FoI responses from SCC & GBC on the need for new secondary school in Normandy

Normandy residents have been very active pursuing Freedom of Information requests in regard of the provision of a 7 Forms of Entry [7FE] secondary school with in the proposed Site A46. It is increasingly important that the information exchanged between Surrey County Council and Guildford Borough Council is examined by residents in order to inform their responses to the draft Guildford Local Plan (Proposed Submission) in regard of Site A46, the Green Belt land between Normandy and Flexford settlements. Normandy Action Group is publishing the information gathered as a result of his FoI requests to both Surrey County Council and Guildford Borough Council. There remain two FoI requests outstanding at the end of June 2016


SCC FoI Request 13/4/2016 Ref. W10001729

Q. What is the need for a new secondary school in Normandy? Please include information on how birth data, or other information, has been used to forecast the number of secondary school places that will be needed in the Guildford area until 2022 

A. Under Section 21 of the Act, we are not required to provide information which is already reasonably accessible to you. The methodology of projecting school places and the factors considered including birth data to forecast secondary places up to 2022 and beyond is described in the School Organisation Plan. This document is on the Surrey County Council website  

The proposed secondary school in Normandy would serve Normandy, Blackwell Farm and Ash, which could be around 4,366 homes. This number of dwellings could yield around 785 secondary aged children. This estimate is based on formulae that calculate the likely average yield from new developments.  

785 is the estimated secondary yield, which could result in around 157 children per secondary year group.  However, it is unknown the actual numbers and ages of children that would occupy dwellings in a new development. Timing of which years is unknown at this early stage until the phasing and timing of the construction of the new homes is known. 

Further response:

785 is the estimated secondary yield, which could result in around 157 children per secondary year group.  However, it is unknown the actual numbers and ages of children that would occupy dwellings in a new development.  Timing of which years is unknown at this early stage until the phasing and timing of the construction of the new homes is known.

Q. What is the need for a new secondary school in Normandy excluding possible demand created by further housing developments in the draft Guildford plan, and how does this data point to the need for a new secondary school to be located in the village of Normandy?

A. The proposed secondary school in Normandy is required to meet the pupil yield from the developments in the draft Local Plan. Excluding the demand created by the developments in the Local Plan, the school would not be required. This is an infrastructure requirement resulting from the draft Local Plan. 

Q. What is the need for a new secondary school in Normandy including possible demand created by further housing developments in the draft Guildford plan, and how does this data points to the need for a new secondary school to be located in the village of Normandy. 

A. Locating the school in Normandy would allow it to serve developments in Blackwell Farm and Ash as well as Normandy. 

Q. What other sites for secondary schools have been considered in the borough and why have these sites have been disregarded, and why is Normandy the preferred option.

A. Under Section 21 of the Act, we are not required to provide information which is already reasonably accessible to you. The details of the sites considered together with the reasons for rejecting or proposing those sites are given in GBC Land Availability Assessment, from page 529. The document is publicly available on the GBC website on the following page (LAA 2016)

Q. What is the the Published Admission Number [PAN] and total capacity for all other secondary schools, school by school, in the borough and the projected spare capacity of these schools 

a. excluding possible demand created by further housing developments in the draft Guildford plan
b. including possible demand created by further housing developments in the draft Guildford plan 

A.  The  PAN of secondary schools in Guildford borough is 1,426. The capacity of secondary schools in Guildford Borough for years 7 to 11 is the PAN of 1,426 multiplied by 5 years giving a total of 7,130. 

School by school the PANs and capacities are shown in the table below:

School PAN Total places
available (11-16)
Howard of Effingham 240 1200
Christ’s College 156 780
George Abbot 300 1500
Guildford County 160 800 
Kings College 180 900
St Peter’s 180 900
Ash Manor 210 1050

Excluding strategic development proposed in the draft Local Plan, year 7 places are likely to be full to capacity in all Guildford schools by 2019. Numbers are likely to dip a little in 2020 and then increase again in 2021, with little spare capacity. 

Q. What is the possible effect on school places of the reduction in birth-rate over the past few years and what effect will this will have on school place planning 

A. A drop in the birth rate was seen in 2014 and 2013. However, it is unknown whether that will continue. Looking at the last 10 years, birth rates in Guildford have fluctuated with dips lasting no more than two years before an increase is seen again, with the trend increasing overall. 

Q. Projecting on from 2015/16 to 2024/25. what will be the projected Year 7 entry to Secondary schools in Guildford. school by school, and year by year? 

A. Place planning is undertaken on an area basis rather than school by school, and includes a range of factors as well as births.  The projected demand for places is published annually in the School Organisational Plan, which is available on the Surrey County Council web site 

Q. What consideration has been given to enlarging existing schools rather than building a new school 

A. Excluding possible demand from the draft Local Plan, two expansions are planned to meet the existing demographic demand. 20 additional places per year are being provided at Guildford County and 30 places per year at St Peters from September 2017. Statutory consultation and determination on the decision to expand each school has been completed, for which documentation is available on the Surrey County Council website.  St Peters is subject to planning permission.

Including demand from the draft Local Plan, further options to expand existing schools are limited, would not provide for the level of demand from the Local Plan and locations of existing schools would not necessarily serve the developments proposed in the Local Plan.

Q. How pupils will be transported to this secondary school?

A. This will be determined and planned in detail at a later stage. The draft Local Plan includes appropriate train routes. 

Q. What research has taken place to see how the local rural roads will cope with the increase in traffic that the new school will bring, especially with regards to the railway bridge in Westwood Lane which only accepts one-way traffic and has a height limit, and the dangerous hump-back bridge in Glaziers Lane which has a weight limit 

A. As Surrey have not undertaken any specific research on either the ability of local roads to cope with traffic that may be associated with a new school, or on road safety issues specifically related to parents parking on Glaziers and Westwood Lanes, there is no information to provide on these two points. This would be looked at as part of the planning application process. 

Q. What road safety issues concerning parents parking on Glaziers Lane and Westwood Lane to drop off and pick up their children have been considered?

A. As Surrey have not undertaken any specific research on either the ability of local roads to cope with traffic that may be associated with a new school, or on road safety issues specifically related to parents parking on Glaziers and Westwood Lanes, there is no information to provide on these two points. This would be looked at as part of the planning application process. 

The same questions were asked of Guildford Borough Council


GBC FoI Request 13/4/2016 Ref 3186

The reply was:

A.  The documents we hold are attached above (‘LAA Sites Considered for Secondary Schools’ and Guildford Local Plan Education Review’.) The  site list is already in the public domain (in the draft Land Availability Assessment that was considered at Borough, Economy and Infrastructure Executive Advisory Board on 14 April) The Education Review paper produced by Surrey County Council is to be made public with the June consultation papers as evidence in support of the Local Plan. 

The school place planning has been undertaken by Surrey County Council Officers 


SCC FoI Request 26/4/2016 Ref 14503

Q, With regard to Secondary Schools in Guildford Borough, what Free Schools in the secondary sector are there? 

A.  There are no secondary free schools in Guildford Borough.

Q. With regard to the proposed new secondary school in Normandy, can you please tell me which Academy or Free School has approached the County Council proposing sponsorship arrangement for the new school. If neither has made the approach can you please advise me on what basis an approach has been made, and by whom, and how this fits with Government legislation regarding new schools

A. The County Council has not received any approaches regarding sponsorship arrangements for the new school. It has not invited any such approaches as it would be too early to do so at this stage. If and when the new school is progressed, the process to do so would be aligned with the Department for Education's guidance on the establishment of new schools.

