On Monday the 24th of July, Anne Milton MP organised a meeting at the village hall that she described as a flood forum and it turned out to be much more than that. She brought together Waverley planners, Thames Water, the Environment Agency, the Drinking Water Inspectorate, Public Health England, Surrey County Council, the National Flood Forum, Cranleigh Parish Council and Cranleigh Civic Society to discuss openly several of the major concerns Cranleigh’s residents have raised with her. 65 members of the public came along and several parish and borough councillors also attended.
The plan was to address these concerns and direct them specifically to the authority responsible, so that the answers could be heard by all. We were very happy to hear sewerage problems, flooding and asbestos cement water pipes all discussed openly. It was always understood that the problems would not be resolved then and there but that efforts could be made to address them in the coming weeks and months.
To aid this, small sub committees were formed to work on specific areas and they will report back at the next meeting planned for the autumn. It was just the beginning of what will be a long term effort but a positive step and one that Cranleigh Civic Society welcomes. Members of the Society volunteered to join sub committees and share the information they have collected specific to each area so we will be close to the decision making process.
As you will be aware we have had major concerns about our ageing and deteriorating asbestos cement drinking water pipes for some time now. Due to the age of previous significant development in Cranleigh in the 60’s, we suspected that they may contain crocidolite (blue asbestos), in addition to chrysotile (white asbestos). Although Thames Water assured us that the pipes were constructed from white asbestos, our own research did not reflect this, and we have been pushing for testing to be carried out.
Over the past two weeks we were successful in getting Thames Water to send a section of drinking water pipe, being replaced in the Hitherwood area, for independent testing to confirm the presence of blue asbestos (crocidolite). This has now been confirmed.
The presence of crocidolite (blue asbestos) is not the result we were hoping for, but it is in line with the guidance given on the Health and Safety Executive’s (HSE) website under the Asbestos section. HSE state that asbestos cement pipes made prior to 1969 are likely to contain crocidolite.
A further section of pipe from the Summerlands area has been tested and this has been shown to contain only white asbestos. We have asked also requested details from Thames Water of the percentage of blue to white asbestos, and to assess how much deterioration has taken place in the pipes. Furthermore, we have requested that a section of pipe be tested from the Park Mead area, although we have been told that this will not be carried out until there is a burst pipe there. We will be challenging Thames water on this.
Blue and white asbestos have very different risks associated with them, with the crocidolite being considered more hazardous. We should stress that the majority of evidenced high risks are associated with inhaling asbestos fibres, however, there does appear to be a growing evidence base worldwide that suggests that there is also a risk associated with ingested fibres.
Recently Australia and New Zealand have announced replacement programmes for their asbestos cement pipes, and in the USA they already test drinking water for asbestos fibres, and have set maximum guidelines, testing is NOT carried out in the UK.
We have been asking the authorities, including the Drinking Water Inspectorate (DWI) and the Health and Safety Executive (HSE), since September 2016 to assess the risk to Cranleigh residents from a high percentage of ageing and deteriorating asbestos cement drinking water pipes without success. Asbestos cement pipes have a 50-70 year design life and some of these in Cranleigh are approaching 70 years old. The issue also affects residents in Dunsfold, Ewhurst and Alfold, we have not looked into any of the other surrounding areas. In a recent planning application in Waverley for development in Alfold, once again the Society advised Waverley of the existence of blue asbestos in the drinking water network, once again we were ignored.
We have questioned the position of the DWI. Whilst their blanket statement broadly states that there is no consistent evidence to suggest that asbestos is dangerous when ingested, we have studied their database of evidence and that of other qualified evidence available and we are of the opinion that the DWI, and the World Health Organisation (WHO), have based their studies in the main on chrysotile (white asbestos). Furthermore, many of the reports back in the 1970s and 1980s were sponsored by the asbestos industry, and in particular by the Chrysotile Institute, and they should be treated with some caution, as well as being based mainly on the effects of chrysotile.
In January 2017, in discussion with HSE, Cranleigh Civic Society circulated our own Risk Assessment under the Health and Safety Act looking at data from contemporary research carried out over the last few years, some of it by highly respected organisations such as the American Journal of Toxicology and Environmental Health (a leading publication respected around the world). Our increasing concerns surrounding crocidolite remain, because of its needle-like structure, it has the potential to penetrate membranes in the body more easily than the more curly fibres of white asbestos.
Our research is continuing, and we have received this from a contact in New Zealand. It was put out by Radio New Zealand and is now on their website:
‘A $2.2 billion price tag has been put on the cost of replacing the country’s asbestos water supply pipelines.
Drinking water delivered through functioning asbestos pipes isn’t risky, but airborne particles from broken pipes can be dangerous.
Asbestos cement pipes were installed for local water supply networks from the 1950s to the 1970s, and manufacturers stopped producing them in the mid 1980’s. The pipes’ life expectancy is about 50 years so many will be due for replacement.
