Cranleigh Society Local Plan Response

The Cranleigh Civic Society has been very busy compiling its response to Waverley’s Local Plan Part One.

Yesterday (3 October 17:00) was the deadline for all comments.  We delivered our forms first thing in the morning and got a receipt for 42 pages!  Although we have not yet seen them on Waverley’s website.

We have provided some of the comments below regarding (Click on the policy heading below to go to relevant section):

Spatial Vision 3.2 Vision for Waverley in 2032

Policy ALH1: The Amount and Location of Housing

Policy SP2: Spatial Strategy

Policy NE2 Green and Blue Infrastructure

Policy ICS1: Infrastructure and Community Facilities

Policy ST1: Sustainable Transport

Policy CC4 Flood Risk Management

Policy SS5: Strategic Housing Site at Land South of Elmbridge Road and the High Street, Cranleigh

Policy SS4: Strategic Housing Site at Horsham Road, Cranleigh

Policy SS7 New Settlement at Dunsfold Aerodrome

Spatial Vision 3.2 Vision for Waverley in 2032

Our Comment:

We object to this point on the following grounds:

• No proposed growth in jobs, employment land assessment not accurate and out-of-date.
• Sustainable transport options minimal, housing is not located in an area where the need for travel is reduced.
• Water quality and air quality not adequately evidence based or mitigated against.
• Cranleigh receiving a disproportionate amount of housing in respect to its position in the settlement hierarchy, which is based on flawed data with regard to employment land.
• Development in Cranleigh has been developer-led rather than plan-led.
• Despite the significant amount of housing there has been no survey on the impact on local biodiversity of a settlement, which would be in total the size of Cranleigh in this corner of the borough.
• The critical revised climate change allowances (February 2016) from 20% to 25% to 70% above the 1% AEP have not been taken into account.

Changes we suggest:
Cranleigh should be allocated a lower number of houses in proportion to employment opportunities and to promote sustainable transport options, as well as in accordance with NPPF policy for sustainable development.

Policy ALH1: The Amount and Location of Housing

Our Comment:

The housing numbers for Cranleigh are disproportionate to its size, range of services, sustainable transport options and employment opportunities and the evidence base is not up-to date.

In most cases household projections should be employment led.  Within the Cranleigh area housing and employment simply do not align.  The assessment of employment land in the Employment Land Reviews (ELR) are seriously flawed and have been significantly exaggerated at an inflated 17% of the borough’s employment land (34.2ha) to justify the position of Cranleigh in the settlement hierarchy.  These errors have been pointed out to Waverley on multiple occasions. The assessment included Cranleigh Brick and Tiles site (20ha) which does not abut, nor does it relate well to, the settlement boundary being situated some 4km from the centre of the village within open countryside on a narrow rural road.

In 2000 the site was declared a “Special Site no 1” by the Environment Agency after representations from Waverley Borough Council, as a result of a perceived threat of pollution of Controlled Waters and was deemed to be one of the most contaminated sites in Europe.  The site was used for chemical production (Arsenic, Bromide, Mercury etc) by Steetly Chemicals and was then purchased by Redland (Lafarge) and subsequently sold onto Cherokee Investments in around 2004, after which the brickworks closed.  Since 2004 there has been no industrial activity on site with the redundant infrastructure falling into significant disrepair.  It has been subject to multiple applications for residential use, the final application (WA/2013/1947) for full planning permission being granted on 10/08/2015.  Work is currently under way to remediate the site prior to development.

The disproportionate proposed allocation of new housing in the south east of the borough includes the following: Cranleigh 1,520; Dunsfold Aerodrome 2,600; Ewhurst 65; Alfold 100; Dunsfold 80; Bramley 70; Wonersh/Shamley Green 20; totalling 4,455 – approx. 45% of the borough SHMA total.  Evidence has not been provided on the severe cumulative impact on highways, associated deaths and health problems due to air quality (impact on schools on the A281 in particularly in Bramley and Shalford), high level services, utilities, as well as negative impact on biodiversity, the further detrimental impact on the river status of Cranleigh Waters in direct contravention of Waverley Borough Council’s responsibilities under the Water Framework Directive.

The report notes that some 63% of the borough is covered by Metropolitan Green Belt and a further substantial area is covered by the national designation Area of Outstanding Natural Beauty. The imposition of a proportion of the total SHMA allocation totalling just under half of the total requirement for the borough onto an area characterised by its rural nature, landscape value, limited employment opportunities, and completely inadequate transport network, cannot be considered a sustainable solution in terms on NPPF.

It is clear that the settlement hierarchy assessment and the subsequent allocation of housing is flawed.  Waverley, have relied on inflated employment opportunities in Cranleigh (the smallest of the settlements with 9.5% of the borough’s population), and although admitting the limits of the road infrastructure, together with acknowledging that improvements are not deliverable (para 2.42) “It is also about recognising that there is a limit to the extent to which infrastructure can change even in the medium term. For example, there will continue to be poor east-west transport connections in Waverley.”, proceed to discount this serious issue as a material constraint to development.  The impact of this plan to allocate 45% of the entire housing allocation to the east corner of the borough, where both housing need is not focused and employment opportunities are not focused, will be severe, damaging and permanent.

This local plan has not been positively prepared as outlined in PPG – “the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development;”.  The council should acknowledge that the constraints in the borough governed by national landscape designations, green belt planning policy, poor transport infrastructure and access to employment opportunities will, for the area around Cranleigh, and for the village itself, on transport grounds, lead to severe and lasting residual cumulative impacts; a situation that NPPF confirms, allows the local authority to restrict or refuse development. This situation provides a suitable evidence base to allow the raw SHMA figure of 9861 to be reduced.

The Local Plan is not consistent with national planning policy.  At the heart of the NPPF is a presumption in favour of sustainable development based on three roles: economic, social and environmental.  The NPPF PPG states that:

“These roles should not be undertaken in isolation, because they are mutually dependent. Economic growth can secure higher social and environmental standards, and well-designed buildings and places can improve the lives of people and communities. Therefore, to achieve sustainable development, economic, social and environmental gains should be sought jointly and simultaneously through the planning system. The planning system should play an active role in guiding development to sustainable solutions.”

It is clear that that extra weight should not be given to one role alone.  In Waverley’s Sustainability Appraisal Report Sept 2014 Page 30 it states with regard to high growth in Cranleigh:

“No major socio-economic arguments in favour of this option. Cranleigh has more of a ‘village feel’ than is the case for the other main settlements, and it is the case that housing need is not focused in this part of the Borough. Also, recent speculative (i.e. non-plan led) applications for housing schemes have served to highlight concerns over infrastructure.”

