Consultation Response

The two settlements of Normandy and Flexford, that along with the areas and hamlets of Christmas Pie, Willey Green, Wyke and Pinewoods make up the ward of Normandy, have been ‘inset’ in the current Local Plan. We are concerned with any Development Management Policy that draws on the NPPF and NPPG guidance to exacerbate existing pressures on infrastructure, the countryside within the inset boundaries and the land designated as Green Belt outwith the inset boundaries.

In particular:

Housing

Policy H4 Housing Density

Economy

Policy E10: Rural development (including agricultural diversification)

Protecting

Policy P6: Biodiversity in New Developments

Policy P8: Woodland, trees, hedgerows and irreplaceable habitats

Policy P14: Regionally Important Geological / Geomorphological Sites


Housing

Policy H4: Housing Density

Preferred option to housing density

The aim of this policy is to enable appropriate residential densities in high quality design-led schemes by having a policy that requires:

1) Maximising the optimal use of land by building homes at the most appropriate density taking into account:

a) the site size, characteristics and location,

b) the urban grain of the area and appropriate building forms and sizes for the site, and

c) the context and local character of the area.

2) Higher density development in the Town Centre, strategic sites or within 500 metres of existing or planned transport interchanges, unless there are strong reasons why it would be inappropriate.

Justification for the choice of options and selection of preferred option

Reasons the options were selected

A number of options have been considered to enable a comparison between them in terms of their ability to meet legislative requirements, Relevant Objectives from LPSS and the highlighted planning issues specific to Guildford borough.

Reasons for selecting the preferred option in light of the other options

Some of the alternative options are less specific to Guildford borough as they rely on generic guidance within the NPPF or PPG, or on the broader strategic Local Plan policies.

The NPPF and PPG set out a range of considerations and tools that can assist in establishing appropriate densities on a site or in a particular area, such as accessibility, characterisation and design studies, environmental and infrastructure assessments and site viability. This is considered preferable to setting minimum density ranges for specific locations (the Town Centre, strategic sites or within 500 metres of existing or planned transport interchanges). To set out minimum density ranges is considered to be restrictive and complicated to ascertain and will limit the flexibility that is often needed when determining a planning application.

The Council’s preferred option requires the optimal use of land by building homes at the most appropriate density. It is considered the most appropriate approach for Guildford. To apply prescriptive density ranges would restrict the flexibility to take all the site constraints and considerations into account. Sites within Guildford can often have their own challenges, such as the topography of the site, being partially within the flood plain or the impact on views which are crucial to the character and setting of the town centre. Flexibility is needed to ensure the right development can take place. Whilst seeking the optimum use of the land there also needs to be flexibility to ensure that a well-balanced range of housing can come forward to meet Guildford’s housing needs.

When considering the relevant issues and options for housing density in Guildford, the Council’s preferred approach is to enable well-designed housing at an appropriate density. There will be a presumption for higher density development in the Town Centre. In the Town Centre there are more limited opportunities for development, yet it is a sustainable location so housing density needs to be optimised. There will also be a presumption for higher density development on strategic sites and within 500 metres of existing or planned transport interchanges. This is because the size of strategic sites will enable thoughtfully designed higher densities, and being in close proximity to transport interchanges enables opportunities to optimise densities on sustainable sites.

The results of the assessment suggest that the preferred option provides a greater amount of guidance and flexibility specific to Guildford borough to help meet the relevant Local Plan objectives.

Question 1: Do you agree with the preferred option to address housing density in Guildford? 

Do you have any other comments or suggestions?

Response: Normandy Action Group disagree

While this wording is based on the National Planning Policy Framework (NPPF) – which is binding - this policy fails to recognise that development in rural areas, with inadequate transport and other infrastructure, cannot cope with the proposed scale of development. It is unsustainable. This should represent an absolute constraint on development.

Comments & Suggestions

The proposed approach to density lacks any ability to ensure that the density of a proposed development is appropriate given the environmental, landscape, character and sustainability constraints and/or opportunities of individual sites. This has resulted in high density housing being built in ‘edge of village’ settings in relatively low sustainability. In Flexford this has contributed to the development of affordable housing to address the Borough general need in Beech Lane, capping over land that had previously acted as a proxy SuDS resulting in flooding of properties not previously inundated and only resolved via the local Flood Forum after resistance to the necessary investment from GBC.

NAG supports the requirement to ensure that the development capacity of sites should avoid the necessary further release of Green Belt land. However, this must not be at the expense of the amenity of local residents (see above) and the character of the surrounding area. 

The second part of the preferred option for housing density states that the policy will require:

Higher Density development in the Town Centre, strategic sites or within 500 metres of existing or planned transport interchanges, unless there are strong reasons why it would be inappropriate. 

