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

Green Belt Policy

In revised Policy P2 Green Belt, GBC continues to include a reference to the Settlement Hierarchy 2014 document as evidence, having renamed the reference to it in the revised policy statement. Flexford ranks 27 (score 10) in the Sustainability rating; Normandy ranks 13 (score 19) in Sustainability based on available services. Flexford is classified as a “Medium Village”, whereas Normandy is classified as a “Small Village”.Wyke is defined as a “Loose knit/Hamlet” community. This distinct separation by rational analysis of the three identified parts of our community continues to be a key argument for remaining “washed over” as their separation and unrestricted views out to the surrounding countryside supports the “openness” of the Green Belt.

It is noted in the new evidence document T3 Sustainability Appraisal 2017 para 10.10.4 that Policy A46 (Land to the south of Normandy and north of Flexford) would have involved the loss of Grade 3a agricultural land that falls in the Environment Agency “Best & Most Versatile” [BMV] category (Grades 1, 2 & 3a), essential for the agricultural future of the country. This further suggests the importance of Normandy and Flexford to the rural economy, as well as their contribution to views into and from the Surrey Hills AONB (Hog’s Back).

Guildford Borough Proposed Submission Local Plan 2017 Appendix H Maps H-P 

Appendix H Maps is the location in the submission documents where the change to the ‘inset’ boundaries can be seen. Within pages 21 to 24 is the sequence of maps showing changes from the previous proposal to ‘inset’ the entire area between and both settlements in withdrawn Policy A46 Normandy & Flexford (p 21) to the new position that removes all boundaries but replaces them with the inset boundaries around Flexford and Normandy settlements and Walden Cottages (p24 Amendments 3-8).

At the detail presented, even when ‘zoomed in’ the new map boundaries are indistinct and provide no basis to distinguish in low-level detail between the 2003 Local Plan established settlement boundaries and where the proposed ‘inset’ boundaries will lie to reveal what new land will be included.

Normandy & Flexford settlements proposed for ‘inset’ from Green Belt

With the removal of Policy A46 and Policy A47 from the proposed submission Local Plan, there remains the question of whether the two separate settlements will remain ‘washed over’ by the Green Belt.

In Policy P2 Green Belt para 4.3.13 it is asserted that Normandy and Flexford “are now inset from the Green Belt”. To remove land from the Green Belt, effectively re-drawing the Green Belt boundary, the council must provide evidence of “exceptional circumstances” as required by NPPF para. 89. The council has provided no such evidence in the proposed submission documents.

In the Sustainability Appraisal 2017 para 10.4.7, it is argued that Policy D4 (Character and design of new development), which refers specifically to design considerations within villages, and a new designation of Open Space (Policy ID4) “that policy is in place to protect open space and village character, which is known to be important to rural communities”. This is no substitute for being ‘washed over’ by the Green Belt and appears instead to be knowingly a sop to the impact of ‘inset.

Local land contributes to ‘openness’

There is evidence in past appeal decisions by planning inspectors that Flexford and Normandy land contributes to the ‘openness’ of the Green Belt, a key test for remaining ‘washed over’. In particular, the final decision at North Wyke Farm [GBC Application 14/P/00779, PINS Appeal APP/Y3615/W/15/3002308] recognised that Normandy settlement land contributed to the ‘openness’ of the Green Belt

This adds to comments supporting ‘openness’ made in the decisions to grant temporary planning permission for Gypsy pitches at Green Lane East [GBC Application 10/P/00507, PINS Appeal APP/Y3615/A/10/ 2140630] and Palm House Nurseries, Glaziers Lane [GBC Application 09/P/01851, PINS Appeal APP/Y3615/A/10/ 2131590].

Traveller sites proposed for ‘inset’

The traveller sites at land to the rear of Palm House Nurseries [Policy A49] plus the travelling show-people site at Whittles Drive, Guildford Road [Policy A50] are proposed for ‘inset’. At present, where such sites are located in the Green Belt, they are subject to the planning restrictions associated with the Green Belt. ‘Insetting’ will create small islands of ‘urban’ land in the Green Belt which is irrational.

