Office of National Statistics data show Guildford Borough Council’s housing numbers are too high

The Office of National Statistics (ONS) has just published new population projection data for the whole country (yesterday, 27/2/2015), which can be found here:

http://www.ons.gov.uk/ons/publications/re-reference-tables.html?edition=tcm%3A77-335242

National Planning Policy Guidance was updated yesterday too, to reflect the fact that this ONS projection, as the most up to date assessment of future housing growth, should be the basis of assessment of housing need – see the new guidelines here:

http://planningguidance.planningportal.gov.uk/revisions/2a/016/

The Office of National Statistics estimates that the population in Guildford borough will grow by a total of 21,600 people between 2012 and 2031.

We have reviewed housing need, taking into account outstanding planning permissions, because these clearly affect the number of homes that will be needed.

Our provisional calculation suggests that an annual housing provision below 400 homes per annum would meet Guildford’s housing needs, including that of any incoming population.  This number is before any adjustment for constraints, such as Green Belt, infrastructure, congestion and air quality.

Why is Guildford Borough suggesting that we need 816 new homes per annum- more than double this?

 

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Guildford BC consultation on the Community Infrastructure Levy

The “Community Infrastructure Levy” or CIL  consultation seems dry as dust, and unbearably technical.  But do please give it a glance.

It’s important to focus on the key issues, and what the problems are.  GBC’s website link is here: http://www.guildford.gov.uk/cil

Note the map of CIL zones on page 3.

CIL is money that developers have to pay to the local council in order to develop land. They pay at the rate below per square metre.  The Council are obliged by law to consult on the levels of tariff (don’t think they are asking out of the goodness of their hearts!).

However, we need to be aware that the differential levels of tariff imply certain levels of predetermination about the local plan, and the tariff rates will have an impact on planning.

The politicians may have told us that the local plan is subject to complete revision – but vote for the existing parties and the plan will go ahead in the version we’ve seen already.  That’s clearly implied by the CIL rates, which are set MUCH lower for greenbelt land than for urban land, and which still show the 3 “Strategic sites” of Blackwell Farm, Gosden Hill Farm and Wisley Airfield as though these have already been agreed (which they have not). The rates are as follows:

Residential:

  • Guildford Town £500
  • Ash & Tongham £100
  • Rural areas and villages £300
  • Slyfield £150
  • Strategic sites £400

Purpose built student accommodation: £75

Assisted care housing £100

Retail £200

Other forms of floorspace £0

What this means is that town centre development will almost all be “other forms of floorspace”, or retail, or student accommodation, because it is so much cheaper to develop that than residential accommodation.  So all residential units will be forced into Ash, Tongham, Slyfield, the rural areas, and the strategic sites. That’s neither in the interest of the residents of the town nor of the country; the town is going to stop being a place to live, and become a major commercial centre with housing squeezed to the periphery.

Note that as ever the online consultation system is “sticky” but you can send your responses as an email.

The GGG response I’ve drafted is as follows:

Qu1:  Charging rates:

Rates for residential (Use Class C3) floorspace
Zone 1 – Rural areas and villages

The rural CIL is too low at £300/m2; it is not clear why this is lower than urban development which is £500/m2. This is not a comment about the absolute quantum, on which we don’t necessarily have a view, but on the relative amounts.  This becomes an incentive to build on the countryside, and is contrary both to NPPG which states that there should be a prioritisation of urban development and to Guildford Borough Council’s stated policy. This rate relates to all land in the borough outside the urban area, proposed strategic sites and area outside the Green Belt. Together with the proposals for development on those strategic sites and on Ash & Tongham, it provides an incentive to build on all areas outside the town. This is contrary to the stated hierarchy of need in the draft Local Plan. It becomes clear that the Council’s plan is to develop the town centre for commercial/industrial/retail use, with some student accommodation, and to force all residential development outward.

It is noted that the land costs for urban brownfield and east Surrey rural greenfield are comparable, and that the remediation costs for urban land are higher; why then have a further cost loading to make building on urban land less attractive compared to rural land?

It should be noted on page 39 point 5.5.14 notes that the rep0rt assumes 14% of dwellings will be allocated to rural and village sites, and 56% to “strategic sites” (most of which are in fact greenfield); so it is likely that around 70% of dwellings will be sited on rural sites.

