Byfleet. West Byfleet, and Pyrford Residents Association has submitted the following further objection to the West Hall planning application (PLAN/2024/0475)
FOR THE ATTENTION OF JOANNE HOLLINGDALE
Dear Ms. Hollingdale,
PLAN/2024/0475
ADDRESS: Land At West Hall Parvis Road West Byfleet Surrey KT14 6EY
PROPOSAL: Hybrid planning application (part outline, part full planning application) for residential development (Class C3) for up to 461no. residential units and delivery of up to 15no. traveller pitches and associated infrastructure including groundworks, car parking, open space and landscaping and new vehicular access via a new [roundabout] access junction from the A245 Parvis Road and highway works to be provided in phases; including full planning application for the detailed phase(s) comprising: construction of 253no. residential units (Class C3) and change of use of land for the provision of up to 15no. traveller pitches and associated infrastructure including groundworks, car parking, open space and landscaping and new vehicular access via a new [roundabout] access junction from the A245 Parvis Road and highway works (Environmental Statement submitted) (Environmental Statement Addendum, amended description, further information and amended / additional plans received December 2024 and January 2025).
The Byfleet, West Byfleet and Pyrford Residents’ Association continues to have serious concerns regarding this Application and wishes to submit further objections. While we mostly welcome the proposed amendments, the reality is that they are little more than tinkering and our previous objections remain valid.
INTRODUCTION
We refer to our previous responses dated 8th October and 10th October 2024 regarding this Application detailing the very serious concerns and reservations we had with the above Proposal and the many inadequacies contained within the voluminous documentation. On or about the 20th December 2024 the Applicant submitted amended documents in relation to this hybrid Planning Application. This resubmission purports to address many of the concerns that were raised by statutory consultees, other consultees, and members of the public. We are assured that the amended information submitted is ‘a result of a comprehensive and useful engagement process’. We are not aware of any engagement process and for the most part it is clear that few of the concerns have been addressed and/or resolved.
Indeed, the social, environmental, and logistical harm and damage that will result from this Application, should it proceed as submitted, remains all too apparent, as evidenced by the many hundreds of objections and expressions of concerns including from Councillors and our Member of Parliament.
We are also promised a further comprehensive response setting out how this amended submission is supported by the NPPF 2024. We look forward to reading that.
At the time of writing this submission the WBC Planning Portal lists 1170 documents, and while many hundreds are objections (one in support), the volume of technical papers from the Applicant are now, at least for the lay person, overwhelming and in their own way not sustainable.
We have therefore primarily focused on documents from:
a) Newsteer Real Estate Advisers acting for the Applicants
- Additional Cover Letter dated 13th January 2025
- Resubmission Cover letter dated 20 December 2024
- Planning Statement Addendum dated December 2024
b) Sweco UK Limited
- Environmental Response (ES) dated 13th December 2024 to the Regulation 25 Letter from WBC
- ES Addendum to PLAN/2024/0475 Environmental Statement dated 13th December 2024
c) Stuart Michael Associates Limited – Consulting Engineers acting on behalf of the Applicants
- Various Reports, Assessments, and conclusions
Where necessary we have cross referenced these reports etc. back to the detailed technical information submitted by the Applicant in support of this amended Application.
We particularly wish to acknowledge the extensive and detailed work undertaken by the WBC Planning Officer in the issue of the Regulation 25 letter and her other responses.
TRAFFIC, TRANSPORT AND ACCESS particularly on the A245 (the Parvis Road)
Once again, the volume of technical papers from the Applicant and its advisers on this matter is overwhelming. The concerns raised in our email of the 8th October 2024 remain pertinent.
Further comments:
a) We are of the view that a number of the concerns / suggestions / recommendations clearly set out in the letters dated 4th December and 8th October 2024 from SCC Transport primarily relating to improving sustainable transport infrastructure have not been addressed. We do not appear to have a ‘Passenger Transport Strategy’ and the request for a S106 agreement is ignored.
Many of the previous traffic modelling concerns have been ignored. We would particularly refer to the submission from Mr. Stuart Bradshaw (dated 30th January on WBC Planning Portal) where, amongst other matters, he points out that the Surrey Highways criticism of the use of ‘LinSig’ as incapable of accurate modelling scenarios…. has been ignored.
