Supplementary Objection to planning applications for 1,000 dwellings and associated development at Fairoaks Airport, as amended in September 2019
On Behalf of Fairoaks 2020
October 2019 Project Reference: 00019
Supplementary Objection to planning applications for 1,000 dwellings and associated development at Fairoaks Airport, as amended in September 2019
On behalf of Fairoaks 2020
Document Issue Record
Version: 1 2 3
Description/ Status: Initial draft Updates following Final comments
Date: 14/10/2019 16/10/19 18/10/19
Produced by: Stuart Miles BEng Stuart Miles BEng Stuart Miles BEng MA MRTPI MA MRTPI MA MRTPI
October 2019 Project Reference: 00019
Contents
Executive Summary ...... 2 1 Introduction ...... 7 2 Changes to Development Proposal ...... 9 3 Local Development Plan Context ...... 14 4 Fairoaks 2020’s Objection: Planning Policy Context ...... 16 Development Plan ...... 16 Surrey Heath Borough ...... 16 Runnymede Borough ...... 21 Conclusion ...... 22 Material Considerations ...... 23 Emerging Development Plan - Surrey Heath ...... 23 Emerging Development Plan - Runnymede ...... 28 National Planning Policy Framework ...... 33 5 Fairoaks 2020’s critique of the applicant’s Very Special Circumstances Assessment ...... 36 Rebuttal of Applicant’s Assessment of Harm to the Green Belt ...... 37 Contribution of and harm to the Green Belt and Openness ...... 38 Other Harm ...... 47 Loss of Aviation ...... 48 Landscape and Visual Impact ...... 65 Transport and Movement ...... 71 Flood Risk and Drainage...... 74 Benefits of the Proposal ...... 75 Utilisation of Previously Developed Land within the Green Belt ...... 76 Continued and Enhanced Economic Role ...... 79 Creating a Mixed Residential Community with no Affordability Gaps .... 82 Provision of Strategic Open Space Providing Wider Local Benefits ...... 84 Creation of a New Sustainable Community Enshrining Garden Village Principles ...... 92 6 Conclusion ...... 94 Appendix 1: Review of Road Transport Matters ...... 96
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Executive Summary
Vision Planning is instructed by Fairoaks 2020 to object to the hybrid planning application for up to 1,000 dwellings etc at Fairoaks Airport. This objection is endorsed by Unity Land LLP.
Initially, we assess the proposal against the adopted development plan, and conclude that the proposed development conflicts with the saved policies of the Surrey Heath Local Plan 2000, and policy M21 in particular, because the proposed development:
• is not solely for business aviation facilities;
• is not limited in scope;
• is not contained within the Major Developed Site; and
• will have a materially adverse effect on the environment of adjacent areas, i.e. the airport itself and areas and infrastructure adjacent to and well beyond the airport.
There is nothing in the adopted Core Strategy and Development Management Policies Plan that suggests that any major change to the strategic planning policy context for Fairoaks Airport is planned and, as the proposed development will cause the airport to close and therefore end its role as a “provider of business aviation services”, the proposal conflicts with the CSDMP. The provision of a helipad within the development does not alter this conclusion.
The proposed development therefore conflicts with the adopted Surrey Heath development plan.
There is nothing in the adopted Runnymede development plan that supports a development of this scale in the open countryside and Green Belt, so it also conflicts with the adopted Runnymede development plan.
As the proposal does not accord with the adopted development plan, it must be refused unless material considerations indicate otherwise.
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The emerging development plans for Surrey Heath and Runnymede propose no alterations to the Green Belt in this location, and the emerging Surrey Heath Draft Local Plan to 2032 proposes to identify the site as a Locally Important Employment Site, so the proposal also conflicts with the emerging development plan.
The applicant claims that the harm to the Green Belt and other harm is clearly outweighed by the benefits of the scheme, and that very special circumstances apply as a result. We totally reject this as being the case and demonstrate that this argument is totally flawed.