The listed transport interchanges include the existing outlying stations of Ash, Ash Vale, North Camp and Horsley, in addition to the proposed stations at Guildford East (Merrow) and Guildford West (Park Barn). 

NAG does not consider that a distance of 500 metres from such transport interchanges would be suitable for high density development. For smaller settlements like Normandy and Flexford a distance of 500m would be outside the settlement boundary and totally inappropriate for high density housing and in many instances this buffer would include areas of low density housing and in many circumstances this would include large areas of existing unallocated Green Belt land.

The wording of the policy regarding the proximity to transport interchanges should be reviewed to ensure that the policy is appropriate for the individual circumstances of existing settlements. 

In addition to transport interchanges, many of the new large sites in the Local Plan are areas of former Green Belt land with significant constraints, not least that of landscape or character impact.


Economy

Policy E10: Rural development (including agricultural diversification)

Preferred option to support development of rural economy

The preferred option is to support the development of the rural economy by means of a policy that clarifies the types of new buildings or changes of use of buildings and land that the Council would consider acceptable in principle, subject to any proposal falling within the exceptions listed in paragraph 145 (a) to (g) of the NPPF for sites in the Green Belt, or meeting the requirement of policy P3 (1) of the Local Plan: Strategy and Sites18 for non-Green Belt sites.

Green Belt

Within the Green Belt, the policy might support the following proposed forms of rural development, provided that any proposal falls within the exceptions listed in paragraphs 145 and 146 of the NPPF:

1) New appropriate facilities for small-scale outdoor sport or outdoor recreation, such as a sports pavilion or clubhouse, or a small-scale building within a farm holding to accommodate outdoor recreational facilities such as an animal petting area.

2) Conversion of vacant or redundant agricultural buildings to small-scale business, or recreational uses.

Countryside

Within the area of countryside, as designated on the Policies Map, the policy could support development of the following new uses in principle, provided they respect the area’s local character:

1) Farm shops (provided they support the farm’s agricultural operations and are operated as part of the farm holding)

2) Other farm diversification proposals, for example activity centres and arts and craft shops

3) tourist accommodation

4) small-scale rural tourism attractions

5) Small-scale leisure facilities

6) Horticultural nurseries and other small-scale business enterprises

New buildings in the countryside should be clustered together where possible to reduce their visual impact on the character of the countryside and any built features should avoid harm to the local environment or residential amenity (particularly through noise).

Non-agricultural uses within farm holdings

New buildings, or proposed changes of use of existing buildings, within a farm holding that are to be used for non-agricultural uses will be required to be operated as part of the farm holding and support the farm’s agricultural operation.

The Council will require adequate space to be made available within the curtilage of any building within a farm holding proposed for a farm shop or other non-agricultural use to allow for staff and visitor parking without detriment to the visual amenity of the countryside.

If permission is granted for a farm shop, the Council may apply conditions to limit the overall scale of the development and require that any goods for sale that are not produced locally remain ancillary to the sale of local produce.

Justification for the choice of options and selection of preferred option

Reasons the alternatives were selected 

'No policy’ is the only reasonable alternative as no further options were identified.

Reasons for selecting the preferred option in light of the alternatives

Whilst policy RE9 of the 2003 Local Plan was superseded entirely by the NPPF in paragraphs 89, 145, and 146 (d), and by the adopted LPSS (2019) in policies P2, P3, E7, E8, E9 and D1, points 1 and 5 of Policy RE8 were not addressed and remain relevant. It was therefore considered the appropriate option to introduce a new development management policy to address these remaining points of Policy RE8. This option would also enable the introduction of new policy wording to explicitly support particular types of rural development that are compliant with the NPPF.

Question 4: Do you agree with the preferred option to address rural development in Guildford?

Do you have any other comments or suggestions?

Response: Normandy Action Group disagree

Comments & Suggestions

As part of the development plan there will be significant housing growth whose impacts will be felt most acutely in the rural areas of the borough where there are planning constraints such as Green Belt, Surrey Hills Area of Outstanding Natural Beauty [AONB]and/or GBC designated Areas of Great Landscape Value [AGLV] amongst other constraints. In our local context, most importantly to Flexford, that has open views of the Hogs Back, the north slopes of which are contained within the adjacent AGLV area that is subject of consideration by Natural England for inclusion in Surrey Hills AONB.

NAG is concerned about ‘limited infilling’ in villages which is set out in part (e) of paragraph 145 in the NPPF. There is a significant lack of any definition for ‘limited infilling’ within the NPPF or guidance. 

