Guildford Greenbelt Group press announcement on the Scrutiny Committee meeting

Guildford Greenbelt Group put out this press announcement in relation to the Scrutiny Committee meeting last summer.  Its conclusions were not implemented and the housing number was not reviewed.  The current draft SHMA has involved an increase in the housing number that, last June, was considered too high.

Guildford Greenbelt Group

Press announcement


20 May 2014

Councillors change direction of local plan


In an astonishing and dramatic U-turn at the Scrutiny Committee last Thursday 14 May 2014, elected councillors challenged the Executive’s direction on the Local Plan for the first time. The councillors voted for the housing numbers to be revised within the draft Local Plan , with massive consequences for the impact on the Green Belt and the future of Guildford.


A surprise vote was called, which was not on the agenda. The motion was not formally worded, but on an ad hoc basis was “to express concern over the housing number set out in the draft Local Plan and to ask the Head of Planning Services and the Lead Councillor for Planning to review the numbers before it comes back to the Executive”. This motion was passed unopposed, with no dissenting votes, by the combined Scrutiny Committee.


The Scrutiny Committee meeting can be viewed on a webcast on the Guildford Borough Council website.


Cllr Jennie Wicks opened the debate with brilliant and dramatic effect by saying “I think that the housing target here is too high, it will have a devastating effect on some parts of the borough. I am reprising… what a couple of our speakers referred to… the comments of Edge Analytics who said that the SHMA housing numbers result from the choice of data and the housing numbers used…Edge said that further scrutiny was needed. Will this be done – and how will we be informed of the outcome?.. I hope we will be doing a reassessment as they recommended, and I hope that…the information will be made properly available to councillors…


She continued “In estimating the housing target, it seems to me that little account has been taken of constraints particularly Green Belt. The current proposed distribution of sites just uses Green Belt as land available for development… The NPPF says that Green Belt boundaries should only be altered in Exceptional Circumstances .. and we have Ministerial statements that housing need of itself will not justify incursion into the Green Belt for houses or travellers’ sites. Why haven’t we referenced those Ministerial statements in our evidence?.. Why have we chosen to renounce any inclusion of windfall sites?…Now we have the conversion of office space to residential which is in addition to the type of windfall that used to come forward, which the Reigate and Banstead Inspector recognised… And why nothing for bringing back empty homes into use?,, I have to comment with considerable sadness about the imbalance of the distribution of the proposed housing. It is proposed that there should be more than 6000 houses on our precious Green Belt between Burpham and the M25, a distance of less than 6 linear miles.”


Cllr Bob McShee said “It is unsustainable and damaging to the Green Belt and our infrastructure.. It is far too much for Worplesdon to absorb…This committee has been asked to consider the draft Local Plan and as far as Worplesdon is concerned, it is unacceptable at this stage.”


Cllr Jennie Powell said “Why have the sustainability indicators been ignored?” and asked a number of specific questions about the flood risk which had been disregarded in West Horsley”.


Cllr Andrew French said “This is not a wholly democratic process… If we really do have to build this out as planned in here it is going to do huge and irreparable damage to this borough. .. Around the NPPF… I recognise that we as a borough need to do a strategic review of the Green Belt. We have done that. However, I don’t think the Green Belt at the moment is being used as a constraint at all. What we seem to have done is taken the view that any site that has been identified in the SHLAA as developable can be developed regardless of whether it is in the Green Belt or not.


“If our housing number was double, would we therefore say that’s fine, we’ll develop twice the number? At what point do we apply constraints here?


“There’s a great deal of pain elsewhere as well, we have to look at the constraints again… That to me is a political judgment, it is not a judgment for the planners to make, it is for us to make as a local authority. I now think we need to exercise that political judgment as to what approach we are going to take. We should not be attempting to send a Local Plan to the Planning Inspector gift-wrapped… we should be getting a Local Plan which is as challenging as possible. We need a plan which simply gets over the line with the minimum possible, not something that is gold- plated.”