Q. Please provide me with information that shows:

1. The planned admission number of the proposed new school in Normandy (how many forms of entry), and how this has been calculated

A.  It is too early to define the admission number of the proposed school in Normandy. This would be largely dependent on the number of housing developments progressed for which a new school may serve, taking into consideration any capacity in existing schools closer to the time when the places are needed.

Further query:

I find this response confusing as the Guildford Borough LAA dated Feb 2016 states clearly, “The site will provide a 7 form entry secondary school.” Does this not equate to a PAN of 210? Why is the response that “it is too early to define the admission number” , given this statement in the LAA

Further response:

The  provisional size is up to 7FE in order to ensure sufficient provision is considered in line with possible housing.

Further query:

In the FOI request W10001729, with regard to this proposed secondary school, you stated, “785 is the estimated secondary yield which could result in around 157 children per secondary year. Is this not PAN of 157, or between a 5 and 6 FE school? Why are the responses different (in one it is 210, and in the other 157), and again, why is the response “it is too early to define the admission number” , given that a number of 157 is given?

Further response:

The number cannot be prescribed at this stage, as this would be dependent on the schemes progressed. 

Further query:

In the FOI request W10001729, with regard to this proposed secondary school, you stated, “The proposed secondary school in Normandy would serve Normandy, Blackwell Farm and Ash, which could be around 4,366 homes. This number of dwellings could yield around 785 secondary aged children. This estimate is based on formulae that calculate the likely average yield from new developments.” 

The Guildford Borough LAA shows the need for a 2FE Primary School at the Blackwell Farm site and I assume these children would move on as a cohort of 60 children to the proposed Secondary School in Normandy. Appendix C of the draft Local Plan, Infrastructure Schedule SED3 states the need for  “A 7FE secondary school at the Normandy site ... only 1FE would be needed to serve the strategic development itself”.  

Further response:

The number of new homes in the Ash area is shown in the Proposed Submission Local Plan on page 27, table 1, published by Guildford Borough Council. 

2. If the proposed intake at the Normandy site is in addition to the extra 3 form entry already commissioned in Guildford town

A. This would be largely dependent on the number of housing developments progressed for which a new school may serve, taking into consideration any capacity in existing schools closer to the time when the places are needed.


SCC FoI Request 15/5/2016 Ref 14606

Q. What capital funding is being provided by the Department for Education for a new Secondary School on the strategic site between Normandy and Flexford that is mentioned in the draft Guildford Local Plan. This is to include any confirmation in writing from the DfE that such resources will be available for the new school. 

A. It is too early for considerations to have taken place with regard to this enquiry; therefore no such documents are available. 

Q. What proposals have been sought to establish a free school on this site via the ‘free school presumption’, or proposals for a new maintained school outside of the competitive arrangements in order to meet demand for a specific type of place. 

A. It is too early for considerations to have taken place with regard to this enquiry; therefore no such documents are available.


SCC FoI Request 9/5/2016 Ref 14586

Q. What considerations have taken place with regard specifically to the need for a new secondary school in the area west of Guildford, taking into account projected housing completions (see highlighted and underlined section above), but not taking into account any additional housing created by the Guildford Local Plan. 

A. Without taking into account any additional housing created by the Guildford Local Plan, there are no proposals for a new secondary school in the area west of Guildford, therefore no such considerations have taken place.


GBC FoI Request 15/5/2016 Ref 3255

Q. What considerations have taken place with regard to:

1.Capital funding being provided by the Department for Education for a new Secondary school on the strategic site between Normandy and Flexford that is mentioned in the draft Guildford Local Plan. This is to include any confirmation in writing from the DfE that such resources will be available for the new school.

2. Seeking proposals to establish a free school on this site via the ‘free school presumption’, or proposals for a new maintained school outside of the competitive arrangements in order to meet demand for a specific type of place.

A. We do not hold the information requested.


GBC FoI Request 25/5/2016 Ref 10014790 & 10014962 (reminder)

I would also like to see all documents etc. between Taylor Wimpey (South West Thames) Ltd   and Councillors or Officers of Guildford Borough Council which relate to the construction of a school on Strategic Site 46 Normandy/Flexford

A.    The information is held by Surrey County Council on this occasion

Further query 9/6/16

With regard to question 2, I cannot understand why there are no documents etc. between Taylor Wimpey (South West Thames) Ltd   and Councillors or Officers of Guildford Borough Council which relate to the construction of a school on Strategic Site 46 Normandy/Flexford, as the school is a key plank in the draft Plan and is the basis to over-ride planning guidelines on this site and build 1,100 homes. I cannot accept, given the importance of the school within the Local Plan, that there have not been extensive talks between GBC and Taylor Wimpey.

I wish to object strongly to your claim that there are no documents held by GBC  with regard to the above questions and  request a review of your decision at the earliest opportunity.

A further query 24/6/2016

Dear Ms Wilmott

Thank you for forwarding this information.

I asked to see all documents etc. between Taylor Wimpey (South West Thames) Ltd   and Councillors or Officers of Guildford Borough Council which relate to the construction of a school on Strategic Site 46 Normandy/Flexford.

You replied, “Please see attached four documents that refer to a school on the site. The representations received from Taylor Wimpey in response to Local Plan consultations are available on our website though the inovem system.”

You have not complied with my request. There will have been much discussion and correspondence between Taylor Wimpey and Guildford Borough Council about the school and you have not forwarded any of this to me. You have forwarded four documents that do not refer specifically to discussions about the construction of a school. And their response to the consultation is not relevant to what I have asked. 

Please forward to me copies of all documents, papers, minutes, analysis and statistics that relate discussions that have occurred between Taylor Wimpey and Councillors or Officers of GBC relating to the construction of a secondary school on strategic site 46.


SCC FoI Request 27/5/2016 Ref. 3281

Q.   Please provide me with copies of all documents, papers, minutes, analysis and statistics etc. that relate to: 

  1. Formal meetings or conversations that have taken place between Councillors or Officers of Surrey County Council and Councillors or Officers of Guildford Borough Council regarding:
  • increasing the intake for undersubscribed schools in Guildford Borough

  • increasing the planned admission numbers for secondary schools in Guildford Borough

  • enlarging existing school premises as opposed to building a new secondary  school in the west of the Borough

A.   Verbal response from SCC School Commissioning Officer:

I was told that there have only been informal discussion.

  1. Formal meetings or conversations that have taken place between Councillors or Officers of Surrey County Council and Headteachers/Chairs of Governors of secondary schools in Guildford Borough, including those just over the County Boundary in Hampshire, regarding: 
  • strategies for increasing the intake, if their school is undersubscribed
  • increasing the planned admission numbers for their school
  • enlarging their school premises to increase their admission number 

as opposed to building a new secondary  school in the west of the Borough 

  • the concern that Headteachers and Chairs of Governors have about a new school reducing the intake to their school 

A.  Verbal response from SCC School Commissioning Officer:

I was told that the School Commissioning Officer discusses issues relating to school roll and premises with Headteachers and Governors. However, the Officer was unable to confirm that any formal meetings or conversations had taken place related to the Local Plan.

