3 Farms Meadows (FWI) WAGs QC quipped : This is : The Wrong - - PowerPoint PPT Presentation

3 Farms Meadows (FWI)

www.wisleyactiongroup.co.uk

WAG’s QC quipped:

This is : The Wrong Development (Unsustainable) In the Wrong Location (Greenbelt, Openness, Highways, SPA, Air Quality, London Density, Transport, Heritage) We need your help to defeat it !

Proposal for a “New Town” on TFM

DECEMBER 2014

Framework Thames Basin Heaths SPA Impact Avoidance and Mitigation Strategy

• OUTLINE Access Planning Permission Sought By WPIL

– 2,068 homes (5,000 people, 4000 cars?) – 2 FE Primary School and 4FE Secondary School to 16 – Health Centre – 8 Travellers pitches – Going to GBC Planning Committee April 6th – 3 New Road Systems – 3 New Road Closures

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Current Site Difficulties for Cayman Island based Speculators

• 114 hectares used mainly for agriculture

– Within Greenbelt – Principally good quality agricultural land – Adjacent to Thames Basin Heath SPA – Part SNCI, whole site proposed for SNCI – SSSI (Site of Special Scientific Interest) – Part (up to 17ha) safeguarded by SCC for waste on the lower section of the site included as PDL – Restrictions due to NATS VOR for Heathrow … And WAG reviewing and reporting of voracity of data

Latest WPIL Phased Development Plan

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Sang Underwater Half of the Year SCC Composting Site Protected NATS VOR Site

TBHSPA

SANGS 400 metre protection Zone

SANGS 5 km Protection Zone Access to Site

Objections

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RHS Wisley Surrey County Council – Waste Surrey County Council – Highways Surrey Wildlife Trust Campaign to Protect Rural England University of Surrey Elmbridge Borough Council Mole Valley District Council Ockham Parish Council East Horsley Parish Council West Horsley Parish Council East Clandon Parish Council Ripley Parish Council Send Parish Council Effingham Parish Council Wisley Action Group Ripley Society Cobham Conservation & Heritage Trust Ockham & Hatchford Residents Association Downside & Hatchford Community Group Effingham Residents Association Byfleet, West Byfleet & Pyrford Residents Association Bookham Residents Association Royal Society for Protection of Birds Many hundreds of individuals

Conditions and concerns have to date been lodged by amongst others:

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Environment Agency Thames Water Highways England Police – Crime Prevention Design Adviser (and further comments awaited) Surrey & Sussex Police Surrey County Council – Archaeology Surrey Playing Fields Association NATS GBC Environmental Health, Flood & Water Services and Housing Development However a real SHOCK Natural England have been negotiated into a ‘No Objection’ response: Ø TBHSPA issues have been adequately mitigated Ø In perpetuity Permanent Warden’ will patrol 4xROW’s Ø SANGS underwater 50% of year can be fully counted

Criteria Needed to Develop on Greenbelt

• Must Comply with Rule of Law and NPPF
• Very Special Circumstances – housing need alone not enough
• Proportionate – 150 households in Ockham and 2068 houses

proposed

• Openness of Greenbelt to be Retained – Highest London Density
• Previously Developed Land ie Brownfield First – 12% available
• Sustainable – Needs Infrastructure: Transport, Sewage, Flood

control, Secondary School, Local Employment, Access, Retail, GP

– GBC calculation of min 1666 houses on this site = Sustainable

• Environment and Heritage to be Protected

– Ockham Village 1000 years old – Nox emissions – TBH SPA – SNCI & SSSI

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Local Plan 2003 and NPPF

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Property not in GBC 2003 Local Plan - should not be approved NPPF ‘presumption in favour of Sustainable Development’ does not apply due to the site’s proximity to the SPA. Additionally lack of Very Special Circumstances (VSC) needed to develop within Greenbelt (N.B. Unmet Housing Need not a VSC) Largest part of Brownfield is SCC protected area for Waste and part within 400 metres of SPA so cannot be considered for development nor currently available for SANGS Remainder (old disused runway) was never built on- so no elevation existed and any building would destroy Openness

NPPF – Very Special Circumstances

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Proposed Greenbelt Developments must measure: Benefits Vs Harms Specific to site Housing Need not normally a VSC

Sustainability – What is it?

