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:
- The site is subject to regular flooding and the flood risk has been significantly underestimated.
- Up-to-date allowances for flooding and climate change (16 February 2016) have not been used.
- Water quality in Cranleigh Waters will be detrimentally affected by this application and it does not comply with the Water Framework Directive.
- 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.
- The site is not deliverable within 5 years.
- 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.
- The distance of this site from the high street means that residents will have a heavy reliance on the use of a private car.
Or email your comments to the case officer Chris French direct on firstname.lastname@example.org 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):
Waverley Borough Council
Additional information :
The application site is bordered on two sides by the Environment Agency designated main rivers – Cranleigh Waters and Littlemead Brook.
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):
This is the reality – Thakeham Homes Site Elmbridge Road 24 December 2013:
28 March 2015:
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.
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.
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.
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 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):
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.
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.