Mrs Carol Humphrey, Head of Planning Services, spoke several times. She said “We think we can accommodate the numbers that we are suggesting”…and ”it is inevitable that the Green Belt will be realigned to allow for the accommodation of some growth”.


Cllr Pauline Searle said “As a councilor of an urban area… all of Guildford is important be it the town, urban area or Green Belt. This is Guildford and it is what we are all proud of…”


Cllr David Wright said “What is robust, what is strong, what is defensible is really a matter of judgment… Such matters of judgment are partly technical and they are partly political. I think there is no councillor who has any appetite for large numbers of additional houses that will be indigestible and that will not in general be welcomed, despite what has been said about the relationship between housing and growth. There is nowhere in this plan a strong causal argument that shows that direct connection and whenever it is challenged it always boils down to anecdotal statements by businessmen. We know the economy of Guildford does well and 50% of the people who work in Guildford live outside, and vice versa. It is the judgments that members of the public will question…The possibility of building on large areas of Green Belt remains a very strong possibility for one basic reason which is the numbers we are being asked to accommodate…The word “objective” in objectively assessed needs can be challenged because it is based on human judgments which are not objective and I think that the public would like a little more transparency about how the objective judgments ultimately were arrived at. I would like to see…the extent to which they were challenged.   I would hope that process is not at an end and I would hope that we can still get the basic number down – because it is that basic number which minimises our ability to protect the character of Guildford which we all want to maintain. So I would put in a plea for that.”


One councilor asked Cllr Juneja to comment on the duty to cooperate. She noted “I have spoken to parish councils, tried to go round all residents’ associations..,.. I’ve also spoken to the Lead Member for Woking, have tried to speak to Rushmoor and Waverley but obviously they are in different situations and sometimes come over later on in the day as have Woking… Spoken to and gone, been to, I have been to a duty to cooperate conference which we led ourselves, we led that and invited a number of different authorities, many still not willing to really come round the table at this stage… We also had an event with all leaders of all districts and boroughs and also had the senior politicians for Surrey County Council and we tried to move that forward in terms of looking at Duty to Cooperate not just for housing. But if indeed we don’t accept other authorities’ housing numbers then we should be certainly looking at infrastructure whether it is schools, roads, doctors’ surgeries, or hospitals…”


Cllr Tony Philips said “I like others am extremely concerned about the high housing numbers. Now, tonight we have had good questions, and reports and statements from members of the public, and Flo [Churchill] and others from the top table have chanted off chapter and verse.   Unfortunately we haven’t had sight of these responses, and I think we should have had sight of these responses to enable us to digest them properly and form our own opinions. .I’d ask if we can have all the responses that we have been given.


Having said all that, I, like Councillor French and others, am still not happy with the housing numbers, and I think that the report for the recommendation that goes back from this joint committee should be that we are still not happy with the housing numbers – and ask the Lead Member for Planning and others to have another look at this. That’s what I’d like to propose.”


It was therefore decided that it was necessary to have a vote on Cllr Tony Phillips’ proposal, and Mr John Armstrong, Head of Democratic Services for the borough, proposed the following wording, and noted this proposal is fundamental to the plan:


“To express concern over the housing number set out in the draft Local Plan and to ask the Head of Planning Services and the Lead Councillor for Planning to review the numbers before it comes back to the Executive (presumably)”.


There was a show of hands. No councilor on the joint Scrutiny Committee voted against the motion.


GGG chair Susan Parker said:


“People in Guildford are delighted with this result and will want to thank the councillors that spoke so effectively last Thursday. It is good to see that the councillors have listened to us, and have heeded the submissions made by GGG previously and by the combined residents’ groups. GGG warmly welcomes this change.


But this vote, welcome as it is, is not in itself enough.  We have seen tokenism before (for example, in the councillors’ vote for full public involvement in the scrutiny of the evidence base, which ended up as just a token representation).


We need a revision of the housing number. We need that revised number to be sensible and we need a radical consequential change to the draft Local Plan. The previous numbers were wrong, much too high with disastrous consequences for everyone in the borough – now they must come down.