With an identified lack of social and economic benefits, justification for high housing numbers in Cranleigh appears heavily reliant on the observation within the report that “Cranleigh is relatively unconstrained environmentally”.  To use this as the reasoning for high growth contravenes the NPPF golden thread of sustainability and also fails to acknowledge the value of Cranleigh’s exceptional landscape, its historical character and setting, together with its contribution to the magnificent views from the Surrey Hills AONB.

Cranleigh residents do not feel that they have been adequately consulted with on the local plan and were extremely disappointed that the Waverley planning portfolio holder and officers did not visit Cranleigh, one of the most negatively affected areas in the borough, during their round of visits in May and June 2014, as confirmed in 3.5 of the Waverley Local Plan Consultation Statement 2016.  We were also extremely disappointed that hard copies of the local plan were not made available to residents in the library as outlined in 2.12 of the Waverley Local Plan Consultation Statement 2016.

Changes we suggest:

Cranleigh should be allocated a lower number of houses in proportion to employment opportunities and to promote sustainable transport options, as well as in accordance with NPPF policy for sustainable development.

Policy SP2: Spatial Strategy

Our Comments:

The assessment of Cranleigh in the settlement hierarchy that informs the spatial strategy is not sound as it is based on evidence that is not up-to-date and does not comply with national policy with regards to sustainable development.

In terms of employment opportunity, the Local Plan is based on seriously flawed and inflated employment land figures.  The employment land recorded in WBC Employment Land Review (ELR) 2009, stated that Cranleigh had 32.4ha (17% of total assessed land within the District) and this was the figure confirmed by Waverley as being used as the evidence base for the analysis in the Local Plan.  In reality Cranleigh has between 3% and 4% of the total employment land for the borough.

This fact is critical as employment land was one of the determining criteria which ranked Cranleigh alongside the larger settlements in the borough – Farnham, Godalming and Haslemere in the settlement hierarchy, placing it in a position to accommodate large housing numbers.

The ELR has continued to include the extensive Cranleigh Brick and Tiles site (20ha).  The brickworks site is remote, situated in open countryside approximately 4km from the centre of the village on a narrow rural road.  Previously the site was used as a munitions store during WWI, then between 1937 and 1989 it was used for chemical manufacturing (Arsenic, Bromide, Mercury etc), finally, between 1990 and 2004 the site reverted to a brickworks.  Since 2004 there has been no industrial activity and the buildings on site have fallen into significant disrepair. This would have been more than apparent when the ELR 2009 was undertaken.

Furthermore, the chemical activity on the site caused considerable contamination, much of which is contained within lagoons on site.  In 2000, after representations from Waverley, the Environment Agency listed the area as Special Site no. 1 and was deemed to be one of the most contaminated sites in Europe.  After several residential planning applications, one for 19 dwellings, including the remediation of the site, was approved on 10 August 2015 WA/2013/1947.  Work is currently under way to remediate the site prior to development.  Waverley were aware in 2009 of the history and the serious nature of pollution on this site and it should have attracted a “poor status” for future use as an employment site.

In the Employment Land Review (ELR) Appendix E it stated that future use for employment was unknown and that it failed in terms of sustainability criteria.  In the ELR update 2011 the site was not mentioned.  In the ELR update 2014 the site was still included in Table 2-3 and it was claimed to be suitable for employment use with no scope for change (page 62), despite the planning application, submitted to Waverley in 2013 and being considered at the time the report was produced.

The 2014 report also inaccurately included Smithbrook Kilns 2.35ha as a Cranleigh site, which is in the parish of Bramley and Swallow Tiles 0.9ha, which was undergoing residential development.

Finally, the Brickworks site was again included in the ELR August 2016 update, although its status was stated as “Poor” for future employment use.  It could be reasonably argued that since remediation work was actually in place at this time, as full permission for residential development had already been granted, this should have been recorded as “Zero” and the 20ha should not have been included.

The inclusion of the brickworks site in the local plan as an employment site is not based on up-to-date information and its prospects as an employment site are not realistic.  Furthermore, due to the remote location with poor public transport accessibility and poor access to strategic road network the site is not sustainable and against national planning policy.

The disproportionate proposed allocation of new housing in the south east of the borough includes the following: Cranleigh 1,520; Dunsfold Aerodrome 2,600; Ewhurst 65; Alfold 100; Dunsfold 80; Bramley 70; Wonersh/Shamley Green 20; totalling 4,455 – approx 45% of the borough SHMA total.  Evidence has not been provided on the severe cumulative impact on highways, associated deaths and health problems due to air quality (impact on schools on the A281 in particularly in Bramley and Shalford), high level services, utilities, as well as negative impact on biodiversity, the further detrimental impact on the river status of Cranleigh Waters in direct contravention of Waverley Borough Council’s responsibilities under the Water Framework Directive.

The report notes that some 63% of the borough is covered by Metropolitan Green Belt and a further substantial area is covered by the national designation Area of Outstanding Natural Beauty. Cranleigh’s important position immediately on the edge of green belt and adjacent to areas of AONB and AGLV has been seriously understated.

The imposition of 45% of the total SHMA allocation totalling just under half of the total requirement for the borough in and around an area characterised by its rural nature, limited employment opportunities, and completely inadequate transport network, cannot be considered a sustainable solution in terms on NPPF and the impact on neighbouring authorities, in particular Guildford, have not been realistically assessed.

It is clear that the assessment of the settlement hierarchy and the allocation of housing is flawed.  Waverley, have relied on an inflated availability of employment opportunities in Cranleigh (the smallest of the settlements with 9.5% of the borough’s population), and although admitting the limits of the road infrastructure, together with acknowledging that improvements are not deliverable (para 2.42) “It is also about recognising that there is a limit to the extent to which infrastructure can change even in the medium term. For example, there will continue to be poor east-west transport connections in Waverley.”, proceed to discount these serious issues as material constraints to development.  The impact of this plan to allocate 45% of the entire housing allocation to the east corner of the borough, where both housing need is not focused and employment opportunities are not focused, will be severe, damaging and permanent.

This local plan has not been positively prepared and does not represent the most appropriate strategy to achieve sustainable development.  The plan has been developer-led rather than plan-led.  The council has not sufficiently acknowledged that the constraints in the borough governed by national landscape designations, green belt planning policy, poor transport infrastructure and access to employment opportunities will, for the area around Cranleigh, and for the village itself, on transport grounds, lead to severe and lasting residual cumulative impacts; a situation that NPPF confirms, allows the local authority to restrict or refuse development.

