Item No: 6
Date: 12th April 2017
Report: Planning Adviser’s Annual Report 2016/2017
Written by: Clive Smith
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Purpose of Report
To report on the work of the Board’s Planning Adviser in 2016/2017.
Summary
This is a report of your Planning Adviser’s eighth year of appointment. It sets out the national and emerging local planning policy context affecting the Surrey Hills AONB and the main risks to the future integrity of the AONB. It updates Board Members of the latest local plan positions of constituent Surrey Hills planning authorities. The report covers the Adviser’s increasing work in responding to local authority consultations on planning applications and local plans. This is an opportunity for Members of the Board to comment on any issues arising.
Recommendation
Members are asked to note the report.
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Background papers: None
Contact details:
Author: Clive Smith
Job title Surrey Hills AONB Planning Adviser
Contact no: 01372 220655
1. National Planning Policy.
1.1 The NPPF is still the national planning policy document supported by several Planning Practice Guidance documents on various subjects. Concerned that insufficient new housing is being built the Government is currently consulting on its Housing White Paper “Fixing Our Broken Housing Market”. It says little about National Parks and AONBs but at the same time does not seem to weaken their protection.
1.2 However, given the understandable clear thrust for more housing, the fear is that some decision takers may give more weight to that factor than protected landscapes. Part of the problem of insufficient new housing has partly been of the Government’s own making in abandoning regional plans. They provided for more housing growth and directed it to where it would be most beneficial both locally and nationally. Had those plans not been abandoned more housing development would recently have taken place. Also, the Government has not continued its past successes of providing the carrots for development in locations where nationally it would be most needed and in designating new towns such as Milton Keynes. This co-ordinated national planning approach would take the pressure off Protected Landscapes and Green Belts.
1.3 So far planning decisions by the Secretary of State, Inspectors and Planning Authorities involving Protected Landscapes or their settings are being made on a case by case basis with judgements varying between the weight being given to considerations of landscape protection and the need for more housing. No trend seems to be emerging between these priorities. Any suggestion of the Government, and possibly also some Councils, concluding that the need for more housing outweighs the protection of designated landscapes would be of great concern for the long term future of this national asset.
1.4 Interestingly, the Government Natural Capital Committee has found that Green Belts and protected landscapes indeed have an economic value to the nation. Their value as national assets seems to have been overlooked by some who see only the more obvious shorter term benefits of economic growth. The Committee’s conclusions of the benefits being greatest where protected landscapes and Green Belts lie near large populations and can promote health, well being and recreation is no more so in the national context than in the Surrey Hills AONB which is within the London metropolitan Green Belt. A more joined up national approach seems to be needed.
1.5 The planning adviser does liaise with other AONB and National Park Planning Advisers through Protected Landscapes Planning Officers Group Meetings. It appears that the influence of other Protected Landscapes Planning Officers on relevant planning decisions and local plans varies. In a few cases where the Protected Landscapes are not within the Green Belt some planning authorities have been allocating housing sites where they have little option. It also appears in some areas AONB designation is not as well recognised or possibly valued by local people as in Surrey. The situation is different in National Parks as they are the Planning Authorities. Few people know that Central Government through policy in the NPPF gives the same protection to the landscape and scenic beauty of AONBs as National Parks.
2. Local Plans.
2.1 Two emerging local plans have been particularly prominent in the last year, that of Waverley and Guildford.
2.2 Waverley Borough Council decided to submit their previous consultation draft local plan for it to be examined by an independent Inspector. In order to progress the local plan without delay only minor revisions to the consultation draft have been made even though it resulted in many objections from local communities. At the time of writing no date has been given for the Local Plan Examination in Public.
2.3 The Waverley Inspector is the same as has recently submitted his interim findings on the Mid Sussex Local Plan. He concluded the already seemingly high annual housing figure in the plan of 800 dwellings per annum should be increased to 1,026 dpa. Mid Sussex is not within the Green Belt. The Council had contended that to increase the figure to 900 dpa would result in the release of 12 sites in the AONB to provide for 300 dwellings. The Inspector did not consider that was sufficient reason to discount them as the Council needed to show that even with mitigation they would still cause harm to the AONB.
2.4 The Waverley Local Plan has proposed several AONB sites at Milford and general areas, like at Chiddingfold, for possible housing to be investigated in a future Part 2 of the Local Plan. The plan also identified sites in the AGLV for housing development. Concern was expressed on behalf of the Board whilst recognising that the Council is severely constrained in its ability to meet its full objectively assessed housing needs without avoiding protected landscapes and the Green Belt.
2.5 Those proposed provisions in the Plan may be sufficient to satisfy this same Inspector. However, the Inspector’s questions put to the Council demonstrate a marked pro development approach. If they are not just being devil’s advocate it is a worry. He has questioned whether the AGLV should be protected as proposed in the Plan in a similar way as the AONB pending the AONB Boundary Review. The Council’s response has been that the policy accords with the conclusions of all the other Local Plan (Core Strategy) Inspectors in the cases of the recent Reigate and Banstead Core Strategy and the earlier Mole Valley and Tandridge Core Strategies. The Council has suggested a qualification to the policy which now reads as follows with the additional wording in italics.
