Brook Sewage Saga Goes On!

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We first wrote about the sewage in the brook saga on 2 June 2015. Can you believe it, nearly 17 months later and the problem is still not resolved.

map of raw sewage entering watercourse in Cranleigh

In the intervening months Cranleigh Civic Society has sent countless emails and made several calls to Thames Water, the Environment Agency and Waverley Borough Council’s Environmental Health Department.

The fact that this problem seems to have been going on for over 7 years, some residents say longer, is a disgrace.  We can’t help but feel that there is something seriously wrong with our sewerage system when the continued discharge of raw sewage into a brook off the high street remains unchecked for so many years.

After unsuccessful attempts to get the brook problem resolved, in April 2015 the Cranleigh Civic Society took water samples, got them analysed at an independent specialist laboratory and reported the results to the Environment Agency (the E coli result was 24 times above the allowable limit).

section of brook in Cranleigh with raw sewage

The Environment Agency response was immediate, they elevated the brook to “Priority Status” and the very next day they served a 30 day notice on Thames Water to deal with the issue.

In May 2015 a cleanup of the brook took place and Thames Water commenced a series of extensive dye tests around Cranleigh, whilst keeping us informed of their progress.

sewage-from-brook-27-05-16

On 1 June 2015 Thames Water confirmed that they had found units on the High Street that had misconnected their foul sewer lines into the surface water sewer draining into the brook. The two properties were advised how to resolve this issue, and we understand that arrangements were made for the connections to be made to the correct sewer system.

However, Thames Water continued with their investigations, as they advised us that two units could not on their own account for the extent of the problem in the brook.

Subsequently, they carried out more camera and dye testing working their way down the High Street sewers.

In August 2015, the Environment Agency (EA) confirmed that Thames Water had discovered a significant misconnection, again located in the High Street.

Apparently, according to Thames Water remedial work for this issue was completed in October 2015; and it was understood that this should resolve most of the issues in the brook.

Thames Water said they were also aware of a couple of  minor outstanding issues  (sinks that need re-plumbing) that they were going to follow up. However, it was stressed that these shouldn’t cause significant growth of fungus in the brook.

Finally, EA confirmed that Thames Water were continuing to work on the problem, including doing some additional clean-up work – “after which they believe they will be able to better judge whether or not there are any other significant misconnections or other pollution sources.”

However that was not the end! After further reports of continued sewage in the brook yet another clean up was carried out on 26 November 2015.

010a2a8f0c3650373e8d31dd92a41025cc480973c0

There was a a lull over the winter months with the onset of heavier rainfall and colder temperatures.  However, in April 2016 sewage was reported to be discharging into the brook once more.

Cranleigh Civic Society advised the EA on 4 May 2016 once again that with the onset of warmer weather sewage fungus was flourishing in the brook  (see image below).  You can also see that a bund (grey pipe),  had appeared across the exit point of the surface water sewer pipe, which was not even touching the surface of the brook, and therefore was of no use whatsoever.

4 May 2016 Brook Cranleigh sewage fungus

On 6 May 2016 the EA replied confirming that “We were made aware of a ‘sludge-like deposit’ on the bed of the channel in the Knowle Park area on the 28/04/16. Thames Water attended the incident within 2 hours of the report. They were unable to identify a discharge to the river, but have logged the incident and confirmed to us that they will be sending out a member of their network team to investigate this matter further. We are currently awaiting further information from them.

On 9 May 2016 the EA confirmed that they had been in contact with Thames  Water who had carried out a CCTV survey of the sewers in the areas and have detected a “small leak from the foul sewer” into the surface water drain.

The solution they said was for Thames Water to re-attend the site to plan works to rectify the issue  The proposal was to to reline the leaking sewers or reroute them.

EA also confirmed that “the incident is having a localised low-level environmental impact on the channel that feeds the Littlemead Brook near Knowle Park. Approximately 10m of the channel was observed to be impacted by sewage fungus.

We have seen no major sewer relining/rerouting work taking place.

9 September 2016 and residents reported sewage fungus again in the brook, which we subsequently reported to Thames Water and Environmental Health at Waverley.  Tankers arrived on 12 September to suck out sewage from the brook and so the problem continues…….

A resident advised us that they had a telephone call on 14 September 2016 from Thames Water confirming that a tanker would be going to the brook on Knowle Lane every six weeks to pump out the sewage until the problem was solved.

The latest email from Thames Water on 19 October 2016 repeats the same old unacceptable story of unknown sewage misconnections into Thames Water’s  surface water sewer in the High Street discharging into the brook:

From the latest reports received, it would appear that there may be further and previously unidentified properties that also have misconnected sewer pipes and we will have to arrange for further testing and investigations to be carried out. I have asked that one of our Engineers reattend Cranleigh High Street and carry out further investigations into the reported problems.”

Thames Water confirmed that they would provide an update by no later than 2 November 2016.  We are not holding our breath.

We want to know what is really going on with the sewerage network in Cranleigh?  Is there a significant problem with the ageing main sewer running down the high street? Is the sewage tank on the corner of John Whiskar Drive and Knowle Lane leaking into the brook?

Against this backdrop of issues, Waverley Borough Council keep granting planning permission for huge estates in and around the village, taking no account of this and other ongoing sewage problems.  For the latest application by Thakeham Homes,  Thames Water has not even applied a Grampian style condition requiring upgrade work to the sewerage network prior to commencement of the development.  This is completely unacceptable.

We intend to keep investigating the problems with our sewerage network and water supply and will keep you updated as soon as we can.

We have kept our MP Anne Milton informed of the situation and she has also been pressing Thames Water for answers.  If you are concerned please email Anne Milton anne.milton.mp@parliament.uk and ask her to continue to pursue this matter on your behalf.  Thank you.


Cranleigh Civic Society is run completely by volunteers, please help us to keep you informed and become a member.

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Thames Water Object to Thakeham Homes

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Thames Water have objected to the Thakeham Homes site for 58 dwellings off Elmbridge Road on the grounds of odour emanating from Cranleigh’s Sewage Treatment Works (STW).

In a document published against the application Thames Water state that:

“Cranleigh STW is located close to the proposed development. Our consultation response reflects our concern that the applicant has failed to demonstrate that future occupiers of the proposed development will have adequate amenity. Given the proposed development’s close proximity to the Sewage Asset we object to the planning application.”

They go on in the document to report that:

Odour

Odour can be a particular issue at our sewage assets. It is important to ensure that development which might be sensitive to the odour environment in the vicinity of existing assets is not permitted to take place unless:

(a) it can be established that it will be located or designed in such a manner as not actually to be sensitive to such odour;

(b) or that funding is made available by the applicant for the installation of odour treatment apparatus sufficient to overcome any conflict between the development and uses proposed.

To address odour as an environmental impact, the applicant should submit an odour assessment to demonstrate that there will be no adverse impact in relation to odour. The odour assessment should be based on assessing onsite odour emissions. The assessment should also include an outline of an odour mitigation measures strategy.

If the odour assessment is considered acceptable by the local planning authority and Thames Water, then we would request that any proposed mitigation that is set out in the odour assessment is controlled via a planning condition.”


You can read the full response from Thames Water here:

Thames Water Objection Thakeham Homes Cranleigh


We are extremely interested to discover how Thakeham Homes will locate and design their houses “as not actually to be sensitive to such odour“. Completely sealed units perhaps, with a garden in a bubble?

As well as seeing what “odour treatment apparatus” they will fund to “overcome any conflict between the development and uses proposed” – Perhaps the standard issue of nose pegs?

Finally, Thames Water have requested, at last, an odour assessment and mitigation to be included in a planning condition.

The condition suggested by Thames Water if the planning application is approved is:

“There should be no occupation of the development until the recommendations of the odour mitigation strategy have been implemented and are operational.”

So Thakeham could still go ahead and build, but no one can move in until the anti-odour strategy is deployed!

And what about the odour assessment, will this be a mere desktop, box ticking exercise, or will real sniffers and survey forms be employed?

Odour assessments can take several months and measurements should be taken at various points in the year.  Summer months can be the most troublesome for residents due to high temperatures.  It is also widely recognised that you cannot rely on a history of complaints, as, although public complaints provide evidence that there is a problem in a given area, they provide no real indication of the actual magnitude of the underlying problem, or the potential for impact on areas proposed for new development. This is because people very often don’t register a public complaint to authorities due to a number of personal reasons, which are unrelated to the extent of the odour nuisance.

We wait to see if, and when, a “real” odour assessment will be carried out.

We have reported that expansion work is taking place at the treatment plant, for which no planning permission, or odour assessment was required.  However, as you are aware we are still investigating this matter.

What we know is that we have existing residents who cannot use their gardens on hot summer days, suffer fly infestations, and only yesterday we had yet another email from a resident confirming that  “I am having to shut my bedroom windows at night due to the smell from the Cranleigh sewage  works.”

Thames Water are obviously concerned about the pong for new residents of the site, we are too, but we are extremely concerned about the pong for existing residents who already live here, and the impact on their quality of life.

Residents near to the sewage treatment works are facing expansion works and a significant increase in sewage being processed at the Elmbridge Road treatment works due to the huge amount of new development already granted in and around Cranleigh.  Another 58 dwellings will only add to, what is already, odour nuisance, and there is still no mention of further environmental damage to Cranleigh Waters, into which mounting levels of liquid sewage effluent is discharged.

If you are concerned about the effect of this application please follow the instructions in our post and add your comments against the Thakeham Homes Planning Application WA/2016/1921.

Cranleigh is being being dumped on! There is no consideration for existing residents, or for sustainable development.  Please add your voice to ours and together we can speak up for Cranleigh.

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Surrey Say Permission Not Needed for Sewage Works Expansion

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Following on from the article below on 4 October confirming that Surrey County Council’s  Enforcement Team were investigating whether Thames Water should have applied for planning permission, and carried out a full odour impact assessment, prior to expansion at Cranleigh’s Sewage Treatment Works:

Surrey County Council Investigate Odour Survey Results

We have now had a reply from Surrey County Council’s Senior Planning Enforcement Officer confirming that members of the enforcement team had been to Cranleigh Sewage Treatment Works and that:

Works were underway for the construction of two 30 m diameter filter beds, with the disposal of excavated spoil on site.  Thames Water maintained that the development was Permitted Development (PD).  We believe however that they failed to interpret the Regulations correctly and that screening to determine whether there is a need for an Environmental Impact Assessment (EIA) should have been done in advance.


An EIA is Environmental Impact Assessment (EIA) is the process by which the anticipated effects on the environment of a proposed development or project are measured. If the likely effects are unacceptable, design measures or other relevant mitigation measures can be taken to reduce or avoid those effects – http://www.epa.ie/monitoringassessment/assessment/eia/ 


The Officer went on to refute the need for an EIA by saying that based on subsequent information supplied by Thames Water the works were lawful and:

notwithstanding the scale of activity the development did not require an EIA.

Strong and unpleasant sewage odour continues to plague residents living near to the sewage treatment works and in other areas of Cranleigh. The current work being carried out is increasing capacity on the site by approximately 30%.  This expansion we were advised was not to accommodate the 1,520 new dwellings being proposed for Cranleigh, of which nearly 800 have now been granted planning permission by Waverley Borough Council.

