Members of Cranleigh Civic Society met with representatives of the Environment Agency (EA) and Thames Water on Friday 16 December 2016 at Thames Water’s offices in Shalford. Surrey Wildlife Trust (SWT) and Waverley Borough Council were invited but were unable to attend on the day. However, Waverley have confirmed that they will be inviting all parties to a meeting in the New Year.
It was a productive meeting, with all parties keen to explore pollution issues in Cranleigh Waters and opportunities to improve the failing status of the river.
All attendees stressed the importance of the next stage of Waverley’s water cycle study and the news that Amec Group Ltd had been appointed to carry this out was welcomed. This study is required as evidence for housing allocations in the Local Plan. Although a water cycle scoping report was produced by Capita (August 2016), it was recognised that the far more detailed stage two of the report was required to identify constraints regarding specific water supply and wastewater discharge, together with identifying upgrades required to the network and the accompanying timeline; taking into account costs, funding and available technology.
The EA confirmed that they had found Waverley’s Local Plan “unsound” based on the evidence presented to date.
Thames Water advised us that the trials to reduce phosphate levels in sewage effluent, should be available in Summer 2017. It is not known yet whether the results of these trials are encouraging, or cost effective. The situation remains that at present it is “technically infeasible” to reduce phosphate levels in discharged effluent to those required by the Water Framework Directive (WFD).
Cranleigh Civic Society is continuing its work with the EA and SWT on Cranleigh Waters with our Volunteer River Wardens. We are currently requesting permission from landowners to access a longer stretch of the river so that we can carry out invertebrate studies and identify areas for possible restoration work, as well as the reason for continued low flow rates.
It was generally recognised that recent dredging work had severely impacted on flow rates and the ability of the river to maintain aquatic life.
Thames Water maintain that current expansion work at Elmbridge sewage treatment plant is to improve current resilience and not to accommodate growth. They advised us that the plant would need to be expanded to deal with sewage from the significant housing estates granted in and around Cranleigh. This would undoubtedly have a further impact on water quality. However, it was not clear whether this upgrade work would involve a full planning application and Thames Water would not commit to carrying out an Odour Impact Assessment.
We stressed the need for this impact study in order to make sure that residents’ quality of life was not further impacted by odour nuisance. Thames Water confirmed that complaints about odour from the sewage treatment works (SWT) had increased but they maintained that it was not clear that this corresponded to an increase in odour from the plant, or was due to the Cranleigh Society highlighting to residents that they could complain. We would stress to residents that they should continue to report any odours from the STW in order that Thames Water have more accurate records.
Please continue to report odour nuisance to Thames Water email email@example.com or 24-hour customer service team on 0800 316 9800 and to Waverley Borough Council Environmental Health on 01483 523393.
Finally we discussed issues surrounding water supply and the recent spate of burst water mains. This will be discussed further at our next meeting.
In addition to the meeting in the New Year with Waverley, Thames Water is also helpfully arranging further meetings with their drainage and water supply departments.
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.
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.
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)
“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.
If you are planning to attend the meeting we would suggest you arrive at least an hour before, as there is bound to be considerable interest in this development.
The application includes 1,800 residential dwellings, in addition to 7,500sqm care accommodation; a local centre to comprise retail, financial and professional, cafes/restaurant/takeaway and/or public house up to a total of 2,150sqm; new business uses including offices, and research and development industry up to a maximum of 3,700sqm; light and general industry up to a maximum of 7,500sqm; storage and distribution up to a maximum of 11,000sqm; a further 9,966sqm of flexible commercial space; non-residential institutions including health centre, relocation of existing Jigsaw School into new premises and provision of new community centre up to a maximum of 9,750sqm and a two-form entry Primary School.
The application also includes a new sewage treatment plant. We have continued to raise concerns about water quality and the discharge point of liquid sewage effluent (by-product of the treatment process) from the site.
The Environment Agency in a letter to Waverley Borough Council on 6 December 2016 have objected to the application, stating that:
“In accordance with paragraph 109 of the National Planning Policy Framework (NPPF) and the associated National Planning Practice Guidance (NPPG) we object to the proposed development as submitted for the reasons outlined below and on the basis that it may have a significant adverse impact on water quality.”
The current proposal now appears to favour discharging into Loxwood Stream (sometimes referred to as the River Lox). The previous proposal had included the use of the Wey & Arun Canal but this has now been ruled out as unsuitable. A new report published against the planning application “Risk assessment for treated sewage disposal” Ref: 65550TN1D1 and dated November 2016 states that:
“Indeed, for the purposes of this assessment, Loxwood Stream has been taken forward as the potential receiving watercourse. This is based on the fact that the pro rata calculation to estimate flow at the point of discharge would seem to be more reliable than that undertaken for Cranleigh Water, where the influence of sewage treatment effluent downstream of the proposed Dunsfold Park outfall makes any pro rata calculation potentially unreliable without benefit of more detailed flow data.”