I am concerned that there is no change to the timetable following this vote. I hope that the Council can make the required changes in the time. I hope that the Executive don’t think that they can ignore this Scrutiny Committee vote as well as the public, and just carry on regardless. ”







Edge Analytics report on the GL Hearn draft SHMA:


See link:




Guildford Greenbelt Group initial response to draft West Surrey SHMA

Guildford Greenbelt Group (GGG)

Press announcement 20 December 2014




Guildford Greenbelt Group (GGG) notes that the combined draft Strategic Housing Market Assessment (SHMA) for Guildford, Woking and Waverley was published late on 18 December 2014.


This document, like the previous draft SHMA published in May 2014, and the draft published in January 2014, was produced by GL Hearn.


The proposed housing number for Guildford is a range of 620-816 homes per year.


GGG will study the new SHMA in detail and will produce detailed comments in due course. However, there are some preliminary observations we feel able to make:


  • GL Hearn has noted that certain of the criticisms made about its previous drafts and calculations are valid
  • GGG has formally requested a copy of GL Hearn’s model (as used previously), in order to assess and check the formal calculations and assumptions made. This has been refused by Guildford Borough Council, despite a formal freedom of information request (even though, unless the method can be reviewed and replicated, an inspector should deem the conclusions invalid).
  • It is worth noting that GL Hearn has expertise in advising developers on how to achieve their objectives, and this is the main focus of its practice. Why did Guildford Borough Council choose – repeatedly – to use a consultant with such a strong pro-development focus? (see notes).
  • Despite certain previous criticisms being accepted as valid, the range of housing need given for Guildford is similar to that proposed previously, with an actual increase in “objectively assessed housing need” (OAN) for the area. Previously objectively assessed housing need was considered to be 652, with a suggestion that Guildford should “test” a possible increase to 780 (ie a previous range of 652-780); now GL Hearn asserts that the actual objectively assessed housing need for Guildford is 820 homes per year.
  • This arises because GL Hearn’s assertion is that the population of Guildford will grow at a significantly higher rate than England as a whole or even than the South East – population growth in Guildford is predicted to be 17.2% compared with 11.7% in Woking .
  • GL Hearn states that growth due to increased economic activity in Guildford will be the cause for a significant proportion of new housing and it inflates the housing number accordingly.
  • Guildford is stated as likely to achieve economic growth which is significantly above average even within the housing market area, and higher than anticipated in the South East as a whole. This development strategy drives a significant element of the housing need assessment; but this strategy has itself never been approved or subject to local consultation.
  • Around 50% of the expected increase in the student population in Guildford (a further 6300 students) will be expected to be housed off campus; there is no expectation of a reduction in the proportion of students currently housed in the town (as has been required by other university towns).
  • It is acknowledged that there will be constraints applied to the calculation of objectively assessed housing need which will include infrastructure and the greenbelt, together with Area of Outstanding Natural Beauty (AONB) and the Thames Basin Heath Special Protection Area (SPA).
  • GL Hearn has applied a higher uplift to housing need in Guildford to increase “affordability” than in either Woking or Waverley, which is apparently because it has a “larger younger population” (ignoring the fact that this is due to the student population).
  • There has not yet been any adjustment for housing need in relation to impact of existing planning permissions, windfall sites and the housing of more current students on the university campus, all of which have been required by ministerial guidance.


Susan Parker, chair of GGG commented:


“The Guildford number for housing need is too high – it has been increased. When the required constraints are applied, we are likely to find ourselves with the same housing projections and proposals as put forward last summer.


The Council has claimed repeatedly that it will challenge the housing number, but it is campaign groups and the community, not the Council, that has challenged and questioned its conclusions at every stage.   The Council has merely put development consultants’ reports forward as a justification for the proposed plan.


It is worth noting that in 2011 the Guildford Conservatives pledged to protect the greenbelt & countryside as a key element in their election manifesto, which led to their election. That pledge was not honoured. The draft Local Plan, put forward by our local Council, broke that promise.  


