Category Archives: Local Plan

Community Infrastructure Levy lost £s

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CCS received a grumbling letter – it goes something like this –

Let’s talk about Community Infrastructure Levy now at last we have a LOCAL PLAN, but what does this mean?

An agreed LOCAL PLAN gives our planners at Waverley Borough Council the power to control future housing development; they can plan for the development of new infrastructure, roads, railways, schools, hospitals etc.  and very importantly it enables the Borough Council to charge house builders a COMMUNITY INFRASTRUCTURE LEVY known as CIL for short. 

What is  CIL?

 CIL raises monies towards the cost of the new Infrastructure needed for the developments to go ahead. What a wonderful step forward we all exclaim!! and so it is. But what of the housing already approved? approaching 2000 houses throughout the borough. Well unfortunately

CIL is not retrospective.

How much will Waverley charge? www.waverley.gov.uk/CIL

According to WBC’s website Waverley’s draft proposal  sets a CIL rate of £395/ Sq Metre of floor area for all new housing, (about £40,000 on an average 3 bed house), except quite reasonably for “Affordable Housing” where there is no charge. So taking the 35% of Affordable Housing the Borough is committed to build away from the approximately 2,000 houses so far approved, there will be a loss of CIL to the tune of a minimum £60 MILLION pounds. £60 MILLION pounds that will NOT be available to improve our ROADS, our SCHOOLS, our HOSPITALS, our BOROUGH!!

 How could this have happened we may ask? It happened because our planning officers at Waverley failed to come up with a plan that satisfied the Government’s criteria for a LOCAL PLAN.

How a Local Plan is developed by the Borough Planners

The basic criteria affecting us as council tax payers was to identify suitable sites for new housing. This has to satisfy the Central Government’s housing policy, a requirement that was for about 350 houses a year until 2032. Woking B C have had an agreed  Local Plan for some years  that has now proved inadequate, so the inspector added a further 150 or so houses per year to WBC’s to cover their shortfall! So WBC’s Yearly requirement rose to 509 houses until 2032 (a total of 7,126 houses) 35% of which must be “Affordable”. Plus a further rise to 590 was deemed necessary by the inspector when I last looked. 

What of democracy?

Of these 7,126 houses, a minimum of 4,300, rising to perhaps 5,000 are planned for CRANLEIGH and DUNSFOLD, with the balance spread around the rest of the Borough; We have to ask – just how democratic is that?

 Improvements to our Local Roads and Rail?

Perhaps we could have a new road to rescue us from the A281 Blight? Unfortunately not: there will, however, be a new roundabout at Shalford, just 100 or so metres from the existing roundabout, which feels as if it will bring the traffic to a complete standstill; and the Elmbridge Road and Bramley crossroads junctions will be reconfigured, so that’s a relief!!! There will also be a new Canal bridge at Elmbridge but no new bridge over the old Railway.

What of the Railway?

No plans whatsoever have been considered since SCC’s last feasibility study found not enough demand and not affordable. 

What of DUNSFOLD AERODROME?

There is a plan for 1,700 or so houses plus factories, shops, a school, a medical centre etc. awaiting Government inspector approval. Oh and in the future the prospect of an increase to 2,600 houses or perhaps 3,500 houses or most likely the full 6,000! Sadly, however, it seems that the developers have convinced the powers that be at Waverley that the development of Dunsfold would be jeopardised by the imposition of CIL on the whole development, so there will be NO CIL on the entire development – thereby saving the developers up to £100 MILLION over the life of the development – so that’s ok then.

So let’s hope the plan goes ahead fully and that our Planners use all their discretion to put right the wrongs – spreading the housing out more fairly – hunting for better sites……    they can – but will they?

