Pyrford Neighbourhood Forum

Green Belt Review

31/7/15 Letter of objection from Graham Christie

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31/7/15 Letter of objection from Graham Christie (Member for Pyrford, Woking Borough Council)

Dear Sir,         Site Allocations DPD –Regulation 18 Consultation Response

 

I write in response to the above consultation in my capacity as Councillor for Pyrford.

 

I have read the report and attachments prepared by LDA Design for the Pyrford Neighbourhood Forum which is in effect a challenge and counter report (covering

primarily Pyrford Area) to the Site Allocations DPD published by Woking Borough Council ( WBC ). I have read my colleague Cllr Ashley Bowes letter of response to WBC dated 23rd July 2015 and concur with his comments. In addition I have read the evidence available to me which purports to support the Site Allocations DPD ( DPD )

 

I do not intend to duplicate the work already done by others in the above responses but of necessity there may be some overlap. My comments are as follows :

  1. I am dis-satisfied about the WBC evidence upon Landscape which appears to lack recent proper appraisal. This may be of little relevance to many wards but has particular significance for Pyrford where character and Green Belt is very very important. This seems contrary to NPPF
  2. WBC has not carried out 1. a Heritage assessment and 2. a Conservation Area assessment for many years and again this adversely affects Pyrford. I suggest breach of several paragraphs of NPPF Section 12 in respect of 1 and 2.

I suggest that the failure of WBC to have up-to-date assessments as above calls into question the validity of the conclusions reached in the DPD as it affects Pyrford. I suggest that NPPF Para 17 ‘take account of different roles………’ has not been given sufficient consideration in the DPD

  1. Infrastructure in Pyrford is under stress and it appears that the DPD is largely silent upon its current capacity and the capacity for change. There seems to be too much emphasis purely upon delivery of houses without sufficient focus upon sustainability.
  2. I question WBC co-operation with neighbouring authorities with particular reference to several developments just across the Borough boundary in Guildford. These developments some of which will proceed, will adversely impact Pyrford due to traffic increase in an already congested area. For example I detect no reference in the Green Belt Review to the Three Meadows Farms development proposals just over the Borough boundary in Guildford and I cannot detect evidence elsewhere.
  3. I am generally concerned about the impact of Green Belt release in the east of the Borough and its massive, adverse impact upon congestion, if houses are built. I call upon WBC to make available recent traffic surveys which I fail to find within the evidence available.
  4. I question the Spatial Planning and Strategic Planning for the Borough and suggest that what is available seems lightweight and this adversely affects Pyrford which is situated in a largely natural area which is an asset to Woking. Sites selected for Green Belt release in the DPD seem to be somewhat at random and I suggest that sites might better be subject to wider appraisal and linked to Strategy.

Overall I accept that WBC has to follow its Core Plan and that growth needs to be provided for, but not growth which unnecessarily affects the viability and character of Pyrford. Other and more suitable sites seem available within the Borough rather than GB 12 & 13.

I urge WBC to revise their DPD in the light of the constructive and detailed comments made to them especially in the documents referred to above.

 

Yours sincerely,

 

Graham Chrystie

Member for Pyrford, Woking Borough Council

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July 2015 Summary of LDA Design Report on WBC Green Belt Review
Posted by: Steve Wright at 21:31, September 7 2015.
Contents1.0 Introduction2.0 Review of Green Belt Review Methodology

3.0 Review of Green Belt Review Preferred Parcels

4.0 Review of Sites 9a and 9b

5.0 Planning for Sustainable Development

6.0 Review of the Site Allocations

 

1.0 Introduction

1.1. Context LDA Design, on behalf of the Pyrford Neighbourhood Forum (“PNF”), has reviewed the Woking Green Belt Review Final Report (January 2014) prepared by Peter Brett Associates (“the Green Belt Review”), the draft Site Allocations Development Plan Document (“Site Allocations DPD”) and accompanying Sustainability Appraisal (“SA”), in order to advise on the process and findings of identifying Parcels of land for release from the Green Belt. LDA Design has undertaken five key stages of work as part of the review:

  1. A review of the Green Belt Review methodology and its application (‘Review of Green Review Belt Methodology’)
  2. A review of the ‘Preferred Parcels’ identified in the Green Belt Review and their suitability for Green Belt release (‘Review of Green Belt Review Preferred Parcels’)
  3. A review of technical constraints of Sites 9a and 9b (within Parcel 9), which are located near Pyrford Village and adjacent to Pyrford Court (‘Review of Sites 9a and 9b’)
  4. Consideration of how urban areas, like Woking, could be properly planned to encourage sustainable development and prevent incremental growth (‘Planning for Sustainable Development’).
  5. A review of the Site Allocations DPD and underpinning evidence contained in the SA (‘Review of Site Allocations’) This report provides a summary of all of the above reports.

1.2. Terminology References to ‘Parcel 9’ relates to the entire Parcel of land identified in the Green Belt Review for potential Green Belt release. Through the Green Belt Review process, Parcel 9 was subsequently ‘narrowed down’ to a single field adjacent to Pyrford and to the west of Upshot Lane. This was referred to as Site WGB009a in the Green Belt Review, and was identified for Green Belt release.   Although no other sites within Parcel 9 were identified for Green Belt release within the Green Belt Review, it was understood that the field to the east of Upshot Lane was being promoted for development. Therefore, for the purposes of the majority of the LDA Design reports concerning the Green Belt Review, the two sites are referred to as Site 9a i.e. land to the west of Upshot Lane and Site 9b i.e. land to the east of Upshot Lane. Sites 9a and 9b have subsequently has been identified as a potential Green Belt release site within the Site Allocations Development Plan (“DPD”) and its accompanying Sustainability Appraisal Report (“SA”). These are referred to as sites GB12 (9a) and GB13 (9b). We therefore use these site references in the context of the Site Allocations DPD and SA.

 

2.0 Review of Green Belt Review Methodology

A general evaluation of the Green Belt Review was undertaken by LDA Design. Several issues have emerged through this evaluation process that undermines the study as a key evidence base for the Site Allocations DPD preparation process. These are summarised briefly below. There are a number of inconsistencies in the application of assessment criteria throughout the assessment stages that consider the potential release of Green Belt Parcels of land. Particularly, the process for progressing sites for Green Belt release from the stages titled “Stage 2” to “Stage 3” in the Green Belt Review is unclear. Introducing ‘availability’ as an overriding determinant of whether land should be released from the Green Belt is problematic as it directly undermines the methodology designed to identify the importance of the land for Green Belt purposes according to the National Planning Policy Framework (“NPPF”), and indicates a disregard for the assessment method established by the Green Belt Review to rank the land Parcels according to their Green Belt purposes and sustainability credentials. Several important baseline studies are missing from the Green Belt Review assessment, in particular an up to date Landscape Character Assessment and Conservation Area appraisal. This has resulted in important landscape and heritage characteristics being missed that would have influenced the outcome of the assessment. The weight that has been given to ‘deliverability’ based on short term availability criteria in selecting sites for Green Belt removal beyond the plan period is a significant concern of the Green Belt Review process. Data based on narrow site availability criteria at a fixed point in time should not be the overriding parameter for prioritising or justifying sites Green Belt release in the long term (i.e. beyond the local development plan period), especially if they have been assessed as performing critical Green Belt functions. Equally, sites that are potentially suitable for Green Belt release should not be discounted from the process based on their not being actively promoted at the time of review, particularly if it is not made clear to landowners that their land is within an area that could be suitable for Green Belt release. It is considered that too much weight has been placed on site availability as a key indicator of deliverability for allocating sites for Green Belt release beyond the plan period. As such Woking Borough Council (‘WBC’) should refer back to the outcome of the Stage 1 and 2 sieving process – which identified preferred Parcels based on Green Belt function, sustainability criteria and landscape capacity – to determine the total land supply and recommended sites for release. The options presented in the Green Belt Review do not reflect the study’s own findings by presenting the most suitable sites for development first. More fundamentally, there is a lack of consideration as to the consequences on the overall shape and functioning of the Green Belt to inform decision makers as to the consequences of choosing any one option over another.   Our own assessments have identified a number of Parcels, and individual sites within them, that we consider as suitable for possible Green Belt release that have not been presented as potential development options the Green Belt Review; for instance Parcels 7, 13, 20 and 31.