We have now been told that the Local Plan will be reviewed by the Council, and a revised Local Plan will be available after the next election. The housing numbers have increased and the Council have not challenged the arguments made, although they have had this report in draft since September.   The Council chose to publish this report a few days before Christmas perhaps so no one would read it. Why should anyone trust them now?“



Notes for editors


  1. Further information on GGG is available on the GGG website

Or on its facebook page:


  1. GGG public meeting open to all members of the public, will be held as follows:
  • 28 January 2015 -Fairlands Community Hall -7pm


  1. See the GL Hearn website: “We act for many of the leading developers and are currently advising on schemes totalling over 3m sq ft. We have a team of over 100 people directly involved in the development sector.” “The practice has in-depth experience of development projects.. this wide-ranging commercial track record is of great benefit for developer clients… We take pride in our ability to drive development projects through to delivery and problem solving with a commercial focus.” “With a client base that includes landowners, developers, investors, Regional Development Agencies and Local Authorities, we approach each project first by fully understanding and then striving to achieve our clients’ objectives. “ “G L Hearn is increasing its work with the public sector providing a consultancy approach with a strong commercial aspect.” “We have a proven track record in the delivery of housing ranging from small residential schemes to larger, complex mixed-use developments, and the longer-term promotion of strategic sites. We provide comprehensive advice on residential strategy, from site identification through to the delivery of planning permission.” “Good development advice requires solid planning and development expertise, together with specialist knowledge across the full range of property sectors. We have the in-house expertise to assess development potential and obtain the required permissions”. “Our expertise and experience in preparing outline and detailed planning applications and our skill and determination in negotiations have secured consent for proposals in all sectors of the development industry. This is often the case where success may have seemed improbable before our involvement. Undertaking S106 negotiations and the provision of viability advice in connection with them, which has become significantly important to secure such consents, regularly feature in this work… Our clients include some of the largest and most active developers in the UK.”


Guildford Borough Council joint SHMA published

Guildford Borough Council has today (18 December 2014) published the West Surrey joint SHMA (Strategic Housing Market Assessment) prepared jointly for them and the boroughs of Woking and Waverley, by the consultants GL Hearn.

GL Hearn prepared a draft SHMA for Guildford borough council in January 2014, with headline housing numbers in a range from 670-800 dwellings per annum. This generated a storm of protest from the community.     After public criticism, that draft SHMA was subjected to a review by Edge Analytics, who said that for some matters they could only give the report “an amber tick”.

A revised draft SHMA was prepared by GL Hearn in May 2014, with revised numbers in a range from 652- 780 homes per year (not a wholesale adjustment).  This was then adopted by Guildford Borough Council in their draft plan without any application of constraints (despite the fact that they could have chosen to apply significant constraints because 89% of the borough is Greenbelt, as stressed by ministerial guidance). GBC also proposed to backdate that housing target to 2011 to generate a housing target for Guildford borough, by 2031, of 13040.  It was pointed out by community members that Guildford had met its objectively assessed housing need to date, so no backdating was required.

It was also pointed out by a number of commentators -including the Office of National Statistics -that the draft SHMA still contained a number of errors, and if the errors were corrected, the calculation of objectively assessed housing need could be shown to be overstated, possibly by as much as 200 homes per annum.  It was also pointed out that Guildford Borough Council – under the previous administration – had gone to the High Court in 2010 to campaign for an interim housing number of 322 homes per year, because the “top down target” of 422 homes per year was judged unsustainable.  That battle was won – the High Court agreed that Guildford could not support 422 homes per year and imposed an interim target of 322 homes.

A number of commentators asked for the calculations and the computer model underlying the GL Hearn analysis to be provided. This request (prepared formally under a freedom of information request, and followed up with an appeal to the Information Commissioner) was refused.

The full combined SHMA has now been published.

