Our last Flood Forum update posted here on 18 March was based on an article The Cranleigh Society were asked to provide by the Surrey Advertiser – but it was not published.
The Society was then asked to expand on other real problems being faced by Cranleigh; we obliged by sending the content for a second article and that, also, was not published.
Both articles were 100% factual, so we can only conclude that the Surrey Advertiser did not wish to be controversial.
Pressure can still be put on Waverley…
As mentioned in the website posting on 18 March, AC drinking water pipes and the Thakeham site were the main concerns expressed at the Flood Forum but the bigger picture also needs to be considered. There is a general concern for the number of sites where there are flood issues and/or an over reliance on Sustainable Drainage Systems (SuDS).
More and more Cranleigh residents are complaining about the ever increasing numbers of grab trucks and other contractor’s vehicles thundering through the High Street. These are causing havoc in the B-roads and narrow lanes, and it is going to get immeasurably worse as the building work intensifies.
These heavy vehicles are causing new potholes to appear daily in the High Street, and cars are being forced up on to paths to avoid wheel and tyre damage.
But Waverley and Surrey County Council do not care.
There are other major problems as well:
- Waverley has pushed 48% of all the new housing in the Local Plan on to sites in and around Cranleigh
- In doing so, they have ignored infrastructure issues.
The Society accepts there is nothing that can be done about the first point. Those planning applications have all received permission, but pressure can still be put on Waverley as regards the infrastructure issues where Cranleigh Civic Society believe Waverley are vulnerable. These are:
1. Flood risk.
2. Asbestos cement pipes.
3. Cranleigh Waters pollution.
Of course, everyone is concerned about roads and bridges too, but these are the responsibility of Surrey County Council, not Waverley.
Naturally prone to flooding…
There is an interesting story emerging about flood risk to which there appears to be no solution, solely because of the actions of Waverley and the inaction of the Environment Agency.
This whole sorry saga began in November 2015 when the owner of the Knowle Park Initiative site dredged a section of Cranleigh Waters, not realising that they needed a permit to do so from the Environment Agency which, incidentally would have been refused.
On site, their contractor told the Society that this was done to “move the flood risk downstream”. The effect of this dredging was to move the flood risk from the KPI site to the area just before the bridge at Elmbridge Road, which at the time was fine as it was just meadowland. The problem is that Thakeham Homes bought the site and, on 5 October 2017, they were granted permission to build 54 houses on it.
KPI knew what would happen by doing this dredging, as it is on their website! They knew that the Thakeham site is “part of the functional flood plain of Cranleigh Waters and is naturally prone to flooding”.
They went on to state; “The main thing is to make sure the drainage and water courses are kept clear (a clear reference here to dredging) to allow these areas (the Thakeham site) to take the water quickly”.
The Thakeham site had serious flooding in December 2013, two years before the dredging – there is now the very real possibility of much higher flood levels, a matter that was totally ignored by Waverley when raised by Cranleigh Civic Society when the application was heard. The Society has a photo of the December 2013 flood level being higher than the site SuDS level, and we know from Met Office Data that they are predicting +30% rainfall during winter months up to 2080. So that is why the Thakeham site is liable to flood.
Reducing, not removing the flood risk…
On 16 March, the Society heard from Surrey Wildlife Trust that the bulk of the funding announced at Anne Milton’s 9th March village meeting is to be spent putting the KPI stretch of Cranleigh Waters back to a two stage river. People may well ask why KPI themselves are not required to bear the cost of the reinstatement to a two stage river – the answer is that the Environment Agency did not act within the time limit of six months from the date of the illegal act, even though Cranleigh Civic Society advised them in January 2016 and the EA visited the site on 29 March 2016. So it appears that public money is now going to be spent correcting the damage done by the KPI dredging!
Was there pressure being put on the Environment Agency to let the KPI planning application go through to help meet Government housing targets? It wasn’t until after the six months statute of limitations period that this all came to light, and the Environment Agency admitted their failure to act.
The problem is that if the KPI stretch of Cranleigh Waters is reinstated to two stage, it reduces (not removes) the flood risk at the Thakeham site and puts a flood risk back onto the KPI site.
What an awful mess – a mess that was totally avoidable if planning was considered on all the facts, good and bad, and not on just chasing housing numbers.
The Society envisages decades of flooding incidents, insurance problems and law suits.
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As an update to this previous article, we have now been informed that the Secretary of State has not agreed to call in this application.
So, sadly that’s another 265 houses approved to be built in an unsustainable location.