At the heart of the NPPF is a presumption in favour of sustainable development based on three roles: economic, social and environmental.  The NPPF PPG states that:

“These roles should not be undertaken in isolation, because they are mutually dependent. Economic growth can secure higher social and environmental standards, and well-designed buildings and places can improve the lives of people and communities. Therefore, to achieve sustainable development, economic, social and environmental gains should be sought jointly and simultaneously through the planning system. The planning system should play an active role in guiding development to sustainable solutions.”

It is clear that that extra weight should not be given to one role alone.  In Waverley’s Sustainability Appraisal Report Sept 2014 Page 30 it states with regard to high growth in Cranleigh:

“No major socio-economic arguments in favour of this option. Cranleigh has more of a ‘village feel’ than is the case for the other main settlements, and it is the case that housing need is not focused in this part of the Borough. Also, recent speculative (i.e. non-plan led) applications for housing schemes have served to highlight concerns over infrastructure.”

With an identified lack of social and economic benefits, justification for high housing numbers in Cranleigh appears heavily reliant on the observation within the report that “Cranleigh is relatively unconstrained environmentally”.  To use this as the reasoning for high growth contravenes the NPPF golden thread of sustainability.

Waverley’s criteria for deciding on the Settlement Hierarchy is further flawed, as it confuses environmental constraints, as displayed in the table Settlement Hierarchy Second Draft January 2010 Page 72, and Green Belt which is a planning policy.

It also appears that Witley Railway Station has been omitted from the public transport ranking, impacting on the total hierarchy score for that settlement.

Waverley have failed in its duty to co-operate with neighbouring authorities in an accurate, up-to-date and timely manner with regard to migration and journey to work patterns.

Cranleigh residents do not feel that they have been adequately consulted with on the local plan and were extremely disappointed that the Waverley planning portfolio holder and officers did not visit Cranleigh, one of the most negatively affected areas in the borough, during their round of visits in May and June 2014, as confirmed in 3.5 of the Waverley Local Plan Consultation Statement 2016.  We were also extremely disappointed that hard copies of the local plan were not made available to residents in the library as outlined in 2.12 of the Waverley Local Plan Consultation Statement 2016.

Changes we suggest:

Cranleigh should be allocated a lower number of houses in proportion to employment opportunities and to promote sustainable transport options, as well as in accordance with NPPF policy for sustainable development.

Policy NE2 Green and Blue Infrastructure

Our Comment:

“Point 16.29 The Water Framework Directive 12 established a legal framework for the protection and promotion of sustainable water management of surface waters (including coastal waters out to one nautical mile) and groundwater.  The Directive requires all inland and coastal waters to achieve “good” status through a catchment-based (system of River Basin Management Plans (RBMPs). Waverley is part of the Thames River Basin District. In preparing the Local Plan, the Council has consulted the appropriate water companies on the scale and location of potential development sites to ensure that these can be delivered within environmental limits and that the required infrastructure can be delivered in a timely manner. The Council continues to gather and assess evidence on water resources, water quality and flood risk, for example through its Water Cycle Study, and will consider whether further information is required, particularly in deciding relevant planning applications.”

We do not find this point sound.  Waverley have not consulted with “the appropriate water companies about the scale and location of potential development sites to ensure that these can be delivered within environmental limits and that the required infrastructure can be delivered in a timely manner.”

Environmental Limits and Infrastructure Delivery:

Local planning authorities have statutory duties to deliver the Water Framework Directive (WFD).  This established a legal framework for the protection and promotion of sustainable water management of surface waters (including coastal waters out to one nautical mile) and groundwater.

The plan does not take into account that WFD requires all inland and coastal waters to achieve “good” status through a catchment-based (Cranleigh Waters is part of the Wey Catchment) system of River Basin Management Plans (RBMPs).  Waverley is part of the Thames River Basin District.  The RBMP outlines the actions needed to meet WFD objectives of ‘good’ water body status.

Under WFD the overarching aims are to:

• Prevent deterioration in water body status
• Reduce water pollution
• Conserve aquatic ecosystems and habitats
• Reduce the effects of floods and droughts on water bodies
• Promote sustainable use of water as a natural resource

The EA have issued a comprehensive guidance document for LPAs “Improving Water Quality, Guidance for Local Authorities, Engaging with the Water Framework Directive, that stresses:

“In legal terms, the WFD is a material consideration in the planning process”

It is Waverley’s role, not that of the EA, to ensure that a full water cycle study is carried out.  The purpose of this study is to assess the existing water infrastructure and water environment to determine if it can accommodate the proposed levels of growth or where further work may be required to facilitate the growth and ensure that it does not detrimentally impact upon the natural environment.

Paragraph 156 of the NPPF states: “Local planning authorities should set out the strategic priorities for the area in the Local Plan. This should include strategic policies to deliver…the provision of infrastructure for transport, telecommunications, waste management, water supply, wastewater, flood risk and coastal changes management, and the provision of minerals and energy”.

A full water cycle study which is necessary to inform strategic policies to deliver the provision of sewerage infrastructure and water supply have not been carried out.  Without this study the local plan is not sound.

Furthermore, Waverley is not meeting its responsibilities under WFD.  it is impossible for Thames Water to confirm that they can deliver levels of discharge effluent that meet with environmental limits within the lifetime of the plan. It is not technically possible (Environment Agency email 25 February 2016) to meet the environmental levels set by the WFD, particularly with regard to phosphates, and currently effluent discharge into Cranleigh Waters is not being measured against WFD.  The last environmental permit to discharge issued to Thames Water was in 2009, when the Environment Agency (EA) applied blanket conditions to Temporary Deemed Consents to bring them in line with other Combined Sewage Overflow permits. This permit was not based on WFD and also relies on a level of dilution which is no longer applicable, since Cranleigh Waters over the last few years has become ephemeral, with low to no flow, particularly during summer months.

The Cranleigh Civic Society received an email from EA on 25 February 2016 at 16:56:44 GMT confirming the elements Cranleigh Waters was failing in, and also that water company trials were taking place to meet the tighter permit levels required under WFD:

“The elements that are not passing are Phosphate (moderate status), macrophytes (moderate status) and diatoms (poor status). Macrophytes and diatoms are ecological indicators of phosphate pressure. Therefore the permit has been reviewed recently with respect to these failing elements (Summer 2015) and it was identified that to improve this status a permit would be required that currently is technically infeasible. As mentioned previously water companies are undertaking trials to try and identify technology that would be capable of treating effluent to meet these tighter permits. The Environment Agency will be tracking the success of these trial and the permits will be reviewed if the technology becomes available to treat to these tighter levels.”