It is noted that the rural proposed rate “provides a comfortable buffer margin for most developments, with further scope for achieving some site specific S106 contributions.” Why should rural development provide such a buffer to developer’s profitability?

 

 

Rates for residential (Use Class C3) floorspace

Zone 2 – Ash and Tongham (excluding strategic location for growth)

he rate for Ash & Tongham, at £100/sq metre, forces development into the area beyond the Greenbelt. Where the area is urban, this may be an acceptable practice. However, in the rural sections of this area, this is forcing development that is unnecessary and inappropriate on to green fields. There needs to be much greater differentiation within this area of the urban and non-urban sections; this is particularly important here since this is land beyond the Greenbelt which is unprotected by primary legislation, but is still of significance as agricultural land. Agricultural land should probably have a comparable CIL rate to the rest of the Green areas of the borough, and this should be significantly higher than urban land.

 

Rates for residential (Use Class C3) floorspace

Zone 3 – Guildford town (excluding strategic sites)

At £500/sq metre the CIL rates for Guildford town present a serious disincentive for building residential accommodation in the urban area. This is the highest CIL rate in the borough.  It means that any urban redevelopment, throughout the whole urban area of Guildford, is incentivised to be retail, commercial, industrial or student accommodation, but that residential development is being forced into greenfield areas outside the town. This is a prescription for urban sprawl and huge urbanisation of our county town by the back door.  This rate  must and should be lower than the rates for building on strategic sites or on greenfield land.  If the rate for building residential accommodation on urban sites is £500/sq metre, then the rate for building on greenfield land in the borough (whether on strategic sites, outside the Greenbelt or on the Greenbelt) should be set higher, say at £600/sq metre (or, conversely, lower the urban CIL rate to a lower amount than the other rates). This as it stands is a perverse incentive – and, coupled with the proposals for student accommodation at £75/sq metre will force out residential accommodation from the town.

Furthermore, it is noted that this particularly high CIL rate will apply to the entirety of the Walnut Tree Close/Woodbridge Meadows areas, thus creating an incentive for a student housing zone here with industrial and commercial units, rather than the urban regeneration that would be better for existing residents and the town as a whole.

 

Rates for residential (Use Class C3) floorspace

Zone 4: Slyfield

Zone 4 rates for urban renewal zones should indeed be lower, and therefore the rate of £150 /sq metre is welcomed as a relatively lower amount for non-student housing. It is not clear however, why, even in this zone, it is higher than the greenfield areas of Ash and Tongham, or higher than student accommodation, or other uses.  This again is an inconsistent policy which is likely to generate perverse incentives.

 

Rates for residential (Use Class C3) floorspace

Zone 5: Strategic sites

This is odd. Firstly no strategic sites have yet been agreed, because the local plan is not confirmed.  However, the strategic sites are shown on the map, as Blackwell Farm, Wisley Airfield and Gosden Hill Farm, as though they had been agreed – surely a clear case of predetermination, which we had thought was not permitted.

Second there seems a desire to spread dissension between the various campaigning groups, in that the tariff for the strategic sites is set higher than for other greenbelt areas.  It is important to note that the tariff is still lower than for urban areas and so still represents a significant incentive for developers to attack these sites rather than to focus on urban land.  This is not a good thing; and it should not be seen as desirable from the point of view of the strategic site residents either.  The lower tariffs for industrial and commercial use are likely to force such other, undesirable uses on to the strategic sites, encouraging housing into the general greenbelt – with the consequence of appalling urban sprawl and congestion throughout the borough.

 

Rates for purpose-built student residential (Use Class C3/C2/sui generis) floorspace?

It is not clear why the rates for building student residential floorspace are so much lower (£75/sq metre) than other residential use, irrespective of location. If that use were assumed to be on campus, that might seem acceptable and appropriate -but for the rate to be set at this level irrespective of where it is in the borough. This is inappropriate – we need incentive for student accommodation on campus, not incentives to build student accommodation instead of other residential accommodation.

 

Rates for assisted living / extra care floorspace?

No comment – this seems an appropriate form of development in all settlement areas and an incentive for this form of development is not inappropriate.

 

Rates for retail floorspace?

It is not at all clear why this is £200/sq metre, compared to building residential accommodation at £500/sq metre in the urban area. Retail floorspace, whether in or out of the town centre, is lower than any other usage. We do not have a screaming need for more retail, but we do need more housing. In fact, retail commentators have noted that retail operations will shrink in the next few years and less floorspace will be needed for this; why then do we need this perverse incentive?