The Part 1 Local Plan sets out a definition of ‘limited infilling’ in paragraph 4.3.23 of the supporting text in relation to Policy P2: Green Belt as follows:

For the purposes of this policy, limited infilling is considered to be the development of a small gap in an otherwise continuous built-up frontage, or the small-scale redevelopment of existing properties within such a frontage. It also includes infilling of small gaps within built development. It should be appropriate to the scale of the locality and not have an adverse impact on the character of the countryside or the local environment.

NAG understands that local planning practice treats ‘limited infilling’ equivalent to the replacement of a single dwelling with two houses on the same site. Large bungalows in large plots are often the focus of such applications, of which there are a large number in the settlement of Flexford.

The approach advocated within Policy E10 does not allow for these impacts to be controlled or, where necessary, mitigated.

We propose that limited infilling is set out within a separate policy altogether for clarity. NAG proposes:

A limit to the size of properties which can be built through infilling 

Infilling reflects the existing character and density of surrounding properties


Protecting

Policy P6: Biodiversity in new developments

The Council’s preferred approach is to include a policy that sets out that biodiversity should be prioritised in development and that opportunities should be taken to maximise biodiversity gains while existing biodiversity features are retained. This is set out below.

Preferred option for biodiversity in new developments

The aim of this policy is to maximise biodiversity gains in all new developments, (including those exempt from biodiversity net gains - see policy P7), by having a policy that:

1) Requires new developments to prioritise biodiversity in their proposals as a general principle.

2) Requires developments within or adjacent to a BOA to support the achievement of the objectives of the BOA as set out in the relevant BOA Policy Statement44 and requires them to protect the designated and priority habitats and species in the BOA and improve habitat connectivity across the BOA.

3) Expects proposals to be guided by other national, regional and local biodiversity strategies. The Green and Blue Infrastructure SPD will signpost and map the relevant strategies to help inform planning proposals.

Planting schemes and landscaping

4) Requires proposals to maximise biodiversity gain in planting and landscaping schemes by choosing species, habitats and management regimes that provide best biodiversity benefit as set out in BOA policy statements and other strategies.

5) Tree canopies are expected to be retained and new tree planting is expected to focus on the creation of new connected tree canopies or the extension of existing canopies. Tree planting schemes should provide resilience in terms of climate, disease and ageing, planting large species with long lifespans where opportunities arise. It is expected that UK sourced native species will be used, unless imported strains would offer greater resilience.

Measures on building structures

6) Requires schemes to include features in or on building structures that support wildlife wherever possible, including integrated nesting boxes and green roofs and walls that will last for the lifetime of the development and cater for appropriate species and habitats.

Site design

7) Expects schemes to take opportunities to create new areas of habitat and provide appropriate links between existing habitats, avoiding and reversing fragmentation and species isolation. Built features are expected to be permeable for wildlife. Where invasive species are present, site design should not facilitate their spread.

8) Expects major schemes to include measures that encourage a sense of community ownership of green spaces.

Sites that include or are adjacent to sensitive habitats

9) Where sites contain or are adjacent to sensitive habitats, appropriate buffers and, where necessary, barriers should be incorporated in order to protect the habitats from the impacts of the development, including those resulting from recreational use. Schemes should be designed to avoid light pollution. If a lighting strategy is provided, it should take account of the potential impacts on wildlife.

10) Development that contains or is adjacent to a watercourse should retain or provide an appropriate buffer between built development (including parking areas, private gardens and landscaping) and the watercourse, composed of natural or semi-natural habitat.

Justification for the choice of options and selection of preferred option

Reasons the alternatives were selected

‘No policy’ is the only reasonable alternative as no further options were identified.

Reasons for selecting the preferred option in light of the alternatives

The national approach to biodiversity changed with the update to the NPPF in 2018 and biodiversity has been given elevated prominence. This, combined with the national focus on biodiversity, means that policy is needed to place a higher priority on biodiversity in development.

Whilst biodiversity could be prioritised through policy P7, which mandates biodiversity net gains on all qualifying developments, and policy ID4 includes a strategic approach to biodiversity, neither of these policies provide enough detail o adequately shape development so that it preserves and enhances biodiversity.

 

Question 6: Do you agree with the preferred option to address biodiversity net gain in Guildford?

Do you have any other comments or suggestions?. 

Response: Normandy Action Group disagree

Comments & Suggestions

The settlements of Normandy and Flexford are now inset within existing Green Belt land. The Green Belt land surrounding the settlements contains recognised stands of Ancient Woodland (e.g. Pusseys Copse, Waldens Copse, Claygate Copse, Kiln Copse, Withybed Copse, Great Westwood, Catherine Frith all listed on DEFRA MAGIC mapping system), a designation that is now recognised in the NPPF, (as well as local SNCIs, i.e. Normandy Common, Wyke School Wood, Henley Park Fields, Withybed Copse are all identified by SyNP as parts of Surrey BOA TBH04). There is now a greater understanding that Ancient Woodland makes a significant contribution to biodiversity.

