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SA REPORT I

SA of the Waverley Local Plan Part 1

TABLE OF CONTENTS

INTRODUCTION ...... 1 1 BACKGROUND ...... 2 2 SA EXPLAINED ...... 2 3 WHAT IS THE PLAN SEEKING TO ACHIEVE? ...... 3 4 WHAT’S THE SCOPE OF THE SA? ...... 5

PART 1: WHAT HAS PLAN-MAKING / SA INVOLVED UP TO THIS POINT? ...... 8 5 INTRODUCTION (TO PART 1) ...... 9 6 DEVELOPING THE REASONABLE ALTERNATIVES ...... 11 7 APPRAISING REASONABLE ALTERNATIVES ...... 29 8 DEVELOPING THE PREFERRED APPROACH ...... 40

PART 2: WHAT ARE SA FINDINGS AT THIS CURRENT STAGE?...... 43 9 INTRODUCTION (TO PART 2) ...... 44 10 APPRAISAL OF THE PROPOSED SUBMISSION PLAN ...... 45

PART 3: WHAT HAPPENS NEXT? ...... 66 11 INTRODUCTION (TO PART 3) ...... 67 12 PLAN FINALISATION ...... 67 13 MONITORING ...... 67

APPENDIX I - REGULATORY REQUIREMENTS ...... 68 APPENDIX II - CONTEXT AND BASELINE REVIEW ...... 73 APPENDIX III - ALTERNATIVES FOR THEMATIC PLAN ISSUES ...... 79 APPENDIX IV - SITE OPTIONS ...... 86 APPENDIX V - SPATIAL STRATEGY ALTERNATIVES ...... 113

SA REPORT II

SA of the Waverley Local Plan Part 1

INTRODUCTION

SA REPORT 1 INTRODUCTION

SA of the Waverley Local Plan Part 1

1 BACKGROUND

1.1.1 AECOM is commissioned to lead on Sustainability Appraisal (SA) in support of the emerging Waverley Local Plan Part 1. SA is a mechanism for considering and communicating the likely effects of a draft plan, and alternatives, with a view to avoiding and mitigating adverse effects and maximising the positives. SA of Local Plans is a legal requirement.1

2 SA EXPLAINED

2.1.1 It is a requirement that SA is undertaken in-line with the procedures prescribed by the Environmental Assessment of Plans and Programmes Regulations 2004, which transposed into national law EU Directive 2001/42/EC on Strategic Environmental Assessment (SEA).2

2.1.2 In-line with the Regulations, a report (known as the SA Report) must be published for consultation alongside the draft plan that essentially ‘identifies, describes and evaluates’ the likely significant effects of implementing ‘the plan, and reasonable alternatives’.3 The report must then be taken into account, alongside consultation responses, when finalising the plan.

2.1.3 More specifically, the SA Report must answer the following three questions:

1. What has Plan-making / SA involved up to this point? – Including in relation to 'reasonable alternatives’. 2. What are the SA findings at this stage? – i.e. in relation to the draft plan. 3. What happens next? – What steps will be taken to finalise (and monitor) the plan?

2.1 This SA Report4

2.1.1 This document is the SA Report for the Waverley Local Plan, and as such each of the three SA questions is answered in turn below, with a ‘part’ of the report dedicated to each.

2.1.2 Before answering Question 1, two initial questions are answered in order to further ‘set the scene’: i) What is the plan trying to achieve?; and ii) What is the scope of the SA?

1 Since provision was made through the Planning and Compulsory Purchase Act 2004 it has been understood that local planning authorities must carry out a process of Sustainability Appraisal alongside plan-making. The centrality of SA to Local Plan-making is emphasised in the National Planning Policy Framework (2012). The Town and Country Planning (Local Planning) (England) Regulations 2012 require that an SA Report is published for consultation alongside the ‘Proposed Submission’ plan document. 2 The SA process incorporates the SEA process. Indeed, SA and SEA are one and the same process, differing only in terms of substantive focus. SA has an equal focus on all three ‘pillars’ of sustainable development (environment, social and economic). 3 Regulation 12(2) of the Environmental Assessment of Plans and Programmes Regulations 2004 4 See Appendix I for further explanation of the regulatory basis for answering certain questions within the SA Report, and a ‘checklist’ explaining more precisely where within this report certain regulatory reporting requirements are met.

SA REPORT 2 INTRODUCTION

SA of the Waverley Local Plan Part 1

3 WHAT IS THE PLAN SEEKING TO ACHIEVE?

3.1 Overview

3.1.1 Once in place, the Local Plan Part 1 will establish a spatial strategy for growth and change in the borough up to 2032, allocate strategic sites and establish strategic policies. A Local Plan Part 2 will be prepared subsequently, allocating further sites and establishing detailed development management policies. The Local Plan Part 1 will also establish a framework for subsequent neighbourhood plan-making.

3.1.2 The Local Plan Part 1 will need to be in general conformity with the National Planning Policy Framework (NPPF), and in-line with planning legislation and regulations including the Duty to Co-operate introduced in the 2011 Localism Act. The Duty to Co-operate places a legal duty on the Council to engage constructively to maximise the effectiveness of Local Plan preparation relating to strategic cross boundary matters.5

3.2 Plan objectives

3.2.1 The plan objectives are as follows -  Contribute to the achievement of sustainable development, having regard to the guiding principles in the UK Sustainable Development Strategy: “Securing the Future”.  Support the delivery of at least 9,861 additional homes in Waverley in the period 2013 to 2032 (an average of 519 homes a year).  Contribute to the delivery of sustainable communities, by directing most new development to the main settlements of Farnham, Godalming, Haslemere and Cranleigh, where there is the best available access to jobs, services and other facilities. This will include some new development on greenfield land on the edge of these settlements.  Support the provision of new development in and on the edge of villages where it meets identified local needs or helps to sustain local facilities and to support the sustainable growth and expansion of rural businesses.  Support the development of suitable brownfield land, including a new settlement at the Dunsfold Aerodrome site.  Ensure that cross boundary impacts arising from major development or infrastructure provision in Waverley or adjoining local authority areas are considered.  Support measures that promote sustainable transport, including improvements to public transport and improved facilities for pedestrians and cyclists.  Maintain and protect all those areas of the Green Belt that fulfil the purposes of the designation.  Protect the countryside for its intrinsic character and beauty and as a recreational asset, including its visitor facilities, and, where appropriate, promote its continued recreational use.  Provide appropriate protection to the hierarchy of national and local landscape designations in Waverley, including the Surrey Hills Area of Outstanding Natural Beauty. To deliver a balance of housing and employment growth that takes account of both the need for additional housing and the need to maintain Waverley’s economic prosperity.  Ensure that adequate provision is made for new or improved social, physical and green infrastructure to meet the needs of the increased population and additional demands arising from employment related development.

5 Neighbouring authorities are Guildford Borough Council, Mole Valley District Council, Horsham District Council, Chichester District Council, South Downs National Park, East Hampshire District Council, Hart District Council and Rushmoor Borough Council. Also, there is a need to cooperate with Surrey, Hampshire and Sussex County Councils.

SA REPORT 3 INTRODUCTION

SA of the Waverley Local Plan Part 1

 Deliver an increase in the overall stock of affordable housing and to ensure that as far as possible the type and tenure of affordable housing meets the local needs identified in the Strategic Housing Market Assessment where is it viable to do so.  Support the delivery of a range of sizes and types of new homes and accommodation, including homes and accommodation to meet the needs of specific groups of the population, including older people and first time buyers.  Safeguard existing employment accommodation and support the delivery of new and improved commercial premises, both within the main settlements and in rural areas, in order to meet flexibly the needs of a range of businesses in Waverley; in particular, to accommodate the projected growth in B1a/b (Offices/Research and Development) uses and the specific needs of small to medium enterprises (SMEs).  Support the vitality and viability of the centres of Farnham, Godalming, Haslemere and Cranleigh, taking account of the difference between each of the centres and the different roles that they play.  Meet the leisure, recreation and cultural needs of the community.  Safeguard and enhance the rich historic heritage and the diverse and attractive landscapes and townscapes in Waverley, and to ensure that new development takes proper account of the character and distinctiveness of the area in which it is located.  Ensure that the design, form and location of new developments contribute to the creation of sustainable communities that are attractive, safe and inclusive.  Protect and enhance Waverley’s biodiversity, including its wildlife species and their habitats, both on designated sites such as the Thames Basin Heaths and Wealden Heaths (Phases 1 and 2) Special Protection Areas, and on undesignated sites.  Reduce the emissions that contribute to climate change and minimise the risks resulting from the impact of climate change.  Ensure that new development is located and designed to manage and reduce its risk from flooding.

3.3 What is the Local Plan not seeking to achieve?

3.3.1 It is important to emphasise that the plan will be strategic in nature. This plan will establish some thematic policy, but the detail will be limited in the knowledge that production of a second Local Plan – focused on addressing detailed development management issues - will follow this current plan. Equally, the allocation of sites / establishment of site-specific policy through this plan should also be considered a strategic undertaking, i.e. a process that omits consideration of some detailed issues (in the knowledge that they can be addressed at the planning application stage).

3.3.2 The strategic nature of the Local Plan is reflected in the scope of the SA.

SA REPORT 4 INTRODUCTION

SA of the Waverley Local Plan Part 1

4 WHAT IS THE SCOPE OF THE SA?

4.1 Introduction

4.1.1 The aim here is to introduce the reader to the scope of the SA, i.e. the sustainability issues / objectives that should be a focus of (and provide a broad methodological framework for) SA.

4.1.2 Further information on the scope of the SA – i.e. a more detailed review of sustainability issues/objectives as highlighted through a review of the sustainability ‘context’ and ‘baseline’ - is presented in Appendix II.

Consultation on the scope

4.1.3 The Regulations require that “When deciding on the scope and level of detail of the information that must be included in the Environmental Report [i.e. the SA scope], the responsible authority shall consult the consultation bodies”. In England, the consultation bodies are Natural England, the Environment Agency and Historic England.6 As such, these authorities were consulted on the SA scope in 2014.7 Since that time, the SA scope has evolved as new evidence has emerged - however, the scope remains fundamentally similar to that agreed through the dedicated scoping consultation in 2014.

N.B. Stakeholders are also welcome to comment on the SA scope at the current time. Any comments received will be taken into account in due course (see Part 3 ‘Next Steps’).

4.2 Key issues / objectives

4.2.1 Table 4.1 presents the sustainability objectives established through SA scoping, i.e. in-light of context/baseline review and consultation. Objectives are grouped under nine topic headings.

4.2.2 Taken together, the sustainability topics and objectives presented in Table 4.1 provide a methodological ‘framework’ for appraisal.

6 In-line with Article 6(3).of the SEA Directive, these consultation bodies were selected because ‘by reason of their specific environmental responsibilities,[they] are likely to be concerned by the environmental effects of implementing plans and programmes.’ 7 Comments received were taken into account and are reflected in an updated version of the Scoping Report, which is available at: www.waverley.gov.uk/newlocalplan.

SA REPORT 5 INTRODUCTION

SA of the Waverley Local Plan Part 1

Table 4.1: Sustainability topics and objectives (i.e. the SA framework) Topics Objectives Biodiversity  Protect and enhance biodiversity, including through a focus on ensuring the continued health and functioning of designated protected sites and strategic ecological corridors Climate  Reduce per capita carbon dioxide emissions from the built environment change  Increase capacity of renewable energy and/or low-carbon district heating networks mitigation Community  Reduce poverty and social exclusion and well-being  Encourage healthy lifestyles, reduce inequalities in health and plan to meet emerging strategic health issues, not least those relating to the ageing population  Ensure access to education and skills development opportunities  Give regard to promoting equality of opportunity for all protected groups, e.g. the elderly.8 Economy  Support economic activity to meet employment needs, including in rural areas  Enhance the vitality of the borough’s centres  Retain well located commercial land  Secure investment in key infrastructure  Encourage the development of a tourism sector based on natural and cultural assets  Improve the match of skills to employment opportunities Heritage and  Conserve and enhance the historic environment, with a focus on designated assets and townscape their settings  Maintain and enhance townscape including through a reduction in derelict or degraded land and a focus on high quality urban fringes Housing  Ensure everyone has the opportunity to live in a decent home  Increase the supply of affordable housing  Support provision of housing for those with specialist needs, including older people Landscape  Conserve and enhance distinctive landscapes, particularly the nationally important AONB and landscapes designated as being of more local importance Soils and  Make most efficient use of land, including through maximising use of previously other natural developed land (including contaminated sites where remediation is possible) resources Traffic and  Reduce the reliance on journeys by car, including through encouraging and supporting transportation trips made by walking, cycling and public transport  Improve accessibility to services, facilities and amenities, including in rural areas  Prevent and seek to reduce traffic congestion, particularly at sensitive locations Water, flood  Minimise the impact of development on flooding (fluvial, surface and groundwater) and risk and other avoid development in at risk areas climate  ‘Climate proof’ urban areas (e.g. through shading and shelter in public spaces) and change infrastructure adaptation issues  Prevent pollution to the water environment  Encourage reduced per capita consumption of water and increased water efficiency.

8 The Council has a duty to give "due regard" to promoting equality of opportunity for all protected groups when making decisions; and publish information showing how they are complying with this duty. ‘Protected groups’ are those with the following characteristics: age; disability; gender reassignment; marriage and civil partnership; pregnancy and maternity; race; religion or belief; sex; sexual orientation.

SA REPORT 6 INTRODUCTION

SA of the Waverley Local Plan Part 1

Has the SA framework been updated recently?

4.2.3 Whilst there has not been formal scoping consultation since 2014 (as discussed above), other evidence has come to light through consultation and technical studies, and as such it is appropriate to modify the SA scope to a small extent.

4.2.4 One area where new evidence has come to light is in relation to traffic and transport. The September 2014 consultation highlighted this to be a key issue, and understanding of transport issues then improved in 2015 and 2016 through technical work (see further discussion in Appendix II).

4.2.5 In light of new evidence, a decision was taken to modify the SA framework (i.e. Table 4.1) through addition of a ‘traffic and transport’ topic heading. Under the 2014 framework, traffic and transport issues were considered under the ‘Climate change mitigation’, ‘Community and well-being’ and ‘Economy’ topic headings (i.e. it was a ‘cross-cutting’ issue); however, it is now considered appropriate to give stand-alone consideration to the subject.

4.2.6 Also, the decision was taken to add a specific reference to equalities objectives, under the ‘communities’ topic heading. This is on the basis that the Council has a duty to give "due regard" to promoting equality of opportunity for all groups with protected characteristics when making policy decisions; and publish information showing how they are complying with this duty. ‘Protected characteristics’ are: age; disability; gender reassignment; marriage and civil partnership; pregnancy and maternity; race; religion or belief; sex; sexual orientation. Of these protected characteristics, some are more relevant to strategic spatial planning than others.

SA REPORT 7 INTRODUCTION

SA of the Waverley Local Plan Part 1

PART 1: WHAT HAS PLAN-MAKING / SA INVOLVED UP TO THIS POINT?

SA REPORT 8 PART 1: PLAN-MAKING / SA UP TO THIS POINT

SA of the Waverley Local Plan Part 1

5 INTRODUCTION (TO PART 1)

5.1.1 Local plan-making has been underway since 2007, with a number of consultations having been held under Regulation 18 of the Local Planning Regulations prior to this current stage, which is under Regulation 19, and a number of Interim SA Reports having been published.

5.1.2 Rather than recap the entire ‘story’ in detail, the intention here is to explain the work undertaken in 2016, which led to the development of the draft plan that is currently the focus of appraisal (see Part 2, below) and is currently published under Regulation 19.

5.1.3 Specifically, in-line with regulatory requirements, there is a need to explain how work was undertaken to develop and then appraise reasonable alternatives, and how the Council then took into account appraisal findings when finalising the draft plan for publication.

5.1.4 More specifically still, this part of the report sets out to present information regarding the consideration of reasonable alternative spatial strategies, i.e. alternative approaches to the allocation of land to meet housing (and economic) needs.

N.B. This information is important given regulatory requirements,9 specifically the requirement to present an appraisal of ‘reasonable alternatives’ and ‘an outline of the reasons for selecting the alternatives dealt with’.

What about other plan issues?

5.1.5 Whilst the plan objectives (see chapter 3, above) are numerous and cover a range of issues, it is clear that an overarching objective10 relates to the identification of land to meet housing needs. Determining an approach to housing growth is the primary means by which the plan seeks to achieve wide ranging objectives. It is the matter at the heart of the plan.

5.1.6 Hence it is considered reasonable11 that alternatives appraisal should focus on this matter. Whilst the plan is set to assign policy to address a range of other specific issues, it was recognised as reasonable and proportionate to develop policy without formal alternatives appraisal (in 2016, recognising that some thematic plan issues had previously been the focus of alternatives appraisal). This matter is discussed further in Appendix III.

What about site options?

5.1.7 Site options - i.e. the pool of sites available, deliverable and potentially suitable for allocation through the plan – were first appraised in 2014 (with appraisal findings presented within the Interim SA Report published at that time), and appraisal findings were subsequently updated in 2015 and 2016.

5.1.8 The role of site options appraisal within the SA process has primarily been to provide an evidence base to facilitate the development of spatial strategy alternatives.12 As such, site options appraisal is not given further explicit attention within this part of the report. Specific sites are discussed as part of the justification for developing alternative spatial strategies, but formal site options appraisal findings are presented only in Appendix IV.13

9 Environmental Assessment of Plans and Programmes Regulations (2004) 10 In line with the Environmental Assessment of Plans and Programmes Regulations (2004), a decision on what ‘reasonably’ should be the focus of alternatives appraisal should be made in-light of the plan objectives. In the case of the Waverley Local Plan, it is suggested that plan objectives (2) and (3), which relate to meeting objectively assessed housing needs, are somewhat overarching. 11 Recent case-law (most notably Friends of the Earth Vs. Welsh Ministers, 2015) has established that planning authorities may apply discretion and planning judgement when determining what should reasonably be the focus of alternatives appraisal, recognising the need to apply a proportionate approach and ensure an SA process / report that is focused and accessible. 12 In other words, site options appraisal was undertaken as a means to an end (i.e. development and appraisal of reasonable alternatives), rather than an end in itself. It is worth noting that site options are not ‘alternatives’ in that they are not mutually exclusive. 13 Also, the merits of preferred site options are discussed in Part 2 of this report.

SA REPORT 9 PART 1: PLAN-MAKING / SA UP TO THIS POINT

SA of the Waverley Local Plan Part 1

Structure of this part of the report

5.1.9 This part of the report is structured as follows:

Chapter 6 - explains reasons for selecting the alternatives dealt with

Chapter 7 - presents an appraisal of the reasonable alternatives

Chapter 8 - explains reasons for selecting the preferred option.

SA REPORT 10 PART 1: PLAN-MAKING / SA UP TO THIS POINT

SA of the Waverley Local Plan Part 1

6 DEVELOPING THE REASONABLE ALTERNATIVES

6.1 Introduction

6.1.1 This chapter explains the work undertaken in 2016 to develop ‘reasonable’ spatial strategy alternatives. This chapter:  explains the context and background to alternatives development; and then  explains the process followed in 2016 in order to establish reasonable alternatives.

6.2 Context and background

6.2.1 It is helpful to consider lessons learned from a number of key stages in the plan-making / SA process:  February 2009: Core Strategy - Issues and Options  January 2010: Core Strategy - Options for the Location of New Homes  September 2010: Core Strategy - Options for the Number of New Homes  January 2011: Core Strategy - Preferred Options and Draft Policies  February 2012: Core Strategy - Revised Preferred Options and Draft policies  August 2012: Core Strategy - Pre-submission.14  August 2014: Local Plan - Potential Housing Scenarios and Other Issues

Issues and options for the Core Strategy (Feb 2009)

6.2.2 Issues covered / questions posed by the consultation documents included:  How many new homes should be planned for and where should new homes be built?  Should the plan protect employment land / deliver additional employment land?  What should the site size threshold be for requiring a proportion of affordable housing, and what amount of affordable housing should be required on development sites?  Should the plan extend the rural exceptions policy to all villages, and should the plan allocate rural exception sites?  What housing densities are appropriate across the borough?  How should the plan: – meet the housing needs of particular groups (including Gypsies and Travellers)? – use the AGLV and Strategic Gap designations to protect landscape? – maximise sustainable design and construction?

6.2.3 An Interim SA Report was prepared alongside the consultation document, which considered the merits of the various options presented for each of the policy issues. There is no need to recap the conclusions of the Interim SA Report here, but the document is available online.15

14 Subsequent to the plan’s submission to Government, and publication the Government appointed Planning Inspector’s initial conclusions, the decision was taken to withdraw the Core Strategy (October 2013). The Council then begun work on a Local Plan. 15 See http://www.waverley.gov.uk/site/scripts/download_info.php?downloadID=574

SA REPORT 11 PART 1: PLAN-MAKING / SA UP TO THIS POINT

SA of the Waverley Local Plan Part 1

Options for the location of new homes (Jan 2010)

6.2.4 The consultation document began with the statement: “We are required by the South East Plan to provide for at least 5,000 new homes in Waverley in the period from 2006 to 2026. The challenge for us is deciding where these new homes should go and this is where we would like your help.” The document then went on to present advantages/disadvantages of five options.

6.2.5 Each option began from the premise that development should be focused primarily within the main settlements of Farnham, (including Badshot Lea), Godalming, Haslemere and Cranleigh, but then varied in relation to the approach to taken to meeting any shortfall that might arise:

Option 1 - Selected releases of land around the main settlements

Option 2 - Selected releases of land around the main settlements and within and potentially around Beacon Hill and Hindhead and the five largest villages

Option 3 - Selected releases of land around the main settlements and within and potentially around the villages generally

Option 4 - A single urban extension to one of the main settlements

Option 5 - A new freestanding settlement.

6.2.6 No Interim SA Report was published alongside the consultation document, but the SA framework was taken into account when preparing the discussion of advantages/ disadvantages for each of the options. The consultation document is available on the Council’s website.16

Options for the number of new homes (Sept 2010)

6.2.7 The consultation document began with the statement: “We need your views to decide on the number of new homes that it would be acceptable to build in Waverley in the coming years… The Coalition Government has removed nationally and regionally imposed home building targets. Instead local councils like Waverley are now allowed to work with their communities to further understand how many homes should be built in their area.” The document then went on to present the ‘advantages and disadvantages’ of three options:

Option 1 - A number based on the South East Plan

Option 2 - A lower number based on an estimate of land available to build homes on

Option 3 - A higher number based on the need and demand for homes in Waverley

6.2.8 The consultation document presented a range of background information, including on: Population Projections/household formation; Evidence of local housing need, including as established through the Strategic Housing Market Assessment (SHMA); Affordability and house prices; Government’s overall ambitions for affordability across the housing market, including the need to improve affordability and increase housing supply; Economic factors; Evidence of the availability of suitable land including as established through the Strategic Housing Land Availability Assessment (SHLAA); Estimates of supply from windfall sites; Implications of Government policy changes around garden land and housing density; Environmental designations; Infrastructure capacity; and Aspirations of adjoining authorities. The consultation document is available on the Council’s website.17

16 See http://www.waverley.gov.uk/downloads/file/1605/housing_options_technical_background_document. 17 See http://www.waverley.gov.uk/downloads/file/1999/technical_paper_setting_a_local_housing_target

SA REPORT 12 PART 1: PLAN-MAKING / SA UP TO THIS POINT

SA of the Waverley Local Plan Part 1

Core Strategy Preferred Options and Draft Policies (Jan 2011)

6.2.9 The consultation document was badged ‘a draft strategy’, and included: a vision for Waverley in 2027; a number of key objectives; and 19 proposed policies. A helpful synopsis of the consultation document is available on the Council’s website.18

6.2.10 The preferred spatial strategy at the time was as follows: “Waverley’s plan includes a proposal for at least 2,591 new homes in the Borough between now and 2027. This figure is based on a current assessment of suitable and available land within the settlement areas and other suitable brownfield land. The figure also includes some allowance for the future delivery of new homes based on past trends. Waverley’s proposed home building figures are a reduction from the previous Government’s top-down target.”

6.2.11 Draft policies were also presented under the following headings: Sustainable transport; Infrastructure and community facilities; Affordable housing on development sites; Rural exception sites; Housing type and size; Gypsies, Travellers and Travelling Showpeople; Sustainable employment development; Town centres; Local centres; Neighbourhood and village shops; Leisure, recreation and cultural facilities; Landscape character; Townscape and urban design and heritage; Biodiversity and geological conservation; Thames Basin Heaths SPA; Sustainable design and construction; and Renewable energy development.

6.2.12 An Interim SA Report was published alongside the consultation. The Report presented an appraisal of alternatives for ‘how much’ and ‘where’, as well as an appraisal of the draft strategy / policies, as presented within the consultation document.19

Core Strategy Revised Preferred Options and Draft policies (Feb 2012)

6.2.13 The summary leaflet published alongside the consultation document began: “We have taken account of the views we received in response to the last consultation, held in January 2011, and we have now reviewed the Core Strategy. We have also had to take account of new national planning policy. The Government wants the supply of new houses to increase and Waverley has had to respond to this by setting an increased new housing target of 230 per year. Waverley is committed to protecting the Borough’s special environment, but we have had to make some changes to the Core Strategy that we believe are necessary to deliver more new homes.”

6.2.14 Aside from the housing target, amendments made to the strategy / policies were as follows:20  New sites for housing on the edge of Farnham, Godalming and Cranleigh  Revised policies to increase the supply of affordable housing in the villages, and make sure developments are more efficient in using energy and water;  A new policy to manage the risk of flooding; and  A new policy supporting employment growth at Dunsfold Aerodrome.

6.2.15 An Interim SA Report document was published alongside the consultation document, which presented an appraisal of the preferred strategy / policies. This Interim SA Report was prepared by AECOM, leading to a ‘new take’ on the merits of the preferred approach at this time. AECOM firstly appraised a ‘working draft’ of the preferred approach and fed-back findings so that these could be taken on-board by the Council when finalising the consultation document (see Appendix 4 of the Interim SA Report for a discussion of the changes that were made in-light of the appraisal). AECOM then updated the appraisal for consultation, drawing a range of conclusions (see Chapter 5) including:21

18 See http://www.waverley.gov.uk/downloads/file/2178/waverley_in_2027-consultation_jan-mar_2011_leaflet 19 See http://www.waverley.gov.uk/site/scripts/download_info.php?downloadID=574 20 See http://www.waverley.gov.uk/downloads/file/2876/waverleys_future_building_consultation_leaflet 21 See http://www.waverley.gov.uk/site/scripts/download_info.php?downloadID=574

SA REPORT 13 PART 1: PLAN-MAKING / SA UP TO THIS POINT

SA of the Waverley Local Plan Part 1

 The Sustainable Transport policy is likely to offer significant benefits in the longer term as the policy is likely to encourage efficient patterns of movement.  The Affordable Housing on Development Sites policy is likely to offer significant benefits, given the longer lead-in times for major developments  The Amount and Location of Housing policy is likely to have a significant adverse effect in relation to risk of surface and groundwater flooding.  The Biodiversity and Geological Conservation policy will likely offer significant benefits in the longer term.  The Thames Basin Heaths Special Protection Area policy is concerned with the conservation of the ecological integrity of the SPA and will likely offer significant benefits in the long term.

Core Strategy: Pre-submission version (Aug 2012)

6.2.16 Subsequent to the Feb 2012 consultation on Revised Preferred Options and Draft Policies, the Council was in a position to prepare the ‘Pre-submission’ version of the Core Strategy for publication (in-line with Regulation 19 of the Local Planning Regulations). A Consultation Statement was published alongside in-order to explain the issues raised through past consultations, and how these had been addressed.22

6.2.17 The Core Strategy SA Report was published alongside the consultation document, in-line with the Regulations. Appraisal conclusions remained broadly the same as those presented within the February 2012 Interim SA Report, and can be seen in summary form in the Non-technical Summary published alongside the SA Report.23 In addition to presenting an appraisal of the preferred strategy / policies, the SA Report documented the full ‘story’ of plan-making / SA up to that point, with a focus on explaining how detailed consideration of alternatives had fed-in.

Potential Housing Scenarios and Other Issues for the Waverley Local Plan (August 2014)

6.2.18 Following comments from the examining inspector on the submitted Core Strategy, mainly about evidence relating to housing need and the proposed number of new homes, the Core Strategy was withdrawn in October 2013, and the Council subsequently resolved to prepare a Local Plan.

6.2.19 AECOM was re-commissioned in late 2013 to support the Council, as SA consultants, and a number of important internal steps were taken in early 2014. Ultimately, this led to publication of the "Potential Housing Scenarios and Other Issues for the Waverley Local Plan" consultation document and an Interim SA Report published alongside.24

6.2.20 The Interim SA Report was structured in Parts, as per this current report, with the Part discussing “plan-making / SA up to this point” giving particular consideration to the internal steps completed in early 2014. Specifically, the report explained (see pg. 28) that steps were taken in early 2014 to: 1) Informally explore the merits of alternative borough-wide growth quanta; 2) Informally explore the merits of strategic alternatives for each settlement; 3) Appraise site options; and 4) Appraise ‘early’ alternative housing scenarios.

6.2.21 Of the steps undertaken in early 2014, it is worthwhile recapping here on step (4).

22 See http://www.waverley.gov.uk/downloads/file/3213/core_strategy_consultation_statement_august_2012 23 See http://www.waverley.gov.uk/site/scripts/download_info.php?downloadID=574 24 See http://www.waverley.gov.uk/info/494/local_plan/1739/sustainability_appraisal

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6.2.22 Alternative housing scenarios were developed in early 2014 for the purposes of transport modelling, and the opportunity was also taken to undertake SA at this time. The alternatives varied both in terms of quantum (337dpa to 522dpa, reflecting the possibility of achieving a figure below or above that understood at the time to represent objectively assessed housing need) and distribution (the main variables being Dunsfold Aerodrome and the level of growth at the four main settlements, where the total percentage increase in dwelling stock ranged between 8% and 40%). Notably, at this point in time, the option of high growth at Godalming (increase in dwelling stock of 21%) was considered ‘reasonable’; however, the subsequent Green Belt Review suggested otherwise. Detailed alternatives appraisal findings were presented within Appendix II of the Interim SA Report, and the headline conclusion is repeated here - see Box 6.1. Box 6.1: Alternatives appraisal conclusions from early 2014, as reported in the 2014 Interim SA Report25

“The appraisal shows that a low growth approach performs well in terms of a number of environmental objectives, but poorly in terms of ‘community and well-being’ and ‘housing’. It is not suggested that a low growth approach would result in significant opportunities missed in terms of ‘economy’ related objectives, although the need for housing to support employment growth in the sub-region is a consideration. Indeed it is suggested that low growth could perform well in terms of economic objectives as the effect would be to minimise increases in traffic congestion. If a high growth approach were to be followed – i.e. an approach that involves delivering housing at a level above the objectively assessed need figure – and growth were to be focused around the main settlements, there would likely be significant negative effects in terms of landscape and also biodiversity (on the assumption that sufficient mitigation through delivery of SANG would be difficult to achieve). Traffic congestion around the main settlements and on major routes would also be problematic.”

6.2.23 The Interim SA Report then went on to present an appraisal of the four alternative housing scenarios that were a focus of the consultation, which can be summarised as:

1) Nil homes at Dunsfold Aerodrome, 8,450 homes elsewhere

2) 1,800 homes at Dunsfold Aerodrome, 6,650 homes elsewhere

3) 2,600 homes at Dunsfold Aerodrome, 5,850 homes elsewhere

4) 3,400 homes at Dunsfold Aerodrome, 5,050 homes elsewhere.

6.2.24 All would involve delivering 470 dwellings per annum, which was the objectively assessed need figure at that time. With regards to distribution, the alternatives reflected a view that no/low growth at Dunsfold Aerodrome would necessitate high growth at Cranleigh, and to a lesser extent Farnham. Specifically: the proposed percentage increase in dwelling stock at Cranleigh ranged from 13% to 36%, according to the level of growth at Dunsfold Aerodrome; whilst at Farnham the proposed percentage increase in dwelling stock ranged from 11% to 23%, according to the level of growth at Dunsfold Aerodrome. By contrast, the proposed percentage increase in dwelling stock at Haslemere was almost constant across the alternatives (ranging between 10% and 11%); and the proposed increase in dwelling stock at Godalming was entirely constant (at 11%). Box 6.2 presents conclusions reached through the appraisal.

25 This text is from 2014, and hence is now somewhat dated.

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Box 6.2: Alternatives appraisal conclusions from August 2014, as reported in the 2014 Interim SA Report25  “Starting with biodiversity, Scenario 4 is best performing primarily on the basis that growth would be directed away from the European designated sites. Scenario 1 performs least well, although it is not possible to conclude significant negative effects at this stage as work is ongoing to assess whether sufficient Suitable Alternative Natural Greenspace (SANG) can be delivered.  With regard to climate change mitigation, growth should either be focused at Dunsfold Aerodrome (Scenario 4) or at the main settlements (Scenario 1). It is suggested that a ‘middle-ground’ approach would perform least well, as there would be the likelihood of increases in per capita CO2 emissions from transport, and missed opportunities in terms of minimising per capita built environment CO2 emissions.  A similar conclusion is reached for ‘community and well-being’, i.e. it is suggested that growth should be concentrated, whether that be at Dunsfold Aerodrome or around the main settlements. On balance, however, it is suggested that Scenario 1 is preferable to Scenario 4, given uncertainties around the potential to deliver necessary infrastructure at Dunsfold Aerodrome.  The discussion under the ‘economy’ heading focuses to a large extent on traffic congestion issues. It is the case that Scenario 4 could help to avoid worsened traffic congestion around the main towns, although there would obviously be more localised issues in the vicinity of Dunsfold Aerodrome. Another important issue, which serves to highlight weaknesses in Scenario 4 and the benefits of Scenario 1, is the need to deliver housing at locations where businesses wish to locate, which means delivering housing at the main settlements (particularly in the west of the borough).  Heritage is perhaps a lesser consideration (i.e. it would be possible to avoid / minimise impacts under any scenario), but on balance it is suggested that focusing growth at Dunsfold Aerodrome would be preferable to focusing growth at the main settlements (with consequent increases in traffic affecting historic centres). It is recognised that growth at Dunsfold Aerodrome would also lead to some impacts.  All alternatives would lead to significant positive effects in terms of housing on the basis that the ‘objectively assessed housing need’ figure for the borough would be achieved. However, Scenario 4 performs least well given that housing need is primarily focused in the north and west of the borough.  Landscape is a key consideration locally given the sensitivities that exist. Scenario 1 would likely lead to significant negative effects. Locally important landscapes would certainly be impacted, there would be an erosion of the historic settlement pattern in the borough’s north and west and the ‘village feel’ of Cranleigh would likely be lost.  ‘Soil and other natural resources’ is perhaps a lesser consideration, but it is obviously the case that Scenario 1 would lead to significant negative effects as growth would be focused on greenfield land. Scenario 4, on the other hand, would lead to significant positive effects as growth would be focused to a large extent on previously developed land at Dunsfold Aerodrome.  Water / flood risk issues are not a relevant in that it is likely that effects can be avoided / minimised under any scenario.”

6.2.25 As part of the consultation, an online questionnaire was published, which received 4,265 responses, the vast majority from individual residents. Nearly 80% of respondees listed the scenarios in ascending order of preference (i.e. Scenario 1 as fourth choice, Scenario 2 as third choice, etc.), indicating a strong preference for maximising growth at Dunsfold Aerodrome. Only 14% of respondees identified Scenario 4 (nil growth at Dunsfold Aerodrome) as their least preferred scenario. This is a notable finding; however, it must be caveated with the understanding that many of those responding will have supported the scenario that would direct housing growth away from where they live, and it is obviously the case that Dunsfold Aerodrome is remote from where most people live.

6.2.26 Many specific issues were raised through the consultation. Box 6.3 presents a selection of key issues raised, in relation to the alternatives, plus a selection of the ‘5th scenarios’ that were suggested (i.e. scenarios other than the four being consulted on).

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Box 6.3: A brief selection of key comments received during the 2014 housing growth scenarios consultation  Natural England had no specific comments on the four scenarios, but emphasised the importance of avoiding or mitigating impacts to nearby internationally important wildlife sites.  The Environment Agency stated: “We do not have a strong preference for any particular housing scenario option that has been presented in the provided document.” EA also highlighted waste water treatment capacity constraints at some villages, and concerns regarding the sewerage network capacity in Farnham.  The RSPB indicated support for Scenario 4 as there would be least potential for impacts to internationally important wildlife sites.  Surrey Hills AONB Board highlighted Scenarios 3 / 4 as being less likely to impact upon protected landscapes, suggesting that additional housing releases on the edges of the main settlements, with the exception of Haslemere, would be possible without harming the AONB or AGLV (Cranleigh in particular, where neither designation adjoins the built up area).  The National Trust supported a strategy of giving protection to the AONB. In relation to Green Belt, the Trust acknowledged Farnham and Cranleigh as less constrained and suggested that the GB around Godalming and Haslemere requires careful protection as it performs an important function.  Guildford, Woking and Waverley Friends of the Earth warned against prioritising Green Belt and AONB above the need to avoid impacts to internationally important wildlife sites. They suggested that the ability to identify Suitable Alternative Natural Greenspace (SANG) to mitigate effects should not be assumed.  Enterprise M3 LEP declined the opportunity to comment on a preferred scenario, but suggested that consideration should be given to how the scenarios link with the economy of both Waverley and its surrounding area.  Thames Water Utilities Ltd highlighted that water supply to Dunsfold Aerodrome is limited, and that development would require a major resource transfer scheme, which would take in excess of four years.  Guildford Borough Council highlighted the importance of linking WBC's Employment Land Review with GBC's Employment Land Assessment as far as practicable. Both Local Plans should plan positively for the Employment needs of the wider functional economic area.  Hart DC highlighted that all scenarios would involve significant development close to Hart in an area already under pressure particularly from traffic at the southern end of the Blackwater Valley urban area.  With regards to representations received from town and parish councils, Farnham Town Council notably highlighted concerns surrounding infrastructure capacity, citing existing problems with school capacity, sewerage and water supply, traffic and air quality. Infrastructure was also raised as an issue for Cranleigh, and other town and parish Councils also highlighted specific growth related concerns.  Many representations were also received from site promoters, with Dunsfold Airport Ltd (promoters of a new settlement at the Aerodrome) notably pointing to the 2014 Strategic Transport Assessment as providing evidence in support of their proposal. More generally, the ‘planning landscape’ is described as having changed since the 2009 appeal decision that resulted in a refusal of planning permission.  A larger scheme at Dunsfold Aerodrome (5,000+ homes) was the ‘5th Scenario’ with by far the most support. Notably, a large body of Cranleigh/Ewhurst residents (some 180+) submitted a standard letter reading: “There should be no housing development on green field sites, ie Green Belt or Countryside beyond the Green Belt, within the Parish boundaries of Cranleigh, Ewhurst, Alfold or Shamley Green & Wonersh. Hence, for all options, all of the homes proposed for green field sites in these Parishes should instead be added to the number for housing development at Dunsfold Aerodrome.”  The other 5th scenario with considerable support was one involving more equitable distribution of development amongst the main towns, i.e. distribution in-line with the existing settlement hierarchy.  Other notable 5th scenario suggestions made included - o Consider a smaller scheme - i.e. a few hundred homes - at Dunsfold Aerodrome, including on the basis that this would enable continued aviation and certain other employment uses on site. o Focus at Milford given good rail and road links (and there was similarly some suggestion of opportunities to the west of Witley). o Focus growth at Wrecclesham alongside development of a new bypass road.

