Category Archives: Flooding

THAKEHAM HOMES ELMBRIDGE ROAD UPDATE

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Since our posting on 6 October we have written to Anne Milton MP, Tom Horwood (Interim MD at Waverley Borough Council) and the Department for Communities and Local Government (DCLG) to confirm our utter amazement and dismay that this application was granted.

We are meeting this morning with Tom Horwood to discuss this matter further.

We asked DCLG to call-in the application on the basis that the Joint Planning Committee Chairman, Cllr Isherwood, refused to allow the members of the JPC to consider the correct flood levels provided by Cllr Hyman and which have been subsequently checked by our expert who confirmed the (higher) levels were 100% correct. The refusal to allow a debate is a fact – have a look at the video of the meeting:

JOINT PLANNING COMMITTEE MEETING 5 OCTOBER 2017

Cllr Isherwood relied heavily on an desktop computer report by a company working on behalf of the developers to the total exclusion of all other primary evidence presented by residents and other councillors. The developer’s representative was allowed unprecedented access to members throughout the entire meeting and sat with officers at the head table and was allowed to speak throughout the discussion of the flooding item, unlike the parish council, residents or the Cranleigh ward member who were only allowed a maximum of 4 minutes.

We take the view that there has been a blatant violation of planning law.  DCLG refused our call-in request so Anne Milton was then requested to not only push DCLG to reconsider their decision but also involve the Department for Environment, Food and Rural Affairs (DEFRA). It was only at the beginning of this year that DEFRA, following the disastrous flooding in the North of England, issued a consultation document asking for submissions on how to reduce the Governments exposure to the ever increasing cost of flood relief – and here we have another Government Department hell bent on condoning the granting of planning permission on a flood plain where future serious flooding is a certainty!

Where is the joined up thinking here?

Hopefully we will be able to get some answers today and achieve some joined up thinking from central government but we have to be prepared for inaction so we have already commenced discussions with the Association of British Insurers with a view to having this Thakeham site as a decline risk for flood insurance as Insurers only take on flood risks, not flood certainties.

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CRANLEIGH FLOOD FORUM – FRIDAY 10 NOVEMBER 2017

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** PLEASE NOTE START TIME AND VENUE **

 The venue is The Band Room  in Village Way, Cranleigh, and the meeting starts at 10:30 am

This is the second  meeting of Cranleigh Flood Forum chaired by Anne Milton MP.  The issues Cranleigh Civic Society wishes to discuss include:

  • Thakeham Homes, Elmbridge Road Planning Permission
  • Illegal river dredging
  • Water Quality (Cranleigh Waters)
  • Asbestos Cement drinking water pipes
  • Flood Risk in general

Please attend this meeting if you can. It is open to all Cranleigh residents, not just Cranleigh Civic Society members!

Please speak to your friends and neighbours as the more people who attend the more we can demonstrate the serious concerns we have in Cranleigh about the over development of our village and problems that lie ahead.

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Anne Milton opens Flood Gates

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On Monday the 24th of July, Anne Milton MP organised a meeting at the village hall that she described as a flood forum and it turned out to be much more than that. She brought together Waverley planners, Thames Water, the Environment Agency, the Drinking Water Inspectorate, Public Health England, Surrey County Council, the National Flood Forum, Cranleigh Parish Council and Cranleigh Civic Society to discuss openly several of the major concerns Cranleigh’s residents have raised with her. 65 members of the public came along and several parish and borough councillors also attended.

The plan was to address these concerns and direct them specifically to the authority responsible, so that the answers could be heard by all. We were very happy to hear sewerage problems, flooding and asbestos cement water pipes all discussed openly. It was always understood that the problems would not be resolved then and there but that efforts could be made to address them in the coming weeks and months.

To aid this, small sub committees were formed to work on specific areas and they will report back at the next meeting planned for the autumn. It was just the beginning of what will be a long term effort but a positive step and one that Cranleigh Civic Society welcomes. Members of the Society volunteered to join sub committees and share the information they have collected specific to each area so we will be close to the decision making process.

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Flooding on Thakeham Site – Elmbridge Road

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As you will be aware the decision on the Thakeham Homes application for 54 dwellings off the Elmbridge Road was deferred by the Joint Planning Committee pending more evidence on flooding and odour from the Sewage Treatment Works.