We believe the existing policy fails to address the following requirement of the NPPF:

NPPF Para 175 c) development resulting in the loss or deterioration of irreplaceable habitats (such as ancient woodland and ancient or veteran trees) should be refused, unless there are wholly exceptional reasons and a suitable compensation strategy exists

We propose in Policy P6 Preferred option for biodiversity in new developments, para 1) additional wording as follows in order for the policy to conform to NPPF 175(c) (text for insertion in bold italic):

"1) Requires new developments to prioritise biodiversity in their proposals as a general principle and protect existing irreplaceable habitats (such as ancient woodland and ancient or veteran trees)"


Protecting

Policy P8: Woodland, trees, hedgerows and irreplaceable habitats

The Council’s preferred approach is to have a policy that requires most developments to deliver a measurable BNG [Biodiversity Net Gain]. This is set out below.

Preferred option for biodiversity net gain

The aim is to provide clarity and detail for the requirement for developments to aim to achieve biodiversity net gain set out in policy ID4 through a policy that:

1) Clarifies that net gain means a minimum gain of 20 per cent. Major developments are required to follow Defra’s net gain calculation methodology ‘Defra Biodiversity Metric 2.0’ and submit a completed spreadsheet with the planning application. Minor developments are required to follow the simplified version of the metric.

2) Clarifies that biodiversity net gain is required on all sites except previously developed sites, unless the previously developed sites support at least one protected or priority species population or habitat, or an assemblage of species with an otherwise demonstrably high biodiversity value

3) Clarifies that proposals for net gain should be delivered in a manner that is consistent with policies P6 and ID4 so that measures are focused on local priorities and will provide best value.

4) Ensures development follows the mitigation hierarchy by:

a) Avoiding impacts on biodiversity as far as possible.

b) Where an impact cannot be avoided, the impact is minimised as far as possible.

c) Where habitats are adversely impacted, they are restored or rehabilitated.

d) Where impacted habitats cannot be wholly restored or rehabilitated, compensation measures are used, including off-site provision in the locality of the development line with the emerging national approach.

5) Requires new habitats delivered under biodiversity net gains to be secured and maintained for at least 30 years.

6) Where the applicant is unable to provide the gains on-site or off-site, the Council will seek a financial contribution to fund habitat measures if suitable land is available.

7) Supports applications for change of use in order to create biodiversity sites in appropriate locations, including biodiversity offsetting sites and sites within Local Nature Recovery Strategies.

Justification for the choice of options and selection of preferred option

Reasons the alternatives were selected

Evidence is available from Defra that shows that a BNG policy set at 10 or 20 per cent can be viable (subject to full plan viability testing).

The only other reasonable alternative is to not have a BNG policy.

Reasons for selecting the preferred option in light of the alternatives 

It is not considered a reasonable option to not have a specific policy covering measurable BNG as this would not be in consistent with NPPF requirements for local plans.

Adopting a BNG of 20 per cent is considered more reasonable than 10 per cent.

At 10 per cent there is greater uncertainty over whether BNG will be achieved overall. The biodiversity decline is more serious in Surrey than nationally and, based on current evidence, the cost of increasing the BNG level from 10 to 20 per cent does not appear to be prohibitive.

Adoption of the standard is subject to full plan viability testing.

Question 8: Do you agree with the preferred option to address woodland, trees, hedgerows and irreplaceable habitats in Guildford?

Do you have any other comments or suggestions?

Response: Normandy Action Group disagree

Comments & Suggestions

NAG believes the distance provision in Policy P8: Woodland, trees, hedgerows and irreplaceable habitats, Preferred option for woodland, trees, hedgerows and irreplaceable habitats, 4 b) set at 15 metres is wholly inadequate. The policy makes no attempt to recognise the issue of wildlife disturbance and displacement during construction phase or post-construction.

Much of the Ancient Woodland stands in the west of the Borough support wildlife populations that benefit from isolation from human activity. Any development will drive away such populations and subsequent human occupation of surrounding developed land with associated activity, noise, air pollution and pet population will make it impossible for their return. The concept of 'net gain' cannot address such species dislocation.

To address development that is likely to have major impact on biodiverstiy and wildlife populations that 'net gain' will not address, we propose (text subject to change in bold italic):

Preferred Option 4(b) Replace “minimum 15 metres” with “minimum 50 metres”.

