Planning Position Statement Dunsfold Park. Dunsfold Airport Ltd

Planning Position Statement Dunsfold Park Dunsfold Airport Ltd

Quality Assurance Site name: Client name: Dunsfold Park Dunsfold Airport Ltd Type of report: Planning Position Statement Prepared by: Tim Havers BA (Hons) MSc MRTPI Signed Date Reviewed by: Guy Kaddish BSc (Hons) DipTP MRTPI Signed Date i

Table of Contents 1 Introduction... 1 2 Background... 1 3 Overview of Waverley... 2 4 New Material Considerations... 2 National Level... 3 Brownfield Land... 3 Green Belt... 3 Flood Risk... 4 Transport... 4 Garden Cities and New Settlements... 4 Local Level and Housing Need... 5 5 Dunsfold Proposal... 5 6 Sustainability... 6 7 Viability and Deliverability... 7 8 Conclusion... 7 9 Next Steps/Collaboration... 7 ii

1 Introduction 1.1 This Planning Position Statement has been prepared by Bidwells on behalf of Dunsfold Airport Limited, to support the promotion of Dunsfold Park for a sustainable, residential-led, mixed use development, to include the expansion of the existing employment area, through the Local Plan process. 1.2 Three development scenarios have been identified in this report, with1,800, 2,600 and 3,400 dwellings respectively for initial capacity assessment and masterplanning purposes. Importantly, each scenario also promotes the expansion and enhancement of the existing Dunsfold Park employment area, which is key to the creation of a truly sustainable settlement. All three scenarios have undergone an initial transport appraisal and have been subjected to modelling testing by Surrey County Council as part of the Local Plan evidence studies. The aspiration for all scenarios is for the development to be an exemplar in terms of both sustainability and design. 1.3 The purpose of this statement is to further promote Dunsfold Park for a residential-led mixed use development by providing an initial planning review through identifying the key planning issues which relate to the re-development of Dunsfold Park in a residential-led mixed use capacity. 1.4 Further work is being undertaken to support the deliverability of the Site for residential led development. Waverley Borough Council have been regularly updated and a detailed formal submission will shortly be made to the Council's Local Plan Issues and Options Consultation which opens on 3 September 2014. 2 Background 2.1 Dunsfold Park is located in the south-east of the Borough and is situated approximately 9 miles south of Guildford, 8 miles south-east of Godalming and just over 4 miles south-west of Cranleigh. The site measures some 248 hectares and contains an operational airfield with fuelling and ground handling facilities, a private motor test track and the largest employment centre in the Borough which accommodates over 100 firms employing more than 700 people. 2.2 The site benefits from a level topography and is bounded on all sides by open countryside which consists primarily of arable farmland and woodland. The main entrance to the site is via Stovolds Hill which leads from the B2130 to the main gatehouse. The Compass Gate, located on the south-eastern boundary of the site provides access from the A281, via Dunsfold Road. 2.3 An application for the re-development of the site to provide a new mixed use settlement was submitted to Waverley Borough Council in April 2008, refused, and the subsequent appeal dismissed by the Secretary of State in September 2009. The appeal was dismissed for two reasons. Firstly, it was considered that on a finely balanced matter the scheme was not compatible with the existing transportation infrastructure of the area at that time, although the Planning Inspector stated explicitly that traffic within the Borough could be expected to increase regardless of whether or not the development was approved and that the amount of new housing required within the Borough would have a major impact on traffic wherever it was located. The Inspector also stated that through a wider assessment as part of the Local Plan process it could be found that Dunsfold Park is a preferable location for development in transport impact terms, hence it was found that the granting of planning permission at that stage would pre-empt the proper consideration of alternatives as part of the development planning process. 2.4 Following the submission and subsequent withdrawal of the Core Strategy from examination on 15 October 2013, Waverley Borough Council is now working on the production of a new Local Plan. The adopted Local Development Scheme sets out the timetable for the adoption of this Plan with a consultation on Issues and Options scheduled to open on 3 September 2014. Due to the size of Dunsfold Park, its acknowledged status as a brownfield site and the significant contribution which it can make to the Borough's housing need over the plan period, it is of great importance that the proposed redevelopment of Dunsfold Park forms part of this consultation and hence this position statement is to inform that process. 1

