March 24, 2015
Guildford Borough Council
Surrey GU2 4BB
Dear Planning Officer
Planning application REFERENCE 15/P/00012
Location: Former Wisley Airfield
GGG objects to this application reference 15/P/00012 re the former Wisley Airfield. This is a massive encroachment into the Green Belt.
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. No exceptional circumstances have been demonstrated in order to waive the status of Green Belt and so by default this application must be rejected.
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 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. The site is not listed for development under the existing 2003 Local Plan and remains in the Green Belt, so its Green Belt status is clearly determined.
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.” No very special or exceptional circumstances exist or have been demonstrated. It has been confirmed by the Court of Appeal in Hunston v St Albans, and by the Secretary of State, that housing need (even if demonstrated) does not pf itself constitute a very special circumstance. No housing need has yet been determined for the borough.
This site will be visible from the AONB and so will affect views into and of the Surrey Hills AONB, in contravention of NPPF. The resulting impact on light pollution, traffic and infrastructure has been gravely underestimated and proposed mitigation measures are totally inadequate.
The impact of 2,100 houses on the environmentally sensitive TBHSPA cannot be mitigated. Damage will occur to the habitats of the protected and endangered rare species in contravention of the EU Birds Directives and Habitats Regulations. The siting of the proposed Suitable Alternative Natural Green Space adjacent to the SPA will only increase visitor numbers causing further damage to the protected area. Para 119 of the NPPF “presumption in favour of sustainable development” does not apply where development requires assessment under the Birds or Habitat Directives and this fact has been totally ignored by the applicant.
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.
The cumulative impact of development in the borough and in the neighbouring boroughs of Woking, Waverley and Elmbridge has not been taken into account. The additional 5,000 residents is the equivalent of doubling the population of East and West Horsley combined. The proposed housing density is completely out of keeping with the surrounding rural area – five storey buildings are not appropriate in a rural environment. The development will impact the listed buildings adjacent to it such as Yarne, Bridge End House and Upton Farm. There is not enough land to provide a sustainable community based on GBC’s own parameters.
Infrastructure for this project is inadequate. There is no provision for secondary school places – the Howard of Effingham is full and the headteacher has noted that even if the Howard is expanded, there will be no places for children of this development. Medical services will not be provided on site and the concept that sick residents should cycle along narrow, busy roads to a doctor’s surgery is ludicrous.
Any site that is dependent on the increased use of private motor cars cannot be considered sustainable. The proposed public transport provision is unrealistic given the nature of the roads in question and the level of congestion in the neighbourhood
The thought that residents will walk or cycle to a rail station on narrow, winding, unlit roads without pavements or cycle lanes is frankly ridiculous, as is the idea that nursery school children should be transported by bike. Parking at the nearest two stations is at capacity. Additional traffic will have a negative impact and cause irreparable damage to historic houses and other buildings in Ockham, Ripley, Downside and further afield. The closure of a number of local roads coupled with a massive increase in traffic will impact a large number of road users from Cranleigh to Cobham and everywhere in between. This site is not deliverable within 5 years due to problems with sewerage and water capacity as outlined by Thames Water. There is insufficient information on the impact on the water table and flooding in the area.
Not only is infrastructure inadequate, but it will have an adverse impact on existing infrastructure which is already stretched. The proposal includes the site safeguarded for waste under the Surrey Waste Plan which Surrey County Council refused to give up in their response to the Draft Local Plan in September. Thames Water have written to express concerns about the capacity of the existing systems to deal with drainage both from surface water and sewage. . The OCK DVOR air traffic control beacon situated onsite limits development and is still operational.
The air quality surrounding the site gives grave cause for concern as levels of NO2 already exceed the EU limit.
There are a number of factual errors in the documentation – for example Natural England has not agreed SANG provision. There are a number of misrepresentations in the paperwork e.g. nine stations within 5 miles – this is however “as the crow” flies – only Horsley and Effingham Junction are within 5 miles by usable road from the middle of the development.
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