The land at Palm House Nurseries and Green Lane East was identified at appeal by the inspector as contributing to the ‘openness’ of the Green Belt and this argues strongly that it should remain ‘washed over’ by the Green Belt, as all other surrounding land in the submission Local Plan is proposed to remain in the Green Belt.

The traveller sites are all assessed as being located in Green Belt land of “high sensitivity” that is quoted as a main reason Policy A46 and A47 were withdrawn (Sustainability Appraisal 2017, Table 10.1: Commentary on proposed Traveller site allocations, including Green Belt sensitivity) indicating a further argument against ‘inset’ boundaries for such small plots being established in this area.

To remove land from the Green Belt, effectively re-drawing the Green Belt boundary, the council must provide evidence of “exceptional circumstances” as required by NPPF para. 89. The council has provided no such evidence in the proposed submission documents.

Key comments for your submission

Policy P2 Green Belt

  • I object to the changes to Policy P2 because they have not addressed many of the 32,000 comments made to the 2016 plan.
  • I object to the new para (1) “The Metropolitan Green Belt will continue to be protected as shown designated on the Policies Map, against inappropriate development.  In accordance with national planning policy, the construction of new development will be considered inappropriate and will not be permitted unless very special circumstances can be demonstrated.” The words “as shown designated on the Policies Map” should be deleted. The Policies Map has effectively ignored huge areas of Green Belt protection and the new para (1) is therefore a sham.
  •  I object to the proposed change that Normandy settlement, Flexford settlement and Walden Cottages should be inset from the Green Belt due to the fact that:
    • There is evidence in past planning appeals APP/Y3615/W/15/3002308, APP/Y3615/A/10/ 2140630 and APP/Y3615/A/10/ 2131590 that the land here contributes to the “openness“ of the Green Belt
    • There is evidence in the Sustainability Appraisal para 10.4.7 that the agricultural land between the settlements is of BMV quality, exhibits ‘openness’ and contributes to the rural economy
    • The land in and around the settlements of Normandy and Flexford contributes to views into and from the Surrey Hills AONB (Hog’s Back)
  • Policy P2 fails to appreciate the importance and permanence of the Metropolitan Green Belt and the fact that it needs to be permanently protected. The Green Belt is intended to check the unrestricted sprawl of built up areas; to prevent neighbouring towns from merging into one another; to safeguard the countryside from encroachment; to preserve the setting and special character of historic towns; and to assist with urban regeneration by encouraging the recycling of derelict and other urban land.
  • Policy P2 omits any assessment of the Green Belt’s value.  The Green Belt is not just empty space but is an inhabited, working environment that safeguards a certain stock of natural capital.
  • It is incorrect to argue, as the Council do, that the plan would involve the loss of “only” 1.6% of the borough’s Green Belt. In reality the figure is nearer 7% when insetting, infilling and settlement boundary extensions are included.  More importantly, there is no “acceptable” percentage (in the NPPF or anywhere else) of land that may be removed from the Green Belt.
  • I object to the statement in the submission Local Plan under Green Belt Policy P2 (4.3.13) which claims that Normandy, Flexford and a further list of 12 villages are “now inset from the Green Belt”. This statement is untrue as GBC is proposing to “inset” these villages. No decision has been made by an Inspector, therefore the villages remain in the Green Belt.
  • I object to the changed “insetting” of 15 villages from the Green Belt, and at “infilling” 12 of the borough’s Green Belt villages.
  • I am concerned that settlement boundaries are to be hugely extended in many villages and that infilling is also proposed outside the settlement boundaries of 11 further villages.  This is completely unplanned and unmeasured development outside the OAN.
  • Many Guildford villages are elongated in outline, reflecting the effect of ribbon development (often along just one side of existing roads) permitted between the Wars.  It is all too easy to square off boundaries by including countryside bounded on only one or two sides by existing development, claiming it contributes nothing to the “openness” of the Green Belt, a term which neither the plan nor the NPPF defines.  The NPPF’s other 4 tests of Green Belt status, including the prevention of urban sprawl, are ignored.  Effectively, this policy makes all villages within the Green Belt vulnerable to large blocks of new development.
Wednesday the 17th - Published by Normandy Action Group, 166 Glaziers Lane, Guildford GU3 2EB - with thanks to Keith Witham, Surrey County Councillor - Hostgator Coupon Template