This content of this email was passed on to Waverley.

EA website maps as at 05-Mar-16 also indicated the following:

• Cranleigh Waters is in “Drinking water safeguard zone” (zone ends at Shalford).
• Cranleigh Waters is in a “Nitrate vulnerable zone”, so “Eutrophic”.
• Cranleigh Sewage Treatment Works shown as “Water industrial pollution: Significant”
• Cranleigh Waters Ecological Quality rated “Bad”. Must be “Good” by 2027 to meet Water Framework Directive (WFD)

Furthermore, data released by EA in 2015 provided reasons for not achieving good status in the Cranleigh Waters in their River Basin Management plan and attributed this to continuous sewage discharge.  This indicated that all three key water body pollution indicator categories, Solids, Biochemical Oxygen Demand and Ammoniacal Nitrogen were being exceeded.

In the absence of an up-to-date environmental permit to discharge into Cranleigh Waters and the need for new technology to process sewage to comply with WFD, it is factually incorrect and unsound for WBC to state that the development sites “…can be delivered within environmental limits”.  They are relying on out of date environmental legislation, this is not consistent with national policy, and are not taking into account the ephemeral nature of Cranleigh Waters.

In addition to contravening limits set by WFD, the timeline for upgrade works to the sewage treatment works, which is already at capacity, cannot at this stage be considered to be “timely”.  As we have established, water companies do not have the technology capable of treating effluent to comply with WFD and the results of these trials will not be available until, at the earliest, 2017.  At the moment new permits to discharge are not being issued by EA to comply with WFD, despite the failing status of rivers like Cranleigh Waters, and the requirement under WFD to improve river status to “Good” by 2027, is within the lifetime of Waverley’s local plan.

Should the water company trials prove to be successful, and the process and technology to deal with the effluent be established, it would still take an additional number of years before expansion and upgrade work to Cranleigh Sewage Treatment Works (SWT) can be carried out.  Thames Water will have to submit a planning application, carry out a full odour assessment survey, as well as applying for funding from Ofwat, the next funding round is not until 2019 for 2020-25.  An expansion to the treatment works of the size required for Cranleigh, we were informed by Thames Water, would take approximately 3 years to complete, as confirmed recently in the High Level Water Cycle Study carried out by Capita for Waverley in August 2016 “Typically local network upgrades take 18 months – 3 years to investigate design and build. More strategic solutions 3 – 5 years and where new Sewage treatment works are required this could take 7 – 10 years.”.

We do not believe that Waverley have realistically or adequately assessed the requirement for sewerage infrastructure in the local plan, particularly in selection of the strategic sites, and it is therefore unsound.

Cranleigh Waters Ephemeral and Eutrophic:

In addition to awaiting the outcome of the previously mentioned water company trials, the need for an updated permit to discharge based on WFD, as well as the failing status of Cranleigh Waters, what makes the position of Cranleigh Waters far more critical than other rivers near main settlements is the ephemeral nature of the watercourse.  With an average daily discharge from the Cranleigh Sewage Works, recorded in 2014, of 5143 m3 (over 2 Olympic-sized swimming pools per day) and, at times, low to no flow in the river upstream of the STW, pollution has increased and the Shamley Green Angling Society has reported depleted fish stocks.  At times the flow downstream of the SWT is almost 100% liquid effluent. which encourages the growth of algae, called eutrophication, which means that it is rich in nutrients and promotes plant growth, leading to low oxygen levels, at the expense of providing a suitable habitat for fish, amphibians and invertebrates.  Since 2009, The EA has classified Cranleigh Waters as “Eutrophic and Bad”, the worst category on their ratings scale.

Some fish may be still present in the river but they will be stressed, suffering large amounts of suspended biodegradable matter (toxic silt, algae etc.) that clog and irritate their gills.  Fish will not feed or spawn in these situations and over long periods of deoxygenation they will become weak and die. The food chain then starts to deteriorate with invertebrate death, then a cascade ecosystem failure ensues. This results in a dead system that will take decades to recover and only then if sources of pollution are stopped or technology becomes available to filter the harmful elements out of effluent discharge.

A local member of the angling society confirmed that:

“As once you could walk the banks of Cranleigh Waters of an evening and see a myriad of ephemerides hatching from the river surface, splashes of feeding fish and a host of water creatures feeding on this bonanza. Now you will see very little surface activity, no ephemerides, dragon flies or demoiselles that once used to fly over this river in large quantities.  In the past the river margins were alive with large shoals of juvenile fish, now only mosquito larva are noticeable.  We have a dying river that needs help. Further expansion of the sewerage works means a greater capacity of polluted discharge into this failing system. The choice is simple, we sit back and let this river die and let its polluted water flow (slowly) into the River Wey at Shalford where it then becomes somebody else’s problem.”

The EA has put this lack of flow down to several reasons, partly due to badly executed dredging, climate change, extraction and also a general increase in population.  Although classified by EA as a main river, this by no means is indicative of the depth and width of Cranleigh Waters.  We have an image that was taken upstream of the SWT on 18 August 2016, which clearly shows the river depth of approximately 2 inches.  EA have also confirmed to us that it is also failing in terms of phosphate levels (Cranleigh Waters EA Walkover Inspection 8 August 2016).

We also took flow measurements (Geopacks ZMFP51 Flow Meter) on the 7th September 2016 and recorded at 1.36 l/s (averaged over several measurements).

PPG Para: 016, states that Water Quality should be considered a significant concern “– through a lack of adequate infrastructure to deal with wastewater.”, we firmly believe this to be the case in Cranleigh.  The local plan has not assessed the full impact on water quality in Cranleigh Waters, or on the wider Wey Catchment, for the additional liquid effluent discharge from 1,520 houses at Cranleigh, as well as the additional 2,600 at Dunsfold, in addition to development at Alfold and Ewhurst, and it is therefore unsound.

Background Information:

When Cranleigh Sewage Works was opened in July 1967 nearly 50 years ago, it was designed to serve between 10,000 and 15,000 residents.  Thames Water calculated in 2011 that the number of residents it was serving had now reached 14,200, and they notified Waverley Borough Council (WBC) that it was nearing capacity.  Recent approved planning applications, including Swallowhurst, (built 58 dwellings) Amlets Lane (outline permission 125 dwellings with Grampian style condition) and Crest Nicholson, Horsham Road (outline permission 149 dwellings with Grampian style condition), Little Meadow (outline permission for 75 dwellings Grampian style condition, Cranleigh Waverley Councillors and members of the JPC declared a pecuniary interest (under investigation), not declared previously, prior to the meeting to decide this application, despite having taken a major part in discussions and meetings facilitating this development, have put the figure well over the 15,000 capacity. This has been more than doubled by the Appeal decision to allow outline planning permission for another 425 dwellings with no Grampian style condition by Berkeley Homes and no strategy of how to deal with the sewage problems.