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Waverley’s Local Plan Part 1 Adopted

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20 Feb 2018  Waverley’s Local Plan Part 1 adopted

was adopted tonight:

  • For – 41
  • Against – 1
  • Abstained – 3

Even those who opposed or had serious reservations took the view that the Waverley area would have more protection with a LP. Even with it’s flaws,  WBC would be able to take back control.  No longer would planning be developer led.

All three Cranleigh Councillors expressed their deep concerns about Waverley’s Local Plan. But they decided to vote For IT because the consequences of having no LP would be disastrous. Nothing will undo the damage that has already been inflicted on Cranleigh but further damage can be minimised with the LP.

http://www.waverley.gov.uk/news/article/337/waverley_s_local_plan_is_adopted

Waverley’s local plan part 1 – Cranleigh Society’s opinion was shared before the vote –

Whilst Cranleigh is viewed by Waverley as one of the four main “settlements”, it has some serious infrastructure problems which the Inspector, Jonathan Bore, has not addressed in the report, even though they were pointed out to him by Cranleigh Civic Society and others at the Inquiry.

  • Cranleigh is only served by already congested B-roads, and lanes (we call them “rat runs”) which do not even qualify for B-road status, and there are no plans in his report (or in the Local Plan) to solve this.
  • Any new dwellings being built in Cranleigh rely on sewage treatment at the Elmbridge Road works.  In recent years, the so-called river that the effluent is pumped into, Cranleigh Waters, has developed serious flow problems, sometimes ceasing flowing altogether.  The river has become polluted, with local angling societies reporting dying fish stocks to the Environment Agency, and there is currently no plan by Waverley to solve this problem.  The Inspector has not considered this in his report.
  • 29.6% of all Cranleigh’s drinking water supply network is made from old asbestos cement pipes which are at the end of their 50 to 70 year design life, and they are regularly bursting releasing free asbestos fibres into the water supply.  Some of the pipes recently tested by Thames Water are made from highly dangerous blue asbestos.  Waverley are aware of this problem, and it has been suggested to them that all the old asbestos cement pipes be replaced before any new housing is connected to the network. Again, this important matter has not been considered by the Inspector in his report.
  • There are no plans to create new local jobs, so increasing the population will simply create a need to commute to work, which is hardly sustainable.

We accept that there is a need to build new houses in SE England and we do not have a problem with Cranleigh taking its fair share, but unless the infrastructure problems are addressed before the plan is published and put into place, we see big problems ahead.

Modern town planning (actually even Ebenezer Howard said this in the 1920s) states that “houses should be built where the jobs are”.  Modern thinking is to build settlements as close as possible to places where people can work or to at least give people easy access to commute.  Of the four settlements in the report, Cranleigh is least able to meet this criteria.  It has only B-roads and narrow lanes leading out of it, no railway station and so on.  The obvious place to build substantial quantities of new houses, in the Waverley area, is Milford, as:

(1) It has a mainline railway station that can easily be extended to take the new 12 car trains to London; (2)  It is close to both the A31 and A3; (3) It is close to the job markets in Guildford, Godalming and Farnham; (4) It is adjacent to the River Wey and therefore readily lends itself to the building of a new major sewage treatment works that can meet the needs of the latest 2017 implementations of the Water Framework Directive.  Yet I think we are correct in saying that the Local Plan only envisages 180 new dwellings in Milford?  If this is the situation we have to ask “Why?”

Richard Bryant

 Vice Chair.

 CRANLEIGH CIVIC SOCIETY.

Go to Waverley Borough Council  website and complete the consultation if you feel you can.

Local Plan Part 2: Site Allocations and Development Management Policies

 

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Waverley Leader advised of No Confidence Vote

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Cranleigh Civic Society have confirmed the vote of “No Confidence” taken by those attending the public meeting on 25 May 2017 to the Leader, Julia Potts, of Waverley Borough Council and are now investigating in full the options available to us and the next steps we will be taking.