4.   Any financial  calculations that have been made to compare the cost of enlarging existing schools in Guildford Borough to cope with increased numbers of pupils arising from the local plan with the cost of building a new school at Normandy, assuming that the serviced land will be provided by the developer.

A.  Verbal response from SCC School Commissioning Officer:

I was told by the School Commissioning Officer that there have  not been any such calculations

I would also like to see all documents etc. between Taylor Wimpey (South West Thames) Ltd   and Councillors or Officers of Guildford Borough Council which relate to the construction of a school on Strategic Site 46 Normandy/Flexford

A.   I  was told by the School Commissioning Officer that no formal conversations had taken place between SCC and the developer


GBC FoI Request 2/6/2016 Ref. 3288 – still awaited

1. The draft Guildford Borough Land Availability Assessment dated February 2016. Site reference 368, land to the south of Normandy and north of Flexford.

In the section re. ‘Transport’, it is stated that “An on and off site cycle network to key destinations including Wanborough railway station and to the Christmas Pie Trail would be needed.”

The Christmas Pie Cycle Trail itself is not mentioned in the Infrastructure Schedule for improvement, and is a convoluted route both east and west, which is unlit, muddy, and passes through dense woodland in places.

Under the Freedom of Information Act 2000, I request that you please provide me with copies of all documents, papers, minutes, analysis and statistics etc. that relate to  any formal or informal considerations that have taken place relating to the following.

Discussions that have taken place about the suitability and safety of the Christmas Pie Cycle Trail leading east to proposed development at Blackwell Farm and west to Ash, for children aged 11 – 16 to use, in all weathers and at all times of the year.

2. Odyssey Markides Llp Technical Note dated September 2014

Pedestrian/Cycle Accessibility:

4.3 There may be scope to extend the existing footway from Wanborough rail station along the western side of Glaziers Lane northwards to the potential site access onto Glaziers Lane

Under the Freedom of Information Act 2000, I request that you please provide me with copies of all documents, papers, minutes, analysis and statistics etc. that relate to  any formal or informal considerations that have taken place relating to the following.

The possibility of the construction of this footway  being feasible, given the many obstructions that are in the way.

3. Discounted sites for schools in Guildford Borough

West of Borough

Site - H12 land between Normandy and Flexford

Under the Freedom of Information Act 2000, I request that you please provide me with copies of all documents, papers, minutes, analysis and statistics etc. that relate to  any formal or informal considerations that have taken place relating to the following.

The suitability of this site for a secondary school

Information awaited from Nicky Morgan at the DfE. Forwarded to her by Jonathan Lord

Am I correct in thinking that Surrey County Council or Guildford Borough Council should have already sought proposals to establish a free school on this site, or a maintained school if it is to meet a specific type of place?

Am I correct in thinking that, even if the developer provides the serviced land free of charge to Surrey County Council, the Department for Education would have to provide the funds to actually build the school and the infrastructure? Is it correct to say that, if this is the case, then Surrey County Council or Guildford Borough Council should already have sought funding in order to include the school on the concept master-plan, and if they have not, then the proposal should be rejected and the school should not appear on the plan?

If the proposal for the new school has to be rejected because capital funding for the buildings and infrastructure  has not been approved, or there is no confirmation that resources will be available, am I correct in thinking that the school shown on the strategic site has to be removed from the plans?

Documents to look at:

SCC School Organisation Plan – School places in Surrey 2015/16 – 2024/25

PDF Document – GBC Secondary Schools Borough Wide Discounted Sites

Guildford Draft Local Plan Education Review

Guildford borough Proposed Submission Local Plan: strategy and sites June 2016

Infrastructure – The Road Network

The road network in Normandy will not be able to sustain the volume of traffic that a development with 1,100 homes would create and there are no highway improvements that can conceivably be made to these country lanes to convert them to the A-class roads needed to serve the proposed development.


Overview

The proposed site is boxed in by an unclassified road (Glaziers Lane D60) on the east, a C-class road (Westwood Lane C16) on the west, and a railway line to the south. Both of the roads struggle to cope with the existing volume of traffic, let alone the increased traffic from an 1,100 home development and road traffic to and from the proposed school.

There is a narrow humpback bridge on Glaziers Lane to negotiate, which is on a deceptive double bend and has very limited sight lines, as well as a right angled bend where the Lane meets another unclassified road, Flexford Lane. There is also an extremely dangerous, single-lane road under a railway bridge on Westwood Lane which also has a deceptive double bend and a height limit of 14’-3” under which a double-decker bus is not able to pass.

There are also dangerous junctions where these roads meet the A323 Guildford to Aldershot road at their northern ends. At rush hour this road is already congested and is identified in GBCs ‘Options Growth Scenario Transport Assessment Report’ as being at full capacity already.

The entry and exit from the A31 ‘Hogs Back’ on to the B3000 to travel to and from the development site via Wanborough Hill is a ‘bottle neck’ at most times of the day, and would be likely to ‘grid lock’ with the increased volume of traffic to and from the site and the school. No amount of improvements to the road system will enable these rural roads to cope with the increased volume of traffic, let alone the construction traffic that would disrupt this fragile infrastructure over possibly a fifteen year period.


 Glaziers Lane

Glaziers Lane is an unclassified road (D60) and is unsuitable for the volume of traffic that the proposed development would generate together with additional traffic going to and from the school. The Lane is a rural, residential road, just 6 metres wide at the widest point, with a 30mph speed limit throughout its length.

The Lane is a busy commuter route for cars, commercial vehicles, lorries, multi-axle heavy goods vehicles and articulated lorries travelling between the A323 Guildford to Aldershot Road and the A3 and A31. Many of these vehicles fail to adhere to the speed limit. The street lighting in Glaziers Lane is poor and could at best be described as footpath lighting. Towards the southern end of the Lane is a humpback road bridge over the railway line, which has a sharp incline and decline so that on approach there is no view of the other side of the bridge. The bridge is also on a slight, but deceptive, double bend in the road. At this point the Lane narrows to 5.5 metres, slightly under in places. This is an especially dangerous part of the Lane as cars speed towards the bridge from both directions, with no view of the other side. The roadway of the bridge is badly sunken on both sides due to the weight of the heavy goods vehicles crossing the bridge.

At the northern end of the Lane is the junction with the A323 Guildford to Aldershot Road, where Glaziers Lane crosses over to Hunts Hill Road. This is a difficult junction to negotiate owing to the amount of traffic travelling along the main road, and also because there are cars turning right out of Glaziers Lane on to the main road, cutting across the path of cars coming across from Hunts Hill Road, with both sets of drivers attempting to find a gap in the main road traffic. There is often a tail-back of traffic in Glaziers Lane waiting to exit.

The single footpath along the Lane is not continuous, changing from side to side of the road along its length. This means that pedestrians have to cross the road at various points in order to remain on the footpath, with two exceptionally dangerous crossing points which are poorly maintained by SCC. One is by the stream just south of no. 35 Glaziers Lane, on a sharp bend, which means that pedestrians have a poor view of vehicles approaching both directions along the Lane, and drivers of these vehicles cannot clearly see the pedestrians until the last moment.