While technically the Green Belt Review does consider sustainability as part of its assessment parameters within the ‘broad location for growth’ identified in Policy CS1 of the Woking Core Strategy, it does not explore potential opportunities for more comprehensive urban extensions or new settlement. This approach is unlikely to result in coherent or sustainable patterns of growth for Woking, and is not supported by best practice guidance and case studies, which encourages considering a variety of growth options and taking a contextual approach to determine how growth can best fit with existing settlement and landscape patterns. This best practice is set out in the accompanying Settlement Planning report.   This lack of clear spatial guidance is compounded by the lack of a ‘strategic level’ landscape assessment. The Green Belt Review only considered development Parcels in isolation without referring back to an overarching set of sustainability or growth objectives. As a result there is no way of considering what contributions different combinations of land Parcels could make in terms of overall sustainability. Instead, the Green Belt Review considers individual Parcels and sites on an incremental/ site by site basis which is unlikely to result in coherent or sustainable patterns of growth. This omission reveals a general lack of strategic thinking with regard to the long term growth and development of Woking in spatial planning terms.

 

3.0 Review of Green Belt Review Preferred Parcels

The methodology adopted in the Green Belt Review to select areas for release from the Green Belt to accommodate development is unconvincing and inconsistent. The Green Belt Review has not made objectively informed decisions, disregarding the assessment findings when identifying the most suitable Parcels/sites for release. In particular, land use and availability considerations have been drawn into the assessment process and are given great weight, resulting in Parcels being identified for Green Belt release which perform ‘Critical’ Green Belt purposes and are unlikely to deliver sustainable development. The weighting applied to the various strands of the assessment process i.e. Green Belt purposes, sustainability criteria and landscape capacity – is not transparent, making it difficult to draw comparisons between different Parcels. In particular there is no matrix contained within the Green Belt Review which demonstrates how the ‘Identification of Areas of Search’ matrix has been applied or utilised when comparing the performance of Parcels. There are also inconsistences in the way Parcels have been assessed. Some have been given ‘split’ score in relation to landscape capacity, while others have benefited from a more detailed analysis of particular area or sites within the Parcel. Interestingly, the two additional sites identified as ‘available’ at Stage 3 (WGB009a and WBG022a) are given ‘split’ scores in Stage 2, allowing for a more detailed assessment to be undertaken and suggesting that ‘availability’ was an influencing factor from the outset. Our own independent ranking of the Preferred Parcels based upon the methodology set out in the Method Statement of the Green Belt Review demonstrates that Parcel 9 ranks as the least suitable land area when compared to all of them. The Green Belt Review indicates that Parcel 9 has ‘low-medium’ sustainability performance; ‘little/no’ and ‘low’ capacity for change; ‘major’ environmental constraints; and fulfilling 2 ‘critical’ Green Belt purposes. There is no alternative evidence within the Green Belt Review (notwithstanding availability) to indicate that Parcel 9 is appropriate for Green Belt release. We agree that Parcels 3, 5 and 6 have potential for Green Belt release, and also suggest that Parcels 2, 7, 13, 20 and 31 warrant further investigations. All of these Parcels perform better than Parcel 9 and we have identified areas within these Parcels that may be suitable for Green Belt release.   LDA Design in conjunction with the Pyrford Neighbourhood Forum has identified an additional site which has not been considered in the Green Belt Review’s Preferred Parcels. The site formed part of Parcel 8 which scored ‘Low’ in terms of relative suitability as an area of search, but is considered to be ‘ Moderately’ sustainable and have a ‘ Moderate’ capacity for change in the Green Belt Review, with only ‘Minor’ environmental constraints. Whilst we are unable to assess this site thoroughly, as we do not have access to databases used within the Green Belt Review for equal assessment, the performance of Parcel 8 is demonstrated in the individual scoring to be more suitable than Parcel 9. We recognise that Parcel 8 was not identified as a Preferred Parcel to be assessed in Stage 3, however the investigation into suitable sites within this Parcel should have come before the recommendation of sites within Parcel 9. Overall it is our view that there is a stage missing from the Green Belt Review which should have undertaken a more refined assessment of individual sites within the high or midranking Parcels.

 