If you have any photos of flooding on this site whatsoever, could you please email your photos to info@cranleighsociety.org or send printed copies of photos to Phill Price, Chair, Cranleigh Civic Society, 18 Brookside, Cranleigh GU6 8DA

thakeham-homes-main-rivers-labelled

Thank you.

 

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Another 54 houses for Cranleigh – **Decision Deferred!**

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As an update on this post from last week, the JPC voted 9-5 to defer the decision on this application, on grounds of flooding and odour from the nearby sewage works.

 

Thakeham Homes application (Planning Ref : WA/2016/1921) for 54 houses off Elmbridge Road goes to Joint Planning Committee this Weds 28 June 2017 6:30pm at Waverley Offices in Godalming. Officers are recommending this for APPROVAL.

thakeham-homes-block-plan

This entire site was underwater in Dec 2013/Jan 2014 – the road, which was higher than the site, was impassable.

In January 2015 about 30%  of the site was flooded.

The site also enjoys sewage odour during the summer months – this has got to be a low point even for Waverley! Under 2.3 Odour Complaints of the Odour Assessment it is alleged that odour is only a problem to residents living NE and SE of the site and that only one property to the south complained.

Is that, perhaps, because the main area to the south is the green field where development is being proposed?

Thakeham Homes have stated that “odour is not considered to be a constraint to residential development at the site”.

Would you like your children to buy a house here with no guarantee of flood insurance and likely to have unpleasant odours?  Doesn’t sound like idyllic village life to us.

What you can do:

Attend the JPC meeting:

6.30pm 28 June 2017 Waverley Borough Council offices, The Bury’s, Godalming.

Object online: http://planning.waverley.gov.uk/live/wbc/pwl.nsf/(RefNoLU)/WA20161921?OpenDocument Click on  and enter your details and comments.

Write to Waverley Borough Council:

http://www.cranleighsociety.org/2014/10/25/joint-planning-committee-contacts/

Write to Anne Milton:

Ask her to call in this outrageous application. Email her on anne.milton.mp@parliament.uk the reference is WA/2016/1921 Land South Of Elmbridge Road, Cranleigh perhaps notice will be taken if lots of people request it.

 

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KPI Decision Challenged – Update

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As an update to this previous article, we have now been informed that the Secretary of State has not agreed to call in this application.

So, sadly that’s another 265 houses approved to be built in an unsustainable location.

Original article follows:

Following the decision two weeks ago by Waverley Borough Council to approve the building of 265 houses on another of Cranleigh’s green fields, Cranleigh Civic Society has written to DCLG (Department for Communities and Local Government) to ask for the application to be ‘called in’.  If accepted, this will lead to an inquiry being held by the Secretary of State.

Our reasons for requesting a call in are:

  1. Cranleigh’s Parish Councillor Liz Townsend was denied a vote for this application, in place of the late Brian Ellis.
  2. The vote was 8 for and 8 against, with the deciding vote given by a Hindhead councillor.
  3. There were four missing members of the JPC who could have given their vote to one of the Cranleigh councillors in their place, but chose not to elect substitutes.
  4. The Planning Officers were not acting impartially, but appeared to be in favour of the developers.
  5. This application had previously been rejected and was just resubmitted without significant changes, so why was this allowed?
  6. We have uncovered the existence of asbestos cement water pipes which could pose a serious risk to public health and if this is to be fixed 30% of Cranleigh’s drinking water pipes will need to be dug up. If not resolved the danger from asbestos will be exacerbated by the extra water pressure from new homes.
  7. Why have the developers not been questioned about the illegal dredging of Cranleigh Waters carried out by a contractor at their request?
  8. The KPI site fails the sequential test, as there are other sites better suited to development which do not flood. There will be no subsidised affordable flood insurance from Flood Re as, since 1 January 2009, new homes should not be built on high flood risk areas.
  9. This application was submitted at the same time as an appeal against the refusal of the previous application, which in itself is odd.

For these reasons we have serious and valid concerns about the granting of this application and hope that the Secretary of State will agree with us.

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KPI application to be heard 15th March

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Development Application: Land at West Cranleigh Nurseries and North of Knowle Park between Knowle Land and Alfold Road, CRANLEIGH

Reference : WA/2016/2207

www.waverley.gov.uk/planning

This application is to be heard on 15 March 2017 7pm at Council Chamber, The Burys, Godalming

Objections need to be submitted by 10 March.

Your village needs you to object NOW.

