Shalford Parish Council – response to consultation on GBC Local Plan Strategy and Sites July 2014
Section 1 : Development growth in conflict with the NPPF
1.1 It is the belief of the Parish Council that the method used to identify the quantity of land needed to meet the housing requirement of the borough is questionable and goes against the guidance of the NPPF. This states that
“Local plans should meet objectively assessed needs with sufficient flexibility to adapt to rapid change unless any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole; or
specific policies in this Framework indicate development should be restricted."
The footnote to the NPPF lists specific policies including designated Green Belt, AONB, SSSI and sites liable to flooding or protected by the Birds and Habitats Directive. GuildfordBC is proud to promote the fact that 89% of the borough is designated as Green Belt yet on this occasion chooses to disregard this very significant point. The NPPF states that only one of the above criteria needs to be met in order to justify a lower level of housing provision than the assessed need. However we consider that both criteria could be applied to the Local Plan because of the impact on the existing infrastructure and the local environment . The Borough Council is currently proposing over 13,000 dwellings,resulting in a need for 652 dpa over the 20 year period 2011-2031 (or well over 800 dpa if calculated over the 15year period in which the new plan will be in operation). This figure needs to be reviewed with regard to balancing the housing need against the impact on the Green Belt, the AONB, AGLV and other local protections as well as the ability of the existing infrastructure to cope with such development. No infrastructure proposals have been published with regard to supporting this level of development across the borough and like most other parishes there is concern about how the possible developments within our parish will impact on the infrastructure of the parish and surrounding areas. This would seem to go against the government guidance.
1.2 The Borough Council is keen to promote the theme of sustainability across its work yet seems to ignore this worthy principle in developing a Local Plan and focuses purely on Market Housing for which there is significant demand, not just from within the borough. Again the government guidance is that market housing numbers should be assessed to ensure that it does not conflict with policies within the NPPF. Looking forward it is clearly an argument that by ignoring the need for sustainability the future of the very attractive borough that exists today and the quality of life offered to the current population will be lost for generations still to come. The Green Belt is such an attractive place for people to live that the Borough Council could not possibly hope to meet the demand for houses here in any sustainable way. One must also ask whether the Council should attempt to do this, so thus making homes more inaccessible for people who have lived in the borough for their whole lives. Like many other parts of the borough Shalford Parish Council recognises the problems facing local people looking for a home and would accept that perhaps this would be a justifiable use of Green belt land. Likewise it acknowledges the suggestion that levels of Affordable Housing should be higher than the national requirement in new development and hopes that this could ease the pressure on Green Belt sites.
1.3There have been recent examples of neighbouring authorities experiencing problems with their Local Plan submissions to the Inspectorate. As a result GBC’s focus seems to be purely on ensuring that the housing need number is robust enough to satisfy the scrutiny of the Inspector and there is little acknowledgement of the special circumstances of the borough mentioned above that allow for the reduction of this figure. As a result, it is possible that the Inspectorate could view the plan as showing inadequate regard to the Green Belt, AONB, AGLV and other protections of which the borough is rightly proud .
Assessing need
1.4 The proposed growth in population in the Draft Plan from 139,700 in 2011 to 155,400 in 2031 is 11.2% over 20 years (approx 0.6%p.a.) as compared to growth from 124,900 in 1980 to 137,200 in 2011 which was 10.6% over 31 years (approx 0.35%p.a.). If this rate of growth were to be extrapolated forward it is clear to see that it is unsustainable in the context of the NPPF taking account of the constraints of Green belt protection, and physical infrastructure limitations of the Borough. Such unrestrained development will affect the quality of life of future generations.
1.5 Despite attempts to gain an understanding from the staff at various consultation events no-one has been able to explain why 13040 new homes are required in the plan period to meet a population increase of 15,700. Appendix B of the Issues and Options document stated that at the 2011 census 137,183 people were housed in 56,400 homes at a density of 2.43 per home. At the same population density of 2.43 it would appear that 6460 new homes would be required to house the anticipated growth of 15,700. We understand that there is hidden homelessness at the moment but such an increase in housing stock cannot be explained by this factor alone. It appears that there is an over-reliance on the various consultants’ reports and that no-one has used basic arithmetic to check that the conclusion is sound.