The other dangerous crossing point is on the north of the road bridge that crosses the railway line, as vehicles approaching from the south only have a short stopping distance after crossing the summit of the ‘blind’ bridge before arriving at the crossing point. These crossing points are especially dangerous for those in wheelchairs, the elderly and infirm, and parents/carers with pushchairs or prams, who require more time to cross the road. At some points the footpath is reduced to a width of much less than a metre, due to the outward growth of hedges meaning that passing pedestrians often have to walk in the road. A build-up of debris where the kerbs are lowered at the crossing points also means that pedestrians have to move on to the road to avoid the mud.

The railway station is situated close to the southern side of the humpback bridge and has limited space for car parking, which will be insufficient for the proposed increase in vehicle numbers. Cars parking instead on Glaziers Lane would add to the hazards that already exist.

Traffic exiting the station car park and turning north has a tight turning circle in order to keep on the correct side of the road and is vulnerable to vehicles speeding over the bridge south bound with limited views of the approaching traffic. The increased volume of cars using the station car park would add considerably to the dangers. This bridge would be hazardous for cyclists travelling to and from the school.


Westwood Lane

Westwood Lane is classified as a C Class road (C16) and is unsuitable for the volume of traffic that the proposed development would generate and additional traffic going to and from the school. The Lane is a rural, residential road, with a 30mph speed limit along the southern residential part of the road up to the railway bridge, and a 40mph limit up to the northern end of the road along which there are no street lights.

The Lane is a busy commuter route for cars, commercial vehicles, lorries, multi-axle heavy goods vehicles and articulated lorries travelling between the A323 Guildford to Aldershot Road and the A3 and A31. Many of these vehicles fail to adhere to the speed limits. The street lighting is poor and there is no street lighting on the long 40mph stretch of the road.

From Flexford Road (an unclassified road) at the southern end of Westwood Lane to the railway bridge is a hill down which vehicles speed. The road under the railway bridge is a single track road on a deceptive double bend, with priority given to vehicles travelling south. There is a 14’ 3” height restriction on the bridge which means that a double decker bus would not be able to pass under (which would considerably restrict being able to bring pupils to and from the school). Immediately on the southern side of the bridge travelling north, on the nearside, is a road exit at Beech Lane.

Vehicles turning left at this point under the bridge travelling north cannot be seen by vehicles that have priority travelling south, and a greater volume of traffic will only increase the inherent dangers at this bridge. This bridge would be hazardous for cyclists travelling to and from the school, and a congestion point for the increased traffic that an 1,100 housing development would bring.

At the northern end of the Lane is the junction with the A323 Guildford to Aldershot Road. This is an extremely dangerous junction with traffic from Westwood Lane attempting to turn both ways onto the busy A323, while traffic from the A323 is attempting to turn into Westwood Lane. This junction is already a ‘bottle neck’ at busy times of the day. There is the added danger that only a few yards to the west is School Lane, along which Wyke Primary school is located. There is a nearby crossing point ‘island’ on the A323 which is hazardous for pupils and their parent to use and cars have already mounted this island demolishing the street sign.

Many parents who drop off and meet their children park alongside the churchyard in Westwood Lane and negotiate this busy crossing point ‘island’ to get to School Lane. This crossing point will become even more dangerous if an additional form of entry is added to the school, and there is increased traffic entering and exiting Westwood Lane. The footpath is on both sides of Westwood Lane as far north as the railway bridge but from there to the northern end of the road is only on the east side.


B3000 entry/exit to the A31 and Wanborough Hill

The entry and exit from the A31 ‘Hogs Back’ on to the B3000 to travel to and from the development site via Wanborough Hill (C16) is a ‘bottle neck’ at most times of the day, and would be likely to ‘grid lock’ with the increased volume of traffic to and from the proposed development site and the school. There is no pavement nor street lighting from Wanborough Hill until the road reaches Normandy.

Introduction

Surrey County Councillor for Normandy, Pirbright and Worplesdon, Keith Witham, has worked hard on behalf of his constituents in Normandy and Flexford to reveal the information that lies behind the apparent educational need that would justify the proposal to build a large secondary school on the same site as the 'developer-led' proposal for 1,100 homes in the Green Belt. He has brought together a number of key points in his submission.


Secondary school at Normandy (Site A46, GBC draft Local Plan)

The proposed site of Normandy/Flexford for a new Secondary School should be rejected as the need for such a school in that location has not been proven.
 
In its last submission to GBC (July 2014)  Surrey County Council, in its official response, said:  "A site within the proposed urban extension at Blackwell Farm, with all necessary access infrastructure built in and a catchment surrounding the site, would be a more sustainable location in transport terms for a new secondary school to serve the western side of Guildford."   Why has GBC not heeded this advice?

I have highlighted that every neighbouring secondary school is currently undersubscribed, Kings Manor in particular with 57% of its school places currently unoccupied. The birth rate which rose in 2011 and 2012 has reduced for the last two years,  so building new schools now seems very foolhardy.
 
The addition of forms of entry to current schools will be much more cost effective and of courses sustainable in the long term if there is a reduction in need – an empty classroom is cost neutral in terms of annual budgets,  but an empty or only part subscribed school is unsustainable, having spent £millions on creating it would be  a huge waste of money
 
Adding forms of entry to several existing schools will see the costs absorbed after the initial capital cost needed to create a few extra rooms – but they still only require one headteacher, one set of staff etc The Head Teacher and Chairman of Governors at Ash Manor School have offered to co-operate with a programme to expand that school.
 
If SCC Education Officers support the proposal, Surrey County Council needs to demonstrate a clear, and undisputed need for such a school at this location, given the current under-subscription of all neighbouring local secondary schools surrounding Normandy. It should also set out how such a school will be financed. If not, the site should be rejected.


Transport & Roads

In terms of transport, site 46 is located well beyond the existing confines of any urban area restricting the potential for sustainable travel. The existence of Wanborough Railway Station is only of a marginal benefit.
 
The area  is bounded by the D60 (Glaziers Lane); the C16 (Wanborough Hill and Westwood Lane) and the A323 (Guildford/Aldershot Road).
 
I cannot envisage any so called "highways improvements" that could be undertaken, particularly on the C16 or D60 that would enable those roads to cope with the increased traffic from 1,100 homes and a Secondary School.
 
The A323 is already a busy major route, and scope for "improvements" to this road are also limited.
 
Although I suggest that in any case  Highways should consider installing a  passing lane, Guildford bound at the junction with Frog Grove Lane, Wood Street Village, to ease the congestion caused by commuter traffic turning right and causing considerable tailbacks. But that is a current, existing problem.
There would be access issues relating to visibility and safety for pedestrians and cyclists, which could be difficult to resolve given that the roads are fundamentally rural roads, and the existing structures of the Westwood Lane Railway bridge and the Glaziers Lane railway Road bridge. The restricted headroom of the Westwood Lane bridge would also prohibit double decker buses from accessing the proposed school.


Rushmore Borough Council - Aldershot development

Local Authorities have a duty to co-operate in making their local plans and I do not believe this has happened.  In 2013 the development of 3,850 dwellings (population of approx. 9,000) in Aldershot was approved by Rushmoor Bourough Council and is situated about 4 miles from Normandy. The development, over a 15 year period, includes two primary schools, and the provision of a SANG and many other provisions.

