The Regulation 19 public consultation started on 5th November 2018 for 6 weeks to 5pm 17th December 2018, and members are encouraged to respond. Please read on to see the Residents’ Association response to Woking Borough Council.
c/o 66 Lincoln Drive
Pyrford
Woking
Surrey
GU22 8RR
12th December 2018
Dear Sirs,
Response to Regulation 19 Consultation December 2018
This letter is written by the Byfleet, West Byfleet & Pyrford Residents’ Association (“RA”) which represents 2,800 members in the three villages of Byfleet, West Byfleet & Pyrford.
The Regulation 19 process has taken a long time to arrive since the adoption of the Core Strategy in October 2012.
In that six years, it has taken many twists and turns and has, at times, proved very difficult to follow and understand. The reports, some of which were only published on the 5th November 2018, under the consultation from 5th November to 17th December consist of :-
Site Allocations DPD (“SADPD”) – this allocates specific deliverable sites to enable the delivery of the development proposals of the Core Strategy. (366 pages)
Sustainability Appraisal Report – this assesses the social, economic and environmental implications of the Site Allocations DPD. (267 pages)
An Executive Summary of the SA Report (8 pages) has also been produced. Appendix 11 (923 pages) and Appendix 12 (717 pages) are separate documents.
Habitats Regulations Assessment – this assesses the implications of the Site Allocations DPD on the European designated sites and species in the Borough. (68 pages)
Proposals Map and Insets Map – (2 pages) the adopted Core Strategy Proposals Map (also known as a Policies Map) has been modified to illustrate the proposals in the SADPD.
This is a total of 2,343 pages, not including the many documents listed in the Research and Evidence Base on Woking2027.info shown in Appendix 1.
The RA believe the relevant paragraphs in the July 2018 National Planning Policy Framework (NPPF) that cover this Regulation 19 process ( the “Process”) are 35 & 36 which are set out below:-
“35. Local plans and spatial development strategies are examined to assess whether they have been prepared in accordance with legal and procedural requirements. Plans are “sound” if they are:-
- Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;
- Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
- Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and
- Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in this Framework.
- These tests of soundness will be applied to non-strategic policies in a proportionate way, taking into account the extent to which they are consistent with relevant strategic policies for the area.”
The RA will try to keep its comments within the Process, but the RA considers that it is also important to set out the current situation faced in the three villages which the RA represents.
The RA and its residents are very concerned about the fact that the current level of infrastructure that is in places is already under severe pressure in the following areas:-
- traffic levels on the A245 and surrounding roads,
- lack of school places,
- full doctor practices,
- lack of NHS dentists,
- waste water management, and
- existing flooding – river and surface water
Looking at each village in turn, the impacts of the SADPD are summarised below:-
Pyrford village is least impacted by the SADPD, as there are no proposed traveller sites, no release of Green Belt nor any allocated sites, but the extra traffic generated from the extra dwellings in Byfleet & West Byfleet will have an impact, as there are three routes through the village to get to the A3 and M25.
Byfleet village has two sites removed from Green Belt and safeguarded until 2027 with a capacity for 210 dwellings plus the current temporary 4 traveller pitches are recommended to become permanent. The village suffers regularly from flooding issues, surface and river, as well as traffic gridlock each day in the morning & evening on the A245.
West Byfleet is significantly impacted by the SADPD proposals as it will completely change the character of the West Byfleet community.
The village covers 294 hectares and, based on the 2011 census data, has a population of 5,626 in 2,320 households. There is currently 85 Hectares of Green Belt. The proposals are to remove
- Broadoaks (GB11 14.7 Hectares 252 dwellings plus a 80 bed Care Home – PLAN/2018/0359)
- West Hall (GB10 29.3 hectares 555 dwellings and 15 permanent traveller pitches )
- West Byfleet Infant Junior Schools (GB18 6.8 Hectares)
a total of 50.8 hectares – 60% of the current Green Belt in the village.