 

Rates for all other liable uses?

At £0 /squ metre, this is the oddest of all.  Residential accommodation is to be subject to aggressive and punitive disincentive, especially in the town- but “all other uses” – which are not fully explored – are without any cost whatever.  This has to be inappropriate.

These uses include town centre and out of centre offices, industrial factories, warehouses, stores and budget hotels. It is not clear that this is something that the residents of Guildford want to be either imposed on the town centre or the rural areas.

 

Qu 2

Do you have any comments regarding Map 1 in the Preliminary Draft Charging Schedule (PDCS) for the charging zones for residential (Use Class C3) floorspace?

See the comments in relation to Qu 1 above.

It is not clear why the strategic sites are differentiated from existing greenbelt, since until a Local Plan is approved, these strategic sites cannot be so designated.  Until it has been agreed that there are exceptional circumstances which justify their removal from the Greenbelt, the sites of Blackwell Farm, Wisley Airfield and Gosden Hill Farm are all  Greenbelt land.

It is also noted that there is no differentiation whatever in relation to building on the AONB.

It is also not clear why Ash and Tongham are undifferentiated between the urban areas here and the residential greenfield areas, which should be at a substantially higher tariff. There should be a demarcation between settlement areas (which could have an urban tariff) and greenfield sites.

It is not clear why the urban area as a whole is marked as a very high tariff for residential use with incentives for retail, commercial and student accommodation only. First, the desire to expand the retail and commercial activities within Guildford is an aspiration of the current council, which has never been subject to any form of consultation. Second, the residential areas of the town will find themselves swamped with more and more large retail and commercial sites. Better, surely, to opt for medium density housing as proposed by GGG than ever larger centres like the Friary, the new North Street redevelopment, the Quadrant, Solum, etc.

Q3 Economic Viability

Local Plan countdown 3 Do you agree that the proposed rates would not threaten the economic viability of development across Guildford borough?

No. We do not agree with this statement.

The very high rate of CIL attached to urban residential development challenges its viability. We have been repeatedly told that the reason that urban residential development is not achievable – for example along Walnut Tree Close- is that it is not commercially viable. Now GBC is proposing to use inflated rates – among the ten highest CIL rates in the country – not to act as a disincentive for using greenfields or Greenbelt, but as a disincentive to use urban land for accommodation. This is to make clear the intentions of Guildford Borough Council and the current administration, which intends to have the town of Guildford as a commercial, industrial and retail hub, forcing all accommodation into the periphery and triggering urban sprawl. This is not growth but a recipe for congestion, stagnation, pollution and ultimately decay.

Q4 Draft 123 List
Local Plan countdown 4Do you have any comments on the infrastructure included in the infrastructure/ draft Regulation 123 list?

It is concerning that the largest component of the CIL contributions will be allocated to Suitable Alternative Natural Greenspace (“SANG”) and Thames Basin Heath Special Protection Area mitigation measures.  While SANG sounds superficially innocuous, what is implied is a designation of an area of existing green land, probably farm land, as Suitable Alternative Natural Greenspace (ignoring the fact that it was green space already, or it wouldn’t qualify), building a car park next to it, and then using this amount of land as a “mitigation measure” in order to allow building within an otherwise protected distance of the internationally protected Thames Basin Heath.  So this contribution will allow building on green space which is designated as important. This is an almost wholly undesirable measure.

The second  item on the 123 list relates to transport and infrastructure intervention, then other items are also covered. This is perhaps what most would expect CIL contributions to cover. It is of course important to ensure that the impact of the additional building (i.e. the costs of the associated infrastructure) will not outweigh the CIL tariff. GGG does not have the skills to appraise this fully, but it is important to ensure that the actual costs of infrastructure associated with new development are all covered in full by the contributions from the developer. Anything that imposes a cost burden on the existing community can be argued to be unsustainable.   This would include roads, water management including supply, drainage and flood risk, community facilities including education, health service and fire service. Unless these costs are fully met by new development, that development should not proceed because it is imposing a burden on existing communities, which outweighs any cash benefit that is given by CIL.  Why should communities, who are disadvantaged by additional congestion and problems with increased pollution and poorer services, also have to pay for the cost of the new services for the new housing, effectively cross subsidising developer profits?