GL Hearn have now produced a revised SHMA on a combined basis for the housing market area of Woking Waverley and Guildford.  The numbers for Guildford are now 620-816 homes per year, doubling the previous target (and more), and supporting GL Hearn’s calculations prepared in January 2014.

Guildford Greenbelt Group will study the new SHMA and will prepare detailed comments on the document. The SHMA is available on this link:


Parliamentary sub-committee review of NPPF

On 16 December 2014, the government published the results of the parliamentary sub-committee into the operations of the NPPF.

In response, GGG wrote the following open letter to all Guildford Borough councillors and MPs:
Dear Councillor

You may be interested to see the parliamentary sub-committee report on the publication of the NPPF, which was published overnight. This should have an impact on our emerging local plan.

GGG submitted written responses to this sub-committee and I was pleased to attend the sub-committee forum on behalf of GGG in order to contribute to this debate.

The report and associated press response can be read here, which includes a hotlink to the full report:

Please note that this report recommends:

1. Developers will not be allowed to challenge inclusion of brownfield sites on the grounds of viability

2. All sites with planning permission will be required to be counted against the 5 year supply

3. There is a call for a remediation fund for brownfield sites to be set up

4. There is a recommendation for a 3 year requirement for implementing a Local Plan

Best wishes

Susan Parker
Guildford Greenbelt Group

GGG public meeting at Wood Street at 7.30pm tonight

This is a joint meeting between GGG and Save Hog’s Back.

7.30 pm Tuesday 9th December at St Albans Church Wood Street.

We will be discussing the Local Plan, where we are now, the prospects for the future and what you can do to get involved.

Speakers will be Neville Bryan (Wood Street/Hog’s Back),  Mike Bruton (East Horsley) Helen Jefferies (Ockham) and Susan Parker (Shere & Gomshall), followed by public discussion.

It is a public meeting and all are welcome. Membership is not required.

From Guildford follow A323 (Aldershot Road) towards Aldershot out of Guilford. At Rydes Hill Roundabout turn left (Broad Street), and follow the road for about 2 miles. The church is at the top of the hill in the village on the right.
From Aldershot follow A323, about 2 miles after Normandy there is a Road on the right (Frog Grove Lane) signed “Wood Street Village” and follow the road for about a mile and a half. The church is at the top of the hill in the village on the left.

St Albans Church is immediately opposite the Royal Oak Pub

Address – St Albans Hall, Oak Hill, Wood Street Village. GU3 3ES,+Guildford,+Surrey+GU3+3ES/@51.2583659,-0.61452,14z/data=!4m2!3m1!1s0x4875d139e76d762d:0xc29621cea946618a


Call for Surrey Hills AONB to become a National Park


 Guildford Greenbelt Group (GGG) calls for the Surrey Hills Area of Outstanding Natural Beauty (AONB) to be redesignated as a National Park.

 The constitution of the AONB has recently been codified or clarified. It is now directly controlled by the same councils that have aggressively viewed the Green Belt as an area for development.

 GGG considers that this area is too important and too precious to be left to local councillors. Our view is that some have already demonstrated in their local boroughs that they cannot be trusted. We need a board that runs this area in order to protect it.

 The Surrey Hills Area of Outstanding Natural Beauty runs across the North Downs from Oxted to Haslemere– where it becomes adjacent to England’s newest National Park – the South Downs National Park. It has countryside of national significance which includes areas like Box Hill, the Hog’s Back or the Devil’s Punchbowl, many other famous beauty spots like Leith Hill, Newlands Corner or Silent Pool; and many historic locations, sites of special scientific interest or wildlife importance. It is internationally famous because of the Olympic cycle routes which have triggered more frequent cycling events along the same or similar routes. It is also a playground for Londoners – cyclists, walkers, campers, riders come here for days out – and a breath of fresh air. Many teenagers have their first experience of serious walking by completing Duke of Edinburgh excursions along the Surrey Hills.

However, “AONB” is a designation that is not universally familiar; we have been told that some Guildford borough councillors were not aware of the designation before becoming councillors. But everyone understands what a National Park does.