In the future, residents living near to the sewage works are going to be faced with further expansion work to accommodate new dwellings in and around Cranleigh, and this may lead to a significant increase in sewage odour problems, in addition to increases in pollution levels in Cranleigh Waters from liquid effluent.

We are  determined to ensure that the impacts on existing residents are taken into consideration and intend to continue to press Surrey County Council on the need for planning permission.

On 22 October we wrote again to Paul Warner, Senior Planning Enforcement Officer at Surrey County Council, (we are also keeping our MP Anne Milton fully informed of this situation) requesting:

Dear Mr Warner,

May we ask you one additional question please?

One of the safeguards put in place by the planning process is to ensure that a valid “Permit to Discharge” has been issued by the Environment Agency before any above or below-ground extension capacity works are done at sewage treatment plants.  Because CPA [County Planning Authority] is trying to short-cut the planning process, we assume that this important safeguard has not been assessed.

Thames Water themselves acknowledge this.  In an email dated 09-Feb-16 to Cranleigh Civic Society, Thames Water said “if Thames Water intend to increase the capacity of the works then the permit will be reviewed and re-modelled.”

Permits to Discharge used to be issued to Cranleigh STW every year or so (Cranleigh Civic Society has got back copies of them), but the last one was issued right back in 2009.  The Environment Agency has told Thames Water that they can’t currently renew the 2009 permit because it is “technically infeasible” for Thames Water to meet current chemical requirements (phosphate content for example).  Thames Water acknowledges this, and they have written to Anne Milton MP (Anne Milton has been copied in on this email) to explain that there are ongoing trials to see if a new process can be adopted to meet current phosphate limits.  The results of these trials are expected later next year, and no one knows yet of course if these trials will prove productive.

The Environment Agency started work on producing a new Permit Limit for Cranleigh STW on 12-May-16, but it will be subject to a successful result to these trials next year, and also to flow-rate infrastructure work being carried out to previously dredged areas of Cranleigh Waters (this work has not been date-programmed yet).

Because Waverley Borough Council has not carried out a full Water Cycle Study for the Borough, we are assuming that they have not pointed these facts out to CPA.  And if CPA allows the STW extension works to continue, they are contravening the 2027 WFD “work towards good status” requirement.

So our question is, has CPA taken the above into account in deciding that an EIA is unnecessary?

We are still reviewing your email dated 19th October and taking advice before replying.

Yours sincerely


If you are concerned about increased odour from Cranleigh Sewage Treatment Works blighting your home please contact your MP Anne Milton anne.milton.mp@parliament.uk and copy in Cranleigh Civic Society info@cranleighsociety.org insisting that Thames Water apply for planning permission for expansion works and carry out  a full odour impact assessment.

Together we need to speak up for Cranleigh!

Please become a member of the Cranleigh Civic Society- a community run organisation run entirely and tirelessly by volunteers.

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Thakeham Homes Apply for Planning Permission

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Another application for planning permission for a further 58 dwellings by Thakeham Homes on a green field site off the Elmbridge Road, that regularly floods, and is one of the last  pieces of Cranleigh’s rapidly diminishing Flood Plain.

Please add your comments against this application Reference WA/2016/1921 (decision date 29 Dec 2016) on the grounds that:

  1. The site is subject to regular flooding and the flood risk has been significantly underestimated.
  2. Up-to-date allowances for flooding and climate change (16 February 2016) have not been used.
  3. Water quality in Cranleigh Waters will be detrimentally affected by this application and it does not comply with the Water Framework Directive.
  4. The sewerage infrastructure is not adequate to deal with sewage from this site, particularly taking into account the cumulative impact of other already granted developments in Cranleigh.
  5. The site is not deliverable within 5 years.
  6. The site is a green field site and there are other identified brownfield sites in Cranleigh, which can provide a higher number of dwellings and are nearer to the high street.
  7. The distance of this site from the high street means that residents will have a heavy reliance on the use of a private car.

Full instructions on how to add your comments online.

Or email your comments to the case officer Chris French direct on planconsult@waverley.gov.uk quoting ref WA/2016/1921 and include your FULL name and Postal Address.

Or write to Waverley Borough Council at (please quote ref WA/2016/1921 and include your FULL name and Postal Address):
Chris French
Planning Officer
Waverley Borough Council
The Burys
Godalming
Surrey
GU7 1HR


Additional information :

Flood Risk

Thakeham Homes in partnership with Stovolds Hill Farms Limited have submitted an application for 58 dwellings to Waverley Borough Council ref WA/2016/1921.

The application site is bordered on two sides by the Environment Agency designated main rivers – Cranleigh Waters and Littlemead Brook.

thakeham-homes-main-rivers-labelled

A significant part of the site is in flood zones 2 and 3.

The following image is of the Environment Agency’s Flood Map for Planning (this map does not include an allowance for climate change):

ea-flood-map-south-elmbridge-rd-thakeham-homes-site

This is the reality – Thakeham Homes Site Elmbridge Road 24 December 2013:

pumping-station-elmbridge-road-24-dec-2013

elmbridge-road-pumping-station-24-12-13

January 2015:

thakeham-homes-site-jan-2015-1

thakeham-homes-site-jan-2015-3

thakeham-homes-site-jan-2015-2

28 March 2015:

elmbridge-road_2-28-march-2016

A Flood Risk Assessment Report dated August 2016 has been produced by Cannon Consulting Engineers on behalf of the applicants.  However, the Environment Agency Flood maps included in the report are dated 26 January 2016 and appear to only include a 20% allowance for climate change.  This does not take into account the revised climate change allowances by the government and the Environment Agency published in February 2016.  These now require applicants and developers to assess a range of climate range allowances from 25% to 70% above the 1% AEP as part of planning applications.  As the application appears to have been submitted to Waverley on 7 September 2016 the new allowances should be used.

The Flood Re Insurance Scheme will not cover these properties

Consultants Cannon Consulting Engineers have been unable to locate the name of the main river-  Cranleigh Waters, they state on Page 2 of their report that:

2. The off-site watercourse which flows northwards some 40 m to the west of the site is apparently unnamed on mapping or in reports, but is again a Main River. The watercourse is a tributary/the headwaters of the River Wey.

The image below taken from the Cannon Report shows Label 2 indicating the “unnamed” main river – not very reassuring for local residents.

cannon-consulting-report-aug-2016-rivers-labelled

We also have major concerns that this development would increase flooding for vulnerable residents at Cedar Court in Elmbridge Village and residents of Elm Park.

thakeham-homes-flood-and-cedar-court


Water Quality and Sewerage Infrastructure

Cranleigh Sewage Treatment Works (STW) is at capacity, current upgrade works, adding 2 new filter beds are to improve resilience for existing residents, and not to accommodate an additional 793 new dwellings already approved by Waverley.  This figure may shortly be increased by a further 120 dwellings following the result of the recent appeal for the brownfield site – Hewitt’s Industrial Estate.  The cumulative effect of these dwellings on the STW and on Cranleigh Waters, into which the liquid sewage effluent is discharged, we believe should be considered as material constraints by Waverley Planning Officers.

National Planning Practice Guidance Paragraph : 016 Reference ID: 34-016-20140306 states that Water Quality is likely to be a significant planning concern when a proposal would affect a water body “– through a lack of adequate infrastructure to deal with wastewater.”,  we strongly believe this is the case with regard to the situation in Cranleigh.  This application should therefore be assessed against the harmful impact on water quality in Cranleigh Waters and the Water Framework Directive,  and the applicant should be able to explain how the proposed development would impact on water quality and how they propose to mitigate these impacts.

Local planning authorities have statutory duties to deliver water quality as outlined in the Water Framework Directive (WFD).  This directive established a legal framework for the protection and promotion of sustainable water management of surface waters and groundwater.  WFD requires all inland (which would include Cranleigh Waters) and coastal waters to achieve “good” status by 2027.

Data released by the EA in 2015 provided reasons for not achieving good status in Cranleigh Waters in their River Basin Management plan and attributed this to continuous sewage discharge.  This indicated that all three key water body pollution indicator categories, Solids, Biochemical Oxygen Demand and Ammoniacal Nitrogen were being exceeded.

Cranleigh Waters is failing in terms of the WFD, particularly with regard to phosphates.  This is confirmed in the High Level Water Cycle Study carried out by Capita for Waverley in August 2016, as evidence for the Local Plan Part 1.


Read the Capita Report in full – wbc-high-level-water-cycle-study-wastewater-final-18-august-2016-issuedm 


The failing status was also confirmed by the Environment Agency (EA) in an email to Cranleigh Civic Society on 25 February 2016 at 16:56:44 GMT (shared with Waverley Borough Council at the time) confirming which elements Cranleigh Waters was failing, and also adivsing of water company trials taking place to meet tighter permit levels required for discharged liquid effluent under WFD:

“The elements that are not passing are Phosphate (moderate status), macrophytes (moderate status) and diatoms (poor status). Macrophytes and diatoms are ecological indicators of phosphate pressure. Therefore the permit has been reviewed recently with respect to these failing elements (Summer 2015) and it was identified that to improve this status a permit would be required that currently is technically infeasible. As mentioned previously water companies are undertaking trials to try and identify technology that would be capable of treating effluent to meet these tighter permits. The Environment Agency will be tracking the success of these trial and the permits will be reviewed if the technology becomes available to treat to these tighter levels.”

The “permit” referred to in the EA’s email was issued to Thames Water in 2009 as part of blanket conditions to bring discharge permits in line with other Combined Sewage Overflow permits.  This has not been renewed since 2009 and was not based on WFD legislation. It also relies on a certain level of dilution in Cranleigh Waters, which is no longer available due to extremely low to non-existent flow levels, particularly during summer months.  At times the flow past the STW discharge point is almost 100% effluent.

cranleigh-waters-stw-discharge-point

As advised by the EA, water companies are undertaking countrywide trials in an attempt to bring effluent levels in line with WFD, the results are not due until 2017.

In the absence of an up-to-date environmental permit based on WFD to discharge into Cranleigh Waters and the need for new technology to process sewage to comply with WFD, it would be reasonable to assume that the cumulative effect of this application by Thakeham Homes, and other development in and around Cranleigh would cause further environmental harm and have a significant negative effect on Cranleigh Waters.

Waverley has a responsibility to ensure that a development does not increase pollution.  Planning Officers are aware that Cranleigh Waters is failing with regard to WFD.  The effluent from an additional 58 dwellings would have a further detrimental effect on water quality and would prevent the river achieving “good” status by 2027.  This contravenes the local authorities obligations under WFD.

Cranleigh Waters Overview

The Environment Agency has confirmed that Cranleigh Waters is ephemeral (suffers from low to no flow) and eutrophic (resulting in low oxygen levels) .

EA website maps as at 05-Mar-16 indicated that:

  • Cranleigh Waters is in “Drinking water safeguard zone” (zone ends at Shalford).
  • Cranleigh Waters is in a “Nitrate vulnerable zone”, so “Eutrophic”.
  • Cranleigh Sewage Treatment Works shown as “Water industrial pollution: Significant”
  • Cranleigh Waters Ecological Quality rated “Bad”. Must be “Good” by 2027 to meet Water Framework Directive (WFD)

In addition to awaiting the outcome of the water company trials, to comply with WFD, and the need for strategic expansion works at the STW off the Elmbridge Road, consideration must be given to the now regular low flow rate of Cranleigh Waters.