Q5 Development Viability Study
Local Plan countdown 5Do you have any comments on the Development Viability Study, and in particular on the methodology and assumptions of the study?

GGG has not undertaken a detailed technical appraisal of the viability study. However, certain points are worthy of note.  These demonstrate that there is a considerable degree of pre-determination in the study; that the study is assuming that the superseded, withdrawn local plan will be implemented as put forward last summer, which cannot be a valid assumption; and it assumes that it is acceptable for existing residents to subsidise the cost of development.

Paragraph 2.4.4. notes

“The revised Regulation 14 requires that a charging authority “strike an appropriate [undefined] balance between:

a. The desirability of funding from CIL (in whole or in part) the .. cost of infrastructure required to support the development of its area.. and

b. The potential effects (taken as a whole) of the imposition of CIL on the economic viability of development across its area. ”

In other words, it is national policy (or at least GBC’s consultants assert so) that the existing residents should subsidise developers for wrecking their area. (As glossed by the subsequent paragraphs).

NOTE the clause, in this research commissioned after the local plan was put on hold, in 3.2.1:

“the average annual target for completions in the Local Plan will be around 650 dwellings per annum” – which, given that the SHMA is still in draft, the constraints have not been applied, and the local plan and brownfield land available have not been subject to the promised appraisal, looks remarkably like adherence to the predetermined trajectory.

On page 22 there is a reference to the implications of the draft local plan policies – not that these are the policies in the draft that has now been WITHDRAWN. However, there is reference to spatial development, rural exceptions homes etc.  The council’s own spatial development strategy, or at least promises in relation to this, have not been taken into account in the charging regime.

Q6 Instalments Policy
Local Plan countdown 6What is your opinion of Guildford Borough Council introducing an instalments policy as we suggest in paragraph 22 of the background document?

No comment

 

Q7 Draft Infrastructure Schedule
Local Plan countdown 7Do you have any comments on the infrastructure projects and their costings set out in the draft Infrastructure Schedule?

In relation to the proposed amendments to the gyratory system, and the road systems in central Guildford, it is vital that there is a much wider consultation system for the community as a whole.  It is premature to propose infrastructure projects, much less to put forward costings, without consideration of what is desirable for the borough.  Why are projects being put forward that would facilitate the development of strategic sites before those sites are approved?  Why is there no proper consideration of the cost of the huge population uplift and its impact on the population as a whole? It is unacceptable to mark costs such as “new primary school” or “GPs surgery” as “TBD” (presumably “to be determined”) with the allocation of the cost as “developer contributions”. It is important, before any projects are approved, to determine whether those projects are sustainable from the viewpoint of the existing residents, and to ensure that they are not unduly burdened with the incremental associated costs.  If the developer will not be bearing the full cost of the incremental requirements, which seems likely in most cases from the context of the report, it must be questioned whether those projects can be deemed to be viable not from the viewpoint of the developer but from the viewpoint of the community -and so they should be subject to fundamental challenge.

As an aside, the borough has a habit of recruiting key chosen representatives who are deemed to represent the community as a whole, notably the Guildford Society (GSoc) and the Guildford Vision Group (GVG). It should be noted that neither of these entities has any form of democratic mandate, and that GVG in particular is a strictly limited group of self appointed experts; there is no general acceptance within the borough that they are suitable experts for consultation.  It is noted that a meeting was convened on 16 February involving the GSoc Chairman, Anne Milton MP, Penny Mordaunt MP, Chris Mansfield (head of development), Stephen Mansbridge (leader of the council) and Sue Sturgeon (managing director) to discuss proposed changes to the town’s infrastructure. Such a meeting cannot discuss the best infrastructure for the town and the borough without a wider consultation on what the best infrastructure should be.

Q8 Any other comments
Local Plan countdown 8Please let us know of any further comments you have on our CIL proposals or any of the supporting documents.

The CIL proposals need to be based on a current local plan document, but the local plan on which they have been based has already been withdrawn as unsound and based on inadequate evidence. There is an undertaking to review that local plan and all component elements of the evidence base in order to consider its direction.  These CIL proposals have not taken that undertaking in relation to fundamental redirection into account, and so are not in themselves fully supported.

The fundamental requirements in assessing CIL should be to:

1. ensure that the existing communities will not bear the incremental burden of cost associated with development

2. provide an incentive to use brownfield land for the required housing need.

