WEST HORSLEY PARISH COUNCIL. OBJECTION to Long Reach SANG

Transcription

1 WEST HORSLEY PARISH COUNCIL OBJECTION to Long Reach SANG 20 th August, 2016 FOA: Ms Kelly Jethwra, Planning Services, Guildford Borough Council Dear Ms Jethrwa, Reference: Location: Application: 16/P/01459 Land with frontage to Long Reach, Silkmore Lane and Green Lane West, Long Reach, West Horsley. Change of use from agricultural land to Suitable Natural Green Space (SANG) with associated scheme of landscaping including a circular walkway, hedge planting and boundary works, new access works, cycle and car parking, interpretation points, benches and bins. West Horsley Parish Council OBJECTS to the above Planning Application for the following reasons: 1. This application represents inappropriate development in the Green Belt: West Horsley Parish Council (WHPC) believe that no very special circumstances exist that clearly outweigh the potential harm to the Green Belt that this application could cause if it were allowed to proceed. Therefore WHPC believes that this application should be deemed inappropriate development in the Green Belt, as it is in contradiction to the NPPF This is supported by the reference to change of use (agricultural to recreational open space) in the Town and Country Planning Act 1990 (as amended) which states that development in the Green Belt is likely to be considered inappropriate unless it falls within the types of development that the NPPF states should not be considered inappropriate at paragraphs 89 and 90. Recreational open space is not included in these types of development, so change of use from agricultural land to open space is likely to be considered inappropriate development in the Green Belt. The application fails to comply with saved policy RE2 of the Guildford Borough Local Plan In particular, under RE2, point 2, development is deemed inappropriate unless it provides essential facilities for outdoor sport and outdoor recreation. The key word here is essential, as West Horsley already has, and is surrounded by, an excess of parkland and recreation ground, and accessible natural green space as highlighted in the GBC Open Spaces, Sports and Recreation Assessment, June 2016 (Table 19, page 79, additional reference to this document can be found below). Therefore WHPC objects most strongly to this application, as further provision of this type of facility is not required. The site proposed is located at some distance from the saved GBC Local Plan 2003 Settlement Boundary. It is also located outside the proposed settlement boundary in the new GBC Draft Local Plan The openness of the Green Belt countryside to the west of Long Reach across Ripley Lane and beyond to the Surrey Hills is a most important characteristic of West Horsley. This is supported by views of West Horsley residents as shown in the results from WHPC May 2015 Household Survey where 96% of respondents (55% of the total 1121 households) strongly agreed or agreed that West Horsley should

2 retain its rural character, defined by open spaces, parkland and green space. In addition, 92% strongly agreed or agreed that West Horsley should retain the open aspect and strategic natural spaces along East Lane, The Street, Ripley Lane, Epsom Road, and Long Reach, which reinforce the village s rural nature. The local area surrounding the SANG is predominantly characterised by housing on one side of the road, with open fields, pasture, farmland, and woodland to the other. Any development, even that of a SANG, would be totally out of keeping with the character and surrounding countryside of the village. In addition, the introduction of a SANG in the proposed area would have a suburbanising effect on the Green Belt through the intrusion of a car park, signage, benches, dog and litter bins, noticeboards and a height restriction barrier which would be clearly visible from the surrounding area. 2. There is no proven need to provide SANG in West Horsley Parish: The allocation for SANG in the GBC draft Infrastructure Delivery Plan 2016 is based on housing need which has not been proven, and therefore to grant planning permission for this SANG would be premature as no identified need has been established, and is therefore unjustified. The development sites for West and East Horsley proposed in the GBC Draft Local Plan 2016 have been determined by WHPC s Planning Consultant to be unsustainable and unsuitable. The Parish Council has strongly objected to the Sites identified in their response to the Draft Local Plan consultation. The proposed housing numbers in the SHMA for GBC are being strongly challenged by Residents Associations and Parish Councils as the West Surrey SHMA calculations contain at least one major and significant error, which when corrected would lower the unconstrained OAN to 510 homes per year and not the 693 proposed. Further evidence from the CPRE states that the number of required new homes per year could indeed be even smaller, with figures quoted in the 400s. Councillor Spooner, Leader of the Council, has confirmed in a recent press release - Following the Brexit vote, and the publication of the new 2014-based and household projections, we will also revisit both the Strategic Housing Market Assessment (SHMA) and the Employment Land Needs Assessment (ELNA) before submitting the Local Plan to the Secretary of State. This will ensure the evidence underpinning the Plan is robust, up-to-date and accurate. Key references in the Draft GBC Infrastructure Delivery Plan 2016 clearly illustrate that the SANG is being proposed to facilitate new housing development proposed for West Horsley and the 5Km surrounding catchment area, with little mention of the perceived benefits to the local community or wildlife. These include: o Page 35/4.18 Proposed Strategic SANGs - Long Reach SANG has been proposed by the owner of the land. Natural England have agreed that the site can be used as a SANG in principle. A small part of the SANG will be used as bespoke mitigation for the landowners own development and the landowner has agreed that remaining capacity will be available as mitigation for other developments. The map adjacent shows the immediate proposed areas for development beside Long Reach SANG (taken from the