The proposed development is inappropriate development in the Green Belt and is therefore by definition harmful to the Green Belt. We further demonstrate that the proposal would cause significant harm to the fundamental aim and purposes of the Green Belt and cause other harm to interests of planning importance.
In terms of other harm, the applicant claims that the proposed development would result in a number of benefits, with harm only in terms of heritage and conservation and noise, and bring benefits in relation to the utilisation of PDL, the continued and enhanced economic role, creating a mixed residential community, provision of strategic open space and a SANG, and significant surface water drainage betterment.
The onus is on the developer, not objectors, to demonstrate that very special circumstances exist so as clearly to outweigh the harm to the green belt as well as any other harm.
We demonstrate, however, that the harm that the proposed development would cause has been significantly understated by the developer, and the benefits claimed are either overstated or are merely mitigation or compensation against the substantial harm which the development would bring.
We also demonstrate that in a number of regards the application is lacking vital information such that the development should be refused planning permission on this basis alone.
On that basis, we demonstrate that the harm to the Green Belt and other harm is not clearly outweighed by the benefits of the scheme, so very special
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circumstances do not apply as a result and that planning permission must in accordance with policy be refused.
There are no material considerations which outweigh the conflict with the development plan, and the application must also on this basis be refused.
Information since Original Planning Application
A report on the aviation related implications of the proposed garden village scheme at Fairoaks Airport by Allan Stratford and Associates Limited (ASA) commissioned by Surrey Heath and Runnymede Borough Councils dated August 2019 was posted on the SHBC website. This reviewed the York Aviation report written in July 2018 and submitted with the planning application as well as a subsequent addendum report prepared in July 2019. Its key conclusion was that there is strong and growing policy support for the development of general aviation and for the protection of specialist GA airfields in the UK. It also concluded that:
• the catchment area for Fairoaks Airport is larger than most of its neighbouring airfields which are further out from central London; • If planning consent for the FGVL and other possible similar development schemes requiring closure of the airport is not granted, there is no reason why Fairoaks could not continue as an operational airport, which would ultimately be under single ownership. • In common with other GA airfields, the majority of movements at Fairoaks is for recreational flying or for flight training although there is a significant level of business movements by turboprop aircraft, which potentially could represent up to 10% of all movements. • Some 144 jobs at Fairoaks could potentially be lost 47 from the West Surrey area if the airport runway were to close, with some 121 jobs lost based on a wider region covering West and outer West London. The total loss of GVA (Gross Added Value) from the local area wider region could amount to about £9.4m per annum and to about £7.9m taking account of direct, indirect and induced employment impacts. • Fairoaks is profitable on a joint basis despite the uncertainty surrounding its future and a general lack of investment in the refurbishment or replacement of its buildings and other airport infrastructure over the past 10 years, and that
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the presence of a comparatively large business park does give significant financial advantages to Fairoaks in comparison with many other UK GA airfields. • There is no reason why the airport could not be financially sustainable in the long term with some incremental investment in new airport and associated commercial development. • Relocation to other airfields was examined. Fairoaks is the aircraft owners’ preferred choice and there would be an economic disbenefit in terms of additional travel time and possibly other flight costs. In the case of aviation related businesses there are fewer options due to the lack of hangarage/offices and competition from similar types of businesses at other airfields. • The proposals for a heliport and its associated hangarage at the FGVL development would not be commercially or financially viable at the scale proposed and that there are also some doubts about the technical and environmental impacts of this facility. • Fairoaks would be included within the top 30 or so GA airfields in the UK, due to its traffic levels including business flights, its large catchment area in comparison to other neighbouring airfields and its overall financial viability, which is enhanced by its associated business park. • Given that the network could potentially comprise about 110 GA airfields, it is highly likely that Fairoaks Airport would be part of the government’s strategic network of protected GA airfields in the UK.
York Aviation has subsequently responded to the ASA Report in its Addendum Report.
Lichfields were commissioned by Surrey Heath Borough Council and Runnymede Borough Council to undertake an independent review of the economic and retail planning elements of the planning application submission, as set out in the supporting OPA9 and OPA20 documents, and reported to them in July 2019.