Preferred Option 4(c) Remove "road" as a separation option

Preferred Option 5 Remove "wherever possible"


Protecting

Policy P14: Regionally Important Geological-Geomorphological Sites

The Council’s preferred approach is to have a policy that protects the value of RIGS sites in line with LPSS Policy ID4. This is set out below.

Preferred option for Regionally Important Geological / Geomorphological Sites

The aims of this policy could be secured by having a policy that:

1) Requires that development proposals that are likely to materially harm the conservation interests of Regionally Important Geological/Geomorphological Sites [RIGS] must demonstrate that the need for the development clearly outweighs the impact on biodiversity.

2) Ensures that where this test is met, every effort is made by the applicant to reduce harm to the conservation interests of the Regionally Important Geological/Geomorphological Site through avoidance and mitigation measures. The applicant must demonstrate that any necessary avoidance and mitigation measures will be implemented and maintained effectively.

Justification for the choice of options and selection of preferred option

Reasons the alternatives were selected

‘No policy’ is the only reasonable alternative as no further options were identified.

Reasons for selecting the preferred option in light of the alternatives

The option to not have a specific policy covering this issue, but to consider planning applications against the NPPF and Planning Practice Guidance, was considered to provide an insufficient level of guidance for the management of development which may affect RIGS within the borough. National policy provides broader guidance for this issue area and it was considered appropriate that additional details were provided in order to clarify how the national guidance should be applied for Guildford’s context.

Having considered the evidence, opportunities and policy context within Guildford, the preferred approach as outlined above is considered to represent the most appropriate method of addressing the issue of development affecting RIGS in Guildford. The preferred approach aligns most appropriately with national legislation and Local Plan Strategy and Sites 2019 policies and guidance, and most effectively addresses the issues outlined within this Plan.

Question 14: Do you agree with the preferred option to address Regionally Important Geological / Geomorphological Sites in Guildford?

Do you have any other comments or suggestions?

Response: Normandy Action Group disagree

Comments & Suggestions

The evidence provided under Issues is wholly deficient in ignoring the locally designated Areas of Great Landscape Value [AGLV]. AGLV as an appropriate geomorphological type (dictionary definition of Geomorphological: “of or relating to the form or surface features of the earth”).

Simply saying that policies from the approved Local Plan 2003 should not be repeated does not make AGLV land to disappear or the responsibility of GBC to appropriately protect it.

Relying on SyNP RIGS is an inadequate response in policy formation. The investigative process should spread its net more widely.

This policy fails to mention Area of Great Landscape Value [AGLV] expressed in Local Plan 2003 Policy RE6 where a specific protection is afforded to a large area recognised as of county-wide importance, addressing landscape character with an intention to provide protection. A large proportion of this area is at some indeterminate point to be considered by Natural England for inclusion in Surrey Hills AONB (subject to MCHLG approval).

The Local Plan 2003 policy stated:

Local Plan 2003, page 87

Policy RE6

AREA OF GREAT LANDSCAPE VALUE (AGLV)

Development within the Area of Great Landscape Value, defined on the Proposals Map, should be consistent with the intention of protecting the distinctive landscape character of the area.

10.27 The AGLV is of county importance and covers the southern half of the Borough as defined on the Proposals Map. Within this area development should have regard to the conservation and enhancement of the existing landscape character.

AGLV in the area of Flexford and Wanborough formed by the northern slopes of the Hogs Back is in process of consideration in Surrey Hills AONB as evidenced by an extract from the report in the GBC Evidence Base as follows:

Surrey Hills AONB Management Plan (2020 – 2025), Post Consultation Draft For Surrey Hills AONB Board, August 2019

1.15 The implications of a Surrey Hills AONB Boundary Review

Significant parts of the Surrey countryside adjacent to the AONB are designated at a county level as Areas of Great Landscape Value (AGLV). These areas have acted as a buffer to the AONB but they also have their own inherent landscape quality and are significant in conserving the landscape setting of some towns and villages. Although AGLV land is not a national designation, previous Surrey Hills AONB Management Plans recognised the importance of AGLV land in protecting the integrity of the Surrey Hills AONB landscape, particularly views to and from the AONB. The application of the Management Plan policies and actions to AGLV land has been instrumental in helping to conserve and enhance the Surrey Hills.

In October 2013, the Surrey Hills AONB Board formally requested that Natural England consider modifying the AONB boundary. In 1958 the Surrey Hills AONB was the second landscape to be designated an AONB, and there has never been a review of the boundary.

