that building in the countryside, away from existing settlements will be strictly controlled.

The Downs Link borders the west of the site with an allocation of higher density housing proposed for this area which will be easily viewed from the footpath. There will also undoubtedly be a loss of privacy for neighbouring dwellings, many of which have minimal fencing in order to enjoy views of the open landscape.

Crest Nicholson Chantreys Cranleigh site plan

This development will have an urbanising effect on the Downs Link. It also abuts a Site of Nature Conservation Importance (SNCI) to the South and is within 2km of an Area of Outstanding Natural Beauty (AONB). There will also be the considerable loss of 5 Grade A oak trees which Officers state are of significant public visual amenity.

The NPPF states in paragraph 38 that developments should be located so that key facilities such as primary schools and local shops are within walking distance of most properties. This is not the case for this site where car usage would be heavily relied upon and public transport opportunities are limited.

“Walkable neighbourhoods are typically characterised by having a range of facilities within 10 minutes (up to about 800m) walking distance of residential areas” this site exceeds this limit and residents will heavily rely on car usage.

The site is approximately 1.35km (17 mins walk) from the outer edge of the site into the village (Stockland Square) and this increases to 1.8 (23 mins walk) from the inner edge of the site.

Crest Nicholson distance to Cranleigh High Street

Using the Downs Link ramp exit at the edge of the site it is approximately 1.67 km (approx. 1 mile and 21 mins walk) to Stockland Square.

Distance displayed on map fromCrest Nicholson Chantreys site via Downs Link

From the eastern edge of the site, walking to the village using the Downs Link this distance increases to 2.25 km (28 mins walk).

The Downs Link is an unlit, unmade rural footpath which is extremely muddy for long periods of the year and unsuitable and unsafe for daily journeys to and from the village.

Muddy Downslink in Cranleigh

Distance from Main Schools

Cuthbert Mayne Catholic Primary School 1.3km (15mins)
Glebelands (no sixth form on site) and opposite Cranleigh Primary School 1.7km (20 mins)
Park Mead Primary School 2km (25 mins)
Godalming Sixth Form College is 9.5 miles from Cranleigh (15.2km).

The above calculations use the accepted average walking distance for adults of 3mph or 4.83 km ph. Children walk at a slower pace of approximately 5.32 to 5.43 km ph.

Bus Service

The only available form of public transport is a rural bus service (no 63 and 63X) that runs along the Horsham Road. The service consists of 2 buses an hour to Horsham in the South and the same to Guildford in the North (the last bus is approximately 20:00 on a weekday). This service only runs on Saturdays until approximately 18:00 and there is no service on Sundays.

Flood Risk

The Flood Risk Assessment for this site makes no mention of water quality from runoff released into the watercourse or of the widely reported serious flood event in December 2013, including 17 houses adjacent to this site. On page 55 of the Officer’s report it states that there is no flooding associated with the Holdhurst Brook although despite several residents’ objections that dispute this.

The basic outline for the SuDS proposal for the only seeks to mimic greenfield runoff. There is simply not enough detail provided in the attenuation storage or long term storage calculations to be reasonably certain that these SuDS are adequate, provide betterment and will not fail.

Housing Mix

Paragraph 50 of the NPPF states that planning authorities objective should be to create mixed and balanced communities.

As outlined in the Officer’s report page 34 onwards the site fails to deliver the housing mix, including the provision of affordable housing, that is outlined in the West Surrey SHMA 2014 and contravenes paragraph 50 of the NPPF on more than one point which states that planning authorities should:
“plan for a mix of housing based on current and future demographic trends, market trends and the needs of different groups in the community”
in addition to:
“identify the size, type, tenure and range of housing that is required in particular locations, reflecting local demand”

The 149 dwellings on this site are split as follows:

Housing mix Crest Nicholson Chantreys site Cranleigh

59.5% of the houses on this site are 4+ bed which does not comply with the evidence in the West Surrey Strategic Housing Market Assessment (2014, SHMA). The report assesses the need for housing of this size at only 20%. This site provides nearly 3 times the figure quoted in the SHMA.

SHMA size housing needed

It is also misleading for the applicant’s agent to claim that the public consultation pointed firmly to the site being a lower density, family dwelling house scheme, to justify the over provision of larger properties. Only 78 feedback forms were received by Crest Nicholson – 4 supportive, 34 objecting and 40 with a range of concerns.

Officers in their report recognise that this development fails to comply with the SHMA and if this pattern were to be repeated across the borough it would fail to deliver the wide choice of homes for the needs of different groups in the community.

The Officers’ report recognises that the affordable housing on the site is also not being provided to meet local needs in Cranleigh, which has a lower demand, and will be offered borough wide. It also states that the applicant is failing to meet the 50:50 affordable rent/intermediate split outlined in the SHMA.

This development fails to meet both the identified requirements for market housing and for affordable housing. If green fields are to be built upon it should be in direct response to identified housing need.

Site Access

There is a single access point to the site or 149 homes. A site of this size could generate an additional 300 cars which would have a significant impact on Cranleigh’s rural road network and our high street. We are not convinced by the applicant’s claim that 35% of residents will work “less than 2km” from home, when currently the average for Cranleigh is 21.7%.

There is no continuous pavement provided for pedestrians from the site entrance on the western side of the Horsham Road directly into the village, or to the bus stop on the Horsham Road for the service heading North towards Guildford.

Thames Water

Thames Water has stated that the existing system can not handle the increased foul drainage.

Residents in Horsham Road already report periodic foul water flooding. We are involved in an ongoing investigation with Thames Water and EA concerning a large and uncontrolled amount of sewage entering the surface water drainage network which is yet to be resolved and could be indicative of a major problem with Cranleigh’s main sewer.

Our Conclusion

This application should at the very least have been deferred until it is confirmed by the Secretary of State that an EIA is not required and the cumulative effect of development on Cranleigh and surrounding villages has been reviewed. It has been suggested that going ahead with a decision on the application whilst residents’ request is being considered could put that decision in jeopardy.

Specific weight cannot be applied to out of date policies. It could be reasonably demonstrated that Waverley has a five year housing supply when taking into account appropriate green field sites.

Policy C2 can be applied in its normal form. This application by virtue of its scale, number of dwellings and urbanising impact, including that on the Downs Link, and harm to landscape character would cause material and detrimental harm to the character and setting of the existing settlement and the intrinsic character, beauty and openness of the countryside contrary to policy C2, D1 and D4 of the Waverley Local Plan 2002 and paragraph 17 of the NPPF.

Contrary to policy D1 due to the openness of neighbouring properties there will be a reasonable loss of amenity in the form of privacy and light and levels of traffic which are incompatible with the local highway network when taking the cumulative impact of the HGV movements for the recently approved land recovery at the Cranleigh brickworks site and construction traffic for 125 dwellings on Amlets Lane.

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