Lichfields concluded that although the applicant’s approach to assessing economic impacts appears to be reasonable, it is impossible on the information submitted to verify the accuracy of resulting impacts and other information presented by Quod. Further information was requested. They also concluded that there was failure to comply with NPPF policy concerning the
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leisure, retail and hotel development proposals.
The Applicants submitted further information in September 2019 which is the subject of this further public consultation. This included an Updated Planning Statement by Savills.
We conclude that this additional information does not alter the planning balance, that very special circumstances do not exist and that the application must be refused.
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1 Introduction
1.1 Vision Planning is instructed by Fairoaks 2020 to object to the hybrid planning application for up to 1,000 dwellings etc at Fairoaks Airport. This objection is endorsed by Unity Land LLP.
1.2 The application site lies in both Surrey Heath and Runnymede Boroughs, and the application has been submitted to both authorities.
1.3 The Surrey Heath Borough application reference is SH18/0642 (also registered as 18/0919), and the Runnymede Borough application reference is RU.18/1615 (also registered as RU18/1678).
1.4 Woking Borough Council has registered two formal consultations relating to this application, with reference numbers PLAN/2018/1172 and PLAN/2018/1175.
1.5 This objection has been submitted to Surrey Heath, Runnymede and Woking.
1.6 This report is structured as follows:
• Part 1: Introduction;
• Part 2: Development Proposal – a brief description of the development proposal, and the changes proposed since the original application was submitted;
• Part 3: Local Development Plan Context – a brief description of the adopted development plan context for Surrey Heath and Runnymede;
• Part 4: Fairoaks 2020’s Objection: Planning Policy Context – a description of the key development plan and national planning policies against which this application will be determined;
• Part 5: Fairoaks 2020’s critique of the applicant’s Very Special Circumstances assessment
• Part 6: Conclusion
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1.7 This objection is the initial response from Fairoaks 2020. We reserve the right to supplement this initial response and to make further representations in due course.
1.8 We note that the Updated Planning Statement explains that this application will be referred to the Secretary of State to decide whether to call the application in for determination if the LPA is minded to approve it1.
1 Updated Planning Statement, Savills, September 2019, para 5.8
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2 Changes to Development Proposal
2.1 The September 2019 revised documents submitted by the applicant refer to a number of changes in a number of places. We summarise those changes below as best we can.
Application Form
2.2 When the applications were first submitted in October 2018, the proposal description was as follows:
“Hybrid application comprising:
(a) Full application for means of site accesses (including alterations to existing accesses and a new road junction onto the A320);
(b) Outline application (all matters reserved) for the phased development of the site for up to 1,000 residential units (C3) and elderly care (C2); and, a total of 62,675sqm of non-residential floorspace, comprising employment (B1, B2, B8), education (D1), retail (A1-A5), leisure and community (D1/D2) and a hotel (C1); and a strategic parkland and Suitable Alternative Natural Greenspace (SANG) with associated car park. The change of use of Blister Hanger (aviation to equestrian), The Pillbox (aviation to D1), Gamekeeper’s Cottage (agricultural to equestrian), the retention of Woking Lodge (C3) and the retention of the Kennels (Sui Generis) and the phased demolition of all other existing buildings. Provision of supporting infrastructure, helipad and associated facilities, re-provision of existing equestrian buildings, open space and landscaping, visitor centre, associated vehicular and other access routes and related highway works.”
2.3 The updated applications, revised in September 2019, described the proposal as:
“Hybrid application comprising:
(a) Full application for means of site accesses (including alterations to existing accesses and a new road junction onto the A320);
(b) Outline application (all matters reserved) for the phased development of the site for up to 1,000 residential units (C3) and elderly care (C2); and, a total of 65,004sqm* of non-residential floorspace, comprising employment (B1, B2, B8),
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education (D1), retail (A1-A5), leisure and community (D1/D2) and a hotel (C1); and a strategic parkland and Suitable Alternative Natural Greenspace (SANG) with associated car park. The change of use of Blister Hanger (aviation to SANG maintenance store*), The Pillbox (aviation to SANG maintenance store*), Gamekeeper’s Cottage (agricultural to equestrian), the retention of Woking Lodge (C3) and the retention of the Kennels (Sui Generis) and the phased demolition of all other existing buildings. Provision of supporting infrastructure, helipad and associated facilities, re-provision of existing equestrian buildings, open space and landscaping, visitor centre, associated vehicular and other access routes and related highway works.”