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3 Aspects of Sustainability for any large development:

• Environmental impact
• Social impact
• Economic impact

Landscape and Heritage Infrastructure

• Transportation (road and rail)
• Other facilities (schools, medical etc)
• Combination approach needed taking into

account other development proposals.

Sustainability : Hierarchy

Points > 20+ Suitable for Growth

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Total points Community Facilitiespoints Rank GuildfordUrban Area 49 18 1 Ash and Tongham 49 17 1 East Horsley 38 18 3 WestHorsley 19 9 13 East & West Horsley together Shalford 29 11 4 Chilworth 28 10 6 Effingham 26 11 7 Send 26 14 7 SendMarsh/Burnt Common 17 7 19 Ripley 25 12 9 Fairlands 24 12 10 Wood St Village 20 9 20

Ockham

4 4 32

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So how can WPI claim that Wisley Airfield is the ‘most sustainable site in Surrey’? This is how it can be done:

Score

today Potential/pie in the sky

S hops

2 Schools

Infant

3

P rim ary

3 Community Facilities Recreation

3

Post Office

3

Doctor

3

Dentist

1

Place of worship 1

1

Open space 1

2

Children's play area

1

Restaurant/café/takeaway 1

1

Community hall 1

1

Transport Buses

3

Railway (within a mile) Employment Local

2

Wider

• 4

30

=== == =====

Villages in GBC Draft Local Plan for Consultation Removed from the Green Belt

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13 14

15

8 4 1 2 5 7

11 10 12

6 3 9

16

CPRE: 600,000 plots in hands of developers not being used !!

Approval=Destruction of 300 Acres of Open Greenbelt in Sensitive Location

• Greenbelt Around one of the Most Important

Cities in the World Showed Great Vision

• Wholesale Decimation of 300+ acres and
• Ancient Villages Withdrawn from Greenbelt

would be a travesty

• The High Cost of Installing New Infrastructure

for a remote new township is waste of government resources

• First Time Buyers will not be able to Afford

these “Affordable Properties” (£300k)

www.wisleyactiongroup.co.uk

Openness of Greenbelt

• View from Surrey Hills
• 4 / 5 storeys on top of Hill – 780 x 48m single bed –WHY?
• Not even affordable at £300k each
• Super High Density Development Visible from Everywhere

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Surrey Hills AONB Board's Response – NO VISUAL IMPACT !!

4/5 Storeys High !!

Likely impacts on surrounding villages

• 5,000 additional residents

– School places – Seats on trains – Parking spaces at Effingham & Horsley station and elsewhere – Longer waiting times for hospital appointments

• 12 years of construction, disruption and HGV’s
• 4,000 additional cars

– Air quality – Longer journeys – More accidents – No/Inadequate footpaths for school children/pedestrians

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‘Misleading Statements’ ? in Planning Application

Only Assembled Site for Five Year Housing Supply

• “It is the only assembled site readily available for development now, to contribute

to the 5 year housing supply” Planning Statement Appendix 3 p25 of 33. The site is subject to: – Up to 3 years work by Thames Water and then subject to funding – Natural England agreed a SANGS area of approx 10 ha per 1000 population ie 49.9Ha SANGS, leaving insufficient land to build a sustainable development – Objection from SCC re Waste Site removes available land – Surrey Highways not content Removal From Greenbelt Within ‘Emerging’ GBC Local Plan

• Para 1.3 of the Planning Statement states that the Site “Has been removed from

the Green belt within the 'emerging GBC Local Plan' as justified by the Council’s evidence base”. Statement repeated in Appendix 6 ‘site…has been taken out (of the Green Belt) as part of the Guildford Greenbelt review. – It is clear no decisions have been made per the GBC press release on the Local Plan deferral stating every development site will be ‘reassessed’.

