This is the text of the Guildford Greenbelt Group objection to Send Marina. This development will lead to building on flood plain, increase flooding and increase road traffic congestion.
25 January 2015
Guildford Borough Council
Surrey GU2 4BB
Dear Planning Officer
Planning application REFERENCE 14/P/02289
Location: Send Marina
I am writing to you on behalf of GGG (Guildford Greenbelt Group), of which I am Chair.
GGG objects to this application reference 14/P/02289 re Send Marina.
This is land in the 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 building/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.
Under NPPF 89 a local planning authority should regard constuction of new buildings as inappropriate in Green Belt – this does not meet any of the permitted exceptions.
The land in the area meets all the five purposes of Green Belt as set out in NPPF 80. To build on this land would be to encroach onto countryside included within Green Belt.
Guildford Borough Council has recently announced that “we have decided to adopt a policy approach which will exclude all development in the green belt, unless it can be demonstrated that the list of constraints in the revised planning practice guidance (including green belt, AONB, flood risk, green space and heritage) can be overcome”. (GBC press announcement published 12 January 2015). We hope that Guildford will implement this policy, exclude this development from the Green Belt and so reject this proposal.
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.
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.”
This proposal will substantially increase traffic congestion in an area already subject to serious congestion. It will also seriously increase the flood risk, which should lead to a presumption of rejection. The infrastructure cannot cope with the proposed development.
The prospect of causing serious pollution should be considered as part of the environmental assessment of this project, including its impact on human health.
As a result this should not be given planning permission. GGG considers that no special circumstances apply which should lead to permission being given.
Guildford Greenbelt Group
Specific objections which are endorsed fully by GGG
- It involves double storey workshops and buildings, toilets and showers, changing rooms and laundry on a green belt site. Guildford has recently been reminded that there is a presumption against development on the green belt. This application ignores it. Exceptional circumstances have to be proved for building on green belt and this application does not begin to do that.
- There is provision for 53 parking places for cars and lorries visiting the site. Tannery Lane, off which the new access road would be built, is narrow and twisty and totally unsuitable for any increase in traffic at all. A big increase in traffic would exacerbate the existing hazard at the junction with Send Road, worsen the traffic problem for Papercourt Lane and threaten the Papercourt Marshes site of special scientific interest. The lane is already at its maximum traffic capacity. It cannot take more.
- It will increase the risk of flooding in Tannery Lane, Wharf Lane and possibly Send Road. This is because the developer does not propose to remove the excavated soil but to raise the level of adjoining land by up to two metres with no surface water abatement. There is flooding already.
- Construction could involve disturbing landfill sites and releasing harmful methane gases. This will be detrimental to the health of Send residents. The proposals are ignoring the noxious, rusty coloured water which oozes out of the landfill and that the proposed buildings would be adjoining a contaminated field.
5.The proposal is massively out of scale with moorings for 80 narrow boats – considerably more than is needed locally. There is insufficient demand for this huge number and it makes no economic sense unless to serve another purpose, namely to open up our precious green belt for housing. The proposed access road would do exactly that.
- A huge marina would destroy the much loved beauty and ambiance of the Wey Navigation. This is supposed to be a Protected Area. It is enjoyed by many Send residents. The existing character and beauty of the stretch from Cartbridge to the Tannery would be destroyed.
- Because of such poor site access the construction upheaval would be prolonged and disruptive. The ongoing noise and light pollution would be deeply damaging to the wildlife on Broadmead and Papercourt Meadow, in particular to the protected bats species which are especially sensitive to this type of disruption. We are fortunate to have a local habitat suitable for some rare birds like lapwings and other wildlife. This can be easily destroyed but can never be recreated. Yet the application has the affrontery to claim that the proposal would improve the habitat and create diversity.
- Some of the land is the best agricultural land in the borough – grade 2 since Guildford does not have any grade 1. It is currently used for growing crops and protected by our current active local plan.
- The application papers, although overwhelming in volume, are riddled with inaccuracies. In some drawings existing houses are shown on the wrong side of the road or not shown at all. Tannery Lane has changed its alignment. What are said to be scale drawings are not to scale at all. The so-called “community consultation exercise” claims virtually one hundred percent support but those who expressed concern have been erased from the records. There may be seventy five documents (which can be purchased for £220!) but quantity is no substitute for integrity.