Cranleigh Civic Society’s Chair Liz Townsend attended a meeting with the Secretary of State for Environment, Food and Rural Affairs, Andrea Leadsom MP, together with Anne Milton MP, and the Environment Agency’s Executive Director of Environment and Business, Harvey Bradshaw on 12 October 2016.
The meeting was kindly facilitated by Anne Milton and provided Cranleigh Civic Society with the opportunity to highlight the apparent breakdown of accountability for delivery of water quality, as outlined in the Water Framework Directive (WFD) legislation, within the planning system and to ask for this to be investigated further.
It was an extremely positive meeting and the points we raised were taken forward for further consideration.
Defra have confirmed that “Any development must not be contrary to the WFD and to paragraph 109 of the National Planning Policy Framework (NPPF) which states that the planning system should contribute to and enhance the natural and local environment.”
Defra have also stated that in our case where a local authority may not be upholding its obligations under the WFD and the NPPF it may be of interest to the Secretary of State for Communities and Local Government, (DCLG) Sajid Javid MP, and have therefore informed him of our situation.
We have now requested a meeting with DCLG and are currently waiting for a response.
109. The planning system should contribute to and enhance the natural and local
● protecting and enhancing valued landscapes, geological conservation interests and soils;
● recognising the wider benefits of ecosystem services;
● minimising impacts on biodiversity and providing net gains in biodiversity where possible, contributing to the Government’s commitment to halt the overall decline in biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures;
● preventing both new and existing development from contributing to or being put at unacceptable risk from, or being adversely affected by unacceptable levels of soil, air, water or noise pollution or land instability; and
● remediating and mitigating despoiled, degraded, derelict, contaminated and unstable land, where appropriate.
Background to discussion points:
The Cranleigh Civic Society pointed out that whilst planning authorities have a duty to deliver the objectives of the WFD, there appears to be a complete breakdown in accountability when it comes to delivering its objectives within the planning system.
The aims of WFD 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
However, in our experience, when it comes to planning decisions and water quality, Waverley defer responsibility to the Environment Agency (EA) who in turn defer back to Waverley as final “decision maker”. There is no acceptance of responsibility and no clear line of accountability and, it appears, no redress when a decision is made by a planning authority resulting in increased pollution and a deterioration in water quality.
In Cranleigh’s case, our river (Cranleigh Waters) is failing in terms of WFD (confirmed by Waverley Borough Council), in the main due to pollution from high levels of liquid sewage effluent being pumped into it on a daily basis.
Waverley maintain that they are meeting their responsibilities under the WFD as the discharged effluent meets with the current permit issued by the EA in 2009. However, Waverley is aware that this permit is outdated, was not issued based on WFD legislation, in fact does not comply with the standards set out in the WFD, and was issued when the flow in Cranleigh Waters was higher.
We pointed out that permits issued by the Environment Agency in 2009, were part of a blanket approval process to standardise levels of discharge into main watercourses. These permits were not based on WFD criteria and were intended to be reviewed and reissued based on up to date legislation.
However, reviews have not taken place, perhaps because it became apparent that many permits, if updated, would result in compliance failure and high levels of fines for water companies.
In order to achieve more stringent levels set by the WFD, water companies have embarked on trials of new technology, results of which are expected in 2017. It appears that the EA could be holding back on issuing new permits until the results of the trials are known, despite its responsibility to achieve ‘good’ status in each river catchment by 2027. Currently only about 36% of the UK’s 10,763 water bodies are classified as ‘good’.
This delay in permit renewals means that there is confusion and a loophole in planning with regard to water quality.
In Cranleigh huge housing estates have been and are being approved which will knowingly increase pollution in Cranleigh Waters, and we are convinced that this is being replicated across Waverley and across the country.
Furthermore, we are not convinced that water companies are taking into account in their trials reducing flows in UK rivers, due to lower levels of groundwater, climate change and a general increase in population, which places higher demand on water supply, especially in the South East.
Low water flows means that sewage effluent is not adequately diluted when it is discharged into a river and this impacts on the discharge permit which, we are informed, is based on an assumed level of dilution.
Adding to the multiple problems of lack of flow, pollution and an absence of adequate regulation, Cranleigh Waters, like other rivers in the UK, has been indiscriminately dredged, particularly in the area at the back of West Cranleigh Nurseries, resulting in widespread and long term damage.
Dredging is being used as a flood defence to widen and deepen rivers. However, we have been informed by the EA that it is counterproductive and amounts in very little gain in flood protection, often moving the problem downstream to larger settlements, in our case Bramley, Shalford and Guildford.
