Consultation on Waverley Potential Housing Scenarios

SURREY

CONSULTATION ON WAVERLEY POTENTIAL HOUSING SCENARIOS

CPRE Surrey has reviewed the Consultation Paper and the supporting documents and has the following comments to make. We have also completed the short questionnaire. The volume of supporting documentation to study was very considerable and we are likely to wish to make further comments, based on a more complete study of those documents at a later date.

1.FLAWS IN THE HMA

We believe that the GLHearn draft HMA is flawed and too biased in favour of developers' aspirations and those of their alleged potential customers. We strongly believe that their calculations need to be independently tested particularly as evidence of true local need is, we think, significantly less than GL Hearn's adjusted figures of alleged demand. In addition, too much reliance is based on theoretical projections (rather than a workable forecast) for net inward migration from London; the 470 number in the WSHMA is potentially so damaging to the character of the borough and the quality of life of its residents that the expenditure involved in such testing would be well justified; we believe that the result would be a lower and more realistic assessment of need, which could stand up to challenge at the Public Examination. We comment further on the draft HMA below.

2.MEETING OR NOT MEETING NEED

We believe that a fault of the consultation (which will result in misleading responses) is that it implies that the need identified by GL Hearn has to be met in full. Paragraph 47 of the NPPF makes it clear that identified housing need may not be accommodated in full unless Waverley can be satisfied that meeting those needs will not be in conflict with other policies within the NPPF. These of course include, critically, the principle of sustainability as well as specific policies for the protection of Green Belts, AONB and AGLV and other intended inhibitions on the location of housing development. It is therefore necessary that the recommendations of housing need take proper account of the Sustainability Assessment and the infrastructure needed to serve new development. It is clear that there are serious concerns that the ability to meet new demands for schools, roads, water, energy, health services etc cannot be met to accommodate a 17% increase in housing provision over this period.

In part this is the result of topography: in some parts of the Borough the current road system is already overstretched and the inevitable additional road traffic cannot be alleviated by new or widened roads which in any event could not realistically be financed. A large increase in road traffic on Waverley’s mainly rural road system is, on all the available evidence, likely to result in gridlock over large parts of the Borough and wider afield. The failure to invite

comment on this issue in Making Waves renders the consultation of questionable value and invites members of the public to make choices on the basis of inadequate information.

3. 2014 PLANNING GUIDANCE ON NEED

The Planning Guidance published on 6th October 2014 makes it clear that need alone is not the only factor to be considered when drawing up a Local Plan. The Guidance states

“assessing need is just the first stage in developing a Local Plan. Once need has been assessed, the local planning authority should prepare a strategic housing land availability assessment to establish realistic assumptions about the availability, suitability and the likely economic viability of land to meet the identified need for housing over the plan period, and in so doing take account of any constraints such as green belt, which indicate that development should be restricted and which may restrain the ability of an authority to meet its need.”

4. ANALYSIS OF HMA.

CPRE believes that within the October 2013 HMA, the evidence allows for different conclusions to be drawn, conclusions which it is for the Council to draw rather than the agents who provided the advice. For example:

(A) Natural growth

The evidence in the October 2013 Hearn Report shows that since 1981 natural growth within Waverley is very low 0.33% pa. (Report paragraph 2.49) This is no surprise as Waverley as a mainly rural area cannot support a rapid increase in population or the housing needed to support such an increase or the infrastructure without which such an increase could be accommodated. It is true that ONS statistics point to an increase in population in England and Wales but this is overwhelmingly in the Greater London Area and the impact of that in Waverley is dependent on

(i)the extent to which London can accommodate its own natural growth

(ii)the extent to which, if London cannot build sufficient housing to meet its own growth, those who are dissatisfied with what London can provide decide to move out of London

(iii)the extent to which those moving out of London move to Waverley ((an admitted high cost area) rather than less expensive areas in the south East or more likely in less expensive areas in the North or West of the Country .

(iv)the extent to which new housing in Waverley is genuinely sustainable.

(B) Inward net Migration

As Natural Growth is low, it appears that the proposed 17% increase in housing to accommodate the demand (equated to need) is almost wholly calculated by reference to inward net migration which acknowledges that assessment of migration trends are notoriously difficult to forecast. In addition to the above points numbered (i) –(iv) above Waverley must, in CPRE’s view, discount to some extent any recommendation based on inward migration and adjust its forecast increase in need by regular monitoring rather than the assumption that ONS forecasts will automatically translate into increased housing demand over the plan period. Hearn state that in reaching their housing number of 8400 new houses over the period to 2031 they have adjusted the total by “ back loading” the projection.

CPRE considers that the Council is not bound to accept this method of meeting claimed housing need as it would clearly be preferable to project future growth by reference to known past experience over a long period and only adjust following periodical updates (as required by the NPPF). Projections based on calculations of future population growth in Waverley (little more

than guesswork) allocated on the basis of an allocation of net migration out of London known to be “notoriously” unreliable cannot be justified in the interests of meeting housing demand if, as we believe, this does irreparable damage to the Countryside and especially the Green Belt and other areas required to be the subject of restraint from development. A Plan which ignores these requirements will not be sound. CPRE contends that the Council is not bound slavishly to accept the Hearn recommendations. .