Dear Ms Potts

As you are aware, Cranleigh Civic Society recently organised a public meeting at our village hall at which we shared our knowledge of what is happening now, and what is being planned for the future of our village. Many of the 229 people who attended passionately expressed their anger and concerns about the volume of housing your team has approved to be built on our green fields and how many more you intend to send our way.

Equal to this were the worries about how our already poor infrastructure will cope with the huge increase in the population. As promised, I relayed your message of how much you care about our village, and I must tell you it was not well received.

At the end of the meeting we offered the opportunity for them to vote by a show of hands if they wanted to send you a strong and clear message that they do not have confidence in your team’s ability to care for the quality of our lives and wellbeing  through your actions and inaction; 226 voted to support this statement, one opposed and two abstained.

I trust this message is clear.

Phill Price

Chairman

Cranleigh Civic Society


 

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VOTE OF NO CONFIDENCE IN WAVERLEY

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VOTE OF NO CONFIDENCE IN WAVERLEY BOROUGH COUNCIL’S LEADERSHIP

 On Thursday 25th May, Cranleigh Civic Society organised a meeting in the Village Hall to discuss the number of new houses where planning permission has already been granted and the further huge amount of housing being earmarked for Cranleigh in the draft Local Plan.
Village Hall 25May17
 
Subjects discussed included:
 
1. Waverley allocating a huge proportion (44%) of their borough-wide new housing target onto Cranleigh, knowing that there are few job opportunities locally.
2. Waverley holding secret meetings with developers.
3. A lack of concern and action by Waverley over the many infrastructure problems facing Cranleigh.
4. A lack of consultation by Waverley with Cranleigh residents and their Parish Council.
5. Waverley’s practice of recruiting substitutes to vote at JPC meetings (against Waverley’s own Constitution), and
6. Waverley’s inability to have produced a coherant Local Plan, having spent many unproductive years working on it.
 
Many residents expressed their deep concerns about the relentless growth of new housing in Cranleigh, particularly as Waverley Borough Council has simply not dealt with Cranleigh’s serious infrastructure problems first.
 

At the end of the meeting, local residents took a vote of “NO CONFIDENCE” in the Leadership of Waverley Borough Council.

The results of the vote were:

 
226 FOR
1 AGAINST
2 ABSTENTIONS
Here’s a link to a short video giving you a flavour of the meeting:

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SAFETY FEARS FOR CRANLEIGH BRIDGE CONTINUE

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Since our posting on 30th January 2016 we have been regularly monitoring the movement of the bridge over the Downs Link on Elmbridge Road and liaising with Surrey County Council (SCC).

Elmbridge Bridge Repairs 29-04-16

On 2nd March, Adrian Clarke (Chartered Builder and Committee Member of the Society) revisited the site as one of our members had alerted us to work being carried out. A sub-contractor acting for Surrey County Council was filling in the cracks with a weak mixture of sand and cement. Adrian noted that a crack not yet filled in had bulged more since his previous visit.

Adrian Clarke at Elmbridge

Filling cracks with a weak mortar mix is a waste of money – it was purely a cosmetic job to hide a very real problem.

It is our view that the bridge abutments should be renewed now whist the arch is still sound. If Surrey County Council delay this work until one of the abutments completely fails, then the structural arch will tilt and once this happens the whole bridge will have to be demolished and completely rebuilt. This would be both extremely expensive and disruptive to village life for a very long time.

In July, another Cranleigh Society member was studying a Surrey County Council document on Dunsfold Park and was startled to see reference to “Downs Link bridge (which is in need of structural work”. Obviously we drew the Council’s attention to this but they played down its significance.

On 2nd August there was a bridge collapse in Leicestershire – a bridge not dissimilar in design to the Downs Link bridge. This prompted us to research other bridge collapses and our findings were sent to Surrey County Council in the forlorn hope that these failures would spur them into taking our concerns more seriously.

At this point we decided to notify our MP, Anne Milton, of the matter and she is being kept informed of developments.