The SADPD removes 1.93% of Woking’s Green Belt of which 1.09% is in West Byfleet village.
The number of dwellings above, when added to the Sheer House outline planning application (PLAN/2017/0128 255 dwellings) means an additional 1,150 dwellings which, based on the 2011 census reported above, is a significant 50% increase in dwellings.
The resulting population increase and traffic impact will have serious and detrimental infrastructure consequences which the mitigation proposals totally fail to address.
Inconsistencies
The documents contain some inconsistencies and/or or lack of details:-
- Appendix 1 of the Sustainability Appraisal Report on page 123 shows the West Byfleet Neighbourhood Plan as not fully adopted but it was on 7 December 2017. Have all the Plan policies been considered when appraising West Byfleet?
- At the top of page 18 the SADPD says “The latest Strategic Housing Land Availability Assessment (“SHLAA”) was published in April 2014. The revised figures have informed the DPD .” Why haven’t the SHLAA 2017 figures, also published on the Council’s 2027 website been used? Surely with these being up to date they would be more relevant.
- On windfall sites or small developments, the SADPD says, “In line with the evidence presented through the Core Strategy, windfall sites are assumed to deliver an average of 42 dwellings each year during the present plan period. The Core Strategy assumes that these will compensate for non-implementation of sites on previously developed land in the Urban Area.” SHLAA 2017 in table 1 shows these are included in the period 11-16 years but not in 0-5 years or 6-10 years. Surely this is inconsistent.
- When discussing UA 44 (Woking Football Club, West Field Avenue), the SADPD on page 229 -231 doesn’t include any estimated dwellings nor on page 342, when other sites do include numbers. Sustainability Appraisal Report, in Appendix 16 on page 256, shows 992, based on a developer proposal. In other places it is listed as 40. The SHLAA shows 40 in Appendix 1. There is a big difference in the various evidence bases and will impact the deliverable number of dwellings in the period 0 -6 years. What confidence can anyone have in the numbers quoted in all the various documents. What number has been in used in the SADPD?
- For many of the sites being reviewed, it is not at all clear what specific part of the site is being proposed for development. For example GB5 -Land to the south of Rectory Lane, Byfleet – includes a children’s playground and land that has been transferred to the local church for use in the future as a burial ground. It seems that only about half of that site has actually been offered up by a landowner for possible development. This lack of detail has caused great consternation within the Byfleet community.
Green Belt Boundaries
In the July 2018 NPPF in paragraph 134 it says:
Green Belt serves five purposes:
- to check the unrestricted sprawl of large built-up areas;
- to prevent neighbouring towns merging into one another;
- to assist in safeguarding the countryside from encroachment;
- to preserve the setting and special character of historic towns; and
- to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
In terms of changing boundaries paragraph 137 goes on to say:
- Before concluding that exceptional circumstances exist to justify changes to Green Belt boundaries, the strategic policy-making authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development. This will be assessed through the examination of its strategic policies, which will take into account the preceding paragraph, and whether the strategy:
a) makes as much use as possible of suitable brownfield sites and underutilised land;
b) optimises the density of development in line with the policies in chapter 11 of this Framework, including whether policies promote a significant uplift in minimum density standards in town and city centres and other locations well served by public transport; and
c) has been informed by discussions with neighbouring authorities about whether they could accommodate some of the identified need for development, as demonstrated through the statement of common ground.
In this context, a review was carried out into options for changing the Green Belt boundary, but it seems there is no equivalent report into making “ as much use as possible of suitable brownfield sites and underutilised land” except possibly for the Strategic Housing Land Availability Assessments of 2011, 2014 & 2017.
The WBC process as outlined on its woking2027.info website is
The Council periodically contacts planning agents, landowners and other interested parties, to request that potential sites are put forward for consideration. This is referred to as a ‘Call for Sites’ and provides the Council with up to date information on potential sites for development across the Borough.