It is not necessary to provide an incentive for economic growth in an area which is already thriving and economically vibrant, and certainly there is no reason for the local community to subsidise the provision of budget hotels or out of town offices or warehouses on precious agricultural or wild land.

GGG public meeting in Albury- come along!

Guildford Greenbelt Group and

Peaslake Protection Group joint meeting

 

DO YOU LIVE IN TILLINGBOURNE?

 

Are you aware of plans for change in our area?

 

COME TO A PUBLIC MEETING

AT ALBURY VILLAGE HALL

 

THURSDAY 26TH FEBRUARY 2015 at 7.30PM

 

DID YOU KNOW

 

  • 15 000 homes or more are proposed for Guildford

more than 10 000 of these new homes would be on greenbelt land

 

  • 6 000 or more homes will be built between Guildford and Leatherhead

 

  • even the Area of Outstanding Natural Beauty is threatened by housing developments

 

  • a new town is proposed near Ockham

 

What will this do to our area?

 

Guildford Greenbelt Group has led the campaign to protect our Greenbelt over the last two years.

 

Speakers will discuss the threat to our area, what we are facing in terms of huge housing development and future congestion, and how we may be able to protect it for the future.

 

Come along and find out more!

GGG Manifesto now launched

PUTTING OUR COUNTRYSIDE FIRST

 

OUR CORE VALUES:

  • Brownfield land should be used for building before any green fields
  • Housing numbers must reflect real local need not developers’ wishes
  • Existing legal protection for the Green Belt and the AONB should stand
  • Green fields matter – they are not just building land
  • The Metropolitan Green Belt is for the benefit of all

     WHO ARE WE?

  • We have led the agenda for change in relation to planning
  • We formed in 2013. We united opposition to green field building across and around the borough
  • We joined together to oppose Guildford Borough Council’s consultation proposals on housing on green fields in autumn 2013 and led opposition to the draft Local Plan in summer 2014
  • We are a cross-party group with no affiliations to any other party
  • We are standing for both local council and for parliament

 

WHAT HAVE WE DONE?

  • We’ve led debate on attacking the proposed housing numbers, associated congestion and the flawed consultancy work supporting council plans
  • We have highlighted basic procedural and planning errors by the planning department and its consultants
  • The first consultation on the new Guildford BC Local Plan (before we formed) involved building on the greenbelt and was supported by a unanimous councillor vote – we have changed the agenda
  • We’ve highlighted flawed evidence. The Council has spent £5 million on the draft Local Plan so far, including that evidence.   The Council wasted another £150,000 on a further consultation in summer 2014 knowing that the required work had not been completed, resulting in the draft being withdrawn immediately after the consultation ended – a complete waste of public time and money.
  • Without GGG, 16 villages would have already been removed from the green belt, and plans for major development would be much more advanced, including on Gosden Hill Farm, the nationally important Hog’s Back, , and around Wisley
  • We have made formal representations on the flaws within the National Planning Policy Framework and have lobbied for change, including giving evidence to a parliamentary select committee
  • We have asked all our MPs to campaign with us. However, we are not aware of any formal opposition from Anne Milton MP to building on the green belt – and she voted for the National Planning Policy Framework

 

 

WHAT WILL WE DO?

PLANNING A FRESH START

  • Prepare a completely new local plan, based on real local needs
  • Identify 5 year housing needs to avoid “planning by appeal” (note the greenbelt is partly protected from planning by appeal if the local council is supportive).
  • Implement a Brownfield First policy using previously developed land before green fields
  • Build new homes above car parks without cutting parking spaces
  • Conserve all protected sites and nature reserves
  • Stop “land banking” by developers
  • Enforce new design guidelines with conservation/heritage/green requirements
  • Work to change the National Planning Policy Framework, with a local democratic right of veto over major projects

 

ECONOMIC GROWTH

  • Support organic growth for existing local businesses
  • Support agriculture and the rural economy including tourism
  • Support growth initiatives that create high quality value-added jobs

 

 

HOUSING

  • Cut the number of empty homes and clamp down on overseas “buy to leave” speculators
  • Make genuinely affordable tied homes available for key workers
  • Require the University of Surrey to build the accommodation it has promised for existing students and ensure that all additional students are housed on campus
  • Boost shared ownership to help first-time buyers onto the housing ladder
  • Bring forward the proposed Slyfield redevelopment within next 5 years
  • Focus development in places which minimise additional road congestion
  • Ensure developers deliver all the “affordable” homes that they have undertaken to build