With an average daily discharge from the Cranleigh Sewage Works, recorded in 2014, of 5143 m3 (over 2 Olympic-sized swimming pools per day) and, at times, low to no flow in the Cranleigh Waters upstream of the STW, pollution has increased.  Shamley Green Angling Society has confirmed that there are depleted fish stocks in the river.  At times the flow downstream of the STW discharge point is almost 100% liquid effluent.  This encourages the growth of algae in the river, called eutrophication, meaning that it is rich in nutrients and promotes plant growth, leading to low oxygen levels, at the expense of providing a suitable habitat for fish, amphibians and invertebrates.

Some fish may be still present in the river but they will be stressed, suffering large amounts of suspended biodegradable matter (toxic silt, algae etc.) that clog and irritate their gills.  Fish will not feed or spawn in these situations and over long periods of deoxygenation they will become weak and die. The food chain then starts to deteriorate with invertebrate death, then a cascade ecosystem failure ensues. This results in a dead system that will take decades to recover and only then if sources of pollution are stopped or technology becomes available to filter the harmful elements out of effluent discharge.

A local member of the angling society confirmed that “As once you could walk the banks of Cranleigh Waters of an evening and see a myriad of ephemerides hatching from the river surface, splashes of feeding fish and a host of water creatures feeding on this bonanza. Now you will see very little surface activity, no ephemerides, dragon flies or demoiselles that once used to fly over this river in large quantities.  In the past the river margins were alive with large shoals of juvenile fish, now only mosquito larva are noticeable.  We have a dying river that needs help. Further expansion of the sewerage works means a greater capacity of polluted discharge into this failing system. The choice is simple, we sit back and let this river die and let its polluted water flow (slowly) into the River Wey at Shalford where it then becomes somebody else’s problem.”

The following image taken upstream of the STW on 18 August 2016, clearly shows a river depth of approximately 2 inches.

cranleigh-waters-18-aug-16

Cranleigh Civic Society also took flow measurements (Geopacks ZMFP51 Flow Meter) on the 7th September 2016 and recorded at 13.61 l/s (averaged over several measurements):

cranleigh-waters-flow-measurement-07-09-16


Deliverability

The Cranleigh Civic Society questions the deliverability of this site.  There are already a number of Grampian style conditions on approved planning applications with regard to water and sewerage infrastructure.

A “Grampian condition” is a planning condition attached to a decision notice that prevents the start of a development until off-site works have been completed on land not controlled by the applicant. (see Planning Practice Guidance Paragraph: 009 Reference ID: 21a-009-20140306)

However, it will take a number of years before expansion and upgrade work to Cranleigh’s Sewage Treatment Works (STW) can be carried out due to several influencing factors.

Firstly, the water company trials (referred to in the email from EA on 25 February 2016 above) need to be successfully concluded, and any new technology to deal with the liquid effluent in line with WFD needs to be established.

Thames Water will have to then submit a planning application, carry out a full odour assessment (there have been a number of complaints about sewage odour from the treatment works), as well as applying for funding from Ofwat, the next funding round is not until 2019 for 2020-25.

A strategic expansion to the treatment works of the size required for Cranleigh, we have been informed by Thames Water, would take approximately 3 -5 years to complete, as confirmed in the High Level Water Cycle Study carried out by Capita for Waverley in August 2016 “Typically local network upgrades take 18 months – 3 years to investigate design and build. More strategic solutions 3 – 5 years and where new Sewage treatment works are required this could take 7 – 10 years.”.

Should the upgrade works take only 3 years after securing Ofwat funding, this would take the timeline to 2023.  This does not meet with the NPPF definition of a deliverable site – see footnote 11, which states that there should be a “realistic prospect that housing will be delivered on the site within five years”:

“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. Sites with planning permission should be considered deliverable until permission expires, unless there is clear evidence that schemes will not be implemented within five years, for example they will not be viable, there is no longer a demand for the type of units or sites have long term phasing plans.”

We do not believe that the requirement for sewerage infrastructure has been realistically or adequately costed or assessed in this application and this affects the deliverability of this site.

Inclusion in the Waverley Borough Council Land Availability Assessment August 2016 (LAA) of this site does not imply that it is acceptable in terms of sustainability criteria as outlined in the NPPF.  Waverley has not carried out a full water cycle study and therefore the impact on sewerage, water quality and supply of any sites in the LAA have not been assessed.

The current study by Capita, carried out after the production of the LAA, is a desktop scoping report (High Level Water Cycle Study August 2016) and although important evidence, should not be confused with a full water cycle study.

The Waverley Borough Council Local Development Framework Pre-Submission Core Strategy Habitat Regulations Assessment Report June 2012 also confirmed that the borough is in an area of serious water stress with regard to water supply.  Concerns about the ability of the existing water supply and sewerage networks to cope have also been highlighted in the Council’s own sustainability appraisals.

areas-of-water-stress-england

Against this backdrop Waverley must take the matter of sewerage infrastructure, water supply and water quality as material constraints when considering this application, as well as the availability of brownfield sites within the village.

The Cranleigh Society will be submitting these points to Waverley Borough Council and objecting to this application on these grounds.


Please add your own comments against this application without delay, together we can speak up for Cranleigh and its residents.

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More Burst Pipes in Cranleigh

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After the last incident when many residents were left without water, there has been yet another spate of burst pipes in Cranleigh.

They have been at:

6 Elmbridge Road – we have been advised that this is scheduled to be fixed by Thames Water on Monday 24 October

Horsham Road – scheduled to be fixed on Tuesday 25 October

Bridge Cottages, Elmbridge Road – scheduled to be fixed on 2 November.  The video below shows water bubbling up through the ground.

We are currently investigating further issues with water supply in Cranleigh, however, please continue to report any burst water mains immediately to Thames Water on the 24-hour customer service team 0800 316 9800  and let us know too info@cranleighsociety.org or use our Contact Us page.

Sewage Odour

We have also recently received several ongoing reports from residents of unpleasant and strong sewage odour issues around the Sewage Treatment Works on Elmbridge Road, on the Downslink at the back of Northdowns and also along the Guildford Road near to Notcutts (the source of this may be the treatment works).  Please ensure that you report these to Thames Water on the 24-hour customer service team 0800 316 9800  and let us know too info@cranleighsociety.org or use our Contact Us page.

We will continue to take these issues up with Thames Water directly, however, it is extremely important that residents also report odour issues to support our efforts.

Thank you.

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Horsham Road Application Gets the Go-ahead

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UPDATE 17 October 2016: Set response from Waverley Leader to multiple residents’ complaints.

Dear xx
Thank you for taking the time to share your concerns with me.
I have now had the opportunity to speak with our Monitoring Officer about this matter and he is satisfied that the meeting was properly managed. He has advised me that there is nothing unusual or improper about the chairman conveying the views of councillors who are not present at the meeting. Whilst I understand that some will be dissatisfied by the decision made by the committee and fully respect the different views held in respect of this planning application, the Council’s Monitoring Officer has confirmed that that the process by which the application was considered and the manner in which a vote was taken and recorded were both done correctly in the usual way.
Yours sincerely,

Julia Potts
Cllr.Julia Potts
Farnham Upper Hale Ward
Leader Waverley Borough Council
01483 523484
07977 443394
END OF UPDATE

Original Article:

After a deferral on the 24 August, the Crest Nicholson application for 149 dwellings came before Waverley Borough Council’s Joint Planning Committee (JPC) again on 3 October 2016 at 7pm.

There was a disappointing turnout for this significant application, with only 15 councillors out of a possible 23 in attendance.

Despite numerous comments and concerns from members of the committee at the previous August meeting, Crest Nicholson had responded with very few changes to the original layout.  However, despite this Planning Officers recommendation was for approval.

Layout submitted in August:

Horsham Road site housing layout Crest Nicholson

 

New layout (spot the difference):

crest-nicholson-amended-plans-september-2016

This was hugely disappointing for residents, who after the August deferral and councillors strong criticisms, particularly regarding the rear parking courts (car parks), were expecting some changes on the northern boundary.

Unfortunately the minimal layout changes and the ongoing legal dispute over ownership of the drainage ditch, into which Crest Nicholson propose to discharge surface water from the site, proved to be no constraint and the application was granted by councillors in a vote of 8 to 7.

Cranleigh’s Borough Councillors Mary Foryszewski and Patricia Ellis fought Cranleigh’s corner, highlighting the high quality of this site, which was now subject to a “poor and uncaring design” not reflective of the area, together with narrow roads that would be unable to accommodate the estimated number of cars, and most importantly the great disservice being done to existing residents. Cranleigh Parish Council also objected to the relatively unchanged plans, the prevalence of parking courts on the northern boundary, issues about sewage capacity and stressed that this was an opportunity to achieve the best possible outcome for existing residents as well as new ones.  Similarly vocal in her support was Farnham Councillor Carole Cockburn who was extremely disappointed and stressed that there had been an opportunity to “do something that works well for everybody” .

In a surprising twist, prior to the vote, the Chairman of the committee, Bramley Councillor Maurice Byham, deviated from normal protocol,  to advise council members that Cranleigh Councillors Jeanette and Stewart Stennett were “happy” with the new scheme and had informed the developers’ agents [Savills]. The couple, he went on to expand, were on holiday in Australia and therefore unable to attend the meeting, however apparently they were watching it closely. Obviously not much going on in Oz at 5am in the morning!

In all of the planning applications that we have attended we have never heard comments read out from councillors not in attendance, or comments that were not officially lodged against the application, or those, as was implied by the Chairman, were personal statements from councillors direct to a developers agent.

You can hear it for yourselves:

To say we were taken aback by this announcement prior to the vote, which might be viewed by some as an attempt to gather support for the development, would be an understatement.

If you share our concerns please ask Julia Potts the Leader of Waverley Borough Council to explain the decision to use absent councillors comments, and whether the monitoring officer’s approval was sought and given prior to the meeting. Please copy in the Cranleigh Society to your email and your MP Anne Milton.

Email addresses:

Julia Potts julia.potts@waverley.gov.uk

Anne Milton anne.milton.mp@parliament.uk

Cranleigh Society info@cranleighsociety.org

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Cranleigh Society Local Plan Response

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The Cranleigh Civic Society has been very busy compiling its response to Waverley’s Local Plan Part One.

Yesterday (3 October 17:00) was the deadline for all comments.  We delivered our forms first thing in the morning and got a receipt for 42 pages!  Although we have not yet seen them on Waverley’s website.

We have provided some of the comments below regarding (Click on the policy heading below to go to relevant section):

Spatial Vision 3.2 Vision for Waverley in 2032

Policy ALH1: The Amount and Location of Housing

Policy SP2: Spatial Strategy

Policy NE2 Green and Blue Infrastructure

Policy ICS1: Infrastructure and Community Facilities

Policy ST1: Sustainable Transport

Policy CC4 Flood Risk Management

Policy SS5: Strategic Housing Site at Land South of Elmbridge Road and the High Street, Cranleigh

Policy SS4: Strategic Housing Site at Horsham Road, Cranleigh

Policy SS7 New Settlement at Dunsfold Aerodrome


Spatial Vision 3.2 Vision for Waverley in 2032

Our Comment:

We object to this point on the following grounds:

  • No proposed growth in jobs, employment land assessment not accurate and out-of-date.
  • Sustainable transport options minimal, housing is not located in an area where the need for travel is reduced.
  • Water quality and air quality not adequately evidence based or mitigated against.
  • Cranleigh receiving a disproportionate amount of housing in respect to its position in the settlement hierarchy, which is based on flawed data with regard to employment land.
  • Development in Cranleigh has been developer-led rather than plan-led.
  • Despite the significant amount of housing there has been no survey on the impact on local biodiversity of a settlement, which would be in total the size of Cranleigh in this corner of the borough.
  • The critical revised climate change allowances (February 2016) from 20% to 25% to 70% above the 1% AEP have not been taken into account.