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Steps taken in 2015 / early 2016

6.2.27 Subsequent to the 2014 consultation, the decision was taken to give consideration to amended scenarios. This decision reflected:  The view, as expressed through consultation, that there is potentially merit to a scenario whereby greenfield development is distributed more or less evenly between settlements, in- line with settlement size / position in the settlement hierarchy / connectivity, rather than with a bias (‘weighting’) to those settlements with least Green Belt and landscape constraint (i.e. the view expressed was that such a scenario cannot be dismissed as ‘unreasonable’).  The West Surrey SHMA 2015, which concluded an Objectively Assessed Need (OAN) figure of 519 dwellings per annum (dpa), i.e. a figure higher than that used as the basis for preparing the 2014 scenarios. Box 6.4 presents a summary.  Updated and refined understanding of site options, as developed on the basis of ongoing work by the Council through the Land Availability Assessment (LAA) work-stream.

6.2.28 Ultimately, six alternative spatial strategies were ‘sketched out’ that related closely to the alternatives appraised / consulted-on in 2014. As per the 2014 alternatives, the key variable was the quantum of housing at Dunsfold Aerodrome and conversely the quantum at the existing settlements. Unlike the 2014 alternatives, however, another variable was the broad distribution of ‘non-Dunsfold Aerodrome’ housing. The alternatives were:  Scenario 1 - 519 dpa; nil at Dunsfold Aerodrome; weighted distribution  Scenario 1a - 519 dpa; nil at Dunsfold Aerodrome; less-weighted distribution  Scenario 2 - 519 dpa; 1,800 at Dunsfold Aerodrome; weighted distribution  Scenario 2a - 519 dpa; 1,800 at Dunsfold Aerodrome; less-weighted distribution  Scenario 3 - 519 dpa; 2,600 at Dunsfold Aerodrome; weighted distribution  Scenario 4 - 541 dpa; 3,400 at D Dunsfold Aerodrome; weighted distribution.

[To reiterate, ‘weighted’ is shorthand for focusing development at Farnham and Cranleigh, as opposed to distributing development in-line with the settlement hierarchy.]

6.2.29 The alternatives were discussed at a series of meetings between Council Officers and AECOM; however, there was no formal written output at this stage. Notable steps were taken in November and January 2016, when the Waverley Executive (a group of Elected Councillors tasked with supporting development of the Local Plan) were briefed on progress with the SA, and, in particular, were introduced to the amended scenarios. The Executive had the opportunity to discuss the merits of the scenarios, guided by Officers (who in turn had been liaising with AECOM). Headline messages were -  The more extreme (‘book-end’) scenarios are likely to involve negative impacts that are challenging to mitigate; hence, the key choice arguably relates to the ‘middling’ scenarios (2a, 2b and 3).  Option 2a - i.e. an option that would involve something of a departure from the 2014 strategy (see discussion at 6.2.24, above)26 of weighting greenfield development towards Farnham and Cranleigh - has some merit, but performs poorly in respect of Green Belt and AONB objectives.

26 To reiterate, all four alternative scenarios consulted on and appraised in 2014 involved a weighting of growth towards Farnham and Cranleigh / away from Godalming and Haslemere.

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Box 6.4: Summary of the West Surrey SHMA 2015 The West Surrey Strategic Housing Market Assessment (SHMA), prepared by GL Hearn, was published in September 2015, thereby superseding the previous version of 2014. The study sets out to establish Objectively Assessed Housing Needs (OAN) at the functional scale of the West Surrey Housing Market Area (HMA), but is also able to establish OAN for each of the three component authorities. The SHMA goes through a number of considerations in turn, before arriving at a final OAN figure (for the HMA as a whole, and each component authority). In doing so, it applies the methodology that is prescribed by Government’s Planning Practice Guidance. The starting point is the latest official ONS population and Government household projections, which are based on past trends and particularly influenced by the balance of people moving in and out of an area (migration) and by household formation rates (e.g. a household forms when young people move out of the family home). Within the SHMA, these matters are considered within Chapter 4 ‘Demographic Projections’, with a series of sensitivity tests applied (e.g. giving consideration to whether ONS migration rates should be adjusted upwards to better reflect likely future rates of migration out of London) before the conclusion is reached that demographic need in Waverley is 493 dwellings per annum (dpa). The next step is to consider whether the demographic need figure (493 dpa) should be ‘uplifted’ in order to support expected economic growth based on past trends and/ or forecasts for future economic performance. This is dealt with in Chapter 5 of the SHMA, with the conclusion reached that, whilst across the HMA there is a need to uplift the demographic needs figure by 6.7%, for Waverley there no need for an economic uplift. This conclusion is based on the assumption that it is not appropriate to plan for a high economic growth scenario in Waverley, given past trends and the established Waverley Economic Strategy (2015). Chapters 6 and 7 of the SHMA then consider whether there is a need for an uplift to address affordable housing needs (recognising that entry level house prices in Waverley are 12.2 times the typical earnings of younger households compared to a ratio of 7.8 nationally) and housing affordability (recognising that prices or rents rising faster than the national/ local average may well indicate particular market undersupply relative to demand). This is a particularly complex calculation (e.g. because as affordable housing need can be influenced by changes in the ownership of existing housing stock and other supply-side factors, not just by new-build development), but ultimately GL Hearn conclude that: “The key impacts of improving affordability would be to improve younger people’s ability to form a household, reducing the numbers of younger people forced to live with parents or in shared accommodation. The impact of this has been modelled by adjusting household formation rates of those aged 25-34, increasing levels of household formation for this age group over time such that it reaches the 2001 levels (in each authority) by 2033… Taking account of these adjusted household formation rates for younger households… need in Waverley is 519 dpa [i.e. an uplift of 26 should be applied to the demographic need figure].”

Objectively assessed housing need figures assigned by the West Surrey SHMA

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6.3 Developing reasonable alternatives in 2016

Introduction

6.3.1 In spring / early summer 2016 it was recognised that the task was to further refine understanding of spatial strategy alternatives (i.e. continue the process of refinement discussed above)27 and ultimately arise at reasonable alternatives for appraisal / consultation.

6.3.2 The task involved giving consideration to ‘top-down’ factors and ‘bottom-up’ factors, before finally ‘pulling things together’ and establishing reasonable alternative spatial strategies.

‘Top-down’ considerations

Quantum

6.3.3 The 2015 SHMA findings (see Box 6.4), which influenced consideration of alternatives in 2015/16, also formed the basis for developing alternatives in 2016. The headline message from the SHMA is that planning to meet objectively assessed needs (OAN) for housing means planning to deliver 519 dpa over the 19 year plan period (9,861 dwellings in total).

6.3.4 The Council is committed to delivering OAN, and indeed the principle of meeting OAN has been established as a plan objective for some time. Whilst Waverley is heavily constrained (environmentally and in infrastructure terms), there are no ‘showstoppers’ and the borough does not stand-out as relatively constrained in the sub-regional context, such that there is justification for considering ‘sub-OAN’ options (i.e. options involving ‘under-delivery’ and thus reliance on neighbouring authorities to meet the shortfall, under the Duty to Cooperate). This conclusion is reached on the basis of Duty to Cooperate discussions, various evidence studies (notably the Strategic Highways Assessment), past SA work (notably spatial strategy alternatives appraisal – see discussion above ) and an understanding of precedents being set elsewhere. The environmental argument for under-supplying is also not persuasive given an assumption that unmet needs would likely have to be met elsewhere within the HMA (i.e. within Guildford, which is heavily constrained; albeit with more established economic growth potential) or elsewhere within the heavily constrained sub-region. Furthermore, it is evidently the case that under-supplying in Waverley would lead to a range of socio-economic problems, given that Woking is already under-supplying within the HMA.28 For these outline reasons29 options that would involve planning for a level of growth below that necessary to meet OAN (519 dpa) were ruled-out as unreasonable.

6.3.5 However, in order to meet OAN there is not a need to provide for precisely 519 dpa through the plan. Rather, in determining the number of homes to provide for through the plan, in order to meet OAN, there is a need to take into account:

A) Since the start of the plan period (2013), 727 new homes have been completed in the borough, and planning permissions are in place to deliver a further 2,579 homes.

B) There has historically been a high rate of high windfall development, and an element of windfall will continue (excluding residential gardens). The assumption is 1,000 homes.30

6.3.6 As such, to deliver OAN there is a need to provide for land to deliver: 519 dpa – (A+B).31

27 National Planning Practice Guidance is clear that understanding of alternatives should be ‘refined’ over time through the SA process. 28 Woking’s adopted Core Strategy makes provision for 4,964 dwellings over the period 2010-2027, equating to 292 dpa, which is considerably less than the OAN figure assigned to Woking by the West Surrey SHMA. 29 To reiterate, in-line with Regulations, there is a need to give ‘an outline of the reasons’ when introducing the reasonable alternatives. 30 It is considered appropriate, by the Council, to assume 1,000 homes on windfall sites, despite windfall delivery historically having been higher than this. Now that there is an up to date LAA, a lot less windfall is expected. 31 There is also a need to consider the possibility of providing for a quantum of homes over and above ‘OAN’ as a contingency for sites not delivering as anticipated (i.e. there is a need to consider the possibility of planning for OAN by providing for OAN plus a buffer).

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6.3.7 However, delivering a quantum of growth to meet the borough’s OAN is not the only option. There is also the need to consider the possibility of delivering a higher quantum in order to meet unmet needs arising from elsewhere within the HMA, and therefore ensure that there is not an under-supply of housing at the HMA-scale. Waverley Borough has not been formally asked by either of the two other authorities within the HMA to meet unmet needs arising from within their areas; however, it is apparent that there is a likelihood of unmet needs arising from Woking of 225 dpa over the period 2013/14 – 2026/27 or 3,150 dwellings.32 Meeting all of this unmet need through the Waverley Local Plan is ‘unreasonable’ as an option (given numerous factors, including the fact that a rate of delivery much higher than past rates would be required, and it is reasonable that Guildford should also take a share given its geographical location adjacent to Woking and its status as an economic centre); however, the option of meeting a significant proportion of Woking’s unmet need cannot be ruled-out, and hence was identified as a reasonable option, for the purposes of developing spatial strategy alternatives.

Distribution

6.3.8 In spring / early summer 2016 it remained the case (i.e. the situation was unchanged from 2015, see discussion above) that there were two broad distribution options ‘on the table’, in respect of greenfield sites:33

1) Distribute greenfield sites in-line with Green Belt constraint (as established by the Green Belt Review) and strategic landscape constraint (notably the AONB), which in practice means distributing with a weighting towards Farnham and Cranleigh

2) Distribute greenfield sites with less importance placed on Green Belt and landscape constraint, i.e. more in-line with the settlement hierarchy (which means considering Godalming and Haslemere on a par with Farnham and Cranleigh) and transport connectivity (which brings Milford and Witley into contention, as villages that are in the second tier of the settlement hierarchy but notably well connected).

6.3.9 The other ‘strategic’ factor (albeit it might also be described as ‘bottom-up’) related to Dunsfold Aerodrome. Whilst four options (nil growth, 1,800 homes, 2,600 homes, 3,400 homes) were understood to be ‘on the table’ in 2014/15, by spring/summer 2016 it was recognised that 3,400 home option could be ruled-out as ‘unreasonable’, on the basis of deliverability and sustainability concerns. Whilst a 3,400 home scheme at Dunsfold Aerodrome would reduce the need to develop greenfield sites, by 2016 Land Availability Assessment (LAA) work had served to identify a range of suitable greenfield sites, whilst at the same time a large scheme at Dunsfold Aerodrome was understood to have certain significant draw-backs (notably, there would be a high proportion of housing in the east of the borough, distant from where housing needs are greatest; and there would be pressure on the local highway network, for the example the A281). The option of nil growth was also identified as arguably ‘unreasonable’, but on balance it was considered appropriate to retain this ‘in the mix’ given the site’s relatively isolated location and the ongoing nature of work to examine infrastructure and highways impacts.

‘Bottom-up’ considerations

6.3.10 A hierarchy of potential growth locations exists within Waverley Borough, with the built up areas of the four main settlements at the top of the hierarchy as locations generally suited to growth, and greenfield land around villages at the bottom of the hierarchy.

32 The SHMA calculates Woking’s OAN to be 517 dpa, from a base date of 2013/14; however, the adopted Core Strategy makes provision for 292 dpa over the period 2012-2027. As such, there is a shortfall of 225 dpa (517 – 292) over 2013/14 – 2026/27. 33 The approach to brownfield development within settlements has always been understood to be less of a strategic (‘top down’) issue.

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6.3.11 The need to distribute growth in a sequential fashion, in-line with the established hierarchy, is an important consideration when examining the ‘reasonableness’ of a given distribution option. However, there are also other considerations. Notably, there is a need to take account of the availability and ‘suitability’ of sites in isolation, as established through the Land Availability Assessment (LAA).

6.3.12 With these points in mind, the following bullet points consider each of the places / growth locations in the hierarchy in turn, examining whether the approach to growth at each should be taken as a ‘given’ or a ‘variable’ for the purpose of developing spatial strategy alternatives.

Built-up areas / previously developed sites

6.3.13 In-line with the sequential approach, there is a need to maximise growth within the built up areas of the main settlements (Farnham, Godalming, Haslemere and Cranleigh), which means providing for 690 dwellings, i.e. the capacity of all suitable LAA sites. Whilst there are additional sites (i.e. ‘unsuitable’ LAA sites) that could conceivably be supported in order to deliver a higher number over the plan period, there is little to suggest the potential to do so sustainably (e.g. without loss of occupied employment land),34 despite the fact that any decision to not allocate increases pressure on locations lower down the hierarchy. As such, the figure of 690 dwellings was identified as a given for the purposes of developing spatial strategy alternatives.

6.3.14 In-line with the sequential approach, the next location at which to maximise growth – i.e. deliver as much of the residual housing as possible - is within the built up areas of other settlements, which means providing for 20 dwellings, i.e. the capacity of all suitable LAA sites. Whilst there are additional sites (i.e. ‘unsuitable’ LAA sites) that could conceivably be supported in order to deliver a higher number over the plan period, there is little to suggest the potential to do so sustainably,35 despite the fact that any decision to not allocate increases pressure on locations lower down the hierarchy. As such, the figure of 20 dwellings was identified as a given for the purposes of developing spatial strategy alternatives.

6.3.15 In-line with the sequential approach, the next location at which to maximise growth – i.e. deliver as much of the residual housing as possible – is at previously developed sites outside of settlements. The LAA identifies ‘suitable’ sites to deliver 2,737 dwellings; however, there are question-marks regarding the suitability of the largest of these sites - namely Dunsfold Aerodrome (DA). As has already been discussed above (para 6.3.9), there remains a need to consider the possibility of the site being redeveloped at a lower density (than that assumed to be suitable through the LAA) and indeed the possibility of the site not being redeveloped at all. As such, the approach to growth at previously developed sites outside of settlements was identified as a variable, for the purposes of developing spatial strategy alternatives, with the options being: 137 (with 0 homes at DA); 1,937 (with 1,800 homes at DA); and 2,737 (with 2,600 homes at DA).

Greenfield sites

6.3.16 In-line with the sequential approach, the next location at which to maximise growth – i.e. deliver as much of the residual housing as possible – is at greenfield sites around main settlements. Each of the main settlements is considered in turn below, in size order, with discussion again aiming to conclude whether the approach to growth should be taken as a ‘given’ or a ‘variable’ for the purpose of developing spatial strategy alternatives.

34 The vast majority of sites listed within as available but ‘unsuitable’ are found to be unsuitable due to the loss of employment land that would result from redevelopment for housing. In two instances the reason is “loss of a community facility”; in one instance the reason is “impact on character”; and in another instance the reason is “loss of land allocated for railways station parking”. 35 The LAA lists only two sites within villages as available but ‘unsuitable’. One (in Witley) is unsuitable on account of its use as a community facility; and the other (at Bramley) is occupied employment land.

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 Farnham is the largest settlement, having a population of approximately 39,000. Farnham is relatively unconstrained by the national landscape designations and the Metropolitan Green Belt; however, it is constrained in other respects, e.g. given proximity to the Thames Basin Heaths Special Protection Area (SPA), a high quality historic core, valued open spaces and low density residential areas with a distinct character. The LAA identifies ‘suitable’ greenfield sites to deliver 900 dwellings, focused to the north and west of the town; however, there is feasibly the potential to support a higher degree of growth (i.e. it could be appropriate to support growth at unsuitable LAA sites, on the basis of strategic considerations).36 As such, the approach to greenfield development at Farnham was identified as a variable, for the purposes of developing spatial strategy alternatives.  Godalming has a population of approximately 22,000. The size and range of services is less than Farnham, and it is significantly influenced by Guildford, which is approximately 10km away via good road and rail links. As the second largest settlement, there are arguments in favour of growth; however, the town is heavily constrained by the Metropolitan Green Belt, its geography (the town straddles the River Wey, and is virtually surrounded by wooded hillsides) and its historic character (with five conservation areas in and around the town). The LAA identifies ‘suitable’ greenfield sites to deliver 50 dwellings, primarily through a 35 home extension to the north (Farncombe); and it is difficult to foresee additional opportunity. In-line with the findings of the Green Belt Review, the only option is Land between Halfway and Eashing Lane (ID851; c.100 homes); however, the deliverability of this site - which spans the boundary with Guildford Borough - is uncertain. As such, there is an argument to suggest that the figure of 50 dwellings should be a given for the purposes of developing spatial strategy alternatives. However, there is a counter argument to suggest that the approach to growth should be taken as a variable for the purposes of developing spatial strategy alternatives (i.e. there is a need to test options that would involve providing for more than 50 homes on greenfield sites), simply on the basis of Godalming’s position in the settlement hierarchy. The question of whether the approach to growth at Godalming should be a given or a variable, for the purposes of developing spatial strategy alternatives, is returned to below (under the ‘establishing reasonable alternatives’ subheading).  Haslemere, which has a population of approximately 17,000, lies in the rural southwest corner of the borough, but like Godalming has good road and rail links. Haslemere is less constrained than Godalming in terms of the Metropolitan Green Belt, but is constrained by the nationally important Surrey Hills AONB. The LAA identifies ‘suitable’ greenfield sites to deliver c.70 dwellings, comprising an extension to the south, a smaller extension to the north and nine homes at nearby Hindhead; however, there is feasibly the potential to support a limited amount of further growth (i.e. it could be appropriate to support growth at unsuitable LAA sites, on the basis of strategic considerations).37 There could feasibly be the potential for further growth still - i.e. high growth - however, sites that would come into contention perform notably poorly given landscape / Green Belt constraint (see further discussion below, under ‘establishing reasonable alternatives’). As such, the approach to greenfield development at Haslemere was identified as a variable, for the purposes of developing spatial strategy alternatives.

36 A stand-out site that might feasibly be supported is Land South of Badshot Lea (ID381; 650 homes), to the north of the town, which offers the opportunity to deliver a strategic-scale scheme. The other large site that is judged unsuitable by the LAA, but which it is assumed (for the purposes of developing alternatives) could feasibly come into contention is Waverley Lane (ID332; 160 homes), to the east of the town. Also, there is a cluster of smaller sites in the Badshot Lea area that it is assumed (for the purposes of developing alternatives) could feasibly come into contention. Sites in this cluster include: East of Badshot Lea (ID27; 30 homes); and Land East of Low Lane (ID615; 50 homes) and Land at Stockwood Way, Hale (ID343; 20 homes). 37 It is assumed, for the purposes of developing alternatives, that there is feasibly potential for c.50 further homes across two sites (Land at Sturt Road, ID667; and Land east of Longdene House, ID563) to the south of the town, within the AONB.

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 Cranleigh has a population of approximately 11,000. Located in the rural southeast of the borough, it has a good range of services for a settlement of its size, with a large green common area extending into the centre and a shopping area that is notable for being attractive and pedestrian friendly. The LAA identifies ‘suitable’ greenfield sites to deliver c.500 dwellings, focused to the west and southwest; however, there is feasibly the potential to support a higher degree of growth (i.e. it could be appropriate to support growth at unsuitable LAA sites, on the basis of strategic considerations).38 As such, the approach to greenfield development at Cranleigh was identified as a variable, for the purposes of developing spatial strategy alternatives.

6.3.17 In-line with the sequential approach, the final location at which to deliver growth is at greenfield sites around other settlements (i.e. settlements other than the four main settlements listed above). ‘Other settlements’ are considered in turn below with discussion again aiming to conclude whether the approach to growth should be taken as a ‘given’ or a ‘variable’ for the purpose of developing spatial strategy alternatives.  Milford and Witley are adjacent villages, along the road/rail corridor to the south of Godalming that stand-out as potentially suitable for growth on the basis of transport connections, albeit recognising Green Belt and AONB constraints. The LAA identifies ‘suitable’ greenfield sites to deliver 430 dwellings, focused to the northern (Milford) part of the settlement area; however, there is an argument to suggest that not all of these sites should be developed, recognising the position of Milford and Witley in the settlement hierarchy. As such, the approach to greenfield development at Milford and Witley was identified as a variable, for the purposes of developing spatial strategy alternatives (i.e. there is the option of supporting development at all suitable LAA sites, but equally there is the option of supporting development at only a proportion of the suitable LAA sites).  Bramley, Chiddingfold and Elstead are the other larger villages, at which the LAA identifies ‘suitable’ greenfield sites with a capacity of 5 dwellings, 92 dwellings and 125 dwellings respectively, resulting in a total figure of 222 dwellings. No other sites stand-out as potentially suitable, given the Green Belt Review findings (all these villages being within the Green Belt), and there is little in the way of strategic argument for higher growth at these villages. As such, a figure of 222 dwellings across these three villages was identified as a given for the purposes of developing spatial strategy alternatives.  Alfold is a smaller village, in the southeast of the borough, 3-4km from Cranleigh and within 1km of Dunsfold Aerodrome, which stands-out somewhat from the other smaller villages in that there are relatively few environmental constraints, and a large number of sites are promoted. The LAA identifies seven sites as ‘suitable’, with a total capacity of 180 dwellings; however, there is a strong argument to suggest that not all of these sites should be developed due to its very limited level of facilities. There is a need to consider the in- combination effects of developing several sites, and also recognise the likelihood of a strategic scale scheme at nearby Dunsfold Aerodrome. The Council is of the firm view that 100 homes is an appropriate scale of growth at Alfold, and hence this figure was identified as a given for the purposes of developing strategy alternatives.  Churt, Dunsfold, Ewhurst, Frensham, Tilford, Wonersh and Shamley Green are the other smaller villages, at which the LAA identifies ‘suitable’ greenfield sites with a total capacity of 137 dwellings in total (82 dwellings at Dunsfold and 55 dwellings at Ewhurst). No other sites are potentially suitable (and indeed there are no additional sites available at several of these villages), and there is little in the way of strategic argument for higher growth at these villages. As such, a figure of 137 dwellings across these three villages was identified as a given for the purposes of developing spatial strategy alternatives.

38 Firstly, there are two sites - Bowles Farm, ID688 (100 dwellings); and Highfold, ID712 (20 dwellings) - to the east of the settlement that it is assumed, for the purposes of developing alternatives, could feasibly come into contention (despite being constrained by local landscape considerations and distance to the village centre). Secondly, there is a cluster of sites to the northwest - Ruffolds Farm, ID296 (150 dwellings); Land adjacent to Ruffolds Farm; ID620 (180 dwellings); Land between Ruffolds Farm and Guildford Road, ID787 (100 dwellings); Land east of Guildford Road, ID905 (40 dwellings) - that it is assumed, for the purposes of developing alternatives, could feasibly come into contention, albeit this land is recommended as an addition to the Green Belt by the Green Belt Review.

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Establish the reasonable alternatives

6.3.18 Having given consideration to the total quantum of land that needs to be allocated and the settlement specific givens / variables, there was a need to pull this information together in order to establish a series of spatial strategy alternatives.

The starting point

6.3.19 The starting point is an option that would involve supporting all of the sites identified as ‘suitable’ by the LAA at all settlements other than Milford/Witley and Alfold, and allocating Dunsfold Aerodrome for 2,600 homes, thereby ensuring that the plan provides for OAN (given completions, commitments and windfalls of 4,300 homes). This was understood to be the Council’s preferred option, and is presented as Option 4 within Table 6.1 below.

6.3.20 Having established this starting point, there was a need to consider options that would involve fewer or nil homes at Dunsfold Aerodrome, or more growth in total through support for additional greenfield sites.

Options involving fewer homes at Dunsfold Aerodrome or a higher overall growth strategy

6.3.21 A range of scenarios can be envisaged whereby land for 800 additional homes is found at greenfield sites thereby either enabling the Council to deliver a smaller (1,800 home) scheme at Dunsfold Aerodrome, or provide for a level of growth 800 homes above OAN. However, for the purposes of developing spatial strategy alternatives two scenarios are highlighted:

1) The 800 homes are provided for at sites where there is no conflict with Green Belt Review recommendations and no impact to the AONB. This would involve supporting sites at Farnham and Cranleigh, given their position in the settlement hierarchy and given constraints at Godalming, Haslemere and Milford / Witley. Specifically, it is fair to assume that this option would involve supporting land close to Badshot Lea (650 homes),39 with the remainder (150 homes) provided for at Cranleigh.40

2) The 800 homes are provided for at sites in-line with the settlement hierarchy / degree of transport connectivity as far as possible, whilst recognising the need to plan in-line with Green Belt Review recommendations and avoid sites that otherwise perform very poorly. This would involve supporting all of the suitable LAA sites at Milford and unsuitable LAA sites (as listed within footnotes above) at Haslemere (c.50 homes to the south), with the shortfall (650 homes) met at Farnham and/or Cranleigh. The shortfall might be met in a variety of ways, but it is fair to assume here a focus at Badshot Lea and north of Cranleigh village centre.41

6.3.22 On this basis, Options 2, 3, 5 and 6 (i.e. two options either side of the Option 4 ‘starting point’) were identified - see Table 6.1.

39 It is assumed, for the purposes of developing alternatives, that a strategic scale scheme of c.650 homes would be delivered at Land South of Badshot Lea. 40 It is assumed, for the purposes of developing alternatives, that there would be a scheme to the north of Cranleigh village centre. A number of sites are promoted, with the Ruffolds Farm site standing out as relatively well related to the existing village edge, and having a capacity of 150 homes. 41 It is assumed, for the purposes of developing alternatives, that a strategic-scale scheme at Land south of Badshot Lea would feature. This site could potentially meet the entire shortfall (650 homes), but under this scenario it is fair to assume a more modest scheme of 500 homes, with the shortfall (650 - 500 = 150 homes) met to the north of Cranleigh village centre (see footnote above).

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Options involving nil homes at Dunsfold Aerodrome or a much higher overall growth strategy

6.3.23 Only one scenario can be envisaged whereby land for 2,600 additional homes is found at greenfield locations, thereby enabling the Council to either deliver nil growth at Dunsfold Aerodrome, or provide for a level of growth 2,600 homes above OAN. This scenario would involve supporting all of the suitable LAA sites at Milford; all of the unsuitable sites referenced in the footnotes to paras 6.3.16 and 6.3.17 as ‘feasibly coming into contention’ under a higher growth scenarios, which have a total capacity of c.1,550; and other unsuitable sites to meet the shortfall (c.950 homes).

6.3.24 It is fair to assume that this 950 home shortfall would be met primarily at Godalming and Haslemere, at sites ruled-out by the LAA on the basis of Green Belt and/or strategic landscape constraints, with the burden shared more-or-less evenly. At Godalming, this would mean 500 homes delivered at Green Belt sites to the west and south of the town;42 whilst at Haslemere this would mean 450 homes (a slightly lower figure than Godalming)43 within the Green Belt / AONB to the north and within the AONB to the west.44

6.3.25 On this basis, Options 1 and 7 (i.e. the two ‘bookend’ options within Table 6.1) were identified.

The reasonable alternatives

6.3.26 The discussion above lead to the identification of seven alternatives; however, as a final step there was a need to ‘double-check’ the alternatives, to ensure their ‘reasonableness’ - see Table 6.1.

42 Sites that it is assumed - for the purposes of developing alternatives - would come into contention are: Land at Busbridge, south of Chestnut Way (ID346; 660 homes); Land at Franklyn Road (ID443; 119 homes); Land South of Brighton Road (ID728; 100 homes); Land between Halfway and Eashing Lane (ID851; c.100 homes); and Heath Farm, Heath Lane Busbridge/Godalming (ID902; c.150 homes). 43 There would likely be a need for growth to the west of Haslemere, where the sites available perform notably poorly; hence any opportunity to minimise growth here should be taken. 44 Sites that it is assumed - for the purposes of developing alternatives - would come into contention are: Land adjacent Weydown Hatch, Weydown Road (ID351; 33 homes); Land at Woolmer Hill, Woolmer Hill Road (ID352; 336 homes) and Kingfisher Farm, Sandy Lane (ID 628; 100 homes)

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Table 6.1: Checking ‘reasonableness’ All suitable LAA Unsuitable LAA sites Dunsfold A reasonable Option Quantum sites at Milford / Aerodrome option? Witley? How many? Distribution? Farnham - 900; All feasible sites, inc. sites Godalming - 500; 1 OAN 0 Yes 2,500 that are heavily constrained Haslemere - 500; (inc. by GB and AONB) Cranleigh - 600

GB and landscape Farnham - 650; 2 OAN 1,800 No 800 constraints fully applied Cranleigh - 150

Farnham - 500; GB and landscape 3 OAN 1,800 Yes 700 Haslemere - 50; constraints less fully applied Cranleigh - 150 Yes

4 OAN 2,600 No - -

5 OAN plus 800 2,600 Yes 700 As per (3)

6 OAN plus 800 2,600 No 800 As per (2)

7 OAN plus 2,600 2,600 Yes 2,500 As per (1) No

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6.3.27 Table 6.1 highlights Option 7 as unreasonable. This is on the basis that it would involve Waverley Borough Council providing for 83% of the HMA’s unmet housing needs (assuming that none of the sites to deliver the 2,600 homes would be needed to meet Waverley’s OAN due to allocated sites failing to deliver as anticipated). It is seemingly unreasonable for Waverley to provide for 83% of Woking’s unmet need, recognising that Guildford is as suited, or better suited (recognising its geographical location adjacent to Woking, where the unmet needs arises from; and also recognising economic growth opportunities).

6.3.28 As such, the decision was taken to adjust Option 7. Specifically, rather than providing for 2,600 homes above OAN, the decision was taken to modify Option 7 such that it would involve providing for 2,200 homes above OAN, or 70% of Woking’s unmet need (assuming that none of the sites to deliver the 2,200 homes would be needed to meet Waverley’s OAN).

6.3.29 The reasonable alternatives are presented below in Table 6.2 and the subsequent Maps.45

6.3.30 These were determined to be the ‘reasonable’ alternatives in that their appraisal would enable and facilitate discussion of numerous important issues/opportunities. Whilst it was recognised that there are other options that could potentially feature, there is a need to limit the number of alternatives under consideration, with a view to facilitating engagement. Box 6.1 considers other (‘unreasonable’) spatial strategy options. Box 6.1: Unreasonable spatial strategy options In order to gain an understanding of the rationale / reasoning behind the seven spatial strategy alternatives defined as ‘the reasonable alternatives’ there is a need to read the chapter above as a whole. Taken as a whole, this chapter presents ‘an outline of the reasons for selecting the alternatives dealt with’. However, it is also worthwhile giving explicit consideration here to some other options considered, but ultimately discounted (as ‘unreasonable’):  Any option involving providing for a level of growth below the OAN figure of 519 dpa over the 19 year plan period (9,861 dwellings in total) - see further discussion at 6.3.4 above.  Any option involving lower growth at the existing settlements than the quantum of growth assumed under Option 4. There is no basis to question the assumption, as reflected in Option 4, that all site found to be suitable through the LAA should be provided for through the plan except at Milford/Witley and Alfold.  Any option involving 3,400 at Dunsfold Aerodrome is deemed to be unreasonable, as discussed in paragraph 6.3.9 above. Whilst a 3,400 home scheme at Dunsfold Aerodrome could reduce the need to develop greenfield sites, a large scheme at Dunsfold Aerodrome is not considered to be deliverable within the plan period and would have certain significant draw-backs (notably, there would be a high proportion of housing in the east of the borough, distant from where housing needs are greatest; and there would be pressure on the local highway network, for the example the A281).  Any option involving higher growth at the existing settlements than the quantum of growth assumed under Option 1. It is already assumed, under Option 1, that 2,500 homes will be brought forward at sites identified as ‘unsuitable’ by the LAA (plus 100 homes would be delivered at Milford over-and-above the quantum that the Council believes is appropriate), and any additional growth would likely lead to unacceptable negative effects at the scale of existing settlements, and at the district / sub-regional scale (e.g. there would be risk of severe congestion on certain transport routes).  Any option involving higher growth than option 7, as: A) this could only be achieved by delivering unreasonably high growth at existing settlements and/or relying on a quantum of growth at Dunsfold Aerodrome that is not known to be deliverable; and B) it would be unreasonable to test options that would meet all (or nearly all) of Woking’s unmet needs (given that Guildford Borough is as well placed, or better placed, than Waverley to meet Woking’s unmet needs).

45 The maps are limited in their accuracy / indicative. Non-LAA sites are not shown specifically, but rather the broad direction of growth is indicated; and the quantum of growth at each location is presented with limited accuracy, e.g. the quantum of growth at Milford LAA sites is depicted as a constant across the alternatives (when in fact it is a variable).

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Table 6.2: The reasonable spatial strategy alternatives - N.B. Greyed-out cells show the ‘constants’

Option 3 Option 5 Option 1 Option 7 OAN; OAN + 800; Option 6 OAN; Option 2 OAN + 2,200; 1,800 at DA; 2,600 at DA; OAN + 800; nil at DA; OAN; 2,600 at DA; all LAA sites at Option 4 all LAA sites at 2,600 at DA; all LAA sites at 1,800 at DA; all LAA sites at Milford/Witley; Milford/Witley; 800 at 'non-LAA' Milford/Witley; 800 at 'non-LAA' OAN; Milford/Witley; 700 at 'non-LAA' 700 at 'non-LAA' sites with GB and 2,500 at 'non-LAA' sites with GB and 2,600 at DA 2,100 at 'non-LAA' sites with GB and sites with GB and landscape sites including sites AONB constraints sites including sites landscape landscape constraints fully constrained by GB fully applied constrained by GB constraints less fully constraints less fully applied and AONB and AONB applied applied LAA Non-LAA LAA Non-LAA LAA Non-LAA LAA Non-LAA LAA Non-LAA LAA Non-LAA LAA Non-LAA

Farnham 900 900 900 650 900 500 900 0 900 500 900 650 900 800 Godalming 50 500 50 0 50 0 50 0 50 0 50 0 50 400 Haslemere 70 500 70 0 70 50 70 0 70 50 70 0 70 400 Cranleigh 500 600 500 150 500 150 500 0 500 150 500 150 500 500 Milford/Witley 420 0 320 0 420 0 320 0 420 0 320 0 420 0 Other large villages 320 0 320 0 320 0 320 0 320 0 320 0 320 0 Small villages 140 0 140 0 140 0 140 0 140 0 140 0 140 0 Dunsfold Aerodrome 0 1800 1800 2600 2600 2600 2600 Completions/ permissions/ 46 5000 5000 5000 5000 5000 5000 5000 windfall/ urban LAA sites Total new homes over the 9,900 9,900 9,900 9,900 plan period 10,700 10,700 12,100

“OAN” = Objectively Assessed Need; “DA” = Dunsfold Aerodrome; “GB” = Green Belt; “AONB” = Area of Outstanding Natural Beauty; “LAA” sites are those identified as suitable by the Land Availability Assessment. Conversely, “Non-LAA” sites are those identified as unsuitable by the Land Availability Assessment.

46 Completions/permissions are distributed as follows: Farnham 953; Godalming 786; Haslemere 360; Cranleigh 820; Milford/Witley 42; Other large villages 100; Small villages 245. Urban LAA sites are distributed as follows: Farnham 198; Godalming160; Haslemere 210; Cranleigh 118; Milford/Witley 22.

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Option 1 - OAN; nil at DA; all LAA sites at Milford/Witley; 2,500 at 'non-LAA' sites including sites constrained by GB and AONB

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Option 2 - OAN; 1,800 at DA; 800 at 'non-LAA' sites with GB and AONB constraints fully applied

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Option 3 - OAN; 1,800 at DA; all LAA sites at Milford/Witley; 700 at 'non-LAA' sites with GB and landscape constraints less fully applied

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Option 4 - OAN; 2,600 at DA

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Option 5 - OAN + 800; 2,600 at DA; all LAA sites at Milford/Witley; 700 at 'non-LAA' sites with GB and landscape constraints less fully applied

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Option 6 - OAN + 800; 2,600 at DA; 800 at 'non-LAA' sites with GB and landscape constraints fully applied

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Option 7 - OAN + 2,200; 2,600 at DA; all LAA sites at Milford/Witley; 2,100 at 'non-LAA' sites including sites constrained by GB and AONB

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7 APPRAISING REASONABLE ALTERNATIVES

7.1 Introduction

7.1.1 The aim of this chapter is to present summary appraisal findings in relation to the reasonable alternatives introduced above. Detailed appraisal findings are presented in Appendix V.

7.2 Summary alternatives appraisal findings

7.2.1 Table 7.1 presents summary appraisal findings in relation to the seven alternatives introduced above. Detailed appraisal methodology is explained in Appendix V, but in summary:

Within each row (i.e. for each of the topics that comprise the SA framework) the columns to the right hand side seek to both categorise the performance of each option in terms of ‘significant effects’ (using red / green) and also rank the alternatives in relative order of performance. Also, ‘ = ’ is used to denote instances where the alternatives perform on a par (i.e. it not possible to differentiate between them).