 

ENVIRONMENT

  • Stop urban sprawl
  • Promote higher environmental standards and energy-saving incentives
  • Promote improvement in air quality by cutting pollution including vehicle emissions
  • Protect the countryside and urban green spaces
  • Seek National Park status for the Surrey Hills Area of Outstanding Natural Beauty (AONB)
  • Endorse the CPRE “Manifesto for the countryside”
  • Promote public access to the countryside and increase public understanding of the natural environment

 

GOVERNANCE AND ACCOUNTABILITY

  • End the dictatorial Executive form of governance and return to collective decision-making
  • Introduce a committee system immediately on an interim (“hybrid”) basis and formally as soon as legally possible
  • Give power back to parish councils and local residents by seeking and respecting their views
  • Bring in stricter codes of conduct for councillors and council employees based on best-practice standards of transparency, integrity and ethics, including a whistle-blowers’ charter
  • Ensure local government offers transparency in decision making and accountability
  • Remove the party whip from any GGG councillor who has brought the party into disrepute

 

FINANCIAL RESPONSIBILITY

  • Conduct an early review of all council functions including the proposed Millmead renovation
  • Ensure continued provision of high-quality public services, cut inefficiency, consultants and waste
  • Make sure public money is spent appropriately, efficiently and wisely – fiscal prudence
  • Seek greater cost-effectiveness through shared services with other councils

 

CONGESTION TRAFFIC AND PUBLIC TRANSPORT

  • Unlike the current council we will not encourage more traffic in the town centre by out-of-town housebuilding and significant retail expansion
  • Work to minimise through-traffic (including the A3)
  • Encourage rail travel
  • Address congestion by promoting more regular bus services and car sharing incentives
  • Offer free park-and-ride services
  • Improve safety for all road users and create better cycle lanes
  • Improve roads by working with Surrey County Council on potholes and repair

 

RUBBISH, RECYCLING AND STREET CLEANING

  • Increase recycling and enforce high service standards
  • Work for more active cleaning of drains
  • Stop fly-tipping

GGG objection to building next to Sayer’s Croft

There is proposed building next to Sayer’s Croft, the wildlife and natural education centre in Ewhurst. If you, or your children – have been there, you will know what a wonderful educational resource this is, and how it will be wrecked by yet more insensitive crass development.

More is available on a separate post on this here:

https://savesheregomshall.wordpress.com/2015/02/04/sayers-croft-a-charity-teaching-children-about-countryside-and-the-outdoors-threatened/

This is the GGG letter of objection, and all are welcome to borrow from it to use for their own objections.

[Address supplied]

February 13, 2015

Planning Department

Planning Services,

Waverley Borough Council,

The Burys,

Godalming

Surrey GU7 1HR.

 

Dear Planning Officer

 

Location: Land at Penlan and Garden Cottage, Cranleigh Road, Ewhurst GU6 7RN

(near Sayers’ Croft).

I am writing to you on behalf of GGG (Guildford Greenbelt Group), a local campaigning group and political party, of which I am Chair.  GGG objects to this application.

 

Sayers Croft is a wonderful charity that exists to teach primary school children about the outdoors, the countryside and the environment, and that seeks to educate all about the importance of the natural world. It has an impact which is out of all proportion to the scale of the site. Children from across London and the South East have their lives enriched permanently by a significant experience of the natural world.

 

15 000 children a year come to Sayers Croft to learn about the countryside and their environment, many from the inner city.

 

It is now threatened with a building site, and this splendid educational resource is likely to be damaged irretrievably.

 

English Heritage have recommended that Sayers Croft should be designated a conservation area, and this site, should be regarded as including heritage assets.. Great crested newts, a species protected by law, are on the site, close to the area  proposed for development, and as Natural England point out they are protected throughout their life cycle. This is not suitable land for development.

 

Sayers’ Croft have produced some comments about their site in relation to grounds for objection, all of which are endorsed in full by GGG.

 

The NPPF protects views into and out of the AONB, and Sayers’ Croft and its environs are overlooked by the Surrey Hills AONB. This is not a suitable site for development, and our members therefore urge Waverley Council to object to this development.