Section 2: Infrastructure
2.1 The most frequently expressed concern of residents within the parish is that the current traffic congestion is a major concern which will clearly only be increased by any further development. The A281 is regularly congested from Bramley to Guildford and the roundabout in Shalford where it is joined by the A248 is often congested back into Chilworth and Wonersh from the east and into Peasmarsh along the Broadford Roadto the west. The fundamental issues here are:
- the inability of the gyratory system in Guildford to handle the volume of traffic entering and passing through this “gap” town; and
- the potential for bottlenecks created by junctions on major roads to the south of Guildford, such as the roundabouts at Shalford and Bramley and the junction at Rice’s Corner in Chilworth.
Recent and proposed development in Waverley will only add to the problem with Guildford being a major employer for all these areas as well as a hub for entertainment and communication. We note that the traffic flows on A roads in Surrey already have 64% higher volumes than the UK averages and some roads are already operating beyond their design capacity.
2.2 We note that the Settlement Hierachy document assessment of both Chilworth and Shalford for ‘being well connected’ grades both villages as ‘poor or neutral’, and this certainly accords with views expressed by residents about the existing rail and local bus services.
2.3 The policies within the Draft Plan relating to Infrastructure and Transport appear to rely mainly on solving congestion problems by improving public transport and bringing about ”behavioural changes, for example in how people travel” (para 4.202) by encouraging car sharing, walking and cycling. While we would welcome such developments, experience tells us that they will not be enough tosolve our congestion problemsand we have great concern that Surrey CC will not have adequate funding to provide the required improvements to the transport infrastructure. In addition the physical landscape constraints of the Downs and the River Wey militateagainst any realistic improvement to roads approaching Guildford from the south.
2.4 The other most frequently stated concern of residents is that any future development will increase the existing pressure which they already experience on schools, medical services and the utility providers. Whilst there may be availability at certain schools within Guildford Borough or its neighbours, this would result in an increased need to travel, with resulting further traffic congestion during school terms.
Section 3: Specific PDA’s within Shalford Parish
Site 68 Land at Hornhatch Farm – 80 homes
3.1 We object to the development of this site for the following reasons;
3.1.1 The proposed site is on Green Belt land within the Tillingbourne Valley. Later in this response (at 4.5) we emphasise the importance of protecting the industrial and landscape heritage of the valley, noting our concerns about the proposal to inset many of its villages, including Chilworth, and urging that their classification as ‘closed’ villages should be re-evaluated.An important landscape aspect of the Tillingbourne Valley is the separation of the individual settlements within it. In our view, development of this site would add to the sprawling effect of current development along New Road, would decrease the gap between the village and neighbouring Wonersh and Shalford and have a detrimental effect on views from the Surrey Hills AONB.
3.1.2 Chilworth has already experienced a good deal of residential development during the last few years, and residents have very real concerns about any further overloading of local services, such as schools and the local medical centre in Wonersh.
3.1.3 Although traffic congestion is a concern throughout the parish, traffic problems in Chilworth are particularly severe. New Road , the A248, provides residents’ only means of entry and exit from the village. Many older houses along the road have no off-street parking, with the result that residents’ cars have to be parked on both sides of the road, severely hampering the flow of traffic. The road carries a significant volume of ‘through’ traffic of all types (including heavy-goods vehicles), because it forms part of the route which by-passes congestion in Guildford and links areas south of Guildford to the A25. During school terms congestion is increased by cars delivering and collecting children from the two schools situated on New Road (a problem made worse by the withdrawal a few years ago of the Pegasus school bus service). Finally, the village still suffers at peak times from the long-standing problems of the junction of the A 248 and the B2128 road to Wonersh Road at Rice’s Corner, with the resulting tailback along the A248. The provision of an additional 80 homes on this site, which will require access from a position on New Road close to Rice’s Corner will only create further congestion through Chilworth. Key issues for the borough appear to support the “promotion of renewable and low carbon energy” and the resulting Bollution at heavily used road junctions such as Rice’s Corner would be a negative result of this development.
3.1.4 We are aware that there was a previously approved proposal to upgrade the junction of the A284 and the B2128 at Rice’s Corner by installing a roundabout. This proposal was never implemented. However, if this development at Hornhatch Farm were to go forward within the Local Plan then it must be a condition of any such development that the developer be made to pay for a roundabout at Rice’s Corner. We believe that many of the concerns noted above are shared by the adjoining parishes of St Martha and Wonersh.
Site 81 Broadford Business Park – 100 homes
3.2We object to the development of this site for the following reasons;
3.2.1 It is confusing to see this site listed for housing development whilst it is also identified in Policy 13 – Economic Development as one of 17 sites which will be protected as strategic employment sites and their change of use to non-employment uses resisted. Sadly the left hand and right hand do not appear to communicate with each other. This issue must be clarified before final submission of the plan.