4.0 Review of Sites 9a and 9b

Overall, we consider the judgements and assessment relating to the Green Belt functions, sustainability, environmental constraints and landscape capacity of Parcel 9 to be broadly correct. While we recognise that Parcel 9 has some local variations in character, it is predominately rural in character and contributes to the setting of the urban and the historic environment. Further technical studies have been undertaken to understand the baseline conditions and technical constraints associated with Sites 9a and 9b (‘the Sites’). In relation to land use, Sites 9a and 9b encompass two arable fields, which are separated by Upshot Lane. Site 9a has mature trees and hedgerows along much of the site boundary, although the site is open to Pyrford Common Road. The trees along the northern and western part of the sit boundary are a particularly prominent feature, approximately 20m high and creating a strong boundary between the urban area and surrounding countryside. All of the trees and woodland within Site 9a are protected by a Tree Preservation Order (TPO). Site 9b also has trees and hedgerows along much of its boundary, although the hedgerow along the eastern boundary is more open and ‘gappy’ in places. In relation to access, Sites 9a and 9b are bordered by B367 Pyrford Common Road to the south, while Upshot Lane runs between the Sites and extends from a priority junction with the B367. The Access Appraisal considers number of different access options, including a roundabout at the priority junction; alteration of the existing priority arrangements; and access points off Upshot Lane. Overall it is concluded that the delivery of an acceptable vehicle access would be partially challenging given visibility splay requirements; potential land take; and impact on protected trees. The roundabout option in particular would be out of keeping with the rural character of the area. In relation to landscape character, Site 9a and 9b form part of a relatively narrow tract of land, curtailed by golf courses, that provides a continuous stretch of uninterrupted countryside between the elevated town and River Wey valley. It also contains a number of important heritage assets. The Sites therefore play an important role in containing the southern edge of Woking; providing a strong landscape context for the urban area of Pyrford and providing context for heritage assets. It is a relatively rare example of an area of rural landscape south of Woking that has not been lost to golf course development. Site 9b is also identified as an area of ‘Escarpment and Rising Ground of Landscape Importance’, designated by Woking Borough Council to protect the character of the escarpment. Overall it is concluded that the development of all or part of Sites 9a and 9b will inevitably change the character of the land itself and its immediate surroundings, and will result in harm to landscape character and views and alter the countryside context of the Registered Park and Garden, Avery Road Conservation Area and Pyrford Village. This Parcel is identifiable as countryside which is of inherent value even though it has no formal statutory protective designation. The development of Site 9b in particular would be contrary to planning policy guidance, which seeks to protect the character of the escarpment. In relation to ecology, the fields themselves have very limited ecological value, however, the field margins and woodland belts have potential to provide valuable habitat for dormice, bats, badgers and invertebrates. There are also two water bodies within 250 m of the Sites which may have potential to support great crested newts. In relation to heritage, Sites 9a and 9b adjoin two Conservation Areas (Pryfrod Village and Aviary Road); Pyrford Court Registered Park and Garden; a number of Listed Buildings; and an Area of High Archaeological Potential. It is judged that the Sites have an important role in maintaining a rural setting to Pyrford Court and – whilst development would not affect views from the house and park across the Wey valley to the North Downs – development could potentially erode the rural setting of Pyrford Court and in particular on accessing the property from along Pyrford Common Road and Upshot Lane. The development could also potentially significantly erode the rural setting of the Pyrford Village, which would have traditionally had access to surrounding fields for growing crops. Indeed, the analysis of the historic landscape characterisation (HLC) and old maps illustrate that the surrounding fields were once farmed by the residents of Pyrford. It is also judged that development could potentially erode the remaining rural setting of the Aviary Road Conservation Area. The Green Belt Review identified that Site 9a could accommodate up 223 dwellings. In light of the constraints identified above, in particular the likely access requirements, it is considered that any development proposals will need to include sufficient land for access; offset from surrounding trees, allowing for root protection and creating habitat corridors; space for surface water drainage; and public open space, informed by WBC open space standards. A study of land use and development capacity has therefore demonstrated that Site 9a have deliver 155 dwellings, which is 65 fewer dwellings than indicated in the Green Belt Review.

 

5.0 Planning for Sustainable Development

The purpose of the Green Belt Review was to review the land beyond the existing urban area of Woking, with a view to identifying areas of land suitable for housing. This was mainly in response to the Core Strategy for Woking Borough (part of the emerging development plan), which established that sufficient land could not be identified within the existing urban areas to accommodate all the housing that is required. While the Core Strategy states that the Green Belt Review will identify specific sites for growth, the Green Belt Review does not seem to provide an overall strategy or strategic vision for the direction of growth for Working, or explore potential opportunities for more comprehensive urban extensions or new settlement. Accordingly the Green Belt Review considers Parcels and particular develop0ment sites in isolation. This approach is unlikely to result in coherent or sustainable patterns of growth for Woking, and is not supported by best practice guidance and case studies which encourages considering a variety of growth options and taking a contextual approach to determine how growth can best fit with existing settlement and landscape patterns. A number of documents exist which provide guidance on delivering high quality settlement planning. Both the Commission for Architecture and the Built Environment   (‘CABE’, which now forms part of the Design Council) and Town and Country Planning Association (‘TCPA’) publications recommend that it is important to consider a range of different growth scenarios or options measured against agreed objectives before deciding the best solution for that place. The range of publications from the TCPA also highlights the benefits of garden cities and garden suburbs to help meet the nation’s housing needs. Set in this context WBC should be encouraged to think strategically and consider the following:  Develop a strategic vision and spatial strategy based on evaluating a number of options or scenarios. This could include aggregating the housing need into one area.  Take a contextual approach to determine how growth can best fit with existing settlement pattern and landscape character.  Consider the need for social, economic and environmental sustainability, and seek to secure meaningful community benefits that can be achieved from consolidated areas growth as opposed to smaller scale, incremental development.  Ensure that there are physical links provided by new or existing infrastructure (transport, green infrastructure etc.) between new settlements and existing places, aiding connectivity and integration.

 

6.0 Review of the Site Allocations

The Council has not demonstrated it has fully met the requirements for the SA, the proposed spatial strategy and its requirement to consider reasonable alternatives. As a result, the draft Site Allocations DPD is not justified as it fails to properly consider reasonable alternatives before committing to its preferred spatial strategy. According to the tests of NPPF paragraph 182, this would mean that plan is not justified and therefore not sound. The requirement for a consistent approach to appraising alternatives is set out in national guidance.   The preferred allocation of sites GB12 and GB13 in the Site Allocations DPD suggests that the proper consideration of some options has been retrofitted and therefore there is the possibility that the consultation DPD, having progressed in a certain direction, may have missed more sustainable opportunities. Evidence presented in the Green Belt Review finds there are more suitable sites for release from the Green Belt and to provide safeguarded land for sustainable development for the period of 2027-2040 than sites GB12 and GB13. This in itself raises doubts that the process followed to identify the preferred strategy was based on a full and consistent understanding and assessment of the alternative options available to meet the development requirements over the plan period. A particular example of where we consider that the SA process has not been followed properly or effectively is the recommendation of site GB13, contrary to the Green Belt Review’s findings. The allocation is not supported by the necessary evidence to justify alteration of the Green Belt boundary at this location and is contrary to paragraph 83 NPPF. While we appreciate that the SA and Green Belt Review are separate processes, it is clear that the SA is intrinsically linked to the Green Belt Review and is a key part of its evidence base; the Green Belt Review provides the only technical assessment of the suitability of sites for release from the Green Belt that is based on Green Belt function as defined by the NPPF. In respect of the proportionate evidence used by the DPD, there is an omission of a Boroughwide Landscape Character Assessment which would identify sites within their wider context, rather than individual and unrelated appraisals. There is no up-to-date survey of heritage assets or historic landscape characterisation to inform judgment about their significance. These omissions devalue the planning judgments made within the SA. Finally, no alternative distribution options are considered with the DPD as the plan rules out consideration of potential viable alternatives in the SA despite differing conclusions being reached in the Green Belt Review.

July 2015 Summary of LDA Design Report on WBC Green Belt Review

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Contents

1.0 Introduction

2.0 Review of Green Belt Review Methodology

3.0 Review of Green Belt Review Preferred Parcels

4.0 Review of Sites 9a and 9b

5.0 Planning for Sustainable Development

6.0 Review of the Site Allocations

 

1.0 Introduction

1.1. Context LDA Design, on behalf of the Pyrford Neighbourhood Forum (“PNF”), has reviewed the Woking Green Belt Review Final Report (January 2014) prepared by Peter Brett Associates (“the Green Belt Review”), the draft Site Allocations Development Plan Document (“Site Allocations DPD”) and accompanying Sustainability Appraisal (“SA”), in order to advise on the process and findings of identifying Parcels of land for release from the Green Belt. LDA Design has undertaken five key stages of work as part of the review:

  1. A review of the Green Belt Review methodology and its application (‘Review of Green Review Belt Methodology’)
  2. A review of the ‘Preferred Parcels’ identified in the Green Belt Review and their suitability for Green Belt release (‘Review of Green Belt Review Preferred Parcels’)
  3. A review of technical constraints of Sites 9a and 9b (within Parcel 9), which are located near Pyrford Village and adjacent to Pyrford Court (‘Review of Sites 9a and 9b’)
  4. Consideration of how urban areas, like Woking, could be properly planned to encourage sustainable development and prevent incremental growth (‘Planning for Sustainable Development’).
  5. A review of the Site Allocations DPD and underpinning evidence contained in the SA (‘Review of Site Allocations’) This report provides a summary of all of the above reports.