The application is not materially different to the original that was refused 29/04/2016 and is now at appeal.  The reason for refusal remain and when an application is not materially different to that refused a period of 2 years must pass before a similar application can be considered.  To reflect on previous objections, the application is not sustainable, remains outside the village envelope, the proposed area is in flood zone 3, agricultural land, removal of employment land, should the other nearby applications commence the accumulation of traffic on the Alfold road, the density of housing is excessive, affordable housing reduced to 35%, the ‘Parkland’ remaining in perpetuity how will this be achieved.

Object today!

How to Object to Planning Applications

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Flood Insurance for new homes?

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The National Planning Policy Framework (NPPF) states that new houses should not be built:

  • on flood plains
  • on other high risk flood areas
  • in areas where, if houses are built, it would increase the risk of flooding neighbouring property

Despite this requirement, many homes are being built (or we expect to be built) in such areas – for example:

  • Crest Nicholson, betweenHorsham Road and the Downs Link
  • Berkeley Homes, south of the High Street
  • Little Meadow, east ofAlfold Road
  • Thakeham Homes, next to Elmbridge Road – on land that was seriously flooded in January 2015including the pumping station!
  • A2 Dominion, Knowle Park – new application expected soon for new houses on the lowest area in Cranleigh!

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

Cranleigh Society will continue to object to Waverley Borough Council to granting permission to build in these high risk flood areas, and to stop relying on so-called Sustainable Drainage Systems (SuDS) as a guarantee against flooding, which are not always reliable!

FloodRe is a joint insurance industry and Government initiative to enable the owners of homes which have flooded to not only obtain flood insurance but at an affordable price. The problem is that FloodRe can only “come to the rescue” when a house was built before 1st January 2009! This is because, since that date, no houses should have been built in those three areas specified in the NPPF.

People who bought a house built after 1st January 2009 which has subsequently flooded are on their own when trying to renew their insurance.  Their house could be uninsurable or, at best, they may have to pay a very expensive premium for cover with a high flood excess.

Until recently, the FloodRe literature did not directly mention that all important date of 1st January 2009 – it merely referred to “qualifying properties” with the reader having to visit their website to see if the house qualified!  We found this to be simply unbelievable!

Cranleigh Society tackled FloodRe on this issue and, finally, they did agree to include the cut-off date in all new literature – with no explanation or apology for excluding it in the first place.  There are thousands of these leaflets in circulation, and with no print date to help distinguish the correct and incorrect versions, this would of course be misleading for house buyers.

FLOODRE LEAFLET WITH 1 JAN 2009 DATE

We fear that a lot of new Cranleigh residents are in for a rough time after their first experience of several days of incessant heavy rain.

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EA Object to KPI Application

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The Environment Agency (EA) have objected to the KPI (now in the name of A2Dominion Developments Ltd) on the grounds that there is not an acceptable Flood Risk Assessment (FRA) for the site.


You can read the full objection by clicking on the link below:

EA obj KPI 4 Jan 2017


The main summarised reasons outlined in the EA objection letter are that the Flood Risk Assessment does not demonstrate that the development will be safe from flood risk for its lifetime, and the potential impacts of climate change have not been satisfactorily taken into consideration.

The Cranleigh Society has maintained serious concerns about the flood risk on this site, which is part of Cranleigh’s rapidly diminshing natural flood plain.

We are extremely glad that the EA have carried out a thorough study of the FRA and echoed many of the points that we raised in our letter against this application:

“Flood Risk

Although there is a presumption in favour of sustainable development however NPPF para 14 states that even if the development plan is absent, silent or relevant policies are out of date, permission should not be granted where specific Framework policies indicate it should be restricted, this includes flooding.

We also object on the grounds that the assessment of flood risk informing the measures proposed by the FRA to avoid, manage and mitigate flood risk, are incomplete and have not been appropriately secured for the lifetime of the development.  There also does not appear to be provision for increased climate change allowances agreed by the Environment Agency and the Government, 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 in November 2016 the new allowances and ranges should be used.

Document 9.0 WATER RESOURCES AND FLOOD RISK point 9.28 fails to mention the significant flooding on Alfold Road in 2013/14 or the flooding on Elmbridge Road.  the Our own FRA review by RAB consultants (Bedford) acknowledges that the recent flooding of December 2013 on the Cranleigh Waters and Littlemead Brook has not been recognised within the flood risk assessment (FRA) dated October 2014.  They go on to say that the extreme nature of the flood in December 2013 warrants recognition within the FRA and an assessment of flood depths and extents at the site if possible.  Additionally, given the nature of flooding in December 2013 and the significant groundwater flooding experience across many parts of the Thames Catchment throughout winter 2014, it would be prudent to include this within the assessment of groundwater risk to the site.