Our AONB is perhaps the most threatened such area in the country. It skirts the M25, in an area with high housing values, between Heathrow and Gatwick and en route to the South Coast at Portsmouth and Southampton. It is an hour from London or less; and property values are high. It is besieged by developers. Our local councils have not been robust in defending our countryside.

Our landscapes – and the views in and out of the Surrey Hills – are of concern to everyone in this area. It is agreed that the views from the AONB, and of the AONB from the surrounding countryside, should be protected landscapes too. It is perhaps a surprise to discover that there is no formal planning role within the AONB, and that the board is not run in the interests of the AONB itself, but by the local councils. (The reason for this is supposedly that those councils make a small contribution to funding the board –but the contribution from each is very small indeed, since we understand around 80% of the funding of the AONB is provided by Natural England.)

 The Surrey Hills AONB is run by the Surrey Hills AONB board. This has representatives from local councils and from other notable entities such as the National Trust, Surrey Wildlife Trust, National Farmers’ Union and CPRE. However, in the past few months the constitution of the Surrey Hills AONB has been changed.

DEFRA gives guidelines about the proper constitution of AONBs that operate conservation boards.  These should comprise:

  • 40% or more local councillors
  • 20% or more parish councillors
  • up to 40% other specialist groups (e.g. National Trust)

 The Surrey Hills AONB board is not a conservation board. It is made up of 75% local councillors who have voting rights and 25% non-council representatives.

Councils do and should have concerns about economic management, economic growth, planning for homes, etc. GGG is concerned that councillors may regard their primary responsibility as being on behalf of their constituent councils, rather than acting in the interest of the AONB itself.

Previously there was no differentiation between voting and non-voting members on the board, so that – theoretically – borough council board positions were in a minority. However, the structural change or codification which has now been approved and which GGG understands has been ratified by all borough councils, means that the board is now controlled entirely by those councils.  Should these councillors decide to approve substantial building projects, this could be voted through. GGG considers that this is unacceptable and in contravention of the purposes of the AONB.

GGG discussed this with the National Association of Areas of Outstanding Natural Beauty (NAAONB) which then consulted with DEFRA on this matter. DEFRA has responded by noting that there are regional variations within AONBs and that constitutions are a local matter.

The only statutory requirement, for all AONBs is that they conserve landscape: “AONBs have the following statutory purpose – To conserve and enhance the natural beauty of the landscape. A Conservation Board has an additional purpose to increase the understanding and enjoyment by the public of the special qualities  of the area”. (Source: DEFRA on AONBs).

However, under the current board, the purpose of the Surrey Hills AONB has already been subverted: the Board website states: “The Board was established in 2008 with the main purpose of; helping to conserve and enhance the landscape, promote public understanding and enjoyment and to strengthen the rural economy of the Surrey Hills area.”. [GGG emphasis].

It is questionable whether this board’s purpose is in fact ultra vires (a legal term meaning, roughly, that the board is proposing to take actions that it does not have the legal power to do). It is certainly morally questionable.

Surrey is an area of almost full employment, with high development pressures. The Surrey Hills is not an area of rural deprivation. In fact, at a Surrey Hills Society meeting attended by some Surrey Hills Board members, it was noted that the area was one where approximately 40% of households included a company director.   The rural economy of the Surrey Hills area doesn’t need much strengthening; and the landscape does need protecting. However, this is not the purpose of the Surrey Hills Board. The published purpose contradicts, in part, the actual statutory function of the AONB.

We think that it is vital that the AONB is run in order to protect and preserve the landscape. It is currently run by councillors who have divided loyalties and responsibilities. Without criticising the individuals concerned, the AONB should be self-standing. A National Park structure would be a clearer, cleaner and more straightforward organisational structure.

It is important that the Surrey Hills is protected. Is an AONB board made up of councillors, the right group of people to act to protect it? Is it right that the AONB should be managed by party politicians? Should it not be managed and controlled by those who are fundamentally concerned with protecting the area, its landscape and its wildlife and who have a track record in doing so? Why have the politicians gained control of the AONB – and who has authorised or approved this change?