1.2. Terminology References to ‘Parcel 9’ relates to the entire Parcel of land identified in the Green Belt Review for potential Green Belt release. Through the Green Belt Review process, Parcel 9 was subsequently ‘narrowed down’ to a single field adjacent to Pyrford and to the west of Upshot Lane. This was referred to as Site WGB009a in the Green Belt Review, and was identified for Green Belt release.   Although no other sites within Parcel 9 were identified for Green Belt release within the Green Belt Review, it was understood that the field to the east of Upshot Lane was being promoted for development. Therefore, for the purposes of the majority of the LDA Design reports concerning the Green Belt Review, the two sites are referred to as Site 9a i.e. land to the west of Upshot Lane and Site 9b i.e. land to the east of Upshot Lane. Sites 9a and 9b have subsequently has been identified as a potential Green Belt release site within the Site Allocations Development Plan (“DPD”) and its accompanying Sustainability Appraisal Report (“SA”). These are referred to as sites GB12 (9a) and GB13 (9b). We therefore use these site references in the context of the Site Allocations DPD and SA.

 

2.0 Review of Green Belt Review Methodology

A general evaluation of the Green Belt Review was undertaken by LDA Design. Several issues have emerged through this evaluation process that undermines the study as a key evidence base for the Site Allocations DPD preparation process. These are summarised briefly below. There are a number of inconsistencies in the application of assessment criteria throughout the assessment stages that consider the potential release of Green Belt Parcels of land. Particularly, the process for progressing sites for Green Belt release from the stages titled “Stage 2” to “Stage 3” in the Green Belt Review is unclear. Introducing ‘availability’ as an overriding determinant of whether land should be released from the Green Belt is problematic as it directly undermines the methodology designed to identify the importance of the land for Green Belt purposes according to the National Planning Policy Framework (“NPPF”), and indicates a disregard for the assessment method established by the Green Belt Review to rank the land Parcels according to their Green Belt purposes and sustainability credentials. Several important baseline studies are missing from the Green Belt Review assessment, in particular an up to date Landscape Character Assessment and Conservation Area appraisal. This has resulted in important landscape and heritage characteristics being missed that would have influenced the outcome of the assessment. The weight that has been given to ‘deliverability’ based on short term availability criteria in selecting sites for Green Belt removal beyond the plan period is a significant concern of the Green Belt Review process. Data based on narrow site availability criteria at a fixed point in time should not be the overriding parameter for prioritising or justifying sites Green Belt release in the long term (i.e. beyond the local development plan period), especially if they have been assessed as performing critical Green Belt functions. Equally, sites that are potentially suitable for Green Belt release should not be discounted from the process based on their not being actively promoted at the time of review, particularly if it is not made clear to landowners that their land is within an area that could be suitable for Green Belt release. It is considered that too much weight has been placed on site availability as a key indicator of deliverability for allocating sites for Green Belt release beyond the plan period. As such Woking Borough Council (‘WBC’) should refer back to the outcome of the Stage 1 and 2 sieving process – which identified preferred Parcels based on Green Belt function, sustainability criteria and landscape capacity – to determine the total land supply and recommended sites for release. The options presented in the Green Belt Review do not reflect the study’s own findings by presenting the most suitable sites for development first. More fundamentally, there is a lack of consideration as to the consequences on the overall shape and functioning of the Green Belt to inform decision makers as to the consequences of choosing any one option over another.   Our own assessments have identified a number of Parcels, and individual sites within them, that we consider as suitable for possible Green Belt release that have not been presented as potential development options the Green Belt Review; for instance Parcels 7, 13, 20 and 31.

While technically the Green Belt Review does consider sustainability as part of its assessment parameters within the ‘broad location for growth’ identified in Policy CS1 of the Woking Core Strategy, it does not explore potential opportunities for more comprehensive urban extensions or new settlement. This approach is unlikely to result in coherent or sustainable patterns of growth for Woking, and is not supported by best practice guidance and case studies, which encourages considering a variety of growth options and taking a contextual approach to determine how growth can best fit with existing settlement and landscape patterns. This best practice is set out in the accompanying Settlement Planning report.   This lack of clear spatial guidance is compounded by the lack of a ‘strategic level’ landscape assessment. The Green Belt Review only considered development Parcels in isolation without referring back to an overarching set of sustainability or growth objectives. As a result there is no way of considering what contributions different combinations of land Parcels could make in terms of overall sustainability. Instead, the Green Belt Review considers individual Parcels and sites on an incremental/ site by site basis which is unlikely to result in coherent or sustainable patterns of growth. This omission reveals a general lack of strategic thinking with regard to the long term growth and development of Woking in spatial planning terms.

 

3.0 Review of Green Belt Review Preferred Parcels

The methodology adopted in the Green Belt Review to select areas for release from the Green Belt to accommodate development is unconvincing and inconsistent. The Green Belt Review has not made objectively informed decisions, disregarding the assessment findings when identifying the most suitable Parcels/sites for release. In particular, land use and availability considerations have been drawn into the assessment process and are given great weight, resulting in Parcels being identified for Green Belt release which perform ‘Critical’ Green Belt purposes and are unlikely to deliver sustainable development. The weighting applied to the various strands of the assessment process i.e. Green Belt purposes, sustainability criteria and landscape capacity – is not transparent, making it difficult to draw comparisons between different Parcels. In particular there is no matrix contained within the Green Belt Review which demonstrates how the ‘Identification of Areas of Search’ matrix has been applied or utilised when comparing the performance of Parcels. There are also inconsistences in the way Parcels have been assessed. Some have been given ‘split’ score in relation to landscape capacity, while others have benefited from a more detailed analysis of particular area or sites within the Parcel. Interestingly, the two additional sites identified as ‘available’ at Stage 3 (WGB009a and WBG022a) are given ‘split’ scores in Stage 2, allowing for a more detailed assessment to be undertaken and suggesting that ‘availability’ was an influencing factor from the outset. Our own independent ranking of the Preferred Parcels based upon the methodology set out in the Method Statement of the Green Belt Review demonstrates that Parcel 9 ranks as the least suitable land area when compared to all of them. The Green Belt Review indicates that Parcel 9 has ‘low-medium’ sustainability performance; ‘little/no’ and ‘low’ capacity for change; ‘major’ environmental constraints; and fulfilling 2 ‘critical’ Green Belt purposes. There is no alternative evidence within the Green Belt Review (notwithstanding availability) to indicate that Parcel 9 is appropriate for Green Belt release. We agree that Parcels 3, 5 and 6 have potential for Green Belt release, and also suggest that Parcels 2, 7, 13, 20 and 31 warrant further investigations. All of these Parcels perform better than Parcel 9 and we have identified areas within these Parcels that may be suitable for Green Belt release.   LDA Design in conjunction with the Pyrford Neighbourhood Forum has identified an additional site which has not been considered in the Green Belt Review’s Preferred Parcels. The site formed part of Parcel 8 which scored ‘Low’ in terms of relative suitability as an area of search, but is considered to be ‘ Moderately’ sustainable and have a ‘ Moderate’ capacity for change in the Green Belt Review, with only ‘Minor’ environmental constraints. Whilst we are unable to assess this site thoroughly, as we do not have access to databases used within the Green Belt Review for equal assessment, the performance of Parcel 8 is demonstrated in the individual scoring to be more suitable than Parcel 9. We recognise that Parcel 8 was not identified as a Preferred Parcel to be assessed in Stage 3, however the investigation into suitable sites within this Parcel should have come before the recommendation of sites within Parcel 9. Overall it is our view that there is a stage missing from the Green Belt Review which should have undertaken a more refined assessment of individual sites within the high or midranking Parcels.