On 8th August we received an email from Surrey County Council which they hoped “would allay our fears” – it does not! They referred to:

  • The Council’s “scheduled and ad hoc visual inspections do not indicate there has been movement in the cracks that are visible from ground level” – we say get a ladder! Also, there is no mention of the walls bulging!
  • The “bridge was strengthened in 2006 ensuring the structure was capable of carrying a 40T full highway loading for single lane traffic” – we want to know why no weight limit has been imposed – also the traffic is controlled by lights and it is quite feasible for a breakdown on the far side of the bridge, or a slow cyclist, to bring a following mini convoy of 40T grab trucks to a halt! Also, nearby Hewitts has just been approved for development – even more HGVs!
  • “We do not currently have any concerns about the structural integrity of the bridge” – we say that this totally contradicts what Surrey County Council stated in the Dunsfold Park document!

Also in August the Infrastructure Delivery Plan (IDP) was published and this includes reference to the Downs Link bridge being rebuilt! We asked Surrey County Council to confirm this is correct but there was no response in their email of 16th November.

That email does refer to “seasonal movement of the wing wall foundations” which we find interesting. Structurally a bridge abutment is designed as a single composite component and if an abutment experiences cracking, then it is no longer acting as a single component – it is now two or more components and engineering performance is obviously compromised. This view is not accepted by Surrey County Council and they insist the bridge is safe – even though the Infrastructure Delivery Plan allows for it to be rebuilt!

Looking at all the photos again, we have noticed that the triangle of bricks within the crack looks different to the other bricks, perhaps suggesting that this section has failed before, was repaired and has failed again? We will investigate!

Elmbridge Bridge 23 Jan 2016

So this is where we are at right now but Cranleigh Civic Society will continue to monitor the bridge and do everything possible to ensure it is made “fit for purpose” for the traffic demands of the 21st century.

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Dunsfold Park Decision Called-in

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Dunsfold Park WA/2015/2395  was granted permission by Waverley’s Joint Planning Committee (JPC) on 14 December in a recorded vote  of 10 Councillors in favour and 8 against.

Before the application went to committee there had been several reports of the application being called-in to the Secretary of State by Anne Milton MP, and the 11 Parish Councils, which form the Joint Parishes.

Subsequently on Thursday 15 December it was confirmed that a planning inspector had in fact been appointed to carry out an inquiry into the granted application. The inspector will report their recommendation to the Secretary of State who will then make the final decision on Dunsfold Park.


Calling-in Process

This is where an application goes to The Secretary of State (SoS) for Communities and Local Government, Sajid Javid MP, for his final consideration and determination.

Applications are called-in where planning issues of more than local importance are involved. This can include applications which:

  • Are of national significance.
  • Conflict with government policy.
  • Impact on long-term economic growth.
  • Have significant effects beyond their immediate locality.
  • Are controversial.
  • Raise significant architectural and urban design issues.
  • Involve national security or foreign governments

Where an application is called in, a planning inspector is appointed to hold an inquiry into the application and the Secretary of State takes the findings of this inquiry into account when they make their final decision.


The Dunsfold Debate

On the night of the JPC meeting, Surrey County Council Highways Department and the Environment Agency maintained their objections to the application on traffic impact and water quality.

The debate lasted over four hours.  Points in favour of the application included the total number of dwellings, including 30% affordable housing, which would meet a significant percentage of the borough’s housing need, as well as significant employment opportunities being provided on site (Dunsfold is already one of the biggest employment sites in the borough), a new primary school and a local bus service funded in perpetuity.  Cllr Foryszewski said:

 “This is a development we can be proud of, that can be exemplary, built for the future, to address how we live and work.”

Cllr Cockburn, also spoke in favour of the application saying that:

“We have been saying for years, use brownfield sites first, especially in Farnham and Cranleigh.”