This is a reactive process from landowners. It only identifies land that is offered by landowners. It is not a review of all possible brownfield sites.
The NPPF also says in paragraph 136:-
Once established, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans. Strategic policies should establish the need for any changes to Green Belt boundaries, having regard to their intended permanence in the long term, so they can endure beyond the plan period. Where a need for changes to Green Belt boundaries has been established through strategic policies, detailed amendments to those boundaries may be made through non-strategic policies, including neighbourhood plans.
As set out below, the evidence shows that to deliver the target of 4,964 to March 2017, it is not required to remove any further land from Green Belt.
Dwelling Numbers
The SADPD on page 17 shows only one table (see below) of sites expected to be delivered, which is from the SHLAA 2011. Since then two further reports have been issued – 2014 & 2017.
Table 7: Housing supply
Period | No. dwellings |
0-5 years | 1,699 |
6-10 years | 1,485 |
11-15 years | 859 |
Total | 3,966 |
Source: SHLAA (2011)
All the SADPD says on page 18
Based on up to date evidence in the SHLAA (2017) and the latest Housing Land Supply Position Statement, sufficient land has been to ensure the delivery of the residual 2,830 homes, plus additional land to compensate for non-implementation. This takes into account updates on the status of individual sites since the Site Allocations DPD was published for Regulation 19 consultation.
No attempt is made in the commentary to support this statement.
If the 2017 SHLAA Table 1 is summarised against SHLAA 2011 it would look like:-
Period | SHLAA 2011 | SHLAA 2017 |
Completions – to March 2017 | 1,789 | |
Completions 2017/18 | 345 | |
0-5 years | 1,699 | 1,309 |
6-10 years | 1,485 | 2,103 |
11-15 years | 859 | 1,661 |
Totals | 4,043 | 7,207 |
SHLAA Table 1 can be summarised:-
SHLAA period | Pre SHLAA | 0-5 years | 6-10 years | 11-15 years | |
2010/11-2016/17 | 2017/18 – 2021/22 | 2022/23 – 2027/28 | 2028/29 – 2032/33 | ||
Source of Supply/potential | Total | ||||
Dwelling completions 2010/11 – 2016/17 | 1,789 | 1,789 | |||
Under construction/unimplemented planning permissions | 1,473 | 240 | 32 | 1,745 | |
Sites with potential for residential development | 181 | 1,313 | 1,034 | 2,528 | |
Sub Totals | 1,789 | 1,654 | 1,553 | 1,066 | 6,062 |
Green Belt | 550 | 395 | 945 | ||
Windfall | 200 | 200 | |||
1,789 | 1,654 | 2,103 | 1,661 | 7,207 | |
Core Strategy Requirement (292 p.a.) | 2,044 | 1,460 | 1,460 | 1,460 | 6,424 |
Surplus/(Deficit) against Core Strategy | (255) | 194 | 643 | 201 | 783 |
If one were to use the developer’s application numbers of 992 for the Woking Football Club site in the Infrastructure report, include windfall sites in all periods and remove all green belt the table would become:-
SHLAA period | Pre SHLAA | 0-5 years | 6-10 years | 11-15 years | |
2010/11-2016/17 | 2017/18 – 2021/22 | 2022/23 – 2027/28 | 2028/29 – 2032/33 | ||
Source of Supply/potential | Total | ||||
Dwelling completions 2010/11 – 2016/17 | 1,789 | 1,789 | |||
Under construction/unimplemented planning permissions | 1,473 | 240 | 32 | 1,745 | |
Sites with potential for residential development | 181 | 1,313 | 1,034 | 2,528 | |
Sub Totals | 1,789 | 1,654 | 1,553 | 1,066 | 6,062 |
Green Belt | 0 | ||||
Adjustment Woking Football Club | 952 | 952 | |||
Windfall | 200 | 200 | 200 | 600 | |
1,789 | 2,806 | 1,753 | 1,266 | 7,614 | |
Core Strategy Requirement (292 p.a.) | 2,044 | 1,460 | 1,460 | 1,460 | 6,424 |
Surplus/(Deficit) against Core Strategy | (255) | 1,346 | 293 | (194) | 1,190 |
As the first three columns represent the period to March 2017, even if a quarter (25% of the 992 dwellings) were included, the surplus number would be 670.
