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.
The Water Services Association of Australia has estimated it could cost $AU8b ($NZ9b) to safely remove Australia’s roughly 40,000km of worn-out asbestos piping.
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.
Cranleigh Civic Society, in consultation with the Government’s Health and Safety Executive, prepared a full Risk Assessment on the network of asbestos cement pipes in Cranleigh and sent this to Waverley Borough Council on the 29th January. Waverley ignored it.
We are aware that this subject will cause a high degree of concern in the village and we will of course keep you informed of any developments.
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.
As you might remember Cala Homes had applied for their Grampian condition to be removed, however, Waverley Borough Council, in a rare moment of what seemed common sense, refused their request. Surprisingly, this did not stop work on Cala’s show houses.
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?
It was also pointed out that Crest’s Grampian was a little more lax than that for Cala Homes, despite all the initial concerns Thames Water had about this site and the need for huge on-site sewage storage tanks. These worries seem to have been a mere flash in the pan!
Not long after the first Crest spade was in the ground, they were plotting to build 121 more houses in the pristine green fields adjacent to this site.
Crest describes Cranleigh on their website:
“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.”
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 firstname.lastname@example.org 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.
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.
We will keep you updated with our progress.
The Amlets Lane application by Cala Homes for 125 dwellings got the final vote of approval at Waverley Borough Council last night by 12 votes to 9. Cranleigh’s Waverley Councillors all voted against the application, however this last minute push was too late to save the site from development.
Liz Townsend spoke on behalf of Summerlands Estate Residents Association and residents of Copse Edge:
We acknowledged that Cala Homes had made some welcome and positive changes to the layout since the application was deferred in September, with a reduction in the height and bulk of the apartment buildings, the positioning of bungalows along Copse Edge and the removal of a parking court.
Residents’ Liaison Group
Residents remain extremely concerned about the access road into the site and the lack of detail regarding the drainage system for surface water run-off. On residents behalf, we requested ongoing involvement in the design of the drainage scheme by sharing local knowledge on flooding. The idea of a liaison group was endorsed by some councillors, and we have emailed Waverley Borough Council today to repeat this request.
To protect the privacy of residents living adjacent to the site, we requested a restriction on permitted development to the roof of any dwelling along the site boundaries, as recently imposed on the Crest Nicholson development on Horsham Road, which was agreed. This means that householders on the Amlets estate will have to apply for planning permission to extend into their roof space.
We also requested details that the buffer zone (shown above) around the edge of the site should be included in the overall management plan for the estate, as there is a risk that it could become overgrown, neglected and unsightly, or encroached on as part of the drainage scheme.
Since the first application, residents have highlighted subsidence issues on Summerlands and the requirement for pile driving on Copse Edge. We expressed surprise that the developers were still recommending concrete strip foundations and maintain that these will not be adequate and the need for deeper foundations could be used as leverage to further reduce the amount of affordable housing on the estate on viability grounds.
We noted with regret, that the proposed tenure split is now to be 50:50 between social rented and shared ownership, rather than, as was agreed at outline, 76% rented and 24% shared ownership. However, Cllrs were unable to discuss this aspect of the application, as the alteration will be by way of a separate variation to the S106 agreement and will be agreed by planning officers under what is called delegated powers. However, we asked Cllrs to honour the original condition as this was one of the main determining points in approving this exceptional green field site.
Sewerage Infrastructure and water Quality
We requested further details from Waverley about the calculation of S106 contributions from the developer for off-site sewage upgrade work, or for water quality mitigation, as required under the Water Framework Directive (WFD), for Cranleigh Waters. We have repeated this request today.
As previously published, considerable expansion work is currently taking place at Cranleigh Sewage Treatment Works in order to accommodate “growth” however the problem surrounding the pumping of increasing amounts of liquid sewage effluent into Cranleigh Waters has not been referred to, or addressed by Waverley.
In response to a meeting on 12 October with Cranleigh Civic Society, Anne Milton and Andrea Leadsom. Defra confirmed that 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. The obligation that Waverley has, to consider WFD when determining local development, has, we believe, not been fully satisfied.
Cranleigh’s Councillors raised lengthy additional comments surrounding road safety, which unfortunately was not one of the reasons for the previous deferral of the application, and although, we firmly agree, extremely important, was all too late to save the Amlets site.
There were further concerns raised about traffic turning out of the estate onto Amlets Lane and the route of construction traffic, suggestions of a one-way system were raised. The Construction Management Plan will ultimately be decided by planning officers, who will we hope take up the suggestion of a further site visit.
We will all need to be vigilant once construction starts on this site and use this road only when necessary and with increased care. Please continue to report any incidents to us email@example.com and send in photos if these can be taken safely.