Guildford Local Plan consultation ends Monday 18 July

Don’t forget to get responses in to the Guildford local plan before 18 July.

Details of the plan itself are here:
http://www.guildford.gov.uk/newlocalplan/

and suggestions, ideas and prompts for your own responses (feel free to agree or disagree!) are here:
http://www.guildfordgreenbeltgroup.co.uk/index.php/issues/guildford-local-plan-2016

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Surrey County Council has approved gas extraction at Albury on 13 July

Surrey County Council approved gas extraction at Albury. The local county councillor, Keith Taylor, both spoke and voted in favour of the motion, apparently noting “locally it is not seen as a big issue”.

Surrey County Council has backed plans by IGas to convert an exploration site near Guildford to gas production.

This morning, members of the planning committee voted by eight to two to approve the company’s application to produce compressed natural gas at Albury.

The site, where gas exploration has been carried out intermittently since 1987, is in the Green Belt and the Surrey Hills Area of Outstanding Natural Beauty and has nature and landscape protections.

Councillors accepted the advice of planning officers that national policy to maximise the exploitation of oil and gas amounted to exceptional or special circumstances and that they outweighed any harm from the development to the surrounding area.

For a fuller report see this link:

Surrey councillors approve 15 years of gas production in AONB

Surrey County Council to decide about gas extraction in Surrey Hills AONB on 13/7

A proposal to allow gas extraction at Albury Heath will be decided by Surrey County Council on WEDNESDAY 13 July.

This is clearly urgent – and it has been kept very quiet.

More information is given here:

Go-ahead recommended for gas production in Surrey protected landscape against planning policy

Independent bodies like CPRE have questioned whether it is right to go ahead. http://www.cpre.org.uk/what-we-do/energy-and-waste/shale-gas

The government promised NOT to allow fracking in AONBs (Areas of outstanding natural beauty). We’re told this isn’t fracking, in that there isn’t hydraulic fracturing, but is the production of Compressed natural gas, using HGVs along New Road in Albury. Compressed gas will be moved along our narrow rural roads; there will be some lighting associated with the development and the operation will be 24/7.

Surrey County Council have responsibility for planning in relation to mineral rights and so have the right to determine this. They have claimed that they have carried out 3 public consultations on proposed fracking at Albury Heath, but as far as we know, most residents were not informed.

If you aren’t happy about this, tell your Surrey County Councillor. This is the body that will make this decision and until Friday it will not be binding. There is a very short window to challenge this, but even if the consultation is formally closed, we can complain until the decision is made.

The Surrey County Councillor for the Shere ward is Keith Taylor. You can write to him at:

Keith Taylor
Tara
Send Marsh Road
Ripley
Woking
GU23 6JR

or keith.taylor@surreycc.gov.uk

but in case of non-reply you can copy Surrey County Council

Surrey County Council
Contact Centre
Room 296-298
 County Hall
Penrhyn Road
Kingston upon Thames
Surrey KT1 2DN

contact.centre@surreycc.gov.uk

too.

For background information, although they do not have a vote on this, you can also tell the borough councillors for the Tillingbourne ward (Richard Billington richard.billington@guildford.gov.uk and David Wright david.wright@guildford.gov.uk)

and the Surrey Hills AONB Board (Chairman, David Wright – this is the same David Wright who is the local borough councillor – david.wright@guildford.gov.uk)

and your MP ( paul.beresford@parliament.uk – his secretary is annie.winsbury@parliament.uk)

Letter on Albury gas from Frack-free Surrey

This is a template letter published by Frack Free Surrey, which we have been given kind permission to publicise and which may be a useful template:

APPLICATION NO: GU15/P/02110

 

Proposed development at: Albury Park Wellsite, East of New Road, Albury, Surrey.

Island Gas Limited.

 

Dear Councillor,

I wish to object in the strongest terms to the application by IGas for production at the above site. As you know, planning applications have to be decided against national and local planning policy. The IGas proposals conflict with policies in the:

  • National Planning Policy Framework (NPPF)
  • Surrey Minerals Plan
  • Guildford Local Plan
  • Metropolitan Green Belt

The recent planning officers report defined the proposal as a “major development”. Under the NPPF paragraph 116, planning permission should be refused for major developments in AONBs except in exceptional circumstances and where it can be demonstrated they are in the public interest.