Lately the drawbacks of dredging are being more widely publicised and the benefits of catchment management highlighted, using natural flood plains, planting trees and creating flood meadows. However, this is too little, too late as far as Cranleigh is concerned, when Waverley has granted planning permission on almost our entire flood plain.
When extensive flooding occurs, of the type we experienced in 2013/14 (when our flood plain was still intact), dredging of the river would have a negligible effect in terms of flood protection, and can increase danger downstream by increasing the velocity of flood water.
These major issues must be addressed before further development is granted planning permission in Cranleigh.
Since the meeting our dialogue with the EA and Thames Water has continued and we have been invited to attend a further meeting with stakeholders to discuss these points.
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.
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.
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
Despite being a remote site on a green field, impact on sewage, roads, visual amenity, urbanising impact, absence of protected species surveys and impact on ancient woodland, the list went on, Little Meadow application for 75 houses on the Alfold Road was GRANTED last night.
This just adds to the concerted effort to dump all Waverley Borough Council’s housing allocation on Cranleigh. Added to the 757 already approved, this brings the GRAND TOTAL to 832 and that’s without the 30 extra new homes on small sites in the village.
Yay, we’re heading towards 900 new houses!
Hang on though……..
Then there’s approximately 220 more on Hewitts and the Cranleigh First and Primary School brownfield sites in the planning system too!
We’ve reached the 1,000 Jackpot!
Cranleigh councillors Brian Ellis, Stewart Stennett and Jeanette Stennett all voted in favour of the Little Meadow development as ALL three said that Cranleigh NEEDS more housing, despite permission granted for over 700 already.
We are not sure when they will think that Cranleigh has enough?
Brian Ellis at the start of the meeting declared that his pecuniary interest in the Knowle Park Initiative (KPI) was a mistake and it was a non-pecuniary interest that should have been recorded in the previous meeting, due to his involvement with the transfer of land between the Parish Council and the Cranleigh Village Hospital Trust of which the owner, Nick Vrijland, of KPI, is also a Trustee.
There was no withdrawal of the Stennetts’ pecuniary interest in the Knowle Park Initiative and Mrs Stennett also declared that she knew the landowners of the Little Meadow site.
Unfortunately Vice Chairman of the Joint Planning Committee Maurice Byham (who had attended the Cranleigh Society stakeholder meeting at the Cranleigh Sewage Works only last week), the planning portfolio holder Bryan Adams, Waverley Mayor Mike Band, Cllr Pat Frost and Cllr Stephen Mulliner did not attend this meeting.
Reasons for Refusal
Despite Cllr Mary Foryszewski’s valiant attempts to draw attention to available brown field sites in Cranleigh and the overall detrimental impact of yet more development on Cranleigh’s green fields, she was in the minority.
Cllr Patricia Ellis drew attention to the state of the Alfold Road and said it was the worst road in Cranleigh.
Cranleigh Councillor’s Brian Freeston’s speech outlining the parish council’s reasons for refusal, including the remoteness of the site, distance from the High Street, availability of brownfield sites and the lack of reports for protected species. He also pointed out that a recent Appeal for a dwelling on Bookhurst Road had been refused on biodiversity grounds, quoting:
“However, there would be a potentially detrimental effect on biodiversity in conflict with national policy and with the development plan. There are no other material considerations including the lack of a 5 year housing supply and the provisions of the Framework that outweigh these findings. Therefore, for the reasons given, the proposal is unacceptable and the appeal should not succeed.”
Cranleigh Civic Society
Warning this may get a bit technical 🙂
The Cranleigh Society (when the video footage seemed to go a bit wonky! A brief moment of fame lost ;D) emphasised the point that Waverley Borough Council’s Officers’ advice to members of the Joint Planning Committee was erroneous and the council was taking on the full risk and liability, if the application was approved, of non-compliance with the Water Framework Directive (WFD).
The Society pointed out that it is the responsibility of Waverley, as advised by the Environment Agency (EA), to assess the impact on water quality from this development. This has not been done to date.
The Society also pointed out that Waverley was wrong in saying that the EA had not objected to this application. Yet again we had to point out to Waverley that the EA is only a regulator with regards to WFD and as such CANNOT OBJECT, only provide advice. The EA had provided strongly worded advice on this subject to Waverley which was largely ignored.
Waverley as the competent authority for planning & development should have ensured that an ‘appropriate’ water quality assessment was made. As it stands, no impact on water quality has been measured or reported.
Waverley, it seems, continues to be confused about their role with regards to WFD and said in their Officer’s report (page 50), that accompanied the meeting last night, that:
“in terms of water quality, it is for Thames Water, in consultation with the Environment Agency to address this matter, and not a matter for consideration under the planning application. This is a separate regulatory process, which the statutory authorities work under.”