2.4 We have underlined the changes in wording. The total non-residential floorspace has increased (primarily to accommodate Prime Acrobatics in the Village Core2) and the Blister Hangar and The Pillbox are now proposed to become SANG maintenance stores, rather than equestrian use and D1 use respectively.
2.5 The application form also now notes that the number of proposed employees is 1,522, where it was previously 1,545. This represents a reduction in total job numbers since the original application.
Affordable Homes
2.6 A change is proposed to the mix of affordable homes to be provided on site.
2.7 The original DAS described the affordable housing provision as “50% of the homes will be affordable or intermediate tenure to meet local need and demand.”
2.8 The original CBRE Green Belt Assessment and Very Special Circumstances report3 described affordable housing provision as “overall, 50% of the proposed housing will be affordable or provide a route into home ownership and 50% will be more traditional market housing.”
2.9 The original S106 Heads of Terms including a range of housing products
2 Para 1.35, Updated Planning Statement, Savills, September 2019 3 Para 6.92, Green Belt Assessment and Very Special Circumstances, CBRE, July 2018
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within Schedule 1, under the heading “Affordability”.
2.10 The current DAS describes the affordable housing provision as “The proposal is that 50% of the new homes are affordable or provide a route into home ownership, with at least 45% of homes meeting the NPPF Affordable Housing definition”.
2.11 The current Very Special Circumstances Addendum notes4 that “the draft Section 106 Heads of Terms commits to 45% affordable housing as defined affordable… OPA 10 outlines the provision of 50% of the proposed housing as affordable or providing a route into home ownership, this remains the case. The additional 5% provision will be achieved through an agreed overall housing mix/ provision of alternative dwellings.”
2.12 The original affordable housing proposal was ambiguous but it implied that 50% of homes on site would be affordable as defined in the NPPF. Now it is clarified that 45% of homes are proposed to be affordable as defined by the NPPF.
Open Space and SANG
2.13 Open space provision overall, and the SANG area in particular, has been reduced since the original application.
2.14 The original DAS5 indicated that 92.23 hectares of open space would be provided, including 52.78 hectares of SANG.
2.15 Now, the DAS6 indicates that 90.24 hectares of open space would be provided, including 51.97 hectares of SANG.
2.16 This appears to be primarily as a result of the exclusion of Wey Farm Kennels from the SANG. Regardless, any benefit resulting from the proposal in this regard has reduced.
4 Para 2.14, Very Special Circumstances Addendum, Savills, September 2019 5 Page 93, Design & Access Statement, JTP, July 2018 6 Page 93, Design & Access Statement, JTP, July 2019
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2.17 One of the areas of SANG is now described as “Fairoaks Parklands”7, where it was “Ottershaw Parklands”8 originally.
2.18 The original Planning Statement9 also suggested that full planning consent was being sought for the SANG, although this did not accord with the application form. This inconsistency has been corrected10.
Jobs
2.19 As noted above, the anticipated number of jobs created on site has fallen from 1,545 to 1,522 since the original application was submitted.
Highway Alterations
2.20 The Site Access Plans show that the proposed highway alterations to accommodate the proposed development have been amended. None of these amendments fundamentally alters the planning balance.