 GGG is supported by many individuals and a large number of campaigning groups, residents’ associations and some parish councils across the whole borough of Guildford, in both the rural and the urban area.

Susan Parker, GGG leader, commented:

“The AONB is too important to be left to politicians. It should be run with the clear and unequivocal purpose of protecting the landscape, the wildlife and the countryside. National Park status is a straightforward structure that would allow proper protection and planning control over the area. A change to National Park status would take control of planning here away from the hands of the politicians.”

 Notes for editors 

  1. Further information on GGG is available on the GGG website

Or on its facebook page:

2. GGG public meetings, open to all members of the public, will be held as follows:

  • 9 December 2014 -St Albans Hall Wood Street Village -7.30pm
  • 28 January 2015 -Fairlands Community Hall -7pm

3. Details of the map of the Surrey Hills AONB:

4. DEFRA guidance on the Conservation Boards which govern AONBs is set out here: which states:

“How are the members chosen?

‘AONB Conservation Boards are made up from:

  • Local Authorities appointees,
  • Parish Council appointees, and
  • Secretary of State ‘national’ appointees.

The basic rules determining the size of these groups within a Conservation Board are that:-

  • At least 40% of members have to be appointed by Local Authorities,
  • At least 20% by the parish councils, and
  • No more than 20% by the Secretary of State.

The Chilterns Conservation Board currently has 29 members, and the Cotswolds Conservation Board has thirty six.

Information for Local Authorities/Conservation Boards

Defra has issued guidance notes on the establishment and operation of English AONB Conservation Boards:

5. Surrey Hills board is described on this website: which states:

“The Surrey Hills Board consists of Core (funding) and Advisory (non-funding) members consisting of representatives from local authorities, public bodies and agencies, landowners, land managers and farmers, and other special interest groups.

The Board was established in 2008 with the main purpose of; helping to conserve and enhance the landscape, promote public understanding and enjoyment and to strengthen the rural economy of the Surrey Hills area.

The Surrey Hills AONB unit undertakes work on behalf of the Board and prepares and implements the Management Plan, which formulates policy for the management of the area.”

Members of the board are as follows:

  • Cllr David Wright (Chairman of Surrey Hills Board) – Guildford Borough Council
  • Cllr Mike Band (Vice Chairman of Surrey Hills Board) – Waverley Borough Council
  • Cllr David Mir – Mole Valley District Council
  • Cllr John Stephenson –Reigate & Banstead Borough Council
  • Cllr Lindsay Dunbar – Tandridge District Council
  • Mike Goodman – Surrey County Council
  • Adam Wallace – Natural England
  • David Kennington – The National Trust

Advisory members are

  • Nigel Davenport – Surrey Wildlife Trust
  • Sandra Nichols – NFU (National Farmer’s Union)
  • Liz Cutter – SCAPT (Surrey County Association of Parish and Town Councils)
  • Tim Harrold – CPRE (Campaign to Protect Rural England)
  • Chris Howard – Surrey Hills Society
  • Simon Whalley – Surrey Hills Enterprises
  • Neil Maltby – Surrey Hills Trust

There are therefore now 8 voting members and 7 non-voting advisory members of a total of 15 members. Of the voting members, 6 out of 8 represent local councils, and Natural England is a government quango. Only The National Trust is an independent – non-governmental – voice in relation to decisions made in relation to the Surrey Hills.









Drilling threat to Leith Hill – a response to the planning inspectorate

There is a threat to drill for oil on Leith Hill -the landscape that inspired Ralph Vaughan Williams to write “Lark Ascending”.

This is the email response written by Guildford Greenbelt Group in relation to that application which wrote:

” to object to proposal APP/B3600/A/11/2166561 at Leith Hill on behalf of the membership of Guildford Greenbelt Group.

This is land in the AONB, in Green Belt outside the settlement boundary.