We spoke to an Environment Planning Specialist at the EA before the meeting last night who confirmed that the above statement was “factually incorrect”. This was relayed to Councillors.
The EA confirmed that it is for the LA [local authority] to ensure that the developer has confirmed that there will be no additional impacts to water quality (& WFD) as a result of the new development.
This water quality impact will then have a knock on impact on WFD. The Environment Agency as a regulator does not assess the developments potential to impact and neither does Thames Water (TW). TW will just confirm whether or not they can accommodate the development within their existing permit or network/STW [sewage treatment works] capacity.
Thames Water’s current environmental permit to discharge effluent into Cranleigh Waters is OLD and does NOT consider the requirements of the Water Framework Directive, as it was issued prior to these regulations and has not been renewed.
As a result, the existence of this permit, or the fact that Thames Water is operating within the boundaries of the permit cannot be used by Officers as an indicator of compliance with WFD, as it has absolutely diddly-squat to do with it and they should know that!
By passing the application last night Waverley has done so with the ‘full knowledge’ that no water quality assessment has been carried out and Waverley will bear the full risk and liability of this decision.
The application was passed by 11 to 7 votes opening the door wide to yet more development in Cranleigh. We wonder if next time WFD will be taken more seriously……………
This is yet another application on Cranleigh’s green fields and will put more strain on our sewerage system, which is already over capacity and rural road network. Please show your support by attending this meeting with us.
Last evening the Knowle Park Initiative (West Cranleigh Nurseries) was rejected by the Joint Planning Committee at Waverley Borough Council.
(Due to the very lengthy debate of 2 ½ hours, the Little Meadow application for 75 houses, which was also due to be heard, was postponed and another date will be arranged.)
Over 100 residents attended the meeting, the public gallery in the Council Chamber was full and the overflow room was packed to the gunnels, where people watched proceedings on a big screen.
The vast majority of people were there to show their opposition against yet another huge housing estate for Cranleigh, which would’ve taken our number to over 1,000 new houses.
At the very start of the meeting, we were somewhat stunned when Cllr Brian Ellis and Cllr Stewart Stennett declared a pecuniary interest in the Knowle Park Initiative application and left the Chamber, followed by Cllr Jeanette Stennett.
There was a lengthy presentation by the planning officers, who until almost the last minute had been publishing extensive updates to members. This was in the main due to the continued pressure that the Cranleigh Society had applied and the serious concerns we and residents had raised. There were many pages in the final documents issued to members that mentioned the Cranleigh Society, our comments formed the basis of several of the final conditions that were to be imposed on this application.
We had, after many hours of research, emailing, telephone calls and sheer determination, managed to get Thames Water to impose a Grampian style agreement, which meant that should permission have been granted the developers would’ve, at the very least, have had to contribute towards the upgrades to Cranleigh Sewage Treatment Works. This in itself was a major achievement, and one that in our view planning officers should’ve been pushing for on behalf of the Cranleigh community.
There was recognition of one of our main arguments around the five five-year housing supply. We pointed out that it would take Thames Water a minimum of 7 years for the sewage works to be upgraded, which would mean a considerable delay to the delivery of these new houses. One of the Councillors asked the planning officers to explain this “time warp” to the members. The fact that the houses couldn’t be built until the sewerage was improved, finally hit home.
Also, the very valid concerns about sewerage raised at the last minute by the Environment Agency, again due to our continued pressure, was acknowledged, together with the damaging effect on the Cranleigh Waters of yet more effluent being pumped into it and the need to assess the impact of multiple developments on water quality.
We also managed at the very last minute to get DCLG involved and should the application have been approved they were going to consider our request for a ‘call in’. This is when the Secretary of State takes the decision-making power on a planning application out of the hands of a local planning authority and he decides whether it should be granted or refused.
It was a very busy day!
Thank you for the many emails you sent, it really did make a difference. It is so important that you add your voice to ours, we have proved how effective we are when we work together.
We would also like to extend our thanks to our MP Anne Milton and her team for replying to our many, many emails, for listening and for their support of Cranleigh residents concerns over infrastructure.
And we would like to thank members of the Joint Planning Committee who undertook an informed and measured debate. There was real empathy shown for Cranleigh’s plight and recognition that our village was about to end up as a building site. One councillor said they wouldn’t want to live in Cranleigh at the moment! Another said Cranleigh will end up looking like Poland in 1939!
We have to reserve a special thank you for Cranleigh’s Cllr Mary Foryszewski , her passion and commitment under immense pressure was admirable. She has on occasion be the lone voice speaking up for Cranleigh and she has our heartfelt thanks.