The first  of these new houses, part of the first phase of 228 dwellings, are now on sale. The land belonged to the Ministry of Defence's former Aldershot Garrison known as Wellesley, Aldershot Urban Extension.  Guildford BC responded to the plan in 2013 (ref: 13/P/00108) and in that said that GBC objected to the application on the grounds that insufficient information had been provided to allow a full assessment on the impact of that development on the highways network and said "the impact on Surrey's network and mitigation required has not been established" It its response to that planning application, Hampshire County Council, dealing with Highways and Transport issues, hardly referred to the A323.  Copies of those responses are attached for reference.


Environmental Considerations

A development of this scale, in such proximity to the Thames Basin Heaths Special Protection Area, should not be supported.
 
This is an environmentally sensitive location next to  one of the component SSSIs of the Thames Basin Heaths Special Protection Area for birds. The Thames Basin Heaths mitigation plan seeks to zone development away from these sites. This results in a 400m buffer zone where no residential development is permitted.

A developer-led proposal driven by commercial considerations does not take account of the damage it would cause to the local environment and the strain it will place on the local infrastructure.
 
The Green Belt and Countryside Study referring to the importance of the openness of the land between Normandy and Flexford, has been ignored.  The current version of the Plan treats Normandy and Flexford as separate settlements for the purposes of Green Belt ‘sensitivity’ but as one settlement for the purposes of ‘sustainability’. This is a double standard
 
There are many vitally important ecological networks (green infrastructure corridors) that surround the proposed development area (namely Ancient and Semi-natural Woodland, Veteran Trees,  Hedgerows, Semi-improved Grassland, Farmland and a Stream) and connect to other important and protected sites within Normandy Parish and the wider countryside (namely Wanborough and Normandy Woods Site of Nature Conservation Importance (SNCI), Normandy Pond SNCI, Normandy Common SNCI (put forward by the Surrey Local Nature Partnership in 2015), Wyke Churchyard SNCI, Little Flexford SNCI, and even more importantly Thames Basin Heaths Special Protection Area (TBH SPA)).
 
This proposed development would destroy a number of these habitats including Semi-natural Woodland, Veteran and Mature Trees, Hedgerows, Farmland and Semi-improved Grassland, plus would have indirect affects on Ancient Woodland habitat and the Stream through pollution (light, noise, litter and diffuse land and road runoff), predation and disturbance by increased number of cats and dogs (187 cats (cat ownership being 17/100 households) and 264 dogs (dog ownership being 24/100 households) and by people (potential fires and vandalism of trees).
 
The proposed SANG is only 10ha and will be on land that will be muddy in wet weather and during the winter. Whereas the TBH SPA of Ash Ranges is dry during wet weather and during the winter, plus is either 5 minutes away by car or 20 minutes by foot.
 
All the habitats within or adjoining the proposed development site are Priority Habitats of Principal Importance under the NERC Act, plus a number of protected species (European Protected Species, Species of Principal Importance and those protected under The Wildlife and Countryside Act (1981) as amended) have been recorded within either the proposed development site or 500m to 1km of the proposed development site. These include Hedgehogs, Dormice, Great Crested Newts, Barn Owls, Stag Beetles, Skylarks, Common Toads, Common Lizards, Grass Snakes, Adders, Slow worms, Badgers and Bats (including potential roosts within a number of veteran and mature oaks and other trees across the proposed development site and within the woodland blocks).
 
Light pollution from this proposed development on this scale would be starkly visible from Surrey Hills Area of Outstanding Natural Beauty (AONB).
 
Effect on surrounding woodland and stream habitats that adjoin these roads including the SNCI's of Normandy Common, Normandy Pond and Wyke Churchyard.

Potential adverse impacts on the SPA could result from noise and disturbance during construction and through usage of the playing fields when, in addition, external lighting could cause disturbance to the feeding and roosting patterns of the SPA bird species. There could also be impacts on hydrology affecting the open water and wet heathland of the SPA/SSSI and from increased traffic on Westwood Lane, Glaziers Lane and Guildford Road. Traffic pollution is a major source of nitrogen pollution that changes heathland into grassland and many journeys to a new Secondary School could be expected to be by car.
 
Prior to any allocation of the site it will be necessary for the borough council to be able to conclude, beyond reasonable doubt, that there would be no adverse impact on the integrity of the SPA as a consequence of the proposed development of the site.
 
Further work is needed by the borough council to provide the evidence needed to be able to reach that conclusion in respect of the use of the site as a secondary school. The site will require archaeological assessment in advance of any application for development being submitted. I am grateful to Danial Winchester, a professional ecologist who lives in Normandy/Flexford, for much of the above information.


SCC Policy

It is Surrey County Council policy (March 2013) by a Motion agreed at a Full Council meeting of Surrey County Council about the Green Belt:
 
Surrey County Council , March 2013
RESOLVED (unanimously):

Council notes:

1. Surrey County Council has a proud history as the creator of the Green Belt. The County’s Countryside Estate founded by the Surrey County Council Act of 1931 was the basis of the London County Council's Green Belt Act of 1938.

2. The Coalition Agreement states:

‘We will maintain the Green Belt, Sites of Special Scientific Interest (SSSIs) and other environmental protections, and create a new designation – similar to SSSIs –to protect green areas of particular importance to local communities.’

Council believes:

Surrey’s Green Belt, Countryside Estate, SSSIs and other green spaces are vital, not only for the county’s environment but also for maintaining a “green lung” around London.

Council resolves:
1. To use its power to protect Surrey’s Green Belt.
2. To support the National Planning Policy Framework (section 9 – paragraphs 79 to 92) and the Government’s policy of protecting the Green Belt.
3. To make Surrey’s MPs and the County’s Districts and Boroughs aware of this resolution.
4. That any Green Belt development in the County is in line with the needs and wishes of Surrey residents

 

In all correspondence make sure you state clearly “I OBJECT” or your response could be counted as supportive.


A46 was not proposed or considered as a strategic site in the first consultation

A46 ‘strategic site’, was not previously proposed in an earlier consultation. It is not appropriate development at this stage. In 2014’s consultation A46 was ‘safeguarded’. It was not removed from the Metropolitan Greenbelt. ‘Exceptional circumstances’ have not been demonstrated or approved by the inspectorate.You can’t just inset boundaries around pieces of greenbelt, A46/A47/A50 and urbanise them. They must remain greenbelt, according to the recent Solihull ruling.


A46 FAILS National Planning Policy Framework (NPPF)

Normandy and Flexford’s ‘needs and priorities have not been decided by the resident’s’. NPPF 1 ‘provides a framework within which local people and their parish councils can produce their own distinctive local and neighbourhood plans reflecting their needs and priorities of their communities’. A46 is an inappropriate use of a rural area for
‘town uses’. Planning Policy and a developer led building proposal (urban centre) have decided Normandy ‘needs and priorities’ 715 homes, 385 flats, 1,500 place secondary school, a Primary School for 420 pupils, residential or care home, parade of shops, and the Borough’s allocation of 6 showman pitches, 8 flats by the station, 8 flats in Glaziers Lane by new access, 4,700 sq metres of retail, permanently destroying Normandy and Flexford’s rural environment.