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Table 7.1: Summary spatial strategy alternatives appraisal findings

Summary findings and conclusions

Categorisation and rank

Option 1 Option 2 Option 3 Option 4 Option 5 Option 6 Option 7 OAN; OAN; OAN; OAN; OAN + 800; OAN + 800; OAN + 2,200; nil at DA; 1,800 at DA; 1,800 at DA; 2,600 at DA 2,600 at DA; 2,600 at DA; 2,600 at DA; all Milford LAA 800 at non- all Milford all Milford 800 at non- sites; LAA sites LAA sites; LAA sites; LAA sites all Milford LAA sites; 2,500 at non- 700 at non- 700 at non- LAA sites LAA sites LAA sites 2,100 at non-LAA Topic sites

Biodiversity 7 2 2 2 2 6

Climate change 7 5 6 4 3 2 mitigation

Community and well- 6 2 2 4 4 7 being

Economy 4 4 4 7 2 2

Heritage 6 2 2 4 4 7

Housing 4 6 5 7 2 3

Landscape 7 2 4 4 2 6

Soils 7 4 4 3 2 4

Transport 3 2 4 5 6 7

Water ======

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Summary findings and conclusions

Option 1 Option 2 Option 3 Option 4 Option 5 Option 6 Option 7 OAN; OAN; OAN; OAN; OAN + 800; OAN + 800; OAN + 2,200; nil at DA; 1,800 at DA; 1,800 at DA; 2,600 at DA 2,600 at DA; 2,600 at DA; 2,600 at DA; all Milford LAA 800 at non-LAA all Milford LAA all Milford LAA 800 at non-LAA all Milford LAA sites; sites sites; sites; sites sites; 2,500 at non- 700 at non-LAA 700 at non-LAA 2,100 at non- LAA sites sites sites LAA sites

Summary and conclusions The first point to note is that the ‘bookend’ options (Options 1 and 7) perform poorly in terms of a number of objectives, notably those relating to Biodiversity, Community and wellbeing, Heritage and Landscape. In each case, this is on the basis that Waverley settlements are not well suited (in the sub-regional context) to supporting extensive growth. The second point to note is that Option 4 (2,600 homes at Dunsfold Aerodrome; least growth at settlements) performs well in terms of the same objectives. Maximising development at Dunsfold Aerodrome is supported in terms of these objectives, and in particular in terms of ‘Landscape’. However, there is some uncertainty in respect of ‘Community and wellbeing’ (is the site too isolated?) and ‘Heritage’ (will traffic impact significantly on surrounding historic villages?). There is also an argument that Option 4 is best performing in terms of ‘Economy’; however, on balance it is determined that Options 5 to 7 (which would involve supporting a higher growth quantum) perform better. Whilst Option 4 is in-line with the Waverley Economic Strategy, a higher growth strategy is in-line with the wider objective of delivering housing to maximise employment growth opportunities within the sub-regional Functional Economic Area (FEMA). Option 1 also arguably has merit as there is a need for employee accommodation in close proximity to where the jobs are focused - i.e. at the main settlements and beyond the borough boundaries to the north and west - however, it would be challenging to deliver new employment land in line with Employment Land Review (ELR) targets without a Dunsfold Aerodrome new settlement. Higher growth options are also supported in terms of ‘Housing’, recognising that Woking is set to provide for less than is necessary to meet OAN, thereby leading to unmet housing needs within the HMA. However, all options would result in ‘significant positive effects’ on the basis that Waverley’s OAN target would be met (assuming delivery of sites as planned), and it may be that Woking’s unmet needs can be met by Guildford (and/or an authority outside the HMA). Option 1 also arguably has merit as there is a need for housing in close proximity to where the needs arise - i.e. at main settlements. By contrast, Dunsfold Aerodrome (upon which there would be a particular reliance under Option 4) is relatively isolated, albeit there will be the opportunity to deliver specialist accommodation. Higher growth options are also judged to perform well in terms of ‘Climate change’, simply because there would be a relative focus on larger, ‘strategic-scale’ schemes that would potentially deliver low carbon infrastructure, thereby helping to minimise per capita CO2 emissions (from the built environment). With regards to ‘Transport’, it is difficult to come to a conclusion. One argument is that growth focused at existing settlements should be supported given the potential to travel by non-car modes; however, there is equally a need to minimise worsened traffic at existing hotspots, e.g. in-and-around Farnham. With regards to ‘Water’, nil growth at Dunsfold Aerodrome could necessitate growth in the Badshot Lea area, where flood risk is an issue; whilst growth at Dunsfold Aerodrome leads to some uncertainties in respect of water supply and waste water treatment. As such, it is difficult to differentiate between the alternatives. Finally, having established that the ‘book-end’ options perform poorly in terms of a range of objectives, and that Option 4 equally performs well in terms of a range of objectives, there is a need to consider Options 2, 3, 5 and 6; all of which would involve supporting c.800 homes at greenfield sites, over and above those supported under Option 4. The primary point to make is that Options 3 and 5 - which would involve distributing the 800 homes with less of a focus at Farnham - perform poorly in terms of ‘Landscape’, given the need to support sensitive sites at Milford and Haslemere. However, diverting some growth from Farnham to Milford and Haslemere does have merit from a transport perspective, and would also help to ensure certainty regarding delivery of sufficient Suitable Alternative Natural Greenspace (SANG) at Farnham (to mitigate recreational impacts to the Thames Basin Heaths).

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8 DEVELOPING THE PREFERRED APPROACH

8.1 Introduction

8.1.1 The aim of this Chapter is to present the Council’s response to the alternatives appraisal / the Council’s reasons for developing the preferred approach in-light of alternatives appraisal.

8.2 The Council’s outline reasons

8.2.1 The following text is in the form of a general discussion of the reasoning and justification behind the preferred option, which is Option 4 (“plan for OAN, with a 2,600 home scheme at Dunsfold Aerodrome”). Explicit responses to alternatives appraisal is drawn out in bold. The Local Plan Part 1 sets out the key policies and overall strategy for managing and directing future development in Waverley over the period to 2032. The Plan has reached the stage where it is ready to be published in its pre-submission form. The Plan has its origins in the Core Strategy, which was originally submitted for Examination in 2013, before then being subsequently withdrawn from Examination on recommendation of the Inspector. In the light of the National Planning Policy Framework (NPPF), which had been published in 2012, the Inspector was of the view that the Council should update its evidence on housing need and should cease relying on a housing target that had been derived from the now revoked South East Plan. Although the Core Strategy was withdrawn from Examination, it is not the case that the Council had to start from scratch with a new Plan. The focus of work in developing the new Local Plan has been to update the evidence of housing need and to develop the most appropriate strategy for both the number and distribution of new homes. An extensive evidence base has been developed to support the new Local Plan. Much of this is already complete and published on the Council’s website. One of the key documents is the West Surrey Strategic Housing Market Assessment (SHMA). This sets out the objectively assessed need (OAN) for new homes within each of the local authorities that make up the West Surrey Housing Market Area (HMA) (Guildford, Woking and Waverley). In Waverley’s case the OAN is equivalent to 519 homes per annum. Other key evidence includes the Employment Land Review, the Strategic Flood Risk Assessment, the Land Availability Assessment (LAA), the Green Belt Review (Parts 1 and 2) and various evidence documents relating to transport infrastructure. A key test of the soundness of the Plan will be whether it is consistent with national planning policy. This is mainly set out in the NPPF. A key requirement of the NPPF is that Local Plans should meet the objectively assessed needs, which for Waverley is 519 homes per annum, unless any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in the NPPF taken as a whole; or unless specific policies in the NPPF indicate that development should be restricted. In the light of the above, the expectation is that through their local plans councils should be seeking to meet the identified needs for development in full, unless there are very good reasons for not doing so. In Waverley’s case, therefore, the expectation is that the Council should be meeting its need for new homes (519 a year). Much of the work undertaken on the new plan has been to consider whether there are any reasons why Waverley cannot meet its needs in full. This has meant considering all the key factors that may impact on the Council’s ability to meet its identified needs. These include the implications of some of the European sites such as the Special Protection Areas (SPAs), the land use and landscape constraints such as the Green Belt and the Area of Outstanding Natural beauty (AONB), physical constraints such as flooding and the capacity of infrastructure, including transport, to accommodate development.

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In September/October 2014, the Council consulted on four potential housing scenarios as well as other issues for the emerging Local Plan. At that time, the draft SHMA identified a need for 470 homes a year. Four alternative scenarios were presented for the broad distribution of new homes, each delivering the equivalent of 470 homes a year. One of the scenarios did not have any new housing proposed at Dunsfold Aerodrome, the other three included various levels of growth at Dunsfold Aerodrome (1,800, 2,600 and 3,400). These are the levels of growth promoted by the site owners. The outcomes from that consultation were reported to the Executive in March 2015. The consultation had attracted over 4,000 responses. Based on those who responded to the consultation, there was overwhelming support for the scenario that included the maximum amount of development at Dunsfold Aerodrome. In addition to this main consultation, there have been various other opportunities to liaise with key stakeholders during the development of the Plan. These included meetings with town and parish councils, liaison on emerging neighbourhood plans, discussions with key neighbouring authorities and liaison with key consultees such as Natural England and the Environment Agency. The implication is that the opportunity to deliver a new settlement at Dunsfold Aerodrome should be realised, and unsustainable levels of growth elsewhere in the borough avoided. These are factors that count against Option 1, from the alternatives appraisal above, and also Options 5 - 7 (which would involve delivering above OAN). Whilst the Council recognises that there is an economic and ‘housing need’ argument for higher growth at the existing settlements, and higher growth overall, there is a need to apply the constraints that exist. Understanding of constraints has developed over the course of the plan-making process, and the appraisal of alternatives has served to reinforce this, particularly in respect of biodiversity and landscape constraints. As explained above, Local Plan Part 1 deals with key strategic policies and the allocation of Strategic Sites. A key part of the Plan is the Spatial Strategy. This sets out the broad approach to the location of development. This has been developed taking account of three key factors: 1) The Settlement Hierarchy; 2) The landscape and other physical, policy and ecological constraints; and 3) The potential availability of sites to deliver the strategy The Council’s strategy seeks to avoid development on land of the highest amenity value and to safeguard the Green Belt. It seeks to focus development in/around the main settlements, taking account of the constraints outlined above. It allows for moderate growth in some of the larger villages and lower levels of growth in villages further down the Settlement Hierarchy. It also seeks to maximise the use of suitable brownfield land. In some cases, it has been necessary to balance these considerations. For example, the Dunsfold Aerodrome site is not as well related to existing services and facilities as other potential development locations, but it is a significant brownfield site. The allocation of the Dunsfold Aerodrome site for a new settlement of up to 2,600 homes is a major element of the plan. It is acknowledged that in the 2014 consultation the housing scenario most favoured by those who responded was the one including 3,400 homes at Dunsfold Aerodrome. In considering the role that Dunsfold Aerodrome could make to meeting housing requirements, account has been taken of a number of factors, including the amount of development that can reasonably be delivered in the Plan period. It is also acknowledged that planning permission has previously been turned down on appeal for a new settlement at Dunsfold Aerodrome. However, officers consider that matters have moved on since 2009. National Planning Policy has changed significantly since 2009 with the introduction of the National Planning Policy Framework (NPPF) and the expectation that councils should be planning to meet their identified housing needs in full. This means that the Council is having to consider delivering considerably more new homes than was the case in 2009.

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It is recognised, however, that there are concerns about the impact of a new settlement upon this site on local infrastructure, particularly the road network. On the other hand, this is a significant brownfield site and its development would be supported by on-site services and facilities and off-site improvements to infrastructure. In addition, the NPPF definition of ‘sustainable development’ goes beyond the location of development and incorporates economic, social and environmental considerations. The inclusion of the site as a major allocation in the Plan is still subject to the provision of appropriate infrastructure to mitigate the impact of development, particularly improvements to the road network. Some work has already taken place to assess the impact of growth on the road network, including the consideration of possible mitigation at key locations on the A281. There is also a need to acknowledge the planning application for the development of Dunsfold Aerodrome site with 1,800 homes and related facilities. That application is currently on hold pending the receipt and consideration of additional information to address a range of matters. In particular, additional information in relation to the transport/traffic implications and associated mitigation is awaited. Once received, this information will enable Surrey County Council to reach a conclusion on the transport matters and advise Waverley Borough Council accordingly. Infrastructure concerns, particularly roads/transport have not just been considered in relation to the Dunsfold Aerodrome site. Officers have worked closely with Surrey County Council, the Highway Authority, as well as other infrastructure and service providers, and the Council’s own transport consultants Mott MacDonald, to consider the effects of the strategy, particularly the number and location of homes, on infrastructure in other hotspots around the Borough. In particular, consideration has been given to the impacts around Farnham, where the Borough’s road network is already the most congested. The evidence has shown that there will be some impacts on the network, including in some areas the potential for additional congestion. There are also various mitigation measures that have been considered. The key matter is that, to date, there has been no indication of an issue that is so fundamental in its impact that advice has been given that the number of homes should be reduced (i.e. the Council should plan for below OAN) or the distribution altered (e.g. with less focus at Farnham and Cranleigh).47 The implication is that the opportunity to deliver a new settlement at Dunsfold Aerodrome should be maximised (i.e. through a 2,600 home scheme), and that the broad strategy of weighting growth away from the most environmentally sensitive locations does not lead to major conflict with transport objectives. Whilst the alternatives appraisal highlights that the preferred option (Option 4) is less than ideal from a transport perspective due to Dunsfold Aerodrome’s relatively isolated location (leading to car dependency and a need to travel longer distances by car), the preferred option has some merit in respect of minimising (within the context of needing to deliver OAN) development at the existing settlements and therefore minimising the likelihood of severe traffic congestion. To conclude, the Local Plan Part 1 has reached a major milestone. In essence, Publication is the stage when the Council has finalised what it believes to be a ‘sound’ Plan - namely one that is positive, justified, effective and consistent with national policy - ready for submission. The appraisal of reasonable alternatives presented in Table 7.1 helps to demonstrate the plan’s ‘justification’ in particular, highlighting that whilst non-preferred options may have merits in certain respects, the preferred option on balance represents sustainable development.

47 Some of the transport work is ongoing. For example more work is being undertaken to look at the knock-on effects on the Farnham road network as a result of some of the mitigation measures that have been considered. In addition, there is ongoing work with Highways England, Surrey County Council and Guildford Borough Council to address the potential impact of development in Guildford and Waverley on the A3 through Guildford. There are some very significant sites in Guildford, close to the A3. However, Highways England also needs to assess the cumulative impact on the A3 both from growth in Guildford itself and from development related traffic arising in Waverley. These discussions with Highways England, Guildford Borough Council and Waverley are ongoing.

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PART 2: WHAT ARE SA FINDINGS AT THIS CURRENT STAGE?

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9 INTRODUCTION (TO PART 2)

9.1.1 The aim of this chapter is to present an appraisal of the Draft (‘Proposed Submission’) Plan, as currently published under Regulation 19 of the Local Planning Regulations.

9.2 Methodology

9.2.1 The appraisal identifies and evaluates ‘likely significant effects’ of the plan on the baseline, drawing on the sustainability topics/objectives identified through scoping (see Table 4.1) as a methodological framework. In total, there are ten topics relating to:

 Biodiversity  Landscape  Climate change mitigation  Soils and other natural resources  Community and well-being  Traffic and transportation  Economy  Water, flood risk and other climate change  Heritage and townscape adaptation issues  Housing

9.2.2 Every effort is made to predict effects accurately; however, this is inherently challenging given the high level nature of the policies under consideration, and understanding of the baseline (now and in the future under a ‘no plan’ scenario) that is inevitably limited. Given uncertainties there is a need to make assumptions, e.g. in relation to plan implementation and aspects of the baseline that might be impacted. Assumptions are made cautiously, and explained within the text (with the aim to strike a balance between comprehensiveness and conciseness/ accessibility to the non-specialist). In many instances, given reasonable assumptions, it is not possible to predict ‘significant effects’, but it is nonetheless possible and helpful to comment on merits (or otherwise) of the draft plan in more general terms.

9.2.3 Finally, it is important to note that effects are predicted taking account of the criteria presented within Schedule 1 of the SEA Regulations.48 So, for example, account is taken of the probability, duration, frequency and reversibility of effects as far as possible. Cumulative effects are also considered, i.e. the potential for the draft plan to impact an aspect of the baseline when implemented alongside other plans, programmes and projects. These effect ‘characteristics’ are described within the appraisal as appropriate.

Adding structure to the appraisal

9.2.4 Whilst the aim is essentially to present an appraisal of ‘the plan’ under each of the SA objective headings, it is appropriate to also give stand-alone consideration to elements of the draft plan. As such, within the appraisal narratives below, sub-headings are used to ensure that stand-alone consideration is given to two distinct elements of the draft plan, before the discussion under a third sub-heading concludes on the draft plan as a whole. Specifically, each narrative below is structured using the following headings:  Commentary on the spatial strategy – i.e. Policies 1.2 and 1.3, plus site specific policy, with specific sites referenced using the ‘ID’ number assigned within the LAA;  Commentary on other policies; and  Appraisal of the draft plan as a whole.

9.2.5 Within these narratives, specific policies are referred to only as necessary (i.e. it is not the case that systematic consideration is given to the merits of every plan policy in terms of every sustainability topic/objective).

48 Environmental Assessment of Plans and Programmes Regulations 2004

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10 APPRAISAL OF THE PROPOSED SUBMISSION PLAN

10.1 Introduction

10.1.1 As introduced above, the aim of this chapter is to present an appraisal of the Proposed Submission Plan ‘under’ the SA framework.

10.1.2 The Local Plan Vision and Key Diagram are presented below (Box 10.1 and Figure 10.1), to give a high level overview of the plan. Box 10.1: The Local Plan vision (abridged) The high quality environment of Waverley, its distinctive character and its economic prosperity will have been maintained, whilst accommodating the growth in housing, jobs and other forms of development. Most of the new development will be located in and around the main settlements of Farnham, Godalming, Haslemere and Cranleigh which have the best available access to jobs, services etc. Where needed to deliver the planned amount of new housing, new development will have taken place on the edge of the main settlements and on rural brownfield sites where these could be delivered in a sustainable way. This would include a new settlement of 2,600 homes at the Dunsfold Aerodrome site. An appropriate level of development will have taken place within Waverley’s villages, having had regard to local needs and to the size, character and available services in each village and to constraints. Working in partnership with other service providers, there will be new and improved infrastructure to support the increased population of Waverley, and, where needed, to mitigate the impact of major developments planned outside Waverley. Support will also be given, where necessary, to the retention of existing facilities and the provision of new facilities that provide for the leisure, recreation and cultural needs of the community. The location, type and size of new housing will have taken account of local needs, demography, the size of settlements, transport and the level of services available in the towns and villages. A range of sizes, types and tenures of new housing and accommodation will have been provided, taking account of the needs across the borough as identified in the Council’s Strategic Housing Market Assessment (SHMA), particularly with regard to the accommodation needs of the older population that will have increased significantly. This will include an increase in the proportion and overall stock of subsidised affordable housing, to meet the needs of those who would otherwise not be able to afford their own home. Waverley’s economy will continue to have prospered without compromising the borough’s attractive character and high quality of life. The local economy and the needs of existing and new businesses in Waverley will have been supported through the provision of high quality infrastructure and a range of employment accommodation, including homes that are affordable for key workers. Important employment assets will have been retained and, where necessary, new development will have contributed to the diverse stock of employment premises. The emphasis will be on sustainable economic development, of the right type and in the right place to meet employment needs both within the towns and in the rural areas. The vitality and viability of the main centres of Farnham, Godalming, Haslemere and Cranleigh will have been safeguarded in a way that takes account of their distinctive roles. In local and village centres shops that meet local needs will have been supported. The rich heritage of historic buildings, features and archaeology in Waverley will have been conserved and enhanced. The attractive landscape of Waverley, which contributes to its distinctive character and includes the Surrey Hills Area of Outstanding Natural Beauty, will also have been protected…. New building will have contributed to the creation of sustainable communities, which are safe, attractive and inclusive and where the high quality design of new development makes a positive contribution to the area in which it is located. The unique and diverse character of Waverley’s towns, villages and countryside will be cherished and preserved…. The rich biodiversity of Waverley will have been preserved and where possible enhanced. Particular regard will be had to Special Protection Areas and Special Areas of Conservation…. Waverley will have become more sustainable through measures to combat the effects of climate change and secure reductions in greenhouse gas emissions. This will have been achieved by locating most new buildings in areas that reduce the need to travel and ensuring that through their design and construction, new buildings produce lower carbon emissions. Measures will have been taken to adapt to the effects of climate change, which will include….

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Figure 10.1: The Local Plan Key Diagram

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10.2 Biodiversity

 Protect and enhance biodiversity, including through a focus on ensuring the continued health and functioning of designated protected sites and strategic ecological corridors

Commentary on the spatial strategy

10.2.1 The broad strategy - planning for OAN only, supporting a new settlement at Dunsfold Aerodrome, and focusing greenfield expansion at Farnham and Cranleigh more so than Godalming and Haslemere - performs well from a biodiversity perspective (see discussion of alternative broad strategies in Chapter 7, above). Farnham is notable for being in proximity to the Thames Basin Heaths SPA, which are at risk from recreational pressure; however, there is confidence in the ability to avoid adverse effects through delivery (and management over time) of Suitable Alternative Natural Greenspace (SANG), in-line with the Thames Basin Heaths Avoidance Strategy. This matter has been the focus of a standalone process of Habitats Regulations Assessment (HRA).

10.2.2 Focusing on the nine proposed strategic allocations, points to note are as follows -  Dunsfold Aerodrome (ID 10) - is distant from European designated sites in the west of the borough, but intersects two locally important SNCIs (and others are located in close proximity) and the nationally important Chiddingfold Forest SSSI is located 150m away at its nearest point. Also, it is understood (Transport Assessment, 2015) that improvements to two junctions on the A281 would be necessary if the road is to accommodate any scheme, and such improvements could necessitate road widening into existing common land (which can tend to have some biodiversity value). An ecological assessment of the site recently submitted as part of a planning application for 1,800 homes concluded that habitats within the site are diverse and include some species rich examples, such as unimproved grassland and ancient woodland remnants. The Planning Statement found that: “…the proposed development represents a significant opportunity to substantially enhance the site's ecological value. The [proposal] retains existing woodlands and tree groups, including those along the Wey and Arun Canal corridor but also includes very substantial areas of informal open space, with clear opportunity for significant habitat creation…” As such, it is important to question whether a 2,600 home scheme would lead to reduced ‘opportunity’, and it is noted that the proposed site specific policy does not reference biodiversity issues/opportunities, although there is a requirement to provide: “publicly accessible local and strategic open space, to include a managed Country Park of at least 103 Ha.” It is recommended that key biodiversity issues/opportunities are referenced within the policy, thereby supplementing borough-wide policies NE1 and NE2.  All three strategic allocations within the Farnham area are within the 5km Thames Basin Heaths SPA buffer, and so can only be supported for development where there is confidence regarding SANG delivery to mitigate recreational impacts to the SPA. The site specific policies do not reference ‘bespoke’ SANG delivery (albeit the need to contribute to ‘strategic’ SANG, as well as strategic access management and monitoring (SAMM) is made clear); however, this is appropriate on the basis that most recent evidence indicates the potential for Farnham Park ‘strategic SANG’ to deliver the great majority of SANG capacity needed to support housing growth in and around Farnham. See Chapter 16 of the plan for further explanation.  At Cranleigh the two adjacent strategic allocations are associated with certain sensitivities; however, it is not clear that there is the potential for impacts to designated habitats. The Wey and Arun Canal is close to the western boundary of ‘Land South of Elmbridge Road and the High Street’, and there are areas of Ancient Woodland, hedgerows, ponds and ditches; however, all of these features are set to be afforded protection through site specific policy. In particular, there is reference to: “The provision of a linear park along the public right of way and the provision of an appropriate landscaped buffer including trees and hedgerows particularly on the southern boundary of the site [and] Reservoirs occupying the western part of the site being retained and their amenity and ecological value enhanced.”

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10.2.3 Focusing on non-strategic sites identified as suitable within the LAA (but not proposed as allocations), some points to note are as follows -  Milford - three adjacent sites are supported to the west of the town (c.110 homes in total), with two intersecting the 400m Thursley, Hankley and Frensham Commons (Wealden Heaths Phase I) SPA buffer. However, an extensive area of common land (non- designated) is in even closer proximity and managed as a nature reserve, and therefore would perhaps ‘absorb’ recreational pressure to an extent. Also, it is important to note that at Milford the LAA assesses more sites as suitable than the number of homes assigned to the village through proposed policy ALH1 (Amount and Location of Housing), thus providing a choice of sites in a future neighbourhood plan or in Local Plan Part 2 (i.e. there is no certainty regarding precisely which sites will ultimately be allocated).  Hindhead - Three brownfield sites are supported for redevelopment within the existing built- up area, which is in very close proximity to the Devil’s Punchbowl (Wealden Heaths Phase II) SPA. However, this approach is in-line with past HRA work, which identified that the Hindhead ‘Concept Area’ (designated following tunnelling of the A3) can accommodate up to 100 net additional dwellings without significant adverse effect on the SPA.  Elstead - is the other village in close proximity to an SPA (Wealden Heaths Phase I). Three sites are supported (c.125 homes in total), with one intersecting the 400m buffer and the other two not far outside (i.e. on the southern edge of the village).  Farnham - There will be a focus of growth (c.450 homes over six sites) to the north, in the Badshot Lea / Hale area. This area is in relative proximity to the Thames Basin Heaths SPA, albeit well outside of the 400m buffer.  Dunsfold - the two supported sites (total capacity c.80 homes) are both adjacent to Dunsfold Common, which is a designated SNCI.  Chiddingfold - is seemingly the only settlement - with greenfield sites supported through the LAA - that falls within a Biodiversity Opportunity Area (BOA). Three sites are supported (c.90 homes in total). There is no indication of particular on-site biodiversity value, although the smallest of the three is described as “a small overgrown green space”.  At various locations sites are identified as suitable through the LAA despite notable onsite habitat. Perhaps most notably, ID713 (Garden Style, Wrecclesham Hill, Farnham; 65 homes) comprises 36% Ancient woodland, albeit this part of the site will in all likelihood be left undeveloped. Also, two adjacent sites to the west of Milford (ID364 Land at Mousehill Mead, Portsmouth Road; and ID449 Land at Manor Lodge; already discussed above) are notably treed/wooded; however, this factor is reflected in the assumed low yield.  Elsewhere, numerous small sites are supported despite containing trees (in some cases with Tree Protection Orders) and/or what seem likely to be mature gardens. For example, at Godalming ID57 (Properties and Gardens 1- 22 Catteshall Lane; 28 homes) contains TPO(s) and is also notable for abutting (and indeed intersecting to a small extent) ancient woodland. Another example is ID94 (Land rear of 38-58 Church Road, Milford; 15 homes), in relation to which the LAA states: “Although the site comprises the rear of back gardens [‘treed’] it provides an opportunity to continue the built form…”

10.2.4 Finally, drawing on GIS analysis (see Appendix IV), points to note regarding the performance of sites supported by the LAA (‘LAA sites’) versus sites not supported (‘non-LAA sites’) are as follows -  Of the 19 sites within 400m of an SAC, three (16%) are LAA sites (at Milford and Elstead).  Of the 27 sites within 400m of an SPA, six (22%) are the LAA sites (at Hindhead, Milford and Elstead).  Of the 42 sites within 400m of a SSSI, eight (19%) are LAA sites (at Hindhead, Milford, Elstead, Dunsfold and Godalming).

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 Of the 45 sites intersecting or adjacent to Ancient Woodland, eight (18%) are LAA sites.  LAA sites are on average further from ancient woodland (304m) than non-LAA sites (259m). Proximity to common land shows a similar trend.

Commentary on other policies

10.2.5 Chapter 16 of the draft plan presents the aspects and policies of the plan which relate to biodiversity. It also outlines the extensive number of biodiversity designations which are wholly or partially present in the plan area.

10.2.6 With regards to effects of particular polices; Policy NE1 (Biodiversity and Geological Conservation) requires that development a) “Retains, protects and enhances features of biodiversity” and b) “Ensures any adverse impacts are avoided, or if unavoidable, are appropriately mitigated.” As part of this, regard is given to the hierarchy designated sites within the plan area, and how these will be assessed in terms of the effect of development on their condition. The policy performs particularly strongly in this regard by providing distances at which the effect of development on European designated sites should be assessed through a HRA in order to ensure that there are no significant effects.

10.2.7 Additionally this policy sets out requirements for development to contribute to the protection, management and enhancement of biodiversity outside of designated areas. The policy states: “The Council will seek to retain and encourage the enhancement of significant features of nature conservation value on development sites”. It is recommended that this section of the policy is strengthened further through providing specified examples of ‘significant features’.

10.2.8 Policy NE2 (Green and Blue Infrastructure) sets out the Council’s aim to protect and enhance the borough’s rivers and canals – including their ecological value. It also sets out the Council’s plan to seek - where appropriate - the maintenance of existing trees woodland and hedgerows in the borough. This policy performs strongly with regards to Blue Infrastructure (rivers and canals) by providing for buffer zones along water courses and through references to Water Framework Directive requirements. It also now includes a strong focus on Green Infrastructure, after it was recommended (through the appraisal of a working draft version of the policy) that this aspect might be strengthened.

10.2.9 Also of note is Policy LRC1 (Leisure, Recreation and Cultural Facilities), which supports “public access for water-based and waterside recreation, provided it does not conflict with nature conservation interests”.

Appraisal of the draft plan as a whole

10.2.10 The broad strategy performs well, recognising that Dunsfold Aerodrome is a relatively non- sensitive location and that Farnham Park has capacity to provide additional SANG. The strategic allocations do not give cause for concern, although it is suggested that the opportunity might be taken to strengthen policy wording in relation to Dunsfold Aerodrome, given some notable constraints and opportunities. There are some concerns raised regarding other suitable LAA sites; however, these are not necessarily ‘significant’, and avoidance/mitigation will be a focus of subsequent plan-making (i.e. Local Plan Part 2 and/or Neighbourhood Plans). Thematic policy within Chapter 16 of the plan is clearly evidence- based and suitably ambitious; and no thematic policies are identified as notably conflicting with biodiversity objectives. Overall, there is no basis upon which to conclude that the plan will result in significant negative effects on the baseline, but equally it is not possible to predict significant positive effects.

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10.3 Climate change mitigation

 Reduce per capita carbon dioxide emissions from the built environment  Increase capacity of renewable energy and/or low-carbon district heating networks

[N.B. The discussion here focuses on reduction of CO2 from the built environment, with CO2 reduction from transport considered separately under the ‘Transport’ heading.]

Commentary on the spatial strategy

10.3.1 The broad strategy - planning for OAN only, supporting a new settlement at Dunsfold Aerodrome, and focusing greenfield expansion at Farnham and Cranleigh more so than Godalming and Haslemere - performs well from a climate change mitigation perspective, primarily on the basis of support for a 2,600 home scheme at Dunsfold Aerodrome. Whilst there can be no certainty, in the absence of detailed proposals, it is fair to assume that a scheme of this scale would enable delivery of a combined heat and power station (potentially even fuelled by biomass, noting the extent of woodland management locally), with a network of piping to provide ‘district heating’. There is also the question of development mix, as mixed use developments (housing and employment) support district heating schemes on the basis of there being a more constant demand across the day. In this respect, Dunsfold Aerodrome - which includes an existing employment area set to expand - performs well as a site.

10.3.2 However, elsewhere the strategy generally involves supporting smaller schemes, unlikely to lead to economies of scale that enable delivery of decentralised heat/electricity supply (or standards of sustainable design / construction significantly above national requirements). Land South of Elmbridge Road and the High Street, Cranleigh is allocated for 765 homes, which is of a suitably strategic scale; however, it is not clear that opportunities exist in practice (see further discussion below). The next largest allocation is at ‘Land at Coxbridge Farm, Farnham’, which at 350 homes is unlikely to be of a suitably strategic scale.

10.3.3 Focusing on the nine proposed strategic allocations, points to note are as follows -  Dunsfold Aerodrome (ID 10) - whilst the policy does not reference low carbon / decentralised heat/electricity supply opportunities, or sustainable design and construction, it is understood that opportunities exist, and will be realised through the application of borough-wide policies, notably CC1-CC3 (see discussion below). A Sustainability and Renewable Energy Strategy accompanying a recent planning application for a 1,800 home scheme, proposed “utilising central energy and water waste facilities; including a solar farm and anaerobic digestion facilities”; however, the solar farm is already in place on site (presumably feeding into the national grid) and the anaerobic digestion plant was granted planning permission in 2013 (but has yet to be implemented). There was also a proposal for “a strategy for super-insulated homes with low energy and water requirements.”  Land South of Elmbridge Road and High Street, Cranleigh (IDs 292, 395 and 853) comprises three separate sites, and therefore the following requirement may help to ensure the coordination that in turn leads to opportunities for the integration of low carbon infrastructure: “A holistic and integrated scheme for the whole site that maximises connectivity and delivers the necessary infrastructure and direct access into the village centre.”

10.3.4 With regards to non-strategic sites identified as suitable within the LAA (but not proposed as allocations), there is little to note in respect of climate change mitigation. There is a cluster of three adjacent sites to the west of Badshot Lea (IDs 25, 438 and 478; of which ID 438 is a strategic allocation within Local Plan Part 1) with a total capacity of c.270 homes; however, it is not thought likely that this gives rise to any particular opportunity.

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Commentary on other policies

10.3.5 There is a need to consider the performance of the draft plan in terms of minimising both per capita greenhouse gas (GHG) emissions from transport, and also per capita GHG emissions from the built environment.

10.3.6 With regards to emissions from transport, Policy ST1 (Sustainable Transport) seeks to support a transition towards low carbon forms of transport, and additionally seeks to ensure that development schemes are accessible by forms of travel other than private car, with support for new and improved footpaths, bridleways and cycle-ways.

10.3.7 With regards to emissions from the built environment, Policy CC2 (Sustainable Construction and Design) sets out a range of areas in which the Council will seek to promote sustainable patterns of development such as through measures to minimise energy and water use, and design measures to encourage access by walking and cycling. Due consideration is also given to the impact of activities related to refurbishment, demolition, excavation and construction; for example, minimising construction and demolition waste and promoting the reuse and recycling of building materials is taken into account.

10.3.8 Policy CC3 (Renewable Energy Development) is concerned with the location and design of renewable energy development. This policy is primarily concerned with mitigating significant adverse effects associated with such development (such as on landscape character and setting) – but also explains that the Council will encourage applications from community led projects.

Appraisal of the draft plan as a whole

10.3.9 Focusing on the potential for the draft plan to support renewable or low carbon energy infrastructure, and hence minimise per capita CO2 emissions from the built environment, the conclusion is reached that the plan performs well on the basis of support for a 2,600 home scheme at Dunsfold Aerodrome. Whilst there can be no certainty, in the absence of detailed proposals, it is fair to assume that a scheme of this scale would enable delivery of a combined heat and power station, with a network of piping to provide ‘district heating’. Elsewhere, there is generally support for smaller schemes; however, there may be some opportunities to deliver low carbon infrastructure (and/or standards of sustainable design and construction above national standards), and borough-wide policies are proposed that should ensure that opportunities are realised as far as possible. With regard to effect significance, no significant effects are predicted. Climate change mitigation is a global issue, and hence it is not possible to conclude on the significance of local actions.

10.4 Community and well-being

 Reduce poverty and social exclusion  Encourage healthy lifestyles, reduce inequalities in health and plan to meet emerging strategic health issues, not least those relating to the ageing population  Ensure access to education and skills development opportunities  Give regard to promoting equality of opportunity for all protected groups, e.g. the elderly.49

Commentary on the spatial strategy

10.4.1 Important considerations include the need to: ensure access to community infrastructure and services for new and existing residents; contribute towards reductions in socio-economic inequality between communities; and support good health amongst those living in the borough (see further discussion in Appendices II and V).

49 The Council has a duty to give "due regard" to promoting equality of opportunity for all protected groups when making decisions; and publish information showing how they are complying with this duty. ‘Protected groups’ are those with the following characteristics: age; disability; gender reassignment; marriage and civil partnership; pregnancy and maternity; race; religion or belief; sex; sexual orientation.

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10.4.2 Having made these introductory points, it is possible to conclude that the broad strategy - planning for OAN only, supporting a new settlement at Dunsfold Aerodrome, and focusing greenfield expansion at Farnham and Cranleigh more so than Godalming and Haslemere - performs well from a communities perspective, on the basis that a limited and selective approach to growth is being followed at the existing settlements, with the corollary of a large scheme at Dunsfold Aerodrome. A 2,600 home scheme at Dunsfold Aerodrome will ensure a critical mass necessary to deliver community infrastructure and transport infrastructure upgrades, e.g. there will be good potential to support quality bus services linking Dunsfold Aerodrome to higher order services/facilities in Cranleigh/ Godalming/ Guildford/ Horsham. However, the new community would still be relatively small, e.g. not on the scale of Northstowe in Cambridgeshire, where there are high hopes of developing cohesive, inclusive and low carbon communities.

10.4.3 Focusing on the nine proposed strategic allocations, points to note are as follows -  Dunsfold Aerodrome (ID 10) - Site specific policy is set to require a local centre and community infrastructure including a new primary school and health facilities. A financial contribution will also need to be made to off-site secondary school provision. Furthermore, there are requirements for: publicly accessible local and strategic open space to include a managed Country Park of at least 103 Ha; appropriate on and off site leisure facilities; a new canal basin to the Wey and Arun Canal; land for a local history museum; and public art.  Other site specific policy has notably less focus on community infrastructure, although policy for Land South of Elmbridge Road and the High Street, Cranleigh (IDs 292, 395 and 853) is set to require: “a linear park along the public right of way [and] a holistic and integrated scheme for the whole site that maximises connectivity and delivers the necessary infrastructure and direct access into the village centre. The parts of the site closest to the village centre should be developed first.” All site specific policy refers to access and transport arrangements, but this is a matter best considered under ‘Transport’ heading below.  The Woolmead, Farnham (ID 670) - lies mostly within the Farnham Air Quality Management Area (AQMA). This matter is not referenced by site specific policy, but it can nonetheless be assumed that steps will be taken to avoid/mitigate effects through layout and design.

10.4.4 Focusing on non-strategic sites identified as suitable within the LAA (but not proposed as allocations), there is only a strategic issue at Cranleigh, where two school sites - Cranleigh Infants School, Church Lane (ID130); and Land at St Nicolas C of E School, Parsonage Road (ID383) - are proposed for redevelopment contingent on replacing the schools with a new combined school providing primary education on the Glebelands School site. The redevelopment of the sites for housing would part fund the new combined school on Glebelands with improved facilities; and the sites would not be developed until after five years to allow for the new combined school to be provided first.