A purpose of the review will be to establish whether land designated at a County level as AGLV should be included in the AONB. Following a comprehensive landscape character assessment of the AONB and AGLV land, candidate areas that meet the AONB criteria have been identified. In February 2014, Natural England agreed to progress a Modification Order. It is anticipated that this process will take about two to three years to progress. The aim will be to generate a consensus on the land to be included in the AONB, particularly amongst the six AONB local authorities, in order to reduce any need for a lengthy and expensive Public Inquiry. 

The decision to pursue the modification of the AONB boundary will have a significant impact on the review process, but such a process is expected to take two to three years to complete. It is therefore expected that the implications of a reviewed AONB will be consolidated within the next AONB Management Plan 2025 – 2030, but this will be kept under review during the course of this AONB Management Plan and Government advice.

Currently a large proportion of this Green Belt land has been sold to a land speculator that is selling it off in small plots on the spurious marketing ploy that the land might obtain planning permission. The uncertainty of the AONB inclusion process suggests the community would benefit from a minimum safety net of AGLV protection through inclusion in Policy P14 as a recognised important geomorphological site.

We propose a new paragraph in the Issues section of Policy P14 as follows (proposed text in bold italic) in order to maintain protection for AGLV designated land:

Geomorphological sites that are valuable for their educational, scientific, historic or aesthetic importance but not otherwise determined as RIGS, specifically AGLV designated land under consideration for inclusion in Surrey Hills AONB, shall be subject of this policy, unless subsequently confirmed for inclusion in Surrey Hills AONB by Natural England and Surrey Hills AONB Board. The Council intends to protect this land in line with the protection afforded to ‘Local sites’ in LPSS Policy ID4: Green and blue infrastructure.

Front line in threat of urban sprawl

The Green Belt Sensitivity analysis carried out by consultants for GBC between the Local Plan Reg 18 and first Reg 19 consultations, indicated the land parcels surrounding and containing Normandy & Flexford (H10, H12, H13, H14 & H16) to be of ‘high sensitivity’, one of the main reasons for the withdrawal of A46, reinforcing the analysis contained in the Green Belt & Countryside Study Volume 5 Appendix 1 that highlighted the role of the same land parcels fulfilling the essential roles of the Green Belt, to prevent sprawl, to prevent the coalescing of settlements and protect the ‘openness’ of the countryside.

Remove ‘inset’ & remain ‘washed over’

To bolster the position of our ward in protecting the west of the borough north of the Hogs Back against this proposed east-to-west and west-to-east sprawl and enhance the Green Belt status of Normandy, Flexford and Wyke, residents should consider proposing the removal of the ‘inset’ planned for our settlements and to remain ‘washed over’ by the Green Belt to continue Normandy & Flexford’s contribution to the ‘openness’ of the Green Belt.

As commented in NAG News, Edition 61, there is evidence in past appeal decisions by planning inspectors that Normandy & Flexford’s land contributes to the ‘openness’ of the Green Belt, a key test for remaining ‘washed over’ and this can be highlighted when writing to GBC on the proposed second Reg 19 Local Plan changes.

Land Sensitivity Analysis

The third consultative document "Proposed Submission Local Plan" has seen the removal of the proposed "safeguarded" status of 72.4 hectares of grade 3 agricultural land containing ancient woodland from Wanborough Station to the A323 Guildford Road. As a result of a further survey within the Green Belt & Countryside Study Vol. 5, to assess the 'sensitivity' to development of land parcels on the Green Belt based on a 'traffic light' classification (red=most sensitive, green=least sensitive, amber=moderate sensitivity), the Green Belt land between Flexford and Normandy has been classified as being of "red" sensitivity. Based on this classification, it would be expected the land would not be proposed for development and remain within the Green Belt.

'Developer-led' Proposal

However, a 'developer-led' proposal has been submitted to the council by Taylor Wimpey for the development of this land for 1,100 homes in combination with a 7-entry form secondary school that has arisen from the Surrey County Council evaluation of the impact of future population growth in the west of Guildford borough. The proposal is included in this latest draft Local Plan as Policy A46. The growth in education need is based partly on the Flexford/Normandy proposal and partly on the creation of a further extensive housing development at Blackwell Farm on land owned by University of Surrey. Other outline proposals for Site A46 include a 420-place primary school, a residential home for up to 60 residents (plus the support staff and other facilities), 6 pitches for travelling showpeople, a new village green and 10 hectares of SANG; to help this along the proposals also contain is new comparison retail (A1) space up to 3,000 sq metres and further retail space (A2-A5) up to 1,200 sq metres. One of the sites removed in the previous round of consultation, land to the rear of the Paddocks, including Flexford Pond and an area designated as a Site of Nature Conservation Interest [SNCI] has reappeared as Policy A47 containing a proposal for 50 new homes. 