Under NPPF80 Green Belt should protect countryside from encroachment, under NPPF79 the fundamental aim of Green Belt is to prevent sprawl by keeping land permanently open; essential characteristics of Green Belt are openness and permanence. This development would fail all these tests. It is inappropriate development in the Green Belt.
Under NPPF87 inappropriate development is by definition harmful to the Green Belt and should not be approved except in very special circumstances which have not been demonstrated in this case. There is insufficient benefit likely to be derived to justify this inappropriate development. The chances of finding oil are very limited. It has been estimated that there is a 1 in 3 chance of finding oil, which is an inadequate justification for damage within the AONB and GreenBelt. Under NPPF 88 “When considering any planning application, local planning authorities should ensure that substantial weight is given to any harm to the Green Belt. “Very special circumstances” will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations.”. Since the possibility of finding oil is so slim, and since oil can be obtained elsewhere from other sources, this cannot constitute a very special circumstance.

The land in the area meets all the five purposes of Green Belt as set out in NPPF 80. To develop this land would be to encroach onto countryside included within Green Belt. As noted by NPPF 83, once established, Green Belt boundaries should only be altered in exceptional circumstances, through the preparation or review of the Local Plan.

The site is in the AONB, and will create substantial harm to a tranquil area. Under NPPF 115 great weight should be given to conserving landscape and scenic beauty in the AONBs, which (like National Parks) have the highest status of protection in relation to landscape and scenic beauty. The conservation of wildlife and cultural heritage are important considerations in all these areas.

This is a major development in an AONB. AONBs have the same level of landscape protection as National Parks, and major developments should be refused in AONBs except in exceptional circumstances and where the development can be demonstrated to be in the public interest. There are no such exceptional circumstances and this is most definitely not in the public interest, as demonstrated by over 2000 letters of objection received by Surrey County Council to the development. It should be noted that in the Surrey County Council summary of the area it notes that long distance views are a feature of the area; Leith Hill is of course a major tourist attraction of historic and heritage significance and of scenic importance.

Under NPPF 147, minerals planning authorities are required to distinguish clearly between exploration, appraisal and production, and consider constraints on production and processing. Under NPPF 143 and 144, when determining planning applications, local planning authorities should ensure that there are no adverse impacts on the natural or historic environment.

The proposed drilling is within the zone of influence of the Leith Hill SSSI and will have adverse impact on the wildlife. See citation:
There are a number of rare species of wildlife in the area, including red-listed birds such as the firecrest. In fact, Leith Hill Action Group reports that this particular area includes an estimated 0.8% of the whole of the UK’s remaining firecrests and 12% of the local population of this species, which we can ill afford to lose. Such rare birds do not simply resettle elsewhere when they are disturbed – that is why they are so rare in the first place.
Under NPPF 117 and 118, proposed development within or outside an SSSI likely to have an adverse effect on an SSSI should not normally be permitted. Under NPPF 118, planning permission should be refused for development resulting in the loss or deterioriation of irreplaceable habitats, including ancient woodland.

The proposed drilling will take place in an area containing important aquifers and thus risks polluting the water supply.

The development’s 1000+ HGV movements will cause material harm to the delicate sunken lane, which is viewed by the Surrey Hills AONB board as being an intrinsic feature of the AONB.

No traffic management system is feasible, and HGVs will inevitably come into serious conflict with cyclists and pedestrians as well as car users. Given the recent increase in popularity of Coldharbour Lane as a cycling hotspot, there is clear potential for danger to life. There is also serious danger to schoolchildren trying to navigate between Knoll Road and both Powell Corderoy and The Priory schools.

The prospect can be surveyed just as well from a site using lateral drilling techniques. Such alternatives would not have all these problems. If there is oil, it could still be explored and extracted by lateral well structures, with permission limited in the context of the environmental consequences and the impact on the AONB, visually and in terms of traffic movements. Permission should not be granted so as to maximise the profit of the oil company at the expense of the AONB and the population who use it.

As a result this should not be given planning permission. GGG considers that no special circumstances apply which should lead to permission being given.