RESPONSE TO DRAFT PYRFORD NEIGHBOURHOOD PLAN
We write with comments on the draft Pyrford Neighbourhood Plan on behalf of Burhill Group Limited (BGL). As we think you may know, BGL owns a significant area of land within the area covered by the Pyrford Neighbourhood Forum and as such, is an important contributor to the draft Neighbourhood Plan. These comments on the draft Pyrford Neighbourhood Plan are consistent with the representations that BGL has submitted to Woking Borough Council’s development plan documents and associated evidence base.
Policy VI 2 – Highways impact of proposals
Policy VI 2 states that ‘proposals that will result in a significant increase in vehicular movements must demonstrate that no harm to highway safety will arise from the development’. This policy is not consistent with the guidance in the National Planning Policy Framework that ‘development should only be prevented or refused on transport grounds where the residual cumulative impacts of development are severe’ (paragraph 32). BGL propose the policy is amended to read that ‘proposals that will result in a significant increase in vehicular movements must be supported by an assessment of the residual cumulative impacts of development and the proposals will not be permitted where the impacts are severe’.
Policy OS 1 – Village Open Spaces
Policy OS 1 states that ‘significant new developments that impact on views of the Pyrford escarpment, or, the extensive rural views the escarpment provides, will be required to provide a visual impact assessment. Development that causes harm in this regard will not be permitted’. Whilst BGL understands that any significant development will be required to produce a visual impact assessment, development in some parts of the Pyrford Neighbourhood Forum (the Forum) area may have a minimal impact on the views in and out of the escarpment. Any potential harm to these views could be mitigated through detailed and careful design. BGL propose that the wording of Policy OS 1 is amended to specify the level of harm which would warrant development not being permitted, as restricting development based on minimal harm is not a sound policy. BGL propose the policy is amended to read, ‘significant new developments that impact on views of the Pyrford escarpment, or, the extensive rural views the escarpment provides, will be required to provide a visual impact assessment. Development that causes significant harm in this regard will not be permitted.’
Figure 1 – Plan showing Escarpment Boundary We note that the suggested boundary of the escarpment reflects the Forum’s Landscape Character Assessment (paragraph 8.1.2). This proposed that all of the land to the west of Upshot Lane and north of Pyrford Common Road is within the escarpment. We provide below an extract from Woking Borough Council’s Proposals Map (October 2012) which sets out a different boundary to the escarpment and it runs along Pyrford Common Road and along Upshot Lane. There is no justification for the line of the escarpment to follow the alignment suggested by the Forum and notwithstanding separate representations that BGL will be making to Woking Borough Council on the alignment of the escarpment as a whole, for the purpose of BGL’s representations to the draft Neighbourhood Plan, BGL proposes that Figure 1 should be amended to at least be consistent with Woking Borough Council’s Proposals Map.
Policy SCS 2 – Recreational Space Policy
SCS 2 states that Pyrford has little recreational space for the young and that in the event of any significant development in the area, the developers must provide appropriate new recreational facilities. Under the ‘Reasoned Justification’ section (paragraph 9.2), the Forum states that they are committed to working with its partners to ensure that mistakes made in the past in terms of the location of recreational space, will not happen again and that children’s play space needs to be provided in a safe and central location. The Forum suggests an ideal site for such a facility would be behind the Arbor Youth Club and beside Tegg’s Lane as it would meet the need for ‘something safer and more central to the community. In addition it would be easy to access, close to the school and be a major contribution to the development of a sustainable community’. It goes on to state in para 10.3 that ‘representation will be made to designate the land behind the Arbor Youth Club for recreational use’. BGL does not object to these proposals and confirm that it is willing to discuss how the “new recreational facilities” could be facilitated within BGL’s development proposals for this land.
Section 10 – Projects
A number of aspirational projects are identified including various footpaths that cross or partly cross land owned by BGL (paragraph 10.1). BGL does not object to these proposals and confirm that it is willing to discuss how the proposed footpaths could be facilitated within BGL’s development proposals for this land.
I would be grateful if you could acknowledge receipt of these representations and keep us informed of further evolution of the draft Plan. I confirm that BGL would welcome the opportunity to discuss with you the Estate’s outline development proposals for its landholdings.