The following letter has been sent by the Wisley Action Group to Guildford Borough Councillors ahead of the meeting of the Planning Committee on April 6 where the proposed development will be discussed.
URGENT
The Guildford Borough Councillors
Guildford Borough Council
Millmead
Guildford Surrey
Copy: Mr Paul Sherman
Dear Councillors,
Re Planning Application 15/P/00012
We are writing to urge you to follow your planning officer’s recommendation to REJECT the Outline Planning application and to recognise the impossibility and damage to the borough of using this site in an attempt to deliver a significant level of housing. This conclusion is supported by over 2000 objections with only 7 in favour from the whole Borough. Your decision should not be deferred due to the amount of time and effort consumed over 2 years and the inability of the applicant to resolve the many issues with the site.
The 14 reasons for rejection recommended by the case officer indicate how little progress this application has made in spite of considerable efforts by council officers and other public authorities’ staff to try to resolve problems with the scheme. The fact is this is not a site capable of this sort of development due to its:
• greenbelt designation,
• proximity to RHS Wisley and Thames Basin Heath Special Protection Area (TBHSPA),
• proximity to A3/M25 bottleneck and Ripley village and roundabouts,
• totally disproportionate attempted location of 2068 dwellings within the ancient village of Ockham with just 159 households,
• the Surrey County Council safeguarded waste site,
• cost of infrastructure required to the detriment of alternative more favourable sites,
• lack of local transport possibilities due to country lanes with no footpaths and cycle ways,
• lack of a coherent plan to meet secondary school requirements
• impact on listed buildings and
• the inability to divert residents and their pets away from the SPA
• the extreme density of the proposed housing with tiny garden spaces
• the site is an unsustainable scheme in an unsustainable location
We believe there are additional reasons to reject this application, as there is better information now available from our experts that seriously question the veracity of some of the applicant’s claims and calculations. These have been forwarded to the planning officer with our objections.
Harm Caused to Area
However as the Planning Officer has stated: “Accordingly, it has not been demonstrated that the level of development could be accommodated without causing significant harm to the character of the surrounding area” leading to the conclusion “ it has not been demonstrated that the benefits of the proposal clearly outweigh the totality of the harm caused and therefore very special circumstances do not currently exist…In conclusion, officers are not able to support the application at this time and accordingly it is recommended that planning permission be refused.”
Not ‘Very Special Circumstances’
One of the criteria is the impact on the greenbelt. In this planning application the criteria used is whether the development meets the ‘very special circumstances’ test in order to carry out ‘inappropriate development’ on the site. This test does not allow the use of housing need alone to represent those very special circumstances. The Planning Officer states “It has not been demonstrated that the benefits of the proposal amount to very special circumstances such as to clearly outweigh the harm to the Green Belt and the other harm identified.”
Integrity of TBHSPA Affected
A key issue for this site is its proximity to the TBHSPA and as a result the recommendation “as the development does not meet the requirements of Regulation 62 the Local Planning Authority must refuse to grant planning permission.” This is therefore not a subjective question. The word MUST informs a great deal. There are many issues with the location as much of the site is within the TBHSPA 400 metre exclusion zone, and as a result threatens the ecology and the wildlife. In addition, the proposed use of SANGS (of which the SANGS on the south side of the development is underwater for almost half of the year and so cannot be used for this purpose) for recreation in the development draws residents and pets to the SPA via the rights of way. This cannot be adequately mitigated with a warden appointed “in perpetuity”.
Pollution to TBHSPA cannot be mitigated
More significantly, the deposition of pollution from the surrounding traffic results in a significant damaging impact on the wellbeing of the heathlands. The current levels of deposition on the TBH heath threatens its survival and so any increment which must arise from an extra 4000 cars will increase the deposition toxicity. As a result, this issue can never be mitigated without removing the topsoil of the heath that would destroy the habitat of the protected ground nesting birds.
The reason for refusal 2 on the SPA should set out the problems with emissions. As paragraph 10.17.6 of the report recognizes, WPIL have failed to consider acid deposition. WAG’s consultants, Air Quality Consultants, also identify problems with NOx emissions and nitrogen deposition. Reason for refusal 2 should therefore be amended to add (before ‘As such the’): “There is a failure to provide adequate information on NOx emissions and nitrogen deposition and to provide any information on acid deposition. Consequently there is also concern that significant harm will be caused to the SPA by emissions.”
Not enough land causing cramped and up to 5 storey development
Other plots of SANGS are double counted due to insufficient developable land. The whole site is 114 Ha of which 50 Ha is required for SANGS and 17 Ha is safeguarded for Waste leaving just 43 Ha for development which is not enough land for 2068 houses. As a result the density proposed for TFM (Former Wisley Airfield) is greater than most London authorities:
Impact on Highways is of Serious Concern
Both Highways England and Surrey Highways expressed serious concern over the development’s impact on major arteries of the A3 and M25 already feeding enormous traffic flow through the County and Borough. Everyone using these roads is aware of the constant back ups and delays with the current levels of traffic. Added to this is one of the most important Horticultural sites in the world resulting in its own needs for traffic to visit and growth. The local network of country lanes is highly constrained so there are very few alternative routes. The officer comments “As such, the application is contrary to the objectives of chapter 4 of the National Planning Policy Framework.”