Changes we suggest:
Cranleigh should be allocated a lower number of houses in proportion to employment opportunities and to promote sustainable transport options, as well as in accordance with NPPF policy for sustainable development.


Policy ALH1: The Amount and Location of Housing

Our Comment:

The housing numbers for Cranleigh are disproportionate to its size, range of services, sustainable transport options and employment opportunities and the evidence base is not up-to date.

In most cases household projections should be employment led.  Within the Cranleigh area housing and employment simply do not align.  The assessment of employment land in the Employment Land Reviews (ELR) are seriously flawed and have been significantly exaggerated at an inflated 17% of the borough’s employment land (34.2ha) to justify the position of Cranleigh in the settlement hierarchy.  These errors have been pointed out to Waverley on multiple occasions. The assessment included Cranleigh Brick and Tiles site (20ha) which does not abut, nor does it relate well to, the settlement boundary being situated some 4km from the centre of the village within open countryside on a narrow rural road.

In 2000 the site was declared a “Special Site no 1” by the Environment Agency after representations from Waverley Borough Council, as a result of a perceived threat of pollution of Controlled Waters and was deemed to be one of the most contaminated sites in Europe.  The site was used for chemical production (Arsenic, Bromide, Mercury etc) by Steetly Chemicals and was then purchased by Redland (Lafarge) and subsequently sold onto Cherokee Investments in around 2004, after which the brickworks closed.  Since 2004 there has been no industrial activity on site with the redundant infrastructure falling into significant disrepair.  It has been subject to multiple applications for residential use, the final application (WA/2013/1947) for full planning permission being granted on 10/08/2015.  Work is currently under way to remediate the site prior to development.

The disproportionate proposed allocation of new housing in the south east of the borough includes the following: Cranleigh 1,520; Dunsfold Aerodrome 2,600; Ewhurst 65; Alfold 100; Dunsfold 80; Bramley 70; Wonersh/Shamley Green 20; totalling 4,455 – approx. 45% of the borough SHMA total.  Evidence has not been provided on the severe cumulative impact on highways, associated deaths and health problems due to air quality (impact on schools on the A281 in particularly in Bramley and Shalford), high level services, utilities, as well as negative impact on biodiversity, the further detrimental impact on the river status of Cranleigh Waters in direct contravention of Waverley Borough Council’s responsibilities under the Water Framework Directive.

The report notes that some 63% of the borough is covered by Metropolitan Green Belt and a further substantial area is covered by the national designation Area of Outstanding Natural Beauty. The imposition of a proportion of the total SHMA allocation totalling just under half of the total requirement for the borough onto an area characterised by its rural nature, landscape value, limited employment opportunities, and completely inadequate transport network, cannot be considered a sustainable solution in terms on NPPF.

It is clear that the settlement hierarchy assessment and the subsequent allocation of housing is flawed.  Waverley, have relied on inflated employment opportunities in Cranleigh (the smallest of the settlements with 9.5% of the borough’s population), and although admitting the limits of the road infrastructure, together with acknowledging that improvements are not deliverable (para 2.42) “It is also about recognising that there is a limit to the extent to which infrastructure can change even in the medium term. For example, there will continue to be poor east-west transport connections in Waverley.”, proceed to discount this serious issue as a material constraint to development.  The impact of this plan to allocate 45% of the entire housing allocation to the east corner of the borough, where both housing need is not focused and employment opportunities are not focused, will be severe, damaging and permanent.

This local plan has not been positively prepared as outlined in PPG – “the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development;”.  The council should acknowledge that the constraints in the borough governed by national landscape designations, green belt planning policy, poor transport infrastructure and access to employment opportunities will, for the area around Cranleigh, and for the village itself, on transport grounds, lead to severe and lasting residual cumulative impacts; a situation that NPPF confirms, allows the local authority to restrict or refuse development. This situation provides a suitable evidence base to allow the raw SHMA figure of 9861 to be reduced.

The Local Plan is not consistent with national planning policy.  At the heart of the NPPF is a presumption in favour of sustainable development based on three roles: economic, social and environmental.  The NPPF PPG states that:

These roles should not be undertaken in isolation, because they are mutually dependent. Economic growth can secure higher social and environmental standards, and well-designed buildings and places can improve the lives of people and communities. Therefore, to achieve sustainable development, economic, social and environmental gains should be sought jointly and simultaneously through the planning system. The planning system should play an active role in guiding development to sustainable solutions.”

It is clear that that extra weight should not be given to one role alone.  In Waverley’s Sustainability Appraisal Report Sept 2014 Page 30 it states with regard to high growth in Cranleigh:

No major socio-economic arguments in favour of this option. Cranleigh has more of a ‘village feel’ than is the case for the other main settlements, and it is the case that housing need is not focused in this part of the Borough. Also, recent speculative (i.e. non-plan led) applications for housing schemes have served to highlight concerns over infrastructure.”

With an identified lack of social and economic benefits, justification for high housing numbers in Cranleigh appears heavily reliant on the observation within the report that “Cranleigh is relatively unconstrained environmentally”.  To use this as the reasoning for high growth contravenes the NPPF golden thread of sustainability and also fails to acknowledge the value of Cranleigh’s exceptional landscape, its historical character and setting, together with its contribution to the magnificent views from the Surrey Hills AONB.

Cranleigh residents do not feel that they have been adequately consulted with on the local plan and were extremely disappointed that the Waverley planning portfolio holder and officers did not visit Cranleigh, one of the most negatively affected areas in the borough, during their round of visits in May and June 2014, as confirmed in 3.5 of the Waverley Local Plan Consultation Statement 2016.  We were also extremely disappointed that hard copies of the local plan were not made available to residents in the library as outlined in 2.12 of the Waverley Local Plan Consultation Statement 2016.

Changes we suggest:

Cranleigh should be allocated a lower number of houses in proportion to employment opportunities and to promote sustainable transport options, as well as in accordance with NPPF policy for sustainable development.


Policy SP2: Spatial Strategy

Our Comments:

The assessment of Cranleigh in the settlement hierarchy that informs the spatial strategy is not sound as it is based on evidence that is not up-to-date and does not comply with national policy with regards to sustainable development.

In terms of employment opportunity, the Local Plan is based on seriously flawed and inflated employment land figures.  The employment land recorded in WBC Employment Land Review (ELR) 2009, stated that Cranleigh had 32.4ha (17% of total assessed land within the District) and this was the figure confirmed by Waverley as being used as the evidence base for the analysis in the Local Plan.  In reality Cranleigh has between 3% and 4% of the total employment land for the borough.

This fact is critical as employment land was one of the determining criteria which ranked Cranleigh alongside the larger settlements in the borough – Farnham, Godalming and Haslemere in the settlement hierarchy, placing it in a position to accommodate large housing numbers.

The ELR has continued to include the extensive Cranleigh Brick and Tiles site (20ha).  The brickworks site is remote, situated in open countryside approximately 4km from the centre of the village on a narrow rural road.  Previously the site was used as a munitions store during WWI, then between 1937 and 1989 it was used for chemical manufacturing (Arsenic, Bromide, Mercury etc), finally, between 1990 and 2004 the site reverted to a brickworks.  Since 2004 there has been no industrial activity and the buildings on site have fallen into significant disrepair. This would have been more than apparent when the ELR 2009 was undertaken.

Furthermore, the chemical activity on the site caused considerable contamination, much of which is contained within lagoons on site.  In 2000, after representations from Waverley, the Environment Agency listed the area as Special Site no. 1 and was deemed to be one of the most contaminated sites in Europe.  After several residential planning applications, one for 19 dwellings, including the remediation of the site, was approved on 10 August 2015 WA/2013/1947.  Work is currently under way to remediate the site prior to development.  Waverley were aware in 2009 of the history and the serious nature of pollution on this site and it should have attracted a “poor status” for future use as an employment site.

In the Employment Land Review (ELR) Appendix E it stated that future use for employment was unknown and that it failed in terms of sustainability criteria.  In the ELR update 2011 the site was not mentioned.  In the ELR update 2014 the site was still included in Table 2-3 and it was claimed to be suitable for employment use with no scope for change (page 62), despite the planning application, submitted to Waverley in 2013 and being considered at the time the report was produced.

The 2014 report also inaccurately included Smithbrook Kilns 2.35ha as a Cranleigh site, which is in the parish of Bramley and Swallow Tiles 0.9ha, which was undergoing residential development.

Finally, the Brickworks site was again included in the ELR August 2016 update, although its status was stated as “Poor” for future employment use.  It could be reasonably argued that since remediation work was actually in place at this time, as full permission for residential development had already been granted, this should have been recorded as “Zero” and the 20ha should not have been included.

The inclusion of the brickworks site in the local plan as an employment site is not based on up-to-date information and its prospects as an employment site are not realistic.  Furthermore, due to the remote location with poor public transport accessibility and poor access to strategic road network the site is not sustainable and against national planning policy.

The disproportionate proposed allocation of new housing in the south east of the borough includes the following: Cranleigh 1,520; Dunsfold Aerodrome 2,600; Ewhurst 65; Alfold 100; Dunsfold 80; Bramley 70; Wonersh/Shamley Green 20; totalling 4,455 – approx 45% of the borough SHMA total.  Evidence has not been provided on the severe cumulative impact on highways, associated deaths and health problems due to air quality (impact on schools on the A281 in particularly in Bramley and Shalford), high level services, utilities, as well as negative impact on biodiversity, the further detrimental impact on the river status of Cranleigh Waters in direct contravention of Waverley Borough Council’s responsibilities under the Water Framework Directive.

The report notes that some 63% of the borough is covered by Metropolitan Green Belt and a further substantial area is covered by the national designation Area of Outstanding Natural Beauty. Cranleigh’s important position immediately on the edge of green belt and adjacent to areas of AONB and AGLV has been seriously understated.

The imposition of 45% of the total SHMA allocation totalling just under half of the total requirement for the borough in and around an area characterised by its rural nature, limited employment opportunities, and completely inadequate transport network, cannot be considered a sustainable solution in terms on NPPF and the impact on neighbouring authorities, in particular Guildford, have not been realistically assessed.

It is clear that the assessment of the settlement hierarchy and the allocation of housing is flawed.  Waverley, have relied on an inflated availability of employment opportunities in Cranleigh (the smallest of the settlements with 9.5% of the borough’s population), and although admitting the limits of the road infrastructure, together with acknowledging that improvements are not deliverable (para 2.42) “It is also about recognising that there is a limit to the extent to which infrastructure can change even in the medium term. For example, there will continue to be poor east-west transport connections in Waverley.”, proceed to discount these serious issues as material constraints to development.  The impact of this plan to allocate 45% of the entire housing allocation to the east corner of the borough, where both housing need is not focused and employment opportunities are not focused, will be severe, damaging and permanent.