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‘Misleading Statements’? in Planning Application

Removal From Greenbelt ‘Very Special Circumstances’

• Statement p25 of 33 para 5.22 – “The independent GBCS by Pegasus,
• n behalf of GBC, concluded the same” ie that the site can be removed

from the greenbelt

• The Pegasus report specifically excluded consideration of ‘Exceptional

Circumstances’ para 18.3 Vol5 and assumed extra land they did not

• wn to meet the sustainability calculations.
• The whole Pegasus GBCS report is based on an assumption of utilising

additional land not owned by the applicants and expressly excluded by

• wners at the time, para 24.82 page 50 Pegasus GB GBCS report. This

weakens its relevance to this Planning Application.

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‘Misleading Statements’? in Planning Application

Transport Claims used for Sustainability Test

• In the Energy Strategy and Sustainability Statement (ESSS) the applicant claims ‘one of the unique aspects

which significantly enhances their sustainability credentials’ is that there are 9 railway stations within 5 miles to service the new development. This has not been measured by road systems as abstracts from the AA route finder shows:

• The routes from GU23 6NU to the following railway stations shows the distances set out:

Effingham Junction 2.1m; Horsley 2.4m; Cobham & Stoke D'Abernon (via Plough Lane) 4.6m; Clandon 5.3m;West Byfleet 5.9m; Bookham 7.5m; Byfleet & New Haw 7.5m;Woking 8.1m

• When they close Plough Lane that will leave just 2 stations within 5 miles Effingham and Horsley.
• A second Claim ‘the settlement has direct consented access to the A3 Trunk Road…’ The applicant does not

disclose that this spur road has restricted approval specifically for the access to the “in vessel’ protected waste site with minimal traffic movements due to the sensitivity of the SPA, SNCI etc.

Previously Developed Land as Grounds for Removal From Greenbelt

• p77 Planning Statement describes the Site as follows:
• ‘The Previously Developed nature of a large proportion of the Site ‘
• This claim attempts to mislead readers into thinking the site can be considered Previously Developed Land.
• At best for the Site it is 30 Ha / 114 Ha and with the waste site ‘protected’ it is just 14ha out of 114ha. Neither are a

‘large proportion’.

www.wisleyactiongroup.co.uk

Statements in Planning Application

GBC Need : Availability to Meet Housing Need within 5 Years

• The claim is the first residences will be built :

– 2016/7 (73), 2017/8 (194) – in para 9.8 under “Implementation, Affordable Housing and s106 Heads of Terms”.

There are significant disclosed barriers to this assertion:

• VOR/DME -

– NATS objecting to the site in GBC LP – NATS working with WIPL as to whether the impact can be mitigated. – NATS state that the VOR may be decommissioned after 2022 – Height restrictions limit development and exclude activities – Restrictions cover a large proportion of the potential development site – This is a significant unresolved issue over deliverability uncertainty and could jeopardise sustainability due to size of area affected

• Thames Water

– Thames Water response under Waste: Developer funded impact study… “has confirmed that there is not sufficient capacity to accept this development” – “in the event of an upgrade to our assets being required, up to 3 years lead in time will be necessary and will be subject to funding approval.”

• Time of Inspectors Report if approved
• Heritage (Yarne) issues not addressed – described as ‘TBC’

‘Only Assembled Site Readily Available for Development Now’

• “It is the only assembled site readily available for development now, to contribute to the 5 year housing supply” Planning Statement

Appendix 3 p25 of 33.

• SANGS as a barrier to SPA – should not abut the SPA (Chobham case ) – would remove 50 Ha making site unsustainable if no other

SANGS were found within 5km

• Natural England response now agreed 50Ha SANGS required – still making site too small and therefore unsustainable

www.wisleyactiongroup.co.uk

Statements in Planning Application

Access to Site Already Approved?