 

4.0 Review of Sites 9a and 9b

Overall, we consider the judgements and assessment relating to the Green Belt functions, sustainability, environmental constraints and landscape capacity of Parcel 9 to be broadly correct. While we recognise that Parcel 9 has some local variations in character, it is predominately rural in character and contributes to the setting of the urban and the historic environment. Further technical studies have been undertaken to understand the baseline conditions and technical constraints associated with Sites 9a and 9b (‘the Sites’). In relation to land use, Sites 9a and 9b encompass two arable fields, which are separated by Upshot Lane. Site 9a has mature trees and hedgerows along much of the site boundary, although the site is open to Pyrford Common Road. The trees along the northern and western part of the sit boundary are a particularly prominent feature, approximately 20m high and creating a strong boundary between the urban area and surrounding countryside. All of the trees and woodland within Site 9a are protected by a Tree Preservation Order (TPO). Site 9b also has trees and hedgerows along much of its boundary, although the hedgerow along the eastern boundary is more open and ‘gappy’ in places. In relation to access, Sites 9a and 9b are bordered by B367 Pyrford Common Road to the south, while Upshot Lane runs between the Sites and extends from a priority junction with the B367. The Access Appraisal considers number of different access options, including a roundabout at the priority junction; alteration of the existing priority arrangements; and access points off Upshot Lane. Overall it is concluded that the delivery of an acceptable vehicle access would be partially challenging given visibility splay requirements; potential land take; and impact on protected trees. The roundabout option in particular would be out of keeping with the rural character of the area. In relation to landscape character, Site 9a and 9b form part of a relatively narrow tract of land, curtailed by golf courses, that provides a continuous stretch of uninterrupted countryside between the elevated town and River Wey valley. It also contains a number of important heritage assets. The Sites therefore play an important role in containing the southern edge of Woking; providing a strong landscape context for the urban area of Pyrford and providing context for heritage assets. It is a relatively rare example of an area of rural landscape south of Woking that has not been lost to golf course development. Site 9b is also identified as an area of ‘Escarpment and Rising Ground of Landscape Importance’, designated by Woking Borough Council to protect the character of the escarpment. Overall it is concluded that the development of all or part of Sites 9a and 9b will inevitably change the character of the land itself and its immediate surroundings, and will result in harm to landscape character and views and alter the countryside context of the Registered Park and Garden, Avery Road Conservation Area and Pyrford Village. This Parcel is identifiable as countryside which is of inherent value even though it has no formal statutory protective designation. The development of Site 9b in particular would be contrary to planning policy guidance, which seeks to protect the character of the escarpment. In relation to ecology, the fields themselves have very limited ecological value, however, the field margins and woodland belts have potential to provide valuable habitat for dormice, bats, badgers and invertebrates. There are also two water bodies within 250 m of the Sites which may have potential to support great crested newts. In relation to heritage, Sites 9a and 9b adjoin two Conservation Areas (Pryfrod Village and Aviary Road); Pyrford Court Registered Park and Garden; a number of Listed Buildings; and an Area of High Archaeological Potential. It is judged that the Sites have an important role in maintaining a rural setting to Pyrford Court and – whilst development would not affect views from the house and park across the Wey valley to the North Downs – development could potentially erode the rural setting of Pyrford Court and in particular on accessing the property from along Pyrford Common Road and Upshot Lane. The development could also potentially significantly erode the rural setting of the Pyrford Village, which would have traditionally had access to surrounding fields for growing crops. Indeed, the analysis of the historic landscape characterisation (HLC) and old maps illustrate that the surrounding fields were once farmed by the residents of Pyrford. It is also judged that development could potentially erode the remaining rural setting of the Aviary Road Conservation Area. The Green Belt Review identified that Site 9a could accommodate up 223 dwellings. In light of the constraints identified above, in particular the likely access requirements, it is considered that any development proposals will need to include sufficient land for access; offset from surrounding trees, allowing for root protection and creating habitat corridors; space for surface water drainage; and public open space, informed by WBC open space standards. A study of land use and development capacity has therefore demonstrated that Site 9a have deliver 155 dwellings, which is 65 fewer dwellings than indicated in the Green Belt Review.

 

5.0 Planning for Sustainable Development

The purpose of the Green Belt Review was to review the land beyond the existing urban area of Woking, with a view to identifying areas of land suitable for housing. This was mainly in response to the Core Strategy for Woking Borough (part of the emerging development plan), which established that sufficient land could not be identified within the existing urban areas to accommodate all the housing that is required. While the Core Strategy states that the Green Belt Review will identify specific sites for growth, the Green Belt Review does not seem to provide an overall strategy or strategic vision for the direction of growth for Working, or explore potential opportunities for more comprehensive urban extensions or new settlement. Accordingly the Green Belt Review considers Parcels and particular develop0ment sites in isolation. This approach is unlikely to result in coherent or sustainable patterns of growth for Woking, and is not supported by best practice guidance and case studies which encourages considering a variety of growth options and taking a contextual approach to determine how growth can best fit with existing settlement and landscape patterns. A number of documents exist which provide guidance on delivering high quality settlement planning. Both the Commission for Architecture and the Built Environment   (‘CABE’, which now forms part of the Design Council) and Town and Country Planning Association (‘TCPA’) publications recommend that it is important to consider a range of different growth scenarios or options measured against agreed objectives before deciding the best solution for that place. The range of publications from the TCPA also highlights the benefits of garden cities and garden suburbs to help meet the nation’s housing needs. Set in this context WBC should be encouraged to think strategically and consider the following:  Develop a strategic vision and spatial strategy based on evaluating a number of options or scenarios. This could include aggregating the housing need into one area.  Take a contextual approach to determine how growth can best fit with existing settlement pattern and landscape character.  Consider the need for social, economic and environmental sustainability, and seek to secure meaningful community benefits that can be achieved from consolidated areas growth as opposed to smaller scale, incremental development.  Ensure that there are physical links provided by new or existing infrastructure (transport, green infrastructure etc.) between new settlements and existing places, aiding connectivity and integration.