This local plan has not been positively prepared and does not represent the most appropriate strategy to achieve sustainable development.  The plan has been developer-led rather than plan-led.  The council has not sufficiently acknowledged that the constraints in the borough governed by national landscape designations, green belt planning policy, poor transport infrastructure and access to employment opportunities will, for the area around Cranleigh, and for the village itself, on transport grounds, lead to severe and lasting residual cumulative impacts; a situation that NPPF confirms, allows the local authority to restrict or refuse development.

At the heart of the NPPF is a presumption in favour of sustainable development based on three roles: economic, social and environmental.  The NPPF PPG states that:

These roles should not be undertaken in isolation, because they are mutually dependent. Economic growth can secure higher social and environmental standards, and well-designed buildings and places can improve the lives of people and communities. Therefore, to achieve sustainable development, economic, social and environmental gains should be sought jointly and simultaneously through the planning system. The planning system should play an active role in guiding development to sustainable solutions.

It is clear that that extra weight should not be given to one role alone.  In Waverley’s Sustainability Appraisal Report Sept 2014 Page 30 it states with regard to high growth in Cranleigh:

“No major socio-economic arguments in favour of this option. Cranleigh has more of a ‘village feel’ than is the case for the other main settlements, and it is the case that housing need is not focused in this part of the Borough. Also, recent speculative (i.e. non-plan led) applications for housing schemes have served to highlight concerns over infrastructure.”

With an identified lack of social and economic benefits, justification for high housing numbers in Cranleigh appears heavily reliant on the observation within the report that “Cranleigh is relatively unconstrained environmentally”.  To use this as the reasoning for high growth contravenes the NPPF golden thread of sustainability.

Waverley’s criteria for deciding on the Settlement Hierarchy is further flawed, as it confuses environmental constraints, as displayed in the table Settlement Hierarchy Second Draft January 2010 Page 72, and Green Belt which is a planning policy.

It also appears that Witley Railway Station has been omitted from the public transport ranking, impacting on the total hierarchy score for that settlement.

Waverley have failed in its duty to co-operate with neighbouring authorities in an accurate, up-to-date and timely manner with regard to migration and journey to work patterns.

Cranleigh residents do not feel that they have been adequately consulted with on the local plan and were extremely disappointed that the Waverley planning portfolio holder and officers did not visit Cranleigh, one of the most negatively affected areas in the borough, during their round of visits in May and June 2014, as confirmed in 3.5 of the Waverley Local Plan Consultation Statement 2016.  We were also extremely disappointed that hard copies of the local plan were not made available to residents in the library as outlined in 2.12 of the Waverley Local Plan Consultation Statement 2016.

Changes we suggest:

Cranleigh should be allocated a lower number of houses in proportion to employment opportunities and to promote sustainable transport options, as well as in accordance with NPPF policy for sustainable development.


Policy NE2 Green and Blue Infrastructure

Our Comment:

Point 16.29 The Water Framework Directive 12 established a legal framework for the protection and promotion of sustainable water management of surface waters (including coastal waters out to one nautical mile) and groundwater.  The Directive requires all inland and coastal waters to achieve “good” status through a catchment-based (system of River Basin Management Plans (RBMPs). Waverley is part of the Thames River Basin District. In preparing the Local Plan, the Council has consulted the appropriate water companies on the scale and location of potential development sites to ensure that these can be delivered within environmental limits and that the required infrastructure can be delivered in a timely manner. The Council continues to gather and assess evidence on water resources, water quality and flood risk, for example through its Water Cycle Study, and will consider whether further information is required, particularly in deciding relevant planning applications.

We do not find this point sound.  Waverley have not consulted with “the appropriate water companies about the scale and location of potential development sites to ensure that these can be delivered within environmental limits and that the required infrastructure can be delivered in a timely manner.”

Environmental Limits and Infrastructure Delivery:

Local planning authorities have statutory duties to deliver the Water Framework Directive (WFD).  This established a legal framework for the protection and promotion of sustainable water management of surface waters (including coastal waters out to one nautical mile) and groundwater.

The plan does not take into account that WFD requires all inland and coastal waters to achieve “good” status through a catchment-based (Cranleigh Waters is part of the Wey Catchment) system of River Basin Management Plans (RBMPs).  Waverley is part of the Thames River Basin District.  The RBMP outlines the actions needed to meet WFD objectives of ‘good’ water body status.

Under WFD the overarching aims are to:

  • Prevent deterioration in water body status
  • Reduce water pollution
  • Conserve aquatic ecosystems and habitats
  • Reduce the effects of floods and droughts on water bodies
  • Promote sustainable use of water as a natural resource

The EA have issued a comprehensive guidance document for LPAs “Improving Water Quality, Guidance for Local Authorities, Engaging with the Water Framework Directive, that stresses:

“In legal terms, the WFD is a material consideration in the planning process”

It is Waverley’s role, not that of the EA, to ensure that a full water cycle study is carried out.  The purpose of this study is to assess the existing water infrastructure and water environment to determine if it can accommodate the proposed levels of growth or where further work may be required to facilitate the growth and ensure that it does not detrimentally impact upon the natural environment.

Paragraph 156 of the NPPF states: “Local planning authorities should set out the strategic priorities for the area in the Local Plan. This should include strategic policies to deliver…the provision of infrastructure for transport, telecommunications, waste management, water supply, wastewater, flood risk and coastal changes management, and the provision of minerals and energy”.

A full water cycle study which is necessary to inform strategic policies to deliver the provision of sewerage infrastructure and water supply have not been carried out.  Without this study the local plan is not sound.

Furthermore, Waverley is not meeting its responsibilities under WFD.  it is impossible for Thames Water to confirm that they can deliver levels of discharge effluent that meet with environmental limits within the lifetime of the plan. It is not technically possible (Environment Agency email 25 February 2016) to meet the environmental levels set by the WFD, particularly with regard to phosphates, and currently effluent discharge into Cranleigh Waters is not being measured against WFD.  The last environmental permit to discharge issued to Thames Water was in 2009, when the Environment Agency (EA) applied blanket conditions to Temporary Deemed Consents to bring them in line with other Combined Sewage Overflow permits. This permit was not based on WFD and also relies on a level of dilution which is no longer applicable, since Cranleigh Waters over the last few years has become ephemeral, with low to no flow, particularly during summer months.

The Cranleigh Civic Society received an email from EA on 25 February 2016 at 16:56:44 GMT confirming the elements Cranleigh Waters was failing in, and also that water company trials were taking place to meet the tighter permit levels required under WFD:

“The elements that are not passing are Phosphate (moderate status), macrophytes (moderate status) and diatoms (poor status). Macrophytes and diatoms are ecological indicators of phosphate pressure. Therefore the permit has been reviewed recently with respect to these failing elements (Summer 2015) and it was identified that to improve this status a permit would be required that currently is technically infeasible. As mentioned previously water companies are undertaking trials to try and identify technology that would be capable of treating effluent to meet these tighter permits. The Environment Agency will be tracking the success of these trial and the permits will be reviewed if the technology becomes available to treat to these tighter levels.”

This content of this email was passed on to Waverley.

EA website maps as at 05-Mar-16 also indicated the following:

  • Cranleigh Waters is in “Drinking water safeguard zone” (zone ends at Shalford).
  • Cranleigh Waters is in a “Nitrate vulnerable zone”, so “Eutrophic”.
  • Cranleigh Sewage Treatment Works shown as “Water industrial pollution: Significant”
  • Cranleigh Waters Ecological Quality rated “Bad”. Must be “Good” by 2027 to meet Water Framework Directive (WFD)

Furthermore, data released by EA in 2015 provided reasons for not achieving good status in the Cranleigh Waters in their River Basin Management plan and attributed this to continuous sewage discharge.  This indicated that all three key water body pollution indicator categories, Solids, Biochemical Oxygen Demand and Ammoniacal Nitrogen were being exceeded.

In the absence of an up-to-date environmental permit to discharge into Cranleigh Waters and the need for new technology to process sewage to comply with WFD, it is factually incorrect and unsound for WBC to state that the development sites “…can be delivered within environmental limits”.  They are relying on out of date environmental legislation, this is not consistent with national policy, and are not taking into account the ephemeral nature of Cranleigh Waters.

In addition to contravening limits set by WFD, the timeline for upgrade works to the sewage treatment works, which is already at capacity, cannot at this stage be considered to be “timely”.  As we have established, water companies do not have the technology capable of treating effluent to comply with WFD and the results of these trials will not be available until, at the earliest, 2017.  At the moment new permits to discharge are not being issued by EA to comply with WFD, despite the failing status of rivers like Cranleigh Waters, and the requirement under WFD to improve river status to “Good” by 2027, is within the lifetime of Waverley’s local plan.

Should the water company trials prove to be successful, and the process and technology to deal with the effluent be established, it would still take an additional number of years before expansion and upgrade work to Cranleigh Sewage Treatment Works (SWT) can be carried out.  Thames Water will have to submit a planning application, carry out a full odour assessment survey, as well as applying for funding from Ofwat, the next funding round is not until 2019 for 2020-25.  An expansion to the treatment works of the size required for Cranleigh, we were informed by Thames Water, would take approximately 3 years to complete, as confirmed recently in the High Level Water Cycle Study carried out by Capita for Waverley in August 2016 “Typically local network upgrades take 18 months – 3 years to investigate design and build. More strategic solutions 3 – 5 years and where new Sewage treatment works are required this could take 7 – 10 years.”.

We do not believe that Waverley have realistically or adequately assessed the requirement for sewerage infrastructure in the local plan, particularly in selection of the strategic sites, and it is therefore unsound.

Cranleigh Waters Ephemeral and Eutrophic:

In addition to awaiting the outcome of the previously mentioned water company trials, the need for an updated permit to discharge based on WFD, as well as the failing status of Cranleigh Waters, what makes the position of Cranleigh Waters far more critical than other rivers near main settlements is the ephemeral nature of the watercourse.  With an average daily discharge from the Cranleigh Sewage Works, recorded in 2014, of 5143 m3 (over 2 Olympic-sized swimming pools per day) and, at times, low to no flow in the river upstream of the STW, pollution has increased and the Shamley Green Angling Society has reported depleted fish stocks.  At times the flow downstream of the SWT is almost 100% liquid effluent. which encourages the growth of algae, called eutrophication, which means that it is rich in nutrients and promotes plant growth, leading to low oxygen levels, at the expense of providing a suitable habitat for fish, amphibians and invertebrates.  Since 2009, The EA has classified Cranleigh Waters as “Eutrophic and Bad”, the worst category on their ratings scale.

Some fish may be still present in the river but they will be stressed, suffering large amounts of suspended biodegradable matter (toxic silt, algae etc.) that clog and irritate their gills.  Fish will not feed or spawn in these situations and over long periods of deoxygenation they will become weak and die. The food chain then starts to deteriorate with invertebrate death, then a cascade ecosystem failure ensues. This results in a dead system that will take decades to recover and only then if sources of pollution are stopped or technology becomes available to filter the harmful elements out of effluent discharge.