3.2.2 As compared to the existing traffic volumes it would seem that 100 homes would create a major increase in traffic movements from Broadford Park with a consequent knock-on effect to the T-junction of that road where it meets the A281 (already noted above for its severe congestion problems – see 2.1 above). It should also be noted that the exit/entrance to the site is very close to a blind bend on the Broadford Road.
3.2.3 As a residential site there is inadequate pedestrian access from the site to the school, railway station,bus stop and shops. There is no safe walking route from Broadford Road along the A281, because there is no pavement on the west side of that road and it is not permitted to construct one on Common land. There are paths over the Common but not of an all-weather nature. If some of these issues could be resolved we would suggest that the site could be possibly support a smaller development of mixed flats and small houses, or even sheltered housing to cater for the elderly and so help to release larger properties for younger families.
3.2.4 The risk of flooding isa concern as parts of the site are identified as Zone 2 and 3 flood zones.We wish to emphasise our concern that any affordable housing provided here should be at no greater risk of flooding than any market property located on the site.
3.2.5 The River Wey is a significant part of the Parish’s “blue infrastructure” and as such would need sensitive development of the site with appropriate screening and due regard for National Trust guidelines. This stretch of water is popular with users of narrow boats and is therefore a valuable tourist attraction for the whole borough. In consequence, it is particularly important that any development of this site does not have an adverse impact on the peaceand tranquillity of the water meadows on the opposite bank.
Site 93 Valley Park Equestrian centre – 5 homes
3.3. Although we know that local residents opposed the application for three temporary pitches (approved in 2012), we have received no representations from them about the current proposal for five permanents pitches on this site.
Section 4: Insetting of Villages- Policy 9
4.1 In response to the Issues and Options document (2013)we raised concern at the process by which the review of current Green Belt boundaries was undertaken. The process described in the Report (Green Belt and Countryside Survey Vol IV Insetting of villages and defining new Green Belt boundaries)involved a number of assessments: ‘assessing the degree of openness’, ‘assessing the location of Green Belt boundaries within the surroundings of each village’ and ‘assessing the suitability of each village for insetting’. We have never found any details of the criteria on which such assessments were based and, despite having been advised by a senior officer within GBC Planning Office that this process is objective, it continues to appear to us to be highly subjective and considerably flawed.
4.2 We note that the objective/subjective assessment process originally resulted in 16 of the 24 villages within the borough being recommended for insetting. In consequence of this, all the Guildford Borough villages in the Tillingbourne valley, with the exception of Albury,stood to lose their Green Belt protection. We note that, following the 2013 consultation, Shere and Gomshall have now been re-classified as open villages and retain this protection.
4.3 A key element in determining whether a village should be inset appears to bethe perception of whether it is ‘open’ or ‘closed’. We believe that the vast majority of residents and visitors to thevillages of the Tillingbournevalley would regard their character as open, as there are extensive visual connections throughout allthese villages to the open countryside of the Green Belt.
4.4 In our view it would be highly undesirable to inset any of the Tillingbourne villages. They all lie between the North Downs and the greensand area to the south, and are visually connected to and from the Surrey Hills AONB.They form part of a unique industrial and landscape heritage (detailed in the 2013application to the Heritage Lottery Fund, led by the Surrey Hills Board). We believe that all the villages in the valley should be regarded as being open and the insetting process needs to be re-evaluated. In our view this is essential if these villages are to preserve their long-term attractiveness and serve to develop the tourism business which GBC wishes to promote.
4.5 Specific issues about insetting villages of Chilworth and Shalford
4.5.1 We note that page 82 of the Report on the Insetting of Villages ( Green Belt and Countryside Study Vol IV)states that ‘the settlement of Shalford contains two distinctive areas: one north and one south of the Kings Road and open Common land’. Furthermore ‘it is close to the urban area of Guildford yet has a Common, rivers and streams converging that make it seem like the countryside’. In addition the Report states: ‘Shalford is situated in the Shalford Gravel Terrace landscape’, ‘the villages of Shalford and Chilworth cover much of the area’ and ‘the landscape strategy for Shalford gravel terrace is to conserve the Commons and the pastoral farmland, the historic village centres and the characteristic relationship of the buildings edging the Common' (emphasis added). We note that the proposed PDAs within the parish and the proposed insetting of the villages of Shalford and Chilworth are in conflict with this landscape strategy.