10.4.5 Finally, drawing on GIS analysis (see Appendix IV), points to note regarding the performance of sites supported by the LAA (‘LAA sites’) versus sites not supported (‘non-LAA sites’) are as follows -  18% of LAA sites are within 400m of a town centre compared to 9.5% of non-LAA sites.  27% of LAA sites are beyond 1600m of a GP surgery compared to 48% of non-LAA sites.  However - – 21% of LAA sites are beyond 60 minutes of a secondary school compared to 19% of non-LAA sites.

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Commentary on other policies

10.4.6 Community and wellbeing is considered through a number of polices e.g. AHN1 (Affordable Housing) , AHN4 (Gypsies, Travellers and Travelling Show People Accommodation), LRC1 (Leisure, Recreation and Cultural Facilities), TD1 (Townscape and Design), ICS1 (Infrastructure and Community Facilities), TCS3 (Neighbourhood and Village Shops).

10.4.7 Although the need to provide healthcare facilities, and the desire to promote health and wellbeing is stated throughout the Local Plan - with a healthcare centre planned for Dunsfold Aerodrome - there is no policy dedicated to health and well-being. It was recommended to the Council (as part of the appraisal of a working draft version of the plan) that, as there is a need to reduce health inequalities within the borough (and in particular to provide suitable facilities for older people and to provide better access to services in rural areas), a dedicated policy should be developed which addresses levels of health and health inequalities. The Council’s response is: “A stand-alone policy could have been beneficial, and will be considered for LP Part 2, but meanwhile, health matters are picked up in separate policies. For example, AHN3 indicates support for people with particular needs, including older people.”

10.4.8 A principal policy for Community and Wellbeing is Policy ICS1: Infrastructure and Community Facilities, which outlines how through Community Infrastructure Levy necessary infrastructure - including community, green and transport infrastructure - will be managed and provided through new developments. The policy also sets out the Council’s opposition to the loss or degradation of community facilities and therefore performs strongly.

10.4.9 A further policy of note is Policy LRC1: Leisure, Recreation and Cultural Facilities, which sets out the Council’s opposition to the loss of recreation and other facilities within the borough; and sets out the provision of new open space, sports, leisure and recreation facilities and the promotion of outdoor recreation as part of further development. Of particular note is the requirement that facilities will be safeguarded from development unless evidence is provided demonstrating that: a) the existing use is no longer required or viable, b) no other leisure, recreation or cultural provision is required or appropriate in that area, or c) alternative provision of a suitable scale and type can be made.

Appraisal of the draft plan as a whole

10.4.10 The broad strategy performs well, recognising that there are communities/wellbeing opportunities to be realised through a 2,600 home scheme at Dunsfold Aerodrome; and equally a limited and selective approach to growth at the existing settlements is in-line with an understanding of existing issues and limited opportunities. None of the strategic allocations, nor the other suitable LAA sites, give particular cause for concern, and it is noted that detailed site specific policy for Dunsfold Aerodrome requires a range of community infrastructure. Thematic policy is suitably detailed, recognising that there is the potential to add detail through Local Plan Part 2. Overall, there is no basis upon which to conclude that the plan will result in significant negative effects on the baseline, but equally it is not possible to predict significant positive effects.

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10.5 Economy

 Support economic activity to meet employment needs, including in rural areas  Enhance the vitality of the borough’s centres  Retain well located commercial land  Secure investment in key infrastructure  Encourage the development of a tourism sector based on natural and cultural assets  Improve the match of skills to employment opportunities

Commentary on the spatial strategy

10.5.1 Key considerations here are those set out within the Waverley Economic Strategy 2015-2020, the Waverley Employment Land Review (ELR) Update and the West Surrey Strategic Housing Market Assessment (SHMA). Matters are discussed in detail in Appendices II and V, but in summary there is a need to: deliver employment land; deliver housing in proximity to employment growth areas; and avoid traffic congestion and impacts to the environmental quality / quality of life factors that make Waverley an attractive location for business.

10.5.2 In light of these points, the broad strategy - planning for OAN only, supporting a new settlement at Dunsfold Aerodrome, and focusing greenfield expansion at Farnham and Cranleigh more so than Godalming and Haslemere - performs well in certain respects, but has a notable draw-back, in that residents of a 2,600 home scheme at Dunsfold Aerodrome would be relatively isolated from employment growth areas. The Dunsfold Aerodrome scheme would deliver a significant expansion of the existing employment area on-site, and the approach to greenfield expansion does involve a focus at Farnham, but ultimately the preferred strategy involves low growth in the vicinity of key employment growth areas (i.e. the north and west of the borough). There is an argument to suggest that the proposed strategy is not best suited to contributing to the achievement of economic objectives within the Functional Economic Market Area (FEMA) that comprises Waverley, Guildford and Woking, or objectives at the scale of the ‘Enterprise M3’ Local Enterprise Partnership (LEP) area; however, there is much uncertainty in this respect.

10.5.3 Focusing on the nine proposed (strategic) allocations, points to note are as follows -  Dunsfold Aerodrome (ID 10) - Site specific policy is set to require expansion of the employment area, with the supporting text explaining that: “The retention and expansion of the Dunsfold Business Park would deliver around 26,000 sqm of new B class employment floorspace. This will contribute towards meeting the economic development needs of the borough and the overall objective of supporting the delivery of new and improved commercial premises in order to meet the needs of businesses in Waverley. This should comprise a range of new floorspace across the B Use Classes, with a range of unit sizes, including space that will appeal to start-up companies and small businesses.”  Land off Water Lane, Farnham (ID 900) is a 4.9 ha employment allocation, with the supporting text to the policy explaining that: “It is currently retained operational land in connection with the adjacent sewage treatment works, but has become surplus to requirements. This site is considered to be appropriate for employment (Class B) development.”  Whilst there are no other strategic employment or mixed use allocations, the approach to employment land is in-line with the Employment Land Review (ELR), which has identified an overall surplus of B1c/B2 (light industrial/general industrial) and B8 (storage or distribution) floorspace totalling some 30,500m2, and established that this surplus has the potential to be re-used to meet the demand for office floorspace.  The Woolmead, Farnham (ID 670) - The redevelopment of the site for a mix of uses provides an opportunity to improve the appearance of this prominent site, which lies within the East Street Area of Opportunity designated in the Waverley Local Plan 2002.

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10.5.4 Focusing on non-strategic sites identified as suitable within the LAA (but not proposed as allocations), some points to note are as follows -  Three sites currently in employment uses (whole or part) are: West Cranleigh Nurseries, Knowle Lane, Cranleigh (ID 292), which includes operational glasshouses; Weyburn Works, Shackleford Road (ID 16), although this site has not been occupied for some time; and Woodside Park, Catteshall Lane, Godalming (ID 648).  At Hindhead two sites - Central Hindhead, London Road (ID 144) and Land at Oakdale, Portsmouth Road (ID 145 ) - will involve the redevelopment of a commercial site to mainly housing, with this approach justified on the basis that the realignment of the A3 has decreased commercial viability.

Commentary on other policies

10.5.5 Economy and employment is addressed through Policies EE1 (New Economic Development), Policy EE2 (Protecting Existing Employment Sites), Policy SS3 (Strategic Mixed Use Site at The Woolmead, Farnham), Policy SS7 (New Settlement at Dunsfold Aerodrome), Policy SS8 (Strategic Mixed use Site at Woodside Park, Godalming), Policy SS9 (Strategic Employment Site on Land off Water Lane, Farnham).

10.5.6 Chapter 10 details the primary policies which pertain to the economy, and also the wider strategy proposed by the Council. In particular Policy EE1 sets out the provision of “at least 16,000 sq. m. of new use classes B1a/b (Offices/Research and Development) floor space”. It also sets out the site allocations for such additional employment floor space. Additionally, it also sets out the Councils intention for the “sustainable redevelopment, intensification and/or expansion of sites presently used for employment uses”. Also, under Policy EE2 the Council seeks to protect existing employment sites against alternative uses – unless “it can be clearly demonstrated that there is no reasonable prospect of the site being used for employment use”. These measures are likely to result in positive outcomes for the local economy by attracting business and creating jobs, in-line with opportunities established by the Employment Land Review (ELR). Elsewhere within Chapter 10 it is discussed that economic growth is required to be balanced against environmental protection, climate change mitigation, and the ‘unique character’ of Waverley.

Appraisal of the draft plan as a whole

10.5.7 The spatial strategy is arguably not ideal from an economic perspective on the basis that Dunsfold Aerodrome - a focus for housing and employment growth - is a relatively isolated location. However, the housing growth strategy is in-line with the findings of the Strategic Housing Market Assessment (SHMA), which accounted for employment growth forecasts, and the employment land strategy is in-line with the findings of the Employment Land Review; plus the strategy is in line with the Waverley Economic Strategy; hence there is no potential to conclude the likelihood of significant negative effects.

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10.6 Heritage and townscape

 Conserve and enhance the historic environment, with a focus on designated assets and their settings  Maintain and enhance townscape including through a reduction in derelict or degraded land and a focus on high quality urban fringes

Commentary on the spatial strategy

10.6.1 The broad strategy - planning for OAN only, supporting a new settlement at Dunsfold Aerodrome, and focusing greenfield expansion at Farnham and Cranleigh more so than Godalming and Haslemere - performs well on the basis of involving a limited and selective approach to growth at the existing settlements and a 2,600 home scheme at Dunsfold Aerodrome. A new settlement at Dunsfold Aerodrome is supported, from a heritage perspective, although it is recognised that there is some potential for impacts to heritage assets. This is particularly the case as there could be pressure placed on the conservation areas at nearby Dunsfold and Alfold villages, and the conservation area at Bramley to the north could be impacted by traffic passing along the A281. It is also possible that traffic generated could impact on other villages, including Chiddingfold to the west, Hascombe and Busbridge en-route to Godalming and Milford, en-route to the A3.

10.6.2 Focusing on the nine proposed strategic allocations, points to note are as follows -  Dunsfold Aerodrome (ID 10) - Site specific policy is set to require land to be reserved on or adjoining the site for the provision of a museum reflecting the site’s history as an aviation centre, as well as public art to reflect the heritage of the site.  Coxbridge Farm, Farnham (ID 29) comprises open fields with adjacent farm buildings to the south, several of which are Grade II Listed. Site specific policy is set to require: “Safeguard and enhance the setting of the adjoining heritage assets at Coxbridge Farm.”

10.6.3 Focusing on non-strategic sites identified as suitable within the LAA (but not proposed as allocations), some points to note are as follows -  Land at Hale Road, Farnham (ID 693) - The Landscape Study concludes that the capacity for development in this area, adjacent to Farnham Park Historic Park or Garden, is limited.  Land to the north of Queens Mead, Chiddingfold (ID286) abuts a Conservation Area, with part of the site understood to be ‘more prominent’ and requiring careful design.  Land adj Nugent Close, Dunsfold (ID 747; 42 homes) - abuts a Conservation Area.  The Bush Hotel, The Borough, Farnham (ID 285) - includes a Grade II Listed Building and occupies a prominent position within Farnham Town Centre.  Land east of Binscombe, Godalming (ID 571) - Having regard to the location of the site and its relationship to the Conservation area and historic buildings, particular attention would need to be paid to the design and density of dwellings on the site and vehicular access on to Binscombe.

10.6.4 Finally, drawing on GIS analysis (see Appendix IV), points to note regarding the performance of sites supported by the LAA (‘LAA sites’) versus sites not supported (‘non-LAA sites’) are as follows -  12% of LAA sites intersect or are adjacent to a conservation area compared to 16% of non- LAA sites.  Of the seven sites intersecting a registered park/garden, only one is a LAA site (Land at Hale Road, Farnham; ID 693)  However, LAA sites are closer to a listed building on average (146m) than non-LAA sites (212m).

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Commentary on other policies

10.6.5 Policy sets out to continue the previous proactive approach adopted by the Council with regards to conservation and enhancement of heritage assets. Policies which relate to this include: Policy HA1 (Protection of Heritage Assets), Policy TCS1 (Town Centres), Policy TD1 (Townscape and Design), Policy RE3 (Landscape Character).

10.6.6 Of particular note is Policy HA1 (Protection of Heritage Assets) which sets out the conservation of the boroughs heritage assets. Importantly, this policy supports the conservation of both designated and non-designated assets, with particular reference made to buildings that are considered locally important (‘Buildings of Local Merit’). It was recommended (as part of the appraisal of a working draft version of the plan) that wording within this policy be amended, with use of the term ‘conserve’ rather than ‘preserve’ (recognising that sensitive change can maintain, or even enhance, the significance of heritage assets), and the Council then amended policy wording accordingly.

10.6.7 Policy TD1 sets out the Council’s aim to ensure that the character and amenity of the borough is protected by: “Requiring new development to be of a high quality and inclusive design that responds to the distinctive local character of the area in which it is located”. Furthermore, the policy states account will be taken of design guidance and Conservation Area Appraisals in order to achieved development which maintains local character.

10.6.8 Policy RE3 (Landscape Character) requires that development “must respect and where appropriate, enhance the distinctive character of the landscape in which it is located”. In relation to Heritage Assets the Council seeks to “preserve the distinctive historic landscape character and archaeological features of the Areas of Special Historic Landscape Value, through continued application of Policy HE12 of the Waverley Borough Local Plan (2002)”.

Appraisal of the draft plan as a whole

10.6.9 The broad strategy performs well, recognising that Dunsfold Aerodrome is a relatively non- sensitive location. A number of the strategic allocations and other suitable LAA sites are in proximity to a heritage asset; however, there is likely to be good opportunity to avoid / mitigate effects. Policy is set to be put in place to ensure that decisions are taken with heritage conservation in mind, and that opportunities to enhance the historic environment are realised (e.g. within Farnham Town Centre).

10.7 Housing

 Ensure everyone has the opportunity to live in a decent home  Increase the supply of affordable housing  Support provision of housing for those with specialist needs, including older people

Commentary on the spatial strategy

10.7.1 The broad strategy - planning for OAN only, supporting a new settlement at Dunsfold Aerodrome, and focusing greenfield expansion at Farnham and Cranleigh more so than Godalming and Haslemere - performs well on the basis that the borough’s objectively assessed need figure, as understood from the Strategic Housing Market Assessment (SHMA), will be met within the borough. However, that is not to say that the proposed strategy is ideal, from a purely ‘housing’ perspective (see discussion of alternatives consideration in Chapter 7, above). The strategy will not contribute to unmet housing needs arising from Woking, and as such will result in a likelihood of OAN not being met within the West Surrey HMA; and the distribution of housing is not in-line with the distribution of housing needs within the borough, with a weighting towards the more rural east.

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10.7.2 With regards to specific sites, one specific point to note is that a Dunsfold Aerodrome scheme would deliver a 7,500m2 care home facility. A large scheme here will also maximise the potential to deliver a good mix of housing, with a proportion of affordable housing in-line with policy. More generally, with regards to affordable housing delivery, there is little potential to suggest that the proposed strategy will have a bearing. There is a relatively high reliance on smaller sites; however, given high development viability in Waverley it should be the case that affordable housing can be delivered even at small sites, in line with policy (although there could conceivably be some risk of localised market saturation).

Commentary on other policies

10.7.3 Policy AHN1 (Affordable Housing) states that, unless contrary to other policy within the Local Plan or a Neighbourhood Plan, the Council will require a minimum provision of 30% affordable housing at: all housing developments in designated rural areas providing a net increase of 6 dwellings or more; all housing developments in non-designated rural areas providing a net increase of 11 dwellings or more; and all housing developments that have a maximum combined gross floor space of more than 1000 sq. m. This policy also takes into account development sites which may be sub divided and states that: “the Council will normally expect each subdivision or smaller development to contribute proportionally towards achieving the amount of affordable housing which would have been appropriate on the whole or larger site”.

10.7.4 Policy AHN3 (Housing Types and Size) outlines the Council’s commitment to meet the needs of specific groups that have been identified in the West Surrey Strategic Housing Market Assessment (older people, families with children, people with disabilities). However, this policy stops short of specifying the thresholds for dwelling types and sizes in relation to development size. Therefore, as part of the appraisal of a work draft version of the policy, it was recommended that this policy set thresholds. The Council responded, stating that: “There is no evidence available to justify appropriate thresholds. We may be able to develop a more detailed policy in Local Plan Part 2.”

10.7.5 Finally, Policy AHN4 (Gypsies, travellers and travelling show people accommodation) sets out the requirement to meet the identified needs of Gypsy and Traveller communities. In particular a number of points outline the requirement for sites to be within easy and safe access to the strategic road network and that sites are located within a reasonable distance of local facilities and services including schools and health facilities.

Appraisal of the draft plan as a whole

10.7.6 It would seem appropriate to conclude a likelihood of the draft plan leading to significant positive effects, as the Waverley OAN figure would be met; however, it is recognised that there is some uncertainty given the proposal not to provide for a ‘buffer’ or provide for a level of growth above OAN in order to contribute to meeting unmet needs within the Housing Market Area (HMA) arising from undersupply in Woking. In line with para. 47 of the National Planning Policy Framework (NPPF), local planning authorities should: “use their evidence base to ensure that their Local Plan meets the full, objectively assessed needs for market and affordable housing in the housing market area, as far as is consistent with [principles of sustainable development].” [Emphasis added]

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10.8 Landscape

 Conserve and enhance distinctive landscapes, particularly the nationally important AONB and landscapes designated as being of more local importance

Commentary on the spatial strategy

10.8.1 The broad strategy - planning for OAN only, supporting a new settlement at Dunsfold Aerodrome, and focusing greenfield expansion at Farnham and Cranleigh more so than Godalming and Haslemere - performs well on the basis of involving a limited and selective approach to growth at the existing settlements and a 2,600 home scheme at Dunsfold Aerodrome - a largely brownfield site - is supported. There will be limited impacts to the nationally important Area of Outstanding Natural Beauty (AONB) and sub-regionally important Area of Great Landscape Value (AGLV), with sites selected in-line with the findings of the Waverley Landscape Study (2014). Also, Green Belt has been applied as a constraint, with development generally only supported where the Waverley Green Belt Review (2014) has found the land parcel in question to perform poorly in terms of contribution to the four/five nationally established Green Belt purposes. The application of landscape / Green Belt constraint is evident in the broad strategy of focusing greenfield growth / urban extension at Farnham and Cranleigh, more so than Godalming and Haslemere.

10.8.2 With regards to the nine proposed strategic allocations, it is noted that all site specific policies reference particular landscaping (or landscape ‘buffers’) that must be implemented, with the exception of two: Land at Woodside Park, Catteshall Lane, Godalming (ID 648 in the LAA); and Land West of Green Lane, Badshot Lea (part of ID 438). The former presents no obvious issues, as a small brownfield site. With regards to the latter, it is noted that the proposed allocation site comprises only about 1/3 of the site originally promoted / considered through the LAA, which serves to suggest that landscape concerns have factored into definition of the proposed site boundary (which does appear to round-off existing development, albeit it is also noted that a footpath runs along the site’s southern boundary, and a cycle route along the eastern boundary), but perhaps equally indicates that landscaping of the site’s southern boundary could be appropriate to help ensure permanence / prevent future sprawl. This site lies within the locally designated Farnham / Aldershot Gap; however, the Waverley Landscape Study identifies potential for development.

10.8.3 Focusing on non-strategic sites identified as suitable within the LAA (but not proposed as allocations), some points to note are as follows -  At Bramley, which lies within the AGLV and is inset from the Green Belt, the proposal is to adjust settlement boundary to only a very limited extent, enabling one small site - Land to the rear Orchard Cottages and Glenafrie, Mill Lane (ID 280) to be developed as infill.  At Chiddingfold, which lies within the AONB and is inset from the Green Belt, three sites are supported (92 homes in total) at sites found to have development potential by the Green Belt Review and Landscape Study. The largest of the three sites - Land to the north of Queens Mead (ID 286) - is notably sensitive, given topography and location adjacent to the Conservation Area. Lower parts of the site are well screened, but higher land is more prominent, leading to a need for careful layout, landscaping and design.  At Elstead, which lies within the AONB and is inset from the Green Belt: Weyburn Works, Shackleford Road (ID 16) - is a large partially brownfield site that does not currently relate well to the main settlement pattern of the village, particularly recognising that development may be focused around the part of the site that is brownfield; Land to the rear of The Croft (ID 308) was not identified as a potential location by the Green Belt Review, but development could act to ‘round off’ the settlement boundary and the Landscape Study recognised that there is some scope for development close to the village; and Land at Four Trees, Hookley Lane (ID 824) is another site of significant scale (in the context of Elstead), where there is potential for development to round-off the existing settlement boundary.

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 At Farnham, aside from the Strategic Allocations, notable sites include: Land to the South of Monkton Lane (657), which is not as well integrated with the settlement area as some other sites, but is understood from the Landscape Study to have low intervisibility and ultimately some development potential; Land at Hale Road (ID 693), where there is low development capacity given its location adjacent to Farnham Park; and Land rear of Three Styles Road (ID 727), which lies on a raised hillside overlooking Farnham town centre, but integrates reasonably well with the settlement pattern and is found to have some potential for development by the Landscape Study.  At Godalming there is support for only small sites that are likely to have limited effects in isolation or in-combination, but it is noted that ‘Properties and Gardens 1- 22 Catteshall Lane (ID 57)’ is a steep site in proximity to the AONB. The only site involving an extension into the Green Belt is Land east of Binscombe (ID 571), where a sensitively designed development would be consistent with the Green Belt review and the Landscape Study.  At Hindhead two sites (IDs 682 and 557) are supported for development on the basis of being relatively self-contained / involving redevelopment of existing buildings; however, the Landscape Study identifies particular sensitivities in this area.

10.8.4 Finally, drawing on GIS analysis (see Appendix IV), points to note regarding the performance of sites supported by the LAA (‘LAA sites’) versus sites not supported (‘non-LAA sites’) one point to note is that: 31% of greenfield LAA sites intersect the AONB or AGLV, compared to 33% of non-LAA sites.

Commentary on other policies

10.8.5 The need to protect the borough’s highly valued rural landscape is a focus of Policy RE1 (Non Green Belt Countryside) which requires non green belt countryside within the borough to be afforded protection in accordance with the NPPF. While this policy does provide some protection to non-Green Belt countryside, it is recommended that this policy is strengthened further by providing specifying the level of protection which will be provided.

10.8.6 Policy RE2 (Green Belt) sets out that the Council’s approach to protection of Green Belt land will be in accordance with the NPPF and that “new development will be considered to be inappropriate and will not be permitted unless very special circumstances can be demonstrated”. The policy sets out a number of changes to be made to the borough’s Green Belt through the Local Plan, in-line with the recommendations of the Green Belt Review (2014).

10.8.7 Policy RE3 (Landscape Character) requires that “New development must respect and where appropriate, enhance the distinctive character of the landscape in which it is located”. This policy sets out requirements for key strategic aspects of the borough’s landscape character including conservation and enhancement of the Surrey Hills Area of Outstanding Natural Beauty, protection of the Farnham / Aldershot Strategic Gap, the Area of Strategic Visual Importance, and the Godalming Hillsides.

Appraisal of the draft plan as a whole

10.8.8 The broad strategy performs well, given that central to the strategy is a new settlement at a brownfield site - Dunsfold Aerodrome. Landscape designations and Green Belt have been applied as a constraint, as evidenced by the weighting of greenfield development to Farnham and Cranleigh / away from Godalming and Haslemere. A limited and selective approach is set to be taken to greenfield development; however, there remain a range of site specific sensitivities. Landscaping, and masterplanning with the avoidance of landscape impacts in mind, is a focus of proposed site specific policy. Significant negative effects are not predicted.

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10.9 Soils and other natural resources

 Make most efficient use of land, including through maximising use of previously developed land (including contaminated sites where remediation is possible)

Commentary on the spatial strategy

10.9.1 The proposed broad strategy - planning for OAN only, supporting a new settlement at Dunsfold Aerodrome, and focusing greenfield expansion at Farnham and Cranleigh more so than Godalming and Haslemere - performs well on the basis of involving a limited and selective approach to greenfield growth and a 2,600 home scheme at Dunsfold Aerodrome - a largely brownfield site.

10.9.2 Also, there is a need to avoid loss of higher quality (‘best and most versatile’) agricultural land. In this respect, all land in Waverley is either Grade 2 (very good quality) or Grade 3 (good to moderate quality) in the Agricultural Land Classification, according to the nationally available ‘Provisional Agricultural Land Quality’ dataset. There is relatively little Grade 2 land, with patches to be found in the parishes of Farnham and Cranleigh, and in particular in the Badshot Lea area and to the west of Cranleigh. Both of these locations are a focus of some greenfield growth under the proposed strategy, although there is a need for detailed survey work before reaching a conclusion regarding loss of ‘best and most versatile’ agricultural land.

10.9.3 With regards to the nine proposed (strategic) allocations, it is noted that potential ground contamination is an issue at two sites, with site specific policy proposed to ensure that this is remediated prior to development.

10.9.4 Contaminated land is also potentially an issue at a number of the non-strategic sites that are supported through the LAA, including Alfold Garden Centre (ID 472); and Woodside Park, Catteshall Lane, Godalming (ID 648).

Commentary on other policies

10.9.5 Although a number of references are made to encouraging the use of previously developed land throughout the plan there is no specific policy which relates to the use of previously developed land; and there is no reference to the matter of contaminated land. However, it is noted that these issues are covered by two policies in the existing Local Plan (D1 and D2) and these will continue to be saved until replaced by updated policies in Local Plan Part 2.

Appraisal of the draft plan as a whole

10.9.6 The broad strategy performs well, given that central to the strategy is a new settlement at a brownfield site - Dunsfold Aerodrome; however, there is likely to be some loss of better quality (grade 2) agricultural land.

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10.10 Traffic and transportation

 Reduce the reliance on journeys by car, including through encouraging and supporting trips made by walking, cycling and public transport  Improve accessibility to services, facilities and amenities, including in rural areas  Prevent and seek to reduce traffic congestion, particularly at sensitive locations

Commentary on the spatial strategy

10.10.1 Key considerations here are those set out within two studies recently prepared for the Council: 1) Transport Assessment (TA): Scenarios for the Distribution of Housing Growth - Stages 1, 2, 3 and 4 Reports (Mott MacDonald, February 2016 – June 2016); and 2) Waverley Local Plan Strategic Highway Assessment (SHA) (Surrey County Council, 2016). Matters are discussed in detail in Appendices II and V, but in summary there is a need to: prevent severe traffic congestion at existing ‘hotspots’, in particular Farnham; and direct housing to more accessible locations, with a view to encouraging modal shift (away from car dependency) and minimise distances travelled. The two objectives can prove to be somewhat conflicting.

10.10.2 In light of these points, the proposed broad strategy - planning for OAN only, supporting a new settlement at Dunsfold Aerodrome, and focusing greenfield expansion at Farnham and Cranleigh more so than Godalming and Haslemere - can be seen to have ‘pros and cons’. On one hand, a focus of growth at Dunsfold Aerodrome aligned with limited growth at Farnham is supported from a traffic perspective (traffic arising from Dunsfold Aerodrome having been the focus of much detailed work, with the conclusion reached that there is the potential for mitigation through junction upgrades); however, on the other hand, residents of a 2,600 home scheme at Dunsfold Aerodrome would be relatively isolated, and it is also the case that a low growth approach at Godalming and Haslemere - two towns with a good train service - is less than ideal.

10.10.3 Focusing on the nine proposed (strategic) allocations, points to note are as follows -  Dunsfold Aerodrome (ID 10) - Site specific policy is set to require “Necessary highways improvements to mitigate the impact of the development on the surrounding road network” and “A package of sustainable transport measures to maximise opportunities for alternative forms of transport and to support alternatives to the private car.” However, even with such measures - which it is noted does not make explicit reference to bus services - a higher degree of car dependency / need to travel longer distances by car can be expected, as can be some issues of traffic congestion. This conclusion holds true even once account is taken of: the potential for some people to live and work on-site and policy that is set to require delivery of a local centre. The Council’s Transport Assessment study suggests that a scenario involving a 2,600 home scheme at Dunsfold Aerodrome could result in new Waverley residents on average having to travel further by car (1.7% further assuming 20% internalisation, or 8% further assuming 10% internalisation) than would be the case under a scenario that involves no housing at Dunsfold Aerodrome. Also, the TA highlights that: there is no existing bus service to the site and it will be difficult for any new bus service to remain viable; there will be relatively poor potential to access local facilities by non-car modes; and there is relatively poor potential to access a train station by non-car modes.  Site specific policy for all other strategic allocations - with the exception of The Woolmead, Farnham (ID 670), a town centre site - includes reference to required access arrangements, and in three instances site specific policy requires ‘sustainable transport’ measures. Notably, policy for Land West of Green Lane, Badshot Lea (part of ID 438) is set to require improvements “to promote the use of Green Lane for walking and cycling only.” This will help to ensure access to Farnham Town Centre, which is beyond easy walking distance (albeit local shops and facilities are in close proximity, and there is access to a bus service). Similarly, Land at Horsham Road, Cranleigh (ID 294 in the LAA) is beyond easy walking distance of Cranleigh village centre, and hence the policy requirement to ensure “direct pedestrian access to the Downs Link” takes on particular importance.”

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Commentary on other policies

10.10.4 Policies relevant to Traffic and Transportation include Policy ST1 (Sustainable Transport), Policy CC2 (Sustainable Construction and Design), Policy SS1 (Strategic Housing Site at Coxbridge Farm, Farnham), Policy SS2 (Strategic Housing Site at Land West of Green Lane, Farnham), Policy SS3 (Strategic Mixed Use Site at The Woolmead, Farnham) Policy SS4 (Strategic Housing Site at Horsham Road, Cranleigh), Policy SS5 (Strategic Housing Site at Land South of Elmbridge Road and the High Street, Cranleigh), Policy SS6 (Strategic Housing Site at Land opposite Milford Golf Course), Policy SS7 (New Settlement at Dunsfold Aerodrome), Policy SS8 (Strategic Mixed use Site at Woodside Park, Godalming).

10.10.5 The key policy with regards to transportation is Policy ST1 (Sustainable Transport) which states the Council’s intention to work with Surrey County Council and other key stakeholders in order to ensure that development will contribute to improving the boroughs transportation. Additionally, Policy CC2 (Sustainable Construction and Design) is likely to lead to positive effects in terms of reducing peak time traffic loads by requiring that new development is designed to encourage walking, cycling and access to sustainable forms of transport.

Appraisal of the draft plan as a whole

10.10.6 The spatial strategy performs well in terms of avoiding worsened traffic congestion, with modelling work having shown there to be good potential to mitigate effects through infrastructure upgrades; however, the strategy is less than ideal in terms of the desire to minimise car dependency / distance travelled by car. Site specific policy is proposed to ensure suitable access, required highways upgrades and measures to support walking and cycling; however, this can only go so far towards mitigating effects. There is no clear basis for concluding ‘significant’ negative effects’, but the plan can be seen to have negative effects in certain respects.

10.11 Water, flood risk and other climate change adaptation issues

 Minimise the impact of development on flooding (fluvial, surface and groundwater) and avoid development in at risk areas  ‘Climate proof’ urban areas (e.g. through shading and shelter in public spaces) and infrastructure  Prevent pollution to the water environment  Encourage reduced per capita consumption of water and increased water efficiency.

Commentary on the spatial strategy

10.11.1 Key considerations relate to: A) waste water treatment infrastructure; B) water supply infrastructure; C) Groundwater Source Protection Zones (SPZs); and D) flood risk.

10.11.2 With regards to waste water treatment infrastructure (i.e. the potential to locate growth in such a way as to ensure that capacity is not at risk of being breached, which can result in water pollution incidents) - both Southern Water and Thames Water were consulted in 2014 and 2015. SW were of the view that: “Wastewater capacity should not be seen as a constraint to development… Necessary investment in strategic infrastructure can be delivered in parallel with development….” TW went slightly further, stating that “there may be local incapacities but, due to the complexities of the sewerage network and the uncertainties around the location, scale and phasing of development, it was difficult to accurately identify the infrastructure needs in terms of what upgrades will be required. Typically, local network upgrades take 18 months to 3 years to investigate, design and build. More strategic solutions 3 to 5 years and where new sewage treatment works are required this could take 7 to 10 years”.

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10.11.3 Most recently, a “stage 1” High Level Water Cycle Study (WCS) has reviewed the sewage treatment works likely to come under pressure and found that: “the existing works have a varying degree of additional capacity for expansion, and whilst generally some small scale developments may be absorbed by the existing capacity the increasing in loads are likely to require capacity increases… As can be seen from the table and without allowing for additional social, commercial or industrial loads, all of the STW’s will require some form of expansion to cater for the additional development.” The study goes on to conclude that: “It is clear that further consultation is required with the water companies, and other relevant managing authorities, so that a more quantitative analysis can analyse the relationships between proposed future growth and the effects on wastewater quality, sewer capacity and environmental capacity. This quantitative analysis will take place in the Stage 2 of the High Level Water Cycle Study.” The study also states that: “The most significant challenge is managing wastewater from the Dunsfold Park development. As a development some distance away from existing STW and the resulting likelihood that the network infrastructure would be significantly under capacity for the proposed development, consideration is needed whether to build and operate network infrastructure to allow for the transportation of sewage to an existing treatment works or to build a local treatment works to service the new development.”

10.11.4 With regards to flood risk, the key source of evidence is the Waverley Level 1 Strategic Flood Risk Assessment (SFRA), which was updated in 2015. There are a number of sites that intersect with a flood risk zone; however, there will be the potential to avoid areas of flood risk (i.e. leave land undeveloped), and also design in Sustainable Drainage Systems to improve surface water run-off and infiltration (as has generally been highlighted by the SFRA Level 2 work, completed in 2016, which examines sites supported through the LAA in detail). Three of the site specific policies for strategic allocations reference flood risk, with the policy for Land South of Elmbridge Road and the High Street, Cranleigh notably stating: “Built development should be focused on that part of the site at low risk of flooding (Flood Zone 1). A Flood Risk Assessment will be required given that part of the site lies within an area of identified high and medium flood risk. The Flood Risk Assessment and mitigation measures will be required to demonstrate safe access and egress from the site.”

10.11.5 GIS analysis (see Appendix IV) highlights that -  18% of LAA sites intersect flood zone 2, compared to 16.5% of non-LAA sites  8% of LAA sites intersect flood zone 2 by more than 25%, compared to 10% of non-LAA sites; and  Four LAA sites (0.5%) intersect flood zone 2 by more than 50%, compared to 17 (7%) non- LAA sites. – One of the four sites - the Bush Hotel, the Borough, Farnham (ID 285) - does not intersect flood zone 3, and hence is suitable on this basis. – Conversely, the other three sites - Land rear of 48-58 Church Road, Milford (ID 94); Victoria House, South Street, Farnham (ID 264); and Land at St Nicholas C of E School, Parsonage Road, Cranleigh (ID 383) - intersect flood zone 3 as well as flood zone 2. The latter site is particularly constrained (62% flood zone 3), and hence allocation would certainly necessitate the exception test being passed.

Commentary on other policies

10.11.6 Policy NE2 (Green and Blue infrastructure) seeks to prevent pollution of the water environment through creating / retaining undeveloped buffer zones around all main rivers and ordinary water courses. Although this will be likely to have a positive effect in terms of shading and shelter in public areas and may have additional benefits with regards to surface water flooding, it is recommended that a more proactive stance is taken for promoting the implementation of Green Infrastructure as part of future development, by requiring that all new development contributes to the extent of trees, woodlands and hedgerows.

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10.11.7 Also of particular note is Policy CC4: Flood Risk Management, which outlines the Council’s aim for reducing flood risk across the borough. It states: “Sustainable drainage systems (SuDS) will be required on major developments and encouraged for smaller schemes. A site- specific Flood Risk Assessment will be required for sites within or adjacent to areas at risk of surface water flooding as identified in the SFRA. Proposed development on brownfield sites should aim to reduce run off rates to those on greenfield sites. There should be no property or highway flooding, off site, for up to the 1 in 100 year storm return period, including an allowance for climate change”. This policy is likely to lead to positive effects through implementation of such SuDs schemes. It was recommended that the policy be strengthened through also requiring SuDs for smaller developments and that the required run- off rates are quantified (e.g. no worsening of run-off rates), and as a result the policy has been amended to clarify that large sites means those of 10 dwelling and above.

Appraisal of the draft plan as a whole

10.11.8 The broad strategy performs well in terms of water quality / water resources, on the assumption that the necessary infrastructure can be delivered to support a new settlement at Dunsfold Aerodrome. With regards to flood risk, it is apparent that this has been taken into account as a constraint, and that where sites intersect an area of flood risk then steps will be taken through layout and design - informed by a Flood Risk Assessment - to minimise risk.

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PART 3: WHAT HAPPENS NEXT?

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11 INTRODUCTION (TO PART 3)

11.1.1 The aim of this chapter is to explain next steps in the plan-making / SA process.

12 PLAN FINALISATION

12.1.1 Subsequent to publication stage, the main issues raised will be identified and summarised by the Council, who will then consider whether the plan can still be deemed to be ‘sound’. Assuming that this is the case, the plan (and the summary of representations received) will be submitted for Examination. At Examination a government appointed Planning Inspector will consider representations (in addition to the SA Report and other submitted evidence) before determining whether the plan is sound (or requires further modifications).

12.1.2 If found to be ‘sound’ the plan will be formally adopted by the Council. At the time of Adoption an ‘SA Statement’ will be published that sets out (amongst other things) ‘the measures decided concerning monitoring’.

13 MONITORING

13.1.1 At the current time, there is a need only to present ‘measures envisaged concerning monitoring’.

13.1.2 The draft plan document includes a range of proposed monitoring indicators, with each indicator attached to a specific policy. Most indicators relate to whether / how often / to what extent the policy is implemented, rather than the ‘state’ of the baseline; however, there are some limited instances of proposals to monitor baseline information, notably:  Air quality within AQMAs to assess any potential negative effects of increases in road traffic.  The level of need for pitches identified within the latest Gypsy and Traveller Accommodation Assessment or Housing Need Study; and the number of unauthorised and illegal Gypsy/Traveller encampments or developments, and enforcement actions carried out within the Borough per annum.  Employment Land supply against demand.  Percentages of retail, leisure, culture and business space within defined primary and secondary shopping centres; and the percentage of vacant retail premises.  Provision of open space, sports, recreation and cultural facilities.  Achievement of the Surrey Hills AONB Management Plan.  Protection of heritage assets and heritage assets at risk.  Extent of areas of biodiversity importance; and quality of SSSIs and SNCIs and other areas of biodiversity importance against national, county and local targets identified in Surrey Biodiversity Action Plan.  Air quality across borough and at European sites likely to be affected by development.