Water Environment Ltd October 2016 appears to be missing Appendices B, C and D. Previously Appendix B of the FRA shows that EA “Product 4” flood data, received 29 July 2014, was used for the assessment.  The EA have updated their flood modelling in the area since this data was obtained. The data used in the FRA has therefore been superseded. Without incorporating all this data we do not believe an appropriate nor up-to-date assessment of flood risk has been undertaken.

Furthermore, evidence exists and data has been collated of the recorded flooding in the vicinity of this development during 2013/14.  This has been submitted in support of a planning application ref WA/2014/0912 by Berkeley Strategic Land Ltd in Appendix 1 from “Technical Review of Flood Risk Assessment (FRA) for the construction of 425 dwellings on land south of Cranleigh, Surrey” dated August 2014.  The FRA should take this evidence into account.

Paragraph 040 of the Planning Practice Guidance (PPG) states: “To demonstrate to the satisfaction of the local planning authority that the development will be safe for its lifetime taking account of the vulnerability of its users, a site-specific flood risk assessment may need to show that appropriate evacuation and flood response procedures are in place to manage the residual risk associated with an extreme flood event.  Proposals that are likely to increase the number of people living or working in areas of flood risk require particularly careful consideration, as they could increase the scale of any evacuation required. To mitigate this impact it is especially important to look at ways in which the development could help to reduce the overall consequences of flooding in the locality … through off-site works that benefit the area more generally.”

This proposal would significantly increase the number of people living in an area affected by very recent flooding and would increase the scale of any emergency evacuation considerably.  The FRA has not considered how this additional burden will be managed in the extreme flood event and has not suggested any off-site mitigations to reduce the overall consequence of flooding in the locality. We therefore object on the grounds that the additional burden on the emergency services in a flood event has not been given due consideration in the FRA.

A further objection is that the FRA fails to prove that the voluntary and free movement of people during a ‘design flood’ can be demonstrated.  Assessments of the adjacent Berkeley Homes WA/2014/0912 application site have shown that dry access/escape routes from the site across green fields are unsustainable in flood risk terms.  The FRA addendum (9 June 2015) for this site previously proposed an approximate 5km pedestrian diversion along unlit and unmade footpaths and public highways without footpaths.  This does not provide a safe nor appropriate route for people, especially for more vulnerable residents.

Evidence to support this is outlined in Appendix 1 of “Technical Review of Flood Risk Assessment (FRA) submitted by Berkeley Strategic Land Ltd WA/2014/0912 which demonstrates that every access route away from this adjacent development, using the Alfold Road, will be inaccessible by foot or car in a flood event like the one that occurred during 2013/14.

NPPF places 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 likely to be within the Functional Floodplain.

The extent of the Functional Floodplain is normally defined by the extent of flooding in the undefended 1 in 20 year (5% annual probability) event and the EA flood data indicates that parts of the site lie within the 1 in 20 year (5% annual probability) flood extent.  As the FRA has not delineated the extent of the Functional Floodplain at the site, we do not believe an appropriate nor up-to-date assessment of flood risk has been undertaken and object on these additional grounds.

The NPPF makes it very clear that the aim of the sequential test is to steer new development to areas with the lowest probability of flooding.  The Sequential Test provided by the applicant does not provide satisfactory justification as to why other suitable sites have been discounted.  We object on the grounds that the site fails the Sequential Test and the Exception Test cannot therefore be applied.  There is a site a far less risk of flooding for 120 dwellings currently at Appeal, the result of which will be available on 9 January 2017.  The council currently has a five-year housing supply and does not require housing on green fields at risk of flooding, on a flood plain, which will increase flooding elsewhere.

We also have concerns about the ability of new residents moving into the site to obtain meaningful flood risk insurance at an acceptable cost since the Association of British Insurers has stated that New Houses built after 1 January 2009 will not be covered by Flood Re; this is to avoid incentivising unwise building in flood risk areas.

The assessment of flood risk needs to demonstrate that the flood risks posed by the development can be managed, ae realistic, taking into account current climate change allowances, and are safe, the FRA fails to do this.”

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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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