NPPF 155 states,’early and meaningful’ engagement and collaboration with neighbourhoods, local organisations is essential’. This has not happened. Evidence has shown that at least 2 years ago, documentation for A46 was submitted on behalf of Taylor Wimpey to GBC Planning Policy. At this stage NO ‘meaningful engagement’ was made
or requested from local people. Does ‘early and meaningful engagement and collaboration’ between Local Authorities and developers appear in the NPPF? Is this legal? GBC should listen to residents rather than breach the NPPF.


‘Sustainability’ versus ‘Sensitivity’

Two of the key concepts that underpin the local plan are ‘sustainability’ (i.e. an areas suitability for development - Policy 1) and ‘sensitivity’ (it’s importance in terms of protecting the Green Belt). Individual settlements are ranked on both counts, and development is favoured in the most ‘sustainable’ ones; conversely, the barrier is higher in the most ‘sensitive ’ones. What is significant is that for the purposes of assessing ‘sustainability’ Normandy and Flexford’ have been treat as one settlement, whereas for ‘sensitivity’ they have been treated separately. This could almost have been designed to give us the outcome we have, as in terms of ‘sustainability’ all the assets from the two settlements are aggregated - which maximises its score on this count - but in terms of Green Belt ‘sensitivity’ the open area between the two settlements is
disregarded - which reduces our score on that one.

This is simply inconsistent’. In fact the original data (used in the first consultation) identified Normandy as one settlement. The data was rewritten in 2014 dividing the settlements in two. Data cannot be changed.


Unsubstantiated claims by GBC that ignore the rights of locals to live in a rural environment

GBC claim, A46 Normandy and Flexford ‘strategic site’, ‘will lead to an improvement in services for existing residents’. GBC have purposely ignored Normandy and Flexford residents’ requesting the removal of A46 from the Draft Plan.

Cllr Spooner stated in a letter, ‘many residents have commented on the lack of retail and a pub’. Five shops have closed and a pub because they were no longer economically viable, (change in shopping habits,) the internet and the milkman (deliveries to your door). A46 is already served by 7 supermarkets, a number of convenience stores, all local petrol stations have attached convenience shops. Small parades of local shops struggle to compete in a saturated market.


Threat to the Thames Basin Heath Special Protection Area (TBHSPA)

A46 ‘strategic site’, is situated only 800metres away from the TBHSPA so is within the 400m - 5km zone of protection. The TBHSPA contains a Site of Special Scientific Interest (SSSI) recognised as one of the key Natura 2000 European sites. A46 Normandy and Flexford ‘strategic’ site will exacerbate all 5 threats. The 5 key threats of high rating are air pollution, human intrusion/disturbance, no funded management plan, recreational use (dog walking causing disturbance), species composition change.
A ‘Visitor Report’ by Natural England (2012) on the TBHSPA identified an increase of visitors to the area to exercise their dogs, 67% had a dog off a lead (potential disturbance to ground nesting birds), only 1% of visitors came from Normandy and Flexford postcodes. The new residents of the A46 ‘strategic site’ and their pets would have a detrimental affect. There is no evidence proving that SANG attracts dog walkers away from TBHSPA.

Natural England states: “Special Areas of Conservation (SACs) are European designated sites, they are afforded protection under the Conservation of Habitats and Species Regulations 2010. Generally speaking, when considering the impacts upon European sites, the Local Planning Authority, under the provisions of the Habitat Regulations, should have regard for any potential impacts that a plan or project may have”.

‘Natural England disagrees with the conclusions reached by the Habitat Regulation Assessment (HRA) and Sustainability Appraisal (SA) and advise that the plan is
unsound on this basis’.

Natural England states further:
“We also have concerns that the Council does not appear to have adopted Government planning policy set out at paragraph 14 of the National Planning Policy Framework (NPPF) stating that local plans should meet objectively assessed development needs unless specific policies in the NPPF (such as protecting designated wildlife sites and landscapes) indicate development should be restricted.”

The Habitats Regulation Assessment document is incorrect. In Section 18 Policies 9. 10, and 13 are assessed but not the policies proposed in this version of The Plan. How can GBC assess incorrect policies.


Flood risks not considered by GBC

As A46 is within 5km of the TBHSPA, (Policy 1: Sustainable Development) GBC should have considered the Habitats Regulations (NPPF) ‘water stress’. This has not been considered. GBC’s Surface Water Management Plan (SWMP) has excluded the land north of A46, flood risk 3a and 3b (identified on the Environmental Agencies flood risk map). Loss of 3b an ‘effective floodplain’ will severely impact on the surrounding areas identified on the SWMP.


TBHSPA is under threat from high density urbanisation

The TBHSPA is under threat from the west of the Borough and A46 ‘strategic site’. Research has shown that relentless encroachment on habitat is having a devastating impact on remaining wildlife. Predation and disturbance by increased number of cats and dogs, 187 cats (cat ownership being 17/100 households) and 264 dogs (dog
ownership being 24/100 households) and by people (potential fires and vandalism of trees) from A46 would have a severe impact on the TBHSPA. There is no robust evidence in the Habitats report of of monitored air quality, NoX and C02 pollution impacting the TBHSPA.

GBC should apply constraints when calculating the overall housing target in the Borough because of the TBHSPA (NPPF). GBC has not applied constraints so are compromising a sensitive ‘designated wildlife sites and landscapes for pro development. A46 is an ‘unsustainable’ development so therefore fails Policy 5.


Who will fund SANG in the future?

Would a proposed ‘bespoke’ SANG of 10 ha be enough for 264 dogs during wet and wintry months, whereas the TBHSPA is dry during the winter.

GBC state, ‘In allocating developer infrastructure contributions, we will prioritise the TBHSPA mitigation and avoidance in order to ensure that we meet our legal responsibilities’.

The TBHSPA’s SANG Avoidance Strategy is about to expire (2016). A new one is not available. Sites proposed in 2004-2009 previous Avoidance Strategy, were not delivered because GBC could not fund their management plans. There is a ‘bespoke’ SANG on A46 but there is no guarantee the SANG will be delivered by the developer. Houses can be built but no SANG will be provided.

Russell Place Farm, Wood Street has been proposed as SANG so developers can build on Flexford Normandy. Natural England has not approved the change of use, from a valuable working farm to SANG, lost because of a developer led proposal ( a travesty).

The Community Infrastructure Levy (CIL) set by GBC (2015) developers to build on prime greenfield sites but the infrastructure and services are much more costly. Any funding, the Community Infrastructure Levy (CIL) secured from this site, will be spent within the whole Borough not on the area affected by development. (New government rules are looming).

Policy 14 states, ‘permission would not be granted for proposals that are likely to materially harm the nature conservation interest of local sites unless clear justification is proved that the need for development clearly outweighs the impact on biodiversity’. If there was no ‘alleged’ need for a Secondary School in the West of the Borough the THBSPA and SSSI would not allow this site to be taken out of Green Belt.


Environmental concerns and issues

There are other vitally important ecological networks (green infrastructure corridors) that surround A46 (namely Ancient and Semi-natural Woodland, Veteran Trees, Hedgerows, Semi-improved Grassland, Farmland and a Stream) and connect to other important and protected sites within Normandy Parish and the wider countryside
(namely Wanborough and Normandy Woods Site of Nature Conservation Importance (SNCI), A47 The Paddocks SNC! (reassessing this site so GBC can build on it,  Normandy Pond SNCI, Normandy Common SNCI (put forward by the Surrey Local Nature Partnership in 2015), Wyke Churchyard SNCI and Little Flexford SNCI.