Phasing
2.21 A revised phasing plan does not appear to be separately available online, although it is included in the DAS11.
2.22 This DAS plan, along with the Planning Statement12 and Very Special Circumstances Addendum13, notes that the following are now proposed to be included in phase 1 of the proposed development:
• Prime Acrobatics;
• The helipad;
• A longer section of link road, from the A319 to the village core; originally only the northernmost 300m was included in phase 1;
7 E.g. section 1.1, SANG Strategy and Design, LDA Design, Updated 23rd August 2019 8 E.g section 1.1, SANG Strategy and Design, LDA Design, 12 July 2018 9 E.g paras 0.15/4.9, Planning Statement, CBRE, July 2018 10 E.g. paras 1.22/5.10, Updated Planning Statement, Savills, September 2019 11 Page 192, Design & Access Statement, JTP, July 2018 12 Para 6.9, Updated Planning Statement, Savills, September 2019 13 Para 1.4, Very Special Circumstances Addendum, Savills, September 2019
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• The full length of pedestrian routes and cycleways to be provided alongside the link road, from the A319 to the A320.
Accommodation for the elderly
2.23 The number of dwellings for the elderly is proposed to increase from 60 to 10014.
2.24 The number of conventional C3 dwellings is proposed to be reduced from 940 to 900 as a consequence.
2.25 We explain in the remainder of this report why none of these changes fundamentally improves the balance between benefits and harm such that the very special circumstances test is met and that, on that basis, the application must be refused.
Planning Performance Agreement Timetable
2.26 A revised PPA Timetable for the application has been posted on the SHBC website which identifies w/c 25/11 for “Report deadline SHBC committee” and w/c 13/1-3/2 (2020) as “Potential SHBC Full Council followed by RBC Planning Committee”.
14 Para 1.35, Updated Planning Statement, Savills, September 2019
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3 Local Development Plan Context
3.1 The current adopted development plans, against which the application should be considered, has not altered since the application was first submitted.
3.2 The adopted development plan for Surrey Heath Borough remains the “Core Strategy & Development Management Policies 2011 – 2028”, adopted in February 2012 (CSDMP), along with saved policies of the Surrey Heath Local Plan 2000, as set out in Appendix 1 of the CSDMP.
3.3 The plan period for the CSDMP is 2011 to 2028, and the plan period for the Local Plan 2000 was originally 1991 to 2006.
3.4 The current adopted development plan for Runnymede Borough remains the saved policies of the Runnymede Borough Local Plan Second Alteration 2001. This covers the period 1991 to 2006.
3.5 The Chobham Neighbourhood Plan is still currently in the early stages of preparation. The designated area includes the part of Fairoaks Airport that lies within Surrey Heath Borough.
3.6 The primary material considerations in the determination of this application are the National Planning Policy Framework (NPPF), Planning Practice Guidance (PPG) and the emerging development plan in both boroughs.
3.7 The emerging development plan for Runnymede is more advanced than for Surrey Heath.
3.8 The Runnymede 2030 Draft Local Plan was made available for Regulation 19 consultation from 11th January to 22nd February 2018, and the Runnymede 2030 Part 2 Draft Local Plan was made available for Regulation 19 consultation from 18th May to 29th June 2018. Both are now being examined, with final hearing sessions scheduled for November 2019. The plan period for the Runnymede 2030 Local Plan is 2015 to 2030.
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3.9 The emerging Surrey Heath Draft Local Plan 2016 to 2032: Issues and Options/Preferred Options Consultation was made available for consultation to 30th July 2018. The plan period for the Surrey Heath Draft Local Plan is 2016 to 2032.
3.10 The applicant’s Planning Statement suggests15 that Surrey Heath BC’s emerging Local Plan has been delayed, noting that the Local Development Scheme proposes pre-submission consultation in June 2019 and submission in September 2019. They note that pre-submission consultation is now proposed for January/February 2020, with a consequent delay to later stages. On the Surrey Heath BC website16 it is stated that the Council is in the process of updating the timetable for the emerging Local Plan (Local Development Scheme). The next consultation on the emerging Local Plan will take place in winter 2020.
15 Para 8.7, Updated Planning Statement, Savills, September 2019 16 As at 16 October 2019
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4 Fairoaks 2020’s Objection: Planning Policy Context
4.1 Fairoaks 2020 continues to strongly object to the proposed development at Fairoaks Airport for the reasons set out in our November 2018 objection and below.