We are all too well aware that for many years now the A245 has failed on both the Level of Service and the Ratio of Flow to Capacity. We now have the Broadoaks development, and this summer the completed Botanical Place complex will be attracting additional traffic to West Byfleet centre. West Hall, should it be approved, will have parking for 912 vehicles and 1107 bicycles.
b) This site was allocated under Surrey Local Transport Plan 3 (LTP3) but we have now moved onto LTP4. This focuses on improving the transport network, supporting economic growth, and addressing climate change. Key goals include reducing carbon emissions, improving air quality, enhancing connectivity, and ensuring the safety and resilience of the transport infrastructure. One of the aims is to reduce traffic congestion. Let those who wrote the policy come to the Parvis Road.
c) Traffic survey data was primarily collected in 2022. Whilst this is still within time, it was certainly also within the COVID-19 WFH culture and is now dated in its statistical relevance as the timing was exceptional and not typical.
d) We do not know the cost of these Parvis Road ‘enhancements’; the inevitable knock-on impact on surface water drainage and the developer contribution under s278 agreement.
e) NPPF 2024
Paragraph 116. – Development should only be prevented or refused on highways grounds if there would be an unacceptable impact on highway safety, or the residual cumulative impacts on the road network, following mitigation, would be severe, taking into account all reasonable future scenarios.
Paragraph 118 – All developments that will generate significant amounts of movement should be required to provide a travel plan, and the application should be supported by a vision-led transport statement or transport assessment so that the likely impacts of the proposal can be assessed and monitored.
To conclude this section, let us quote from SCC Transport – ‘this site is not well served by public transport and is unsustainable in transport terms.’
TRAVEL PLAN
We have studied the additional supporting submissions from Newsteer and also the relevant information within the Travel Assessment from Stuart Michael Associates (acting for the Applicant). Our comments of the 8th and 10th October 2024 remain relevant.
We would draw your attention to the three submissions from Mr. Keith Creswell dated 18th and 21st January on your Planning Portal where he discusses connectivity, cycle routes, footpaths and shared paths with persuasive knowledge and authority.
We would in particular draw attention to the Planning Response from Active Travel England dated 11th February 2025 where they list and explain their many concerns. This includes reference to the NPPF, cycling accessibility, access to public transport, off-site transport infrastructure, and many other travel route audit issues.
Active Travel England state: ‘From the information provided, it is not clear that all opportunities to promote and prioritise active travel modes have been taken within and outside of the site, as is required by the NPPF. ATE is also not convinced that the development has fully met the requirements of the local site allocation to improve accessibility to the district centre and the strategic pedestrian and cycle network. The design of the access roundabout is also of concern and includes some critical issues and there is scope for significant improvements to the level of service provided to pedestrians and cyclists. Further assessment and agreements are therefore recommended, and ATE is not yet in a position to support the development.‘
We are in agreement with the above statement.
WEST BYFLEET & BYFLEET EARLY YEARS, PRIMARY and SECONDARY SCHOOL CAPACITY and NUMBER of PUPILS
As we stated in our previous submission, this development, if approved, will result in a shortage of early years and secondary school places. A CIL contribution of £2,499,529 will be required.
This is calculated as follows:
Early Years Contribution:£436,968
Primary Contribution:£0
Secondary Contribution:£2,062,561
Overall Contribution:£2,499,529
The problem is that we understand that the approximate amount of CIL under this application will be circa £4.5 million (though we note that Newsteer suggest that it will be circa £3 million). Of this amount, 25% (£1,125,000) goes to West Byfleet Neighbourhood Forum and 40% (£1,800,000) goes to the provision of a compensating SANG (GB12). This leaves £1,575,000. SCC Education department require £2.5m. So, even before other infrastructure requirements, we have a shortfall of almost £1million.
HEALTH CARE / WEST BYFLEET HEALTH CENTRE
In our submission of 8th October 2024 we stated the following:
‘The Surrey Heartlands Integrated Care Board considers it necessary for measures to be put in place so that the impacts to local health care as a direct result of this proposed development is addressed. If left unmitigated, the proposal would be considered unsustainable development. An index linked S.106 financial contribution will be sought.
