Category Archives: Green Fields

Cranleigh Stuffed!

Share Button

One of our Facebook friends asked us to post a map of all the development in Cranleigh to indicate to residents the true scale of our problem.  Well here it is, hot off the Waverley Planning Maps website:

Cranleigh Planning Applications 2011 onwards

This only shows planning applications from 2011 onwards.  You will no doubt recognise the mega site south of the High Street which totals 765 new dwellings alone!  This includes Berkeley Homes 425 dwellings (spanning Knowle Lane to Alfold Road), Little Meadow (Alfold Road) 75 dwellings and the Knowle Park Initiative (A2 Dominion) 265 dwellings (Alfold Road as well!). We do not understand how Surrey Highways thinks the rural roads will cope, with the explosion of  houses Waverley has planned for this area. and how they believe road safety will not be compromised.

Those of you also concerned about the sewage and foul water from all of these houses, will no doubt be astonished to learn, as we were last week at a meeting in Guildford with Thames Water, that no provision has yet been made for the expansion of the sewage treatment works on Elmbridge Road and no consideration has been given to the river into which the effluent flows.  We have reported countless times that Cranleigh Waters now regularly dries up, yet apparently, according to the “experts” in their desktop studies, it can cope with double the number of houses, and double the amount of effluent being poured into it, yes another minimum of 4,455 new dwellings, without any pollution problems whatsoever!

Over the last couple of days, Residents have yet again been reporting to us more Thames Water contractor vans across the village (picture below opposite turning to Elm Park 5 June 2017).

Elm House opp Elm Park 5 June 2017

Thames Water confirmed it had spent £1M on new filters to improve the sewage treatment works for EXISTING residents only, but as yet have not secured funding, or designed the sewage works for the new loos, showers, dishwashers, washing machines etc in the pipeline for 1,300 new houses in Cranleigh, let alone the 2, 600 (Local Plan figure) for Dunsfold or 600+ on the Springbok Estate.  This is utter madness!!  And yet still more applications pile up – another 98 on the primary school sites and another 101 in phase 2 for the Crest Nicholson site off the Horsham Road, which some of you may have attended the consultation in the village for.  Does it end there?  No of course not the numbers just keep growing, whilst the certain environmental damage on our doorstep is being firmly ignored.

What legacy is this Waverley Borough Council leaving to the next generation of residents in Cranleigh?

Share Button

KPI Decision Challenged – Update

Share Button

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.

Share Button

KPI application to be heard 15th March

Share Button

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

Share Button

Death of the Grampian Condition

Share Button

It won’t have gone unnoticed to residents that both Crest Nicholson on the Horsham Road and Cala Homes on Amlets Lane have started developing their sites.

Both these sites had Grampian style conditions.  This was meant to prevent the start of the development until off-site works were completed on the sewerage network, including the sewage treatment works on Elmbridge Road. However, we were recently advised by planning enforcement at Waverley that the Grampian Condition wording is too woolly to enforce and doesn’t specifically mention the words sewage “TREATMENT”,  so no work to the sewage works are apparently included – another nail in the coffin for Cranleigh.

To say that we felt let down by the lack of rigour exercised in the planners’ wording of the Grampian and the lack of ability by Waverley to enforce it, is an understatement!

There is no consideration being given to existing residents, who after all fund the borough council, in the scramble to achieve a housing number at all costs.  We don’t need to remind you, that you will have to bear the brunt of polluted rivers, congested roads, odour nuisance from the sewage works, an over burdened GP surgery, the list goes on.


As you might remember Cala Homes had applied for their Grampian condition to be removed, however, Waverley Borough Council, in a rare moment of what seemed common sense, refused their request. Surprisingly, this did not stop work on Cala’s show houses.

Amlets 8 Jan 2017

The bungalow on the Horsham Road, which was acquired by Crest Nicholson to provide an access road to the site, was demolished long before their Grampian Condition was even discharged (such as it was), and work was also immediately commenced on the green fields to build 149 houses.  Grampian, what Grampian?

It was also pointed out that Crest’s Grampian was a little more lax than that for Cala Homes, despite all the initial concerns Thames Water had about this site and the need for huge on-site sewage storage tanks. These worries seem to have been a mere flash in the pan!

Not long after the first Crest spade was in the ground, they were plotting to build 121 more houses in the pristine green fields adjacent to this site.