Original article follows:
Following the decision two weeks ago by Waverley Borough Council to approve the building of 265 houses on another of Cranleigh’s green fields, Cranleigh Civic Society has written to DCLG (Department for Communities and Local Government) to ask for the application to be ‘called in’. If accepted, this will lead to an inquiry being held by the Secretary of State.
Our reasons for requesting a call in are:
- Cranleigh’s Parish Councillor Liz Townsend was denied a vote for this application, in place of the late Brian Ellis.
- The vote was 8 for and 8 against, with the deciding vote given by a Hindhead councillor.
- There were four missing members of the JPC who could have given their vote to one of the Cranleigh councillors in their place, but chose not to elect substitutes.
- The Planning Officers were not acting impartially, but appeared to be in favour of the developers.
- This application had previously been rejected and was just resubmitted without significant changes, so why was this allowed?
- We have uncovered the existence of asbestos cement water pipes which could pose a serious risk to public health and if this is to be fixed 30% of Cranleigh’s drinking water pipes will need to be dug up. If not resolved the danger from asbestos will be exacerbated by the extra water pressure from new homes.
- Why have the developers not been questioned about the illegal dredging of Cranleigh Waters carried out by a contractor at their request?
- The KPI site fails the sequential test, as there are other sites better suited to development which do not flood. There will be no subsidised affordable flood insurance from Flood Re as, since 1 January 2009, new homes should not be built on high flood risk areas.
- This application was submitted at the same time as an appeal against the refusal of the previous application, which in itself is odd.
For these reasons we have serious and valid concerns about the granting of this application and hope that the Secretary of State will agree with us.
The nightmare has come true! Yet another 265 houses on green fields were voted in last night on the casting vote of the Waverley Joint Planning Committee’s Chairman Cllr Peter Isherwood.
So now Cranleigh has a deluge of 1,236 new houses (and that doesn’t include the infilling going on all around Cranleigh in back gardens everywhere, especially up the Horsham Road) of these houses 418 are meant to be affordable – whatever that really means.
We just want to put the enormity of the scale of this development into context, the Swallowhurst Estate was for 58 houses only!
This is now the masterplan (so far) for Cranleigh, showing the Berkeley’s, Little Meadow and now KPI sites (A2 Dominion) together:
The countryside to the left of the high street has now all but disappeared:
Cllr Mary Foryszewski was the only Cranleigh Councillor who could vote at last night’s meeting, as once again Cllrs Stewart and Jeanette Stennett declared a pecuniary interest in the KPI development, and Cllr Patricia Ellis was nowhere in sight. Cllr Foryszewski alone battled valiantly for Cranleigh, but all was in vain. Be very scared Cranleigh residents, Waverley has big plans for Cranleigh and they are not pretty.
It was also revealed last night that Waverley agreed a reduction in affordable housing on the KPI site in return for more money for the Elmbridge Road bridge (we can’t wait to see what actually happens there, as the estimated cost by Waverley is more akin to a fairy tale) and a sizeable contribution to a new Leisure Centre, proposed for the parish owned Snoxhall Fields, no doubt surrounded by a big car park. Never mind, Cranleigh doesn’t need free recreation space, not when it can have even more houses who will pay council tax to Waverley! However, it transpired that the Parish Council were not even given the courtesy of a consultation about this new Leisure Centre, the Cllrs we spoke to knew nothing about it, and are desperately trying to save this area for the community, by putting the land into a Trust, rather than see it consumed by Waverley.
Cllr Liz Townsend, who it seems has not been allowed to take up Cllr Brian Ellis’s vacant place on the planning committee, was allowed a speaking slot and conveyed how angry Cranleigh residents felt about the destruction of our village. She also pointed out how seriously under represented Cranleigh is on the planning committee and that our voices were not being heard.
Officers brushed Cllr Townsend’s concerns about flooding on the site under the carpet, as well as the carefully worded advice from the Environment Agency to Waverley about something called the Sequential Test, which basically seems to mean that areas at less risk of flooding in Cranleigh should be built on first. However, officers forged ahead regardless, avoiding carefully answering the question of whether the sequential test had actually been passed. One shocked Cranleigh resident said “it’s as if the officers work for the developers”.
Cllr Townsend spoke from the heart, highlighting the unsustainable location of Cranleigh, and the harm that this deluge of development, in such as short space of time, would have on the character of Cranleigh and on its residents. However, other hearts and minds appeared firmly closed, particularly Cllr Brian Adams (yes, he’s the one who said if we accepted the Crest Nicholson site for 149 houses Cranleigh would’ve taken its share of the borough’s housing, strangely the webcast of that meeting disappeared) who called his fellow councillors perverse if they refused this application, even though they had refused the identical application only last year.