A local member of the angling society confirmed that:

As once you could walk the banks of Cranleigh Waters of an evening and see a myriad of ephemerides hatching from the river surface, splashes of feeding fish and a host of water creatures feeding on this bonanza. Now you will see very little surface activity, no ephemerides, dragon flies or demoiselles that once used to fly over this river in large quantities.  In the past the river margins were alive with large shoals of juvenile fish, now only mosquito larva are noticeable.  We have a dying river that needs help. Further expansion of the sewerage works means a greater capacity of polluted discharge into this failing system. The choice is simple, we sit back and let this river die and let its polluted water flow (slowly) into the River Wey at Shalford where it then becomes somebody else’s problem.”

The EA has put this lack of flow down to several reasons, partly due to badly executed dredging, climate change, extraction and also a general increase in population.  Although classified by EA as a main river, this by no means is indicative of the depth and width of Cranleigh Waters.  We have an image that was taken upstream of the SWT on 18 August 2016, which clearly shows the river depth of approximately 2 inches.  EA have also confirmed to us that it is also failing in terms of phosphate levels (Cranleigh Waters EA Walkover Inspection 8 August 2016).

We also took flow measurements (Geopacks ZMFP51 Flow Meter) on the 7th September 2016 and recorded at 1.36 l/s (averaged over several measurements).

PPG Para: 016, states that Water Quality should be considered a significant concern “– through a lack of adequate infrastructure to deal with wastewater.”, we firmly believe this to be the case in Cranleigh.  The local plan has not assessed the full impact on water quality in Cranleigh Waters, or on the wider Wey Catchment, for the additional liquid effluent discharge from 1,520 houses at Cranleigh, as well as the additional 2,600 at Dunsfold, in addition to development at Alfold and Ewhurst, and it is therefore unsound.

Background Information:

When Cranleigh Sewage Works was opened in July 1967 nearly 50 years ago, it was designed to serve between 10,000 and 15,000 residents.  Thames Water calculated in 2011 that the number of residents it was serving had now reached 14,200, and they notified Waverley Borough Council (WBC) that it was nearing capacity.  Recent approved planning applications, including Swallowhurst, (built 58 dwellings) Amlets Lane (outline permission 125 dwellings with Grampian style condition) and Crest Nicholson, Horsham Road (outline permission 149 dwellings with Grampian style condition), Little Meadow (outline permission for 75 dwellings Grampian style condition, Cranleigh Waverley Councillors and members of the JPC declared a pecuniary interest (under investigation), not declared previously, prior to the meeting to decide this application, despite having taken a major part in discussions and meetings facilitating this development, have put the figure well over the 15,000 capacity. This has been more than doubled by the Appeal decision to allow outline planning permission for another 425 dwellings with no Grampian style condition by Berkeley Homes and no strategy of how to deal with the sewage problems.

The sewerage infrastructure in Cranleigh is already in a critical state.  We have regular instances of sewage back flowing into toilets in Cranleigh as well as seepage into gardens and up through manhole covers.  Additionally, for the past 12 years sewage regularly flows into a brook just off the high street, and from there into the river network.  This has remained unresolved, despite ongoing complaints and repeated remedial work.

To improve resilience for existing residents, the SWT is currently undergoing a 30% upgrade with 2 new filter beds being installed.  However, the works are being carried out without any planning permission and a full odour impact assessment.  This contravenes Defra’s Code of Practice on Odour Nuisance and the Defra Odour Guidance for Local Authorities, because of the many odour complaints from residents living within 800m of the Sewage Treatment Works negate any permitted development rights under the Planning Act.  Cranleigh Society has carried out a basic odour assessment to provide an indication of the extent of this issue. Of the respondents, 71% of households had experienced odour problems from the STW, and 93% wanted Thames Water to carry out a full Odour Impact Assessment before proceeding with further work on site (full Survey results can be provided.  This situation is now being investigated by Surrey County Council.)

Despite being aware of these sewage issues for some time, it is surprising that provision of sewerage infrastructure is not been a principal part of Waverley’s infrastructure delivery plan and that a full water cycle study has not been carried out.  Early in 2014 Waverley sought advice from Thames Water about the capacity of Cranleigh Sewage Treatment Works, as part of evidence gathering for their new Local Plan. Thames Water said to WBC that they were at design capacity.  WBC then stated in their draft Local Plan Part 1: Strategic Policies and Sites Infrastructure Update September 2014 that ‘Concerns about waste water services at Cranleigh Sewage Treatment Works (STW). Sewage treatment capacity unlikely to be able to support anticipated demand.’  Thames Water have also commented on recent planning applications in Cranleigh that they have ‘identified an inability of the existing waste water infrastructure to accommodate the needs of this application’, in addition to highlighting concerns about water supply “The existing water supply infrastructure has insufficient capacity to meet the additional demands for the proposed development.”  They have been recommending that Grampian style conditions for foul and surface water, as well as water impact assessment studies.

Cranleigh Civic Society also met with Waverley Planning Officers on 3 March 2016 to discuss the implications on deliverability of the water company trials, the out of date environmental permit to discharge, low flow rates in Cranleigh Waters, together with its failing status under the WFD.  We then met again with a planning officer at Cranleigh Sewage Treatment Works for a stakeholder meeting on 11-May-16, representatives from Thames Water, the Environment Agency, Surrey Wildlife Trust, Cranleigh Parish Councillors and Waverley Borough Councillors were also in attendance.  At the stakeholder meeting the EA stressed the requirement for a full water cycle study to be carried out as part of the local plan, and confirmed that discussions on this point were underway with the council.  However, despite this a full water cycle study has not yet been carried out.  The current study by Capita is a desktop scoping report (High Level Water Cycle Study August 2016) and although a valuable piece of evidence, should not be confused with a full water cycle study.

The impact of Waverley’s growth plans for Cranleigh have been highlighted in Capita’s report, as shown in Table 5-4.  This report also highlights the need for a quantitative analysis to take place in Stage 2 of the High Level Water Cycle Study, without this assessment and a full water cycle study the plan is unsound.

The Waverley Local Plan Sustainability Appraisal Report 2016 also highlights key considerations relating to:

“A) waste water treatment infrastructure; B) Groundwater Source Protection Zones (SPZs); and C) flood risk.

The Waverley Borough Council Local Development Framework Pre-Submission Core Strategy Habitat Regulations Assessment Report June 2012 also confirms that the borough is in an area of serious water stress with regard to water supply, concerns about the ability of the existing water supply and sewerage networks to cope were highlighted in previous sustainability appraisals.

Against this backdrop Waverley has failed to take the matter of sewerage infrastructure, water supply and water quality fully into account in the local plan, in addition to the impact this will have on neighbouring authorities.

The considerable constraints for the treatment of sewage and the impact on water quality in Cranleigh Waters of 1,520 new dwellings in Cranleigh has not been satisfactorily assessed, nor has the liquid effluent emanating from 2,600 new dwellings at Dunsfold.  Waverley has selected strategic sites for almost 50% of their total housing allocation with full knowledge that Thames Water have no plan or schedule for the delivery of the necessary sewerage infrastructure.  This serious oversight means that the plan is not sound.

Cranleigh residents do not feel that they have been adequately consulted with on the local plan and were extremely disappointed that the Waverley planning portfolio holder and officers did not visit Cranleigh, one of the most negatively affected areas in the borough, during their round of visits in May and June 2014, as confirmed in 3.5 of the Waverley Local Plan Consultation Statement 2016.  We were also extremely disappointed that hard copies of the local plan were not made available to residents in the library as outlined in 2.12 of the Waverley Local Plan Consultation Statement 2016.

Changes we suggest:

A full water cycle study should be carried out and this should inform the selection of strategic sites.  Furthermore, the cumulative impact of liquid effluent entering the Cranleigh Waters from approximately 4,000 new dwellings should be assessed based on updated legislation (WFD) and the river achieving good status by 2027.


Policy ICS1: Infrastructure and Community Facilities

Our Comment:

This policy is not sound as it is not based on objectively assessed evidence.

The impact on Cranleigh’s local road network has not been assessed and proposed infrastructure improvements are not adequately funded or deliverable.  The ongoing flawed employment land review assessment by Waverley has seriously overestimated the availability of employment land in the village, which impacts the projected number of daily car movements in and out of the village.

Waverley’s calculation of employment land is fundamentally flawed and continues to include the 20ha highly contaminated site at Cranleigh Brickworks. Knowle Lane.  This brickworks site is remote, situated in open countryside approximately 4km from the centre of the village.  Previously the site was used as a munitions store during WWI, then between 1937 and 1989 it was used for chemical manufacturing, finally, between 1990 and 2004 the site reverted to a brickworks.  In 2000 is was named as Special Site no 1 by the Environment Agency due to the amount of pollution on site and the risk to controlled waters.  Since 2004 there has been no industrial activity and the buildings on site have fallen into significant disrepair.  After several residential planning applications, one for 19 dwellings, including the remediation of the site, was approved on 10 August 2015 WA/2013/1947 and work has started.

Cranleigh is the smallest of the four main settlements of the borough and the least sustainable in terms of transport infrastructure. There is no rail network, motorway or national trunk road. Most traffic seeks to access the national trunk network via B class roads to reach Guildford (with its main-line railway 15.9km away, concerns from users are highlighted in Para 2.24 “about the current and future capacity of the trains” in addition to limited availability of parking at stations) or the A3/M25 national route. The B class roads around Cranleigh are characterised by their narrowness and rural backdrop. Para 2.22 – Roads and Transport, notes that “Much of Waverley’s road network is rural and narrow and therefore unsuitable for heavy goods vehicles. The safe accommodation of heavy goods traffic is on the principal through routes (including) the A281 and its impact on communities through which these roads pass presents a continuing challenge.”  Para 2.23 confirms that “The most significant delays and congestion occur in and around…Cranleigh and Bramley.”

Cranleigh has a high reliance on car use, the Mott MacDonald Stage 1 February 2016 report highlights that the Cranleigh East and West (Wards) car mode share for residential trips to work has increased to 70%.  Current vehicular journeys from Cranleigh, especially at peak times, seek to travel to Guildford, either as a journey termination for employment or for access to the national rail system or for continuation by road to access the national trunk and motorway system. The route into Guildford is either via the A281 which routes traffic through two major pinch points at Bramley and Shalford or via the B2128 which routes traffic through the villages of Shamley Green and Wonersh and then Shalford. These routes are already heavily congested at peak times and queuing at Bramley and Shalford can present unacceptable delays now. The imposition of a further potential vehicular increase driven by development of some 4,455 new houses in Cranleigh (equivalent to another settlement the size of Cranleigh) and its hinterland must result in severe cumulative impacts, both from the poor transport infrastructure and reduced air quality. With regard to Bramley and Shalford pinch points, the plan suggests that mitigation will make this vehicular increase sustainable. It is difficult to see how these two major bottlenecks can ever be mitigated such that the additional traffic becomes sustainable and the plan makes no reference to how this might be achieved.

Under the duty to co-operate the impact on additional traffic on Guildford is out-of-date and appears not to have assessed the impact of 45% of the Waverley’s housing allocation being situated in and around Cranleigh, in addition to the impact of the associated traffic from this amount of housing on Guildford town centre, in particular the one-way system, along with the negative effect on Guildford’s Air Quality Monitoring Area (AQMA).