On A46 a number of these habitats including Semi-natural Woodland, Veteran and Mature Trees (urban lighting next to Ancient Woodland), Hedgerows, Farmland and Semi-improved Grassland, would have indirect affects on Ancient Woodland habitat and the stream through pollution (light, noise, litter and diffuse land and road runoff), predation and disturbance by increased number of cats and dogs and by people (potential fires and vandalism of trees) will cause major decline of our wildlife.

(Policy 14) Although gardens and the planting of developments play an important part in contributing to sustaining biodiversity, 20 years of research has shown, the continual fragmentation of natural habitat has caused the dramatic decline of our birds and wildlife species to levels where even our most popular species are under threat.


Habitats and wildlife should be protected

All habitat within or adjoining A46 are Priority Habitats under the NERC Act, including protected species (European Protected Species, Species of Principal Importance and those protected by The Wildlife and Countryside Act (1981). These include Hedgehogs, Dormice, Great Crested Newts, Barn Owls, Stage Beetles, Skylarks, Toads,  Lizards, Grass Snake, Adders, Slow worms, Badger and bats. Although gardens are a positive source of biodiversity, research has shown it is not enough, fragmentation of habitat is the cause of the devastating decline to wildlife. Policy 14 fails in the protection of wildlife.

Important’ views of the village from the surrounding AONB landscape

Policy D4 states that, ‘new development within inset villages will have particular regard to ‘important’ views of the village from the surrounding landscape’. The urbanisation of A46 proposal will impact on views from the Surrey Hills AONB during daylight hours and light pollution during darkness. There is no ‘important relationship
between (A46) the built development and the surrounding landscape’.

The essential characteristics of Green Belt are their openness and their permanence


A46 FAILS the NPPF.

The fundamental aim of green belt policy is to prevent urban sprawl by keeping land permanently open. To check the unrestricted sprawl of large built up areas.
‘The essential characteristics of Green Belts are their openness and their permanence’ (NPPF). GBC are ignoring past verdicts of planning inspectors that our green fields (A46) contribute to the ‘openness’ of the Green Belt and panoramic view of our green fields to the Surrey Hills AONB.


No ‘Exceptional Circumstances’ can justify changing Normandy & Flexford’s green belt boundaries

It is important to distinguish between the "exceptional circumstances" required to redraw the Green Belt boundary and the "very special circumstances" required to permit building in the Green Belt.

There is no legal definition of "exceptional circumstances". The circumstances are examined on a case by case basis. In the case of the Normandy/Flexford proposals, it is likely to be argued that lack of educational provision requiring the building of a 7FE secondary school to satisfy future need will contribute to the "exceptional circumstances" required to withdraw the land from the Green Belt. However, the Surrey County Council School Organisation Plan, December 2015 predicting school places 2016/16-2024/25, using July 2015 data provided by Guildford Borough Council, only predicts a requirement of 3FE secondary school places in the west of the borough that can be accounted for with existing/currently planned capacity. In addition, FoI requests to Surrey County Council by Normandy residents has reveled that even if the 1,100 homes were to be built, this would give rise to need for only 1FE secondary school places; furthermore, the building of 1,800 homes at Blackwell Farm would give rise to need for only only 2FE secondary school places. Due to under-utilisation of existing capacity, this new need can be catered for by existing schools and planned expansion of existing schools in the west of the borough. There appears to be no justification for an additional 4FE secondary school places, therefore rendering the proposal for the new school inappropriate, removing any capacity for its use as an "exceptional circumstance" that contributes to the removal of the land between Normandy and Flxford settlements from the Green Belt.

When it comes to considering a planning application to build in the Green Belt, the NPPF para 87 states 'inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances. In legal terms, this is a stronger test then that required to prove "exceptional circumstances"

When considering any planning application, local planning authorities should ensure that substantial weight is given to any harm to the Green Belt. ‘Very special circumstances’ will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations (NPPF para 88).

In defining Green Belt protection, planning practice guidance states, ‘Unmet housing need (including for traveller sites) is unlikely to outweigh the harm to the Green Belt and other harm to constitute the ‘very special circumstances’ justifying inappropriate development on a site within Green Belt.’


Protecting countryside from encroachment of urbanisation

The purpose of green belt land is to assist in safeguarding the countryside from encroachment. Changing green fields into on large urban sprawl is adding to creeping suburbanisation of the west of the Borough threatening to merge with Ash and Tongham urban area. Key to this is the ability of the land between Normandy and Flexford settlements to maintain the "openness" of the Green Belt, keeping it permanently open (NPPF Para 79). The land parcel H12 is evaluated in the Green Belt & Countryside Study Vol 5 as contributing the to three of the five purposes of the Green Belt (see NPPF para 80) and further evaluated by more recent work in the GBCS as having special sensitivity ("red") and consequently flagged as inappropriate for development.


There is no proven need for a secondary school

There is no PROVEN need for a secondary school. The birth rate has fallen in the past 2 years. Secondary schools to the west of the Borough are under subscribed by 736. Another 480 places will available at the new Technical College (2018) and there are approved expansions at Guildford County and St. Peters. The New Hoe Valley school will have 120 places available per year, 25 places this year not taken (no catchment area).

Developments in teaching and learning (independent learning) mean that Secondary Schools could become obsolete in the near future.

The Land Availability Assessment (LAA) projections show there will be no identified ‘need’ for a school for the first 5 years of construction of 450 homes.

An application for housing and a 5FE secondary school has been submitted for the development at Rokers, Worplesdon.


Traffic chaos

(Policy 12) On 24th May, GBC’s elected Councillors voted through the Draft Plan, without scrutinising a major piece of evidence, ‘The Strategic Transport Report’ (missing document). An adjournment was requested, but was outvoted by the majority.

The Road Investment Strategy’s main focus is M25 and the A3 (strategic roads), the responsibility of Highways England. No funding is available for any improvements from The Road Investment Strategy Phase 2, until after 2020.

SCC have not yet published their ‘Transport Strategy’.

Surrey County Council traffic simulations verify, the level of traffic on our roads is already above capacity the roads were designed for.

Guildford’s unrealistic ‘growth’ plans will force more traffic onto busy A roads and minor roads. With no evidence of secure funding for any improvements to the A3 (during the life time of the Draft Plan ) the road network will gridlock causing damage and stagnation of our economy.

A further 5,600 will be generated from the combined developments A46 (1,100 homes) and Blackwell Farm (1,800 homes) with access to the A3. Local roads and ‘A’ routes will grind to a halt at peak times with massively increase exhaust pollution of NoX and C02 threatening elderly people and children.

GBC have ignored Rushmoor’s expansion of 4,000 homes which will generate huge volumes of commuter journey from outside the borough, (east to west), compounding traffic congestion in the surrounding roads A31, A323, junctions at Glaziers Lane and Westwood Lane.

Although the GBC’s ‘aspiration’ is to build a tunnel costing billions of pounds, to ease traffic congestion along the A3, it will not be completed during the life span of this Local Plan.

Guildford Residents’ Association (representing 26 residents’ associations including Normandy) June 2016 press release ‘United in Opposition to Local Plan Across Town and Country’, Infrastructure to little to late, argues the ‘vague proposals for a ‘Snake’ (Sustainable Movement Corridor) at A3 improvements offer too little to late’…..’Land is not safeguarded for A3 tunnel entrances or the ‘Snake’…..’Residents are disturbed that no one has had a chance to look at a crucial piece of evidence that should have
informed the Plan - the long awaited ‘Strategic Transport Assessment’.