2.5 There have been significant changes since 2009 in terms of planning policy, Waverley Borough Council's housing need and the Government's commitment to support sustainable garden settlements, all of which provide substantial support for the residential led re-development of Dunsfold Park, which this Statement considers in more detail. 3 Overview of Waverley 3.1 Waverley is a predominantly rural Borough located on the south-western periphery of Surrey. It has a population of circa 120,300 and contains 4 key settlements; Farnham, Godalming, Haslemere and Cranleigh. Farnham is the largest of these settlements, with a population of approximately 36,000 and Cranleigh the smallest, with a population of circa 12,000. 3.2 The Borough faces a number of serious constraints with regard to the provision of land for new housing. Of the 92% of the Borough which is classed as rural, 61% lies within the Metropolitan Green Belt. Furthermore, 80% of the countryside is designated as either an Area of Outstanding Natural Beauty and/or an Area of Great Landscape Value (Waverley Core Strategy Pre-Submission, August 2012). In addition, development within most of Farnham is affected by the town's location within the Thames Basin Heath Special Protection Area (SPA) zone of influence. These physical constraints pose a serious challenge to the Council in its attempt to meet the required housing need within the Borough. 3.3 The future capacity of rail travel within the Borough is under pressure and rail links are orientated on a north-south axis. Bus services are also limited within rural areas. 3.4 House prices within the Borough are significantly higher than the national average and there is an acute shortage of affordable housing. The proportion of owner occupied properties is also high. In terms of dwelling type, the proportion of detached properties is notably higher than the national average and there is a shortage of flatted developments. Waverley Borough Council's draft Strategic Housing Market Assessment (SHMA) (October 2013) identifies this lack of tenure variation as indicating a lack of suitable options for newly forming households within the Borough, with younger families being forced to move outside the Borough due to a lack of affordable dwellings. The SHMA also finds a significantly higher number of dwellings to be required to meet the full objectively assessed housing needs of the Borough. 3.5 With regard to employment, a significant number of the Borough's population travel beyond Waverley's boundaries to their place of work, placing further pressure on the existing infrastructure. Within the Borough, the majority of employment development is located within the four key settlements; however there is also a substantial amount of employment land within the rural areas; in addition to Dunsfold Park as the single largest employment site within Waverley. 3.6 In summary the Borough of Waverley has an identified housing requirement to provide for as part of the emerging Local Plan, but this requirement is challenged by policy designations as to where new development can take place; as well as the need to consider technical issues such as flooding and transport impact. 4 New Material Considerations 4.1 There have been a number of major changes with regard to the planning and transport position since the refusal and subsequent dismissal at appeal of the previous proposal for the redevelopment of Dunsfold Park in September 2009. These new material considerations now weigh significantly in favour of the residential-led redevelopment of the site and it is considered that the current planning position for the promotion of the site is extremely positive and presents a different planning context to the consideration of the earlier application. To consider these leading new considerations: 2