4.2 Section 38 (6) of the Planning and Compulsory Purchase Act 2004 requires planning applications to be determined in accordance with the adopted development plan unless material considerations indicate otherwise.
4.3 Most of the proposed built form in the application lies within Surrey Heath Borough, with most of the proposed SANG and strategic open space being proposed within Runnymede Borough.
4.4 The current and emerging development plans for Surrey Heath and Runnymede are set out in section 3.
Development Plan
4.5 The assessment below demonstrates that the proposed development does not accord with the adopted development plan, and that the additional information provided, and changes proposed by the applicant in September 2019 do not alter this.
4.6 In accordance with Section 38(6) of the Planning and Compulsory Purchase Act 2004, unless material considerations indicate otherwise, there is a presumption against granting planning permission for the proposed development. It will also be demonstrated in this assessment that there are no considerations which outweigh the policies of the development plan.
Surrey Heath Borough
4.7 All of the built form of the proposed development, other than part of the
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link road and buildings associated with the sports facility and SANG Visitor Centre, lies within Surrey Heath Borough.
4.8 Fairoaks Airport is defined in saved policy RE17 of the Surrey Heath Local Plan 2000 as one of three “Major Developed Sites in the Green Belt”. The policy notes that “further development at Fairoaks Airport will be subject to Policy M21 of this Plan.”
4.9 Policies RE17 and M21 are as follows:
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4.10 The Proposals Map: East Sheet shows the boundary of the Major Developed Site at Fairoaks Airport, and shows that the site lies entirely with the Green Belt. An extract is overleaf.
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4.11 Saved policy M21 sets a number of criteria for development at Fairoaks Airport. These include (with our emphasis):
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• that the airport has “limited potential for the development of business aviation facilities”;
• this limited development must “not have a materially adverse effect on the environment of adjacent areas”;
4.12 The policy then goes on to explain how proposals for infill and redevelopment within the bounds of the Major Developed Site should be considered.
4.13 The proposed development:
• is not solely for business aviation facilities;
• is not limited in scope;
• is not contained within the Major Developed Site; and
• will have a materially adverse effect on the environment of adjacent areas, i.e. the airport itself and areas and infrastructure adjacent to and well beyond the airport.
4.14 The proposal therefore conflicts with the Local Plan 2000.
4.15 Policy CP1 of the Surrey Heath CSDMP maintains the current Green Belt and notes that changes to Major Developed Sites are to be considered through a site allocations DPD.
4.16 Paragraph 5.7 of the CSDMP confirms that the Fairoaks Airport Major Developed Site boundary remains extant and paragraph 5.91 notes that:
“the role of Fairoaks Airport both as a provider of business aviation services and an important local employer will be supported. Fairoaks Airport is identified as a Major Developed Site within the Green Belt. The Borough Council expects the future development needs of the site to be addressed through an airport masterplan to support its identification as a Major Developed Site within the Green Belt as set out in Policies RE17 and M21 of the Surrey Heath Local Plan 2000. Those policies will be updated and reviewed through the Site Allocations DPD.”
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4.17 There is nothing in the CSDMP that suggests that any major change to the strategic planning policy context for Fairoaks Airport is planned and, as the proposed development will cause the airport to close and therefore end its role as a “provider of business aviation services”, the proposal conflicts with the CSDMP.
4.18 The proposed development therefore conflicts with the adopted Surrey Heath development plan.
Runnymede Borough
4.19 The application proposes various forms of strategic open space within Runnymede, as well as part of the link road and built form associated with the sports facility and SANG Visitor Centre.
4.20 The Runnymede Local Plan 2001 policies map identifies the site as being with the Green Belt and a Landscape Problem Area.
4.21 Of the Runnymede policies which relate to the Green Belt and are saved, only policy GB5 is relevant.
4.22 We will demonstrate later that the proposed development as a whole must be considered, that no part of it is essential, and the provision of outdoor sports facilities in this location cannot be argued to be essential
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either.