Functioning pipes being used for water do not pose a threat to health. The World Health Organisation has said swallowing asbestos present in water does not present the same cancer risk as inhaling dry particles. However, asbestos pipes that are cut or broken when dry can pose a health risk if particles are released into the air.
Water New Zealand estimated the total length of this country’s water supply pipelines at 36,436km, with the network valued at $8.7b. It estimated 9000km of those pipes were made of asbestos cement and that they would need to be replaced in the next 20 to 30 years.
With many of the pipes nearing the end of their useful life, Water New Zealand chief executive John Pfahlert said local councils would have to do careful planning to make the replacement affordable to ratepayers. There were a number of available options cheaper than digging them out, such as relining existing pipes or leaving decommissioned pipes in the ground and placing new pipes around them, he said. Wellington Water spokesperson Alex van Paassen said replacing asbestos cement pipes, as opposed to those made of other materials, did require safety precautions. However, he said, those precautions would not add a significant amount to the overall cost of replacement. Mr van Paassen said pipes in Wellington were prioritised for renewal based on how critical the need for repairs was, or how many households were served, and not on whether they were made of asbestos.
“Wellington Water had a regular pipe renewal schedule for all types of pipes”, he said.’
We have continued to keep our MP Anne Milton informed of our research and she has now arranged a meeting on 24th July in Cranleigh to investigate this further. Thames Water, the DWI and other relevant parties have confirmed their attendance. This is also following the petition sent to Anne Milton following our public meeting on 25th May. We are grateful to her for listening to our concerns and seizing this opportunity to seek answers.
Adrian Clarke of Cranleigh Civic Society and Cranleigh Borough Councillor Liz Townsend were interviewed by Surrey Radio this week about the severe pollution problems in the brook that flows out of a culvert behind Marks and Spencer’s car park. The brook problem is also featured on the front page of the current edition of the Surrey Advertiser (Friday 31 March 2017).
Residents have been complaining to Thames Water about raw sewage in the brook for 8 years, and in 2015 Cranleigh Civic Society took samples from the brook and got an independent laboratory to test them. The report, which showed very high levels of e coli, was sent to the Environment Agency who investigated it and immediately put it onto their ‘UK Priority Hot Spot List’.
Cranleigh Civic Society also tried unsuccessfully to get Waverley Borough Council’s Environmental Health Department to help to get this serious pollution issue resolved. We suspect that the reason why Waverley did not want to get involved is because it would jeopardise their hugely unpopular draft local plan. In case you didn’t know this, Waverley wants to dump 44% of its new housing allocation into the Cranleigh area. The same Waverley we all have to pay our very high Council Tax charges to.
Since the Environment Agency got involved, Thames Water has been carrying out tests, putting dyes in outflows and feeding cables with cameras from the culvert back towards the High Street, but with mixed results. Thames Water claims to have discovered several ‘misconnections’ over the last year, but they have been very secretive about the number and locations of these. Misconnections are where a house or a commercial property illegally connects its foul drainage to rainwater pipes either intentionally, or by mistake.
An engineer from Thames Water told us that, over the weekend of 1-2 April 2017, his team had identified eight commercial properties in the High Street that had misconnections; an amazing admission considering that Thames Water have had crews out investigating this problem now on several occasions over the last two years!
The cost of all these investigations so far is huge, the Thames Water engineer told us, and that, as it is unfair to burden their customers with this cost, Thames Water will be seeking to recover the cost from the commercial premises in the High Street.
We are hoping that Thames Water will now issue 21-day notices to the offending premises in the High Street to correct their problems. If the businesses ignore the 21 day notice, they can face large penalties.
Why is all this a problem? Children were seen last summer playing in the brook building a dam, and they often retrieve footballs from the brook when playing on the adjacent field, and people walk their dogs next to the brook (and dogs like to jump into water). Also, the brook joins Cranleigh Waters, a stream that is already heavily polluted and which has caused fish stocks to die out in Bramley.
We will keep you informed of any updates on this story.
It won’t have gone unnoticed to residents that both Crest Nicholson on the Horsham Road and Cala Homes on Amlets Lane have started developing their sites.
Both these sites had Grampian style conditions. This was meant to prevent the start of the development until off-site works were completed on the sewerage network, including the sewage treatment works on Elmbridge Road. However, we were recently advised by planning enforcement at Waverley that the Grampian Condition wording is too woolly to enforce and doesn’t specifically mention the words sewage “TREATMENT”, so no work to the sewage works are apparently included – another nail in the coffin for Cranleigh.
To say that we felt let down by the lack of rigour exercised in the planners’ wording of the Grampian and the lack of ability by Waverley to enforce it, is an understatement!