 

Yours sincerely

 

Susan Parker

 

Chair

Guildford Greenbelt Group

 

Specific objections which are endorsed fully by GGG

 

Heritage:

  • Sayers Croft was built in 1940 and has a rich heritage including a Grade 2 Listed building. The whole site has been recommended by English Heritage to be designated a Conservation Area. Under the National Planning Policy Framework, developers and local authorities must consider the setting of Heritage assets

 

Economic Sustainability:

* Sayers Croft provides employment for over 40 people and provides homes for 27 local people in affordable accommodation. Its business relies solely on providing quality outdoor learning experiences for young people in a rural setting. The raison d’être of Sayers Croft is to provide quality outdoor learning experiences. The majority of children visiting Sayers Croft (around 15,000 per annum) are from inner city London and come to Sayers Croft for the rural setting – to get away from housing developments, traffic, concrete playgrounds – to experience nature in a way they never have had the opportunity to before

* At Sayers Croft there is often noise created by late-night discos, fire drills and alarms, drumming in the woods or simply the sound of 200 children having fun. It doesn’t take much imagination to foresee conflict between the new residents of million pound plus houses and the educational institution

 

Biodiversity:

* Natural England guidance states “Great crested newts, their breeding sites and resting places are protected by law. The law protects them throughout their lifecycle.” Developers and Local authorities have a legal duty to ensure that these animals, which have been found at Sayers Croft less than 50m from the development site, are not harmed. In this case the developers have not shown due diligence in conducting the necessary surveys. If the local authority were to pass this application without due diligence, they too would be negligent.

 

Sayers Croft, a charity teaching children about countryside and the outdoors, threatened!

The endless proposed building plans go on..

Sayers Croft is a wonderful charity that exists to teach primary school children about the outdoors, the countryside and the environment, and that seeks to educate all about the importance of the natural world.

15 000 children a year come to Sayers Croft to learn about the countryside and their environment, many from the inner city.

It is now threatened with a building site.

English Heritage have recommended that Sayers Croft should be designated a conservation area. Great crested newts, a protected species, are on the site, close to the area  proposed for development.

The last scheme was thrown out by Waverley Council – but it has now been resubmitted, with changes.

Sayers Croft need you to oppose this, please.  Anyone can oppose, you don’t need to live in Waverley to do so.

You can sign their petition (I have) and you can write to Waverley Council to object, before 20 February 2015.

More details of how to object are here:

http://us1.campaign-archive2.com/?u=ae7ad7de9f55b03737d20a816&id=d82ca0705b

Do note this ISN’T about affordable housing. The homes planned won’t be affordable homes for young families and key workers. They will be extensive and  expensive. There is more profit in a large home built on a greenfield site  than there is in cheaper flats built in the urban area.

This is part of the proposal to put thousands on homes in and around Cranleigh and Ewhurst – most of which will be large and expensive homes.  That’s in addition to the 13000-15000 proposed for the countryside in Guildford, of which about 70% are planned for the greenbelt and countryside. That’s in part due to the National Planning Policy Framework and the government changes in legislation and guidance to give less and less protection to the environment.

None of the major parties are interested in the countryside or the environment, that’s why we formed Guildford Greenbelt Group. The name is an historical accident, but GGG is a blue/green grass roots party which is dedicated to protecting our environment.  We care about the countryside here, and we will do our best to protect it. We think the political process will help us to do so, and a democratic vote for change will alert government to the fact that their policies are wrong.

This area is precious, vulnerable, and we should work together to save it.

Susan Parker

Guildford Greenbelt Group

 

 

 

GGG – key points for objection to development at the former Wisley Airfield (Three Farms Meadows)

There is now a formal planning application in on the Three Farms Meadows/former Wisley Airfield site.  The developer has applied for outline planning permission. This means that if approved the applicant can change all of the details without going back to the public for any kind of consultation (this includes the housing number, configuration, design) – so much for localism!
This would become the third largest settlement in the borough of Guildford (after the town of Guildford itself and Ash/Tongham).   GGG are discussing the problems associated with this site with Wisley Action Group, who are best placed to advise on this.  There is a huge volume of data to work through.  We have only just started reading through the paperwork and we will not be in a position to give an extensive list of problems associated with this application for some weeks. After some considerable pressure, from GGG, Wisley Action Group and many other concerned residents across the borough,  Guildford Borough Council have now extended the deadline to 31st March for everyone.