The following will be requested:
Primary Care £ 497,340
Acute Care £ 443,381
Intermediate Care £ 14,689
Mental Health Care £ 34,650
Total Capital Cost £ 990,060‘
It is clear that the increase in population from this development will result in an additional capital cost to health care provision of £990,060. What does not appear to be clear is whether the Applicant is responsible for the full amount under a s.106 agreement or only that part that relates to Primary Care.
However, Surrey Heartlands Integrated Care Board have submitted a further letter dated 17th February 2025 which sets out a very different financial request. The total Capital Cost has been reduced to £279,280 of which Primary Care amounts to £193,589.
There is no explanation for these amended figures.
SANG (GB12)
Natural England have no further comments to make. Until such time as their previously stated concerns and reservations are addressed to their satisfaction, they will continue to object.
Statement from Newsteer:
‘2.49 The Council’s SANG Assessment Schedule confirms that the development of the site would be mitigated through the delivery of the Byfleet SANG (GB12) or the Horsell Common Extension SANG, or the Brookwood Community Park. The Site Allocations DPD identified GB12 would be delivered by the end of 2023/24.
2.50 There are options being explored with WBC and the Applicant in respect of bringing forward SANG in the local area.’
We do not accept the alternatives in 2.49 and we require more information on 2.50.
We wish to repeat our previously stated requirements:
‘The RA requires confirmation that:
a) WBC will comply with and satisfy the conditions set out by Natural England;
and WBC will prior to the Planning Committee meeting to discus this Application:
b) set out the costs of creating this SANG (GB12) to mitigate the impact of this proposed development
c) confirm that the necessary funds are available and will not be impacted by any future S.114 Notice
d) has planning permission in its own right
e) no occupation of the development will be permitted until such times as the SANG facility is available to the public.‘
If the timing is not possible, then the above must be a Planning Obligation.
FLOOD RISK and DRAINAGE
A new pump station has been added adjacent to the orchard area to assist with the review of the drainage strategy.
SCC is the Lead Local Flood Authority on this Application. They have reviewed the surface water drainage strategy for this proposed development and have assessed it against the requirements of the NPPF, the PPG, and the Non-Statutory Technical Standards for sustainable drainage systems. In their letter of the 23rd January they confirm that they have reviewed the additional and updated documents.
They state “Whilst the LLFA are content with the over-arching principles of the application including discharge location, proposed discharge rate and attenuation volumes, there are design elements and additional information required through the detailed design stage if planning permission is granted by the Local Planning Authority, information that will be required is set out below:…….”
In addition to the very detailed additional information that is required, the LLFA goes on to list a number of Planning Conditions which they believe are necessary.
This advice and conditions were in the original response from LLFA, so it is disappointing that they do not appear to have been addressed.
In a further letter from LLFA dated 3rd February, LLFA state “We would request that some additional information is submitted with regards to the proposed drainage at the site entrance. Works appear to be proposing a new roundabout, increasing the impermeable area but with no inclusion of any sustainable drainage. The chosen discharge location appears to be the existing sewers, when there are watercourses available adjacent to the highway. It is unclear on the decision process for the highway drainage.”
As regards fluvial flood risk the responsible body is the Environment Agency.
The Flood Risk Assessment and Drainage Strategy Summary and Conclusion provided by Stuart Michael Associates appears somewhat premature in its optimism!
FOUL WATER/THAMES WATER
Development Planning Thames Water have submitted a further letter dated 27th January. Once again it does not make reassuring reading.
“Thames Water has identified an inability of the existing FOUL WATER network infrastructure to accommodate the needs of this development proposal. As such Thames Water request that the following condition be added to any planning permission. “The development shall not be occupied until confirmation has been provided that either:- 1. All foul water network upgrades required to accommodate the additional flows from the development have been completed; or- 2. A development and infrastructure phasing plan has been agreed with the Local Authority in consultation with Thames Water to allow development to be occupied………
The proposed development is located within 20m of a Thames Water Sewage Pumping Station. Given the nature of the function of the pumping station and the close proximity of the proposed development to the pumping station we consider that any occupied premises should be located at least 20m away from the pumping station as highlighted as best practice in our Codes for Adoption.”