There is no consideration being given to existing residents, who after all fund the borough council, in the scramble to achieve a housing number at all costs. We don’t need to remind you, that you will have to bear the brunt of polluted rivers, congested roads, odour nuisance from the sewage works, an over burdened GP surgery, the list goes on.
The bungalow on the Horsham Road, which was acquired by Crest Nicholson to provide an access road to the site, was demolished long before their Grampian Condition was even discharged (such as it was), and work was also immediately commenced on the green fields to build 149 houses. Grampian, what Grampian?
“Cranleigh is a pretty Surrey village where one can enjoy a relaxed pace of life yet benefit from daily conveniences aplenty on the doorstep, including a selection of shops, cafes and restaurants.”
Sounds idyllic, and surprising how keen developers are to emphasise that we are a “village” in their marketing literature.
Despite the unsustainable location of Cranleigh, on a rural road network, with little public transport, a heavy reliance on the use of the private car, limited employment opportunities, water quality issues, a high percentage of asbestos cement drinking water pipes, an inadequate sewage treatment plant, and on green fields to boot, none of this matters, as long as the houses are built.
The ONLY reason for these dwellings is because we have NO GREEN BELT protection, nothing else, and national planning policy will be twisted at the whim of the planners to suit their ultimate plan for this area, which is CRANLEIGH TOWN.
However, before you start thinking, how bad can that be, it will be bad! We are the only community in Waverley without green belt protection AND any environmental designation. Farnham at least has the protection of Thames Basin Special Protection Area. So going forward, Cranleigh will be the dumping ground for any, and all, unmet housing in Waverley. However, Waverley Borough Council seem to be the winners, they have a convenient area, in the corner of the borough, which will be a cash cow for council tax, and with only 5 councillors (Farnham has 18) representing this area, and two of those with a declared pecuniary interest in development, this really does seem like a marvellous arrangement.
There is the rather inconvenient truth of Cranleigh Waters, which is polluted and failing in terms of the Water Framework Directive, but that can be smoothed over, by applying pressure to an overworked and under resourced Environment Agency (EA) with the promise of funds for river restoration and flood plain replacement projects.
There’s the problem of the rural roads and A281, but as Matthew Evans, Ex-Waverley Head Planner, said it really doesn’t matter if people are stuck in traffic. Obviously air quality issues and quality of life, for residents in this part of the borough, was not something that disturbed his sleep.
And then there’s the ageing asbestos cement drinking water pipes, which have an extremely inconvenient habit of bursting whenever water pressure increases, still, studies of health risks are inconclusive, so it appears Waverley don’t need to worry about that either. Despite the fact that we can find no reports that include the age of pipes we have here, or our particularly agressive type of water.
It would be difficult to imagine what would ever be considered as a material constraint by Waverley planners against development in Cranleigh, perhaps the discovery of uranium in the high street?
And to add insult to injury, the EA are now actively looking for replacement flood plain for this area, as let’s face it, they don’t want to create too much flooding downstream for Bramley and Guildford, residents there might start to wonder why the hell all this building was allowed, or should we say encouraged, on the natural flood plain we DID have.
However, we still have something up our sleeve and that’s you!
Joined together, you are the most powerful force. Stronger than Waverley and stronger than developers.
Working together in big enough numbers, people can, and will, make a difference. We can fight for fairness, we can fight for our community, and we can fight for our environment.
“Never doubt that a small group of thoughtful, committed citizens can change the world; indeed, it’s the only thing that ever has.”
The main summarised reasons outlined in the EA objection letter are that the Flood Risk Assessment does not demonstrate that the development will be safe from flood risk for its lifetime, and the potential impacts of climate change have not been satisfactorily taken into consideration.
The Cranleigh Society has maintained serious concerns about the flood risk on this site, which is part of Cranleigh’s rapidly diminshing natural flood plain.
We are extremely glad that the EA have carried out a thorough study of the FRA and echoed many of the points that we raised in our letter against this application:
Although there is a presumption in favour of sustainable development however NPPF para 14 states that even if the development plan is absent, silent or relevant policies are out of date, permission should not be granted where specific Framework policies indicate it should be restricted, this includes flooding.
We also object on the grounds that the assessment of flood risk informing the measures proposed by the FRA to avoid, manage and mitigate flood risk, are incomplete and have not been appropriately secured for the lifetime of the development. There also does not appear to be provision for increased climate change allowances agreed by the Environment Agency and the Government, published in February 2016. These now require applicants and developers to assess a range of climate range allowances from 25% to 70% above the 1% AEP as part of planning applications. As the application appears to have been submitted to Waverley in November 2016 the new allowances and ranges should be used.