However, councillors also voiced concerns about traffic. It was pointed out that significant impacts on the surrounding highways had led to the dismissal of the previous planning Appeal in 2009.  Furthermore, the robustness of traffic modelling  was brought into question and was said to be “more of an art than a science” .  The extent of objectors and the evidence they had submitted, including a professional transport study, should, it was noted, be taken seriously.  Although it was recognised that there would be considerable contributions from the applicants, amounting to a package of approximately £40M, which is proportionally far higher than those negotiated with other Cranleigh developers, the opportunity to deliver extensive road improvements, due to the limiting characteristics of the A281,  was questioned.

Cranleigh Civic Society would stress that we feel that these same characteristics should apply to the over 1,500 dwellings being proposed for our village too.

Cllr Mulliner (Haslemere East and Grayswood Ward) pointed out that this was the most significant site in Waverley and highly contentious,  having had over 5,000 objections submitted against it. He disagreed with officers on the point of prematurity with regard to the Local Plan, which he pointed out was at an advanced stage, having been agreed by full council two weeks previously, and was being submitted for examination by the inspector two days later on 16 December 2016 (the Local plan has 3,500 objections against it).

Dunsfold Park is listed as a Strategic Site in the Local Plan with a total of 2,600 dwellings proposed for the site.  Cllr  Mulliner expressed his concern that the application should not be determined until the Inspector had rigorously examined the Local Plan and agreed that the Dunsfold site should be included. Otherwise, he said, this could be predetermining the scale, position and phasing of 25% of Waverley’s entire housing allocation.  He went on to state that this was “clearest possible case of predetermination and pre-emption of the Inspector’s role”.

The Objectively Assessed Need (OAN) figure of 519 dwellings per year for the Waverley borough was also commented on.  This figure has already been challenged by the Neil MacDonald Report (September 2016).  The report concluded that the OAN figure should be reduced by approximately 120 dwellings per year. Over the lifetime of the local plan this could equate to a total decrease of 2,280 dwellings.

The MacDonald  concludes that:

The key issue emerging from this report is the significantly different picture painted by the most recent projections and population statistics from that set out in the SHMA. Whilst the SHMA suggests that the full objectively assessed need for housing in Waverley is 519 homes a year 2013-33, the analysis in this report indicates that an up to date estimate would lie in the range 400 +/- 30 homes a year.”

( SHMA = Strategic Housing Market Assessment.  The last assessment was carried out in September 2015 by GL Hearn and set the annual housing need for Waverley at 519 dwellings – see page 117)

GL Hearn, authors of the SHMA, in their response to the MacDonald report in November 2016  accepted the main point of the report.

5.13 In conclusion we recognise that if repeating this work today a different figure is likely to emerge, particularly as we would have a different starting point. This reflects the availability of data. However our approach is one that reflects the NPPF and PPG and remains a sound basis for planning.”

We now await the Inspector’s report to the SoS, which may take a couple of months to be issued.


You can watch the full Waverley meeting from 14 December 2016 here on YouTube.

 

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Cranleigh Society Local Plan Response

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

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

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

Spatial Vision 3.2 Vision for Waverley in 2032

Policy ALH1: The Amount and Location of Housing

Policy SP2: Spatial Strategy

Policy NE2 Green and Blue Infrastructure

Policy ICS1: Infrastructure and Community Facilities

Policy ST1: Sustainable Transport

Policy CC4 Flood Risk Management

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

Policy SS4: Strategic Housing Site at Horsham Road, Cranleigh

Policy SS7 New Settlement at Dunsfold Aerodrome


Spatial Vision 3.2 Vision for Waverley in 2032

Our Comment:

We object to this point on the following grounds:

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

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


Policy ALH1: The Amount and Location of Housing

Our Comment:

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

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

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

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

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

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

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

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

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

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

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

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

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

Changes we suggest:

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


Policy SP2: Spatial Strategy

Our Comments:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Changes we suggest:

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


Policy NE2 Green and Blue Infrastructure

Our Comment:

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

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

Environmental Limits and Infrastructure Delivery:

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

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

Under WFD the overarching aims are to:

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

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

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

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

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

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

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

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

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

This content of this email was passed on to Waverley.