 

6.0 Review of the Site Allocations

The Council has not demonstrated it has fully met the requirements for the SA, the proposed spatial strategy and its requirement to consider reasonable alternatives. As a result, the draft Site Allocations DPD is not justified as it fails to properly consider reasonable alternatives before committing to its preferred spatial strategy. According to the tests of NPPF paragraph 182, this would mean that plan is not justified and therefore not sound. The requirement for a consistent approach to appraising alternatives is set out in national guidance.   The preferred allocation of sites GB12 and GB13 in the Site Allocations DPD suggests that the proper consideration of some options has been retrofitted and therefore there is the possibility that the consultation DPD, having progressed in a certain direction, may have missed more sustainable opportunities. Evidence presented in the Green Belt Review finds there are more suitable sites for release from the Green Belt and to provide safeguarded land for sustainable development for the period of 2027-2040 than sites GB12 and GB13. This in itself raises doubts that the process followed to identify the preferred strategy was based on a full and consistent understanding and assessment of the alternative options available to meet the development requirements over the plan period. A particular example of where we consider that the SA process has not been followed properly or effectively is the recommendation of site GB13, contrary to the Green Belt Review’s findings. The allocation is not supported by the necessary evidence to justify alteration of the Green Belt boundary at this location and is contrary to paragraph 83 NPPF. While we appreciate that the SA and Green Belt Review are separate processes, it is clear that the SA is intrinsically linked to the Green Belt Review and is a key part of its evidence base; the Green Belt Review provides the only technical assessment of the suitability of sites for release from the Green Belt that is based on Green Belt function as defined by the NPPF. In respect of the proportionate evidence used by the DPD, there is an omission of a Boroughwide Landscape Character Assessment which would identify sites within their wider context, rather than individual and unrelated appraisals. There is no up-to-date survey of heritage assets or historic landscape characterisation to inform judgment about their significance. These omissions devalue the planning judgments made within the SA. Finally, no alternative distribution options are considered with the DPD as the plan rules out consideration of potential viable alternatives in the SA despite differing conclusions being reached in the Green Belt Review.

6 July 2015 Object to proposal to develop 400+ houses

by 5 Comments

400+ NEW HOUSES FOR PYRFORD?

  1. The Story so Far – Woking BC have announced their proposals for meeting housing requirements in the period 2015-2040. This predominantly impacts the east end of the Borough and earmarks the two Pyrford fields, either side of Upshot Lane, for 423 new houses in the 2027 – 2040 timeframe (see map here). This blights land in the current Green Belt and endangers heritage views from the Pyrford Escarpment to the North Downs. Additionally one of the fields was not recommended as appropriate for use by the councils’ own planning consultants, PBA, in the Green Belt Review published late in 2014. We are now in a 6 week consultation period when representations and objections to these proposals from the public will be received by the Council.
  2. What’s been done About It? – A public meeting held on 22 June resolved that the Neighbourhood Forum would challenge the removal of 2 fields from the green belt and the proposals to build 400+ new homes on them. Indeed your Neighbourhood Forum has been active in working with Graham Chrystie, one of our Borough Councillors and a team of Planners and Lawyers, sponsored by a local resident, to defend our environment. The nature of the village and the surrounding green landscape is very dear to the majority of residents and why many of us came to live here, in the first place. In addition the draft Neighbourhood Plan has just achieved a 98.2% agreement rating in our own local consultation and reflects a great deal of community concern about the state of the local road infrastructure suggesting that, with the West Byfleet and Wisley development proposals, we could soon live in a state of permanent gridlock!
  3. Way Forward – The Forum has made representations to Woking BC in this regard and is preparing further representations with our advisors. However your personal objections are very powerful in reminding the powers that be of the opinions held by the electorate.

So if you are against the proposals we urge you to email your response to planning.policy@woking.gov.uk or write direct to Planning Policy team, Woking Borough Council, Civic Offices, Gloucester Square, Woking, Surrey, GU21 6YL. If you choose to email please send us a copy on info@pyrfordforum.org.

Please remember to include your name, address and post code, whichever method you choose, and make the representation personal. We have added below some suggestions to help you with your letter/email. Full details about the consultation are explained athttp://www.woking2027.info/allocations.

WE HAVE UNTIL 31st JULY TO REGISTER OUR OBJECTIONS

YOU MUST OBJECT NOW!

References – Communications and information concerning the site allocation consultation will be managed through the Pyrford Neighbourhood Forum web site where further reference material, and suggestions for objections will be added.  Please see www.woking2027.info – for full documentation on Woking BC site allocation proposals.

This summary is intended to illustrate key issues for your letter to the Borough:

  1. The Borough have ignored the PNF’s 2 letters raising concerns about the Green Belt Review and their advisers attempts to address the Borough Executive were repulsed with the Executive proceeding to take the decision to publish the DPD apparently without reviewing valid representations. The PNF has objected to the Borough’s approach as have their advisers.
  2. The Borough (WBC ) have substantially departed from their own independent advisers, Peter Brett Associates, recommendations concerning Pyrford : is this acceptable to you?
  3. The PNF advisers comments as made to WBC, in the advisers paragraph 2 are clear. Is it acceptable that WBC chose to defer any action upon these points and proceed to approve a DPD over which there is a big question mark around Pyrford issues?
  4. Do you agree Pyrford’s charm and character are important and that maintaining the natural landscape and views as well as footpaths are important? Pyrford is unique in Woking Borough in enjoying its relatively unspoilt countryside and we believe this forms an asset for the entire borough. Do you concur?
  5. Pyrford is unique in the Borough for its well maintained historic buildings and conservation areas. Heritage assets are highly valued nationally. Would removal of Green Belt status from our 2 threatened fields could cause irreparable damage to these assets?
  6. Pyrford is already congested during the day around the central village area. Would the imposition of 433 new houses be likely to increase congestion and perhaps result in gridlock?
  7. Are you satisfied with traffic/highways congestion at present?
  8. Are  you satisfied with the lack of WBC focus upon likely major housing developments just over the WBC border in Guildford Borough EG Wisley Airfield and two others?  Do you accept the possible imposition of massive traffic increase  from the south passing through Pyrford on its way to West Byfleet Station and Retail Centre? Do you accept that the Newark Bridges could cope with greatly increased traffic?
  9. Please think about Ecolgical Impact , Water and Sewerage impact plus other Infrastructure problems. Transport is essential to us all! What about bio-diversity?  ​

A. Pyrford Primary School is about to be re-built ( 50 year lifespan expected ) and the number of pupils will slightly increase to meet current demand. 433 new houses will throw up a massive need for school places possibly in 2030.
B. Elderly Care Facilities are needed
C. Nursery and Pre School facilities are at capacity at present
D. Our Village is a community where people want to live and much of this revolves about the pleasant environment. Safety is of paramount importance and the character of the village and its wide blend of facilities is something which once destroyed cannot readily be re-created.
E. It would be unrealistic if we were not to concede that some change and  development must occur. Is a wholesale change to the character of  the village by the threat of 433 new houses the solution? Perhaps we should focus upon the supply of suitable downsizing apartments for mature citizens who want to stay in the area but cannot find a suitable new home? Or perhaps we could encourage some affordable homes which are sadly lacking in Pyrford ( affordable generally means 80% of market rent which is a high barrier for many ) By imaginative ideas and concepts we can demonstrate that Pyrford can move forward and continue to be a vibrant growing community. Can you come up with some innovative ideas? ​Please supply the Forum with your ideas as well as telling WBC.
F. We hope that we have given you some food for thought and you will respond  to WBC and ensure that your voice is heard : your response really counts! Pyrford has always responded magnificently to all calls upon it and just recently over 500 of you responded to our Survey and Questionaire about our new Neighbourhood Plan. Success may well depend upon substantial local support!