Impact of Insetting

The further redefinition of land within and between the current settlements as 'urban' is promoted by "insetting" the settlement of Flexford and the settlement of Normandy. The "inset" boundaries in the main follow the redrawn settlement boundaries proposed in the Green Belt & Countryside Study, Volume 4. This will result in the removal of Green Belt planning restrictions, with the 

This version of the draft Guildford Local Plan was published on 5 April 2016 for scrutiny by the Borough, Economy & Infrastructure Executive Advisory Board on 13 April 2016. The document was further reviewed by the borough council Executive Committee on 11 May 2016 before final consideration by the full council on 23 May 2016, when it was approved as the Submission version ready for Regulation 19 public consultation.

The official Regulation 19 consultation period commenced 6 June 2016 and lasts 6 weeks up to 17 July 2016.  Under Regulation 19 of the Planning and Compulsory Purchase Act 2004, respondents have the opportunity to review the process followed by the council in drawing up the final submission version of the draft Local Plan and its accompanying evidence base and submitting their observations on potential changes they would like to see in the submission version of the draft local plan before it is finally packaged up for its examination by the Planning Inspectorate. The submission version of the Local Plan and its accompanying evidence base must pass a test of legal 'soundness' when examined by a Planning Inspector.

By submitting comments during this stage in the consultation process, respondents provide themselves with the opportunity to request to appear in front of the Planning Inspector during the Examination in Public [EiP] phase of the plan's examination towards the end of the year.

There are five core documents that require review in order to have an all-round picture of what is proposed by our borough council.  The proposals are likely to see a profound change in land use if adopted without modification but that's the purpose of consultation.

A further five documents and their associated appendixes are provided, ten documents in all, to round out the background information.

This version of the draft Guildford Local Plan was published on 6 May 2017 for scrutiny by the Borough, Economy & Infrastructure Executive Advisory Board on 8 May 2017. The document was further reviewed by the borough council Executive Committee on 14 May 2017 before final consideration by the full council on 23 May 2017, when it was approved as the Submission version ready for Regulation 19 public consultation.

The official Regulation 19 consultation period commenced 6 June 2017 and lasts 6 weeks up to 24 July 2017.  Under Regulation 19 of the Planning and Compulsory Purchase Act 2004, respondents have the opportunity to review the process followed by the council in drawing up the final submission version of the draft Local Plan and its accompanying evidence base and submitting their observations on potential changes they would like to see in the submission version of the draft local plan before it is finally packaged up for its examination by the Planning Inspectorate. The submission version of the Local Plan and its accompanying evidence base must pass a test of legal 'soundness' when examined by a Planning Inspector.

By submitting comments during this stage in the consultation process, respondents provide themselves with the opportunity to request to appear in front of the Planning Inspector during the Examination in Public [EiP] phase of the plan's examination towards the end of 2017.

The borough council have stressed that this fourth consultation is restricted to the changes in the documentation highlighted in red and that previous comments that do not address these changes are not permissible. However, that does not prevent respondents from requesting that their comments made in the previous 2016 consultation should be taken into account where relevant. 

There are four core documents that require review in order to have an all-round picture of what is proposed by our borough council.  The proposals are likely to see a profound change in land use if adopted without modification but that's the purpose of consultation.

Summary of key changes to the Proposed Submission Local Plan: strategy and sites (2017)
This note provides a brief summary of the changes to the policies, maps and Appendix C: Infrastructure Schedule. Some of the policy changes have been significant and include:

  • additional requirements to the policy (e.g. requiring a proportion of accessible, adaptable and wheelchair accessible homes in Policy H1)
  • clarification on how the policy will be applied (e.g. replacement of ‘we will expect’ with ‘will be required’ in Policy ID3)

Proposed Submission Local Plan 2017 (Strategy & Sites) and Appendixes A - G 
This lays out the core 27 Policies and other aspirations to develop villages and settlements in the Green Belt, including Normandy and Flexford in its 312 pages and Appendixes A-G

Proposed Submission Local Plan (Strategy & Sites) Appendix H Maps H-P

Proposed Submission Local Plan (Strategy & Sites) Appendix H Maps R-W

Subcategories

Proposed Submission Local Plan (Reg 18) - Flexford & Normandy


Land Sensitivity Analysis

The third consultative document "Proposed Submission Local Plan" has seen the removal of the proposed "safeguarded" status of 72.4 hectares of grade 3 agricultural land containing ancient woodland from Wanborough Station to the A323 Guildford Road. As a result of a further survey within the Green Belt & Countryside Study Vol. 5, to assess the 'sensitivity' to development of land parcels on the Green Belt based on a 'traffic light' classification (red=most sensitive, green=least sensitive, amber=moderate sensitivity), the Green Belt land between Flexford and Normandy has been classified as being of "red" sensitivity. Based on this classification, it would be expected the land would not be proposed for development and remain within the Green Belt.