National Level 4.2 The National Planning Policy Framework (NPPF) was published in March 2012 replacing all principal Planning Policy Statements (PPS) and Planning Policy Guidance (PPG). The NPPF is underpinned by a presumption in favour of sustainable development, which it identifies as a golden thread running through both plan-making and decision taking. The document also places a direct requirement upon local planning authorities to 'positively seek opportunities to meet the development needs of their area' and states that 'Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to rapid change' (para.14). This specific and robust requirement for local planning authorities to act positively and proactively when preparing their Local Plan and to meet objectively assessed needs is a result of the government's determination to tackle the current housing crisis. This is emphasised in the Ministerial foreword to the document which directs that 'planning must not simply be about scrutiny. Planning must be a creative exercise in finding ways to enhance and improve the places in which we live our lives'. 4.3 In addition to the NPPF, the live version of the accompanying National Planning Policy Guidance (NPPG) was published on 6 March 2014. This is a material consideration in both the plan making and decision taking processes and provides important guidance in relation to a number of issues which are relevant to the promotion of Dunsfold Park. Brownfield Land 4.4 Following the Inspector's findings in 2009, with which the Secretary of State agreed and Waverley Borough Council accepted; it is an agreed fact that 86% of Dunsfold Park is previously developed or 'brownfield' land. This is of particular significance given not only the NPPF's direction to encourage the reuse of brownfield land (para. 17), but also the recently published NPPG. This reiterates the importance of bringing brownfield land back into use stating 'a core principle in the National Planning Policy Framework is to encourage the effective use of land by reusing land that has been previously developed' (para.24 ID 8-024-20140306) and makes it clear that previously developed land should be developed as a matter of priority. 4.5 In this fresh policy context, the case for the residential-led mixed use redevelopment of Dunsfold Park gains significant weight. Dunsfold Park is a brownfield site of significant and exceptional size, and represents a unique opportunity within Waverley to locate a substantial residential-led development on the policy preferred previously developed land, whilst facilitating the expansion of the site's significant existing employment area. Green Belt 4.6 The NPPF is clear in its approach to inappropriate development in the Green Belt, stating that development that is not specifically listed as being appropriate in the NPPF should not be approved except in very special circumstances (para.87). This is re-affirmed by the NPPG, which confirms that unmet housing need is unlikely to outweigh the harm to the Green Belt and other harm to constitute the very special circumstances required to justify inappropriate development in the Green Belt. 4.7 Nick Boles' letter of 3 March 2014 to Sir Michael Pitt further emphasised the Government's determination to ensure that the Green Belt remains protected, stating that Green Belt reviews should be supported and led by Local Authorities rather than being imposed by Planning Inspectors. The letter also re-emphasises that the NPPF 'makes clear that a Green Belt boundary may be altered only in exceptional circumstances and reiterates the importance and permanence of the Green Belt'. 3

4.8 It is therefore absolutely clear that the weight which should be attached to the preservation of the Green Belt is considerable. Dunsfold Park is a substantial previously developed site which is not situated within a Green Belt location. It represents a sustainable opportunity to accommodate a significant amount of housing, whilst expanding the existing employment area and providing associated local shops and services without necessitating the release of Green Belt land for inappropriate development; an important preference imposed by Government policy. Flood Risk 4.9 The NPPF provides clear guidance in relation to development and flood risk. It advocates the use of a sequential, risk based approach to the location of development and states (para. 101) that 'development should not be allocated or permitted if there are reasonably available sites appropriate for the proposed development in areas with a lower probability of flooding'. The NPPG provides a great deal of further detail in relation to flooding and development and provides clear guidance that the aim is 'to steer new development to Flood Zone 1'. Recent flooding across Britain has heightened the awareness of the issue along with further rhetoric from Ministers that strengthens the Governments' position that flood protection is a leading priority. 4.10 Predominantly Dunsfold Park is not located within an area at risk of flooding, and is categorised as Flood Zone 1. A small area of the site, located on the eastern periphery, is located within flood zone 2 and a smaller part still is flood zone 3. In the context of the site as a whole this represents a very minor constraint. Importantly, the deliverability of the development scenarios identified is not dependent upon built development within this minor area of the site and it is not required for the viable redevelopment of Dunsfold Park to be delivered. 4.11 In terms of a sequential approach to development and flooding, as required by the NPPF, it is therefore clear that Dunsfold Park is a location to which development should be directed, and it is a site which is capable of accommodating a sustainable, residential-led, mixed use scheme, without placing existing or future property at risk of flooding. Transport 4.12 With regard to transport, the key reason for the dismissal of the previous appeal, the NPPF again provides a new material consideration which weighs heavily in favour of the residential led development of the site. The framework states at paragraph 32 that 'Development should only be prevented or refused on transport grounds where the residual cumulative impacts of development are severe'. This directive that preventing development on transport grounds is only justifiable in severe cases is reinforced by the Government's recognition that opportunities to maximise sustainable transport will not be consistent across rural and urban areas (para.29). It is therefore clear that the approach to assessing highway impact is now different and the policy test is less onerous. Garden Cities and New Settlements 4.13 The NPPF states at paragraph 52 that 'the supply of new homes can sometimes be best achieved through planning for larger scale development, such as new settlements that follow the principles of Garden Cities'. It goes on to state that 'local planning authorities should consider whether such opportunities provide the best way of achieving sustainable development'. This support for the garden settlement was echoed in the Government's publication of a garden city prospectus on 14 April 2014. 4.14 The re-development of Dunsfold Park in a residential-led mixed use capacity provides a unique and sustainable opportunity within Waverley to create a new settlement which can make an important contribution to the supply of new homes within the Borough, over the plan period, in a manner that is supported either in principle or in spirit by Government guidance. 4