The Core Strategy, adopted in 2012, assumed releasing 550 home from the Green Belt. The numbers above show that as Woking Borough Council has decided to build “up not out“, i.e. using the Woking Town Centre instead of Green Belt, no Green Belt needs to be released. There are clearly sufficient dwellings proposed in Woking Town Centre and Sheerwater regeneration. The SHLAA 2017 includes for the regeneration 408 dwellings, 32 of which are in period 11-15 years.
Planning application PLAN/2018/0337 ( not decided as at 7 December 2018) seeks 869 dwellings and the increase of 461 eliminates the deficit of 194.
As a result, the RA, contends that no Green Belt land needs to be released.
Turning to the infrastructure areas of concern:-
1) Traffic
Each morning and evening cars queue to use the A245 – from Sheerwater Road/Albert Drive junction all the way up to the A3 interchange at Cobham.
The A245 mitigation study states in paragraph 3.2.1 that “the Byfleet Road/Seven Hills Road Junction is currently operating at or just above its capacity” and in 3.3.3 that “Parvis Road/Camphill Junction is also shown currently operate at or just below its capacity”. (NB This is actually a very complex 5 road junction). It also says in paragraph 3.5.2 that “the A245 between Old Woking Road and Broadoaks is one of the most heavily congested areas in the study”. It also says in paragraph 3.3.1 that the link capacity assessments show that the A245 Parvis Road is already at its theoretical capacity “.
It also states in paragraph 3.1.10 that the last full review by the consultants WSP in 2002 identified that there is no ideal solution as this route is constrained by urban development. This A245 mitigation study also says in paragraph 3.1.11 that this WSP report, now 16 years old, is used as the basis of mitigation options. The report seems to assume that little has changed in 16 years. This is just not true. Surely as over 1200 dwelling are proposed in the West Byfleet & Byfleet area, a more up to date and realistic A245 mitigation study is needed. There are also other significant developments proposed nearby such as Sheerwater and in neighbouring Councils Fair Oaks & Wisley Airfield.
2) School Places
The local primary schools:
- St Mary’s C of E Primary School
- Byfleet Primary School
- West Byfleet Infant & Junior Schools
- Marist Catholic School
- Pyrford C of E Primary School
are already oversubscribed. In the last few years the PAN’s in some of these schools have already been increased.
The Draft Infrastructure Plan noted in Appendix 1 page 6 that Woking as a whole needs up to 22 primary classes. A significant proportion of those classes will need to be in West Byfleet. The existing West Byfleet Infant & Junior schools have recently expanded and there is now insufficient land available to expand again. There are no sites allocated in the SADPD for any primary educational infrastructure.
Fullbrook, the nearest secondary School to the major developments, reduced its PAN in September 2016 from 280 to 240 p.a. to “improve the learning environment”.
The Draft Infrastructure Plan noted in Appendix 1 page 7 that Woking as a whole needs up to 16 secondary classes. The note says that “some of which will be located at Bishop David Brown School, St John the Baptist School and Hoe Valley School.” David Bishop Brown has a service from Byfleet & West Byfleet but there is only one service scheduled at the right time in the morning.
Again, no education infrastructure is allocated in the SADPD.
3) Doctor Practices
The local three practices for the three villages are based in West Byfleet Health Centre. They are already over-subscribed.
The Draft Infrastructure Report accepts in para 10.24 that “overall there is inadequate GP provision across the Borough”. The average in Surrey is 1,994 patients per GP whereas the national average is 1,364 per GP. The average practice size in Woking is 8,645 versus a national average of 7,685.