Detrimental health issues

The potential combination of A3 road improvements and major site work A46 over the next 15 years would be catastrophic for Normandy and Flexford’s link up roads classified at C16 (Westwood Lane and Wanborough Hill) and the D60 (Glazier’s Lane - unclassified road). The construction traffic, continual noise and pollution generated
by the developer will be excessive. Planning Policy has not fully considered the location of the site and traffic impact A46 will have on this rural community.

Scenario 5 demonstrates that if Normandy/Flexford is fully developed approx 800 traffic movements will occur every hour.

5% of the population die from premature death caused by inadequate air quality from traffic pollution. This will lead to significant health issues, especially for
residents who border the three sides of the proposed strategic site and the railway embankment bordering the south. No regard has been given for the well-being of residents. This urban centre is ‘unsustainable’. There is no guarantee between BT or developers that broadband will be available to a site. (Policy E5).

 

With 27 policies being proposed it is important to identify how each of these might apply to the Normandy/Flexford sites A46, A47 and A49 and A50. Once identified, their relevance can be examined and challenged where inappropriate.


SHMA is no justification

The Draft Plan’s proposed ‘growth’ is based on a document called the SHMA. The SHMA is the evidence base which GBC housing targets are based on. The report’s statistics are distorted by large student numbers from Guildford University and has disproportionately increased the ‘need’ for houses. The Office for National Statistics
(ONS) downgraded Guildford’s population growth. The confidential commercial model used to calculate the SHMA numbers cannot be checked (because GBC do not hold the model), it has been taken on trust, this is not satisfactory to some councillors. On the 24 May, some Councillors raised these concerns regarding the SHMA produced by G L Hearn, (the most critical piece of evidence in the Draft Local Plan) but the majority vote indicated that the full council meeting was satisfied that the SHMA was ‘a professional document’!


The Draft Plan proposes to build 693 homes per year, a total of 13,860 homes

The National Planning Policy Framework (NPPF) provides the opportunity to GBC apply constraints when calculating the overall housing target in the Borough (e.g. the Metropolitan Greenbelt, TBHSPA, Surrey Hills AONB, flooding, infrastructure) GBC has applied no constraints to reduce housing numbers whereas other Council’s in Surrey have chosen so to do. (Guildford Resident’s Association press release 7/6/2020 Legend Chart clearly illustrates the ‘unsustainable’ development proposed by GBC, in comparison to other council’s ‘sustainable’ housing targets of approx 300 homes per year.

Green Belt is being eroded by disproportionate ‘strategic sites’ without secure funding for infrastructure and road improvements, inset villages, insetting, the manipulation of boundaries, using rural exception sites outside settlement areas for the whole Borough rather than ‘needs’ of individual rural communities. Guildford and the surrounding village and countryside will be damaged irreparably. (Policies S2,H3,P6,D4).

NPPF 17 requires local authorities to ‘take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the greenbelts around them, recognising the intrinsic character and beauty of the countryside and supporting thriving communities within it’. GBC Draft Local Plan does not meet the requirement of (Policies S2,H3,P6,D4).


Are existing brownfield/retail sites being used wisely?

Only 2,742 homes are planned in Guildford Town Centre and urban areas. One third of jobs will be lost in the retail sector by 2020 according to The British Consortium,
because of increased internet shopping (13% of retail) and higher costs to retailers on the High Street. The recent closures of well known brands highlight a change in shopping habits.

Keith Meldrum of Guildford Residents Association stated in a press release June 2016, ‘Why do we need a 40% increase in retail space in the era of the internet when that land could be used for homes? Why are our politicians, who promised to protect Green Belt, offering up so much countryside for development and making so little
progress in better planning the town? Guildford Residents Association wants to see the following changes in the Local Plan, a realistic housing target that focuses on the needs of Guildford and takes full account of the constraints of being a congested gap town, a bus interchange which means you can travel easily in any direction from central point without needing a car...”Guildford’s green setting, tree lined approaches, fine view, historic centre and riverside maintained as valued and distinctive features of the town; a realistic housing target that focuses on the needs of Guildford, taking in full account of the constraints of being a congested gap town’.


Wasted and underutilised space

Park and rides take up lots of flat space. It has been argued that only one third of Onslow Village Park and Ride is utilised and questions have been asked whether the spaces are used by commuters travelling to London.


What is required and realistic?

The Housing and Planning Act 2016, means Local Authorities must have a register of brownfield land so sites can be recycled, regenerated and put back into use eg: Woodbridge Meadows, Walnut Tree Close by the station area and North Street. There is a desperate need for housing in central Guildford.

It would be more ‘sustainable’ to build homes in urban areas (brownfield sites have some or all services in place so it’s less expensive to develop).

To provide accommodation for 80 - 90% of university students on campus freeing up hundreds of homes in the town, instead of GBC’s proposed 60% of university students living on campus.

GBC own 30 acres of car parking accounts. By building more multi-storey car parks to reduce the amount of flat parking this could potentially release 8-9 acres of council owned land which could be developed for residential housing.

(Policies (B1-B8)There is a slow turnover of office space around the town centre and urban areas indicating a lack of demand. Long term redundant B1a offices could be changed to C3 residential properties (Government Guidance).

Avoid B8 (large warehouses and distribution centres) with low employment opportunities (due to the introduction of robotic technology) taking up acres of land.

(Policy E7)To avoid massive retail expansion in town centre as traditional retail falls, impacted by Internet retail. Developers have pulled out of North Street regeneration because it is not economically viable. It would be more sensible to have a smaller amount of retail, with more sustainable homes built in the town.

(Polices E2,E4) Surrey Research Park has permission granted to expand by 14% (not yet developed), GBC is proposing another expansion even though there is enough land to last the life of this Draft Plan (2015 Land and Assessment Need growth forecast is11.9%).

GBC should apply all constraints within the NPPF, to reduce the numbers of homes. GBC has planned for large urbanised ‘strategic sites’. It would be fairer and more ‘sustainable’ to work with Resident Associations, Parish Councils and residents and focus on the ‘need’ of the communties throughout Guildford Borough rather than focusing on ‘growth’, a decision wrongly taken by GBC planners.

By focusing on ‘need’ in communities would not overload the existing infrastructure, amenities and the road network. NPPF 1 provides a framework within which local people and their parish councils can produce their own distinctive local and neighbour plans reflecting their needs and priorities of their communities.


Building over our greatest assets

GBC’s pro develop Draft Plan extends to the countryside in our Borough (a concreted over landscape).

The rural areas around the Borough are highly valued by residents, dog walkers, visitors, ramblers, cyclists for leisure and competitions, and horse riders.

GBC acknowledges the importance of tourism and leisure within the Borough but again favours development over the protection of the Borough’s greatest asset the rural countryside and wildlife, The North Downs, Hog’s Back AONBs, LGVs, SPA, SSSIs and the THBSPA.

Monday the 26th - Published by Normandy Action Group, 166 Glaziers Lane, Guildford GU3 2EB - with thanks to Keith Witham, Surrey County Councillor - Hostgator Coupon Template