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

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

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

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

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

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

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

Cranleigh Waters Ephemeral and Eutrophic:

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

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

A local member of the angling society confirmed that:

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

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

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

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

Background Information:

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

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

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

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

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

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

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

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

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

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

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

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

Changes we suggest:

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


Policy ICS1: Infrastructure and Community Facilities

Our Comment:

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

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

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

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

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

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

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

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

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

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

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

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

Changes we suggest:

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


Policy ST1: Sustainable Transport

Our Comment:

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

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

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

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

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

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

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

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

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

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

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

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

Changes we suggest:

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


Policy CC4 Flood Risk Management

Our Comment:

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

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

With regard to groundwater the 2016 report also states that:

“2.2.4 Groundwater Flooding

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

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

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

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

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

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

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


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

Our Comment:

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

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

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

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

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

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

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

Changes we suggest:

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


Policy SS4: Strategic Housing Site at Horsham Road, Cranleigh

Our Comment:

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

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

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

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

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

Changes we suggest:

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


Policy SS7 New Settlement at Dunsfold Aerodrome

Our Comment:

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

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

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

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

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

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


Changes we suggest:

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

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Important News Update from Cranleigh Society

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Cranleigh Parish Council Drop-in Session

Have organised a drop-in session on Thursday 15 September 6pm – 9pm at the Village Hall.  All residents are invited to discuss Waverley’s Local Plan with your Parish Councillors.

This is a very important opportunity.  The Local Plan will have a significant impact on where you live.  You have until 3 October 2016 at 17:00 to get any you have comments to Waverley, after that the plan will be sent to a Government Planning Inspector for examination.

Don’t miss out on this opportunity to find out how this will affect you.

Representatives of Waverley Borough Council were invited to the meeting but unfortunately are unable to attend.

Read more about what a Local Plan contains on the CPRE website

This should not be confused with Cranleigh’s Neighbourhood Plan which is a completely separate process and must comply with policies outlined in the Local Plan.


Crest Nicholson Site, Horsham Road

We are currently looking over a new site layout submitted by Crest Nicholson after their application for detailed planning was deferred.

Residents are very disappointed that their major concerns about the layout of the site have still not been taken on board by Crest Nicholson.

This is due to come back before the Joint Planning Committee very soon.


Cala Homes, Amlets Lane

The application for detailed planning comes before the Joint Planning Committee this Wednesday 14 September 2016, 7pm at the Council Offices in Godalming.  Public are welcome.

We have been busy looking at new information lodged against this application.

Access has not yet been agreed for this site. We carried out a traffic survey of Amlets Lane on 12 Sept to compare our figures to those of the developer’s original transport assessment.


The Gate House

We have submitted new flood evidence to the Planning Inspectorate for the Appeal to demolish the Gate House in Knowle Lane and replace it with a substantial block of flats.

knowle-lane-gatehouse-new-flats-street-scene

Windy Way, The Common

We have submitted an objection to Waverley Borough Council against the demolition of Windy Way, a bungalow in the Conservation Area on Cranleigh Common and the building of a block of 6 flats (over 13m high) and two semi detached dwellings on the site.

This development will have a harmful impact on the new Cranleigh Conservation Area.

Existing Bungalow

windy-way-bungalow-front-elevation

Replacement Block flats and Houses

Flats Side elevation (over 13m in height):

windy-way-flats

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

windy-way-semi-detached

Position on plot:

windy-way-block-plan

Please get in touch with your views and comments.

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Waverley Plan to Destroy Cranleigh

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OUT NOW – WAVERLEY BOROUGH COUNCIL CONSULTATION ON THE PRE-SUBMISSION LOCAL PLAN PART 1: STRATEGIC POLICIES AND SITES

The Pre-Submission Local Plan Part 1: Strategic Policies and Sites setting out the planning strategy for Waverley up to 2032 was published on 19 August 2016.