Richard Bryant, on behalf of Cranleigh Civic Society, reminded Waverley that they have a legal duty to maintain water quality in our rivers and not to increase pollution levels in accordance with the Water Framework Directive. Unfortunately, this was not even acknowledged, Waverley’s eye was firmly on the prize of 265 dwellings that won’t have to go anywhere near their precious green belt. Houses that are far from major roads, far from a train station, far from jobs, and far from where most Waverley Councillors live.
Concerns about the sewage treatment works were cast aside with ease and pollution of Cranleigh Waters was not really worthy of a mention from officers, other than to imply that all was fine and dandy. Apparently, the sewage from an additional 3,000 residents makes no difference. And don’t forget that’s just Cranleigh’s new residents, we have other surrounding villages sending their muck here too to process. Oh, and did we forget to say, no one gives a damn about the environment, it’s an inconvenient tick box in a developer-led planning system.
Cranleigh Cllr Brian Freeston admitted “we don’t feel part of Waverley at all, can you blame us?” he spoke about the unfair allocation of houses on a blighted Cranleigh. The fact that we are being forced to take 30% (so far), in the village alone, other areas have a maximum of 15%, and that doesn’t even take the Dunsfold settlement into account. Cllr Freeston voiced concerns about the viability of the parkland, and said Cranleigh was in an untenable position. Serious and informed comments about the ageing asbestos cement drinking water pipes, of which Cranleigh unenviably has almost 30%, compared to 2% in the entire Thames Water area, received about as much attention as a Cranleigh Councillor at a Local Plan meeting.
As Cllr Townsend said “there is not a big enough material constraint, not even banned blue asbestos, that trumps more housing on Cranleigh’s green fields”.
So there you have it folks, Cranleigh is being officially destroyed with impunity by Waverley, next it will be a massive big shopping centre, just like Waverley have planned for Farnham, and one day you will wake up and find yourselves living in the biggest town in Waverley, and wonder how the hell you got there.
Development Application: Land at West Cranleigh Nurseries and North of Knowle Park between Knowle Land and Alfold Road, CRANLEIGH
Reference : WA/2016/2207
This application is to be heard on 15 March 2017 7pm at Council Chamber, The Burys, Godalming
Objections need to be submitted by 10 March.
Your village needs you to object NOW.
The application is not materially different to the original that was refused 29/04/2016 and is now at appeal. The reason for refusal remain and when an application is not materially different to that refused a period of 2 years must pass before a similar application can be considered. To reflect on previous objections, the application is not sustainable, remains outside the village envelope, the proposed area is in flood zone 3, agricultural land, removal of employment land, should the other nearby applications commence the accumulation of traffic on the Alfold road, the density of housing is excessive, affordable housing reduced to 35%, the ‘Parkland’ remaining in perpetuity how will this be achieved.
How to Object to Planning Applications
The Environment Agency (EA) have objected to the KPI (now in the name of A2Dominion Developments Ltd) on the grounds that there is not an acceptable Flood Risk Assessment (FRA) for the site.
You can read the full objection by clicking on the link below:
EA obj KPI 4 Jan 2017
The main summarised reasons outlined in the EA objection letter are that the Flood Risk Assessment does not demonstrate that the development will be safe from flood risk for its lifetime, and the potential impacts of climate change have not been satisfactorily taken into consideration.
The Cranleigh Society has maintained serious concerns about the flood risk on this site, which is part of Cranleigh’s rapidly diminshing natural flood plain.
We are extremely glad that the EA have carried out a thorough study of the FRA and echoed many of the points that we raised in our letter against this application:
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.”
With the recent publication of the Agenda and accompanying Local Plan documents for the Joint Overview and Scrutiny Committee for Monday, 27th June, 2016 7.00 pm came the shocking news that Waverley are dumping 45% of their total housing allocation in and around Cranleigh, with a new settlement on Dunsfold Park.
Waverley’s published Local Plan documents include Strategic Sites selected across the borough. This includes two strategic sites in Cranleigh, including phase 2 of the Crest Nicholson site with an additional 101 houses off the Horsham Road, this increases the total housing number on this site to 250 houses.
The other site is an amalgamation of the Berkeley Homes, Little Meadow and Knowle Park Initiative sites, creating a huge mega-site off the Alfold Road of 765 houses. The West Cranleigh Nurseries site (Knowle Park Initiative) which was going to be refused by planning officers, then got called in by Cllr Brian Ellis, thereby by-passing officers’ decision and finally was refused by Waverley’s Joint Planning Committee.