3 Draft GBC Infrastructure Delivery Plan 2016): The map below shows the potential 5km catchment area for Long Reach SANG: o o o Page 37/4.31 Long Reach and Effingham Common SANGs provide mitigation for the east of the borough. This scenario allocates all the proposed development in the east of the borough to Long Reach SANG and none to Effingham Common SANG as a parking area is needed to release Effingham Common s strategic SANG capacity and it is not clear at this stage how many parking spaces and how much SANG capacity can be released (see 4.15). Page 36/4.28 Figure 4 Amount of development proposed for allocations to each SANG 923 houses for Long Reach. Page 40/Figure 10: LAA sites allocated to Long Reach SANG: o Page 87/Table that shows that SANG 8 Long Reach costs are in the region of 7,573,822, to be met by developer contributions. Notably the delivery method has yet to be identified. There has been in further correspondence a vague reference to a suitably worded S106 legal agreement, but again this has not been detailed and has clearly not been thought through, or been consulted on within WHPC as representatives of our community. The focus here is purely on the mitigation for development, NOT on improving the local environment. 3. A bespoke SANG already exists at Ben s Wood, Long Reach, West Horsley, just across the road from the proposed Long Reach SANG. At approximately 8.4 hectares this already more than meets the needs of local residents (8 hectares per 1000 people) and is regularly used by dog walkers from a number of the surrounding roads.

4 Proposed bespoke SANGs We expect the developers of the following sites to deliver bespoke SANGs to mitigate their own developments. These developers are working with Natural England to produce suitable SANG proposals. i. Land at Manor Farm East Lane, West Horsley, land between East Lane and Lollesworth Wood West Horsley (LAA sites 15 and 2063) (Bens Wood SANG) (page 36). 4. West Horsley does not need an artificial, out of character, and potentially less biodiverse environment. Green Reach Ltd claim that the exceptional circumstances for this proposed development within the Green Belt are based on the provision of an additional outdoor recreational opportunity. However, West Horsley already benefits from a considerable number of existing open and natural green spaces for residents and visitors to enjoy. In the immediate area these include: The Surrey Hills AONB and Sheepleas (less than 2km from the proposed site) Barnsthorn Wood, East Horsley Kingston Meadows, East Horsley Ripley, Effingham, Bookham, and Ockham Common RHS Wisley Newlands Corner Hatchlands Park (April to October), and the Estate of the Mary Roxburge Trust (trustees of West Horsley Place) (both on the doorstep) Ben s Wood (just across the road) For those that do not know the area and to illustrate the extent of outdoor recreational opportunities that already exist, Sheepleas is an area of some 110 hectares, located within the AONB, managed by the Surrey Wildlife Trust. This area is well connected to the whole of West Horsley and beyond, through a network of existing green infrastructure. It is used regularly by walkers and dog walkers, with three parking areas, picnic areas, the Millennium viewpoint, and The Coronation Meadow. Supporting images of Sheepleas:

5 This wealth of availability (and more can be provided) is evidenced in GBC s Open Spaces, Sports and Recreation Assessment June 2016, part of the Draft Infrastructure Delivery Plan June , which states that the Ward of Clandon and Horsley has a shortfall across the majority of typologies with the exception of park and recreation ground and accessible natural green space. Therefore WHPC OBJECTS to the proposed provision of this SANG which is a man-made creation, and clearly not essential. 5. West Horsley Parish Council also OBJECTS to the need to provide an additional 2.4km walkway within the Parish. There are already a considerable number of existing footpaths, bridleways and walkways for residents and visitors to enjoy. These included: BOATs at Green Lane west and Silkmore Lane north. A number of permissive footpaths across the road from the proposed SANG that lead around the back of Horsley Football Club, into Ben s Wood, and behind the Horsley Caravan and Camping Club. Also those on the West Horsley Place Estate. A number of Bridleways and footpaths that lead across the fields within walking distance of Long Reach and Ripley Lane. A number of footpaths that criss-cross the surrounding fields and open countryside. Examples from the Horsley Countryside and Preservation Society web site: Those who live in or near to, the Horsleys, are extremely fortunate to have hundreds of acres of open countryside and accessible woods, within easy reach. But many residents who are new to the area, or even some of those who have lived here for some time, may not yet have discovered them all! Included in this section are articles on: The Forest, 44 acres - between the Drift and the railway. The Great Ridings Wood, 78 acres - along the border with Effingham. Oldlands and Effingham Forest - accessible from the A246, Greendene and the Crocknorth Road. Clamp Rough and Gallows Grove, 20 acres - at Effingham Junction. The Sheepleas, 400 acres - car parks at West Horsley Church, Shere Road and Green Dene. Great Bookham Common, 450 acres - car parks near to Bookham Station or at the Hundred Pound Bridge, reached from Downside, Cobham. 6. West Horsley Parish Council also OBJECTS to the loss of agricultural land: The fields in question were classed as good quality arable farmland up until the time of purchase by the new owner. The previous owners terminated their arrangement with a local tenant farmer and he was unable to continue arable farming on this tract of land, although we believe he would have been happy to continue.