The planning officers accepted the development would have:

“some detrimental effect on the landscape and would not enhance the natural beauty of the AONB during either the construction or operational period.” That the proposal amounted to “significant harm” to the Green Belt by encroaching on openness.

The proposal also breached policies designed to protect the AONB in the Surrey Minerals Plan and Guildford Local Plan.

The Surrey Minerals Plan policies MC2 and MC14 state that minerals developments in the AONB can be approved only if they have been demonstrated to be in the public interest, there is a need for them and there will be no significant adverse impacts on the appearance, quality and character of the landscape.

Policies RE5 and RE6 in the Guildford Local Plan seek to conserve the visual quality or distinctive character of the AONB. Policy RE2 states that new building would be inappropriate unless it prevents sprawl, reserves character or assists urban regeneration.

The planning officers’ report also says that the proposal would harm ancient woodland by creating car parking on the access track. The NPPF says loss or deterioration of irreplaceable habitats, such as ancient woodland has to be outweighed by benefits.

I reject, in the strongest terms, the conclusion of the planning officer that all of the above negative impacts can simply be outweighed by a national ‘need’ for ‘indigenous’ gas supply.

 

The recently released DECC Committee on Climate Change report stipulates that UK onshore gas production should only be permitted

If three vital conditions are in place

https://www.theccc.org.uk/wp-content/uploads/2016/07/CCC-Compatibility-of-onshore-petroleum-with-meeting-UK-carbon-budgets.pdf

– none of these conditions, especially Carbon Capture and Storage technologies, are remotely certain to be met.

 

I implore you to reject this proposal in an AONB as there are no reasonable ‘exceptional circumstances’ and it is clearly not in the national public interest, given our legally binding climate change mitigation commitments, and it is certainly not in the local public interest.

 

Air pollution and emissions

 

The period of gas flaring is very concerning for a number of reasons.

 

The Research Journal of Environmental and Earth Sciences 4(5): 525-528, 2012 states:

‘Gas flares have harmful effects on the health and livelihood of the communities in their vicinity, as they release a variety of poisonous chemicals. Some of the combustion by-products include nitrogen dioxides, sulphur dioxide, volatile organic compounds like benzene, toluene, xylene and hydrogen sulfide, as well as carcinogens like benzo(a)pyrene and dioxins. Humans exposed to such substances can suffer from variety of serious ill-health effects.’

 

No detailed analysis has been produced of the gas to be flared. This is a serious omission from the application.

 

Evidence of gas flaring from the USA and Australia suggests that the total harm caused by flaring pollutants is more than the sum of the individual components.

 

Natural gas processing is a significant source of fugitive emissions of both methane and volatile organic hydrocarbons (VOCs). The World Bank estimates that every year, some 360 million tonnes of CO2 is released to the atmosphere through flaring and venting. This has a detrimental effect on the environment, contributing significantly to global warming and acidification of both land and sea. A considerable proportion of this CO2 comes from the production of Oil and Gas. At a crucial point in human history, if we are to avoid runaway climate change ‘keeping it in the ground’ needs to be the concern of every public authority, and indeed the UK’s Climate Change Act 2008 places legal obligations on public bodies to comply with emission reductions targets relating to climate change. These duties require that a public body must, in exercising its functions, act in the way best calculated to contribute to the delivery of emissions reduction targets. Flaring is incompatible with this objective, which is why there are international calls for ‘green completions’, involving the capturing of the gas – this is not proposed at this site.

 

 

Gas compressor emissions

 

Very concerning for the local population is the proposed notion of powering the gas compressor by burning some of the gas from the well 24/7 for 15 years. There needs to be a detailed analysis of the effects of the exhaust emissions of this from a variety of aspects: human health, ecology, local amenity impacts e.g. from those using the nearby playing fields. Moreover, the effect on vegetation is likely to be very significant.  

 

Traffic and Transportation

 

The increase in vehicle movements is very concerning, given the nature of their load. In effect there will be a couple of tonnes of compressed gas being moved on a daily basis. These vehicles are a serious danger to not only the local population around the site but to those on the route to the ultimate destination. A recent US study, by the National Institute for Occupational Safety and Health, showed that vehicle crashes are the single biggest cause of fatalities to oil and gas workers while the increase in onshore gas production has resulted in a 350% increase in traffic fatalities in regions where gas production is occurring.