The sewerage infrastructure in Cranleigh is already in a critical state.  We have regular instances of sewage back flowing into toilets in Cranleigh as well as seepage into gardens and up through manhole covers.  Additionally, for the past 12 years sewage regularly flows into a brook just off the high street, and from there into the river network.  This has remained unresolved, despite ongoing complaints and repeated remedial work.

To improve resilience for existing residents, the SWT is currently undergoing a 30% upgrade with 2 new filter beds being installed.  However, the works are being carried out without any planning permission and a full odour impact assessment.  This contravenes Defra’s Code of Practice on Odour Nuisance and the Defra Odour Guidance for Local Authorities, because of the many odour complaints from residents living within 800m of the Sewage Treatment Works negate any permitted development rights under the Planning Act.  Cranleigh Society has carried out a basic odour assessment to provide an indication of the extent of this issue. Of the respondents, 71% of households had experienced odour problems from the STW, and 93% wanted Thames Water to carry out a full Odour Impact Assessment before proceeding with further work on site (full Survey results can be provided.  This situation is now being investigated by Surrey County Council.)

Despite being aware of these sewage issues for some time, it is surprising that provision of sewerage infrastructure is not been a principal part of Waverley’s infrastructure delivery plan and that a full water cycle study has not been carried out.  Early in 2014 Waverley sought advice from Thames Water about the capacity of Cranleigh Sewage Treatment Works, as part of evidence gathering for their new Local Plan. Thames Water said to WBC that they were at design capacity.  WBC then stated in their draft Local Plan Part 1: Strategic Policies and Sites Infrastructure Update September 2014 that ‘Concerns about waste water services at Cranleigh Sewage Treatment Works (STW). Sewage treatment capacity unlikely to be able to support anticipated demand.’  Thames Water have also commented on recent planning applications in Cranleigh that they have ‘identified an inability of the existing waste water infrastructure to accommodate the needs of this application’, in addition to highlighting concerns about water supply “The existing water supply infrastructure has insufficient capacity to meet the additional demands for the proposed development.”  They have been recommending that Grampian style conditions for foul and surface water, as well as water impact assessment studies.

Cranleigh Civic Society also met with Waverley Planning Officers on 3 March 2016 to discuss the implications on deliverability of the water company trials, the out of date environmental permit to discharge, low flow rates in Cranleigh Waters, together with its failing status under the WFD.  We then met again with a planning officer at Cranleigh Sewage Treatment Works for a stakeholder meeting on 11-May-16, representatives from Thames Water, the Environment Agency, Surrey Wildlife Trust, Cranleigh Parish Councillors and Waverley Borough Councillors were also in attendance.  At the stakeholder meeting the EA stressed the requirement for a full water cycle study to be carried out as part of the local plan, and confirmed that discussions on this point were underway with the council.  However, despite this a full water cycle study has not yet been carried out.  The current study by Capita is a desktop scoping report (High Level Water Cycle Study August 2016) and although a valuable piece of evidence, should not be confused with a full water cycle study.

The impact of Waverley’s growth plans for Cranleigh have been highlighted in Capita’s report, as shown in Table 5-4.  This report also highlights the need for a quantitative analysis to take place in Stage 2 of the High Level Water Cycle Study, without this assessment and a full water cycle study the plan is unsound.

The Waverley Local Plan Sustainability Appraisal Report 2016 also highlights key considerations relating to:

“A) waste water treatment infrastructure; B) Groundwater Source Protection Zones (SPZs); and C) flood risk.

The Waverley Borough Council Local Development Framework Pre-Submission Core Strategy Habitat Regulations Assessment Report June 2012 also confirms that the borough is in an area of serious water stress with regard to water supply, concerns about the ability of the existing water supply and sewerage networks to cope were highlighted in previous sustainability appraisals.

Against this backdrop Waverley has failed to take the matter of sewerage infrastructure, water supply and water quality fully into account in the local plan, in addition to the impact this will have on neighbouring authorities.

The considerable constraints for the treatment of sewage and the impact on water quality in Cranleigh Waters of 1,520 new dwellings in Cranleigh has not been satisfactorily assessed, nor has the liquid effluent emanating from 2,600 new dwellings at Dunsfold.  Waverley has selected strategic sites for almost 50% of their total housing allocation with full knowledge that Thames Water have no plan or schedule for the delivery of the necessary sewerage infrastructure.  This serious oversight means that the plan is not sound.

Cranleigh residents do not feel that they have been adequately consulted with on the local plan and were extremely disappointed that the Waverley planning portfolio holder and officers did not visit Cranleigh, one of the most negatively affected areas in the borough, during their round of visits in May and June 2014, as confirmed in 3.5 of the Waverley Local Plan Consultation Statement 2016.  We were also extremely disappointed that hard copies of the local plan were not made available to residents in the library as outlined in 2.12 of the Waverley Local Plan Consultation Statement 2016.

Changes we suggest:

A full water cycle study should be carried out and this should inform the selection of strategic sites.  Furthermore, the cumulative impact of liquid effluent entering the Cranleigh Waters from approximately 4,000 new dwellings should be assessed based on updated legislation (WFD) and the river achieving good status by 2027.

Policy ICS1: Infrastructure and Community Facilities

Our Comment:

This policy is not sound as it is not based on objectively assessed evidence.

The impact on Cranleigh’s local road network has not been assessed and proposed infrastructure improvements are not adequately funded or deliverable.  The ongoing flawed employment land review assessment by Waverley has seriously overestimated the availability of employment land in the village, which impacts the projected number of daily car movements in and out of the village.

Waverley’s calculation of employment land is fundamentally flawed and continues to include the 20ha highly contaminated site at Cranleigh Brickworks. Knowle Lane.  This brickworks site is remote, situated in open countryside approximately 4km from the centre of the village.  Previously the site was used as a munitions store during WWI, then between 1937 and 1989 it was used for chemical manufacturing, finally, between 1990 and 2004 the site reverted to a brickworks.  In 2000 is was named as Special Site no 1 by the Environment Agency due to the amount of pollution on site and the risk to controlled waters.  Since 2004 there has been no industrial activity and the buildings on site have fallen into significant disrepair.  After several residential planning applications, one for 19 dwellings, including the remediation of the site, was approved on 10 August 2015 WA/2013/1947 and work has started.

