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).

 

Saturday the 18th - Published by Normandy Action Group, 166 Glaziers Lane, Guildford GU3 2EB - with thanks to Keith Witham, Surrey County Councillor - Hostgator Coupon Template