This shocking plan proposes 1,520 new houses in Cranleigh with an additional 2,600 on Dunsfold Aerodrome, and a further 335 in surrounding villages.

Waverley Borough Housing Allocation June 2016

That’s a total of 4,455 houses in and around Cranleigh.

Please make sure that you add any comments you have about this plan before 5.00pm on Monday 3 October 2016.


After the October deadline, Waverley Borough Council wants to submit the Local Plan Part 1: Strategic Policies and Sites and associated documents to the Secretary of State for Communities and Local Government later this year, for examination, any comments you submit will be included.


REMEMBER NO COMMENT MEANS SILENT CONSENT


We believe the Local Plan is fatally flawed.

We do not think that dumping 45% of the total housing allocation in Cranleigh, where there is no identified need for this level of housing is sound.

We do not think that the transport assessment has looked at the impact this will have on our local roads, or taken into account safety for road users.

We do not think that the impact on our rivers, streams, biodiversity and air quality has been adequately taken into account.

We do not think that the community engagement with residents on this plan stands up to scrutiny.  The consultation was limited to a 4 housing scenario proposal in September 2014, which only had 4,265 responses (taken as a percentage of Waverley residents this would be 3.5%).  How many respondents were actual residents of Waverley is unknown as well as their location in the borough.

The Cranleigh Society will be submitting a comprehensive response to the Local Plan.

However, please also submit your comments about the plan.  We cannot stress enough how important it is for you to have your say.

This plan hugely affects Cranleigh, the consequences of the unprecedented growth in housing over the plan period will make way for Cranleigh New Town.

If you say nothing this will be taken as implied consent to the dumping of 4,455 new houses, equivalent to another settlement the size of Cranleigh, on your doorstep.


Add your Comments

You can add your comments to the Local Plan in the following ways: –

  1.  Online Consultation Website:

You can view the documents and comment online, via the Waverley Borough Council website at http://consult.waverley.gov.uk .  To submit comments, you must first register on the website. If you have done so already, then you can use your existing username and password.

  1.   Download a Representation Form:

You can also download the local plan document and representation form by visiting http://www.waverley.gov.uk/newlocalplan and following the link to the Local Plan consultation. This can be filled in electronically and emailed back to Waverley Borough Council at planningpolicy@waverley.gov.uk. You can also print the form and send it back to Waverley at; Planning Policy Team, Planning Services, Waverley Borough Council, The Burys, Godalming. GU7 1HR.

  1.  View the documents and collect a paper copy of the representation form

The Waverley Borough Pre-Submission Local Plan Part 1, the Sustainability Appraisal Report and other associated submission documents are available for inspection at the following locations, where you can also collect paper copies of the representation form:

  • Planning Reception, Council Offices, The Burys, Godalming, Surrey, GU7 1HR. Monday-Thursday 9.00 am -5.00 pm, Friday 9.00 am – 4.00 pm. (Excluding Bank Holidays)
  • Farnham Locality Office, South Street, Farnham, Surrey, GU9 7RN. Monday-Thursday 9am-5pm, Friday 9am-4.30pm (closed each day 12.30pm to 1.30pm) (Excluding Bank Holidays)
  • Godalming, Farnham, Haslemere, Cranleigh and Bramley libraries. Please see www.surreycc.gov.uk/libraries   for their opening times.

ADD YOUR COMMENTS BEFORE 5.00pm on Monday 3 October 2016.

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Residents Demonstrate Against Waverley Local Plan

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Last night around 100 residents from the borough’s Eastern Villages came together to voice their anger and frustration with Waverley Borough Council’s Local Plan which dumps over 4,500 new houses in this area, amounting to 45% of the total housing allocation for the entire borough.