• Para 1.12 page 9 of 114 of Planning Statement
• The Applicant states that
• “Direct access onto the A3(T) at Ockham Interchange facilitating enhanced bus

services as well as the primary site access” without qualification.

• It is well known that the approval for this access route was provided for the IVC Waste

Composting 16 Ha site and limited daily truck movements. As this development will not take place the approval for the new use spur road requires a new application to be approved by Highways. This has not been disclosed.

Last Use of Site ‘Airfield’ statement in Application Cover

• Stated in the application last use as “Airfield” – this temporary use ceased in
• 1972. The site originally requisitioned for the “War effort” was to be

returned to agricultural land. The site has been in mixed (livestock/arable) use for centuries.

Abstract from Application:

• “Is the site currently vacant?

Yes

• If Yes, please describe the last use of the site:

Airfield

• When did this use end (if known) (DD/MM/YYYY)? 01/01/1972

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Quality of Agricultural Land

The majority of the site is Agricultural land advertised by Knight Frank 2014 as grade 3 and used by farmer as such for many years. Applicant’s

• riginal claim that it is lowest quality Grade 4 land or worse has now

been corrected. Almost 20ha is BMV land (best and most versatile - the threshold is 20ha!) The site has been farming and agriculture for centuries.

www.wisleyactiongroup.co.uk

Statements in Planning Application

Statements in Planning Application

Pollution P12 ES Non Technical Summary states

• “A quantitative assessment of the potential changes in concentrations of nitrogen

dioxide (NO2) and particulate matter (PM10) at sensitive human receptors during the operational phase of the Development was undertaken. The significance of change to local air quality conditions at existing receptors was determined to be negligible and new residents will not be negatively affected due to predicted concentrations of these pollutants being below the relevant air quality objectives as set out in the UK Air Quality Strategy. “

• Nearest J10 Long Term Data available suggests that the average NO2 air quality

should not exceed 40 : Clearly the intersection measured already exceeds EU safe limits of 40.

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Ockham A3 NO2 Exceeds EU regulations Already !

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Nitrogen Dioxide Data capture % 2007 2008 2009 2010 2011 2012 2013 Bridge Street n 92 39 39 38 40 42 38 34.7 Stoke/York Road n 100 34 33 34 37 39 37 38.5 Josephs Road n 100 26 18 19 22 21 22 22.1 Doverfield Road n 92 26 22 22 29 23 24 23.4 Wisley n 100 38 37 38 40 44 44 44.9 Chantries n 100 15 16 12 17 13 13 13.8 Sands n 100 14 13 14 17 14 15 15 Down Lane n 100 27 23 23 30 23 26 23.4 A331 slip Ash n 92 28 33 26 31 24 26 26.7 The Garth n 92 20 21 16 19 16 19 17.5 Beckingham Road n 83 25 35 28 29 30 27 28.9 WTC n 100 n/a 37 31 34 31 32 32

Wisley JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC mean 2010 50 57 50 45 43 14 24 10 40 46 54 48 40.08 2011 50.1 30.7 49.8 50.1 36 42.4 36 39.2 43.5 54.1 62.5 32.9 43.94 2012 29 49 58 40 37 33 37 44 45 57 63 41 44.42 2013 47.3 47.3 61.4 46.5 29.1 47.3 47.3 41.5 35.7 38.2 51.5 45.6 44.90 2014 43 52 41 39 50 59 49 45 45 41 41 45.91

EU NO2 Limit is 40µg/m3

Expert Ecology Report

In summary the Air Quality Assessment,

• failed to take into account the high levels of pollution the site already

receives,

• incorrectly screens out impact pathways,
• failed to assess changes in acid deposition,
• failed to assess all sources of air pollution,
• failed to carry out an ‘in-combination’ assessment
• failed to fully assess the likely significant effect of change in air quality

upon Thames Basin Heaths SPA. CONCLUSION BY CONSULTANTS: I am of the view that as a result of the above the ES is not likely to be legally compliant and that if the LPA were to rely on the documentation presented to complete the Appropriate Assessment, that assessment would also be flawed.