Para 2.41 also notes that “…new development often takes place on small sites, so the cumulative impact of development needs to be considered.”.  We can see no evidence that the cumulative impact of the allocation of a minimum of 1520 new houses in Cranleigh and 335 in the surrounding villages has been considered against the proposal for 2600 new houses immediately adjacent to Cranleigh at Dunsfold Aerodrome, yet it is clear that all traffic generated by these developments will be seeking to use the same, already overloaded road network. The various transport modelling works undertaken for the council by Mott McDonald appear to have considered only that traffic generated by a potential new town at Dunsfold Aerodrome. No evidence can be found that the reports have factored in the additional traffic from other new developments, or the impact on Cranleigh rural road network.

Para 3.2.9 In proposing a vision for the borough at the end of the plan period, the statement makes the claim that “The vitality and viability of the main centres…will have been safeguarded in a way that takes account of their distinctive roles. This will have been achieved through carefully planned development, which meets the needs of these centres, whilst recognising the importance of preserving and enhancing their historic character.” However, it is clear that development in Cranleigh has been developer-led rather than plan-led.  It is also clear from the detailed applications for permission being submitted, after consultation with officers, that there has been an agreed shift to far taller residential units and 2.5 to 3 storey apartment buildings, which do not enhance, preserve or respect Cranleigh’s rural character and directly contravene the SPD Cranleigh Design Statement 2008.

Para 5.21 notes that “NPPF requires the council to positively seek opportunities to meet the development needs of the borough and to meet objectively assessed needs unless any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in the NPPF as a whole.” In section 8. Infrastructure and Community Services it is noted that (8.17) In regard of infrastructure provision, “However, a lack of, or identified current deficiencies in, infrastructure is not, in itself, a constraint to development.” It must be clear that lack of or deficiencies in, infrastructure must be a constraint to development if, in line with NPPF, development is to be sustainable.

The Infrastructure Delivery Plan that accompanies the local plan is not sound.  The report lacks detail and substance.  There appears to be no realistic funding sources corresponding to the Cranleigh Draft Infrastructure List by Surrey County Council.  In the main it simply provides an aspirational list, with an end date of “By 2032” and funding gap “tbc”.  This is not positively prepared and is not borne up by the current contribution level of secured S106 agreements for the already approved 793 dwellings.  The Cranleigh Draft Infrastructure List by Surrey County Council referred to in the report does not appear to be an evidence document and therefore the methodology used to devise it, the evidence base and assessment of need for each project cannot be properly scrutinised. However, one of the most critical projects for Cranleigh regarding upgrade and expansion work for the Sewage Treatment Works has been very worryingly omitted.

We would also point out that Surrey County Council, in its recent Infrastructure Study (Jan 2016), has already identified a substantial funding gap between what is required to meet existing needs in Waverley and what is available. Of a total requirement just under £128M, just £540,000 has been secured. The funding gap between what is secured and expected, and what is required is calculated at £61M, most of which is required for Highways improvements. These figures were based on the expectation of just 3,750 new houses for Waverley between 2016 and 2030. With the new total proposed now 9,861, clearly even this massive funding gap is a significant underestimate.  Surrey’s funding gap is now reported to be at £3bn.

Cranleigh residents do not feel that they have been adequately consulted with on the local plan and were extremely disappointed that the Waverley planning portfolio holder and officers did not visit Cranleigh, one of the most negatively affected areas in the borough, during their round of visits in May and June 2014, as confirmed in 3.5 of the Waverley Local Plan Consultation Statement 2016.  We were also extremely disappointed that hard copies of the local plan were not made available to residents in the library as outlined in 2.12 of the Waverley Local Plan Consultation Statement 2016.

Changes we suggest:

The inclusion of expansion to Cranleigh Sewage Treatment Works must be included in the infrastructure delivery projects, in addition to a more detailed timeline for project delivery and funding sources. Furthermore the impact on cumulative traffic on Cranleigh’s local rural road network and cross boundary projects, including key road stress points, should be adequately assessed.


Policy ST1: Sustainable Transport

Our Comment:

The proposal for 45% of the borough’s total housing allocation in and around Cranleigh, including a new settlement at Dunsfold, does not achieve the Council’s aim that development “should be directed to the most sustainable locations that are easily accessible without the use of the car”.  The level of unsustainable development that the council has included in its local plan is staggering.

There are few sustainable transport options for Cranleigh and the surrounding area, other than a rural bus service, with reduced services at weekends and no late night bus.  There is no train station, the nearest main-line railway station is 15.9km away.  The roads into Guildford are in the main narrow, winding B roads, with access onto a single A road (A281) leading into Guildford.  The significant amount of new housing that is reliant on private car usage being proposed for this inadequate road network makes the local plan unsound in terms of sustainable transport and air quality.

The draft plan does not confirm that Waverley has sufficiently investigated the impact on air quality of additional traffic through the villages of Bramley and Shalford, which will suffer the impact of increased queues of standing vehicles from traffic generated by new development at Cranleigh and Dunsfold. As far as we can determine, it appears that Waverley is only capturing data for nitrogen dioxide NO2 and not monitoring particulates at all.  Furthermore, they have not included in their evidence base data from approximately 40 temporary air quality monitors that they have across the borough, which provide critical information on local air quality.  These are serious omissions that we believe could impact on the health of residents and especially for children attending schools located on the A281.

Particulates are the deadliest form of air pollution due to their ability to penetrate deep into the lungs and blood streams unfiltered, causing permanent DNA mutations, heart attacks, and premature death.

Estimates of the number of deaths in UK local authorities that can be attributed to long term exposure to particle air pollution were published by Public Health England (PHE) in April 2014.

This report estimated the annual number of attributable deaths due to particle air pollution in the age group 25+ in Waverley is 56, with a loss of 554 associated life-years lost.  The figure, it is recognised, could in reality be higher.

The estimates are made for long term exposure to particulate air pollution (i.e. over many years) rather than short term exposure to high pollution episodes. However, short term exposure to high levels of air pollution can cause a range of adverse health effects including exacerbation of asthma, effects on lung function, increases in hospital admissions and mortality.

The report was produced to inform public health professionals and air quality specialists in local authorities about the likely effects of particle air pollution on public health in the UK. The estimates are intended to help local authorities consider air pollution among other public health issues.  This should have been included in the background evidence base for the Local Plan.  Whereas it appears that the impact of an increase in particulates has been omitted.

As air pollution is a serious and well-documented increasing risk to public health, at the very least we would expect to see realistic measures that would significantly reduce air pollution, including particulates, for residents, employees, and children attending local schools.

There is no evidence currently to support point 17.7 in the Local Plan Part One that Waverley is “working in partnership with Surrey County Council to reduce the need to travel, encourage alternative forms of transport to the car and reduce emissions. This links to the need to tackle air pollution.”, whilst placing 45% of its total housing allocation in an area reliant on private car usage.

Furthermore, there is no mention of the negative impact on the Guildford AQMA, despite the proposed increase in traffic on the A281 north into Guildford town centre, under the duty to co-operate.

Cranleigh residents do not feel that they have been adequately consulted with on the local plan and feel that their health, from exposure to increased levels of air pollution, will be compromised in the pursuit of a disproportionate number of houses in this area of the borough, where employment opportunities and housing need are not focused and the use of the private car will inevitably grow exponentially. We were extremely disappointed that the Waverley planning portfolio holder and officers did not visit Cranleigh, one of the most negatively affected areas in the borough, during their round of visits in May and June 2014, as confirmed in 3.5 of the Waverley Local Plan Consultation Statement 2016.  We were also extremely disappointed that hard copies of the local plan were not made available to residents in the library as outlined in 2.12 of the Waverley Local Plan Consultation Statement 2016.

Changes we suggest:

Cranleigh should be allocated a lower number of houses in proportion to employment opportunities and to promote sustainable transport options, as well as in accordance with NPPF policy for sustainable development.


Policy CC4 Flood Risk Management

Our Comment:

Evidence of Cranleigh’s flood risk in Waverley Borough Council Level 2 Strategic Flood Risk Assessment (SFRA) August 2016 has not adequately assessed for surface water flooding, or ground water flooding.  Surface Water flood maps indicate that Cranleigh is in an area of wide surface water flooding and yet this fact receives little to no attention in the SFRA 2016.

We would also draw attention to Capita’s Strategic Flood Risk Assessment for Waverley 2010 which reported “High” likelihood of surface water flooding in Cranleigh, as shown in Figure 5.1 Surface Water Flooding Waverley SFRA.

With regard to groundwater the 2016 report also states that:

“2.2.4 Groundwater Flooding

There are very few records of groundwater flooding across Waverley. Based on previous records made available it appears groundwater flooding has historically occurred in Upper Hale, Godalming, Elstead, Churt, Shottermill, Wormley, Witley, south of Busbridge, and Cranleigh. Hambledon is noted as being within the South East England Regional Flood Risk Assessment as being at risk from groundwater flooding. However in the examples of Upper Hale and Cranleigh, it is more likely that the recorded flooding problems were related to water logging and poor surface water drainage than groundwater flooding.”

The 2016 FRA point 2.2.2 makes no mention of ongoing surface water flooding in Cranleigh, despite primary source evidence, including correspondence on this issue between the planning department and Cranleigh Society, including emails, photos, videos and face to face meetings.

Evidence in the WSP Flood Risk Assessment that accompanied the Berkeley Homes application for 425 dwellings (WA/2014/0912) reported that 17 out of 41 (42%) of the trial boreholes across the site showed the presence of groundwater, with 9 (22%) of the total showing groundwater at less than a metre from the surface.

Furthermore, the Environment Agency Groundwater maps record the presence of aquifers i.e. a body of saturated rock to the south and west of Cranleigh.  This means that water may be discharged from this area by upward seepage through the overlying clay.  Previously saturated weald clay has a “rapid run-off behaviour”, meaning that water exits the site far more aggressively than “dry-soil” models.  The EA refer to Cranleigh as a “flashy catchment” – defined as a catchment area that, because of geographic, topographic, and geological factors, shows an almost immediate response to intense rainfall, resulting in a flash flood.  As experienced time and time again in Cranleigh, most recently on 25 June 2016.

Furthermore, the SFRA does not take into account recent revised climate change allowances by the government and the Environment Agency published in February 2016.  These now require applicants and developers to assess a range of climate range allowances from 25% to 70% above the 1% AEP as part of planning applications.  These are significant higher allowances than the previous 20% allowance.

Waverley’s SFRA is not sound and should be updated to reflect more accurately flood risk to Cranleigh from all sources, residents first-hand experience of flooding, together with up-to-date climate change allowances.  It must also reassess the cumulative impact downstream of an additional 4,455 dwellings in this part of the borough with regards to increased flood risk from all sources.

Cranleigh residents do not feel that they have been consulted with on the risk of local flooding and were extremely disappointed that the Waverley planning portfolio holder and officers did not visit Cranleigh, one of the most negatively affected areas in the borough, during their round of visits in May and June 2014, as confirmed in 3.5 of the Waverley Local Plan Consultation Statement 2016.  We were also extremely disappointed that hard copies of the local plan were not made available to residents in the library as outlined in 2.12 of the Waverley Local Plan Consultation Statement 2016.