4) Dentists
Again, like Doctors, the dental practices are oversubscribed.
According to the Infrastructure report, there are 27 dental clinics in Woking but only 13 offer NHS funding. The report states gaps in provision include Pyrford.
5) Waste Water Management
In Byfleet the surface water flows into the foul sewers and poor maintenance by the agencies means that significant surface water causes flooding. In December 2013 there was flooding, the waste pumps failed and surface water flooding.
The Draft Infrastructure report on page 193 notes comments in 2015 from Thames Water that in case of
- UA51 – Land at Station Approach, West Byfleet
- G15 – Land surrounding West Hall, West Byfleet
- GB5 – Land south of Murrays’ Lane
- GB12 – Land of rear of Lovelace Drive, Pyrford (Now removed!)
that “the waste water capacity in this area is unlikely to be able to support the demand anticipated…”
The comments also note it “would take around 18 to 36 months to design and deliver a solution”.
As, three years later, the current waste water infrastructure is still causing major issues this is a very significant concern in supporting any development in the East of Woking.
6) Flooding
Much of Byfleet is in Flood Zone 2 & 3 and as yet no flood alleviation scheme(s) have yet been agreed.
Process
The process has been implemented in such a way that the residents of Byfleet & West Byfleet are unable to comment under Regulation 18 processes on the now proposed traveller pitches in Byfleet and West Byfleet.
It was not until the 10 October 2018 that residents found out that Woking Borough Council officers were proposing a significant change in the location of Travellers Pitches. In both stages of the Regulation 18 consultations – June/July 2016 (2015?) and February 2017 – no traveller pitches were allocated in the East of Woking. Now there are at least 19 proposed – 15 in the land surrounding West Hall and four temporary pitches made permanent. The detail behind GB4 & GB5 also suggests that these might also be suitable sites for further traveller pitches.
This appears to be a totally disproportionate allocation of the required number for Woking Borough to Byfleet and West Byfleet.
Summarising
The RA believes that any of the existing precious Green Belt in our three villages should not be used for future developments. The existence of the Green Belt status protects the land that is already there. It currently fulfils the key purpose of preventing the three villages of Byfleet, West Byfleet & Pyrford from further merging together.
Whilst the Core Strategy sets out the removal of Green Belt land to deliver 550 dwellings over the plan period to March 2027, the RA believes that now there is no need to remove ANY land from Green Belt status for development. The evidence shows that sufficient sites exist in the existing non- Green Belt areas to deliver the target of the 2012 Core Strategy of 4,964 dwellings.
There is no justification in the SADPD documents for imposing such significant change on West Byfleet Village and the evidence base used does not justify this outcome.
The RA believes SADPD is unsound because the paragraph 35 test have not been fully met. In particular:-
Procedural requirements – travellers’ sites in the East were not included in regulation 18 consultation
Positively prepared – the allocated sites in East Woking are not sustainable due to current and future inadequate infrastructure
Justified – reasonable alternatives in Kingfield regarding Woking Football Club have not been properly taken into account
Effective – It is not clear that sufficient joint working has been undertaken to consider fully the proposed developments at Fairoaks and Wisley Airfield.
Finally, as requested by WBC in their Guidance Notes, the RA would like to make its wishes known that it would like to appear at the Examination in Public to defend the existing Green Belt boundaries by seeking to convince the Planning Inspector there is sufficient availability in existing non Green Belt land.
Yours faithfully,
Stewart Dick Gary Elson Andrew Grimshaw
Chairman Vice Chairman Planning Officer
Byfleet, West Byfleet & Pyrford Residents’ Association
Fiona Syrett says
Thank you for this very helpful information. Can I just make one small point – re Inconsistency no.5 above, you say that part of GB5 has been transferred to the church. It does in fact belong to the church, having been bequeathed by Mr Locke King many years ago to be used as burial ground into perpetuity. It is currently leased to WBC for a peppercorn rent.