Crest describes Cranleigh on their website:

“Cranleigh is a pretty Surrey village where one can enjoy a relaxed pace of life yet benefit from daily conveniences aplenty on the doorstep, including a selection of shops, cafes and restaurants.”

Crest Nicholson demolish Bungalow Horsham Road

Sounds idyllic, and surprising how keen developers are to emphasise that we are a “village” in their marketing literature.


Despite the unsustainable location of Cranleigh, on a rural road network, with little public transport, a heavy reliance on the use of the private car, limited employment opportunities, water quality issues, a high percentage of asbestos cement drinking water pipes, an inadequate sewage treatment plant, and on green fields to boot,  none of this matters, as long as the houses are built.

The ONLY reason for these dwellings is because we have NO GREEN BELT protection, nothing else, and national planning policy will be twisted at the whim of the planners to suit their ultimate plan for this area, which is CRANLEIGH TOWN.

However, before you start thinking, how bad can that be, it will be bad!  We are the only community in Waverley without green belt protection AND any environmental designation.  Farnham at least has the protection of Thames Basin Special Protection Area.  So going forward, Cranleigh will be the dumping ground for any, and all, unmet housing in Waverley.  However, Waverley Borough Council seem to be the winners, they have a convenient area, in the corner of the borough, which will be a cash cow for council tax, and with only 5 councillors (Farnham has 18) representing this area, and two of those with a declared pecuniary interest in development, this really does seem like a marvellous arrangement.

There is the rather inconvenient truth of Cranleigh Waters, which is polluted and failing in terms of the Water Framework Directive, but that can be smoothed over, by applying pressure to an overworked and under resourced Environment Agency (EA) with the promise of funds for river restoration  and flood plain replacement projects.

There’s the problem of the rural roads and A281, but as Matthew Evans, Ex-Waverley Head Planner, said it really doesn’t matter if people are stuck in traffic.  Obviously air quality issues and quality of life, for residents in this part of the borough,  was not something that disturbed his sleep.

And then there’s the ageing asbestos cement drinking water pipes, which have an extremely inconvenient habit of bursting whenever water pressure increases, still, studies of health risks are inconclusive, so it appears Waverley don’t need to worry about that either.  Despite the fact that we can find no reports that include the age of pipes we have here, or our particularly agressive type of water.

It would be difficult to imagine what would ever be considered as a material constraint by Waverley planners against development in Cranleigh, perhaps the discovery of uranium in the high street?

And to add insult to injury, the EA are now actively looking for replacement flood plain for this area, as let’s face it, they don’t want to create too much flooding downstream for Bramley and Guildford, residents there might start to wonder why the hell all this building was allowed, or should we say encouraged, on the natural flood plain we DID have.

However, we still have something up our sleeve and that’s you!

Joined together, you are the most powerful force.  Stronger than Waverley and stronger than developers.

Working together in big enough numbers, people can, and will, make a difference.  We can fight for fairness, we can fight for our community, and we can fight for our environment.

JOIN US


“Never doubt that a small group of thoughtful, committed citizens can change the world; indeed, it’s the only thing that ever has.”

Margaret Mead


 

Share Button

EA Object to KPI Application

Share Button

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.”

Share Button

Amlets Lane Approved

Share Button

The Amlets Lane application by Cala Homes for 125 dwellings got the final vote of approval at Waverley Borough Council last night by 12 votes to 9.  Cranleigh’s Waverley Councillors all voted against the application, however this last minute push was too late to save the site from development.


Liz Townsend spoke on behalf of Summerlands Estate Residents Association and residents of Copse Edge:

We acknowledged that Cala Homes had made some welcome and positive changes to the layout since the application was deferred in September, with a reduction in the height and bulk of the apartment buildings, the positioning of bungalows along Copse Edge and the removal of a parking court.

Residents’ Liaison Group

Residents remain extremely concerned about the access road into the site and the lack of detail regarding the drainage system for surface water run-off.  On residents behalf, we requested ongoing involvement in the design of the drainage scheme by sharing local knowledge on flooding.  The idea of a liaison group was endorsed by some councillors, and we have emailed Waverley Borough Council today to repeat this request.

Permitted Development

To protect the privacy of residents living adjacent to the site, we requested a restriction on permitted development to the roof of any dwelling along the site boundaries, as recently imposed on the Crest Nicholson development on Horsham Road, which was agreed.  This means that householders on the Amlets estate will have to apply for planning permission to extend into their roof space.