Local Level and Housing Need 4.15 At the local level, the planning position has also changed significantly. Waverley Borough Council's Core Strategy was withdrawn from submission in October 2013, following the Inspector's concerns in relation to a number of issues. These included the need for a new Strategic Housing Market Assessment (SHMA), which considered the market area as a whole, and the Core Strategy housing total. With regard to the latter, the Inspector felt that the Council was reluctant to depart from the 230 dpa total figure which had been derived from the (revoked) South East Plan process as a matter of principle. 4.16 The Inspector found that a reconsideration of the Borough's capacity to accommodate new housing need in the light of the National Planning Policy Framework was required, with the Council to take a positive approach to providing the scale and mix of housing identified in any updated SHMA. 4.17 A new SHMA was subsequently commissioned, and the draft document published (October 2013). The findings of the draft SHMA are significant, with the identification of around 470 homes per annum (8460 homes over the 2013 2031 period) being given as an objective assessment of full need for market and affordable housing. This represents a sharp increase from the target of 230 homes per annum adopted in the Waverley Borough Council Pre-Submission (August 2012) Core Strategy. It is clear that Waverley will now need to provide significantly more new homes over the plan period than the previous Core Strategy allowed for; a significant new material consideration. Dunsfold Park is an important component in this evaluation, and has the ability to make a significant contribution to the Borough's ability to meet the objectively assessed housing need over the new plan period. 4.18 It is also noteworthy that the principle of significant levels of development at Dunsfold Park has been actively promoted by Waverley Borough Council. Policy CS10 of the withdrawn Core Strategy set out the Council's support for the expansion of the existing employment activity at the site and recognised the potential of Dunsfold Park to accommodate substantial amounts of sustainable development. This policy serves to demonstrate Waverley Borough Council's clear recognition that Dunsfold Park is an acceptable location for additional large scale sustainable development. 4.19 In summary, it is therefore clear that the planning policy context has changed considerably since the submission of the previous application for the re-development of Dunsfold Park and the production of Waverley Borough Council's withdrawn Core Strategy. There are now a number of significant, new material considerations, at both the local and national level, which greatly strengthen the planning position for the residential led, mixed use re-development of the site. 5 Dunsfold Park Proposal 5.1 The proposal is for the allocation of Dunsfold Park for a residential-led, mixed use development which would be an exemplar in terms of both sustainability and design and would facilitate the expansion and enhancement of the existing Dunsfold Park employment site. The scale and mix of development will be subject to an environmental, design and capacity led review which responds to the site's specific constraints. A range of development options will be considered. The development will respond positively to its surrounding context and will place a significant emphasis on forming the foundation for sustainable development. A variety of dwelling sizes, designs and layouts will be included, with a focus on creating a built environment which is capable of meeting the housing needs of all sectors of society, whilst ensuring an interesting and diverse living environment with carefully incorporated, usable green spaces. 5.2 The current employment base, the largest in the Borough, would be enhanced and expanded and the focus of development will primarily be on the previously developed area of the site. An initial capacity assessment exercise has identified an indicative location for a central core of the settlement with increased connectivity across the site. The provision of carefully planned and co-ordinated local shops, services, educational facilities and recreational facilities will be key. The capacity exercise has also confirmed the ability of the site to accommodate a large quantum of mixed use development, in a sustainable manner, whilst respecting the existing site constraints and wider landscape context. 5