The reference is 15/P/00012

If you wish to object now here is an INITIAL list of the very obvious issues:-

– MAJOR AND UNJUSTIFIED ENCROACHMENT OF THE GREEN BELT AND A DANGEROUS PRECEDENT. Impact on the openness of the Metropolitan Green Belt and the negative impact on views to and from the Surrey Hills AONB
– The urbanisation of a rural area (2100 NEW DWELLINGS, OVER 5100 NEW RESIDENTS PLUS STAFFING FOR NEW FACILITIES AND VISITORS with a negative impact on light pollution, air pollution, traffic, infrastructure, SERVICES, roads etc
– NEW RESIDENT POPULATION (AND NUMBER OF DWELLINGS) WILL BE AT LEAST 14 TIMES THAT OF OCKHAM CURRENTLY, AROUND 2 ½ TIMES THAT OF SEND, AND 3 ½ TIMES THAT OF RIPLEY.
– NEW BUILDINGS WILL BE UP TO 5 STOREYS HIGH
– Impact on the environmentally sensitive Thames Basin Heath Special Protection Area, Site of Special Scientific Interest and the Site of Nature Conservation Interest resulting in loss of habitat for a number of protected and endangered species
– INACCURATE nature AND CONTENT of the planning statement and other documents
– No demonstration of very special circumstances to change green belt boundaries
– Housing need IN THE BOROUGH is not yet determined
– Outline planning permission provides a number of loopholes for the applicant to renege on promises which cannot be guaranteed by Section 106 agreements
– Reliance on the motor car and non-existent public transport where there are clear alternatives in locations where access to the train or existing public transport network are feasible
THERE ARE ONLY 2 (NOT 9) RAILWAY STATIONS (HORSLEY AND EFFINGHAM JUNCTION) WITHIN 5 ACTUAL ROAD MILES OF THE SITE AND THESE ARE ONLY REACHABLE VIA NARROW UNLIT COUNTRY LANES AND HAVE CAR PARKING ALREADY AT NEAR CAPACITY (This is an error in the developer’s application)
– Impact on the water table resulting in flooding of neighbouring historic properties
– No REALISTIC account taken of GENERAL ORGANIC GROWTH AND other proposed major developments and impact on traffic and infrastructure
– INEVITABLE MAJOR INCREASE IN TRAFFIC TO AND FROM THE SITE ALONG UNSUITABLE NARROW UNLIT COUNTRY LANES (WHICH ARE AND WILL REMAIN OVERLY DANGEROUS FOR PEDESTRIANS AND CYCLISTS)
– SIZE AND TIMING OF CONSTRUCTION OF PROPOSED PRIMARY SCHOOL ON SITE ARE ISSUES NOT ONLY FOR NEW RESIDENT POPULATION BUT EXISTING DEMAND IN THE AREA. No secondary school allocation at nearby secondary schools – no room to build on site
– Density of development misrepresented and far in excess of surrounding neighbourhoods and villages
– UNSUSTAINABLE PRESSURES ON SERVICES IN NEIGHBOURING VILLAGES (MEDICAL,DENTISTRY, SHOPS, SCHOOLS, PARKING, ETC) WHICH WILL NOT BE MET BY PROPOSED FACILITIES ON THE SITE
– Includes the area safeguarded for waste under the Surrey Waste Plan 2009 which SCC refused to concede in their response to the Draft Local Plan in September
– The inclusion on onsite SANGS (Suitable Alternative Natural Green Space) in mitigation is ridiculous as it will only increase visitor numbers to the SPA rather than draw them away
– Not enough SANG allocated per Natural England response to draft local plan
– Not enough land to provide a sustainable community based on GBC’s own parameters
– Does not concur with the existing Local Plan 2003 where this site is not listed for development

Please email planningenquiries@guildford.gov.uk giving your name and address – residents from outside the borough are able to register their views so letters from the wider area which will be impacted by the traffic increase, hospital capacity shortage, school places etc would be welcomed. We need several hundred people to respond so that Councillors are in no doubt as to what the electorate’s view is.

Please copy the wisleyactiongroup@gmail.com on your response

Thank you to those who have already written.

There is a Wisley Action Group meeting on 25th February at East Horsley Village Hall in the Millenium Room – start at 7.45pm.