'Developer-led' Proposal

However, a 'developer-led' proposal has been submitted to the council by Taylor Wimpey for the development of this land for 1,100 homes in combination with a 7-entry form secondary school that has arisen from the Surrey County Council evaluation of the impact of future population growth in the west of Guildford borough. The proposal is included in this latest draft Local Plan as Policy A46. The growth in education need is based partly on the Flexford/Normandy proposal and partly on the creation of a further extensive housing development at Blackwell Farm on land owned by University of Surrey. Other outline proposals for Site A46 include a 420-place primary school, a residential home for up to 60 residents (plus the support staff and other facilities), 6 pitches for travelling showpeople, a new village green and 10 hectares of SANG; to help this along the proposals also contain is new comparison retail (A1) space up to 3,000 sq metres and further retail space (A2-A5) up to 1,200 sq metres. One of the sites removed in the previous round of consultation, land to the rear of the Paddocks, including Flexford Pond and an area designated as a Site of Nature Conservation Interest [SNCI] has reappeared as Policy A47 containing a proposal for 50 new homes. 

Impact of Insetting

The further redefinition of land within and between the current settlements as 'urban' is promoted by "insetting" the settlement of Flexford and the settlement of Normandy. The "inset" boundaries in the main follow the redrawn settlement boundaries proposed in the Green Belt & Countryside Study, Volume 4. This will result in the removal of Green Belt planning restrictions, with the potential to lead to an intensification of land use within the "inset" boundaries with housing density in excess of the 30 dwellings per hectare [dph] threshold suggested for Green Belt developments.

Once the settlement areas defined by the "inset" boundaries become contiguous with the land for the 'developer-led' proposal and school, the land boundary for the whole area from Flexford Road in the south to the A323 Guildford Road in the north becomes one large urban land area, with the proposal for a total of 1,100 dwellings (715 houses + 385 flats), 2,640 residents (at 2.4 people per household as per ONS) and 1,375 passenger vehicles (at 1.25 per household as per ONS), up to 400 dogs and over 300 cats. A sprawling "garden village" visible from the AONB of the Hogs Back, gobbling up land that at present fulfills three essential purposes out of five for the Green Belt:

  1. To check the unrestricted sprawl of large built-up areas
  2. To prevent neighbouring towns from merging into one another
  3. To assist in safeguarding the countryside from encroachment

Once an area of land has been defined as Green Belt, the stated opportunities and benefits include:

  • Providing opportunities for access to the open countryside for the urban population, outdoor sport and outdoor recreation near urban areas
  • The retention of attractive landscapes and the enhancement of landscapes, near to where people live
  • Improvement of damaged and derelict land around towns
  • The securing of nature conservation interests
  • The retention of land in agricultural, forestry and related uses

These opportunities and benefits would disappear from our community in less than a resident's lifetime, making the area unrecognisable from what we see today.

Further information to inform responses to the consultation

Proposed Submission Local Plan (Reg 19) - Flexford & Normandy


Front line in threat of urban sprawl

The Green Belt Sensitivity analysis carried out by consultants for GBC between the Local Plan Reg 18 and first Reg 19 consultations, indicated the land parcels surrounding and containing Normandy & Flexford (H10, H12, H13, H14 & H16) to be of ‘high sensitivity’, one of the main reasons for the withdrawal of A46, reinforcing the analysis contained in the Green Belt & Countryside Study Volume 5 Appendix 1 that highlighted the role of the same land parcels fulfilling the essential roles of the Green Belt, to prevent sprawl, to prevent the coalescing of settlements and protect the ‘openness’ of the countryside.

Remove ‘inset’ & remain ‘washed over’

To bolster the position of our ward in protecting the west of the borough north of the Hogs Back against this proposed east-to-west and west-to-east sprawl and enhance the Green Belt status of Normandy, Flexford and Wyke, residents should consider proposing the removal of the ‘inset’ planned for our settlements and to remain ‘washed over’ by the Green Belt to continue Normandy & Flexford’s contribution to the ‘openness’ of the Green Belt.

As commented in NAG News, Edition 61, there is evidence in past appeal decisions by planning inspectors that Normandy & Flexford’s land contributes to the ‘openness’ of the Green Belt, a key test for remaining ‘washed over’ and this can be highlighted when writing to GBC on the proposed second Reg 19 Local Plan changes.

What’s relevant to Flexford & Normandy?

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