- Weds 9th March, 8pm: East Horsley Village Hall, Kingston Avenue, East Horsley, KT24 6QT. Organised by the Wisley Action group.
- Tues 22 March, 8pm at the Parish Rooms, Ockham Lane, Ockham, GU23 6NP. Organised by the Ockham and Hatchford Residents Association.
We need people to write letters of objection as soon as possible. To make it easier please see this attachment where WAG identifies some of the errors in the application and the key issues which impact the immediate neighbourhood and further afield Grounds to object2
Interesting story on Get Surrey about how Elmbridge council (which neighbours the proposed development) have responded. It’s not just that they have objected, but they have questionned the validity of the whole process.
Elmbridge Borough Council voted unanimously to raise an objection to the proposal at a West Area Planning Sub-Committee meeting on Monday evening (March 23).
It relates to an application submitted by Wisley Property Investments last December to build 2,100 homes on and around the airfield in Ockham, along with a primary school, nursery, health facility and shops.
Councillor Timothy Grey, representing Cobham Fairmile, believes the whole proposal has been “appallingly managed”.
He said: “I’ve tried to familiarise myself with the planning process of Guildford Borough Council, and if I thought we had problems in Elmbridge – Guildford is well behind everything that we have achieved.
“This is nonsense, and it feeds into the paranoia that this development is being pushed through for nefarious reasons.”
Cllr Grey questioned the lack of consultation from the neighbouring borough before the plans were submitted.
“I cannot understand why Guildford didn’t come to us in the beginning and say ‘We are thinking about doing this, what do you think?’,” Cllr Grey said.
“It is simply untenable – Guildford should have paid us the respect of coming and asking us. I urge them to get their house in order.”
From this week’s Surrey Advertiser: Wisley Airfield campaigners label green belt claims a ‘fantasy’
Campaigners have expressed their outrage after it was claimed that a development of more than 2,000 homes at the former Wisley Airfield site ‘will not cause harm to the green belt’.
The Wisley Action Group [WAG] is casting its collective eyes over the documentation submitted with a planning application which was lodged with Guildford Borough Council earlier this month.
The application, by the Cayman Islands-registered Wisley Property Investments, to build up to 2,100 properties, as well as a school, care home and shops, is now with the council’s planning officers for consideration.
The plans have been described by WAG as a ‘massive assault on Guildford’s green belt’ and the group argues that the very special circumstances which could justify development do not exist.
This week, campaigners discovered an appendix of the application’s planning statement, drawn up by Savills, entitled Green Belt: Very Special Circumstances Statement.
It reads: “The development by virtue of the mix of use proposed, and mitigation measures forwarded, will not cause harm to the Green Belt, or any other harm.”
A spokesman for WAG said: “We are ploughing through the mountains of documentation which constitute this proposed assault on the borough’s green belt and believe it would be inappropriate to make any formal comment until we have a more fully formulated picture of both of the application and its implications, together with the likely impact on the borough.
“The highly contradictory ‘no harm to the green belt’ statement is, unfortunately, just one of many claims which appear to be fundamentally at variance with reality.
“Its author demonstrates a vivid imagination and could undoubtedly look forward to a promising career in literary fiction – albeit in the fantasy genre.
“WAG is discussing the application with legal representatives and will be staging a public meeting during February.”
WPI argues that the former airfield, which is outside the area of outstanding natural beauty, contributes less to the purposes of the green belt than other areas identified as potential sites for major house building projects in the borough.
The company has claimed that more than 60% of feedback at public consultation events in East Horsley, Ripley and Guildford, was either positive or neutral.
Mike Murray, of Causeway Land, the project co-ordinator, said: “With around 70 acres of concrete runway and hardstanding, Wisley Airfield site contains the largest area of previously developed site in the Guildford green belt.
“The new community will combine the best of modern services and countryside living and will feature shops, a school, two nurseries, sports facilities, medical provision, employment areas and a care home.
“Wisley Airfield is the only strategic site in the borough that can realistically deliver significant housing within five years and is one of the best connected strategic sites in the borough.
“There are nine railway stations, including Woking and Effingham Junction, within five miles of the site and consent has already been granted for direct access from the A3 at the Ockham Interchange.”
A spokesman for the project added: “Development is possible in the green belt where justified against very special circumstances, as outlined in our proposal.”
Cllr Monika Juneja, (Con, Burpham) has been charged (August 14) with seven offences, including one count of wilfully pretending to be a barrister contrary to the Legal Services Act 2007.
A police statement said that 35-year-old Cllr Juneja: “… was also charged with two offences contrary to the Fraud Act 2006, three offences contrary to the Forgery and Counterfeiting Act 1981, and one count of pecuniary advantage contrary to the Theft Act 1968 when she returned to Guildford Police Station earlier today.
“The Crown Prosecution Service has been consulted throughout the investigation.
Letter to the Surrey Advertiser…
The Guildford draft Local Plan is not logical or sound because it does not set out the ‘exceptional circumstances’ on which GBC relies to make the most drastic changes to the property rights of everyone living in the Green Belt since 1945.
The Green Belt is intended to be ‘permanent’. So the law provides that it can only be changed if exceptional circumstances necessitate the change.