Document 9.0 WATER RESOURCES AND FLOOD RISK point 9.28 fails to mention the significant flooding on Alfold Road in 2013/14 or the flooding on Elmbridge Road. the Our own FRA review by RAB consultants (Bedford) acknowledges that the recent flooding of December 2013 on the Cranleigh Waters and Littlemead Brook has not been recognised within the flood risk assessment (FRA) dated October 2014. They go on to say that the extreme nature of the flood in December 2013 warrants recognition within the FRA and an assessment of flood depths and extents at the site if possible. Additionally, given the nature of flooding in December 2013 and the significant groundwater flooding experience across many parts of the Thames Catchment throughout winter 2014, it would be prudent to include this within the assessment of groundwater risk to the site.
Water Environment Ltd October 2016 appears to be missing Appendices B, C and D. Previously Appendix B of the FRA shows that EA “Product 4” flood data, received 29 July 2014, was used for the assessment. The EA have updated their flood modelling in the area since this data was obtained. The data used in the FRA has therefore been superseded. Without incorporating all this data we do not believe an appropriate nor up-to-date assessment of flood risk has been undertaken.
Furthermore, evidence exists and data has been collated of the recorded flooding in the vicinity of this development during 2013/14. This has been submitted in support of a planning application ref WA/2014/0912 by Berkeley Strategic Land Ltd in Appendix 1 from “Technical Review of Flood Risk Assessment (FRA) for the construction of 425 dwellings on land south of Cranleigh, Surrey” dated August 2014. The FRA should take this evidence into account.
Paragraph 040 of the Planning Practice Guidance (PPG) states: “To demonstrate to the satisfaction of the local planning authority that the development will be safe for its lifetime taking account of the vulnerability of its users, a site-specific flood risk assessment may need to show that appropriate evacuation and flood response procedures are in place to manage the residual risk associated with an extreme flood event. Proposals that are likely to increase the number of people living or working in areas of flood risk require particularly careful consideration, as they could increase the scale of any evacuation required. To mitigate this impact it is especially important to look at ways in which the development could help to reduce the overall consequences of flooding in the locality … through off-site works that benefit the area more generally.”
This proposal would significantly increase the number of people living in an area affected by very recent flooding and would increase the scale of any emergency evacuation considerably. The FRA has not considered how this additional burden will be managed in the extreme flood event and has not suggested any off-site mitigations to reduce the overall consequence of flooding in the locality. We therefore object on the grounds that the additional burden on the emergency services in a flood event has not been given due consideration in the FRA.
A further objection is that the FRA fails to prove that the voluntary and free movement of people during a ‘design flood’ can be demonstrated. Assessments of the adjacent Berkeley Homes WA/2014/0912 application site have shown that dry access/escape routes from the site across green fields are unsustainable in flood risk terms. The FRA addendum (9 June 2015) for this site previously proposed an approximate 5km pedestrian diversion along unlit and unmade footpaths and public highways without footpaths. This does not provide a safe nor appropriate route for people, especially for more vulnerable residents.
Evidence to support this is outlined in Appendix 1 of “Technical Review of Flood Risk Assessment (FRA) submitted by Berkeley Strategic Land Ltd WA/2014/0912 which demonstrates that every access route away from this adjacent development, using the Alfold Road, will be inaccessible by foot or car in a flood event like the one that occurred during 2013/14.
NPPF places significance with respect to land in the “Functional Floodplain” or Flood Zone 3b. Figure 4.3 of Volume 3: Mapping of the WBC SFRA identified areas of Functional Floodplain within the borough. This figure shows parts of the development site are likely to be within the Functional Floodplain.
The extent of the Functional Floodplain is normally defined by the extent of flooding in the undefended 1 in 20 year (5% annual probability) event and the EA flood data indicates that parts of the site lie within the 1 in 20 year (5% annual probability) flood extent. As the FRA has not delineated the extent of the Functional Floodplain at the site, we do not believe an appropriate nor up-to-date assessment of flood risk has been undertaken and object on these additional grounds.
The NPPF makes it very clear that the aim of the sequential test is to steer new development to areas with the lowest probability of flooding. The Sequential Test provided by the applicant does not provide satisfactory justification as to why other suitable sites have been discounted. We object on the grounds that the site fails the Sequential Test and the Exception Test cannot therefore be applied. There is a site a far less risk of flooding for 120 dwellings currently at Appeal, the result of which will be available on 9 January 2017. The council currently has a five-year housing supply and does not require housing on green fields at risk of flooding, on a flood plain, which will increase flooding elsewhere.
We also have concerns about the ability of new residents moving into the site to obtain meaningful flood risk insurance at an acceptable cost since the Association of British Insurers has stated that New Houses built after 1 January 2009 will not be covered by Flood Re; this is to avoid incentivising unwise building in flood risk areas.
The assessment of flood risk needs to demonstrate that the flood risks posed by the development can be managed, ae realistic, taking into account current climate change allowances, and are safe, the FRA fails to do this.”