Local Transport Sustainability Provision Inadequate and Impossible to Solve
Without a reliable and frequent long term committed bus service, appropriate footpaths, cycle ways and adequate train provision within proximity, the addition of 5000 residents and 4000 cars cannot be accommodated in the area as they commute offsite to work, shops and school. The officer concluded “Accordingly, the development is contrary to the policies M4 and M6 of the Guildford Borough Local Plan 2003 (as saved by CLG Direction dated 24/09/2007) and the objectives of chapter 4 of the National Planning Policy Framework.”
Scheme Fails to Secure Affordable Housing Needs
The ambition of 40% affordable housing cannot be provided by this extremely expensive scheme in the wrong location. As is apparent in the report, the Council’s officers do not have confidence that 40% will be achieved – the risk is that viability will be used to justify little or no affordable housing being provided. The minimum housing cost is stated to be £300,000 and will be located a long way from the Guildford urban area and the Surrey University.
Heritage Settings are very sensitive
The need to preserve heritage assets is recognized in the officers recommendation However a key historical heritage site has been overlooked : the listed Chatley Heath Semaphore Tower which is open to the public on weekends and is occupied. It is the best flag signalling tower of its kind in the country and overlooks the site to the south which is part of the heritage to signal across the landscape to southern towers. Placing a 5 storey very high density township in its near (750 metre) sight-line would significantly impact this building as well as many others bordering the site.
The Planning Officer concludes: The development would fail to comply with policies HE4 and HE10 of the Guildford Borough Local Plan 2003 (as saved by CLG Direction dated 24/09/2007) and the objectives of chapter 12 of the National Planning Policy Framework.
We agree the site does not meet exceptional circumstances either and there would be very substantial HARM to the greenbelt with a development of this type in this location with up to 5 storey high dwellings with virtually no garden space forcing a London type density in this open area and pushing residents to use the SANGS area which will naturally lead them on the rights of way to the world renowned Thames Basin Heath Special Protection Area.
It is clear that the high risk of ever achieving this development due to the numerous planning issues means this site should NOT be relied upon to meet the housing needs of the Guildford Borough.
The heritage reason for refusal (9) should also have added as a second sentence:
“The site also affects the setting of the Chatley Heath Semaphore Tower”
The next sentence, ‘This development is’ should be amended to refer to the harm to ‘these designated heritage assets’.
Transitional Provision of Schooling and Construction effect over 12 years
There is no solution prosed for the schooling for the first phase of construction completion for 500 houses. There are NO LOCAL SCHOOLS capable of taking the children from this first Phase. After the school is fully commissioned with 4 Form entry there will be substantial surplus places 600 – 356 who will have to travel onto the site. This is an unsustainable location for a secondary school even with the development proposed.
We object to the impact of construction on site and the traffic flows in the vicinity over a 12 year period to current residents and new residents on site. The difficulty of mitigating this is the whole northern boundary being in SANGS and the 400 metre protection zone for the SPA and there is limited room on the south side which is prone to flooding.
Many Years before the Site Becomes Available So Could not reliably meet Housing Need
The site has substantial infrastructure problems so it would take a considerable time before any housing could be brought forward. There are timing issues with Thames Water of 3 years plus financing, the strategic and local highways, the VOR Beacon which will remain on site at least until 2022, the need for SANGS to be available before any residential occupation takes place, phased delivery proposed over 12 years and many expensive mitigation issues for flooding, sewage, installation of utilities in sensitive areas.
Deferral
We see that the developer is seeking to have the application deferred. It was originally submitted in January 2015 and has since been subject to two major sets of amendments and further information. WPIL have been incapable of resolving the technical issues even despite the hard work of officers in the Council and in other public bodies to work with them. Even some of the matters which ought in principle to be capable of being resolved by legal agreements have fundamental problems: in particular affordable housing and education. It may be that more time would enable the library contribution to be resolved, but that would still leave 13 other reasons for refusal. Major technical issues such as highways should have been sorted out even before the application was submitted. That they are still not resolved suggests that they are insoluble. Delay does not address the fundamental issues of principle with the scheme and the application should be determined and refused.
Conclusion
The development will cause great harm to the surrounding areas and is totally out of character with the rural area into which it is intended to be inserted. The applicant has not been able to resolve any of these over the last 2 years with substantial input from your hard working planning department. It is contrary to the development plan and national policy.
We therefore agree with your planning officer that the application should be REJECTED because it does not meet very special circumstances (nor exceptional circumstances either) and there would be very substantial HARM to the greenbelt with a development of this type in this location with up to 5 storey high dwellings with virtually no garden space forcing a London type density in this open area. Residents using the northern SANGS area will naturally be drawn towards the rights of way which lead straight on to the world renowned Thames Basin Heath Special Protection Area.
It is clear that the high risk of ever achieving this development due to the numerous planning issues means this site should NOT be relied upon to meet the housing needs of the Guildford Borough.
Yours faithfully
Helen Jefferies
For WISLEY ACTION GROUP