In addition, we would like to thank the Cranleigh Parish Council, Cllr Brian Freeston spoke on behalf of the planning committee and eloquently voiced their many objections to this application.
Finally thank you to the Cranleigh Civic Society committee whose commitment, courage, persistence, and reliability are second to none and they should stand proudly today together with all our members.
The fight is not over! However today we will celebrate a victory for democracy, transparency, and the right to be heard.
PICTURE ABOVE SHOWS SEWAGE FUNGUS IN CRANLEIGH BROOK 10 APRIL 2016
On 27th April 2016 at 7pm both applications for the Knowle Park Initiative and Little Meadow (Crownhall Estates Ltd) amounting to another 340 houses off Alfold Road go before the Joint Planning Committee (JPC) in Waverley.
Come to the JPC meeting, it is extremely important that councillors make this decision directly in front of Cranleigh residents and we know exactly how they vote, especially our local Cranleigh councillors.
If approved, this would bring the total number of new houses off Alfold Road to 765.
The nearby Hewitts Industrial Estate application for another 120 houses is also due to be heard at Appeal by the Planning Inspector in October 2016. That would bring the TOTAL JUST in this part of the village to 885.
Where’s the Sewage Going?
We also note that Thames Water have not raised any objection to either of these applications based on sewerage capacity and yet they have placed Grampian style conditions on both Cala Homes and Crest Nicholson, which means that development cannot commence on these sites until foul water drainage strategies for on and/or off-site work, has been approved by Waverley Borough Council and Thames Water.
We have written to Thames Water to point out this discrepancy and the fact that we believe that it is in breach of its statutory obligations as the water and sewage undertaker if it now fails to raise an objection to the Knowle Park Initiative and Little Meadow applications.
Knowle Park Initiative Saga
For those of you who have been following the Knowle Park Initiative (KPI) application, you might remember that Thames Water originally objected to the application on the grounds that the existing waste water (that’s sewage) infrastructure couldn’t accommodate another 265 houses in addition to 425 on the Berkeley Homes site. It also confirmed that the water supply infrastructure didn’t have sufficient capacity either.
When the Berkeley’s application for 425 homes was refused on 6 January 2015, KPI’s advisers moved swiftly and contacted Thames Water on 7 January 2015 to point out that in light of the refusal there was now some notional sewage capacity available to them, although we wonder where this was, seeing as Cala and Crest were told there was none?
Thames Water faced with the fact that they had not objected at all to the Berkeley Homes application on sewage grounds had to concede on this point and issued a letter on 15 January 2015 ( view KPI Correspondence to Waverley regarding Thames Water ) withdrawing their objection. However, the letter from Lance Cooper of Thames Water did point out that: “Please note that the views expressed by Thames Water in this letter is in response to this pre-development enquiry only and does not represent our final views on any future planning applications made in relation to this site.”
Now you might think that in light of the decision for Berkeley Homes Appeal on 31 March 2016 giving permission for 425 houses, and bearing in mind the recent widely publicised sewage issues in Cranleigh, which are referred to by planning officers in their report for the meeting on 27 April, Waverley officers would go back to Thames Water and get an updated statement before they recommended 340 more houses for approval in Cranleigh?
And especially as the sewers becoming overwhelmed by another 340 houses and foul water flooding would be an environmental and a public health risk.
But you would be wrong, the planning officers have recommended both of these sites for approval, relying on what might be a verbal update from Thames Water prior to the meeting on 27 April. This seems to amount to a serious oversight by Waverley Borough Council Planning Officers.
What about the Water Supply?
And what of the water supply infrastructure you might ask? That’s the stuff that comes out of your taps. Thames Water has maintained that the water supply infrastructure CANNOT SUPPORT either of these developments, however, this appears to have been completely overlooked by officers. There is no mention of a condition regarding this in their recommendation to approve these sites, and there is no mention of the impact study that Thames Water requested.
We think this is yet another serious oversight by Waverley Planning Officers and we would like to know why.
What are we doing?
Yesterday we wrote to Thames Water regarding the Knowle Park Initiative and Litle Meadows applications requesting that they uphold their statutory obligations and we copied in our MP Anne Milton, Waverley Planning Officers and the Environment Agency.
We also met up yesterday with a representative of Waverley’s Environmental Health Department, who seem to be taking this issue seriously.
We will keep you informed of the outcome.
What can you do?
Demand to know what is going on with Cranleigh’s sewerage system:
Send ONE email to the following people quoting references KPI WA/2015/1569 and Little Meadow WA/2015/0478 (please copy us in at firstname.lastname@example.org):