Cranleigh is the smallest of the four main settlements of the borough and the least sustainable in terms of transport infrastructure. There is no rail network, motorway or national trunk road. Most traffic seeks to access the national trunk network via B class roads to reach Guildford (with its main-line railway 15.9km away, concerns from users are highlighted in Para 2.24 “about the current and future capacity of the trains” in addition to limited availability of parking at stations) or the A3/M25 national route. The B class roads around Cranleigh are characterised by their narrowness and rural backdrop. Para 2.22 – Roads and Transport, notes that “Much of Waverley’s road network is rural and narrow and therefore unsuitable for heavy goods vehicles. The safe accommodation of heavy goods traffic is on the principal through routes (including) the A281 and its impact on communities through which these roads pass presents a continuing challenge.”  Para 2.23 confirms that “The most significant delays and congestion occur in and around…Cranleigh and Bramley.”

Cranleigh has a high reliance on car use, the Mott MacDonald Stage 1 February 2016 report highlights that the Cranleigh East and West (Wards) car mode share for residential trips to work has increased to 70%.  Current vehicular journeys from Cranleigh, especially at peak times, seek to travel to Guildford, either as a journey termination for employment or for access to the national rail system or for continuation by road to access the national trunk and motorway system. The route into Guildford is either via the A281 which routes traffic through two major pinch points at Bramley and Shalford or via the B2128 which routes traffic through the villages of Shamley Green and Wonersh and then Shalford. These routes are already heavily congested at peak times and queuing at Bramley and Shalford can present unacceptable delays now. The imposition of a further potential vehicular increase driven by development of some 4,455 new houses in Cranleigh (equivalent to another settlement the size of Cranleigh) and its hinterland must result in severe cumulative impacts, both from the poor transport infrastructure and reduced air quality. With regard to Bramley and Shalford pinch points, the plan suggests that mitigation will make this vehicular increase sustainable. It is difficult to see how these two major bottlenecks can ever be mitigated such that the additional traffic becomes sustainable and the plan makes no reference to how this might be achieved.

Under the duty to co-operate the impact on additional traffic on Guildford is out-of-date and appears not to have assessed the impact of 45% of the Waverley’s housing allocation being situated in and around Cranleigh, in addition to the impact of the associated traffic from this amount of housing on Guildford town centre, in particular the one-way system, along with the negative effect on Guildford’s Air Quality Monitoring Area (AQMA).

Para 2.41 also notes that “…new development often takes place on small sites, so the cumulative impact of development needs to be considered.”.  We can see no evidence that the cumulative impact of the allocation of a minimum of 1520 new houses in Cranleigh and 335 in the surrounding villages has been considered against the proposal for 2600 new houses immediately adjacent to Cranleigh at Dunsfold Aerodrome, yet it is clear that all traffic generated by these developments will be seeking to use the same, already overloaded road network. The various transport modelling works undertaken for the council by Mott McDonald appear to have considered only that traffic generated by a potential new town at Dunsfold Aerodrome. No evidence can be found that the reports have factored in the additional traffic from other new developments, or the impact on Cranleigh rural road network.

Para 3.2.9 In proposing a vision for the borough at the end of the plan period, the statement makes the claim that “The vitality and viability of the main centres…will have been safeguarded in a way that takes account of their distinctive roles. This will have been achieved through carefully planned development, which meets the needs of these centres, whilst recognising the importance of preserving and enhancing their historic character.” However, it is clear that development in Cranleigh has been developer-led rather than plan-led.  It is also clear from the detailed applications for permission being submitted, after consultation with officers, that there has been an agreed shift to far taller residential units and 2.5 to 3 storey apartment buildings, which do not enhance, preserve or respect Cranleigh’s rural character and directly contravene the SPD Cranleigh Design Statement 2008.

Para 5.21 notes that “NPPF requires the council to positively seek opportunities to meet the development needs of the borough and to meet objectively assessed needs unless any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in the NPPF as a whole.” In section 8. Infrastructure and Community Services it is noted that (8.17) In regard of infrastructure provision, “However, a lack of, or identified current deficiencies in, infrastructure is not, in itself, a constraint to development.” It must be clear that lack of or deficiencies in, infrastructure must be a constraint to development if, in line with NPPF, development is to be sustainable.

The Infrastructure Delivery Plan that accompanies the local plan is not sound.  The report lacks detail and substance.  There appears to be no realistic funding sources corresponding to the Cranleigh Draft Infrastructure List by Surrey County Council.  In the main it simply provides an aspirational list, with an end date of “By 2032” and funding gap “tbc”.  This is not positively prepared and is not borne up by the current contribution level of secured S106 agreements for the already approved 793 dwellings.  The Cranleigh Draft Infrastructure List by Surrey County Council referred to in the report does not appear to be an evidence document and therefore the methodology used to devise it, the evidence base and assessment of need for each project cannot be properly scrutinised. However, one of the most critical projects for Cranleigh regarding upgrade and expansion work for the Sewage Treatment Works has been very worryingly omitted.

We would also point out that Surrey County Council, in its recent Infrastructure Study (Jan 2016), has already identified a substantial funding gap between what is required to meet existing needs in Waverley and what is available. Of a total requirement just under £128M, just £540,000 has been secured. The funding gap between what is secured and expected, and what is required is calculated at £61M, most of which is required for Highways improvements. These figures were based on the expectation of just 3,750 new houses for Waverley between 2016 and 2030. With the new total proposed now 9,861, clearly even this massive funding gap is a significant underestimate.  Surrey’s funding gap is now reported to be at £3bn.

Cranleigh residents do not feel that they have been adequately consulted with on the local plan and were extremely disappointed that the Waverley planning portfolio holder and officers did not visit Cranleigh, one of the most negatively affected areas in the borough, during their round of visits in May and June 2014, as confirmed in 3.5 of the Waverley Local Plan Consultation Statement 2016.  We were also extremely disappointed that hard copies of the local plan were not made available to residents in the library as outlined in 2.12 of the Waverley Local Plan Consultation Statement 2016.

Changes we suggest:

The inclusion of expansion to Cranleigh Sewage Treatment Works must be included in the infrastructure delivery projects, in addition to a more detailed timeline for project delivery and funding sources. Furthermore the impact on cumulative traffic on Cranleigh’s local rural road network and cross boundary projects, including key road stress points, should be adequately assessed.

Policy ST1: Sustainable Transport

Our Comment:

The proposal for 45% of the borough’s total housing allocation in and around Cranleigh, including a new settlement at Dunsfold, does not achieve the Council’s aim that development “should be directed to the most sustainable locations that are easily accessible without the use of the car”.  The level of unsustainable development that the council has included in its local plan is staggering.