 

6 July – More suggestions for objection letters

by 3 Comments

6 July – More suggestions for objection letters from our advisors at Pinsent Masons and LDA Design

Comments to form part of the Consultation process commencing 18th June 2015

  1. The Council have approved the draft Site Allocations DPD without taking into account full representations received. The Executive, in the meeting on 4 June 2015, referred to a letter dated 3 June 2015, sent by LDA Design on behalf of the Pyrford Neighbourhood Forum. The Executive chose not to review the representations of the letter but were of the view that the draft Site Allocations DPD was “based on robust evidence” and as a result could be approved. The LDA Design letter in fact stated to the contrary and demonstrated that the evidence base was not robust. The Executive should have therefore fully taken into account the comments raised within the LDA Design letter before approving the draft Site Allocations DPD for public consultation.
  2. The draft Site Allocations DPD is in part based upon the Peter Brett Green Belt Review (‘the Green Belt Review’), which is flawed in a number of respects. Particularly:
  • Sites GB12 and GB13 are consistently assessed in the Green Belt Review as not being suitable for release due to fulfilling two ‘critical’ Green Belt purposes, with poor sustainability and high landscape sensitivity. Furthermore, much of the evidence presented in the Green Belt Review undermines the case for its subsequent inclusion.
  • Site GB13 was considered in the Green Belt Review as being particularly sensitive due to the open, exposed, nature of the Site and its designation as an ‘Escarpment and Rising Ground of Landscape Importance’ (designated in the Woking Local Plan 1999 under Policy NE7 and carried forward into the Woking Core Strategy 2012 by Policy CS24 – Woking’s Landscape and Townscape). GB13 was considered unsuitable for residential development.
  • The Green Belt Review “sieves” out a number of sites based on a combination of Green Belt, environmental and sustainability factors, including GB12 and GB13. It then reintroduces GB12 back into the assessment at the end of the process based on land availability and whether the sites have been previously promoted. This is not identified as criteria within the methodology, and there are fundamental flaws in utilising availability/promotion as a key factor for determining areas suitable for release.
  • The Green Belt Review does not provide any reasonable justification for reintroducing sites GB12 and GB13, particularly when there are several alternative sites which have performed better in terms of their Green Belt suitability and/or sustainability credentials, notably Parcels 7, 13, 2, and 28.
  • The sites identified in the Green Belt Review have not all been subject to an equal and consistent assessment. Some sites have been broken down into ‘sub-parcels’ and subjected to a more refined appraisal, while others have been identified as “potentially suitable” but are not considered further due to a lack of information about ownership and availability. As set out above, this is not a sound means of determining areas suitable for release.
  1. Purpose 4 of the Green Belt ‘To preserve the setting and special character of historic towns’ as defined in the National Planning Policy Framework (NPPF) is removed from the Green Belt Review as it considered irrelevant to Woking, and the assessment consistently neglects to consider important historic assets within the Borough. While it is noted that Woking is not an ‘historic town’, historic assets should still be assessed in combination with other important ‘local’ considerations relevant to the setting of Woking.
  2. The Council states that it is satisfied that the draft Site Allocations Development Plan Document (draft Site Allocations DPD) follows those recommendations made in the accompanying Sustainability Appraisal (SA) and Green Belt Review, in order to deliver the most sustainable pattern of development as required within the Core Strategy. However there are obvious and noted conflicts between the SA and Green Belt Review conclusions including:
  • Site GB13 was not considered as suitable for release from the Green Belt in the Green Belt Review, yet it is identified as a “preferred site” in the SA. The Council considered that the capacity of sites recommended for release in the Green Belt Review was not sufficient to meet the 2040 housing land supply targets. As a result, the Council have included site GB13 as a safeguarded site based on the SA recommendation, despite consistently being identified as unsuitable in the Green Belt Review and removed from consideration in Stage 2 of the assessment.
  • Parcel 7 is rejected from the SA as it is not considered to be a reasonable alternative, contrary to the Green Belt Review’s recommendation that it could be considered as a safeguarded site if other parcels cannot provide sufficient quantum of development for the plan period and beyond to 2040 (as discussed above).
  • The Council rejected the Green Belt Review’s recommendation that sites are released for rationalisation of the Green Belt Boundary (with the exception of West Byfleet Junior and Infant School Playing Fields) or released to provide a buffer around identified development sites, stating they are already “clear and defensible”.
  • The SA does not only assess sites recommended in the Green Belt boundary review report for development. It is a separate and distinct evidence base that assesses all other reasonable alternative sites promoted and identified in the Strategic Housing Land Availability Assessment (SHLAA) and the Employment Land Review and Topic Paper in equal detail. However, the SA does not assess any sites within Parcel 31, which in the ranking order of Parcels within the Green Belt Review, is considered more suitable than Parcel 9.
  1. Conflict between Core Strategy and Sustainability Appraisal: There are conflicts that exist between the Core Strategy objectives and SA objectives, as a result of the need to protect the purpose of the Green Belt, whilst identifying sufficient sites to deliver the unmet housing need.
  2. Sustainability Appraisal and the draft Site Allocations DPD:
  • The SA only partially relies on the Green Belt Review. The Council have come to their own decisions on site allocation and suitability ranking, without any further evidence base to justify this decision. The SA therefore cannot be said to form a robust evidence base;
  • The Site Allocations DPD draws directly upon the evidence of the Green Belt Review and the SA, rather than utilising the key document, the SA. The SA in itself has already discounted certain sites and conclusions reached within the Green Belt Review. It is therefore inconsistent to reintroduce this document and conclusions already discounted back into the Site Allocations DPD process;
  • The Site Allocations DPD alternates between the Green Belt Review and SA at different stages of the assessment process. Stage 2 utilises the Green Belt Review, whilst stage 3 utilises the SA. This creates an unsound evidence base and inconsistency in the assessment methodology process.
  1. Landscape Impact of Developing GB12 and GB13
  • Site GB12 is bound by mature tree and shrub belts which substantially screen the urban edge of Woking. All the trees within Site GB12 are covered by a Tree Protection Order (TPO).
  • Site GB13 is open, sitting on top of the south-east facing slope of the Wey Valley and with connecting views between the escarpment, river valley and beyond to the Surrey Hills AONB. Development will have an impact of the character of both GB12 and GB13 and could result in the loss sensitive landscape features.
  • When considered in the wider context, Sites GB12 and GB13 – together with the adjoining woodland and fields – form a relatively narrow tract of land that provides a continuous stretch of uninterrupted countryside between the town and river valley. This countryside is curtailed by surrounding golf courses, which are formal man-made features in the landscape and of distinctly different character, comprising artificial land forms, fairways and bunkers.
  • Sites GB12 and GB13 play an important role in containing the southern edge Woking, and providing a strong landscape context for the village of Pyrford. Sites GB12 and GB13 also form part of a rare example of an area of rural landscape that has not been lost and degraded by golf course development.
  1. Historic Environment Impact of Developing sites GB12 and GB13
  • This countryside contains a number of important heritage assets. Development on GB12 and GB13 could cause adverse impacts to such heritage assets.
  • Sites GB12 and GB13 have an important role in providing a rural setting to Pyrford Court Registered Park and Garden and Listed Buildings. Development could potentially erode the landscape around Pyrford Court, in particular when accessing the property from along Pyrford Common Road and Upshot Lane.
  • Sites GB12 and GB13 also form part of the land surrounding Pyrford Conservation Area and an analysis of the historic maps illustrate that the surrounding fields were once farmed by the residents of Pyrford. Whilst development of Sites GB12 and GB13 would not affect the architecture and layout of the village it could erode the rural setting of the village.
  1. Through development of GB12 and GB13, there would be an adverse impact on:
  • Pyrford Court Registered Park and Garden and Listed Buildings and a number of grade II listed buildings;
  • the Pyrford Area, and its surrounding agricultural landscape and several farms that are judged to form part of its setting, including eastwards along Warren Lane to incorporate (grade II Wheelers Farm and Barn);
  • the 1480’s well preserved listed Wheelers Farmhouse and outbuildings together with the adjoining 300/400 year old Barn; and
  • the building at Key Lees.