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Unique Wildlife and Ground Nesting Birds at risk from Pets

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Nightjars, Woodlarks, Dartford Warblers, Bats, Reptiles

Unique Wildlife and Ground Nesting Birds at risk from Development & ROW

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New Town !!

• Standing on slow trains

ALREADY FULL

• Traffic standstill in peak hours
• No Senior school places

ALREADY FULL

• No parking at stations

ALREADY FULL

NEW TOWN

• Standing room only on trains

ALREADY FULL

• Traffic standstill

ALREADY FULL

• Nowhere to park at the

stations ALREADY FULL

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20 40 60 80 100 120 140 Lovelace Clandon & Horsley Surrey TFM Islington

Population Density per Hectare Proposed for Site

Islington has the Highest population Density in All of London !!

Proposed Road Changes 3 Roads Blocked With 4000 Vehicles Added !! 2 New Roundabouts for Congestion

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M25 M25 A3 Black Swan J10 O c k h a m R d N

• r

t h O c k h a m L a n e

RIPLEY

A3 St Andrews Church

OCKHAM

DOWNSIDE

COBHAM

Old La Old Lane High St Newark La Rose La The Drift Forest Rd Pointers Lane O c k h a m L a Horsley Rd C h i l b r

• k

R d Long Reach Access to A3 South Pyrford Lock Effingham Common Rd Byfleet Rd

PLEASE READ Proposals for new road network

OBJECT TO NEW TOWN

Application for 2,100 homes estimates 4,000 extra vehicles

planningenquiries@guildford.gov.uk Ref: 15/P/00012 Contact wisleyactiongroup@gmail.com for more information www.wisleyactiongroup.co.uk

new roundabout

P lo u g h L a

Plough Lane blocked off

Upton Farm

Ockham Lane blocked off new twin roundabout

EFFINGHAM

• ne way

north only

new site of 2,100 homes

site access road site access roads

new roads

• n site

Car park access only

No access from A3 into Old Lane

Elm Corner access closed

Access through site only

Guileshill La RHS East Lane Ockham Rd North

HORSLEY

Additional impacts

• Impact on historic buildings in Ripley, Ockham,

Downside, East and West Horsley, Send

• Loss of good quality agricultural land
• Negative impact on water table
• 675,000 litres additional sewerage a day
• More light pollution
• Flooding Risk
• 12 year construction plan!

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3FM Annual Rainfall Run-off Equates to A Small Lake

• r

The Cargo of a Supertanker

Wiped Out ! Heritage Site : 1000 Years Ockham

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29 Listed Heritage Sites Affected

11th Century Ockham Church Grade 1 Listed

Ockham VOR for Heathrow Reduces Land Availability until 2022+

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Ockham VOR – Large Part of Site Restricted to 2020+ & Safeguarded for Heathrow

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Significant Issues

• Traffic data inconsistent with previous

information – Highways England concerned

• J10 improvements planned but junction is critical

to Strategic Road Network

• Local roads CANNOT COPE NOW – mitigation

impossible

• No easy access to rail (2 miles min – roads not

suitable for PSVs/buses)

• Air quality worst in borough – applicants data

significantly worse than GBC data [SPA requires lower limit]

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Significant Issues(more)

• Air Traffic VOR needed until at least 2022
• Impact on other developments (due to

location could impact development further south down A3 and those planned by RHS)

• Habitats & Appropriate Assessments Required
• Surrounding Councils & Many Objections

Lodged

Conclusion

• This proposed WPIL development is:

– In the wrong place (greenbelt,A3/M25,ancient village, congested Roads, Highways & Trains) – Is too large & dense (unsustainable) for the small rural site available in this location – Will not meet the affordability nor timeliness needs for ‘affordable homes’ for our Borough

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