There are few sustainable transport options for Cranleigh and the surrounding area, other than a rural bus service, with reduced services at weekends and no late night bus.  There is no train station, the nearest main-line railway station is 15.9km away.  The roads into Guildford are in the main narrow, winding B roads, with access onto a single A road (A281) leading into Guildford.  The significant amount of new housing that is reliant on private car usage being proposed for this inadequate road network makes the local plan unsound in terms of sustainable transport and air quality.

The draft plan does not confirm that Waverley has sufficiently investigated the impact on air quality of additional traffic through the villages of Bramley and Shalford, which will suffer the impact of increased queues of standing vehicles from traffic generated by new development at Cranleigh and Dunsfold. As far as we can determine, it appears that Waverley is only capturing data for nitrogen dioxide NO2 and not monitoring particulates at all.  Furthermore, they have not included in their evidence base data from approximately 40 temporary air quality monitors that they have across the borough, which provide critical information on local air quality.  These are serious omissions that we believe could impact on the health of residents and especially for children attending schools located on the A281.

Particulates are the deadliest form of air pollution due to their ability to penetrate deep into the lungs and blood streams unfiltered, causing permanent DNA mutations, heart attacks, and premature death.

Estimates of the number of deaths in UK local authorities that can be attributed to long term exposure to particle air pollution were published by Public Health England (PHE) in April 2014.

This report estimated the annual number of attributable deaths due to particle air pollution in the age group 25+ in Waverley is 56, with a loss of 554 associated life-years lost.  The figure, it is recognised, could in reality be higher.

The estimates are made for long term exposure to particulate air pollution (i.e. over many years) rather than short term exposure to high pollution episodes. However, short term exposure to high levels of air pollution can cause a range of adverse health effects including exacerbation of asthma, effects on lung function, increases in hospital admissions and mortality.

The report was produced to inform public health professionals and air quality specialists in local authorities about the likely effects of particle air pollution on public health in the UK. The estimates are intended to help local authorities consider air pollution among other public health issues.  This should have been included in the background evidence base for the Local Plan.  Whereas it appears that the impact of an increase in particulates has been omitted.

As air pollution is a serious and well-documented increasing risk to public health, at the very least we would expect to see realistic measures that would significantly reduce air pollution, including particulates, for residents, employees, and children attending local schools.

There is no evidence currently to support point 17.7 in the Local Plan Part One that Waverley is “working in partnership with Surrey County Council to reduce the need to travel, encourage alternative forms of transport to the car and reduce emissions. This links to the need to tackle air pollution.”, whilst placing 45% of its total housing allocation in an area reliant on private car usage.

Furthermore, there is no mention of the negative impact on the Guildford AQMA, despite the proposed increase in traffic on the A281 north into Guildford town centre, under the duty to co-operate.

Cranleigh residents do not feel that they have been adequately consulted with on the local plan and feel that their health, from exposure to increased levels of air pollution, will be compromised in the pursuit of a disproportionate number of houses in this area of the borough, where employment opportunities and housing need are not focused and the use of the private car will inevitably grow exponentially. We were extremely disappointed that the Waverley planning portfolio holder and officers did not visit Cranleigh, one of the most negatively affected areas in the borough, during their round of visits in May and June 2014, as confirmed in 3.5 of the Waverley Local Plan Consultation Statement 2016.  We were also extremely disappointed that hard copies of the local plan were not made available to residents in the library as outlined in 2.12 of the Waverley Local Plan Consultation Statement 2016.

Changes we suggest:

Cranleigh should be allocated a lower number of houses in proportion to employment opportunities and to promote sustainable transport options, as well as in accordance with NPPF policy for sustainable development.

Policy CC4 Flood Risk Management

Our Comment:

Evidence of Cranleigh’s flood risk in Waverley Borough Council Level 2 Strategic Flood Risk Assessment (SFRA) August 2016 has not adequately assessed for surface water flooding, or ground water flooding.  Surface Water flood maps indicate that Cranleigh is in an area of wide surface water flooding and yet this fact receives little to no attention in the SFRA 2016.

We would also draw attention to Capita’s Strategic Flood Risk Assessment for Waverley 2010 which reported “High” likelihood of surface water flooding in Cranleigh, as shown in Figure 5.1 Surface Water Flooding Waverley SFRA.

With regard to groundwater the 2016 report also states that:

“2.2.4 Groundwater Flooding

There are very few records of groundwater flooding across Waverley. Based on previous records made available it appears groundwater flooding has historically occurred in Upper Hale, Godalming, Elstead, Churt, Shottermill, Wormley, Witley, south of Busbridge, and Cranleigh. Hambledon is noted as being within the South East England Regional Flood Risk Assessment as being at risk from groundwater flooding. However in the examples of Upper Hale and Cranleigh, it is more likely that the recorded flooding problems were related to water logging and poor surface water drainage than groundwater flooding.”

The 2016 FRA point 2.2.2 makes no mention of ongoing surface water flooding in Cranleigh, despite primary source evidence, including correspondence on this issue between the planning department and Cranleigh Society, including emails, photos, videos and face to face meetings.

Evidence in the WSP Flood Risk Assessment that accompanied the Berkeley Homes application for 425 dwellings (WA/2014/0912) reported that 17 out of 41 (42%) of the trial boreholes across the site showed the presence of groundwater, with 9 (22%) of the total showing groundwater at less than a metre from the surface.

Furthermore, the Environment Agency Groundwater maps record the presence of aquifers i.e. a body of saturated rock to the south and west of Cranleigh.  This means that water may be discharged from this area by upward seepage through the overlying clay.  Previously saturated weald clay has a “rapid run-off behaviour”, meaning that water exits the site far more aggressively than “dry-soil” models.  The EA refer to Cranleigh as a “flashy catchment” – defined as a catchment area that, because of geographic, topographic, and geological factors, shows an almost immediate response to intense rainfall, resulting in a flash flood.  As experienced time and time again in Cranleigh, most recently on 25 June 2016.

Furthermore, the SFRA does not take into account recent revised climate change allowances by the government and the Environment Agency published in February 2016.  These now require applicants and developers to assess a range of climate range allowances from 25% to 70% above the 1% AEP as part of planning applications.  These are significant higher allowances than the previous 20% allowance.

Waverley’s SFRA is not sound and should be updated to reflect more accurately flood risk to Cranleigh from all sources, residents first-hand experience of flooding, together with up-to-date climate change allowances.  It must also reassess the cumulative impact downstream of an additional 4,455 dwellings in this part of the borough with regards to increased flood risk from all sources.