5. NO SUPPORT FOR SCENARIOS.

CPRE cannot therefore support any of the four scenarios.

Scenarios 1 and 2 would result in unsustainable development in Farnham (as concluded in the Sustainability Assessment and Habitat Assessment) and in Cranleigh.

The Interim Sustainability Appraisal Report concludes that Scenario 1 would likely lead to significant negative effects. Locally important landscapes would certainly be impacted, there would be an erosion of the historic settlement pattern in the Borough’s north and west and the ‘village feel’ of Cranleigh would likely be lost; and would, as regards soil and other natural resources, lead tosignificant negative effects as growth would be focused on Greenfield land.

Scenarios2, 3&4 would result in unsustainable development at Dunsfold Aerodrome

(see 14 below)

6. GREEN BELT REVIEW

While we did not believe it necessary for the Council to undertake a Green Belt review, we note that the report found that nearly all the Green Belt in the Borough was performing the purposes laid down in the NPPF. We cannot, however, see any justification for taking Chiddingfold, Elstead , Milford and Witley out of the Green Belt. Chiddingfold and Elstead are in the heart of the Surrey Hills AONB and, in the case of Chiddingfold, the SHLA contains no red or amber sites in or around the village. Each of these villages could be expected to provide some housing within their existing boundaries over the life of the plan and in aggregate this might be in the region of 300-450 contemplated in the scenarios. In each case this can be determined by the Village Neighbourhood Plan. We support the extension of the Green Belt to the two areas mentioned but this should not be seen as a quid pro quo for excluding other areas.

As repeated in the October 2014 Planning Guidance:

“Unmet housing need (including for traveller sites) is unlikely to outweigh the harm to the Green Belt and other harm to constitute the “very special circumstances” justifying inappropriate development on a site within the Green Belt.”

7. AONB and AGLV.

We strongly support the continued protection of the AONB and the AGLV. In view of the strength of the AONB policies in the NPPF, it is doubted that the Council would be able to justify any greenfield development within the AONB, except for small scale affordable housing in suitable locations. The AONB Candidate Areas, being those identified by Natural England’s consultants as meeting Natural England’s criteria of natural beauty, should in effect be treated in the same way as the AONB; it would be invidious and unjust to treat them in any other way; but it is also important to retain the whole of the AGLV not only until Natural England concludes its deliberations, but also, in the case of those areas not upgraded to AONB, for the life of the plan provided they satisfy a landscape character assessment.

The Surrey Hills are an irreplaceable and much valued natural asset. CPRE does not consider that Waverley has any mandate to compromise what should be protected for the sake of future generations. It would seem illogical to consider the development of a site within the Surrey Hills as meeting the NPPF requirement for sustainable development.

8.LOCAL LANDSCAPE DESIGNATIONS

We note that the Landscape review recommends the retention of the local landscape designations (ASVI, AHLV, Godalming Hillsides and the Farnham /Aldershot Strategic Gap). We have always maintained that they perform a valuable purpose and we therefore welcome this.

9. SMALLER VILLAGES

We believe that there is some scope for the smaller villages to accommodate some additional housing within their existing boundaries but priority must be given to affordable or low cost housing, and any sites should be supported by the Neighbourhood Plan where the village has adopted one. The figure proposed of 150 dwellings in total for the smaller villages seems to be the upper limit of what is sustainable.

10.PREVIOUSLY DEVELOPED LAND

Maximum use for housing development should be made of brownfield sites within the settlements and in rural areas (but see below our comments on Dunsfold Aerodrome).

11. HOUSING DENSITIES

We believe that there is scope to increase the amount of new housing (including permitted house extensions) within the boundaries of all existing settlements and higher densities within settlements are to be encouraged but they must not have a negative impact on local amenity or on the character of the area.

12. FARNHAM

The level of growth contemplated in and around Farnham in Scenarios 1and 2 would be clearly unsustainable

The Interim Sustainability Appraisal Report concludes that Scenario 1 would be likely lead to significant negative effects. Locally important landscapes would certainly be impacted, there would be an erosion of the historic settlement pattern in the Borough’s north and west; and would, as regards soil and other natural resources, lead tosignificant negative effectsas growth would be focused on Greenfield land.

The Habitats Assessment concludes that Scenarios 1 and 2 are the least preferable scenarios from a European site viewpoint, posing greater deliverability challenges unless adequate SANG can be identified (at least in outline) prior to submission of the Local Plan to the Secretary of State (which is extremely unlikely).

There are also serious inadequacies in Farnham’s infrastructure (particularly transport but also education), which contribute to the unsustainability of Options 1, 2 and 3.

A low growth approach is, in CPRE’s view, the right answer for Farnham. The failure to consider this as an option and invite comment in the consultation casts doubt on the validity of the consultation and could result in the adoption by Waverley of a Local Plan which is clearly undeliverable as well as unsustainable.