    10. Access and Transport Impact of Developing GB12 and GB13

  • The existing B367 and Upshot Lane priority junction is already busy with traffic and is an accident cluster. This indicates there may be issues with the design, layout or condition of the local highway network.
  • Access into Site GB12 from Upshot Lane would be problematic due to the existing, dense, tree line/hedgerow that borders the site. The result would be a large amount of tree clearance and land take into the Site, which would reduce overall capacity.
  • Site GB12 could also be accessed from the B367 Pyrford Common woodland, bordering the site’s southern boundary but this would also result in substantial tree loss and direct vehicular access on to trunk roads is not desirable.
  • Consideration has been given to a roundabout at the priority junction but this would require a very large diameter, resulting in significant tree loss and landscape/heritage impacts. Additionally the area is considered to be of archaeological importance.
  • Pedestrian access to Sites GB12 and GB13 is also considered to be problematic due to the lack of existing footway provision and speed of traffic along the local roads.

    11. Other points to include in the consultation response:

  • Ecological Impact of Developing GB12 and GB13: Any local evidence of badgers, birds, protected species or ecological activity.
  • Water Resource and Hydrology: Any local evidence flood risk and drainage on both sides.
  • Infrastructure difficulties and transport: Reference to access, transport and infrastructure difficulties should be included as applicable.

 

16 May 2015 GBR Update

by 4 Comments

 

From our work on the Pyrford Neighbourhood Development Plan we know that everyone in our community really values the Green Belt that is a key to, and an integral, part of the character of the neighbourhood.  Hence it is important to up-date you on the current position of the Green Belt Review (GBR), how Woking Borough Council (WBC) will choose Site Allocations for new housing development, demanded by the Government and what the Forum is doing on your behalf.

WBC is legally bound to review the Green Belt periodically and there is an obligation to facilitate the building of 292 houses per annum in the Borough. Once brown field sites and other land development has been exhausted then it is necessary to turn to the Green Belt to provide sites for housing in the period to 2040 WBC were advised that Green Belt land is required to meet their obligations and commissioned a Green Belt Review, to identify appropriate Green Belt development sites, from consultants, Peter Brett Associates (PBA).   PBA reported back to WBC, in late 2013, and copies of the PBA Review were released by WBC, to the public, in the summer of 2014.

What has happened since then?

FORUM ACTION

Pyrford Neighbourhood Forum (PNF) has been considering the PBA review since autumn last year.   Whilst the planning issues are very complex it is also clear to the layman, that there are several discrepancies and contradictions in the PBA review.  As a consequence PNF wrote on two occasions to WBC:

1. 29th December 2014 (see separate article below) – identifying discrepancies and detailing our views on the PBA review.

2. 24th March 2015 (see separate article below) – detailed our views on a planning application, to Guildford Borough Council, for 2,100 houses at Wisley Airfield and it’s impact on our already overstretched road infrastructure, traffic congestion and safety as commuters drive through Pyrford to Woking and West Byfleet stations on their daily commutes to work.  We also noted that this application was not mentioned in the PBA review. This development site is just over the southern boundary of WBC, close to Ripley and on the far side of the A3.

WBC has not responded to either of these letters.

PROFESSIONAL ASSISTANCE

In April 2015 we were approached by a local resident who offered to sponsor our costs involved in engaging a top team of professional planners and solicitors to help counter the PBA review.   We are now represented by LDA Design and they have worked hard in recent weeks to research the issues in greater depth and advise us.   As a consequence LDA wrote to WBC, on our behalf, in a letter dated 7th May 2015 querying the Accuracy of the PBA review.

WBC have rejected the LDA offer to meet and discuss the objections, or, place their evidence before the WBC Executive, who are expected to meet and decide development site allocations on 4th June 2015.   We will be responding to this WBC refusal to discuss at this time, very soon.

It should be noted that any local person or body is entitled to comment upon WBC actions and published documents and we and our agents have been repulsed or ignored on 3 occasions now.
PROCESS & THE ROLE OF THE EXECUTIVE

We are advised it is fundamental that WBC proceed with the Green Belt review and Site Allocations on the basis of sound advice and we question the PBA review. The matter of actual Site Allocations will only be known to the public when the WBC Executive decides to publish the Site Allocation proposals.  This is scheduled to be shortly after the WBC Executive meeting on 4th June 2015.

Because our three representations have been repulsed we are concerned that the draft Site Allocations DPD document may be founded on poor and erroneous information.   We feel it is essential that the WBC Executive are fully appraised of valid correspondence and approaches from planning specialists on our behalf but this will not be allowed until after the Executive have actually proposed site allocations on 4th June.

Please note that we are not, at present disputing Site Allocations because these are as yet unknown but that we are objecting to the accuracy and construction of the PBA review which is the cornerstone of the process.

Once proposals have been announced on 4th June they will be published locally and all residents and local stakeholders will be invited to contact and discuss with WBC over a period of 6 weeks. WBC is bound to take all comments during the 6 week consultation period into account prior to submitting a Delivery DPD document to the Secretary of State for examination.   This Delivery DPD will be subject to a local public examination by an Independent Inspector appointed by the Secretary of State and everyone supporting or opposing the proposals is entitled to be heard. The Inspector is bound to ensure that delivery of houses down to 2040 is achieved on the basis of data available to him. WBC will receive a report from the Secretary of State and only after taking it into account will the Delivery DPD be adopted and binding.

In the past, Inspectors have heeded valid and persuasive local views and have adjusted Delivery DPD recommendations but times are now different. Land values are much greater as is the need and the pressure to deliver is now much greater. Pyrford has a proud record of putting its case with success but we must not be complacent in the light of the current real threat to our Green Belt.

THE WAY FORWARD 

We are continuing to try and get our reasonable proposals discussed prior to 4th June and when the Site Allocation DPD document is published will take whatever reasonable action is necessary to oppose materially adverse proposals.  We must all be aware that landowners are entitled to submit proposals also and we are not privy to these details.  We are very grateful for all your support to date and to our sponsor who has given us the resources to put up a technically competent argument to WBC and deal with the Site Allocations when they are announced.

We will continue to strive for the best interests of Pyrford and you will realise that as population grows then provision must be made for housing. Many areas of the Borough will be affected by change and our aim will always be to ensure the impact upon Pyrford is contained so that we can maintain the character of our village.