Cranleigh residents do not feel that they have been consulted with on the risk of local flooding and were extremely disappointed that the Waverley planning portfolio holder and officers did not visit Cranleigh, one of the most negatively affected areas in the borough, during their round of visits in May and June 2014, as confirmed in 3.5 of the Waverley Local Plan Consultation Statement 2016.  We were also extremely disappointed that hard copies of the local plan were not made available to residents in the library as outlined in 2.12 of the Waverley Local Plan Consultation Statement 2016.

Policy SS5: Strategic Housing Site at Land South of Elmbridge Road and the High Street, Cranleigh

Our Comment:

500 dwellings have already been approved on this site.  The remainder of this site was subject to a separate planning application WA/2014/2127 (West Cranleigh Nurseries) was refused by Waverley on 27 April 2016 – 265 dwellings.  There is no justification for this additional growth in Cranleigh, which has insufficient access to employment opportunities, limited sustainable transport options and this policy does not take into account up-to-date and revised allowances for climate change published in February 2016 by the government and Environment Agency from 20% to 25% to 70% above the 1% AEP.

This section of the site includes some of the best agricultural land in Waverley (Grade 2) which is in limited supply.  it is also an employment site for horticultural purposes.

This cumulative effect on Alfold Road of this amount of development has not been taken into account and would be severe.  Due to the distance from the high street and local schools, this development would rely heavily on private car use.

The sewerage infrastructure is at capacity and cannot support a development of this size.  There would also be a negative impact on water quality in Cranleigh Waters due to an increase in liquid effluent. No provision is made in the Infrastructure Delivery Plan for sewerage provision.

This proposal would significantly increase the number of people living in an area affected by flooding and would increase the scale of any emergency evacuation considerably.

NPPF places particular significance with respect to land in the “Functional Floodplain” or Flood Zone 3b.  Figure 4.3 of Volume 3: Mapping of the WBC SFRA identified areas of Functional Floodplain within the borough. This figure shows parts of the development site are within the Functional Floodplain.

Cranleigh residents do not feel that they have been adequately consulted with on the selection of this strategic site in the local plan and were extremely disappointed that the Waverley planning portfolio holder and officers did not visit Cranleigh, one of the most negatively affected areas in the borough, during their round of visits in May and June 2014, as confirmed in 3.5 of the Waverley Local Plan Consultation Statement 2016.  We were also extremely disappointed that hard copies of the local plan were not made available to residents in the library as outlined in 2.12 of the Waverley Local Plan Consultation Statement 2016.

Changes we suggest:

Cranleigh should be allocated a lower number of houses in proportion to employment opportunities and to promote sustainable transport options, as well as in accordance with NPPF policy for sustainable development.  Alternative brownfield sites within the village settlement should be investigated that are at lower risk of flooding.

Policy SS4: Strategic Housing Site at Horsham Road, Cranleigh

Our Comment:

There is insufficient evidence to support further green field development on this site when there are suitable brown field sites within the village settlement that have been identified by the Neighbourhood Plan in the Call for Sites.

There is insufficient access to employment land, it would create further reliance on private car use and increase flood risk to neighbouring properties.

The provision of sewerage infrastructure to support this site is not part of the Infrastructure Delivery Plan.

There would be a further detrimental impact on water quality in the local river Cranleigh Waters and on biodiversity, including ancient woodland.

Cranleigh residents do not feel that they have been adequately consulted with on the local plan and were extremely disappointed that the Waverley planning portfolio holder and officers did not visit Cranleigh, one of the most negatively affected areas in the borough, during their round of visits in May and June 2014, as confirmed in 3.5 of the Waverley Local Plan Consultation Statement 2016.  We were also extremely disappointed that hard copies of the local plan were not made available to residents in the library as outlined in 2.12 of the Waverley Local Plan Consultation Statement 2016.

Changes we suggest:

Cranleigh should be allocated a lower number of houses in proportion to employment opportunities and to promote sustainable transport options, as well as in accordance with NPPF policy for sustainable development.  Alternative brownfield sites within the village settlement could be investigated with regard to delivery in 2021.

Policy SS7 New Settlement at Dunsfold Aerodrome

Our Comment:

At para 18.15 Dunsfold Aerodrome – in terms of infrastructure, it is noted that “… developments that generate significant movements should be located where the need to travel will be minimised and the use of sustainable transport maximised.”  there are minimal sustainable transport options available for this site.

“Although Dunsfold Aerodrome is in a relatively isolated location, it is considered in the local plan that the benefits such as the fact that there are no other large brown-field sites in Waverley outweigh any concerns regarding the location of the site.” It appears that the council are justifying the selection of this site based on availability rather than sustainability criteria.

Consultation on Potential Housing Scenarios and Other Issues for the Waverley Local Plan point 2.27 highlights that the Secretary of State in refusing an application for this site “said that the scheme would generate considerable additional road traffic and that this would have a severe and unacceptable impact on an overstretched local road network.  He concluded that the scheme would be unsustainable in transport terms and that allowing the proposals to proceed at that stage would pre-empt the proper consideration of alternatives through the Local Plan process“.  It is unclear what has changed about the impact of the traffic from the original application and how in transport terms the site is now sustainable, also considering the cumulative impact of 1,520 proposed dwellings at Cranleigh.

Although a new sewage treatment plant has been proposed for the site, it is unclear where the liquid effluent will be discharged.  If this was to be in Cranleigh Waters, it would negatively impact water quality.  The river has been highlighted in the High Level Water Cycle Study August 2016 as failing with regard to the Water Framework Directive.

Due to the lack of green belt and environmental protection, there is a high risk of coalescence in the future between Cranleigh, Dunsfold and Alfold. which would impact on surrounding AGLV and the Surrey Hills AONB.

Cranleigh residents do not feel that they have been adequately consulted with on the new settlement at Dunsfold and were extremely disappointed that the Waverley planning portfolio holder and officers did not visit Cranleigh, one of the most negatively affected areas in the borough, during their round of visits in May and June 2014, as confirmed in 3.5 of the Waverley Local Plan Consultation Statement 2016.  We were also extremely disappointed that hard copies of the local plan were not made available to residents in the library as outlined in 2.12 of the Waverley Local Plan Consultation Statement 2016.

Changes we suggest:

Confirmation that the Dunsfold settlement will not discharge into Cranleigh Waters.  The creation of a strategic gap between the settlements of Cranleigh, Dunsfold and Alfold to avoid coalescence of settlements.  The full assessment of the cumulative impact on Cranleigh’s local rural road infrastructure and services of a new settlement at Dunsfold.