Briefing Note
Spelthorne Development Plan - Core Strategy and Policies Development Plan Document and Allocations Development Plan Document
Alternative Site Allocations
Issues Common to all proposals for Alternative Site Allocations
1. Green Belt
1(1). In line with our stated position described in the Vision for Lower Sunbury (see under menu ‘About LOSRA’), this Association is opposed to the release of any green belt land for the purpose of development.
1(2). The Surrey Structure Plan states “North Surrey is the most densely developed part of the County….Spelthorne Borough has amongst the highest average density of population of districts in the South-East”
1(3).The “Surrey Structure Plan : Examination in Public” document published in 2003 made further crucial statements about North Surrey, which includes Spelthorne. It stated : “In North Surrey, we were impressed by the shared concerns that further major development would increase problems of service and infrastructure provision……In practice, much housing will come from previously developed land. If this can be accommodated with proper infrastructure and contributes to the quality of life (e.g. with regard to traffic generation or maintaining open space provision, there is no reason to prevent it as a matter of principle. However, these are important requirements, which will not easily be satisfied in the North Surrey sub-area. In many parts of the sub-area, it may not be possible to satisfy them at all……..Where those requirements cannot be met, then we have no doubt that development should not be allowed.”
1(4).Our position in relation to the release of Green Belt in general, may be seen by clicking on to the News Archive 2008 on the Main menu and scrolling down to the entry posted on 9th April and then clicking LOSRA’s Response.
2. Flooding
2(1).Another area of concern relates to the adequacy of drainage, not just in Lower Sunbury but in the whole of Spelthorne Borough. We have no storm sewers.
2(2).The Spelthorne Borough Council Strategic Flood Risk Assessment, 2006 (ch.5 para 60) states: ‘Localised flooding as a result of surface water flooding is also a known risk to properties. Surface water flooding may occur as a result of (for example) culvert and/or gully blockage, surcharging of the underground drainage (or sewer) system, and heavy rain falling on paved areas and/or saturated ground. Surface water flooding is exacerbated in Spelthorne due to the relatively flat topography of the Borough. Water is not able to drain away quickly.’
2(3). Para 61 continues: ‘it is also important to recognise that there is a risk to properties as a result of groundwater flooding. A large proportion of the Borough overlays a soil layer commonly referred to as the ‘Thames Gravels’. These gravels allow the infiltration of local catchment runoff into the ground, reducing the risk of surface water flooding.’
2(4). Volume 1 of the House of Commons, Environment, Food and Rural Affairs Select Committee report on Flooding, is a highly contemporary document having just been published in May 2008.
2(5). It states: ‘ The 2007 floods revealed that, to date, most organisations - including the Government - have focussed almost exclusively on river and coastal flooding, and much less so on surface water and groundwater flooding. Coastal flooding does remain the most serious threat. But (sic) about two thirds of the summer 2007 flooding was caused by surface water flooding, often after intense heavy rainfall overwhelmed drainage systems. No organisation currently has responsibility for surface water flooding, at either the national or local level….’
2(6). The report continues: ‘Regulatory changes are needed to ease pressure on the existing public drainage and sewerage system. We welcome the Government’s Water Strategy policies to change householders’ rights to allow them to pave over their front gardens without planning permission only if the surface is porous and to review the automatic right to connect water drains and sewers to the public sewerage systems….’
2(7). Referring to the development of a long-term strategy the report says: ‘The strategy should also take account of the effect of climate change on the frequency and intensity of rainfall and storm surges. The summer floods exposed the vulnerability of the nation’s critical infrastructure to flooding.’ ….’Some of the places they (the summer 2007 floods) affected had not been thought to be at special risk from flooding (by Environment Agency assessments) and were therefore not well prepared.’
2(8).Para. 6 of the Introduction to the Report states: ‘Surface water flooding often happens quickly and is difficult to predict because it is dependent on the particular features of certain streets, drains and the topography of urban areas. It is expected to become a more common type of flooding event than we have seen in the past - partly because more land has been paved over with impermeable materials and also because of the more intense rainfall expected as a result of climate change. (author’s underlining).
2(9). The Report makes a highly significant observation on the limitations of the Environment Agency: ‘The Environment Agency is the lead delivery body for flood risk management. However, many of its main responsibilities - including its flood defences, maps and warning systems - are geared to river and coastal flooding only.’ (author’s underlining).
Housing Targets
3. Spelthorne Borough Council is confident that it can meet its housing targets without the release of green belt land. Currently, and depending on which figures you use, the Borough is between 6 and 8 years ahead of its target. (In November 2007, the Borough was nearly 8 years ahead). The developers will argue that, because future ‘windfall’ sites cannot be taken into account in making future projections, then those projections will not be met under existing plans. The Borough disagrees and so does this Association. Put simply, LOSRA does not believe that additional housing need has been demonstrated by the developers.