13.1.3 Some of these indicators respond to the impacts highlighted through SA (e.g. effectiveness of the Surrey Hills AONB Management Plan) and HRA (e.g. Air quality at European sites likely to be affected by development). However, there is the potential to further develop the monitoring framework. In particular, consideration should be given to the possibility of site specific monitoring indicators, in particular in relation to Policy SS7: New settlement at Dunsfold Aerodrome, where movement/transport patterns could justify monitoring. Also, the matter of traffic congestion (and possibly also uptake of sustainable transport options / modal shift away from car dependency) in Farnham could be a worthy focus of monitoring effort.

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APPENDIX I - REGULATORY REQUIREMENTS

As discussed in Chapter 2 above, Schedule 2 of the Environmental Assessment of Plans Regulations 2004 explains the information that must be contained in the SA Report; however, interpretation of Schedule 2 is not straightforward. Table A links the structure of this report to an interpretation of Schedule 2 requirements, whilst Table B explains this interpretation.

Table A: Questions answered by this SA Report, in-line with an interpretation of regulatory requirements

Questions answered As per regulations… the SA Report must include…

 An outline of the contents, main objectives of the What’s the plan seeking to achieve? plan and relationship with other relevant plans and programmes

 Relevant environmental protection objectives, established at international or national level What’s the sustainability ‘context’?  Any existing environmental problems which are relevant to the plan including those relating to any

areas of a particular environmental importance

 Relevant aspects of the current state of the environment and the likely evolution thereof without What’s the SA implementation of the plan Introduction scope? What’s the sustainability  The environmental characteristics of areas likely to ‘baseline’? be significantly affected  Any existing environmental problems which are relevant to the plan including those relating to any areas of a particular environmental importance

What are the key issues  Key environmental problems / issues and objectives and objectives that that should be a focus of (i.e. provide a ‘framework’ should be a focus? for) assessment

 Outline reasons for selecting the alternatives dealt with (and thus an explanation of the ‘reasonableness’ of the approach)  The likely significant effects associated with What has plan-making / SA involved up Part 1 alternatives to this point?  Outline reasons for selecting the preferred approach in-light of alternatives assessment / a description of how environmental objectives and considerations are reflected in the draft plan

 The likely significant effects associated with the draft plan What are the SA findings at this current Part 2 stage?  The measures envisaged to prevent, reduce and offset any significant adverse effects of implementing the draft plan

Part 3 What happens next?  A description of the monitoring measures envisaged

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Table B: Questions answered by this SA Report, in-line with regulatory requirements

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Whilst Tables A and B signpost broadly how/where this report meets regulatory requirements. As a supplement, it is also helpful to present a discussion of more precisely how/where regulatory requirements are met - see Table C.

Table C: ‘Checklist’ of how (throughout the SA process) and where (within this report) regulatory requirements have been, are and will be met. Regulatory requirement Discussion of how requirement is met

Schedule 2 of the regulations lists the information to be provided within the SA Report a) An outline of the contents, main objectives of the Chapter 3 (‘What’s the plan seeking to achieve’) plan or programme, and relationship with other presents this information. relevant plans and programmes; b) The relevant aspects of the current state of the These matters were considered in detail at the environment and the likely evolution thereof scoping stage, which included consultation on a without implementation of the plan or programme; Scoping Report. The Scoping Report was updated post consultation, and is available on the website. c) The environmental characteristics of areas likely to be significantly affected; The outcome of scoping was an ‘SA framework’, and this is presented within Chapter 4 (‘What’s the scope d) Any existing environmental problems which are of the SA’) in a slightly updated form. relevant to the plan or programme including, in Also, more detailed messages from the Scoping particular, those relating to any areas of a Report - i.e. messages established through context particular environmental importance, such as areas and baseline review - are presented (in an updated designated pursuant to Directives 79/409/EEC and form) within Appendix II. 92/43/EEC.; e) The environmental protection, objectives, The Scoping Report presents a detailed context established at international, Community or national review, and explains how key messages from the level, which are relevant to the plan or programme context review (and baseline review) were then and the way those objectives and any refined in order to establish an ‘SA framework’. environmental, considerations have been taken The SA framework is presented within Chapter 4 into account during its preparation; (‘What’s the scope of the SA’). Also, messages from the context review are presented within appendix II. With regards to explaining “how… considerations have been taken into account” -  Chapters 6 explains how reasonable alternatives were established in 2015/16 in-light of earlier consultation/SA.  Chapter 8 explains the Council’s ‘reasons for supporting the preferred approach’, i.e. explains how/why the preferred approach is justified in-light of alternatives appraisal (and other factors).  Chapter 10 provides examples of how findings and recommendations from appraisal of a working draft plan have been taken into account.

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Regulatory requirement Discussion of how requirement is met f) The likely significant effects on the environment,  Chapter 7 presents alternatives appraisal findings including on issues such as biodiversity, (in relation to the spatial strategy, which is the population, human health, fauna, flora, soil, water, ‘stand-out’ plan issue and hence that which should air, climatic factors, material assets, cultural be the focus of alternatives appraisal/ consultation). heritage including architectural and archaeological heritage, landscape and the interrelationship  Chapters 10 presents the Draft Plan appraisal. between the above factors. (Footnote: These As explained within the various methodology effects should include secondary, cumulative, sections, as part of appraisal work, consideration has synergistic, short, medium and long-term been given to the SA scope, and the need to permanent and temporary, positive and negative consider the potential for various effect effects); characteristics/dimensions. g) The measures envisaged to prevent, reduce and Chapter 10 provides examples of how as fully as possible offset any significant adverse recommendations from appraisal of a working draft effects on the environment of implementing the plan have been taken into account. plan or programme; At the current time, the appraisal identifies how the plan might potentially ‘go further’ in certain respects, and makes a number of specific recommendations. h) An outline of the reasons for selecting the Chapters 5 and 6 deal with ‘Reasons for selecting alternatives dealt with, and a description of how the the alternatives dealt with’, in that there is an assessment was undertaken including any explanation of the reasons for focusing on particular difficulties (such as technical deficiencies or lack of issues and options. know-how) encountered in compiling the required Also, Chapter 8 explains the Council’s ‘reasons for information; selecting the preferred option’ (in-light of alternatives appraisal). Methodology is discussed at various places, ahead of presenting appraisal findings, and limitations are also discussed as part of appraisal narratives. i) description of measures envisaged concerning Chapter 13 presents measures envisaged monitoring in accordance with Art. 10; concerning monitoring. j) a non-technical summary of the information The NTS is a separate document. provided under the above headings

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Regulatory requirement Discussion of how requirement is met

The SA Report must be published alongside the draft plan, in-line with the following regulations authorities with environmental responsibility and the An Interim SA Report, essentially presenting public, shall be given an early and effective opportunity information on alternative spatial strategies within appropriate time frames to express their opinion (‘scenarios’), was published as part of the ‘Potential on the draft plan or programme and the accompanying Housing Scenarios’ consultation in 2014, under environmental report before the adoption of the plan or Regulation 18 of the Local Planning Regulations. programme (Art. 6.1, 6.2) At the current time, the SA Report is published alongside the Proposed Submission Plan, under Regulation 19, so that representations might be made ahead of submission.

The SA Report must be taken into account, alongside consultation responses, when finalising the plan.

The environmental report prepared pursuant to Article The Council has taken into account the Interim SA 5, the opinions expressed pursuant to Article 6 and the Report (2014), alongside consultation responses results of any transboundary consultations entered received, when finalising the plan for publication. into pursuant to Article 7 shall be taken into account Appraisal findings presented within this current SA during the preparation of the plan or programme and Report will inform a decision on whether or not to before its adoption or submission to the legislative submit the plan, and then (on the assumption that procedure. the plan is submitted) will be taken into account when finalising the plan at Examination (i.e. taken into account by the Inspector, when considering the plan’s soundness, and the need for any modifications).

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APPENDIX II - CONTEXT AND BASELINE REVIEW

Introduction

As discussed in Chapter 4 (‘What’s the scope of the SA?’) the SA scope is primarily reflected in a list of objectives (‘the SA framework’), which was established subsequent to a review of the sustainability ‘context’ / ‘baseline’, analysis of key issues, and consultation. The aim of this appendix is to present a summary key issues emerging from context / baseline review.

Overview Waverley Borough, which has a population of 121,272 , is located in the southwest corner of Surrey. It is predominantly rural and extends to some 345 sq. km. (133 sq. miles). The Borough contains four principal urban settlements of varying size, with about 72% of the population living in one of these centres, plus a large number of villages of varying size and character. Altogether, there are 21 separate town or/ parish councils. Farnham is the largest settlement, having a population of approximately 39,000. Farnham is relatively unconstrained by the national landscape designations and the Metropolitan Green Belt; however, it is constrained in other respects, e.g. given proximity to the Thames Basin Heaths Special Protection Area (SPA), a high quality historic core, valued open spaces and low density residential areas with a distinct character. Functionally, it has links with centres outside Waverley, including Guildford, Aldershot and Farnborough. Godalming has a population of approximately 22,000. The size and range of services is less than Farnham, and it is significantly influenced by Guildford, which is approximately 10km away via good road and rail links. As the second largest settlement, there are arguments in favour of growth; however, the town is heavily constrained by the Metropolitan Green Belt, its geography (the town straddles the River Wey, and is virtually surrounded by wooded hillsides) and its historic character (with five conservation areas in and around the town Haslemere, which has a population of approximately 17,000, lies in the rural southwest corner of the borough, but like Godalming has good road and rail links. Haslemere is less constrained than Godalming in terms of the Metropolitan Green Belt, but is constrained by the nationally important Surrey Hills Area of Outstanding Natural Beauty (AONB). It is surrounded by wooded hillsides and accessible high quality countryside, with the South Downs National Park to the south of the town. The town has a large rural catchment, which extends into adjoining counties. Cranleigh has a population of approximately 11,000. Located in the rural southeast of the borough, it has a good range of services for a settlement of its size, with a large green common area extending into the centre and a shopping area that is notable for being attractive and pedestrian friendly.

Biodiversity There are three Special Protection Areas (SPAs) designated under the European Birds Directive as being of European importance for their populations of the woodlark, nightjar and Dartford warbler: Thursley, Hankley and Frensham Commons (also known as Phase I of the Wealden Heaths SPA), the Hindhead Commons (which form part of Phase II of the Wealden Heaths SPA) and a small part of the Thames Basin Heaths SPA. Only 80 hectares of the Thames Basin Heaths SPA lies within Waverley, to the north of Farnham, but its zone of influence extends 5km from its boundary and therefore affects development in most of Farnham. The Thames Basin Heaths Avoidance Strategy sets out the Council’s approach in seeking to avoid the effect of a net increase in population from new housing developments within 5km of the SPA, and how it proposes to discharge its legal obligations under the Conservation of Habitats and Species Regulations 2010. Less formal strategies are also in place to ensure appropriate mitigation of impacts to the other two SPAs. Some of the areas of SPA are also designated as a Special Area of Conservation (SAC) under the European Habitats Directive and/or as an internationally important wetland under the Ramsar convention. Also, a range of other sites are designated as a nationally important Site of Special Scientific Interest (SSSI) or locally important Site of Nature Conservation Importance (SNCI). SNCI are Surrey’s local sites of nature conservation importance, elsewhere known as Local Wildlife Sites. These are recommended for protection within the planning system by an appointed panel of biodiversity experts and then adopted in local development plan plans.

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Waverley’s landscape has a distinctive wooded character, representing 31% of its total area. 11.5% of this woodland is classified as Ancient Woodland, and this constitutes the largest area of this type of woodland in Surrey. Canals and river corridors are also of particular biodiversity value in Waverley, with the River Wey and its tributaries, the Wey and Arun Canal, the River Wey and Godalming Navigations, and the River Blackwater all of ‘multifunctional’ value. Finally, there is a need to explain that work undertaken by the Surrey Biodiversity Information Centre, and coordinated by Natural England, has identified a network of Biodiversity Opportunity Areas (BOAs) across Surrey that feature, at their cores, high concentrations of important wildlife habitats formerly selected as significant sites for nature conservation. Where appropriate, Surrey’s BOAs link with those identified in neighbouring counties to form a South East regional network.

Climate change mitigation The Government has set a target under the Climate Change Act 2008 to reduce CO2 emissions by 80% by 2050, with an interim target of 34% by 2020, both against a 1990 baseline. The Government requires local planning authorities to adopt proactive strategies to mitigate and adapt to climate change and reduce the consumption of natural resources. For example, the impact of new development on climate change can be reduced by locating it where possible in places where it is not entirely necessary to rely on having access to a car; and by the design of carbon neutral homes which seek to achieve energy and water efficiency through sustainable construction and by increased use of renewable energy. The Climate Change Strategy of the Surrey Transport Plan (2011-2026) sets a target of 10% reduction in CO2 emissions by 2020 increasing to 25% reduction by 2035 on 2007 levels. The Council is therefore working in partnership with Surrey County Council to reduce the need to travel, encourage alternative forms of transport to the car and reduce emissions. This links to the need to tackle air pollution. With regards to ‘sustainable design and construction’, the Local Plan’s role is more limited, following Government’s withdrawal of the Code for Sustainable Homes in March 2015. There is, however, the potential to minimise carbon emissions from the built environment by supporting decentralised, low carbon heat and electricity generation/transmission. A report by TV Energy and RPS indicates that there is low potential for Combined Heat and Power and distributed heat systems in Waverley following a heat mapping exercise of the region. What potential there may be is more likely to occur in the larger settlements of the Borough or larger high density developments, industrial parks or leisure centres.

According to government statistics, Waverley’s total per capita CO2 emissions in 2012 were the second lowest in Surrey and below both the county average and England as a whole. However, relative to the national picture the borough performs less well, with high car ownership particularly notable.

Community and well-being The 2015 Indices of Multiple Deprivation shows that Waverley is the 4th least deprived area in the whole of Britain. Waverley’s affluence is also demonstrated by high house prices, high incomes, households with more than two cars and a relatively high proportion of children who attend private schools. However, there are identified small pockets of relative deprivation, typically in medium-sized housing estates on the periphery of the main settlements. Also, some rural areas however, are 'deprived' in terms of barriers to housing (given affordability issues). The Borough does not score very well either in some parts on access to services such as supermarkets, secondary schools, libraries, doctors and banks, again because of the rural character of the area. The juxtaposition of low-income communities with neighbouring affluent areas - and the associated costs of living in Waverley - means that the problem of relative disadvantage remains challenging. Waverley has an ageing population, with a relatively high proportion of people above retirement age. In 2011, 19.5% of Waverley's population was over 65, compared with the national figure of 16%. In-line with national forecasts, a significant percentage increase is forecast in the number of people over 65 and over 85 and could mean that potentially by 2032, 27% of Waverley's population will be over 65, and 6% over 85. Waverley has adopted an Ageing Well Strategy 2015-2018 to try to address some of the associated issues. Some 96% of the borough’s resident population is white, with the remaining 4% made up from a mix of other ethnic groups. Between the years 2002 and 2015, some 905 Overseas Nationals registered for National Insurance numbers in Waverley. 59% of this group came from Eastern European countries. There is a relatively large and long-standing Gypsy and Traveller community in Waverley.

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Waverley is generally a healthy borough, with 86% of the population reporting their health was ‘very good or good’ in the 2011 Census. The Borough is well served by doctor’s surgeries; however, some village residents do need to travel by car to access their nearest health facility; and the Accident and Emergency facilities at the Royal Surrey County Hospital in Guildford and the Frimley Park Hospitals are remote from some areas. Waverley has some 41 primary schools across the borough, particularly in the more urban areas, and each of the four main settlements has at least one secondary school. Historically there have been capacity issues at some of these schools, and in Farnham there is continuing pressure on secondary places. There are also opportunities for further education in the sixth form colleges in Farnham and Godalming; and Farnham is the location of the University for the Creative Arts, which has over 2,000 students at the Farnham Campus. The countryside in Waverley is highly accessible, with large areas of common land across the borough, and an extensive network of public rights of way. Frensham Common and the Hindhead Commons, including the Devil’s Punchbowl, are visited by large numbers of people. Visitor numbers to the latter have increased significantly since the rerouting of the A3 via the Hindhead Tunnel. Recreation facilities include the Council's own sports centres which include a swimming pool, in each of the four main settlements, sports pitches and many public and private schools which hire out their leisure facilities to community organisations. There are also a number of private health and fitness clubs and many well-used village and church halls in both towns and villages. Cultural and artistic activities in Waverley are mainly provided by the voluntary and private sectors at venues such as the Cranleigh Arts Centre, the Farnham Maltings, the University for the Creative Arts, the borough Hall in Godalming, and the Haslemere Hall. A multi-screen cinema in Farnham has planning approval.

Economy Waverley has a buoyant economy, with low unemployment. Its business base is dominated by small and medium enterprises, with only 15 large enterprises employing 250 or more people. The Borough has a highly qualified resident population with 40% of residents aged 16 and over holding Level 4 qualifications and above (significantly higher than the Surrey average of 36%), and this is reflected in the nature of local employment. The largest employment site is Dunsfold Park where there are some 100 companies. Some 43% of the resident workforce travels outside Waverley to their place of work, while some 32% both live and work in Waverley. There are also many people who work in Waverley but live outside the borough, due in part, to the high house prices. Over 26,000 people commute into Waverley each day. Waverley’s towns tend to compete with those outside the borough rather than with each other, due to the dispersed geography of the borough and the indirect links between the towns. Guildford draws custom from all four towns, but other competitors include Aldershot, Farnborough, Camberley, Basingstoke and Fleet to the northwest, Midhurst and Petworth to the south, Petersfield and Alton to the southwest, and Horsham and Dorking to the southeast and east respectively. In addition, Waverley hosts a broad range of small rural businesses which need to adapt continually to changing demand. Broadband access is a key economic priority for these businesses and business start-ups. Currently some 93% of premises in Waverley can access Next Generation Access (NGA) download speeds of 15mbps or more; and the aim is to increase this to 94% by 2018 (with the County-wide goal 97% by 2018). There are some 15 hotels in the borough, 12 of which are located in Farnham, Godalming and Haslemere. With the exception of the Hindhead Commons and the Devil’s Punchbowl there are no major visitor attractions in the borough; however, visitors to the towns and villages play a significant part in the local economy. A picture of the policy context and baseline situation, in respect of the local economy, can be gained most clearly from the following studies -  The Waverley Economic Strategy 2015-2020 concludes by establishing a series of ‘objectives’, with the following of particular note - – ‘Safeguard and enhance the borough’s attractive character and high quality of life’ - The discussion under this objective focuses on maintaining the attractiveness of towns (with reference to heritage), also making reference to environmental assets; and does not identify growth related opportunities. – ‘Manage employment growth and continue to encourage higher skilled and well paid jobs’ - The discussion explains that accelerating employment growth/diversification is not a priority, although opportunities for new employment at Dunsfold Aerodrome could be explored.

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– ‘Provide affordable housing for key workers’ - In this regard, there is a need to provide housing at existing settlements, particularly in the west of the borough.  The ELR, authored by Atkins, considers three employment growth scenarios: Scenario 1 is based on the outputs of econometric forecasts from Experian (March 2015); Scenario 2 assumes that recent trends (1997-2013) will continue; and Scenario 3 assumes that the Economic Strategy objectives are implemented, which in practice means that past trends are assumed to continue, but with some extra shift away from traditional employment sectors and toward less land intensive sectors. The ELR concludes that: “On balance, Scenario 3 appears to be the most realistic, aligning with both historical trends and Waverley Council’s strategic priorities as outlined in the Economic Strategy. It projects small levels of employment growth, with most of the growth coming from outside the core B use class sectors – and therefore resulting in little additional B use class floorspace and land requirements. Scenario 3 is also aligned to the EM3 LEP’s strategy which does not specifically target the borough or its towns for economic growth...” With regards to Scenario 1, the ELR concludes that: “The Experian- based scenario forecasts significant levels of employment growth that do not align with historical trends or Waverley Borough Council’s vision of managed growth, as outlined in the Economic Strategy. In total, Experian’s forecasts suggest a 21% employment increase across all sectors over the period to 2033. This is considered unrealistic considering the borough’s historically low growth levels, the limited availability of additional employment land, and the Council’s continued focus on managing employment growth levels so that they do not adversely affect the borough’s attractive environment, and high quality of life.”  The ELR conclusions are also supported by GL Hearn, the authors of the SHMA, who are confident in dismissing the Experian scenario. The SHMA assumes a lower employment growth scenario (i.e. one broadly in line with past trends and the Economic Strategy) and on this basis concludes that there is not a need to deliver new homes in Waverley, over-and- above those needed to meet demographic needs etc., in order to house workers. Conversely, the SHMA concludes that there is a need to deliver additional housing, over-and-above demographic needs etc., in Guildford and Woking in order to ensure sufficient local workforce (and avoid unstainable commuting).

Heritage and townscape Waverley has a rich historic heritage, with 43 Conservation Areas, some 1800 listed buildings and 590 Buildings of Local Merit. In addition, there are 23 Scheduled Ancient Monuments, together with 11 County defined Sites of Archaeological Importance. There are also 8 Historic Gardens, including Farnham Park. West Surrey contains a substantial number of works from England's best known architects. Many such examples are in Waverley, built during the nineteenth century for wealthy middle class families seeking country houses. These were the clients for whom the Gothic Revival and later local Arts and Crafts architects, such as Edwin Lutyens, and Harold Falkner designed. The value of the vernacular architecture of the area became apparent at this time and local materials such as Bargate stone and timber framing contribute much to the character of Waverley today, parts of which can be said to be the epitome of the West Surrey vernacular. Many of the residential parts of Waverley have a distinct semi-rural character. Haslemere and Godalming have wooded hillsides surrounding them, while in Cranleigh there is a much more rapid transition from urban to rural, with common land extending into the heart of the shopping centre. The southern entrances to Farnham have retained their green aspect with the help of long-standing planning policies. A number of the villages as well as Farnham and Haslemere have produced Design Statements, which seek to identify the principles, design features and quality standards that they value.

Housing Waverley is an area of high demand for housing, with house prices in the area higher than the South East average and almost twice the national average. The 2015 Strategic Housing Market Assessment (SHMA) shows that the affordability of property in the housing market area - which also includes Guildford and Woking - has worsened quite markedly over the past 15 years and that affordability pressures have been consistently more acute in Surrey than in the wider South East. Furthermore, evidence on median house prices and median incomes in the SHMA suggests that in Waverley this is not just an issue for the lower end of the market as moving home may be more difficult than first time buying. It is also necessary to recognise the specific accommodation and housing needs of different groups in the local community. Further discussion of SHMA findings is presented in Box 6.4 of the main report, above.

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Landscape The distinctive natural environment in Waverley is generally of a very high quality. Approximately 61% (21,000 hectares) lies within the Metropolitan Green Belt and 31% (10,624 hectares) is designated as Rural Areas Beyond the Green Belt. 78% of the borough’s countryside is also designated as an Area of Outstanding Natural Beauty (AONB) and/or Area of Great Landscape Value (AGLV). The geology of the borough is varied. The Surrey Landscape Assessment 2015: Waverley Borough has detailed profiles of the various character areas. Much of the northern and western part of the borough is made up from Cretaceous Greensand Hills, while the southern part is underlain by the Wealden Clay. Haslemere is highly sensitive, as it is surrounded by the AONB on three sides and the South Downs National Park on the fourth, with only small parcels of land falling outside these nationally designated landscapes. Land to the north and east is also within the Green Belt, and has been found by the recent review to be contributing to Green Belt purposes. Godalming is constrained by the AONB to the east, with other areas around the town designated as AGLV; also, virtually all land surrounding Godalming is part of the London Green Belt, with the recent Green Belt Review only recommending three relatively small areas (two to the north, and one to the west) for removal from the Green Belt (plus another area to the south east was considered closely, but ultimately not recommended for removal). Milford and Witley are ‘washed-over’ by the Green Belt, and constrained to the west by the AONB; however, the Green Belt Review identified some capacity, specifically recommending that the villages should be ‘in-set’ from the Green Belt and that the boundary should not necessarily extend up to the existing urban edge.

Soils and other natural resources

Much of Waverley’s agricultural land is shown by the ‘Agricultural Land Classification - Provisional” dataset (available at magic.gov.uk) to be Grade 3, with smaller areas of lower quality Grade 4 land and just three small patches of higher quality Grade 2 land. There is no Grade 1 (i.e. highest quality) agricultural land.

The “Provisional” dataset is very low resolution, and does not differentiate between Grades 3a and 3b; an important consideration as the National Planning Policy Framework classifies Grades 1, 2 and 3a agricultural land as ‘best and most versatile. In order to establish agricultural land quality with any certainty there is a need to undertake field level survey using the “post 1988 criteria”; however, within Waverley survey data is available for very few sites (and none that are likely in contention for allocation).

Traffic and transportation The main road connections in Waverley are north-south, with relatively poor connections east-west. There are no motorways within the borough and the only national trunk road is the section of the A3 between Grayshott and Milford which includes the Hindhead Tunnel. Many of Waverley's residents work outside the borough and use the A3 to gain access to Guildford and beyond. Much of Waverley's road network is rural and narrow and therefore unsuitable for heavy goods vehicles. The safe accommodation of heavy goods traffic is on the principal through routes namely the A31, A281, A283, A286, A287 and A325) and its impact on communities through which these roads pass, presents a continuing challenge. In common with much of Surrey, many of Waverley’s main roads are heavily-trafficked, especially in the morning and evening peak periods. The most significant delays and congestion occur in and around Farnham (A31, A325 and A287 including the town centre), Cranleigh (A281/B2130/B2127) and Bramley (A281). In terms of rail links, Farnham is on the London to Alton line; with Farncombe, Godalming, Milford, Witley and Haslemere all on the London to Portsmouth line. Cranleigh does not have a rail link and there are no direct east-west rail links in the borough. Waverley’s railway lines are heavily used, and there is growing concern from users about the current and future capacity of the trains. The railway is also a source of local road congestion at the level crossing in Farnham Station. Bus services are relatively frequent within the main urban areas, but services are more patchy and infrequent in rural areas, with services generally reduced at evenings and weekends. Buses across Waverley are at capacity at school travel times.

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The limited bus service in Waverley in rural areas and at off-peak times, has an impact on accessibility for residents, particularly those without access to a car, to jobs, services and facilities such as shops, schools and colleges, health services and leisure and recreational facilities. A picture of the policy context and baseline situation, in respect of the transport and traffic, can be gained most clearly from the following studies -  Transport Assessment (TA): Scenarios for the Distribution of Housing Growth - Stages 1, 2, 3 and 4 Reports (Mott MacDonald, February 2016 – June 2016) - Stage 1 of the TA is a scoping stage, and then: Stage 2 focuses on traffic at key junctions along the A281 corridor under housing growth scenarios, taking account of mitigation (e.g. road upgrades); Stage 3 focuses on traffic in Farnham under housing growth scenarios, taking account of mitigation; and Stage 4 focuses the potential for modal shift away from car dependency at Farnham, Cranleigh and Dunsfold Aerodrome.  Waverley Local Plan Strategic Highway Assessment (SHA) (Surrey County Council, 2016) - The SHA examines traffic flows under five scenarios (one “do-minimum” and four “do-something”). The most detailed scenario is Scenario 5, which accounts for development of all (or at least most) LAA sites plus a 2,600 home scheme at Dunsfold Aerodrome - i.e. a scenario close to Option 4 - plus a range of strategic highways mitigation measures. Also of relevance are Scenarios 2, 3 and 4, which assume the same growth strategy (LAA sites plus 2,600 homes at Dunsfold Aerodrome) but with less mitigation. The SHA conclusion is that: “This strategic assessment indicates that with mitigation the residual impact of [planned growth] is not considered severe in terms of the National Planning Policy Framework guidance, with the possible exception of the effect on the A3.”

Water, flood risk and other climate change adaptation issues Rivers flowing through the borough include the River Wey and Cranleigh Water. The North Wey (a chalk river until Farnham) flows from Alton to Tilford, and joins the borough at Wrecclesham. The South Wey flows from Haslemere to Tilford and the combined Wey from Tilford to Godalming. The Cranleigh Waters flows from Cranleigh to Bramley. In addition to the main watercourses, there are a number of smaller tributaries, as well as the partially-restored Wey and Arun canal that passes through the south-east of the borough. Flood risk in Waverley originates from a number of sources - rivers, surface water, sewers, groundwater and artificial water bodies. Although a greater emphasis is placed on flooding from rivers, surface water flooding and groundwater emergence are the other main sources of flood risk. The Level 1 Strategic Flood Risk Assessment (SFRA) for Waverley (2010) has been updated for the new Local Plan. In keeping with the NPPF and its accompanying Technical Guidance (Flood Risk and Coastal Change Planning Practice Guidance [PPG]), the updated assessment’ objectives were to – • Identify the extent of all Flood Zones; • Identify areas at risk of flooding from all flood sources present in the study area, providing the Council with the tools required to apply the Sequential Test; • Provide evidence-based reports to inform the preparation of the Local Plan regarding potential flood risk and which are also suitable to inform the Sustainability Appraisal of related documents; • Advise on suitable policies to address flood risk management in a consistent manner across its administrative area; • Advise on the requirements of site specific flood risk assessments based on local conditions and policy recommendations; • Advise on the principles, objectives and applicability of Sustainable Drainage Systems (SuDS) throughout the study area; and • Present information to inform the Council of the flood considerations necessary in developing and progressing flood emergency planning. The Environment Agency’s classification of water stressed areas (2013 update) confirmed that all three water companies that serve Waverley have serious water stress issues. Combined with higher than average levels of water consumption in the borough, this emphasises the local importance of water minimisation. The status of water resources within Waverley is classified within the Environment Agency’s Wey Catchment Abstraction Licensing Strategy (2012). This shows that, at low flow levels, part of the catchments have either restricted or no water availability for abstraction. Average water usage in Waverley in 2008-09 was estimated to be 160-170 litres per person per day across three different water companies. Changes to the Building Regulations in April 2010 required a whole building standard of 125 litres per person per day. National Planning Practice Guidance (Para 014; revised March 2015) states that, where there is clear local need, Local Plan policies can require new dwellings to meet the tighter Building Regulations option of 110 litres per person per day. Sources of evidence of local need include the Environment Agency’s Water Stressed Areas classification.

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APPENDIX III - ALTERNATIVES FOR THEMATIC PLAN ISSUES

Introduction As explained within Chapter 5 above, a decision was taken in 2016 to focus formal alternatives appraisal work on the ‘the spatial strategy’, without formally appraising alternatives in relation to other, thematic plan issues. The aim of this Appendix is to demonstrate that this approach was justified and ultimately ‘reasonable’. This appendix discusses each of the policy areas / issues covered by the Proposed Submission Plan.  For some issues it is clearly the case that there is little to be gained from formal alternatives appraisal - i.e. formal alternatives appraisal would clearly not be proportionate. These plan issues are discussed only briefly below.  For other issues there is a need to explore the issues closely before the conclusion can be reached that there is no strategic choice being made that warrants formal alternatives appraisal. For example, more detailed discussions are presented in relation to Gypsies and Travellers and employment land. Of course, the information presented within this appendix is supplemented by the detailed appraisal findings presented in relation to the Draft Plan, as presented within Part 2. As part of the appraisal, presented within Part 2, all proposed policy approaches are appraised against the baseline (i.e. the ‘do nothing option’).

Sustainable transport Chapter 7 of the Draft Plan presents policy in relation to “sustainable transport”, recognising that achievement of transport objectives is a challenge in a rural Borough like Waverley, but that there are considerable opportunities relating to the location of development, supporting rural transport initiatives, requiring travel plans and encouraging walking, cycling, car sharing and the use of public transport. The proposed policy (Policy ST1) presents a brief policy statement for nine specific issues in turn. Amendments to specific policy statements might be envisaged; however, it is not clear that there are strategic choices to be made. The scope for alternative policy is constrained by national policy (see discussion of the NPPF within the supporting text), regional policy (e.g. see discussion of the Surrey Transport Plan) and technical evidence (e.g. the Surrey Strategic Highways Assessment, SHA). Formal alternatives appraisal was not warranted.

Infrastructure and community services Chapter 8 of the Draft Plan presents policy in relation to “infrastructure and community services”, recognising that housing growth (and an ageing population) will lead to capacity issues, and hence infrastructure to meet social, economic and environmental needs will need to be provided. The proposed policy (Policy ICS1) presents a brief policy statement for five specific issues in turn. It is difficult to envisage an alternative strategic ‘thrust’ that might be taken to the policy, and whilst amendments to specific policy statements might be envisaged, it is not clear that there are strategic choices to be made. An alternative policy approach with less of an emphasis on SANG provision might be envisaged; however, it is not clear that any such policy could be considered ‘reasonable’, given the need to adhere to the findings of Habitats Regulations Assessment (HRA; the means of ensuring ‘no significant adverse effects’ on the SPAs). Equally, an alternative policy approach with an increased emphasis on specific types of infrastructure (e.g. green infrastructure and water infrastructure, given issues discussed in the supporting text); however, additional detail is probably not warranted given that the policy will be implemented alongside an Infrastructure Delivery Plan and Schedule. Formal alternatives appraisal was not warranted.

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Affordable housing on development sites Chapter 9 of the Draft Plan presents policy in relation to affordable housing, recognising that there are currently over 1,500 households on the Council’s Housing Needs Register in housing need; and, of these, about 1,200 households are considered to be in housing need with a local connection. The proposed policy (AHN1) establishes a site size threshold, thereby establishing which development sites will need to provide for affordable housing, and also establishes the proportion of homes at each qualifying site that must be affordable. Alternatives can certainly be envisaged - i.e. a higher/lower site size threshold and/or a higher/lower proportion figure - however, the reasonableness of any alternatives is questionable. The Council’s preferred approach balances the desire to maximise affordable housing delivery, with the need to ensure development viability, taking into account the level of CIL the Council wishes to charge to help fund new infrastructure; and draws on robust evidence. There is no potential to compromise the objective of maximising affordable housing delivery; nor is there any scope to compromise development viability / infrastructure delivery. Also, it is important to note that alternatives were appraised at the ‘Issues and Options’ stage in 2009, with the SA Report published/submitted alongside the Core Strategy (the predecessor of the Local Plan) in 2012 explaining the justification for the preferred approach, in light of alternatives. The 2009 alternatives can now be considered dated, and need not be repeated here.50 Formal alternatives appraisal was not warranted (in 2016).

Rural Exception Sites Chapter 9 of the Draft Plan also presents policy in relation to Rural Exception Sites, recognising that the West Surrey SHMA 2015 shows a net need of 83 new affordable homes per annum from 2013 to 2033 in locations outside the four main settlements of Cranleigh, Farnham, Godalming and Haslemere. The proposed policy (AHN2) is in two parts, with the first part presenting criteria that must be met for affordable housing only schemes to be permitted, and the second part explaining the criteria that must be met if an element of enabling market housing is also to be permitted. As explained within the supporting text: “It is expected that the land provided for affordable housing will be provided at low or nil cost. However, if it can be demonstrated that it is necessary to create additional funds over and above those available from free and low-cost land, to overcome specific constraints, or that the provision of low cost dwellings for local needs is not realistic or practicable without extra subsidy, an element of open market housing may be permitted within an overall scheme… The Council will need to be satisfied that the number of open market dwellings is the minimum necessary to ensure delivery of the scheme.” An alternative can be envisaged whereby there is no allowance for market housing. However, any such approach would be contrary to national policy (NPPF, para 54). Furthermore, there would be little potential to differentiate between these alternatives in terms of sustainability objectives. As long as a policy approach of allowing ‘enabling’ market housing is applied with care, then it will support the primary objective of delivering affordable housing. Formal alternatives appraisal was not warranted.

Housing type and size Chapter 9 of the Draft Plan also presents policy in relation to housing type/size, recognising that the NPPF requires local planning authorities to plan for a mix of housing which takes account of different groups in the community, and that evidence in the SHMA identifies certain groups in Waverley as having particular housing needs (e.g. older people).

50 See discussion within Appendix 4 of the 2012 SA Report; available at: http://www.waverley.gov.uk/downloads/download/574/core_strategy-sustainability_appraisal_reports

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The proposed policy (AHN3) essentially states that a housing mix will be provided for in-line with the SHMA findings; and hence it is difficult to envisage a reasonable alternative. An alternative approach might be envisaged whereby site size thresholds are employed - i.e. policy prescribes housing mix requirements according to site size - however, there would be little potential to differentiate between these alternatives in terms of sustainability objectives. The choice of procedural approach (‘across the board’ requirement vs requirements dependent on site size) must be made in light of practical knowledge, i.e. knowledge of which approach is most likely to deliver the required housing mix. Formal alternatives appraisal was not warranted.

Gypsies, Travellers and Travelling Showpeople Chapter 9 of the Draft Plan also presents policy in relation to Gypsies, Travellers and Travelling Showpeople, recognising that these are two other important groups with specific accommodation needs; and recognising that the Government’s Planning Policy for Traveller Sites (PPTS) requires Councils to identify a five year supply of sites. Within Waverley, there are currently 14 authorised sites and 1 unauthorised site for Gypsies and Travellers. There are also 2 authorised and 1 unauthorised sites for Travelling Showpeople. All except one (The Willows site in Runfold) are privately owned and managed; and all are in countryside locations. A Traveller Accommodation Assessment (TAA) was carried out in 2014, identifying a need for 11 additional pitches for Gypsies and Travellers and 3 Travelling Showpeople plots between 2012-2017. Assuming a growth rate of 3% there is a further requirement for 39 pitches for Gypsies and Travellers and 3 Travelling Showpeople plots from 2017 to 2027. The proposed policy (AHN3) is in two parts: the first part commits to providing for Gypsy and Traveller accommodation through Local Plan Part 2, rather than through this current plan, and specifies broadly the nature of sites that might be suitable; and the second part lists more specific site suitability criteria. The approach of delaying allocations to Local Plan Part 2 is justified on the basis that the Council feels this to be the most expedient way to deliver sites, and also provides sufficient opportunity for sites to be identified through Neighbourhood Plans. As for the matter of broad locations that are suitable, an alternative approach might be envisaged whereby there is explicit support for the provision of Gypsy and Traveller pitches as part of large housing or mixed use developments; however, it is not thought that there are particular opportunities. The only truly large site (e.g. above 500 homes) is Dunsfold Aerodrome, but this is not a particularly suitable location on the basis that there is already a relatively high density of pitches in the Dunsfold area. Formal alternatives appraisal was not warranted.