“The same principles for protecting the AONB will apply in the AGLV which will be retained for its own sake and as a buffer to the AONB, until there is a review of the Surrey Hills AONB, whilst recognising that the protection of the AGLV is commensurate with its status as a local landscape designation”.
2.6 How the Council and Inspector will handle the issue of the Plan’s allocation of 2,600 dwellings at Dunsfold Aerodrome now that the Secretary of State has called-in for his own determination the planning application for 1,800 dwellings on the site is unclear. The issue of whether there should be a new settlement at Dunsfold is central to the Plan’s housing strategy.
2.7 In 2009 an appeal was dismissed for a similar application by the Secretary of State following an Inspector’s report and recommendation. The rejection was because the new settlement would be in an unsustainable location where the highway network was inadequate and there was no public transport. If anything the unsustainable development case is now even stronger, including greater the problems with the capacity of the A281 into Guildford. However, the Waverley Local Plan consultation response showed significant support for the new settlement from the majority of respondents elsewhere in the Borough understandably preferring this location for development rather than nearer to where they live. Although the development would lie just outside the AONB the main concern is that with an inadequate highway network and lack of public transport, motorists will divert onto several unsuitable country lanes passing through the AONB undermining the relative tranquillity and character of those areas.
2.8 The current version of the Draft Guildford Local Plan, in spite of proposing substantial development growth, has commendably avoided allocating any sites for housing within the AONB. Those objecting to the western extension of University owned land for housing development to the north of the Hogs Back are concerned that the development would spoil the setting of the AONB. Further, that a Landscape Character Assessment concluded that parts of the site should be included in the AONB. The Council will be consulting on proposed changes to the previous draft plan this June/July before deciding on the local plan to be submitted to the Secretary of State with an Examination in Public probably early next year.
2.9 Responses on behalf of the Board have been submitted to consultations on several emerging Neighbourhood Plans. None has caused any AONB concern.
2.10 Unlike Guildford and Waverley, Mole Valley and Tandridge both have formally adopted Core Strategies based upon the former South East Regional Plan. Those strategies need updating and so both Councils are working on producing their consultation draft local plans. Tandridge has recently announced that it will be proposing a new settlement of about 4,000 dwellings to make a major contribution to meeting its housing requirements. No site has been announced yet but is unlikely to involve the AONB or AGLV. Reigate and Banstead’s Core Strategy is more up to date and consequently the Council is preparing more detailed policy documents.
Community Infrastructure Levy (CIL)
3.1 The Statutory Members Group is anxious for Councils to provide within their Community Infrastructure Levy (CIL) documents scope for CIL payments to be directed towards projects within the Surrey Hills AONB and for bids to be made. So far the CIL documents do seem to provide for Councils to direct payments towards landscape enhancement projects. However, such bids have to compete against other big players such as education, highways and health. Councils will only likely consider such bids where specific projects have been identified within their authority boundaries and not generically.
3.2 A report needs shortly to be brought before the Board to agree the best approach to make successful bids that bring investment into the AONB to help mitigate the increasing recreation and development pressures. The Board does not have an executive in the same way as the County, Borough and District Councils or even Parish Councils. It is more an enabler and persuader. In this context to attract CIL funding towards the management of pressures on the AONB and its enhancement, specific projects need to be identified possibly through consultations with Parish Councils and other relevant stakeholders. Such projects might include:
· providing public rights of way directional finger posts with Surrey Hills logo and distances and identifying and creating off road cycle and equestrian routes,
· identifying the creation of currently hidden potential inspiring views, agreeing them with landowners and financing tree and shrubbery clearance, seating, their future maintenance and where necessary improved access and,
· creating with Surrey County Council a distinctive Surrey Hills Quiet Lanes Project to be jointly financed.
If any Board Members have other ideas for suitable projects or thoughts on the above, please raise them at the meeting or subsequently with the Director.
4. Surrey Hills AONB Boundary Review.
4.1 Natural England’s latest estimate for commencing work on the boundary review is next year once work on the boundary review for Suffolk Heaths and Coast has been completed.
4.2 The continued lack of progress on the Surrey Hills AONB Boundary Review creates uncertainty and confuses the situation over the status of the AGLV in local plan preparation. The 3 Core Strategies so far adopted give similar protection to the AGLV as that applied to the AONB until the Boundary Review has been completed. However, as outlined in paragraph 2.4 above this approach has been questioned by the Waverley Local Plan Inspector.
5. Planning applications.
5.1 The Planning Adviser responded to 293 planning application consultations in the financial year 2016/17, up from 211 in 2015/16 and 156 applications the year before. The figure is about triple than when the Adviser was appointed 8 years ago and almost twice that of two years ago. The increase does not reflect a corresponding increase in applications submitted to Surrey Hills planning authorities but an increase in applications Councils seek protected landscape advice, including in some cases within the AGLV. In order to manage the workload Tandridge Planning Department has been asked only to consult on significant development proposals within the AGLV. The same may need to be sought of Reigate and Banstead. The problem is that the Core Strategies of both authorities apply similar AONB protection to the AGLV as mentioned earlier.
5.2 Site visits in all cases is not always possible. Where none has been made the advice refers to it being based upon a desktop exercise. A particular regret is there is not the considerable time to prepare for and attend Planning Inquiries and Hearings to support Council’s AONB or AGLV reasons for refusals. Inspectors will still have before them to take into account the original reports submitted on behalf of the Board.