Buffer Zone

amlets-lane-buffer-zone

We also requested details that the buffer zone (shown above) around the edge of the site should be included in the overall management plan for the estate, as there is a risk that it could become overgrown, neglected and unsightly, or encroached on as part of the drainage scheme.

Foundations

Since the first application, residents have highlighted subsidence issues on Summerlands and the requirement for pile driving on Copse Edge. We expressed surprise that the developers were still recommending concrete strip foundations and maintain that these will not be adequate and the need for deeper foundations could be used as leverage to further reduce the amount of affordable housing on the estate on viability grounds.

Affordable Housing

We noted with regret, that the proposed tenure split is now to be 50:50 between social rented and shared ownership, rather than, as was agreed at outline, 76% rented and 24% shared ownership.   However, Cllrs were unable to discuss this aspect of the application, as the alteration will be by way of a separate variation to the S106 agreement and will be agreed by planning officers under what is called delegated powers.  However, we asked Cllrs to honour the original condition as this was one of the main determining points in approving this exceptional green field site.

Sewerage Infrastructure and water Quality

We requested further details from Waverley about the calculation of S106 contributions from the developer for off-site sewage upgrade work, or for water quality mitigation, as required under the Water Framework Directive (WFD), for Cranleigh Waters.  We have repeated this request today.

As previously published, considerable expansion work is currently taking place at Cranleigh Sewage Treatment Works in order to accommodate “growth” however the problem surrounding the pumping of increasing amounts of liquid sewage effluent into Cranleigh Waters has not been referred to, or addressed by Waverley.

In response to a meeting on 12 October with Cranleigh Civic Society, Anne Milton and Andrea Leadsom.  Defra confirmed that development must not be contrary to the WFD and to paragraph 109 of the National Planning Policy Framework (NPPF) which states that the planning system should contribute to and enhance the natural and local environment.  The obligation that Waverley has, to consider WFD when determining local development, has, we believe, not been fully satisfied.

Road Safety

Cranleigh’s Councillors raised lengthy additional comments surrounding road safety, which unfortunately was not one of the reasons for the previous deferral of the application, and although, we firmly agree, extremely important, was all too late to save the Amlets site.

There were further concerns raised about traffic turning out of the estate onto Amlets Lane and the route of construction traffic, suggestions of a one-way system were raised.  The Construction Management Plan will ultimately be decided by planning officers, who will we hope take up the suggestion of a further site visit.

We will all need to be vigilant once construction starts on this site and use this road only when necessary and with increased care. Please continue to report any incidents to us info@cranleighsociety.org and send in photos if these can be taken safely.

Share Button

Thames Water Object to Thakeham Homes

Share Button

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.

Share Button

Thakeham Homes Apply for Planning Permission

Share Button

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.

Share Button

Little Meadow passed by Waverley Councillors

Share Button

Despite being a remote site on a green field, impact on sewage, roads, visual amenity, urbanising impact, absence of protected species surveys and impact on ancient woodland, the list went on, Little Meadow application for 75 houses on the Alfold Road was GRANTED last night.

This just adds to the concerted effort to dump all Waverley Borough Council’s housing allocation on Cranleigh.  Added to the 757 already approved, this brings the GRAND TOTAL to 832 and that’s without the 30 extra new homes on small sites in the village.

Yay, we’re heading towards 900 new houses!

Hang on though……..

Then there’s approximately 220 more on Hewitts and the Cranleigh First and Primary School brownfield sites in the planning system too!

We’ve reached the 1,000 Jackpot!

Cranleigh councillors Brian Ellis, Stewart Stennett and Jeanette Stennett all voted in favour of the Little Meadow development as  ALL three said that Cranleigh NEEDS more housing, despite permission granted for over 700 already.

We are not sure when they will think that Cranleigh has enough?

Pecuniary Interest

Brian Ellis at the start of the meeting declared that his pecuniary interest in the Knowle Park Initiative (KPI) was a mistake and it was a non-pecuniary interest that should have been recorded in the previous meeting, due to his involvement with the transfer of land between the Parish Council and the Cranleigh Village Hospital Trust of which the owner, Nick Vrijland, of KPI, is also a Trustee.

You can read more about this in the Surrey Advertiser story at the time.

There was no withdrawal of the Stennetts’ pecuniary interest in the Knowle Park Initiative and Mrs Stennett also declared that she knew the landowners of the Little Meadow site.