New economic development Chapter 10 of the Draft Plan presents policy in relation to new economic development, recognising that: on the one hand, it is important that the Local Plan contributes to the economy of the sub region, the region and the nation; whilst on the other hand, growth needs to be balanced against a need to protect the unique character and environment of Waverley. The most critical aspect of the proposed policy (EE1) is the first part, which states: “The provision of development for economic growth to meet the needs of the economy, including at least 16,000 sq. m. of new Use Classes B1a/b (Offices/Research and Development) floorspace, will be delivered through: a) The allocation of sites for additional employment floorspace:  On Land off Water Lane, Farnham in accordance with Policy SS9 of this Local Plan.  On Land at Dunsfold Aerodrome in accordance with Policy SS7 of this Local Plan.  In accordance with relevant saved policies of the Waverley Borough Local Plan 2002 and in Local Plan Part 2: Non Strategic Policies and Sites.”

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Expansion of the existing employment area at Dunsfold Aerodrome, under Policy SS7, should provide 26,000 sqm of new B class employment floorspace; however, not all of this provision will be within Use Classes B1a/b (Offices/Research and Development), and indeed it could transpire that relatively little falls within these use classes, given the location of the site. Rather, it could be that there is a high proportion of B1c/B2 (Light/General Industrial) and B8 (Storage and Distribution). As for Land off Water Lane, Farnham, there is no certainty at this stage regarding the quantity of B-class employment land that will be delivered (under Policy SS9), plus there is uncertainty regarding the type of B- class uses that will be delivered. As such, there is naturally a need to question the strategy, and in particular to ask whether there might be an alternative approach that would provide more certainty regarding the achievement of economic objectives, and in particular more certainty regarding the delivery of “at least 16,000 sq. m. of new Use Classes B1a/b (Offices/Research and Development) floorspace”. An alternative strategy might be envisaged whereby additional sites are allocated (through Local Plan Part 1) for employment or mixed use development; however, in practice it is not clear that this is a reasonable alternative on the basis that -  the Employment Land Review (ELR) has identified an overall surplus of B1c/B2 (light industrial/general industrial) and B8 (storage or distribution) floorspace totalling some 30,500 sq. m., and established that this surplus has the potential to be re-used to meet the demand for office floorspace (see discussion of ‘protecting existing employment land, below); and  opportunities for additional allocations to deliver Use Classes B1a/b are limited, with only one employment site (i.e. site promoted solely for employment use) having been considered and rejected through the LAA.51 Formal alternatives appraisal was not warranted.

Protecting existing employment land Chapter 10 of the Draft Plan also presents policy in relation to protecting existing employment land, recognising that the Employment Land Review (ELR) recommends that the Council safeguards its existing sites for B1a/b and explore opportunities to provide additional B1a/b floorspace from B1c, B2 and B8 uses; whilst equally recommending that the Council safeguards good quality, fit for purpose B1c, B2 and B8 sites to maintain a diverse business base and to respond to any unforeseen future opportunities. The proposed policy (EE2) sets out to achieve this objective, by specifying that “The Council will protect existing employment sites against alternative uses unless it can be clearly demonstrated that there is no reasonable prospect of the site being used for employment use.” There is clearly no alternative approach that might be taken; however, alternative policy approaches might be envisaged in respect of how “no reasonable prospect” must be demonstrated. The proposed approach is that a conclusion of “no reasonable prospect” should be reached taking account a range of factors, but an alternative approach would be for policy to specify quantitative criteria - e.g. the number of weeks that the site has been marketed for. These alternatives could be appraised; however, no substantive conclusion could be reached. It would not be possible to conclude on which procedural approach has greater potential to effectively safeguard employment land, and the alternatives would have few (if any) implications in terms of wider sustainability objectives. Again, the choice of procedural approach must be made in light of practical knowledge of which approach is most likely to deliver the stated objective. Formal alternatives appraisal was not warranted.

Town centres Chapter 11 of the Draft Plan presents policy in relation to town centres, recognising the specific issues that must be addressed when considering town centre planning applications, and recognising that the nature and amount of new development in each centre must be appropriate to its scale, character and role in the local hierarchy.

51 Land adjacent to Manfield Industrial Park; rejected on the basis of its Green Belt location.

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The proposed policy (TCS1) is relatively high-level, in that it is not settlement specific; however, there is little reason to suggest that this flexibility is not appropriate. It will, of course, be possible to apply understanding of locally specific issues when judging planning applications against this policy. Also, it is important to recognise that some key policy decisions - in particular decisions in respect of the extent of primary and secondary frontages in the town centres - will be made through Local Plan Part 2. The other point to note is the proposal to defer the allocation of town centre sites to Local Plan Part 2. This approach is justified by the Council on the basis that are no ‘strategic’ sites in need of early allocation (Local Plan Part 1 only dealing with strategic sites), and that there is a need to provide the opportunity for allocations to be made through Neighbourhood Plans. Formal alternatives appraisal was not warranted.

Local centres Chapter 11 of the Draft Plan also presents policy in relation to local centres, recognising the need to safeguard and consolidate their function. One of roles of the proposed policy approach (TCS2) is to identify the borough’s local centres, which potentially gives rise to consideration of alternatives; however, this is not the case in practice. The hierarchy of centres in Waverley is quite ‘set’. Formal alternatives appraisal was not warranted.

Neighbourhood and village shops Chapter 11 of the Draft Plan also presents policy in relation to neighbourhood and village shops, recognising that these provide facilities and services to meet the day-to-day needs of neighbourhood and village communities, but can nonetheless come under pressure for change of use (to housing). The proposed policy approach (TCS3) states that: “Proposals for the loss of shops will need to demonstrate that continuing in this use is unviable.” An alternative approach might be to specify precisely how ‘unviability’ must be demonstrated; however, again, appraisal would not lead to any substantive conclusions. Formal alternatives appraisal was not warranted.

Leisure, recreation and cultural facilities Chapter 12 of the Draft Plan presents policy in relation to leisure, recreation and cultural facilities, recognising that the Local Plan has a role in supporting the delivery of new and improved facilities that may be required to meet local needs and in helping to safeguard existing amenities. As explained within the supporting text: “This support may take a number of forms including:  the provision of new or improved facilities where there is an identified deficit in provision…  policies to safeguard existing amenities;  securing provision of new/improved facilities, or financial contributions toward their provision, where needed to offset the additional demands arising from new housing development.” The proposed policy approach (LRC1) deals with each specific issue/opportunity in turn, generally specifying the evidence-base that must be drawn upon when making planning decisions in respect of provision and safeguarding. Notably, there is policy support for “public access for water-based and waterside recreation, provided it does not conflict with nature conservation interests”, and an alternative might be envisaged whereby there is a different policy emphasis; however, sustainability implications are limited. Formal alternatives appraisal was not warranted.

Non Green Belt countryside Chapter 13 of the Draft Plan presents policy in relation to non Green Belt countryside, but the proposed policy (RE1) only goes as far as to sign-post to NPPF policy. An alternative could be envisaged whereby additional criteria are presented; however, there does not appear any evidence basis for such an approach. Formal alternatives appraisal was not warranted.

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Green Belt Chapter 13 of the Draft Plan also presents policy in relation to Green Belt, but the proposed policy (RE2) primarily serves only to implement the recommendations of the Green Belt Review. An alternative approach can be envisaged whereby the recommendations of the Green Belt Review are implemented differently. See discussion of alternative spatial strategies in Chapter 6 of this report.

Landscape character Chapter 13 of the Draft Plan also presents policy in relation to landscape character, recognising that there are a range of designated landscapes including a number of locally designated landscapes that must be kept under review by the Council. The proposed policy approach (RE2) generally roles forward the existing designations, pending review through Local Plan Part 2. An alternative approach can be envisaged whereby there is a loosening of protection to the designated landscapes . See discussion of alternative spatial strategies in Chapter 6 of this report.

Townscape and design Chapter 14 of the Draft Plan presents policy in relation to townscape and design, recognising the importance of achieving high quality buildings and places that respond to the distinctive character of the borough. The proposed policy approach (TD1) covers a number of specific issues, and is relatively high-level; hence an alternative approach might be envisaged whereby there is additional detail, potentially with the policy split-up. However, there is little reason to suggest that this flexibility is not appropriate. It will, of course, be possible to apply understanding of locally specific issues when judging planning applications against this policy. Formal alternatives appraisal was not warranted.

Protection of heritage assets Chapter 15 of the Draft Plan presents policy in relation to heritage, recognising the need to continue the Council’s good record of a proactive management of heritage assets within the borough. The proposed policy approach (HA1) covers a number of specific issues, and is relatively high-level; hence an alternative approach might be envisaged whereby there is additional detail. However, there is (again) little reason to suggest that this flexibility is not appropriate. Formal alternatives appraisal was not warranted.

Biodiversity and geological conservation Chapter 16 of the Draft Plan presents policy in relation to biodiversity and geological conservation, recognising that there are range of important sites locally, classified according to their significance (international, national and local) and all requiring a tailored approach to conservation. The proposed policy approach (NE1) includes a particular focus on internationally important sites, specifying particular conservation measures. An alternative approach would be to present equally detailed policy in respect of nationally important SSSIs; however, evidence-base is limited, and flexibility on balance likely to be appropriate. Formal alternatives appraisal was not warranted.

Green and blue infrastructure Chapter 16 of the Draft Plan also presents policy in relation to green and blue infrastructure, recognising that there are considerable opportunities locally, including within identified Biodiversity Opportunity Areas (BOAs). The proposed policy approach (NE2) includes a broad focus on both blue infrastructure (river and canal corridors) and green infrastructure (with particular reference to trees, woodland and hedgerows). Some shifts in focus could be suggested, but the broad approach would seem to be suited to the local area. Formal alternatives appraisal was not warranted.

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Thames Basin Heaths Special Protection Area (SPA) Chapter 16 of the Draft Plan also presents policy in relation to the Thames Basin Heaths SPA, recognising that the Thames Basin Heaths Avoidance Strategy sets out a sub-regionally agreed approach to avoiding the effect of a net increase in population from new housing developments within 5km of the SPA. The proposed policy approach (NE3) primarily seeks to implement the agreed avoidance strategy, and hence it is difficult to envisage an alternative. It might be suggested that the other SPAs and SACs locally should also have a dedicated policy; however, it is not clear that there is evidence base to inform such an approach. The Thames Basin Heaths are unique in having been the focus of much dedicated work that has enabled development of a detailed avoidance and mitigation strategy. Formal alternatives appraisal was not warranted.

Climate change Chapter 17 of the Draft Plan presents policy in relation to climate change, recognising that the NPPF states that Local Planning Authorities should adopt proactive strategies to mitigate and adapt to climate change. The proposed policy approach (CC1) lists six factors that should be central to decision-making, relating to both climate change and adaptation. There is the potential to tweak the policy focus, and to increase its stringency; however, there are limited (in terms of range) strategic sustainability implications. Formal alternatives appraisal was not warranted.

Sustainable construction and design Chapter 17 of the Draft Plan presents policy in relation to sustainable construction and design, recognising that, whilst there is no longer the potential to establish local standards (following Government’s withdrawal of the Code for Sustainable Homes in March 2015), there remains the potential to promote certain measures as being of particular importance locally. The proposed policy approach (CC2) lists seven factors that should be central to decision-making. Again, there is the potential to tweak the policy focus, and to increase its stringency; however, there are limited (in terms of range) strategic sustainability implications. Formal alternatives appraisal was not warranted.

Renewable energy development Chapter 17 of the Draft Plan also presents policy in relation to renewable energy development, recognising that there are considerable opportunities locally (notably commercial scale wind energy, biogas, energy from waste and heat pumps). The proposed policy approach (CC3) is focused on avoiding and mitigating adverse impacts on landscape, wildlife, heritage assets and amenity. An alternative policy might be envisaged that is more positive/supportive; however, there are limited (in terms of range) strategic sustainability implications. Formal alternatives appraisal was not warranted.

Flood risk management Chapter 17 of the Draft Plan also presents policy in relation to flood risk management, recognising that flood risk in Waverley originates from a number of sources - rivers, surface water, sewers, groundwater and artificial water bodies (e.g. Frensham Ponds, Broadwater Lake and the Wey and Arun Canal). The proposed policy approach (CC4) is in two parts, with the first dealing with avoiding flood risk and the second dealing with delivering Sustainable Drainage Systems (SuDS). The first part of the policy largely repeats national policy, and it is difficult to envisage an alternative. With regards to the second part of the policy, there are a number of requirements that could potentially be strengthened; however, there are limited (in terms of range) strategic sustainability implications. Formal alternatives appraisal was not warranted.

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APPENDIX IV - SITE OPTIONS

Introduction As explained within Chapter 6 above, site options - i.e. the pool of sites that are available, deliverable and potentially suitable for allocation through the plan - have been appraised for completeness. The aim of this appendix is to:

1) explain how the list of site options was arrived at;

2) explain the site options appraisal methodology; and then

3) present the outcomes of site options appraisal.

Identifying site options From the long list of sites known to the Council - primarily sites that have been promoted for development at some point over recent years - steps were taken to sieve out A) sites too small to accommodate 5 dwellings; B) sites currently unavailable or with planning permission; and C) sites with certain ‘showstopper’ constraints. In relation to (C), sites were sieved-out where found to be -  within a Special Protection Area (SPA) or are within 400m of the Thames Basin Heaths SPA;  within a Site of Special Scientific Interest or Special Area of Conservation;  within the functional floodplain (Flood zone 3b); or  greenfield land and entirely more than 100m from a town or village policy boundary for a settlement in one of the top three tiers of the Waverley Settlement Hierarchy or a settlement in a neighbouring authority. This left a shortlist of site options for appraisal.

Developing the appraisal methodology Given the number of site options and limited site-specific data availability it was not possible to simply discuss (‘qualitative analysis’) the merits of each site option under the SA framework (i.e. take an approach to analysis as per that taken to the appraisal of spatial strategy options - see Appendix V).52 As such, work was undertaken to develop a methodology suited to site options appraisal, whilst also reflecting the SA framework as best as possible. The methodology essentially involves employing GIS data-sets, and measuring (‘quantitative analysis’) how each site option relates to various constraint and opportunity features. The site options appraisal methodology is presented in Table A. The list of criteria is virtually unchanged from that applied in 2014 (Appendix I of the 2014 Interim SA Report). Within the 2014 report the methodology was presented alongside a discussion of limitations; however, that discussion is not repeated here for conciseness. Despite clear limitations to the methodology, it has not been possible to make improvements since 2014 - i.e. add additional criteria - due to limited data availability. Also unchanged since 2014 are the rules uses to categorise the performance of sites in terms of each criterion. It is important to be clear that the aim of categorising the performance of site options is to aid differentiation, i.e. to highlight instances of site options performing relatively well / poorly. The intention is not to indicate a ‘significant effect’.53

52 Qualitative analysis of site options would only have been possible were time / resources available to generate data/understanding for all site options through site visits and discussion with promoters. Without this data/understanding, any attempt at qualitative analysis would have led to a risk of bias (e.g. sites that are being proactively promoted may have been found to perform favourably). 53 Whilst Regulations require that the SA process identifies and evaluates significant effects of the draft plan and reasonable alternatives, there is no assumption that significant effects must be identified and evaluated for all site options considered. See Part 1 of this report for a discussion of how reasonable alternatives have been considered through the Waverley Local Plan / SA process, and in particular see Chapter 7 for an appraisal of the reasonable alternatives at the current time.

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Table A Site options appraisal methodology Criteria ‘RAG’ rules Intersects with a flood zone? R = > 50% intersects with Flood risk zone 2 or 3 A = < 50% intersects with Flood risk zone 2 or 3 G = Flood risk zone 1

Intersects with a surface water flood zone? R = > 50% intersects with 1 in 30 or 1 in 100 year risk A = < 50% intersects with 1 in 30 or 1 in 100 year risk; or > 50% intersects with 1 in 1000 year risk G = No surface water flood risk

Proximity to a Special Protection Area, Special Area R = <400m of Conservation or Ramsar site? A = 400m - 5km G = >5km

Proximity to a Site of Special Scientific Interest R = <200m (SSSI)? A = 200 – 800m G = >800m

Proximity to an ancient woodland (ASNW), R = Includes or is adjacent designated common land or local nature reserve? A = <50m G = >50m

Intersects with high quality agricultural land?54 R = Grade 2 A = Grade 3 G = Does not intersect, 2 or 3

Intersects with agricultural land under an R = Organic or Higher Level Stewardship 55 Environmental Stewardship Scheme? A = Entry Level Stewardship G = Does not intersect

Intersects with potentially contaminated land?56 A = Not contaminated G = Intersects

Intersects with a site designated by the Surrey R = Intersects or adjacent 57 Minerals and Waste Plan? A = <100m G = >100m

Intersects with a utility feature? A = Intersects G = Does not intersect

Proximity to sensitive groundwater location58 A = Intersects Source Protection Zone G = All other areas

Proximity to a Conservation Area? R = Intersects

54 It is possible to make use of a nationally available dataset; however, this dataset is of poor resolution. 55 Environmental Stewardship is an agri-environment scheme which provides funding to farmers and other land managers who deliver effective environmental management on their land. 56 Contamination is assumed to be a ‘positive’ on the basis that development of contaminated land could lead to remediation of land that would otherwise remain contaminated, posing a risk to human health and the water environment. 57 It is important to avoid ‘sterilising’ land that could be required in the future for minerals extraction or for a waste management use. 58 There is limited potential to be certain that any site option would lead to impacts to groundwater (as issues can generally be resolved at the planning application stage), but it is worthwhile querying the location of site options in relation to SPZs and primary aquifers nonetheless.

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Criteria ‘RAG’ rules A = <50m G = >50m

Proximity to a Historic Park or Garden? R = Intersects A = <50m G = >50m

Proximity to a Scheduled Monument? R = Intersects or is adjacent A = <50m G = >50m

Proximity to a listed building? R = Intersects or is adjacent A = <50m (or <20m locally important building) G = >50m

Proximity to a building of local importance? R = Intersects A = Adjacent G = Distant

Proximity to an archaeological asset? A = Intersects or is adjacent G = Distant

Proximity to the South Downs National Park? R = <50m A = 50 – 100m G = >100m

Proximity to the Area of Outstanding Natural Beauty R = Intersects (AONB)? A = <50m G = >50m

Intersects with an Area of Great Landscape Value A = Intersects (but not the AGLV)? G = Adjacent or distant

Intersects with other local landscape designation (but A = Intersects 59 not the AONB or AGLV)? G = Adjacent or distant

Intersects with the Green Belt? R = Wholly intersects A = Partially intersects G = Outside

Proximity to a town centre? R = >800m A = 400-800m G = <400m

Proximity to a primary school? R = >800m A = 400-800m G = <400m

Proximity to a secondary school? R = >60 minutes walking time A = 30-60 minutes walking time

59 Other locally designated landscapes are: Areas of Strategic Visual Importance, Godalming Hillsides, the Farnham/Aldershot Strategic Gap and areas designated as ‘Historic Landscape’.

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Criteria ‘RAG’ rules G = -<30 minutes walking time

Proximity to a GPs/Health centre? R = >800m A = 400-800m G = <400m

Proximity to a local shop? R = >800m A = 400-800m G = <400m

Proximity to a bus stop? R = >400m G = <400m

Proximity to a train station? A = >800m G = -<800m

Intersects with a public right of way (PROW)? A = Intersects G = Does not intersect

Proximity to an AQMA? R = Within or adjacent an AQMA A = <1km from an AQMA G = >1km from an AQMA

Is the site within an area that suffers from problems of R = Site does not intersect with an ‘output area’ that health deprivation?60 is relatively deprived A = Any of the site intersects with an ‘output area’ Is the site within an area of employment deprivation? that is relatively deprived i.e. in the 20-40% (2nd quintile) most deprived in the district Is the site within an area that suffers from problems of overall deprivation? G = Any of the site intersects with an ‘output area’ that is relatively deprived (i.e. in the 0-20% (1st quintile) most deprived in the district

60 It is assumed that development in an area of relative deprivation is a ‘plus’ on the basis that development can bring with it investment that will in turn help to facilitate an increase in prosperity locally / reduce spatial inequalities in terms of relative deprivation.

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Appraisal findings Table B presents appraisal findings in relation to the site options that have been a focus of plan-making. Specifically, the table presents an appraisal of the site options in terms of the 35 appraisal criteria (Table A), with performance categorised on a simple ‘RAG’ scale. Sites are listed -  firstly in order of settlement (as sites at a given settlement may be alternatives);  secondly according to whether the site is a proposed strategic allocation, a non-strategic site identified as suitable within the LAA (“LAA site”) or a site identified as not suitable within the LAA; and  thirdly according to whether the site is urban, rural greenfield or rural brownfield.

Certain limitations have already been discussed, but furthermore there is a need to explain that - It is recognised that only limited understanding can be gained from strict GIS analysis; and equally it is recognised that presenting appraisal findings for all site options in tabular format is in practice of limited assistance to those interested in the spatial strategy. As such, the spreadsheet containing the underlying data is available upon request. The spreadsheet allows for more effective interrogation of the data as it is possible to compare and contrast particular sites (that might be alternatives) and examine sub-sets (e.g. sites around a particular settlement).

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Table B Site options appraisal findings

Site arden

Type

Settlement 61

[With proposed strategic allocations and LAA

sites highlighted]

Floodzone Surfacewater site Eurobiodiversity SSSI Localsite biodiversity Agriculturalland Envstewardship landContaminated Mineralswaste and Groundwater Utility areaConservation Historic / g park Scheduledmonument Listedbuilding Archaeology SouthDowns AONB AGLV Otherlandscape GreenBelt Town centre Primaryschool Secondaryschool GP Localshop Busstop Trainstation PROW AQMA Healthdeprivation Employmentdeprivation Overalldeprivation

10 Dunsfold Aerodrome/Park None B

472 Alfold Garden Centre Alfold B

893 Brookfield, Horsham Road, Alfold GU6 8JE Alfold B

470 Land at Chilton Close (rear of The Willows) Alfold G

Land at Brockhurst Farm, Dunsfold Road, 857 Alfold G Alfold Crossways Land West of Sweeters Copse, Loxwood 913 Alfold G Road, Alfold Crossways

392 Land at Linden Farm, Rosemary Lane Alfold G

574 Land East of Loxwood Road Alfold G

614 Land west of Loxwood Road Alfold G

Alfold Farm Barn and Alfold Farm 687 Alfold G Bungalow Land North of Springfield Cottages, 708 Alfold G Horsham Road, Alfold

710 Springbok Estate, Sachel Court, Alfold Alfold G

61 U = urban; G = rural greenfield; B = rural brownfield.

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Site arden

Type

Settlement 61

[With proposed strategic allocations and LAA

sites highlighted]

876 Horders Meadow, Alfold Alfold G

Land adjoining Chilton Close, Alfold Alfold 276 G Crossways Crossways Land adjacent to Brockhurst Farm, Alfold 277 G Dunsfold Road Crossways Land Adjacent to Wildwood Golf Club, Alfold 275 G Horsham Road Crossways Land West of Sweeters Copse, Loxwood Alfold 692 G Road, Alfold Crossways Crossways Land to the rear Orchard Cottages and 280 Bramley G Glenafrie, Mill Lane

769 Bramley Garage, High Street, Bramley Bramley U

469 Land south side of Bramley Bramley G

Land to South of Birtley Courtyard (Birtley 555 Bramley G Green)

622 The Nursery, Gosden Common Bramley G

627 Park Drive B Bramley G

640 Land to the west of Bramley High Street Bramley G

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Site arden

Type

Settlement 61

[With proposed strategic allocations and LAA

sites highlighted]

652 Land off Chestnut Way Bramley G

728 Land South of Brighton Road, Busbridge Busbridge G

Land to the north of Queens Mead (west of 286 Chiddingfold G the A283) Land South of Field View Close, 402 Chiddingfold G Chiddingfold Land to the rear of The Croft, Woodside 865 Chiddingfold G Road, Chiddingfold

840 The Old Stick Factory, Fisher Lane Chiddingfold B

401 Land between Ballsdown and the Surgery Chiddingfold G

403 Land to the rear of houses in Ridgley Road Chiddingfold G

408 Land on Ballsdown Chiddingfold G

Land adjacent to Turners Mead, 481 Chiddingfold G Chiddingfold

819 Land at Skinners Lane, Chiddingfold Chiddingfold G

Bunchfield, Fisher Lane, Chiddingfold, GU8 Chiddingfold 895 B 4TB and Dunsfold Land at Borrow House Cottage, Jumps 888 Churt B Road, Churt GU10 2LB

4 Land at Churt Road Churt G

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Site arden

Type

Settlement 61

[With proposed strategic allocations and LAA

sites highlighted]

684 Churt Place Nurseries, Tilford Road, Churt Churt G

Land rear of Morton House, Crossways, 743 Churt G Churt Land at rear of Hitchin Croft and Little 744 Churt G Shawfield

292 West Cranleigh Nurseries, Knowle Lane Cranleigh G

294 Land at Horsham Road, Cranleigh Cranleigh G

853 Land at Little Meadow Cranleigh G

13 47 - 53 Horsham Road Cranleigh U

130 Cranleigh Infants School, Church Lane Cranleigh U

Land at St Nicholas C of E School, 383 Cranleigh U Parsonage Road

874 Elmbridge Road, Cranleigh Cranleigh G

Buildings at Astra House, and adjacent to 5 Cranleigh U the Common

9 Hewitts Industrial Estate Cranleigh U

11 Astra House, Cranleigh Cranleigh U

129 Park Mead Junior School, Park Drive Cranleigh U

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Site arden

Type

Settlement 61

[With proposed strategic allocations and LAA

sites highlighted]

552 Jewsons LTD, The common, Cranleigh Cranleigh U

553 Little Manor Service Station Cranleigh U

8 Notcutts, Guildford Road Cranleigh B

791 Land at Smithbrook Kilns, Cranleigh Cranleigh B

296 Ruffolds Farm, Guildford Road, Cranleigh Cranleigh G

Land rear of The Meadows, Guildford 397 Cranleigh G Road, Rowly

562 Land adjacent to Swallow Tiles Cranleigh G

565 Land adjacent to Manfield Industrial Park Cranleigh G

569 Land at Thorns Flush Barn, Guildford Road Cranleigh G

620 Land adjacent to Ruffold Farm Cranleigh G

Land at Lower Barrihurst Farm, Dunsfold 649 Cranleigh G Road

668 Land at Rowly Edge, Cranleigh Cranleigh G

Homeleigh Nursery, Guildford Road, 669 Cranleigh G Cranleigh Stonescapes Quarry & Stone Yard, 685 Cranleigh G Cranleigh

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Site arden

Type

Settlement 61

[With proposed strategic allocations and LAA

sites highlighted]

712 Land at Highfold, Horsham Road, Cranleigh Cranleigh G

726 Barcroft, Barhatch Road, Cranleigh Cranleigh G

Land between Notcutts and Stonescapes, 746 Cranleigh G Guildford Road Land between Ruffold Farm and Guildford 787 Cranleigh G Road, Cranleigh Cranleigh Preparatory and Senior Schools, 873 Cranleigh G Horseshoe Lane, Cranleigh

905 Land East of Guildford Road, Cranleigh Cranleigh G

747 Land adj Nugent Close Dunsfold G

788 Land East of Dunsfold Dunsfold G

15 Land at Dunsfold Common Road Dunsfold G

299 Land at Shoppe Hill Dunsfold G

476 Leylands Farm, Wrotham Hill Dunsfold G

638 Land at Combe Bury Cottage Dunsfold G

658 Alehouse Field, The Common, Dunsfold Dunsfold G

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Site arden

Type

Settlement 61

[With proposed strategic allocations and LAA

sites highlighted]

833 Land at Mill Lane, Dunsfold Dunsfold G

904 Land at Hurstford Stables Dunsfold G

Land to the rear of Hermongers Lane (East 309 Ellens Green G of Cox Green)

16 Weyburn Works Elstead B

824 Land at Four Trees, Hookley Lane, Elstead Elstead G/U

308 Land to the rear of The Croft Elstead G

20 Land and rear gardens off Hill Crescent Elstead U

867 6 Westbrook Hill Elstead U

577 Tanshire Park, Elstead Road, Peperharow Elstead B

Land rear of Stacey's Farm Cottage, 471 Elstead G Thursley Road

613 Sunray Farm, West Hill Elstead G

624 Moors Lane Elstead G

689 Land off West Hill and Hill Crest, Elstead Elstead G

Land at Red House Farm, Red House 695 Elstead G Lane, Elstead

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Site arden

Type

Settlement 61

[With proposed strategic allocations and LAA

sites highlighted]

398 Land south of Cranleigh Road Ewhurst G

399 Land at Backward Point, Cranleigh Road Ewhurst G

Land to the north of Penlan, Cranleigh 400 Ewhurst G Road

558 Ewhurst Brickworks, Horsham Road Ewhurst B

694 Smokejacks, Horsham Road, Ewhurst Ewhurst B

Hurtwood Park Polo Club, Horsham Lane, 741 Ewhurst G Ewhurst Land to the rear of Tamarisk, Mapledrakes 909 Ewhurst G Road

670 The Woolmead, Farnham Farnham U

29 Coxbridge Farm, Alton Road Farnham G

438 Land west of Green Lane, Badshot Lea Farnham G

900 Land off Water Lane Farnham G

264 Victoria House, South Street Farnham U

281 25 - 27 Hurlands Close Farnham U

285 The Bush Hotel, The Borough Farnham U

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Site arden

Type

Settlement 61

[With proposed strategic allocations and LAA

sites highlighted]

882 2-3 The Borough, Farnham GU9 7NA Farnham U

Part of SSE Farnham Depot, Lower 478 Farnham G/U Weybourne Lane

25 Land West of Badshot Lea Farnham G

546 West of Switchback Lane, Rowledge Farnham G

Land to the south of Monkton Lane, 657 Farnham G Farnham

693 Land at Hale Road, Farnham Farnham G

713 Garden Style, Wrecclesham Hill Farnham G

727 Land rear of Three Styles Road, Farnham Farnham G

872 Little Acres Nursery and Land to the West Farnham G

Badshot Lea Service Station, 131 Badshot 33 Farnham U Lea Road Land at the rear of 6 The Street, 132 Farnham U Wrecclesham Land rear of Viners Mead and Colemans, 133 Farnham U Wrecclesham Road

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Site arden

Type

Settlement 61

[With proposed strategic allocations and LAA

sites highlighted]

136 35 - 42 East Street Farnham U

Land opposite Twyford Lane junction, 369 Farnham U Burnthill Road

460 Montrose House, South Street Farnham U

498 Weydon Works, Weydon Lane, Farnham Farnham U

1-9 Romans Business Park (Site A), 550 Farnham U Farnham

551 Unit 1-4 East Street (Site B), Farnham Farnham U

Land between Hale Road and Guildford 556 Farnham U Road

576 Farnham Delivery Office, West Street Farnham U

609 123a Badshot Lea Road, Badshot Lea Farnham U

767 Wellingtons, 16 Folly Hill, Farnham Farnham U

Hurlands Business Centre, Hurlands Close, 785 Farnham U Farnham

891 74-84 East Street, Farnham Farnham U

Land at Preymead Farm Industrial Estate, 436 Farnham B Badshot Lea Road

770 Knowle Livery, Old Park Lane, Farnham Farnham B

SA REPORT: APPENDICES 100

SA of the Waverley Local Plan Part 1

Site arden

Type

Settlement 61

[With proposed strategic allocations and LAA

sites highlighted]

679 30 Frensham Vale, Lower Bourne Farnham G/U

27 Land to the East of Badshot Lea Farnham G

153 Land at Clumps End, Clumps Road Farnham G

184 Rosemead Cottage, River Lane Farnham G

332 Land at Waverley Lane, Farnham Farnham G

333 Land at 35 Frensham Vale, Lower Bourne Farnham G

343 Land at Stockwood Way, Hale (Parcel B) Farnham G

Land south of Badshot Lea (CON071, 381 Farnham G CON001, CON002) Land south of Wendy's Wood, Tilford Road, 439 Farnham G Lower Bourne

442 Land at Runwick Lane, Dippenhall Farnham G

Land to the rear of 48 Wrecclesham Hill, 461 Farnham G Farnham

475 Land at St. Georges Road, Badshot Lea Farnham G

SA REPORT: APPENDICES 101

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Site arden

Type

Settlement 61

[With proposed strategic allocations and LAA

sites highlighted]

554 Beavers Farm, Crondall Lane Farnham G

559 Land at Hale Road Farnham G

564 Century Farm, Green Lane, Badshot Lea Farnham G

568 Land at Redhill House, Tilford Road Farnham G

615 Land east of Low Lane Farnham G

625 Rowhills, Farnham Farnham G

644 Land at Cedar House, Byworth Road Farnham G

Lower Paddock Gardeners Hill Road, 653 Farnham G Farnham

654 Hill Fields, Gardeners Hill Road, Farnham Farnham G

Wrecclesham Farm Buildings, Echo Barn 655 Farnham G Lane, Farnham Wrecclesham Farm Nursery, Echo Barn 656 Farnham G Lane, Farnham

663 Land at Tongham Road, Runfold Farnham G

Land rear of 12 Heathyfields Road, 671 Farnham G Farnham

696 Land South of Frensham Vale Road Farnham G

SA REPORT: APPENDICES 102

SA of the Waverley Local Plan Part 1

Site arden

Type

Settlement 61

[With proposed strategic allocations and LAA

sites highlighted]

701 Land at Lavender Lane, Farnham Farnham G

716 13 Upper Old Park Lane, Farnham Farnham G

Land South of Quernsmuir, 19 Sands 720 Farnham G Road, Farnham

740 Two Acres, Monks Walk, Farnham Farnham G

761 Land at Little Acres Nursery, Badshot Lea Farnham G

854 Land at Low Lane, Badshot Lea Farnham G

Land at Green Lane, Badshot Lea, 898 Farnham G Farnham, GU9 9JL

907 Land west of Crown Lane, Badshot Lea Farnham G

724 Dockenfield Farm, Pitt Lane, Frensham Frensham G

843 1 Hillside Road Frensham G

617 Land at Shortfield Common Road Frensham G

648 Woodside Park Godalming U

Properties and Gardens 1- 22 Catteshall 57 Godalming U Lane Land at Charterhouse School, Peperharow 66 Godalming U Road

SA REPORT: APPENDICES 103

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Site arden

Type

Settlement 61

[With proposed strategic allocations and LAA

sites highlighted]

915 Catteshall Manor, Catteshall Lane Godalming B

571 Land east of Binscombe Godalming G

49 Hillside Works, Catteshall Lane Godalming U

56 Llanaway Works, Meadrow Godalming U

68 Mint Street/Station Road Car park Godalming U

Land to the rear of 20 - 36 North Street, 76 Godalming U Farncombe

388 The Square Medical Practice, High Street Godalming U

Panda House and Riverview House, 567 Godalming U Catteshall Lane

575 Godalming Delivery Office, Woolsack Way Godalming U

602 Unit 8 Woodside Park, Catteshall Lane Godalming U

698 The Wharf Car Park, Woolsack Way Godalming U

SA REPORT: APPENDICES 104

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Site arden

Type

Settlement 61

[With proposed strategic allocations and LAA

sites highlighted]

779 Old Fire Station, Queen Street, Godalming Godalming U

780 Panda House, Catteshall Lane, Godalming Godalming U

783 128030 High Street, Godalming Godalming U

863 Land at Catteshall MIll Godalming U

Former Batemans Laboratories, Catteshall 916 Godalming U Lane

52 Thames Water, Borough Road Godalming B

794 The Meath, Westbrook Road Godalming B

Broadwater School, Summers Road, 51 Godalming G Farncombe Ladywell Convent, Land south of Pullman 344 Godalming G Lane/Ashtead

346 Land at Busbridge (south of Chestnut Way) Godalming G

443 Land at Franklyn Road Godalming G

651 Land west of Scizdons Climb Godalming G

661 The Brambles, Mark Way, Godalming Godalming G

SA REPORT: APPENDICES 105

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Site arden

Type

Settlement 61

[With proposed strategic allocations and LAA

sites highlighted]

851 Land between Halfway and Eashing Lane Godalming G

902 Heath Farm, Heath Lane, Godalming Godalming G

908 Hambledon House, Vann Lane Hambledon B

Land to the east of Rose Cottages, The 348 Hascombe G Street, Hascombe

463 Land at Hascombe Hascombe G

753 Land at Gorebridge Green Hascombe G

Land at West Street including Haslemere 141 Haslemere U Key Site Clement Windows and Motorcycle Shops 5 245 Haslemere U - 21 Weyhill

697 Land at Wey Hill, Haslemere Haslemere U

Land south east of Haslemere Water 674 Haslemere G Treatment Works, Sturt Road Land north of Haslemere Saw Mills, Sturt 714 Haslemere G Road

80 Concours Peugeot, Sturt Road Haslemere U

85 Haslemere Fire Station, West Street Haslemere U

SA REPORT: APPENDICES 106

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Site arden

Type

Settlement 61

[With proposed strategic allocations and LAA

sites highlighted]

681 Chapman House, Meadway, Haslemere Haslemere U

Paint Services Group Ltd, Weydown Road, 782 Haslemere U Haslemere

79 Mills Yard, Bell Road Haslemere B

88 land at the end of Sunvale Avenue Haslemere G

249 Land at Red Gables, Weydown Road Haslemere G

Land adjacent Weydown Hatch, Weydown 351 Haslemere G Road

446 Sturt Farm, Sturt Road Haslemere G

Land East of Longdene House, Hedgehog 563 Haslemere G Lane

628 Kingfisher Farm, Sandy Lane Haslemere G

630 Land along Midhurst Road Haslemere G

631 Land at Whitmoor Vale Haslemere G

664 Land at Oak Tree Lane, Haslemere Haslemere G

SA REPORT: APPENDICES 107

SA of the Waverley Local Plan Part 1

Site arden

Type

Settlement 61

[With proposed strategic allocations and LAA

sites highlighted]

755 Part of Sturt Meadow House Haslemere G

756 Site south of Upper Mount, Grayswood Haslemere G

Land between Brayshott Chase and Sports 762 Haslemere G Bungalow, Woolmer Hill, Haslemere

870 Land at Nutcombe Lane, Haslemere Haslemere G

829 35 The Golden Hind, London Road Hindhead U

682 West Down, Portsmouth Road, Hindhead Hindhead G

Site A, Land Adjacent to Chasemoor, 849 Hindhead G Portsmouth Road Hindhead/ 144 Central Hindhead, London Road U Beacon Hill Hindhead/ 145 Land at Oakdale, Portsmouth Road, U Beacon Hill Brownscombe House and Cottage, Hindhead/ 557 B Hindhead Road Beacon Hill Hindhead/ 352 Land at Woolmer Hill, Woolmer Hill Road G Beacon Hill Hindhead/ 445 Highcombe Edge, Tilford Road, Hindhead G Beacon Hill