Indeed, this essentially repeats what was said in August 2024 and no progress had been achieved. It is acknowledged that Thames Water does have a statutory duty to upgrade the system, but given their current financial problems can this be relied upon?
It is suggested that, in the event of Application approval, then the above planning condition should be part of the approval. We do not believe that is sufficient. It must at the very least be a Planning Obligation and preferably a Grampian condition.
Indeed, the Environment Agency in their letter of the 7th February state that they have no comments to make in respect of the amended plans, and repeat that no development shall be commenced until a scheme for the improvement of the sewerage system to accommodate the additional wastewater flows from the development has been submitted and approved in writing by the local planning authority, and this must include a timetable for network and/or wastewater treatment work improvements.
We support these requirements and their enforceability.
ENVIRONMENTAL HEALTH
a) Travellers’ Pitches
The Environmental Health Officer again (25th February 2025) raises the issues that the Pitches do not have sufficient space to accommodate the vehicles which are the lifestyle requirements of such communities.
Also, the application refers to the final layout being determined by the Travellers, but no information as to whether or not this has happened.
b) Air Quality and Air Quality Assessment
The EHO has no adverse comments.
c) Noise and Vibration
The EHO has no adverse comments.
d) Air Source Heat Pumps
The introduction of these requires a noise assessment.
e) BNG
We are interested to learn how this will be achieved while removing trees, putting many others at risk, and for example destroying badger sets.
f) Site Level
It is proposed that the level of the site is raised by around 2 metres. We seek information and reassurance on:
i) the source of the soil
ii) the number of vehicle movements and the travel plan
iii) the impact on tree roots
iv) the impact on surface water drainage
v) the impact on the stability of the site
TREES
Barratt David Wilson Southern Counties and Westden Property Limited in their Planning Statement Addendum of December 2024 have made a robust response to the WBC’s Tree Officer’s original objections. They make several very clear and helpful conclusions, including reference to the submitted Arboricultural Statements (paragraph 3.4.1 of the AIA) which, unfortunately, I cannot identify.
The Tree officer in his response dated 14th February is not persuaded stating:
“Further to my earlier objections to the scheme essentially relating to tree loss and the impact on retained trees, I am further concerned following the latest submission which shows a significant impact upon the major arboricultural linear feature within the site. This relates to the build up of soil within the RPAs of the vast majority of these mature trees with a significant amount of these trees being affected on both sides which will, contrary to the information provided have a detrimental impact upon them.
The applicant has provided a generic indication as to how this could be constructed but this is unacceptable. As I have previously indicated the fact that the land is to be raised across the site will have a detrimental impact in the long term upon these trees and this further incursion creates further pressure on these trees and will in time result in the significant deterioration and loss of this historical linear arboricultural feature.”
It will be a brave Council that does not follow the advice of its Tree Officer.
CONCLUSION
This Application was validated on 16th July 2024 after many months, if not longer, of discussion and guidance. The volume of documentation submitted is truly remarkable (as are the number of objections) and we are now into our second extension of time period.
What cannot be ignored is that in spite of further information and amended/additional plans received in December 2024 and January 2025, the responses from the many statutory and other consultees remains overwhelmingly negative. These are not community residents who might be accused of bias, but highly skilled professional experts who fully understand the implications of this Application and the infrastructure mayhem and environmental destruction that will result, should it be approved.
We remind ourselves that the sites in question (GB9 and GB9A) are no longer Green Belt land and have been allocated for housing. Therefore, residential development is established in principle.
However, the NPPF is clear that such development must be supported by the necessary improvements to local infrastructure, and the Deputy Prime Minister in her letter of the 24th July 2024 to local authority Leaders has emphasised that this includes GP surgeries, schools, and transport links. As regards the latter, see paragraphs 115-118.
We gain the impression that the Applicant and their advisers are of the opinion that the NPPF provides support for their Application. We are less positive. We consider that there is one word in particular in the NPPF with which they will struggle, namely ‘sustainable’. This site is not fit for the proposed purpose and it is clear that the proposed ‘solutions’ are woefully inadequate.
Our recommendation to you as Planning Officer and to the Planning Committee is that this Application as again presented should be refused.
Kind regards.
Stewart Dick
Chair
Byfleet, West Byfleet and Pyrford Residents’ Association
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