Policy SS5: Strategic Housing Site at Land South of Elmbridge Road and the High Street, Cranleigh

Our Comment:

500 dwellings have already been approved on this site.  The remainder of this site was subject to a separate planning application WA/2014/2127 (West Cranleigh Nurseries) was refused by Waverley on 27 April 2016 – 265 dwellings.  There is no justification for this additional growth in Cranleigh, which has insufficient access to employment opportunities, limited sustainable transport options and this policy does not take into account up-to-date and revised allowances for climate change published in February 2016 by the government and Environment Agency from 20% to 25% to 70% above the 1% AEP.

This section of the site includes some of the best agricultural land in Waverley (Grade 2) which is in limited supply.  it is also an employment site for horticultural purposes.

This cumulative effect on Alfold Road of this amount of development has not been taken into account and would be severe.  Due to the distance from the high street and local schools, this development would rely heavily on private car use.

The sewerage infrastructure is at capacity and cannot support a development of this size.  There would also be a negative impact on water quality in Cranleigh Waters due to an increase in liquid effluent. No provision is made in the Infrastructure Delivery Plan for sewerage provision.

This proposal would significantly increase the number of people living in an area affected by flooding and would increase the scale of any emergency evacuation considerably.

NPPF places particular significance with respect to land in the “Functional Floodplain” or Flood Zone 3b.  Figure 4.3 of Volume 3: Mapping of the WBC SFRA identified areas of Functional Floodplain within the borough. This figure shows parts of the development site are within the Functional Floodplain.

Cranleigh residents do not feel that they have been adequately consulted with on the selection of this strategic site in the local plan and were extremely disappointed that the Waverley planning portfolio holder and officers did not visit Cranleigh, one of the most negatively affected areas in the borough, during their round of visits in May and June 2014, as confirmed in 3.5 of the Waverley Local Plan Consultation Statement 2016.  We were also extremely disappointed that hard copies of the local plan were not made available to residents in the library as outlined in 2.12 of the Waverley Local Plan Consultation Statement 2016.

Changes we suggest:

Cranleigh should be allocated a lower number of houses in proportion to employment opportunities and to promote sustainable transport options, as well as in accordance with NPPF policy for sustainable development.  Alternative brownfield sites within the village settlement should be investigated that are at lower risk of flooding.


Policy SS4: Strategic Housing Site at Horsham Road, Cranleigh

Our Comment:

There is insufficient evidence to support further green field development on this site when there are suitable brown field sites within the village settlement that have been identified by the Neighbourhood Plan in the Call for Sites.

There is insufficient access to employment land, it would create further reliance on private car use and increase flood risk to neighbouring properties.

The provision of sewerage infrastructure to support this site is not part of the Infrastructure Delivery Plan.

There would be a further detrimental impact on water quality in the local river Cranleigh Waters and on biodiversity, including ancient woodland.

Cranleigh residents do not feel that they have been adequately consulted with on the local plan and were extremely disappointed that the Waverley planning portfolio holder and officers did not visit Cranleigh, one of the most negatively affected areas in the borough, during their round of visits in May and June 2014, as confirmed in 3.5 of the Waverley Local Plan Consultation Statement 2016.  We were also extremely disappointed that hard copies of the local plan were not made available to residents in the library as outlined in 2.12 of the Waverley Local Plan Consultation Statement 2016.

Changes we suggest:

Cranleigh should be allocated a lower number of houses in proportion to employment opportunities and to promote sustainable transport options, as well as in accordance with NPPF policy for sustainable development.  Alternative brownfield sites within the village settlement could be investigated with regard to delivery in 2021.


Policy SS7 New Settlement at Dunsfold Aerodrome

Our Comment:

At para 18.15 Dunsfold Aerodrome – in terms of infrastructure, it is noted that “… developments that generate significant movements should be located where the need to travel will be minimised and the use of sustainable transport maximised.”  there are minimal sustainable transport options available for this site.

Although Dunsfold Aerodrome is in a relatively isolated location, it is considered in the local plan that the benefits such as the fact that there are no other large brown-field sites in Waverley outweigh any concerns regarding the location of the site.” It appears that the council are justifying the selection of this site based on availability rather than sustainability criteria.

Consultation on Potential Housing Scenarios and Other Issues for the Waverley Local Plan point 2.27 highlights that the Secretary of State in refusing an application for this site “said that the scheme would generate considerable additional road traffic and that this would have a severe and unacceptable impact on an overstretched local road network.  He concluded that the scheme would be unsustainable in transport terms and that allowing the proposals to proceed at that stage would pre-empt the proper consideration of alternatives through the Local Plan process“.  It is unclear what has changed about the impact of the traffic from the original application and how in transport terms the site is now sustainable, also considering the cumulative impact of 1,520 proposed dwellings at Cranleigh.

Although a new sewage treatment plant has been proposed for the site, it is unclear where the liquid effluent will be discharged.  If this was to be in Cranleigh Waters, it would negatively impact water quality.  The river has been highlighted in the High Level Water Cycle Study August 2016 as failing with regard to the Water Framework Directive.

Due to the lack of green belt and environmental protection, there is a high risk of coalescence in the future between Cranleigh, Dunsfold and Alfold. which would impact on surrounding AGLV and the Surrey Hills AONB.

Cranleigh residents do not feel that they have been adequately consulted with on the new settlement at Dunsfold and were extremely disappointed that the Waverley planning portfolio holder and officers did not visit Cranleigh, one of the most negatively affected areas in the borough, during their round of visits in May and June 2014, as confirmed in 3.5 of the Waverley Local Plan Consultation Statement 2016.  We were also extremely disappointed that hard copies of the local plan were not made available to residents in the library as outlined in 2.12 of the Waverley Local Plan Consultation Statement 2016.


Changes we suggest:

Confirmation that the Dunsfold settlement will not discharge into Cranleigh Waters.  The creation of a strategic gap between the settlements of Cranleigh, Dunsfold and Alfold to avoid coalescence of settlements.  The full assessment of the cumulative impact on Cranleigh’s local rural road infrastructure and services of a new settlement at Dunsfold.

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Surrey County Council Investigate Odour Survey Results

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Following receipt of the Cranleigh Civic Society’s Odour Assessment Survey, Surrey County Council Planning Enforcement Team are now investigating whether Thames Water should have applied for planning permission, and carried out a full odour impact assessment, prior to expansion at Cranleigh’s Sewage Treatment Works.


Background to Survey

On 8 May 2016 representatives from Cranleigh Civic Society, Cranleigh Parish Council, the Surrey Wildlife Trust and Waverley Borough Council met with Thames Water and the Environment Agency at Cranleigh Sewage Treatment Works (STW) on Elmbridge Road, to discuss capacity issues and concerns about pollution from the liquid effluent discharge (by-product of sewage treatment) into Cranleigh Waters.

At that meeting Thames Water confirmed that the STW was being expanded from 6 filter beds to 8, a 30% increase in filtration capacity, to improve resilience at the SWT in response to capacity issues.

Cranleigh Civic Society pointed out to Thames Water that when some minor works were done in 2010, Thames Water had needed to apply for Planning Permission and had carried out an Odour Impact Assessment, triggered by a number of odour complaints they had received previously from residents.  Thames Water were asked why they had not followed this process for the current works and they advised us that it was classed as “permitted development”.  However, we have continued to have doubts as to whether this information was correct.

Odour Survey and Results

At the beginning of July 2016, Cranleigh Civic Society carried out our own survey to find out whether there still was a problem with odour problems from the sewage works.

We delivered 330 forms to households within an 800m radius of the Cranleigh Sewage Treatment Works (STW), 104 survey forms (32%) were returned.

The aim of the survey was to identify if residents had existing odour nuisance problems, whether they had reported these to Thames Water or Waverley Borough Council and whether they were aware of the enlargement work being carried out at Cranleigh sewage treatment plant.

Of the respondents, 71% of households had experienced odour problems, however only 16% of households had complained directly to Thames Water or Waverley Borough Council about the issue, and 93% wanted Thames Water to carry out a full Odour Impact Assessment before proceeding with further work on site.

cranleigh-swt-800m-radius

Of the 71% of households who said that odours from Cranleigh STW have been a nuisance,  47 households went on to say that, on a scale of 1 to 5, where 5 is “very offensive”, that they rated the odour nuisance at 4 or 5.

97% of households said that they had not been made aware by Thames Water that Cranleigh STW was being expanded.

The survey results indicated that currently there is a high level of concern from residents living within 800m concerning the odours emanating from the STW.

It also highlighted the number of residents that fail to report odours, therefore reliance on the level of complaints to Thames Water cannot be taken as indicative of the true number of households affected by this ongoing problem.  One resident replied “I didn’t know I could complain”.

The survey also identified the detrimental impact on residents’ enjoyment of their property. This distressing nuisance is particularly prevalent on warm summer evenings when residents living near the STW report having to close their windows, of mosquito infestations and being unable to sit in their garden due to the overwhelming and offensive odour of sewage.

Against this background and the advice given in DEFRA’s “Odour Guidance for Local Authorities, 2010”, we have submitted the survey results to Waverley Borough Council for them to investigate.

We received the following response on 29 September 2016 from Waverley’s Planning Enforcement Officer


“TOWN AND COUNTRY PLANNING ACT 1990 (AS AMENDED)

RE: CRANLEIGH SEWAGE TREATMENT WORKS

Further to our previous correspondence regarding the site I have now had the opportunity to discuss with colleagues at Surrey County Council and have been informed that they are the appropriate Planning Authority to investigate the matter.

They have requested that your complaint be emailed directly to mwcd@surreycc.gov.uk please include the full details of your concerns together with any reasoning as to why you believe there to be a breach of planning control. Once they have received the enquiry they open a case for action.

Please be informed that unless I am informed to the contrary, because we are not the most appropriate authority to investigate, the complaint case C/2016/00257 will be recommended for closure.

Should you have any further queries please do not hesitate to contact me and I will direct your concerns as best I can.”


On 30 September 2016 we then received notification from Surrey County Council’s Senior Planning Enforcement Officer that the matter had been passed on to him by Waverley and he confirmed that:


I can inform you that the County Planning Authority (CPA) have requested full details of works from Thames Water.  On receipt of requested information the CPA will be assessing the position with regard to Permitted Development Rights or alternatively if there is a need for formal planning consent.  Officers also intend to visit the site to view the works.

Following consideration of this matter, the CPA will advise you of its findings.”


We now await the outcome of their investigations with interest.

However, in the meantime sewage issues continue to be reported to us, the latest today is on the Downslink where it joins Snoxhall fields, adjacent to Hitherwood.

downs-link-thames-water-04-10-16-1

downs-link-thames-water-04-10-16 -2

If you have any information regarding sewage issues please do get in touch.

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Windy Way, The Common Application Refused

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Waverley Borough Council refused the application WA/2016/1544 on 29 September 2016 for the demolition of Windy Way on Cranleigh Common and the building of a block of 6 flats and two semi detached dwellings on the site.

The reasons given were in summary:

  • Harm to the Conservation Area.
  • Harm to neighbouring properties.
  • Over development of the site.
  • Proposed buildings out of keeping.
  • Not a good use of the space.

You can read the refusal reasons in full here:

windy-way-refusal-29-09-16

Existing Bungalow

windy-way-bungalow-front-elevation

Replacement Block flats and Houses

Flats Side elevation (over 13m in height):

windy-way-flats

Houses (x2) Side Elevation (over 13m in height):

windy-way-semi-detached

Position on plot:

windy-way-block-plan

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