450 Land opposite Milford Golf Club Milford G

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SA of the Waverley Local Plan Part 1

Site arden

Type

Settlement 61

[With proposed strategic allocations and LAA

sites highlighted]

94 Land rear of 48-58 Church Road, Milford Milford U

364 Land at Moushill Mead, Portsmouth Road Milford G

449 Land at Manor Lodge Milford G

467 Land at Highcroft, Petworth Road Milford G

Land at Coneycroft, Guildford and 703 Milford G Godalming By-Pass Road, Milford White Lion Public House, Portsmouth 878 Milford U Road, Milford GU8 5BB

365 Land at Hurst Gate, Portsmouth Road Milford G

448 Land to the rear of 10 & 11 Busdens Close Milford G

452 Land at Petworth Road Milford G

636 Land adj Oakwood Milford G

641 Land at Roe Deer Farm, Portsmouth Road Milford G

643 Land at Busdens Lane Milford G

Land South of Wood Farm, Portsmouth 665 Milford G Road

847 Land Adjacent to Petworth Road Milford G

SA REPORT: APPENDICES 109

SA of the Waverley Local Plan Part 1

Site arden

Type

Settlement 61

[With proposed strategic allocations and LAA

sites highlighted]

293 Cranleigh Nurseries, Guildford Road, Rowly Rowly G

295 Gleneagles, Rowly Drive, Rowly Rowly G

Southern part of land to the rear of The 729 Rowly G Meadows, Guildford Road, Rowly Northern part of the land to the rear of The 730 Rowly G Meadows, Guildford Road, Rowly Shamley Green STW, Lordshill Green, Shamley 454 G Shamley Green Green Land at Hyde Farm, Guildford Road, Shamley 457 G Shamley Green Green Land at Little Plonks, Church Hill, Shamley Shamley 621 G Green Green Shamley 659 Land at Northcote Farm, Shamley Green G Green

827 Uplands Stud, Bowlhead Green Road Thursley B

634 Land East of Thursley Thursley G

757 Land at Shepherd's Way Tilford U

718 Land South of Grange Road, Tilford Tilford G

722 Land South of Stockbridge Cottages Tilford G

SA REPORT: APPENDICES 110

SA of the Waverley Local Plan Part 1

Site arden

Type

Settlement 61

[With proposed strategic allocations and LAA

sites highlighted]

835 Starcross Farm, TIlford, Area 1 Tilford G

836 Starcross Farm, Tilford, Area 2 Tilford G

914 Gorse Hill, Petworth Road, Wormley Witley B

Land at Wheeler Street Nurseries, Wheeler 368 Witley G Lane

875 Land at Old Elstead Road, Milford Witley G

912 Witley and District Social Club, Mill Lane Witley B

366 Land west of George Eliot Close, Witley G

Land East of Petworth Road and South of 561 Witley G Mill Lane

618 Land west of Petworth Road, Witley Witley G

632 Land adj Barrow Hills School Witley G

633 Land at Cramhurst Lane Witley G

635 Land adj to Willow House Witley G

646 Curtis's Piece Witley G

Land rear of Sandford, Petworth Road, 672 Witley G Witley

SA REPORT: APPENDICES 111

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Site arden

Type

Settlement 61

[With proposed strategic allocations and LAA

sites highlighted]

821 Rockwood, Haslemere Road, Witley Witley G

856 Land at Barrow Hills School Witley G

Land adjacent to Petworth Road (South of 871 Witley G Milford) Land to the rear of Wonersh United 894 Wonersh B Reformed Church (URC), The Common

455 St. Johns Seminary Wonersh G

Land at Great Tangley, Manor Farm, 709 Wonersh G Wonersh Land south of junction with Smithwood 832 Wonersh G Common Road, Guildford Road Land South of Franklin Court, Brook Road, 676 Wormley G Wormley

677 Land off Bridewell Close, Wormley Wormley G

616 Land at Combe Lane, Wormley Wormley G

Land opposite King Edwards School, 678 Wormley G Petworth Road, Wormley

686 Tigbourne Farm, New Road, Wormley Wormley G

690 Land north of Westway Close, Combe Lane Wormley G

SA REPORT: APPENDICES 112

SA of the Waverley Local Plan Part 1

APPENDIX V - SPATIAL STRATEGY ALTERNATIVES

Introduction As explained within ‘Part 1’ above, a focus of work has been on the development and appraisal of spatial strategy alternatives, with a view to informing determination of the preferred strategy. In summary, the alternatives are as follows -  Option 1 - OAN; nil at Dunsfold Aerodrome; all ‘LAA sites’ at Milford/Witley; 2,500 at 'non-LAA' sites including sites that are heavily constrained by GB and AONB  Option 2 - OAN; 1,800 at Dunsfold Aerodrome; 800 at 'non-LAA' sites with GB and landscape constraints fully applied  Option 3 - OAN; 1,800 at Dunsfold Aerodrome; all ‘LAA sites’ at Milford/Witley; 700 at 'non-LAA' sites with GB and landscape constraints less fully applied  Option 4 - OAN; 2,600 at Dunsfold Aerodrome;  Option 5 - OAN + 800; 2,600 at Dunsfold Aerodrome; all ‘LAA sites’ at Milford/Witley; 700 at 'non-LAA' sites with GB and landscape constraints less fully applied  Option 6 - OAN + 800; 2,600 at Dunsfold Aerodrome; 800 at 'non-LAA' sites with GB and landscape constraints fully applied  Option 7 - OAN + 2,200; 2,600 at Dunsfold Aerodrome; all ‘LAA sites’ at Milford/Witley; 2,100 at 'non-LAA' sites including sites that are heavily constrained by GB and AONB

Appraisal methodology For each of the options, the assessment examines likely significant effects on the baseline, drawing on the sustainability objectives identified through scoping (see Table 4.1) as a methodological framework. Green is used to indicate significant positive effects, whilst red is used to indicate significant negative effects. Every effort is made to predict effects accurately; however, this is inherently challenging given the high level nature of the policy approaches under consideration. The ability to predict effects accurately is also limited by understanding of the baseline (now and in the future under a ‘no plan’ scenario). In light of this, there is a need to make considerable assumptions regarding how scenarios will be implemented ‘on the ground’ and what the effect on particular receptors would be. Where there is a need to rely on assumptions in order to reach a conclusion on a ‘significant effect’ this is made explicit in the appraisal text.62 Where it is not possible to predict likely significant effects on the basis of reasonable assumptions, efforts are made to comment on the relative merits of the alternatives in more general terms and to indicate a rank of preference. This is helpful, as it enables a distinction to be made between the alternatives even where it is not possible to distinguish between them in terms of ‘significant effects’. Finally, it is important to note that effects are predicted taking into account the criteria presented within Regulations.63 So, for example, account is taken of the duration, frequency and reversibility of effects. Cumulative effects are also considered (i.e. where the effects of the plan in combination with the effects of other planned or on-going activity that is outside the control of the Guildford Local Plan). Appraisal findings Appraisal findings are presented below within 10 separate tables (each table dealing with a specific sustainability objective) with a final table drawing conclusions. The appraisal methodology is explained above, but to reiterate: For each sustainability topic the performance of each scenario is categorised in terms of ‘significant effects (using red / green) and also ranked in order of preference. Also, ‘ = ’ is used to denote instances of all alternatives performing on a par.

62 Conclusions reached on significant effects in relation to Option 4 - the Council’s preferred option - are supplemented within Chapter 10 of this report, which presents an appraisal of the draft plan - i.e. the preferred spatial strategy plus supporting policies. 63 Schedule 1 of the Environmental Assessment of Plans and Programmes Regulations 2004.

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SA of the Waverley Local Plan Part 1

Sustainability Topic: Biodiversity

Option 1 Option 2 Option 3 Option 4 Option 5 Option 6 Option 7 OAN; OAN; OAN; OAN; OAN + 800; OAN + 800; OAN + 2,200; nil at DA; 1,800 at DA; 1,800 at DA; 2,600 at DA 2,600 at DA; 2,600 at DA; 2,600 at DA; all Milford 800 at non- all Milford all Milford 800 at non- all Milford LAA sites; LAA sites LAA sites; LAA sites; LAA sites LAA sites; 2,500 at non- 700 at non- 700 at non- 2,100 at non- LAA sites LAA sites LAA sites LAA sites

Rank 7 2 2 2 2 6

Significant Yes No Yes effects?

A key consideration is the potential for impacts on internationally important heathland sites (Thames Basin Heaths SPA; Wealden Heaths SPA; and Thursley, Hankley and Frensham Commons SPA), which are sensitive to visitor pressure, given ground-nesting birds. Impacts in this regard are being considered through a standalone process of Habitats Regulations Assessment (HRA), but it is also appropriate to take SPA matters into account here. Also, there is a need to consider impacts to areas designated as being of national importance (Sites of Special Scientific Interest, SSSIs) and local importance (Sites of Nature Conservation Importance, SNCIs). Furthermore, there is a need to consider the potential for impacts on non- designated habitats that contribute to ecological connectivity at the landscape scale, and more generally ‘green infrastructure’ locally. With regards to non-designated habitat, the evidence- base is limited; however, the extent of Biodiversity Opportunity Areas (BOAs) is known. In light of these points, the alternatives can be distinguished as follows:  Option 1 - performs poorly on the basis of maximum loss of greenfield land around the edge of settlements. Perhaps most notably, high growth at Haslemere would likely necessitate a significant extension to the west at a site comprising mature woodland (a proportion of which is ancient woodland), adjacent to registered common land (albeit this is MOD land with managed access) and in proximity (c.400m) to the Wealden Heaths Phase II SPA (albeit this is again MOD land, and the A3 is to some extent a barrier to access). Also, development of all LAA sites at Milford would mean growth to the west, leading to the loss of woodland and growth in proximity (c.400m) of the Thursley, Hankley and Frensham Commons SPA, albeit Discussion extensive areas of common land (non-designated) in even closer proximity are managed as a nature reserve, and might therefore ‘absorb’ recreational pressure to an extent. Also, growth to the east of Cranleigh would be in proximity to, and potentially abut, a swathe of land designated as SNCI (comprising ancient woodland and intervening fields); and growth to the west would likely lead to the loss of a fairly extensive area of scrubland, to the east of the sewage treatment works. Finally, high growth at Farnham could lead to difficulties in respect of mitigating recreational impacts to the nearby Thames Basin Heaths SPA through delivery of adequate Suitable Alternative Natural Greenspace (SANG).  Option 2 - performs notably better than Option 1, as there would be considerably less pressure on greenfield sites, and a 1,800 home scheme at Dunsfold Aerodrome gives rise to relatively few concerns (see discussion below).  Option 3 - performs broadly on a par with Option 2. The assumption is that all LAA sites at Milford would be developed (meaning growth to the west, in a sensitive location, as discussed under Option 1); however, lower growth at Badshot Lea could help to ensure sufficient ability to mitigate recreational impacts to the nearby (c.2 - 3km) Thames Basin Heaths SPA through delivery of SANG.  Option 4 - performs better than Options 1 and 2, as there would be less pressure on greenfield sites and a 2,600 home scheme at Dunsfold Aerodrome gives rise to relatively few concerns. Having said this, two locally important SNCIs intersect the edge of Dunsfold Aerodrome, others are located in close proximity and the Chiddingfold Forest SSSI is located

SA REPORT: APPENDICES 114

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150m away at its nearest point. Also, it is understood (Transport Assessment, 2015) that improvements to two junctions on the A281 would be necessary if the road is to accommodate any scheme, and such improvements could necessitate road widening into existing common land (which can tend to have some biodiversity value). An ecological assessment of the site recently submitted as part of a planning application for 1,800 homes concluded that habitats within the site are diverse and include some species rich examples, such as unimproved grassland and ancient woodland remnants. The Planning Statement found that: “…the proposed development represents a significant opportunity to substantially enhance the site's ecological value. The [proposal] retains existing woodlands and tree groups, including those along the Wey and Arun Canal corridor but also includes very substantial areas of informal open space, with clear opportunity for significant habitat creation…” As such, it is important to question whether a 2,600 home scheme would lead to reduced ‘opportunity’.  Option 5 - performs broadly as per Option 3. Option 5 would involve a large (2,600 home) scheme at Dunsfold Aerodrome; however, it is not possible to conclude that this is problematic, given that Dunsfold Aerodrome is relatively non-sensitive from a biodiversity perspective, in the sub-regional context. The effect will be to reduce pressure on other locations in the Housing Market Area (or wider sub-region) that might well be more sensitive.  Option 6 - performs broadly as per Option 2. Again it is not possible to conclude that a larger scheme at Dunsfold Aerodrome leads to this option performing worse than Option 2.  Option 7 - performs poorly, recognising that - as per Option 1 - there would be development at sensitive greenfield sites and high growth in proximity to the Thames Basin Heaths SPA; however, relative to Option 1 the scale of greenfield development would be reduced somewhat, and this would likely involve a reduced scale of growth to the west of Haslemere and to the east of Cranleigh. Again it is not possible to conclude that a larger scheme at Dunsfold Aerodrome leads to this option performing worse than Option 1. On the basis of these points, it is possible to conclude that Option 4 is best performing as it would involve minimal greenfield growth (2,300 at LAA sites), followed by the four options that would involve c.800 additional homes at greenfield sites (i.e. Options 2, 3, 5 and 6, which would involve 3,100 homes at LAA and non-LAA sites), followed by the two options that would involve considerably higher greenfield growth (with Option 1, which would involve the most - 4,900 - homes at LAA and non-LAA sites, performing worst). With regard to effect significance, it is appropriate to conclude a likelihood of Options 1 and 7 leading to significant negative effects, as there is little certainty that SANG could be delivered to absorb the recreational effects generated by population growth at Farnham (c.3,100-3,200 over the plan period, in total) on the Thames Basin Heaths SPA; plus development at Milford and Haslemere could well be within walking distance (i.e. c.400m) of other SPAs. It is less clear that other options would lead to significant negative effects. Much of the greenfield land surrounding settlements that would come under pressure is relatively non-sensitive, from a strategic biodiversity perspective, with relatively few SNCIs likely to come under pressure and seemingly no potential for impacts to land that lies within a Biodiversity Opportunity Area (BOA).

SA REPORT: APPENDICES 115

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Sustainability Topic: Climate change mitigation

Option 1 Option 2 Option 3 Option 4 Option 5 Option 6 Option 7 OAN; OAN; OAN; OAN; OAN + 800; OAN + 800; OAN + 2,200; nil at DA; 1,800 at DA; 1,800 at DA; 2,600 at DA 2,600 at DA; 2,600 at DA; 2,600 at DA; all Milford 800 at non- all Milford all Milford 800 at non- all Milford LAA sites; LAA sites LAA sites; LAA sites; LAA sites LAA sites; 2,500 at non- 700 at non- 700 at non- 2,100 at non- LAA sites LAA sites LAA sites LAA sites

Rank 7 5 6 4 3 2

Significant No effects?

A key climate change mitigation consideration relates to the potential for each scenario to affect average per capita transport-related CO2 emissions, noting that this is an issue in Waverley (reflecting the rural nature of the borough). However, this is considered under the ‘Transport and traffic’ heading below. Instead, the discussion here focuses on the potential for scenarios to support renewable or low carbon energy infrastructure, and hence minimise per capita CO2 emissions from the built environment. In practice, this means supporting larger scale developments of several hundred homes (or clusters of smaller developments that can be developed in a coordinated way), as development at scale enables delivery of the necessary infrastructure. In light of these points, the alternatives can be distinguished as follows:  Option 1 - performs poorly, as there would be no new settlement at Dunsfold Aerodrome; however, on the plus side, the assumption is that there would be strategic scale schemes - i.e. schemes of several hundred homes - at Farnham, Godalming, Haslemere and Cranleigh. In particular, there would be a likelihood of a strategic scale scheme at Badshot Lea, potentially involving up to 650 homes (leading to economies of scale and thereby certainty regarding delivery of low carbon energy infrastructure, and potentially standards of sustainable design and construction over-and-above national requirements). Discussion  Option 2 - is judged to perform better than Option 1, on the basis that a 1,800 home scheme at Dunsfold Aerodrome would enable delivery of per capita carbon savings; however, there is some uncertainty. A Sustainability and Renewable Energy Strategy accompanied a recent planning application for a 1,800 home scheme, proposing “utilising central energy and water waste facilities; including a solar farm and anaerobic digestion facilities”; however, the solar farm is already in place on site (presumably feeding into the national grid) and the anaerobic digestion plant was granted planning permission in 2013 (but has yet to be implemented). There was also a proposal for “a strategy for super-insulated homes with low energy and water requirements.”  Option 3 - performs worse than Option 2, but better than Option 1. There would be a 1,800 home scheme at Dunsfold Aerodrome; however, under this option there is less likelihood of a ‘strategic-scale’ scheme being delivered at Badshot Lea, and the sites that would come into contention at Haslemere and Milford are unlikely to give rise to opportunity.  Option 4 - performs better than Options 1-3 on the basis that there would be a 2,600 home scheme at Dunsfold Aerodrome. Whilst there can be no certainty, in the absence of detailed proposals, it is fair to assume that a scheme of this scale would enable delivery of a combined heat and power station (potentially even fuelled by biomass, noting the extent of woodland management locally), with a network of piping to provide ‘district heating’. There is also the question of development mix, as mixed use developments (housing and

SA REPORT: APPENDICES 116

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employment) support district heating schemes on the basis of there being a more constant demand across the day. The likelihood is that the development would be less ‘mixed’;64 however, it is not clear that this is a significant consideration.  Option 5 - Performs better than Option 4, as there would be both a 2,600 home scheme at Dunsfold Aerodrome and the likelihood of a strategic scale scheme at Badshot Lea.  Option 6 - Performs better than Option 5, as there would be the likelihood of a larger scheme at Badshot Lea.  Option 7 - Performs best, as there would be both a 2,600 home scheme at Dunsfold Aerodrome and a likelihood of strategic scale schemes at Farnham, Godalming, Haslemere and Cranleigh, albeit the scale of schemes would be reduced relative to Option 1, which could well have a bearing on whether the necessary critical mass is achieved. On the basis of these points, it is possible to conclude that Option 7 is best performing (despite being a high growth option)65 with the relative performance of the other options judged to be a factor of the scale of development at Dunsfold Aerodrome first and foremost, and secondly a factor of the degree to which development elsewhere will be concentrated (i.e. delivered through strategic-scale schemes). With regard to effect significance, no significant effects are predicted. Climate change mitigation is a global issue, and hence it is not possible to conclude on the significance of local actions.

Sustainability Topic: Community and well-being

Option 1 Option 2 Option 3 Option 4 Option 5 Option 6 Option 7 OAN; OAN; OAN; OAN; OAN + 800; OAN + 800; OAN + 2,200; nil at DA; 1,800 at DA; 1,800 at DA; 2,600 at DA 2,600 at DA; 2,600 at DA; 2,600 at DA; all Milford 800 at non- all Milford all Milford 800 at non- all Milford LAA sites; LAA sites LAA sites; LAA sites; LAA sites LAA sites; 2,500 at non- 700 at non- 700 at non- 2,100 at non- LAA sites LAA sites LAA sites LAA sites

Rank 6 2 2 4 4 7

Significant Yes No Yes effects? The equivalent appraisal narrative of 2014 begun by explaining that key considerations include the potential for each scenario to: ensure access to community infrastructure and services for new and existing residents; contribute towards reductions in socio-economic inequality between communities; and support good health amongst those living in the borough. These points reflect an understanding that housing growth can lead to funding being made available to provide new and upgraded infrastructure, and also stimulate town centre vitality and Discussion employment growth, which in turn can lead to ‘sustainable communities’ - i.e. a situation whereby both new and existing communities flourish. However, since 2014, it has become apparent that significant growth related opportunities are relatively limited in Waverley, with no headline opportunities for growth to support strategic infrastructure having been highlighted through consultation. At the same time, community concerns have been voiced regarding potential negative effects of growth. In light of these points, the alternatives can be distinguished as follows:

64 According to the site promoters, a 1,800 home scheme would deliver a net gain of 26,000 sqm of employment floorspace, whilst a 2,600 home scheme would deliver only an additional 800 sqm). 65 As high growth option, Option 7 would result in high CO2 emissions from residents in Waverley; however, per capita emissions would (it is suggested) be minimised on the basis that a greater proportion of residents would live within a modern new housing development with CHP / district heating and possibly other low carbon measures integrated.

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 Option 1 - performs poorly, despite being a lower growth option (meeting OAN). There are certain arguments in favour of focusing growth at the existing settlements (e.g. in respect of good ‘access’), and consultation with infrastructure providers has indicated few strategic community infrastructure constraints (and there will be the potential to deliver upgrades through CIL and S106); however, the scale of growth under this option could potentially present problems in respect of infrastructure. Also, the likely sites that would come into contention tend to be less than ideal in certain respects: o Farnham - There would likely be a focus of growth at Badshot Lea, including a strategic scale scheme (up to c.650 homes). There are issues of relative deprivation in the Badshot Lea area,66 and growth-related opportunities have been mooted; however, few details have been advanced. It is not clear that development would lead to strategic infrastructure upgrades or stimulate an upturn in economic activity (e.g. by attracting a major new employer to the area). Farnham would also likely see a focus of growth to the east, along Waverley Lane, some distance (over 1km) from the town centre / train station. o Godalming - There would likely be a focus of growth to the south, some distance (at least 1km) from the town centre / train station; and a relatively small (<100 home) scheme to the west of the Aaron’s Hill is also assumed. Aaron’s Hill is one of two areas within the borough that stands-out as relatively deprived; however, it is not clear that a relatively small extension would have the potential to deliver regeneration benefits. o Haslemere - There would likely be a focus of growth to the west, some distance (>1.5km) from the town centre and train station (albeit adjacent to a school and leisure centre); and to a lesser extent to the south in good proximity to the train station and town centre beyond. o At Cranleigh - There would likely be a focus of growth (perhaps 100-150 homes) to the east, some distance (>1km) from the village centre, and to the west of the village centre. Growth to the west of the village centre (perhaps as much as 450 homes) at non-LAA sites could impact in-combination with anticipated growth to the south of the village centre, at ‘LAA sites’ and sites with planning permission. It might be that there is some potential to pool developer contributions, and so deliver necessary upgrades to infrastructure; however, equally there could be negative in-combination effects, with pressure placed on existing infrastructure, e.g. education and health facilities.  Option 2 - performs better than Option 1, on the basis that a 1,800 home scheme at Dunsfold Aerodrome enables lower growth at existing settlements. Dunsfold Aerodrome is a relatively isolated location, and a smaller scheme has certain implications for critical mass (see discussion under Option 4); however, on the plus side, there would be good potential to design in green infrastructure. Development at non-LAA sites would be concentrated at Farnham and Cranleigh, with a particular concentration at Farnham (the assumption being a strategic-scale scheme at Badshot Lea - see discussion under Option 1). At Cranleigh, it is assumed that development at non-LAA sites (c.150 homes) would be concentrated fairly close to the western edge of the village centre, i.e. in a fairly accessible location.  Option 3 - performs broadly on a par with Option 2. The assumption is that there would be a smaller, c.500 home, scheme at Badshot Lea, with the 150 home shortfall made up at Haslemere and Milford. It is difficult to be certain whether or not a smaller scheme at Badshot Lea is ‘a positive’, but what is more certain is that development to the south of Haslemere (close proximity to the town centre), and to a lesser extent Milford (all sites in contention are in proximity to village centre and/or train station), has merit.  Option 4 - performs best, on the basis of involving nil growth at non-LAA sites surrounding the existing settlements; and given that a 2,600 home scheme at Dunsfold Aerodrome will ensure the critical mass necessary to deliver certain community infrastructure and transport

66 The most deprived area (‘Lower Super Output Area’) in the borough, according to the latest data (Index of Multiple Deprivation, 2015) is at Heath End, to the north of Farnham Park. This area is the 7,432nd most deprived Lower Super Output Area nationally, out of 32,844. The second most deprived LSOA is to the east of Godalming, ranking 10,878th nationally. These two areas stand-out as relatively deprived. Also, it is notable that in 2010 (when the last IMD data-set was published), the two LSOAs were ranked in reverse order, i.e. the area to the west of Godalming was the most deprived LSOA in the borough.

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infrastructure upgrades, e.g. there would be potential to support quality bus services linking Dunsfold Aerodrome to higher order services/facilities in Cranleigh/ Godalming/ Guildford/ Horsham. However, the new community would still be relatively small, e.g. not on the scale of Northstowe in Cambridgeshire, where there are high hopes of developing cohesive, inclusive and low carbon communities. The site promoters have recently confirmed that community infrastructure would be delivered in-line with the quantum of homes at the site, and a larger (2,600 home) scheme would enable delivery of a day nursery; however, a larger (2,600 home) scheme would not lead to a larger medical centre or additional sports facilities.  Option 5 - performs similarly to Option 3, but marginally worse on the assumption that a larger scheme at Dunsfold Aerodrome would lead to increased potential for in-combination effects, notably in respect of services/facilities at Cranleigh.  Option 6 - performs similarly to Option 2, but marginally worse on the assumption that a larger scheme at Dunsfold Aerodrome would lead to increased potential for in-combination effects, notably in respect of services/facilities at Cranleigh.  Option 7 - performs similarly to Option 1, but marginally worse on the assumption that a larger scheme at Dunsfold Aerodrome would lead to increased potential for in-combination effects, notably in respect of services/facilities at Cranleigh. On the basis of these points, it is difficult to draw conclusions on merits of the alternatives. The conclusion reached in 2014 was that: “… growth should either be focused at Dunsfold Aerodrome (Scenario 4) or at the main settlements (Scenario 1).” However, understanding of the issues and opportunities has moved on to some extent since 2014. On balance, it seems appropriate to conclude that Option 4 is best performing; followed by the two options that would involve 800 additional homes at the existing settlements (3,100 homes at LAA and non- LAA sites in total) and a 1,800 home scheme at Dunsfold Aerodrome (Options 2 and 3); followed by the two options that would involve 3,100 homes at LAA and non-LAA sites and a 2,600 home scheme at Dunsfold Aerodrome (Options 5 and 6); followed by Option 1 (4,900 homes at LAA and non-LAA sites), followed by Option 7 (4,500 homes at LAA and non-LAA sites, and a 2,600 home scheme at Dunsfold Aerodrome). With regard to effect significance, it would seem that the question at hand relates to whether or not significant negative effects are likely, as the potential for significant community benefit is not apparent under any option (e.g. ‘regeneration’ as a result of new development is unlikely). On the basis of consultation responses received from the public - who have voiced concern regarding high growth at the existing settlements (see discussion at para 6.5.25), and generally an understanding that numerous smaller sites will lead to challenges in respect of infrastructure delivery - it would seem appropriate to conclude a likelihood of Options 1 and 7 leading to significant negative effects.

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Sustainability Topic: Economy

Option 1 Option 2 Option 3 Option 4 Option 5 Option 6 Option 7 OAN; OAN; OAN; OAN; OAN + 800; OAN + 800; OAN + 2,200; nil at DA; 1,800 at DA; 1,800 at DA; 2,600 at DA 2,600 at DA; 2,600 at DA; 2,600 at DA; all Milford 800 at non- all Milford all Milford 800 at non- all Milford LAA sites; LAA sites LAA sites; LAA sites; LAA sites LAA sites; 2,500 at non- 700 at non- 700 at non- 2,100 at non- LAA sites LAA sites LAA sites LAA sites

Rank 4 4 4 7 2 2

Significant No effects? Within the Interim SA Report published for consultation alongside alternative housing growth scenarios in 2014, the appraisal under this ‘Economy’ topic focused primarily on the extent to which each scenario would lead to traffic congestion, on the basis that this is an important factor affecting business activity locally. In 2014 it was not clear that there was any other evidence-based understanding of strategic issues/opportunities to inform appraisal. However, things have now moved on to some extent, in particular on the basis of the Waverley Economic Strategy 2015-2020, the Waverley Employment Land Review (ELR) Update and the West Surrey Strategic Housing Market Assessment (SHMA). Beginning with the Waverley Economic Strategy 2015-2020, of the five concluding ‘objectives’, that which is most relevant to this appraisal is the objective to ‘Safeguard and enhance the borough’s attractive character and high quality of life’. The discussion under this objective focuses on maintaining the attractiveness of towns (with reference to heritage), also making reference to environmental assets; and does not identify growth related opportunities. Also, a second relevant objective is to ‘Manage employment growth and continue to encourage higher skilled and well paid jobs’, with the discussion explaining that accelerating employment growth/diversification is not a priority, although opportunities for new employment at Dunsfold Aerodrome could be explored. On the basis of these two objectives, it would seem that there is evidence in support of scenarios that focus growth at Dunsfold Aerodrome, and limit growth at existing settlements; however, it is also noted that a sixth (and final) objective is to ‘Provide affordable housing for key workers’. In this regard, there is a need to provide housing at Discussion existing settlements, particularly in the west of the borough. The ELR, authored by Atkins, considers three employment growth scenarios: Scenario 1 is based on the outputs of econometric forecasts from Experian (March 2015); Scenario 2 assumes that recent trends (1997-2013) will continue; and Scenario 3 assumes that the Economic Strategy objectives are implemented, which in practice means that past trends are assumed to continue, but with some extra shift away from traditional employment sectors and toward less land intensive sectors. The ELR concludes that: “On balance, Scenario 3 appears to be the most realistic, aligning with both historical trends and Waverley Council’s strategic priorities as outlined in the Economic Strategy. It projects small levels of employment growth, with most of the growth coming from outside the core B use class sectors – and therefore resulting in little additional B use class floorspace and land requirements. Scenario 3 is also aligned to the EM3 LEP’s strategy which does not specifically target the borough or its towns for economic growth...” With regards to Scenario 1, the ELR concludes that: “The Experian- based scenario forecasts significant levels of employment growth that do not align with historical trends or Waverley Borough Council’s vision of managed growth, as outlined in the Economic Strategy. In total, Experian’s forecasts suggest a 21% employment increase across all sectors over the period to 2033. This is considered unrealistic considering the borough’s historically low growth levels, the limited availability of additional employment land, and the Council’s continued focus on managing employment growth levels so that they do not adversely affect the borough’s attractive environment, and high quality of life.” The ELR conclusions are also supported by GL Hearn, the authors of the SHMA, who are

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confident in dismissing the Experian scenario. The SHMA assumes a lower employment growth scenario (i.e. one broadly in line with past trends and the Economic Strategy) and on this basis concludes that there is not a need to deliver new homes in Waverley, over-and- above those needed to meet demographic needs etc., in order to house workers. Conversely, the SHMA concludes that there is a need to deliver additional housing, over-and-above demographic needs etc., in Guildford and Woking in order to ensure sufficient local workforce (and avoid unstainable commuting). The discussion above would suggest that there is little evidence to support a desire to ‘force’ development - whether that be purely housing focused, or mixed-use - at the existing settlements in order to support the achievement of economic objectives. Rather, an appropriate strategy is to avoid levels of growth at the existing settlements that might compromise what currently makes them successful. In light of these points, the alternatives can be distinguished as follows:  Option 1 - has merit in the sense that it would deliver employee accommodation in close proximity to where the job opportunities are focused - i.e. at the main settlements, and to the north and west of the borough - which is a priority issue sub-regionally (albeit less of a priority issue for the Waverley Economic Strategy). However, the opportunity to deliver new employment land would not be realised, with no development at Dunsfold Aerodrome. Strategic scale schemes would be delivered at a number of locations (e.g. Badshot Lea), but it is not thought this would trigger opportunities to deliver employment land.  Option 2 - performs broadly on a par with Option 1. There would be significantly less new housing in proximity to employment opportunities at the main settlements, but a 1,800 home scheme at Dunsfold Aerodrome would deliver employment growth, i.e. a significant expansion of the existing employment area on-site.  Option 3 - performs broadly on a par with Option 2. More residents would live in proximity to a train station - enabling good access to Guildford and other growth areas - but the number of homes involved (c.150) means that this is not a significant consideration.  Option 4 - performs worse than Options 1, 2 and 3, on the basis of involving lowest growth at the existing settlements. A 2,600 home scheme at Dunsfold Aerodrome would deliver only limited employment land over-and-above a 1,800 home scheme,67 and residents would be relatively isolated from employment growth areas. Dunsfold Aerodrome is well linked to Guildford (recognising recent transport work, which suggests traffic congestion on the A281 is not a major barrier, i.e. there is potential for mitigation through upgrades),68 but is relatively poorly linked to Woking, or the growth towns to the west of the borough. The M3 Local Enterprise Partnership (LEP), through their consultation response in 2014, stated that they: “… strongly advise that consideration is given to how the scenarios link with the economy of both Waverley and its surrounding areas.” Also, Guildford Borough Council’s response highlighted the need to take account of their employment land studies (which forecast high growth) and recognise that the two authorities share a Functional Economic Market Area (FEMA).  Options 5 and 6 - perform better than Options 1, 2 and 3. There would be 3,100 homes at LAA and non-LAA sites at the existing settlements (as per Options 2 and 3) and a 2,600 home scheme at Dunsfold Aerodrome would maximise the potential to deliver new employment land.  Option 7 - performs best, on the basis that there would be high growth at existing settlements (4,500 homes at LAA and non-LAA sites) and a 2,600 home scheme at Dunsfold Aerodrome would maximise the potential to deliver new employment land. This option would contribute to meeting unmet housing needs within the Housing Market Area (HMA) and, therefore, potentially the achievement of economic objectives within the FEMA (as a shortage of housing is a barrier to employment growth); however, it would run contrary to the

67 According to the site promoters, a 1,800 home scheme would deliver a net gain of 26,000 sqm of employment floorspace, whilst a 2,600 home scheme would deliver only an additional 800 sqm). 68 There is a strong relationship between Waverley and Guildford, with over 7,700 people per day (17.6% of residents) travelling from Waverley to Guildford for work (and 3,722 in the other direction). This is the highest flow identified in West Surrey (SHMA, 2015).

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Waverley Economic strategy, which recognises that growth brings with it risks, e.g. in respect of traffic and loss of the distinctive character that makes Waverley settlements an attractive location for business. On the basis of these points, it is possible to conclude that Option 7 is best performing, followed by the options that would involve 3,100 homes at LAA and non-LAA sites aligned with 2,600 homes at Dunsfold Aerodrome alongside (Options 5 and 6); followed by the options that would involve either 4,900 homes at LAA and non-LAA sites with no scheme at Dunsfold Aerodrome (Option 1) or 3,100 homes at LAA and non-LAA sites aligned with 1,800 homes at Dunsfold Aerodrome alongside (Options 2 and 3); followed by Option 4, which performs poorly on the basis of involving only 2,300 homes at LAA and non-LAA sites. With regard to effect significance, it is difficult to conclude the likelihood of significant positive effects. This is on the basis that benefits would be relatively indirect - i.e. housing growth will deliver workforce accomodation, which in turn will support employment growth - with direct benefits (i.e. new employment floorspace) only delivered at Dunsfold Aerodrome (a relatively isolated location). Furthermore, there is a strong argument to suggest that higher growth is not in-line with the Waverley Economic Strategy, with traffic congestion a particular concern . As such, on balance, no significant effects are predicted.