Waverley Borough Housing Allocation June 2016

Councillors ran the gauntlet of protesters with placards outside the Godalming offices chanting “The Local Plan is rubbish, shame on you!”

Most protesters cited inadequate infrastructure, together with a complete lack of consultation with eastern villages, and a disregard for the quality of life for existing residents, as the main reasons for attending the event.

“We are sick of being ignored” said one attendee, “The improvements to the roads that are being suggested are a complete joke!”.

Councillors were called to a meeting of the Full Council to consider, a recommendation to put forward the draft Local Plan to a 6-week consultation stage.  Concerns were raised by several councillors about road infrastructure and highway safety, as well as questioning the inadequate improvement measures submitted by Surrey Highways, including those for the A281.  There was additional criticism about the complete lack of any impact study on the minor B roads which account for the majority of the road network in and around Cranleigh.

It was generally felt that a “lot more work” needed to be done on infrastructure. Several times it was stressed that the Local Plan was a “living document” that would be subject to change prior to being submitted for independent inspection.  We hope that this will be the case, as at the moment we do not have any confidence in the effectiveness of the extremely minimal road network improvements that are being put forward for Cranleigh, in addition to the lack of scrutiny regarding sewerage, water quality and air quality.

Cllr Mary Foryszewski pointed out that the consultation provided the forum for the local plan to be thoroughly inspected by everyone and that all responses would be taken into account.

Previously Cllr Foryszewski has pointed out that there has been a complete lack of consultation with Cranleigh Parish Council in selecting the  strategic sites contained in the Local Plan for Cranleigh.

Placating comments that “this [development] will not happen overnight” are not supported by the fact that development is heavily weighted towards the first five years of the plan, when it is forecast that 5,000 new homes, out of the total 9,861,  will be delivered in Waverley.

There was also a shock revelation that this figure could increase to over 12,000 if Woking cannot meet their housing allocation numbers and it could then fall to adjoining boroughs to absorb the shortfall.

The Leader of the Council, Julia Potts mentioned that Waverley was a unique borough with large areas of green belt and AONB (Area of Outstanding Natural Beauty)  providing protection for most of the borough with the exception of the East and West.  She expressed sympathy towards Cranleigh and Farnham that were taking the bulk of development, but basically said there was no where else to put the housing.  This could be seen to contradict her previous statement on 2 Oct 2015 –  “The most important thing is that any new homes are built in the right places and that the council works with Waverley residents to ensure it has the right strategy in place to meet our community’s needs over the coming years.”

We cannot understand why our council, faced with the borough’s considerable environmental constraints, have not challenged the number of 519 houses per year, allocated to the borough in the Strategic Housing Market Assessment (SHMA).

The SHMA document produced by a the company GL Hearn uses a commercially sensitive calculation method to project the number and type of dwellings needed across an area.  This calculation is not published and is not subject to any independent analysis.  It is extremely difficult to challenge a number when you have no idea how is was arrived at!

We welcomed Julia Potts invitation for interested groups to get involved with the consultation process and we will be taking her up on this offer.


 

HOW CAN YOU GET INVOLVED?

YOU MUST REGISTER TO TAKE PART IN THE CONSULTATION

The consultation is not “live” yet but if  you register you will be kept informed of the process and will have six weeks to make your comments.

When the consultation period starts, anyone wishing to make a representation on the draft Local Plan can either:

·    Log onto the consultation portal.

·    Email planningpolicy@waverley.gov.uk.

·    Write to: Planning Policy, Waverley Borough Council, The Burys, Godalming, GU7 1 HR.

We cannot stress to you the importance of being involved.  Every comment will be sent to the Inspector for consideration this is not a case of Waverley picking and choosing the ones that they want.  We have made some observations so far on some of the areas included in the Local Plan in our article about the residents’ demonstration and will be adding to this over the next couple of weeks.

If you have any queries or concerns just get in touch.

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