Unfortunately Vice Chairman of the Joint Planning Committee Maurice Byham (who had attended the Cranleigh Society stakeholder meeting at the Cranleigh Sewage Works only last week), the planning portfolio holder Bryan Adams, Waverley Mayor Mike Band, Cllr Pat Frost and Cllr Stephen Mulliner did not attend this meeting.

Reasons for Refusal

Despite Cllr Mary Foryszewski’s valiant attempts to draw attention to available brown field sites in Cranleigh and the overall detrimental impact of yet more development on Cranleigh’s green fields, she was in the minority.

Cllr Patricia Ellis drew attention to the state of the Alfold Road and said it was the worst road in Cranleigh.

Parish Council

Cranleigh Councillor’s Brian Freeston’s speech outlining the parish council’s reasons for refusal, including the remoteness of the site, distance from the High Street, availability of  brownfield sites and the lack of reports for protected species.  He also pointed out that a recent Appeal for a dwelling on Bookhurst Road had been refused on biodiversity grounds, quoting:

However, there would be a potentially detrimental effect on biodiversity in conflict with national policy and with the development plan. There are no other material considerations including the lack of a 5 year housing supply and the provisions of the Framework that outweigh these findings. Therefore, for the reasons given, the proposal is unacceptable and the appeal should not succeed.

Cranleigh Civic Society

Warning this may get a bit technical 🙂

The Cranleigh Society (when the video footage seemed to go a bit wonky! A brief moment of fame lost ;D) emphasised the point that Waverley Borough Council’s Officers’ advice to members of the Joint Planning Committee was erroneous and the council was taking on the full risk and liability, if the application was approved, of non-compliance with the Water Framework Directive (WFD).

The Society pointed out that it is the responsibility of Waverley, as advised by the Environment Agency (EA), to assess the impact on water quality from this development. This has not been done to date.

The Society also pointed out that Waverley was wrong in saying that the EA had not objected to this application. Yet again we had to point out to Waverley that the EA is only a regulator with regards to WFD and as such CANNOT OBJECT, only provide advice. The EA had provided strongly worded advice on this subject to Waverley which was largely ignored.

Waverley as the competent authority for planning & development should have ensured that an ‘appropriate’ water quality assessment was made.  As it stands, no impact on water quality has been measured or reported.

Waverley, it seems, continues to be confused about their role with regards to WFD and said in their Officer’s report (page 50), that accompanied the meeting last night, that:

in terms of water quality, it is for Thames Water, in consultation with the Environment Agency to address this matter, and not a matter for consideration under the planning application. This is a separate regulatory process, which the statutory authorities work under.”

We spoke to an Environment Planning Specialist at the EA before the meeting last night who confirmed that the above statement was “factually incorrect”. This was relayed to Councillors.

The EA confirmed that it is for the LA [local authority] to ensure that the developer has confirmed that there will be no additional impacts to water quality (& WFD) as a result of the new development.

This water quality impact will then have a knock on impact on WFD. The Environment Agency as a regulator does not assess the developments potential to impact and neither does Thames Water (TW).  TW will just confirm whether or not they can accommodate the development within their existing permit or network/STW [sewage treatment works] capacity.

Thames Water’s current environmental permit to discharge effluent into Cranleigh Waters is OLD and does NOT consider the requirements of the Water Framework Directive, as it was issued prior to these regulations and has not been renewed.

As a result, the existence of this permit, or the fact that Thames Water is operating within the boundaries of the permit cannot be used by Officers as an indicator of compliance with WFD, as it has absolutely diddly-squat to do with it and they should know that!

By passing the application last night Waverley has done so with the ‘full knowledge’ that no water quality assessment has been carried out and Waverley will bear the full risk and liability of this decision.

The application was passed by 11 to 7 votes opening the door wide to yet more development in Cranleigh.  We wonder if next time WFD will be taken more seriously……………

Share Button

Little Meadow Planning Application Alfold Road

Share Button

The postponed planning application for 75 houses on the Little Meadow site on the Alfold Road has now been arranged for 16 May 7pm at the Waverley Borough Council offices.

Position of Little Meadow Alfold Road planning application

This is yet another application on Cranleigh’s green fields and will put more strain on our sewerage system, which is already over capacity and rural road network.  Please show your support by attending this meeting with us.

And if you haven’t objected you can still do so Waverley Borough Council Ref WA/2015/0478.

We would like to thank all of you for your support that contributed towards the refusal of the Knowle Park Initiative planning application for a remote site of 265 houses on the Alfold Road.

Share Button