Sustainability Topic: Heritage

Option 1 Option 2 Option 3 Option 4 Option 5 Option 6 Option 7 OAN; OAN; OAN; OAN; OAN + 800; OAN + 800; OAN + 2,200; nil at DA; 1,800 at DA; 1,800 at DA; 2,600 at DA 2,600 at DA; 2,600 at DA; 2,600 at DA; all Milford 800 at non- all Milford all Milford 800 at non- all Milford LAA sites; LAA sites LAA sites; LAA sites; LAA sites LAA sites; 2,500 at non- 700 at non- 700 at non- 2,100 at non- LAA sites LAA sites LAA sites LAA sites

Rank 6 2 2 4 4 7

Significant Yes No Yes effects? There is the potential for growth at the main settlements to put pressure on the integrity of historic cores / conservation areas, e.g. through increased traffic. This is a key consideration, however it is recognised that in practice growth can also bring with it investment in high streets that can support conservation of the historic environment and maintenance of historic character. Another consideration is direct impacts to the setting of designated historic assets (e.g. listed buildings); however, this is not always a strategic consideration, given that there is often good potential avoid/mitigate effects through masterplanning, landscaping and design. Discussion In light of these points, the alternatives can be distinguished as follows:  Option 1 - performs poorly as high growth at existing settlements could lead to a range of impacts: o Farnham - There would likely be a focus of growth at Badshot Lea, including a large scheme to the south of the existing built-up area where there is a cluster of three listed buildings at Badshot Farm. There would also be a likelihood of a c.160 home scheme to the east of the town at ‘Waverley Lane’; however, this site is not heavily constrained.69 o Godalming - There would likely be a focus of growth to the south, which is seemingly very

69 An recent officers report, in response to a planning application, states: “..there are no listed buildings in close proximity to the site. Third party representations have raised concerns with regard to the impact on Waverley Abbey. Officers are, however, satisfied that the resulting distance between the proposal and this heritage asset would not cause any harm. Overall, officers consider that the proposal would not cause harm to any heritage asset.” The full report is here: http://plandocs.waverley.gov.uk/Planning/StreamDocPage/obj.pdf?DocNo=5418799&PageNo=1&content=obj.pdf

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sensitive area from a heritage perspective. Specifically, development would intersect with the Munstead Conservation Area and Busbridge Lakes Registered Park / Gardens. o Haslemere - a high growth option gives rise to few risks of direct impacts, with no heritage assets in proximity to the likely growth location to the west, and only a cluster of three listed buildings (Sturt Farm) at the western edge of the site to the south of the town that would likely be called upon (with impacts likely to be mitigatable, given the size of the site). The river Wey Conservation Area is also a short distance to the west of the site to the south of the town. o Cranleigh - There would likely be a focus of growth to the west of the village centre (perhaps as much as 450 homes) at non-LAA sites with limited potential to directly impact upon heritage assets (one listed building - at Ruffold Farm - might be in close proximity). The Cranleigh Conservation Area (CA), with its high concentration of listed buildings, would be a short distance to the east, but it seems unlikely that these sites - especially those to the south of the Downs Link, which are notably separated from the CA - contribute significantly to its setting. There is also the need to consider the potential for indirect impacts from traffic, given that extensive growth is also planned to the south of the village centre at ‘LAA sites’ (in close proximity to the CA), but it is likely that most traffic arising from housing to the west of the village would avoid the village centre. o Milford - There would be a need to support the allocation/development of all ‘LAA sites’, leaving no flexibility to leave undeveloped those sites that are more sensitive. The extensive golf course site is in close proximity to the Milford Conservation Area; however, the Waverley Landscape Study (2014) concludes that: “Visibility into the area is very limited with the tree screen, giving the area an enclosed feel to its Character.” The other notably sensitive LAA sites are clustered to the west of Milford, where c.100 homes would be in proximity to a cluster of four listed buildings at Amberley Farm.  Option 2 - performs better than Option 1, as there would be less risk of housing growth at existing settlements leading to heritage impacts, and a 1,800 home scheme at Dunsfold Aerodrome leads to relatively few concerns (see discussion below). Growth at non-LAA sites would be focused at Farnham (the assumption is a large scale scheme at Badshot Lea) and Cranleigh (c.150 homes to the west of the village centre) (see discussion above).  Option 3 - performs broadly on a par with Option 2. A more modest scheme at Badshot Lea might be supported, from a heritage perspective, but development of all LAA sites at Milford gives rise to some (limited) concerns.  Option 4 - performs best, on the basis of involving lowest growth at the existing settlements and a 2,600 home scheme at Dunsfold Aerodrome. High growth at Dunsfold Aerodrome is supported, from a heritage perspective, although it is recognised that there is the potential for impacts to heritage assets. This is particularly the case as there could be pressure placed on the conservation areas at nearby Dunsfold and Alfold villages, and the conservation area at Bramley to the north could be impacted by traffic passing along the A281. It is also possible that traffic generated could impact on other villages, including Chiddingfold to the west, Hascombe and Busbridge en-route to Godalming and Milford, en- route to the A3.  Options 5 and 6 - perform worse than Options 2 and 3, given the potential for higher growth at Dunsfold Aerodrome to lead to traffic impacts. There is little potential to conclude that higher growth at Dunsfold Aerodrome should be supported, from a heritage perspective, as it would reduce the risk of unmet housing need arising from Woking having to be met at more sensitive locations within the sub-region.  Option 7 - performs worse than Option 1, with the potential for ‘in-combination’ effects notable at Munstead/Busbridge and Cranleigh, where the conservation areas would be under pressure from development in the locality and also traffic emanating from Dunsfold Aerodrome (albeit the reduced scale of development at non-LAA sites, compared to Option 1, could mean that the worst sites - notably that which intersects the Munstead Conservation Area - are left undeveloped). Again, there is little potential to conclude that higher growth at Dunsfold Aerodrome should be supported, from a heritage perspective, as it would reduce the risk of unmet housing need arising from Woking having to be met at more sensitive

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locations within the sub-region. On the basis of these points, it is possible to conclude that Option 4 is best performing; followed by the two options that would involve 3,100 homes at LAA and non-LAA sites and 1,800 homes at Dunsfold Aerodrome (Options 2 and 3); followed by the two options that would involve 3,100 homes at LAA and non-LAA sites and 2,600 homes at Dunsfold Aerodrome (Options 5 and 6); followed by Option 1 (4,900 homes at LAA and non-LAA sites and nil homes at Dunsfold Aerodrome); followed by Option 7 (4,500 homes at LAA and non-LAA sites and nil homes at Dunsfold Aerodrome). With regard to effect significance, it would seem appropriate to conclude a likelihood of Options 1 and 7 leading to significant negative effects, given a clear likelihood of impacts to nationally important assets at Godalming in particular.

Sustainability Topic: Housing

Option 1 Option 2 Option 3 Option 4 Option 5 Option 6 Option 7 OAN; OAN; OAN; OAN; OAN + 800; OAN + 800; OAN + 2,200; nil at DA; 1,800 at DA; 1,800 at DA; 2,600 at DA 2,600 at DA; 2,600 at DA; 2,600 at DA; all Milford 800 at non- all Milford all Milford 800 at non- all Milford LAA sites; LAA sites LAA sites; LAA sites; LAA sites LAA sites; 2,500 at non- 700 at non- 700 at non- 2,100 at non- LAA sites LAA sites LAA sites LAA sites

Rank 4 6 5 7 2 3

Significant Yes effects? The starting point for the appraisal is the West Surrey SHMA (2015) prepared by GL Hearn. As discussed in Box 6.4 above, the SHMA concludes that the Objectively Assessed Housing Need (OAN) figure for Waverley is 519 dwellings per annum (dpa), reaching this figure on the basis of a range of assumptions (around migration trends and housing needed to support economic growth objectives, delivery of affordable housing to meet acute housing needs, and delivery of housing to respond to market signals / address worsening affordability). There is a need to plan for the OAN figure to be achieved, or exceeded such that Waverley might contribute to meeting the unmet housing needs arising from Woking (where the adopted Core Strategy makes provision for a level of growth below OAN) in-line with the Duty to Cooperate (and recognising that Woking and Waverley share a Housing Market Area, along with Guildford Borough). However, the quantum of homes delivered is not the only consideration here. Rather, there is also a need to consider distribution, recognising that housing need is concentrated at the existing settlements, and generally more concentrated in the west of the borough than it is in the rural east. Discussion In light of these points, the alternatives can be distinguished as follows:  Option 1 performs relatively well. The plan would make provision to meet OAN, distribute housing to where it is needed most (i.e. existing settlements) and with no reliance on a new settlement at Dunsfold Aerodrome there would be high confidence that OAN would be met in a timely fashion (i.e. there would be no risk of delays to the Dunsfold Aerodrome scheme impacting on the housing trajectory).  Option 2 - performs worse than Option 1. There would be provision to meet OAN; however, a 1,800 home scheme at Dunsfold Aerodrome is less than ideal (in respect of delivering housing where it is needed most; and in respect of possible delayed delivery). Having said this, it is recognised that a strategic scale scheme at Dunsfold Aerodrome (and at Badshot Lea) would deliver a good housing mix (including a proportion of affordable housing in-line with policy) and specialist accommodation (notably, a Dunsfold Aerodrome scheme would deliver a 7,500m2 care home facility).

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 Options 3 - performs marginally better than Option 2, as growth at LAA and non-LAA sites would be more dispersed, thereby helping to ensure that more local housing needs (i.e. needs associated with particular settlements) are met, and potentially helping to ensure timely delivery (i.e. a robust housing trajectory over the plan period).  Options 4 - performs relatively poorly. There would be provision to meet OAN; however, with reliance on a 2,600 home scheme at Dunsfold Aerodrome new housing would be remote from where existing need is greatest, and there would be a risk of delayed delivery. According to the scheme promoters, it is not the case that a larger scheme would enable delivery of a larger care home facility.  Options 5 and 6 - perform better than Options 2 and 3, as a larger scheme at Dunsfold Aerodrome would mean Waverley making provision to deliver above OAN, which would help to ensure that Waverley delivers upon its OAN figure in practice, i.e. it would involve putting in place a ‘buffer’ to counter the risk of one or more sites not delivering (or not delivering fully) within the plan period. It also seems likely that under this Option Waverley would be in a position to contribute to meeting a proportion of unmet housing needs arising from Woking.  Option 7 - would result in Waverley delivering above OAN in practice (even accounting for the risk of some sites not delivering as planned) and thereby contributing significantly to reducing unmet housing needs within the Housing Market Area (HMA), arising from Woking. On the basis of these points, it is possible to conclude that Option 7 is best performing; followed by the options that would involve supporting the allocation of land to deliver ‘OAN plus 800 homes’ (Options 5 and 6; with Option 5 marginally preferred); followed by Option 1 (meet OAN, with housing dispersed to existing settlements); followed by the options that would meet OAN with a 1,800 home scheme at Dunsfold Aerodrome (Options 2 and 3; with Option 3 marginally preferred); followed by Option 4, which would meet OAN with a 2,600 home scheme at Dunsfold Aerodrome. With regard to effect significance, it would seem appropriate to conclude a likelihood of all options leading to significant positive effects, as the Waverley OAN figure would be met; however, it is recognised that there is some uncertainty under Options 1 - 4 (i.e. the options that would not plan for a ‘buffer’). Also, it is recognised that another argument suggests that only Option 7 would lead to significant positive effects as it is only this option that would ensure (or, at least, virtually ensure) that housing needs are met at the HMA scale. In line with para. 47 of the National Planning Policy Framework (NPPF), local planning authorities should: “use their evidence base to ensure that their Local Plan meets the full, objectively assessed needs for market and affordable housing in the housing market area, as far as is consistent with [principles of sustainable development].” [Emphasis added]

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Sustainability Topic: Landscape70

Option 1 Option 2 Option 3 Option 4 Option 5 Option 6 Option 7 OAN; OAN; OAN; OAN; OAN + 800; OAN + 800; OAN + 2,200; nil at DA; 1,800 at DA; 1,800 at DA; 2,600 at DA 2,600 at DA; 2,600 at DA; 2,600 at DA; all Milford 800 at non- all Milford all Milford 800 at non- all Milford LAA sites; LAA sites LAA sites; LAA sites; LAA sites LAA sites; 2,500 at non- 700 at non- 700 at non- 2,100 at non- LAA sites LAA sites LAA sites LAA sites

Rank 7 2 4 4 2 6

Significant Yes No Yes effects? There is a need to avoid greenfield development within the AONB and avoid loss of Green Belt that has been established as contributing to Green Belt purposes by the Green Belt Review. Also, there is land adjacent to the AONB that is currently designated as an Area of Great Landscape Value (AGLV), and which is also a significant constraint (particularly given a commitment by Natural England to undertake an AONB boundary review, and given an independent study that has identified candidate sites within Waverley to add to the AONB). Finally, there is a need to recognise that all landscapes within Waverley will have an identified character, with varying degrees of importance and sensitivity. Government guidance in the NPPF recognises the intrinsic character and beauty of the countryside, and encourages the effective use of previously developed (brownfield) land, provided that it is not of high environmental value. In light of these points, the alternatives can be distinguished as follows:  Option 1 - performs poorly, as there would certainly be impacts to designated landscapes at a number of locations. Specifically - o Farnham - There would likely be a focus of growth at Badshot Lea, where land is designated locally as a strategic gap (between Aldershot and Farnham), and the desire to Discussion avoid a continuous urban corridor (Farnham, Aldershot, Farnborough, Camberley and northward to Reading) is arguably of ‘larger than local’ importance. However, that part of the gap that surrounds Badshot Lea has been found by a recent review to make a “limited” contribution’ to Strategic Gap purposes.71 Also, at Farnham, there would be a likelihood of a c.160 home scheme to the east of the town at ‘Waverley Lane’, which is adjacent to designated landscapes (AGLV to the north, and AONB to the east). The Waverley Landscape Study (2014) stated, in relation to a parcel of land including this site that: “The area with its high quality character, sensitivity, and proximity to the AONB with direct visual connection means that any capacity for development is likely to be limited.” o Godalming - There would likely be a focus of growth to the south, where the land is designated as AGLV; and development would likely border the AONB and therefore could impact upon its setting. Notably, the Waverley Landscape Study refers to the parcel of land along the southern edge of the town as having “a strong landscape character with a steep wooded valley leading to the Busbridge Lakes Historic Garden and lakes.” Also, growth to the west would be within the AGLV; however, the Waverley Landscape Study (2014) identifies some development capacity. o Haslemere - Growth would likely be focused to the south and west, within the AONB. However, the Waverley Landscape Study concludes only medium (as opposed to high)

70 The evidence base is provided by the Landscape Review (AMEC, 2014), which is in three parts and available at: www.waverley.gov.uk/downloads/download/1780/waverley_landscape_report_august_2014; and the Green Belt Review (Amec, 2014), which is in two parts at: www.waverley.gov.uk/downloads/download/1781/waverley_green_belt_review-august_2014 71 Waverley Local Landscape Designation Review (Amec, 2014). Available at: http://www.waverley.gov.uk/downloads/download/1780/waverley_landscape_report_august_2014

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landscape value, and identifies some development capacity within the site to the south. o Cranleigh - There are no surrounding landscape designations, and land surrounding Cranleigh falls outside of the Metropolitan Green Belt; however, landscapes will nonetheless have some local value. To the east, the Waverley Landscape Study identifies some limited capacity for development, but equally is clear that much of the land forms “a pleasant pastoral landscape.” To the west the Landscape Study draws an even more nuanced conclusion, with the conclusion reached in relation to land west of Cranleigh and south of the Downs Link referring to low character and inter-visibility, but equally a contribution to the “green rural character to this edge of Cranleigh”. o Milford - There would be a need to support the allocation/development of all ‘LAA sites’, leaving no flexibility to leave undeveloped those sites that are more sensitive, namely sites to the west that fall within the AONB. These sites are inherently sensitive given the AONB designation; however, the Landscape study (2014) concludes “some potential for development in the area contained by the A3 and the existing settlement boundary.”  Option 2 - performs notably better than Option 1, as there would be considerably less pressure on sensitive greenfield sites (3,100 homes at LAA and non-LAA sites, rather than 4,900) and a 1,800 home scheme at Dunsfold Aerodrome gives rise to few concerns. This is a brownfield site, and whilst the AGLV skirts the site (and the AONB is c.1.2km to the northwest) there is little reason to suggest that there are ‘setting’ issues.  Option 3 - performs marginally worse than Option 2, as the assumption is that greenfield sites to the west of Milford and to the south of Haslemere would be supported, enabling lower growth at Farnham. Growth at both locations would involve impacts to the AONB, albeit the Landscape Study identifies some development capacity (see discussion above).  Option 4 - performs well, as there would be considerably less pressure on sensitive greenfield sites (as there would be nil need to support non-LAA sites; and there would not be a need to allocate/develop all LAA sites at Milford) and a 2,600 home scheme at Dunsfold Aerodrome gives rise to few concerns (as a brownfield site).  Option 5 - performs poorly as per Option 3. In addition to development at sensitive greenfield sites (as discussed under Option 3), Option 5 would also involve a 2,600 home scheme at Dunsfold Aerodrome and therefore result in the plan providing for ‘above OAN’ in order to meet Woking’s unmet needs. However, it is not possible to conclude that this is problematic, given that Dunsfold Aerodrome is non-sensitive from a landscape perspective.  Option 6 - performs relatively well as per Option 2. Again it is the case that a decision to support a larger scheme at Dunsfold Aerodrome does not mean that this option performs worse than Option 2, given that the effect will be to reduce pressure on other locations in the Housing Market Area (or wider sub-region) that might well be more sensitive.  Option 7 - performs poorly, recognising that - as per Option 1 - there would be development at sensitive greenfield sites including at sites where there would be impacts to the AONB and AGLV; however, relative to Option 1 the scale of development at some sensitive locations (e.g. to the west of Haslemere, to the south of Godalming and to the east of Cranleigh) would be reduced somewhat, leading to greater potential to leave sensitive land undeveloped or provide screening/landscaping. On the basis of these points, it is possible to conclude that Option 4 is best performing; followed by the two options that would involve 3,100 homes at LAA and non-LAA sites with a focus at Farnham and Cranleigh (Options 2 and 6), followed closely by the two options that would involve 3,100 homes at LAA and non-LAA sites with less of a focus at Farnham and Cranleigh (and conversely an increased focus at Haslemere and Milford) (Options 3 and 5); followed by the two options that would involve 4,500 or 4,900 homes at LAA and non-LAA sites (Options 7 and 1 respectively). With regard to effect significance, it is appropriate to conclude that only Options 1 and 7 would lead to significant negative effects, recognising the extent of impacts to the AONB and/or AGLV and/or landscapes that are clearly of local importance (e.g. land to the west Cranleigh village centre, which could potentially be added to the Green Belt); however, Options 2, 3, 5 and 6 would also lead to impacts.

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Sustainability Topic: Soils and other natural resources

Option 1 Option 2 Option 3 Option 4 Option 5 Option 6 Option 7 OAN; OAN; OAN; OAN; OAN + 800; OAN + 800; OAN + 2,200; nil at DA; 1,800 at DA; 1,800 at DA; 2,600 at DA 2,600 at DA; 2,600 at DA; 2,600 at DA; all Milford 800 at non- all Milford all Milford 800 at non- all Milford LAA sites; LAA sites LAA sites; LAA sites; LAA sites LAA sites; 2,500 at non- 700 at non- 700 at non- 2,100 at non- LAA sites LAA sites LAA sites LAA sites

Rank 7 4 4 3 2 4

Significant Yes No effects? A primary consideration here relates to the loss of greenfield, agricultural land to development. In this respect, there are clearly benefits to focusing growth at Dunsfold Aerodrome as this is largely a brownfield site. Also, there is a need to avoid loss of higher quality (‘best and most versatile’) agricultural land. In this respect, all land in Waverley is either Grade 2 (very good quality) or Grade 3 (good to moderate quality) in the Agricultural Land Classification, according to the nationally available ‘Provisional Agricultural Land Quality’ dataset.72 There is relatively little Grade 2 land, with patches to be found in the parishes of Farnham and Cranleigh. Elsewhere in the Housing Market Area (HMA) the pattern of agricultural land quality is similar to that in Waverley. On the basis of these points, it is possible to conclude that Options 4 is best performing, as it would maximise growth at Dunsfold Aerodrome and involve minimal greenfield development Discussion (2,300 homes at LAA sites). The next best performing options are those that would maximise growth at Dunsfold Aerodrome and involve 3,100 homes at LAA and non-LAA sites (Options 5 and 6); followed by the options that would either not capitalise on the opportunity at Dunsfold Aerodrome (Options 2 and 3), or would involve 4,500 homes at LAA and non-LAA sites (Option 7); followed by Option 1 which would involve 4,900 homes at LAA and non-LAA with no development at Dunsfold Aerodrome. There is an argument to suggest that options with less of a focus at Badshot Lea and west of Cranleigh (where the borough’s resource of higher quality Grade 2 agricultural land is understood to be concentrated) perform better; however, this is a less strategic consideration. With regards to effect significance, it is appropriate to conclude that Option 1 would lead to significant negative effects, as the opportunity to make best use of brownfield land at Dunsfold Aerodrome would not be realised.

72 The “Provisional” dataset, available at www.magic.gov.uk, is very low resolution, and does not differentiate between Grades 3a and 3b; an important consideration as the National Planning Policy Framework classifies Grades 1, 2 and 3a agricultural land as ‘best and most versatile. In order to establish agricultural land quality with any certainty there is a need to undertake field level survey using the “post 1988 criteria”; however, within Waverley survey data is available for very few sites (and none that are likely in contention for allocation).

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Sustainability Topic: Transport and traffic

Option 1 Option 2 Option 3 Option 4 Option 5 Option 6 Option 7 OAN; OAN; OAN; OAN; OAN + 800; OAN + 800; OAN + 2,200; nil at DA; 1,800 at DA; 1,800 at DA; 2,600 at DA 2,600 at DA; 2,600 at DA; 2,600 at DA; all Milford 800 at non- all Milford all Milford 800 at non- all Milford LAA sites; LAA sites LAA sites; LAA sites; LAA sites LAA sites; 2,500 at non- 700 at non- 700 at non- 2,100 at non- LAA sites LAA sites LAA sites LAA sites

Rank 3 2 4 5 6 7

Significant No effects? As discussed at the start of this report, the decision was taken in 2015 to add this topic to the SA framework. Previously, under the 2014 framework, traffic and transport issues were considered across ‘Climate change mitigation’, ‘Community and well-being’ and ‘Economy’. The aim here is to draw upon the findings of two studies recently prepared for the Council: 1) Transport Assessment (TA): Scenarios for the Distribution of Housing Growth - Stages 1, 2, 3 and 4 Reports (Mott MacDonald, February 2016 – June 2016); and 2) Waverley Local Plan Strategic Highway Assessment (SHA) (Surrey County Council, 2016). Stage 1 of the TA is a scoping stage, and then: Stage 2 focuses on traffic at key junctions along the A281 corridor under housing growth scenarios, taking account of mitigation (e.g. road upgrades); Stage 3 focuses on traffic in Farnham under housing growth scenarios, taking account of mitigation; and Stage 4 focuses the potential for modal shift away from car dependency at Farnham, Cranleigh and Dunsfold Aerodrome. The SHA examines traffic flows under five scenarios (one “do-minimum” and four “do- something”). The most detailed scenario is Scenario 5, which accounts for development of all (or at least most) LAA sites plus a 2,600 home scheme at Dunsfold Aerodrome - i.e. a scenario close to Option 4 - plus a range of strategic highways mitigation measures.73 Also of relevance are Scenarios 2, 3 and 4, which assume the same growth strategy (LAA sites plus 2,600 homes at Dunsfold Aerodrome) but with less mitigation. Perhaps most notably, for the Discussion purposes of this current appraisal, the SHA finds that: “A number of links and junctions within the borough have been identified as incurring increases in flow and delay.... The locations of such increases are predominantly located close to the largest development sites, such as Dunsfold [aerodrome] and west of Cranleigh, as well as Farnham… [However] the highway links that are to incur the greatest increases in flow… do not become the most congested links in the borough. [Rather] existing areas of congestion… specifically in the north west of the borough surrounding Farnham, continue to have the highest [congestion under all scenarios].” Also clearly of note is the overall SHA conclusion, namely that: “This strategic assessment indicates that with mitigation the residual impact of [planned growth] is not considered severe in terms of the National Planning Policy Framework guidance, with the possible exception of the effect on the A3.” On the basis of these points, the alternatives can be distinguished as follows:  Option 1 - would involve focusing development at the main settlements, with no development at Dunsfold Aerodrome. There would be good potential for Waverley residents to access services/facilities and employment opportunities within the main settlements by walking, cycling and public transport, and there would be less significant concerns regarding the A281 corridor (see discussion below); however, there would clearly be a risk of traffic congestion

73 Specifically, under Scenario 5 the SHA assumes: Highways England strategic improvements to M25 junction 10, as well as between junctions 10 and 16; widening the A3 to dual three lanes between the A31 and A320, together with improvements to the Tesco and Cathedral junctions; and local highway mitigation schemes in both Waverley and Guildford boroughs.

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impacts at Farnham. In total there would be growth of c.3,200 homes at Farnham over the plan period, a level examined within the TA Stage 3 Report, but well in excess of that assumed under the SHA scenarios. The conclusion of the TA Stage 3 Report is that mitigation measures can be envisaged, but there are challenges. Specifically: “The overall conclusion is that it should be possible to largely mitigate for the impacts of additional traffic demand resulting from new housing allocations in Farnham… but there will be additional delay due to background growth.” The TA is also clear mitigation will be easier to achieve under a lower growth scenario (with TA referring to a scenario involving 2,300 homes). Another consideration is that there is a designated Air Quality Management Area (AQMA) within Farnham.  Option 2 - would involve a 1,800 home scheme at Dunsfold Aerodrome. There would be relatively low potential for self-containment - i.e. an “internalisation” figure of c.10% might be expected - and on the basis of this level of internalisation the TA Stage 4 Report suggests that new Waverley residents would on average travel 6.6% further by car than would be the case were all new housing to be directed to existing settlements. With regards to the traffic impacts of a 1,800 Dunsfold Aerodrome scheme, in combination with growth at Cranleigh, the TA concludes that mitigation measures should be possible, although there will be delays at the A281 / Station Road junction in Bramley even after signalisation (see further discussion below). At Farnham the assumption is that non-LAA sites would still be required, and that there would be a strategic scale scheme at Badshot Lea; however, there would be 250 fewer homes at Farnham in total, relative to Option 1. A strategic scale scheme would likely lead to funding being made available for some road infrastructure upgrades; however, Badshot Lea is over 1km from Farnham Town Centre and over 2km from the Farnham train station (with Aldershot train station a similar distance). The following TA conclusion (Stage 4 Report), which is supportive of higher growth at Farnham, may only be supportive of growth focused at Badshot Lea to a limited extent: “Farnham is considered to be the most sustainable location overall for provision of new homes given its current transport options and the potential to address local car trips by transferring them to other modes.”  Option 3 - performs better than Option 2, on the basis that, whilst there would be the same quantum of growth at Dunsfold Aerodrome, there would be lower growth at Badshot Lea, with the shortfall met at Haslemere and Milford, in locations where residents would have good access to a town centre and/or train station.  Option 4 - would involve a 2,600 home scheme at Dunsfold Aerodrome. There are a number of points to make: o This is a relatively isolated location, and hence a higher degree of car dependency / need to travel longer distances by car can be expected. This conclusion holds true even once account is taken of: the potential for some people to live and work on-site; the likelihood that a high growth approach will enable delivery of a local centre and some form of bus service; the potential to support walking/cycling through design-measures; and the fact that residents of nearby rural communities will be able to make use of new services/facilities. o The number of residents working within the settlement would be higher than under Options 2 and 3 (1,800 home scheme), but the internalisation figure would still be low compared to Cranleigh (31%) and Farnham (28%); a high proportion of trips will be made by car (74-78%), which is notably higher than Cranleigh and Farnham, at 70 and 71% respectively); and car trips will be fairly long (15-16km on average, which is similar to, or slightly lower than, Farnham, but notably higher than Cranleigh at 13.5km). o The outcome of the analysis, from TA Stage 4 Report, is a suggestion that a scenario involving a 2,600 home scheme at Dunsfold Aerodrome could result in new Waverley residents on average having to travel further by car (1.7% further assuming 20% internalisation, or 8% further assuming 10% internalisation) than would be the case under a scenario that involves no housing at Dunsfold Aerodrome. o Also, the TA highlights that: there is no existing bus service to the site and it will be difficult for any new bus service to remain viable; there will be relatively poor potential to access local facilities by non-car modes; and there is relatively poor potential to access a

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train station by non-car modes. o With regards to traffic congestion, the TA (Stage 2) analysis suggests that, whilst without mitigation measures the problems currently experienced on sections of the A281 would worsen substantially, with specific mitigation measures (as set out in the TA Stage 2 Report ) delays will not significantly increase. The TA demonstrates that the Station Road junction in Bramley is likely to represent the largest constraint to traffic on the A281, even allowing for an improvement scheme to replace the existing mini-roundabout with a signalised junction. It finds that some delay would be expected in 2031 with 1,800 new homes at Dunsfold, with increased delays with 2,600 homes; however, the level of delay in the future is likely to be around the same as that currently experienced (reflecting the fact that junction improvements are forthcoming). o As such, the TA finds that it should be possible mitigate impacts on the A281.74 However, there remain uncertainties. The County Council has yet to come to a view on the related planning application for 1,800 at Dunsfold Aerodrome and is awaiting a significant amount of additional information from the developer before coming to a final view; and no mitigation has yet been identified to deal with the potential impacts on the A281 in Guildford Borough.  Option 5 - which would involve the same quantum of growth at Dunsfold Aerodrome, but additional housing at Farnham, Cranleigh, Haslemere and Milford - performs worse than Option 4. This is on the basis that development at Badshot Lea and Cranleigh is not to be supported (or at leads to question-marks) from a transport perspective (and only a small proportion of additional growth would be directed to Haslemere and Milford). The main issue at Badshot Lea is its distance from a train station (over 2km) whilst Cranleigh is a relatively rural location without a train station (albeit there is a good bus service and a high incidence of residents working in the town).  Option 6 - performs worse than Option 5, as there would be an increased focus at Farnham and Cranleigh, with less of a focus at Haslemere and Milford relative to Option 5.  Option 7 - which is the high growth option - performs poorly. o Existing issues of traffic congestion would be exacerbated at Farnham; and there would also be issues at Cranleigh (given high growth combined with 2,600 homes at nearby Dunsfold Aerodrome), although it is understood that the County Council has been seeking pooled contributions from developers of the main sites around Cranleigh to deal with traffic issues. o There is also the issue of the potential impact on the A3, particularly in conjunction with growth at Guildford. Highways England has concerns regarding the critical stretch of the A3 through Guildford. o As a relatively rural borough, in the context of the Housing Market Area (HMA), there is little in the way of a ‘sustainable transport’ argument for Waverley meeting Woking’s unmet housing needs. On the basis of these points, it is a challenge to differentiate the alternatives with any certainty. On the one hand, there is a need to prevent severe traffic congestion at Farnham, whilst on the other hand there is a need to direct housing to more accessible locations, with a view to encouraging modal shift (away from car dependency) and minimise distances travelled. On balance, however, it is determined that the latter is an overriding consideration, and hence Option 1 is best performing, with the rank of the other options a factor of A) the quantum of growth at Dunsfold Aerodrome; B) the extent to which growth would be focused at Godalming, Haslemere and Milford - i.e. those settlements with train stations and not identified as traffic hotspots; and C) the total quantum of growth. With regards to effect significance, no significant effects are predicted. The matter of car dependency / distance travelled by car is ‘at root’ a climate change mitigation / communities

74 A key message that emerged from the Strategic Transport Assessment (2014) is that there is benefit to following a strategy that focuses growth at Dunsfold Aerodrome in the sense that increased traffic congestion around the towns will be avoided and average traffic congestion across the borough will be minimised (and hence average traffic speed maximised).

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and well-being consideration, and in neither respect is there any basis for suggesting significant effects. With regards to traffic congestion considerations, whilst it is possible to point to particular locations that will be significantly impacted (e.g. Farnham under Options 1 and 7, or Bramley under Options 4-7), it is not clear that impacts at these locations would be ‘severe’ (the test that must be applied, in light of NPPF para 32), and even if localised ‘severe’ impacts could be predicted, it is not clear that this would translate to a significant negative effect at the borough-scale. There is also the matter of needing to avoid worsening of air quality within the Farnham AQMA - which includes areas of The Borough, South Street, East Street, West Street and the Woolmead - however, there is little potential to draw on evidence to conclude that this would be the case under any option.

Sustainability Topic: Water, flood risk and other climate change adaptation issues

Option 1 Option 2 Option 3 Option 4 Option 5 Option 6 Option 7 OAN; OAN; OAN; OAN; OAN + 800; OAN + 800; OAN + 2,200; nil at DA; 1,800 at DA; 1,800 at DA; 2,600 at DA 2,600 at DA; 2,600 at DA; 2,600 at DA; all Milford 800 at non- all Milford all Milford 800 at non- all Milford LAA sites; LAA sites LAA sites; LAA sites; LAA sites LAA sites; 2,500 at non- 700 at non- 700 at non- 2,100 at non- LAA sites LAA sites LAA sites LAA sites

Rank ======

Significant No effects? Key considerations relate to: A) waste water treatment infrastructure; B) Groundwater Source Protection Zones (SPZs); and C) flood risk.  With regards to waste water treatment infrastructure (i.e. the potential to locate growth in such a way as to ensure that capacity is not at risk of being breached, which can result in water pollution incidents) - both Southern Water and Thames Water were contacted in 2014 and 2015 with regards to the alternative housing scenarios (as they stood then). SW were of the view that: “Wastewater capacity should not be seen as a constraint to development… Necessary investment in strategic infrastructure can be delivered in parallel with development….” TW went slightly further, stating that “there may be local incapacities but, due to the complexities of the sewerage network and the uncertainties around the location, scale and phasing of development, it was difficult to accurately identify the infrastructure needs in terms of what upgrades will be required. Typically, local network upgrades take 18 months to 3 years to investigate, design and build. More strategic solutions 3 to 5 years and where new sewage treatment works are required this could take 7 to 10 years”. Most recently, a “stage 1” High Level Water Cycle Study (WCS) has reviewed the sewage Discussion treatment works likely to come under pressure and found that: “the existing works have a varying degree of additional capacity for expansion, and whilst generally some small scale developments may be absorbed by the existing capacity the increasing in loads are likely to require capacity increases… without allowing for additional social, commercial or industrial loads, all of the STW’s will require some form of expansion to cater for the additional development.” The study goes on to conclude that: “It is clear that further consultation is required with the water companies, and other relevant managing authorities, so that a more quantitative analysis can analyse the relationships between proposed future growth and the effects on wastewater quality, sewer capacity and environmental capacity. This quantitative analysis will take place in the Stage 2 of the High Level Water Cycle Study.” The study also states that: “The most significant challenge is managing wastewater from the Dunsfold Park development. As a development some distance away from existing STW and the resulting likelihood that the network infrastructure would be significantly under capacity for the proposed development, consideration is needed whether to build and operate network infrastructure to allow for the transportation of sewage to an existing treatment works or to build a local treatment works to service the new development.”

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 With regards to SPZs, non-LAA sites at Badshot Lea, Haslemere and Milford, which would likely feature under certain options, are located within an SPA; however, this is unlikely to be a constraint to housing growth. SPZs are constraint to polluting developments first and foremost, although there can be issues in relation to housing growth, particularly given implications for the type of sustainable drainage systems (SuDS) that can be implemented.  With regards to flood risk, the key source of evidence is the Waverley Level 1 Strategic Flood Risk Assessment (SFRA), which was updated in 2015. o There is a stand-out area of flood risk affecting land to the north of Badshot Lea, where a cluster of non-LAA sites are to be found; however, it is not clear that any of these sites would feature under any option (although there is greatest likelihood under Options 1 and 7). Also, there are extensive areas within the Badshot Lea area where soil/geology is a constraint to the implementation of infiltration SuDS (see Figure 9, Infiltration SuDS Suitability Map, within the SFRA). o Another site that is constrained by flood risk is ‘Waverley Lane’, which would likely feature under Options 1 and 7; however, the flood risk zone clips the southern edge of the site, and hence it is fair to assume that vulnerable land uses in this location could be avoided (i.e. the land could be retained as open space). o Finally, it is noted that the flood risk zone clips one of the LAA sites at Milford, such that those options (Options 3, 4 and 5) where there is not a need to develop all LAA sites at Milford can be seen to have merit. On the basis of these points, it is not possible to differentiate between the alternatives with any certainty. Nil growth at Dunsfold Aerodrome would likely necessitate growth in the Badshot Lea area, where flood risk is an issue; whilst growth at Dunsfold Aerodrome leads to some uncertainties in respect of waste water treatment and water supply infrastructure. It is not possible to conclude that Option 7 performs worst simply on the basis of involving highest growth, as it is fair to assume that the effect would be to decrease the need for housing growth elsewhere in the South East of England, which is a water stressed region. With regard to effect significance, no significant effects are predicted at the current time. With regards to flood risk, it is recognised that there will be good potential to avoid and mitigate risk through site selection, layout and design.

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Summary findings and conclusions

Categorisation and rank

Biodiversity 7 2 2 2 2 6

Climate change 7 5 6 4 3 2 mitigation

Community and well- 6 2 2 4 4 7 being

Economy 4 4 4 7 2 2

Heritage 6 2 2 4 4 7

Housing 4 6 5 7 2 3

Landscape 7 2 4 4 2 6

Soils 7 4 4 3 2 4

Transport 3 2 4 5 6 7

Water ======

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Summary findings and conclusions

Option 1 Option 2 Option 3 Option 4 Option 5 Option 6 Option 7 OAN; OAN; OAN; OAN; OAN + 800; OAN + 800; OAN + 2,200; nil at DA; 1,800 at DA; 1,800 at DA; 2,600 at DA 2,600 at DA; 2,600 at DA; 2,600 at DA; all Milford LAA 800 at non-LAA all Milford LAA all Milford LAA 800 at non-LAA all Milford LAA sites; sites sites; sites; sites sites; 2,500 at non- 700 at non-LAA 700 at non-LAA 2,100 at non- LAA sites sites sites LAA sites

Summary and conclusions The first point to note is that the ‘bookend’ options (Options 1 and 7) perform poorly in terms of a number of objectives, notably those relating to Biodiversity, Community and wellbeing, Heritage and Landscape. In each case, this is on the basis that Waverley settlements are not well suited (in the sub-regional context) to supporting extensive growth. The second point to note is that Option 4 (2,600 homes at Dunsfold Aerodrome; least growth at settlements) performs well in terms of the same objectives. Maximising development at Dunsfold Aerodrome is supported in terms of these objectives, and in particular in terms of ‘Landscape’. However, there is some uncertainty in respect of ‘Community and wellbeing’ (is the site too isolated?) and ‘Heritage’ (will traffic impact significantly on surrounding historic villages?). There is also an argument that Option 4 is best performing in terms of ‘Economy’; however, on balance it is determined that Options 5 to 7 (which would involve supporting a higher growth quantum) perform better. Whilst Option 4 is in-line with the Waverley Economic Strategy, a higher growth strategy is in-line with the wider objective of delivering housing to maximise employment growth opportunities within the sub- regional Functional Economic Area (FEMA). Option 1 also arguably has merit as there is a need for employee accommodation in close proximity to where the jobs are focused - i.e. at the main settlements and beyond the borough to the north / west - however, it would be challenging to deliver new employment land in line with Employment Land Review (ELR) targets without a Dunsfold Aerodrome new settlement. Higher growth options are also supported in terms of ‘Housing’, recognising that Woking is set to provide for less than is necessary to meet OAN, thereby leading to unmet housing needs within the HMA. However, all options would result in ‘significant positive effects’ on the basis that Waverley’s OAN target would be met (assuming delivery of sites as planned), and it may be that Woking’s unmet needs can be met by Guildford (and/or an authority outside the HMA). Option 1 also arguably has merit as there is a need for housing in close proximity to where the needs arise - i.e. at main settlements. By contrast, Dunsfold Aerodrome (upon which there would be a particular reliance under Option 4) is relatively isolated, albeit there will be the opportunity to deliver specialist accommodation. Higher growth options are also judged to perform well in terms of ‘Climate change’, simply because there would be a relative focus on larger, ‘strategic-scale’ schemes that would potentially deliver low carbon infrastructure, thereby helping to minimise per capita CO2 emissions (from the built environment). With regards to ‘Transport’, it is difficult to come to a conclusion. One argument is that growth focused at existing settlements should be supported given the potential to travel by non-car modes; however, there is equally a need to minimise worsened traffic at existing hotspots, e.g. in-and-around Farnham. With regards to ‘Water’, nil growth at Dunsfold Aerodrome could necessitate growth in the Badshot Lea area, where flood risk is an issue; whilst growth at Dunsfold Aerodrome leads to some uncertainties in respect of water supply and waste water treatment. As such, it is difficult to differentiate the alternatives. Finally, having established that the ‘book-end’ options perform poorly in terms of a range of objectives, and that Option 4 equally performs well in terms of a range of objectives, there is a need to consider Options 2, 3, 5 and 6; all of which would involve supporting c.800 homes at greenfield sites, over and above those supported under Option 4. The primary point to make is that Options 3 and 5 - which would involve distributing the 800 homes with less of a focus at Farnham - perform poorly in terms of ‘Landscape’, given the need to support sensitive sites at Milford and Haslemere. However, diverting some growth from Farnham to Milford and Haslemere does have merit from a transport perspective, and would also help to ensure certainty regarding delivery of sufficient Suitable Alternative Natural Greenspace (SANG) at Farnham (to mitigate recreational impacts to the Thames Basin Heaths).

SA REPORT: APPENDICES 135

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