Site specific issues
When considering specific sites in written responses, it may well be that all or some of the reasons for opposition outlined above (1-3) will apply.
1. Site off Croysdale Avenue, Sunbury
Network Rail who acquired this site from Jarvis at the beginning of the decade is requesting that the Green Belt boundary should be amended to exclude their site. They point out that this part of Spelthorne is quite urban in character and that a minor revision of the boundary here would not conflict with the Core Strategy. It would also not conflict with the purpose and role of Green Belts as the site is constrained on all sides by the golf course buildings and other residential development; and therefore cannot result in urban sprawl or loss of access to the countryside.
They further argue that the large golf course buildings and car park already compromise the Green Belt at this point; and that drawing the boundary between the golf course and their site would appear to be a more logical demarcation.
They assert that some of the sites already allocated to meet the housing targets may not come forward within the plan period (the inference being that theirs would).
To see the proposal in full, please log on to the Council website and follow the instructions.
Observations
- Given the size of the plot, this would not constitute a ‘minor revision’. The plot is a significant parcel of land.
- It is precisely because the land is ‘constrained on all sides by the golf course building and other residential development’ that it should be protected for it is fulfilling a primary green belt function.
- Para. 2 (Flooding) and particularly 2.(3) above are very significant. The plot is of sufficient size to ameliorate drainage and minimise flood risk in the area.
- The site was acquired from Jarvis by Network Rail many years ago purely as a speculative venture, that is, to make a profit. This is an asset on which they took a gamble that, in the fullness of time, it would be given over to development. It was Green Belt when they bought it and should remain so now.
- Access to the site would necessitate increased traffic flows in an already congested Green Street; and would also contribute to the pollution levels which are already above acceptable limits at the Sunbury Cross end of Green Street.
6. Para. 3 above (Housing targets) applies.
2. Stratton Road Site
Owned by Persimmon Homes South East, who ask that this land be made available for residential development together with an area for recreational/educational use. They argue that a number of site allocations within the Development Plan Document are unsound for a variety of reasons including, unavailability and being in relatively unsustainable locations. The Stratton Road Site would not (presumably) be similarly disadvantaged.
To see the proposal in full, please log onto the Council website and follow the instructions
Observations
- Access to the site would necessitate increased traffic flows in Nursery Road and Green Street both of which suffer peak time congestion. Additionally, air pollution levels which are already above acceptable limits in the area would be further increased. Green Street is by definition a ‘distributor road’ but is fast becoming a trunk road. Further substantial development in the area would put an intolerable strain on both Nursery Road and Green Street.
- Para. 3 (Housing targets) above applies.
- Para. 2 (1) et seq. (Flooding) above applies.
- The plot is surrounded by substantial development and whilst it may be the intention of Persimmon Homes to give part of it over for recreation/educational use, the certain way to maintain such amenity is to allow it to remain Green Belt. It may be that at some future time it could be made the subject of a Compulsory Purchase Order if the Council identifies the need for more recreational space.
3. Land at Vicarage Farm
A piece of land owned by CEMEX who argue that the site could form a natural greenfield extension to Sunbury and Upper Halliford; and that it has potential to accommodate growth and should be considered for residential development. CEMEX is asking the Council to consider the long-term housing needs of the Borough.
They argue that the releasing of this site from the Green Belt would not compromise wider Green Belt objectives in the vicinity.
To see the proposal in full, please log onto the Council website and follow the instructions.
Observations
- Reference should be made to the LOSRA position on Green Belt. In particular that part which refers to the fulfilment of Green Belt in its primary function of preventing the convergence of settlements. Vicarage Farm sits squarely within this definition. It is difficult to imagine a more inappropriate site to have its allocation changed.
2. Para. 2 (1) et seq. (Flooding) above applies. In particular para. 2 (3).
3. Para. 3 (Housing Targets) above, applies.
4. The case advanced by CEMEX is highly speculative and unconvincing.
Kempton Race Course (2 sites)
The sole rationale behind this proposal is that it is deliverable and that current allocations for development are inter alia, unsustainable or in flood zone. The Race Course owners seek to demonstrate that their holding will solve the problem.
To see the proposals in full, please log onto the Council website and follow the instructions.
It is expected that, given its location, representations pertaining to this site will be put forward by the Sunbury Common Residents’ Association. This said, LOSRA is aware that a number of residences have received consultation papers from SBC.
Observations
- The levels of pollution within a half mile radius of Sunbury Cross are already well above permissible levels. The owners of the Race Course envisage a high concentration of flats on the car park site. The implications for further congestion on Staines Road East are obvious.
- Para. 3 (Housing Targets) above, applies
John Hirsh,
Hon. Chairman LOSRA