Cranleigh Civic Society is now a member of the Cranleigh Waters Partnership, along with Thames Water, the Environment Agency and Surrey Wildlife Trust. Our next meeting takes place on 15 December 2016.
Permission has already been GRANTED for nearly 800 new houses in Cranleigh and the following pending applications will also be sending their sewage to be treated in Cranleigh and will discharge sewage effluent into Cranleigh Waters:
WA/2016/2207 Knowle Park Initiative (West Cranleigh Nurseries) – now in name of A2Dominion Developments Limited- Alfold Road, 265 dwellings
WA/2015/1381 Springbok Estate, Alfold 480 dwellings and primary school (at Appeal)
The Appeal against the decision by Waverley Borough Council to refuse permission for an application WA/2015/2006 to demolish The Gate House, Knowle Lane, Cranleigh GU6 8RD and replace with 8 dwellings has been dismissed!
The Inspector was particularly concerned about whether the proposal would result in material harm to the living conditions of neighbouring occupiers, mainly Magnolia Cottage, Knowle Lane, with particular regard to outlook and visual impact, daylight and overlooking. He also concluded that it was not in keeping with the local character. We welcome his decision.
You can view a full copy of the Appeal decision here.
The Inspector’s conclusion was:
“45. Although I have found that there would be no material harm caused to employment land supply, heritage assets, parking and highway safety and flooding, the harm that I have found to character and appearance and to living conditions is significant, and is sufficient for me to find that the proposal conflicts with the development plan as a whole. Thus, for the reasons given above, I conclude that the appeal should be dismissed.”
You can read more about the application here in our article:
Despite ongoing complaints of sewage odour from residents living near to Elmbridge Road Sewage Treatment Works, work has commenced on two additional 30m diameter open-air filtration beds.
Members of Cranleigh Civic Society are extremely disappointed that Surrey County Council has maintained its position that planning permission is not required for the expansion work, despite evidence of ongoing odour nuisance and serious pollution issues in Cranleigh Waters – the river the sewage works discharges into.
For some time residents living near to the sewage treatment works have been emailing us about the effect of sewage odour on their homes. Residents report being unable to use their gardens because of the overwhelming smell of sewage and of distressing fly infestations. Although we asked Thames Water to carry out an odour impact assessment, nothing appeared to be forthcoming, so we arranged for an odour survey on behalf of residents living within an 800m radius of the sewage works, in accordance with Thames Water’s “Odour Zone” criteria. The results were sent to Waverley Borough Council and Surrey County Council.
The reason for the expansion work has not been firmly established, however, Thames Water recently informed us that this 30% expansion is in readiness for the new housing estates being planned for Cranleigh and surrounding villages, as unfortunately most of the untreated sewage is headed this way. However, other residents have reported a very different story from Thames Water, who have advised them that the work is simply to upgrade the system to accommodate current users. Cranleigh Civic Society is meeting with representatives from Thames Water on 16 December 2016, as part of Cranleigh Waters Partnership and this is one of the queries we will be taking up with them. The Environment Agency and Surrey Wildlife Trust will also be attending.
Cranleigh Civic Society discovered that the sewage treatment plant expansion work was being carried out without planning permission back in October, this means that the effect on residents of any additional odour originating from these extra filtration beds is not being taken into account.
We believe that Surrey County Council should have undertaken an Environmental Impact Assessment to investigate not only odour but also pollution issues in Cranleigh Waters from additional liquid sewage effluent. On 29-Sep-16 we challenged the council to this effect and their response was to undertake a scoping report, subsequently issued on 11-Oct-16, which concluded that Thames Water did notneed to get planning permission as the works came under what is called “Permitted Development”.
On behalf of residents, we have studied relevant Government legislation and we disagree, and have outlined our reasons to Surrey County Council and to Anne Milton MP. However, Surrey are regrettably sticking to their original decision.
We have also sought the assistance of Waverley Environmental Health and on 7-Nov-16 wrote to them asking for an Abatement Notice to stop works on site until a full Environmental Impact Assessment was done. We also sent them a copy of the Society’s July Odour Survey that residents took part in.
In a telephone call on 23-Nov-16, Environmental Health told us, that after consulting with the Waverley Planning Department, they would not be taking our survey results into account as it was carried out by a pressure group, instead going forward they would be asking affected residents to fill in a diary of days on which they experience odour nuisance. This appears to ignore any previous history of odour problems whilst the sewage works expansion progresses unchecked.
We think that residents’ prior complaints should be taken into account.
If you have been affected by odour nuisance from the sewage works, are worried about the risk of increasing odour arising from the current expansion, and you think that the impact on your home should be considered, please write to, or email, your MP Anne Milton. Please always include your FULL name and address with any correspondence.
Please copy Cranleigh Civic Society in on your email/letter, if possible, prior to our next meeting with Thames Water on 16-Dec-16, where we will be discussing this matter, as well as concerns about ongoing and increasing pollution of Cranleigh Waters.