The NPPF states at paragraph 83:
‘Once established, Green Belt boundaries should only be altered in exceptional circumstances, through the preparation or review of the Local Plan.’
The 2005 UK Government Sustainable Development Strategy paper sets out ‘Guiding Principles’, one of which is
‘Promoting Good Governance: Actively promoting effective, participative systems of governance in all levels of society…’
GBC should justify changing the boundaries of the Green Belt by setting out the exceptional circumstances on which it relies inside the draft Local Plan. It has not done this.
The draft Local Plan: Strategy and Sites document uses the phrase ‘exceptional circumstances’ just once . In para 4.123 the requirement of para 83 of the NPPF is repeated. But no exceptional circumstances are cited. Para 4.123 refers to the Green Belt and Countryside Study (GBCS) and states,
‘This will enable us to demonstrate the level of development we consider we could accommodate…’
Note that it does not state that the GBCS has demonstrated – past tense. It states that it will demonstrate – future tense.
The Green Belt and Countryside Study does not set out any exceptional circumstances justifying moving the boundaries of the Green Belt? Pegasus Consulting expressly state at para 18.5 of the Summmary of Volume V of GBCS Pegasus:
“It is not within the remit of this Study to assess whether exceptional circumstances exist to enable major development,
The only mention of moving the Green Belt boundaries that appears in the draft LP is in Policy 10 Green Belt and Countryside where it is stated:
“The Green Belt boundaries can be viewed on the Policies Map. “
The Policies Map is not included in any of the published documents. You have to go to the Local Development Scheme 2014 to find out more about the Policies Map:
There you learn that the Policies Map has not yet been created and there is no timetable for its creation:
‘Whilst the Policies Map is an LDD it is not proposed to set out a detailed timetable for its preparation. The Policies Map will be revised as necessary upon the adoption of each DPD, as the DPD tables below show. The adopted Policies Map will be revised as and when new LDDs, or their revisions, are themselves adopted.’ (Bold emphasis added. No tables below are apparent!)
LDD = Local Development Document (required by law)
DPD = Development Plan Document
The proposed Green Belt boundary changes are not set out on the Policies Map – because it does not yet exist.
The Public is being consulted about potential boundary changes that have not yet been justified. GBC reserves the right to change the Green Belt boundaries at some later date by reference to an as yet unpublished map which in turn is subject to HRA and Heritage Assessments (and still other stuff) which have not yet been produced (or even started?).
GBC should be accountable for its proposals to move the Green Belt Boundaries. It needs to set out its justification now in the draft local plan not at some point in the future as part of some other document which the Public may never look at.
Why is the draft LP conspicuously silent on the exceptional circumstances upon which GBC purports to rely?
I asked a Guildford Borough Councillor where the exceptional circumstances upon which the Council is relying are set out. This was the response:
‘GBC could now reasonably say they have now set out the ‘exceptional circumstances’ in the Topic paper, but of course these should have been available to all councillors BEFORE we were asked to agree to consultation on the draft Local Plan.’
The Green Belt Topic paper says this (at para 2.13) about the purported exceptional circumstances:
‘There is no definition of what constitutes exceptional circumstances, as this will vary from locality to locality.’
That’s not accurate. The Court of Appeal has defined what exceptional circumstances are in this context.
‘Housing (or employment land) need can be an exceptional circumstance to justify a review of Green Belt boundaries.’
In theory it can. But does it? At this point GBC has not yet completed its Strategic Housing Market Assessment and cannot as yet know whether that gives rise to exceptional circumstances, unless it has prejudged the outcome which would make a mockery of the consultation.
‘There is a combination of factors that exist locally that together constitute the exceptional circumstances that requires us to amend our Green Belt boundaries. This includes the high level of housing need, including affordable homes, exacerbated by a significant backlog of unmet need, the lack of suitable alternative land, the general lack of affordability across the borough, issues with housing mix and employment needs.’
That’s an unsupported assertion. It does not state exactly what the exceptional circumstances are either individually or collectively. Neither evidence nor argument is set out to show that affordable homes constitute an exceptional circumstance. There may in fact be no backlog of unmet housing need contrary to GBC’s assertions. General lack of affordability is not an exceptional factor since it is well known that house prices are cyclical. No evidence or logic for Housing mix and employment needs being exceptional circumstances are set out
I made a Freedom of Information request of GBC to discover what exceptional circumstances it is relying on :
‘Please set out the Legal advice taken by GBC in full stating a) the author of Appendix 4 of the document [which I quoted – which has almost identical wording to the Topic Paper] b) the author of the cited legal advice c) the substance of the legal advice.’
This was the response:
‘The Council’s solicitor considers that the advice is covered by legal privilege and that failure to disclose would not be a breach of the Code of Conduct.’
What about accountability to the public during a public consultation? This is a matter of public policy affecting the entire borough. This is a matter of public interest. Legal privilege is a flimsy pretext not a serious argument. Why does GBC not want to disclose this? Other Councils have disclosed legal opinion. Why won’t GBC?
Many people consider that the ‘public consultation’ is a sham. GBC’s failure to set out and consult upon its case for exceptional circumstances reinforces that impression. It has a public duty to be accountable and transparent about its justifications for the radical changes it proposes, changes which profoundly affect the property rights of everyone living in the Green Belt.