5.3 The proposal will maximise the effective use of land, making full use of a previously developed site, subject to responding to environmental, social and economic impacts. The sustainability value of achieving this level of development without needing to release a greenfield site is extremely significant and represents a unique opportunity to allocate a strategic level, residential-led, mixed use development within the Borough. 5.4 The below table provides an initial high level site capacity overview. It is acknowledged that space for, in particular, local centre and commercial development will need to be accommodated. However, at this initial stage, the purpose is to demonstrate that the different development scenarios identified can be realistically accommodated in masterplanning terms. 5.5 All densities are indicative only and each demonstrates only one way in which the land could be developed as part of the capacity testing. Development 1 2 3 Scenario Dwellings 1,800 2,600 3,400 Population 4,248 6,136 8,024 (2.36ppd) Gross Density 7.3dph 10.5dph 13.7dph (Whole Site 248ha) Average Density (Assumed Developable Area @ 142.43ha) 12.6dph 18.3dph 23.9dph 5.6 The above table identifies three development scenarios which have been tested in the development capacity process and demonstrates that each scenario would be at a density of development that could be appropriately and physically accommodated on the site. 6 Sustainability 6.1 Sustainable development is identified in paragraph 14 of the NPPF as being the golden thread running through both plan-making and decision-making. The promotion of the site will continue to be centred on the principle of sustainable development. Dunsfold Park has many unique opportunities in terms of sustainability through a carefully planned new settlement to capture these and deliver a significant amount of much needed housing within Waverley Borough. 6.2 The re-development of the site would deliver not only crucial new housing, including affordable provision, but would include the provision of carefully planned local shops, services, educational facilities and green spaces, whilst enhancing and expanding the existing employment area on the site. It is the ability to provide this mix of uses which will allow the site to become truly sustainable, and maximise the self- containment of the new settlement. 6.3 The earlier planning application was acclaimed by the Secretary of State and the Planning Inspector as having a high aspiration for sustainable development, to the extent that Friends of the Earth formally supported the development. The same aspiration for sustainable development remains. 6

7 Viability and Deliverability 7.1 The deliverability of the site is a critical matter, which includes ensuring that a development is viable. It is recognised that ensuring these matters are properly considered from the outset is of the utmost importance and in this regard a specialist consultant team has been formed for this express purpose. An initial, high level viability appraisal has been undertaken, to provide the confidence that the site is capable of delivering a viable residential-led mixed use scheme which will facilitate the expansion of the existing employment area and provide associated local shops and services. 7.2 Subject to a suitable Local Plan allocation the intention is for the delivery of housing and associated services and the expansion of the employment area at the site to commence very early on in the Local Plan period, with options to phase delivery over time. 8 Conclusion 8.1 This Planning Position Statement has been prepared to provide a brief account of the planning context in support of the promotion of Dunsfold Park for a sustainable, residential-led, mixed use development through the Local Plan process. 8.2 It is clear that Dunsfold Park presents a unique and sustainable opportunity for the creation of a new settlement, further supported by the concept of the Government's garden communities agenda. The redevelopment of a largely brownfield site, which is not at risk of flooding and is not subject to the constraints and designations which the majority of Waverley is, must be given serious consideration. The site has the ability to accommodate a large amount of new housing whilst promoting the expansion of the existing employment area, as part of a residential-led mixed use scheme. This will make a significant and urgently required impact upon the substantial housing need identified within the Borough in the October 2013 SHMAA and ensure that one of Waverley's key employment sites is both expanded and enhanced. 8.3 It is for these reasons that Waverley Borough Council should take forward a preferred allocation for Dunsfold Park for a residential-led mixed use development. 9 Next Steps 9.1 In common with the Council's time frame for the forthcoming Issues and Options Consultation, a full submission will be made by October 17 th 2014 in support of the promotion of Dunsfold Park for residentialled mixed use redevelopment. 7