You can look at the full meeting details and documents using the link below:
Dunsfold New Town
It is clear that Waverley are now favouring 2,600 new houses at Dunsfold Park and this has also been identified as a strategic site.
At the moment there is a planning application for 1,800 houses on this site, however, Waverley have delayed making a decision on this. You can still add your comments and objections against this application.
Any housing on Dunsfold is in addition to 1,520 houses in Cranleigh, as well as 335 in the surrounding villages. This brings the total amount of new housing in this area to 4,455, which is equivalent in total to a new settlement the size of Cranleigh.
Dunsfold in the 2011 census had a population of 989 with 467 dwellings. Should an additional 2, 600, plus 80 dwellings be added to Dunsfold village, this will be almost a six-fold increase in the number of houses and with the proposed business expansion create a new town adjacent to Alfold and Cranleigh.
A previous attempt to develop a new town at Dunsfold Aerodrome was put forward in 2007 and sought to develop a town of exactly the same size with 2,600 houses. This was rejected by Waverley and dismissed at Appeal as unsustainable.
The planning inspector stated at the 2009 Appeal; “The site is not in a sustainable location and little can be done to improve the existing infrastructure.” Under Overall Conclusions, he stated “The Secretary of State has concluded that the development would generate a considerable amount of additional road traffic and he concludes that this would have a severe and unacceptable impact on an overstretched local road network, and that the scheme would be unsustainable in transport terms.”
What has changed in the surrounding area since 2009 to make the road network around Cranleigh now sustainable to Waverley Planning Officers?
What are the implications for Cranleigh?
With the proposal for 1,520 more houses for Cranleigh and almost 3,000 in total in neighbouring villages the effect on Cranleigh and the high risk of coalescence between Cranleigh, Dunsfold and Alfold is huge.
In the gaps between these three areas there will be continued pressure by developers to acquire land for residential and commercial use. The Cranleigh Neighbourhood Plan provides no policies for any buffer zones or strategic gaps between these settlements, and it does not suit Waverley to limit development in countryside beyond the green belt. The pressure to develop and fill these gaps could be constant and overwhelming.
Cranleigh is deemed the nearest main service centre for Dunsfold and Alfold and there will be massive impacts on the village from all the development:
- Urbanisation of our village and loss of countryside. At the recent consultation regarding the relocation of the Cranleigh Primary School when the developer’s agent was asked about the urban feel to the proposed housing they replied that Waverley wanted an urban look.
- 4,500 houses will double the number of local cars on our road infrastructure (this is approximately the same number of houses that Cranleigh has in total NOW). That’s a potential 9,000 extra vehicles.
- Increased traffic will lead to increased congestion, especially on the roads in and out of Cranleigh, Bramley and Shamley Green as well as all locations along the A281.
- There will be a significant impact on local services including our doctors and schools.
- The negative impact on Air Quality from traffic emissions from petrol and diesel-engined motor vehicles include a wide variety of pollutants, principally carbon monoxide (CO), oxides of nitrogen (NOx), volatile organic compounds (VOCs) and particulate matter (PM10), which have an increasing negative impact on air quality, on public health and on the environment. In addition, pollutants from these sources may not only prove a problem in the immediate vicinity of these sources, but can be transported long distances.
- The current sewerage system has no capacity and there is no provision being made for a 100% increase in liquid effluent being discharged into Cranleigh Waters and no mitigation being proposed. Waverley have not even done a Water Cycle Study, which is usually carried out at the beginning of the Local Plan process.
- Cranleigh is in an area of known severe “Water Stress” as acknowledged by Surrey County Council Water Management Report Sept 2013. This combination of increased housing and limited supply could lead to serious water shortages.
- Requirement for large increase in electrical supply. EDF indicated to Waverley in January 2011 that Cranleigh would require an increase in capacity if there was a significant increase in population. This also appears to have NOT been factored in so far.
Have your say
Waverley say in the Local Plan documents that:
“The vitality and viability of the main centres of Farnham, Godalming, Haslemere and Cranleigh 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 need of these centres, whilst recognising the importance of preserving and enhancing their historic character” [our emphasis]
We have never read such utter and blatant ‘spin’ regarding development in and around Cranleigh. We know that the only reason they are dumping housing here is simply because there is NO GREEN BELT.
It’s time to let the Leader of Waverley Borough Council, Julia Potts and the planning portfolio holder, Brian Adams what you think about their decision to dump 45% of their housing allocation in and around Cranleigh
Tell them by email, always include your name and address and copy in both the Cranleigh Civic Society – firstname.lastname@example.org and your MP Anne Milton – email@example.com :
Julia Potts – firstname.lastname@example.org
Brian Adams – email@example.com