6 The land was previously advertised in August 2013 by Smithsgore (now Savills) as predominantly Grade 3 fine loam over clayey soil (Wickham series 4 soil series MAFF Soil Series for England and Wales) suitable for winter sown arable crops and grass leys. Grade 3 is separated into two sub-sections (3a and 3b) which cover good to moderate quality agricultural land. The advertisement stated that The land is currently sown with spring wheat as part of a Wheat, Barley and Oil seed rape rotation. It is also states that The land is subject an Entry Level Scheme until 31 st January 2017 which requires a 6m buffer strip on some of the cultivated land. It is noted that the applicant s own land consultants stated within their Preliminary Ecological Appraisal Issue 6, that the land comprises well managed arable land It is a shame that the land now appears neglected and overgrown, but this is only because of its recent disuse, and does not reflect its true agricultural potential which is reflected in the pictures below: 7. West Horsley Parish Council also strongly OBJECTS to this proposed SANG on the grounds that there is NO legal agreement in place to secure the maintenance and management of the SANG, or to ensure public access to the site in perpetuity. Therefore the proposed development would fail to comply with the saved policy G6 of the Guildford Borough Local Plan 2003 and the NPPF 2012 and should be refused. Although Natural England may have agreed in principle on the proposal, their recent submission to this application suggests that they are NOT confident as to how this proposal will work in practice. Natural England state in their comments on this proposed application that the information submitted with the application is INSUFFICIENT to provide certainty that

7 the site will be maintained and managed effectively in perpetuity as a SANG specifically. In addition they state We have outstanding concerns in relation to the sites functionality as a SANG. These concerns are detailed within Natural England s note, and lead them to conclude that due to their concerns the site CANNOT at this time be considered as a measure to avoid recreational impact on the Thames Basin Heath Special Protection Area (SPA). Notably one of their key concerns is that no management body has been identified for the SANG. West Horsley Parish Council have a number of other areas of concern that form part of our objection that we would like considered: It is the belief of CPRE, and many other bodies of note, that there is no proven evidence that SANG does what it is created for i.e. to provide relief for the TBHSPA. Can Natural England provide this? There is no evidence in the draft GBC Local Plan 2016 evidence base to prove that the creation of new SANG would deliver its objectives, i.e. to preserve the TBHSPA by diverting use to other areas. Without such evidence in place WHPC does not see that there is any proof to suggest that the proposed SANG would deliver its environmental objectives. WHPC are concerned that there are no measures provided within the application to manage flooding: o This site is prone to flooding. The western end is primarily Flood Zone 1, but there is a smaller area identified by the Environment Agency as Zone 3 which floods each winter, adding to the flooding of Ripley Lane. Long Reach floods at north end near junction with B2039 from time to time. There are no measures proposed within the application to manage this. WHPC are disappointed at the limited and selective village consultation: o The applicant s Statement of Community Involvement and List of who was notified is particularly disappointing. o No attempt was made to contact West Horsley Parish Council a major omission given that the proposed SANG is within the village of West Horsley. o The Open Day was arranged in the Ockham Parish rooms on Tuesday 21 st June and not at one of West Horsley s meeting facilities. Indeed had the owners checked with WHPC, the Parish Council were in session for their monthly meeting that evening, and this would have been a good opportunity to discuss the applicant s proposals. o The timing of the event did not allow for those working to attend as the event finished during the day. o The event was not widely advertised within the local community nor indeed within the 5km catchment area affected by this development. o In addition it is very concerning to WHPC that there was extremely limited formal notification by letter of the proposed planning application to neighbours of the immediate area. A list of those written to was requested by WHPC, and was subsequently placed in the list of documents for the public to view, after concerns were raised by residents that some had, and some had not received letters, even though they lived opposite the site. The list shows that 15 letters were issued, but not all were received. Along Long Reach, Woodside, Farley s Close and the smaller lanes that all overlook or have immediate access to the site there is a total of some 140 homes. Even if there are only 2 adults per household that is 280 people that

8 o should have been consulted. This does not take into account the number of homes within the 5km catchment area for the proposed SANG. Whether it is policy or not to only inform a small % of residents affected by any proposed development, for an application of this nature a more consultative approach would have been welcomed, and in WHPC s opinion should have been adopted. Given the lack of marketing and communication within the immediate community by the applicants PR company, it is not surprising that there are no proposals in place for how the proposed SANG would be advertised and signposted to the 5km catchment area, in order to draw people away from the TBHSPA. I trust that these objections and concerns will be taken into account, and that West Horsley Parish Council s recommendation for refusal of this planning application will be acknowledged.