4.23 No other adopted development plan policies for Runnymede express any support for the proposed development.
Conclusion
4.24 The proposal does not accord with the adopted development plan, so it must be refused unless material considerations indicate otherwise.
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Material Considerations
4.25 As noted above, the primary material considerations in this instance are emerging planning policy in Surrey Heath and Runnymede, the National Planning Policy Framework (NPPF) and Planning Practice Guidance (PPG).
Emerging Development Plan - Surrey Heath
4.26 The Surrey Heath Local Development Scheme 2018-2021 includes the following timetable for the emerging Local Plan.
4.27 The Surrey Heath Draft Local Plan to 2032: Issues and Options/Preferred Options Consultation was released, on time, in June 2018.
4.28 The pre-submission consultation and submission drafts of the emerging Local Plan have been delayed however, as noted in paragraph 3.10. The applicant suggests17 that pre-submission consultation is now proposed for January/February 2020, with a consequent delay to later stages.
4.29 On that basis, the Issues and Options/Preferred Options Consultation
17 Updated Planning Statement, Savills, September 2019, para 8.7
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remains the most recent version of the emerging Surrey Heath Local Plan.
4.30 The Preferred Policy Approach to Housing Delivery in the emerging Local Plan is as follows18:
4.31 The only housing development proposed in the Green Belt is “small scale development in previously developed land in the Green Belt.” This development is not small scale, it is large scale, and we will demonstrate later that the majority of the site is not previously developed, so the
18 Para 3.24, Surrey Heath Draft Local Plan to 2032: Issues and Options/Preferred Options Consultation, June 2018
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proposal conflicts with the emerging policy in this regard.
4.32 The Preferred Policy Approach to Employment Land includes the following19:
…
4.33 The draft policy specifically refers to Enterprise M3’s priority and niche sectors set out in its Strategic Economic Plan.
19 Para 4.13, Surrey Heath Draft Local Plan to 2032: Issues and Options/Preferred Options Consultation, June 2018
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4.34 These include a number of business sectors already found at Fairoaks Airport, including “advanced aerospace/ automotive manufacturing”, “aerospace and defence” (including pilot training), “professional and business services”, “ICT and digital media”.
4.35 The applicant proposes to provide a net addition of circa 1,227 jobs on site, in association with the additional 1,000 homes. It is notable that, when the application was submitted, the proposed net additional jobs was 1,250, so this benefit claimed by the applicant has reduced in the year that the application has been with the LPAs for determination.
4.36 In any event, the loss of the airport will inevitably result in the loss of high quality skilled aviation based jobs at the airport. The applicant’s proposal to provide a helipad will not mitigate this loss, whether it is included in phase 1, or later as previously proposed.
4.37 The helipad is proposed to be located 150m from the nearest new housing, where helicopter operations would be likely to cause an unacceptable impact on residential amenity by reason of noise and disturbance. Further, the location of the proposed helipad is impractical for helicopter operations.
4.38 In terms of sites within the Green Belt, the Issues and Options/Preferred Options Draft Plan includes preferred policy approaches to extensions, replacement buildings, limited infilling or partial or complete redevelopment of previously developed sites, and proposals for the reuse of buildings.
4.39 The applicant claims, wrongly as we explain later, that a large proportion of the site is previously developed. Such a claim is contrary to the definition of PDL (previously developed land) in NPPF.
4.40 The preferred policy approach in this regard is as follows20:
20 Page 89, Surrey Heath Draft Local Plan to 2032: Issues and Options/Preferred Options Consultation, June 2018
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4.41 Even if the site was entirely previously developed, and we demonstrate later that it is clearly not, the proposal will have a “detrimental impact upon the openness of the Green Belt”, so it does not accord with this emerging policy.
4.42 On that basis, the proposal does not accord with the emerging Surrey Heath Local Plan policy in relation to housing, employment or the Green Belt.
4.43 Any suggestion that this emerging policy supports an approval of the application can be demonstrated to be flawed with reference to the Wisley Airfield recovered appeal.