 

The roads around in AONB are totally inappropriate for these sorts of vehicle movements, and the villages the HGVs will pass through are densely populated and the roads very narrow in places.

 

I urge you to reject this proposal.

 

 

Yours sincerely,

 

 

 

 

Surrey CC email list

 

tim.hall@surreycc.gov.uk; keith.taylor@surreycc.gov.uk; tim.hall@surreycc.gov.uk; keith.taylor@surreycc.gov.uk; steve.cosser@surreycc.gov.uk; carol.coleman@surreycc.gov.uk; margaret.hicks@surreycc.gov.uk ; ernest.mallett@surreycc.gov.uk; michael.sydney@surreycc.gov.uk; richard.wilson@surreycc.gov.uk; jonathan.essex@surreycc.gov.uk ; marisa.heath@surreycc.gov.uk; mary.angell@surreycc.gov.uk; ian.beardsmore@btinternet.com; stephen.cooksey@surreycc.gov.uk ; will.forster@surreycc.gov.uk; denis.fuller@surreycc.gov.uk; ramon.gray@surreycc.gov.uk; nicholas.harrison@surreycc.gov.uk; peter.hickman@surreycc.gov.uk ; john.orrick@surreycc.gov.uk; adrian.page@surreycc.gov.uk; chris.pitt@surreycc.gov.uk; fiona.white@surreycc.gov.uk; chris.townsend@surreycc.gov.uk;

Surrey County Council to decide on gas production at Albury on 13 July

A proposal to allow gas extraction at Albury Heath will be decided by Surrey County Council on WEDNESDAY 13 July.

This is clearly urgent – and it has been kept very quiet.

More information is given here:

Go-ahead recommended for gas production in Surrey protected landscape against planning policy

Independent bodies like CPRE have questioned whether it is right to go ahead. http://www.cpre.org.uk/what-we-do/energy-and-waste/shale-gas

The government promised NOT to allow fracking in AONBs  (Areas of outstanding natural beauty). We’re told this isn’t fracking, in that there isn’t hydraulic fracturing, but is the production of Compressed natural gas, using HGVs along New Road  in Albury. Compressed gas will be moved along our narrow rural roads; there will be some lighting associated with the development and the operation will be 24/7.

Surrey County Council have responsibility for planning in relation to mineral rights and so have the right to determine this. They have claimed that they have carried out 3 public consultations on proposed fracking at Albury Heath, but as far as we know, most residents were not informed.

If you aren’t happy about this, tell your Surrey County Councillor. This is the body that will make this decision and until Friday it will not be binding. There is a very short window to challenge this, but even if the consultation is formally closed, we can complain until the decision is made.

The Surrey County Councillor for the Shere ward is Keith Taylor. You can write to him at:

Keith Taylor
Tara
Send Marsh Road
Ripley
Woking
GU23 6JR

or keith.taylor@surreycc.gov.uk

but in case of non-reply you can copy Surrey County Council

Surrey County Council
Contact Centre
Room 296-298
 County Hall
Penrhyn Road
Kingston upon Thames
Surrey KT1 2DN

contact.centre@surreycc.gov.uk

too.

For background information, although they do not have a vote on this, you can also tell the borough councillors for the Tillingbourne ward (Richard Billington richard.billington@guildford.gov.uk and David Wright david.wright@guildford.gov.uk)

and the Surrey Hills AONB Board (Chairman, David Wright  – this is the same David Wright who is the local borough councillor – david.wright@guildford.gov.uk)

and your MP ( paul.beresford@parliament.uk – his secretary is annie.winsbury@parliament.uk)

 

 

GGG objection letter to former Wisley airfield

March 24, 2015

Planning Department

Guildford Borough Council

Millmead House

Millmead

Guildford

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.

Yours sincerely

Susan Parker

Chair

Guildford Greenbelt Group

 

 

 

 

Guildford Greenbelt Group asked to comment on Wisley airfield

Guildford Greenbelt Group and a group of local residents have been interviewed on ITV’s “Tonight” programme, aired at 7.30pm tonight ( 5/3/15).  We’ve been asked to comment on the proposed development at Wisley airfield.  That interview will be apparently set against the Adam Smith Institute which has a habit of advocating development on green belt.