13.CRANLEIGH

In terms of future development in Cranleigh, CPRE believes that each of the four scenarios depicted in the Consultation document are unsustainable due to the extent of the development being proposed in the area embracing Cranleigh and Dunsfold Aerodrome. None of the four options is acceptable due to the lack of infrastructure and the requirement to develop open countryside in order to achieve the targets suggested. Cranleigh is the smallest of the four centres in Waverley and very poorly served in terms of infrastructure.

Cranleigh has neither a rail link nor an A class trunk road through it, nor is it in close proximity to major arterial routes. Being remote from such transport links, Cranleigh is, in transport terms, particularly ill suited to take significant levels of additional housing development. The local economy is strongly reliant on car based commuting, either to Guildford or London, resulting in a high level of car movements. The nearest A road (A281) is already at saturation level. Most traffic generated by Cranleigh is commuter based and entails a twice-daily journey to and from Guildford. Any further traffic generated by additional development either within Cranleigh itself or from an entirely new settlement at Dunsfold will simply increase the unsustainable levels of traffic on this route. All journeys to and from these new developments would pass through one or more of the smaller villages of Alfold, Hambledon, Hascombe, Shamley Green, Wonersh and Bramley, and Godalming, to the further detriment of these communities. The consequence for Guildford would be inevitable and in our view significant. The consultation does not mention any cross boundary co-operation on this subject

14. DUNSFOLD AERODROME

The construction of a large number of new homes at Dunsfold Aerodrome will place a considerable strain on the infrastructure of south east Waverley. Waverley Borough Council decided firmly in 2008/9 that development on the scale envisaged at Dunsfold Aerodrome was unsustainable and the Planning Inspector agreed with this conclusion on transport grounds. Nothing has changed since then. There appears to be no solution to the problems recognised by the Inspector relating to traffic flows on the A281, regardless of the amount of money that might be available from developers if permission were given for 1800 to 3400 houses on the Aerodrome, particularly as there is no prospect of any significant government funding being available. The B2130 from Dunsfold to Godalming, is also very busy, especially in the mornings and evenings, and parking in Godalming particularly for commuters, is already inadequate.

In paragraph 13.1.5, the SA Report makes it clear that “considerable assumptions have been made regarding what can be achieved through development in terms of the delivery of infrastructure and ‘planning gain’ more generally. There is a general assumption made that large schemes will lead to funds being made available to mitigate many of the impacts associated with growth, deliver services / facilities that benefit residents and also deliver infrastructure that brings environmental benefits. In practice, until detailed investigation is completed, there is considerable uncertainty about what can be achieved”.

In the case of Dunsfold Aerodrome that detailed investigation has already been carried out by Rutland Group and their consultants and by Surrey County Council, which were considered in detail at the Public Inquiry. The conclusion was that there is no solution to these problems. The site remains unsustainable for large-scale housing unless and until a sustainable transport solution can be identified. These problems are in fact unsurmountable without completely altering (and in reality destroying) the rural environment.by radical restructuring the road network.

We would add that CPRE does not accept that the whole of Dunsfold Aerodrome (500 acres or so) should be treated as previously developed land. Much is open countryside, with the runway and the present industrial and office buildings being the only built structures. A runway does not have a curtilage

15 CONCLUSION

The SA report in paragraph 13.1.5 stated that the consultants had appraised

“a low growth approach which shows that a low growth approach performs well in terms of a number of environmental objectives, but poorly in terms of ‘community and well-being’ and ‘housing’. It is not suggested that a low growth approach would result in significant opportunities missed in terms of ‘economy’ related objectives, although the need for housing to support employment growth in the sub-region is a consideration. Indeed it is suggested that low growth could perform well in terms of economic objectives as the effect would be to minimise increases in traffic congestion”

The SA report acknowledges that there may be a need to revisit the “growth quantum” and that the housing needs figure is not “cast in stone”. In paragraph11.6, the SA report states

“ Subsequent to the appraisal of initial alternatives ….. the Council recognised that the

alternative housing scenarios that are the focus of consultation should all deliver 8,450 homes

over the plan period……..” and that “ At the current time, in light of the emphasis placed by the NPPF on seeking to meet objectively assessed housing needs, it would be inappropriate to actively consider a lower growth scenario. However, there is the potential to revisit the growth quantum in the future, if consultation and appraisal at the current time calls into question the sustainability of delivering 470 dpa.”

CPRE believes that that time has come; the evidence is significant that the housing needs figure is not sufficiently reliable not is it sustainable

Waverley is exceptionally heavily constrained by having 80% of the Borough designated as AONB or AGLV, 61% designated as Green Belt and significant SPAs and SACs. It is therefore essential, in a predominantly rural borough such as Waverley, for the Council, in framing its policies for the next 20 years, to be careful to conserve for future generations the rural environment (a guiding principle of sustainability). In CPRE’s view, Waverley Council should do nothing which irrevocably damages the rural nature of the Borough by allowing creeping suburbanisation and industrialisation.