4.44 In the Wisley appeal21, the Inspector explains that “this site is identified in the eLP (emerging local plan); it is the only such site in this emerging local plan
21 Appeal Ref: APP/Y3615/W/3159894
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and its allocation is supported in … background documents… GBC (Guildford Borough Council) has agreed that it is essential for the development strategy proposed in the eLP. As things stand, however, the site still lies within the Green Belt although GBC, through the eLP is seeking to remove it from this designation. As set out above, however, the eLP has still to undergo its EiP and its weight is limited.”22
4.45 Therefore, even if Surrey Heath Borough Council was to propose to allocate the whole of the airport for the development proposed, which we emphasise it does not, it could not be approved at this stage as being in accordance with policy.
Emerging Development Plan - Runnymede
4.46 The Runnymede Borough Local Plan Part One was submitted in January 2018. Part Two was submitted in May 2018.
4.47 The Runnymede Borough Local Plan Policies Map shows that the part of the site in Runnymede lies within the Green Belt, where emerging policies EE14 to EE19 apply, and within the Thames Basin Heaths SPA 5km Buffer Zone, where emerging policy EE10 applies.
4.48 The southern extremity of the site lies within a Biodiversity Opportunity Area where policy EE11 applies.
4.49 In some cases, the submission draft version of these policies are proposed to be modified, as set out in Appendix 6 of Runnymede BC’s “Responses to the Inspector’s Matters and Questions for the Stage 2 hearings (matter 11)”, dated February 2019.
22 Para 20.165, Inspector’s Report, Appeal Ref: APP/Y3615/W/3159894
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4.50 Proposed policy EE14 deals only with extension and alteration to and replacement of buildings in the Green Belt, so is not relevant to this proposal.
4.51 Proposed policy EE15 deals only with the reuse of buildings so is not relevant to this proposal.
4.52 Policy EE16 deals with outdoor sport and recreation so this policy is relevant to the proposed sports facility and associated buildings. The latest version of the policy, as proposed to be modified by the LPA at the examination, is as follows.
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4.53 As noted above in relation to adopted policy GB5, we will demonstrate later that the proposed development as a whole is not required, so the provision of outdoor sports and recreation facilities in this location cannot be required either.
4.54 Proposed policy EE17 deals with infilling or redevelopment on previously developed land. The latest version of the policy, as proposed to be modified by the LPA at the examination, is as follows.
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4.55 As noted above in relation to the emerging Surrey Heath planning policy, we will demonstrate later that the majority of the site is not previously developed. Furthermore, it has a “greater impact on the openness of the Green Belt than the existing development” so the proposal conflicts with the emerging policy in this regard.
4.56 The proposed road would be considered against proposed policy EE18. The version as proposed to be modified is below.
4.57 The development as a whole conflicts with local and national planning policy.
4.58 Proposed policy EE10 sets out requirements for the provision of or contributions towards SANG in circumstances where development is, in principle, acceptable. Policy EE11 sets out requirements for the contribution towards the delivery of green infrastructure. Both policies aim to mitigate the negative effects of residential development. They do not provide policy support for unacceptable development. We deal with this further in paragraphs 5.212 to 5.219.
4.59 On that basis the proposed development conflicts with the emerging policies in the Runnymede Local Plan, particularly in relation to the Green Belt. The engineering operations proposed, which include construction of a link road, are inappropriate development which conflicts with Green Belt policy.
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National Planning Policy Framework
4.60 Paragraph 11 of the 2019 NPPF sets out a presumption in favour of sustainable development. It reads as follows:
4.61 The footnotes are also relevant. These are as follows:
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4.62 The applicant argues that the Runnymede and Surrey Heath development plans are out of date on the basis of age and a shortage of local housing land supply, and on that basis argues that paragraph 11 d) is triggered.
4.63 Paragraph 11 d) states that permission should be granted, subject to two provisos:
• Part i. is that “the application of policies in (the NPPF) that protect areas or assets of particular importance provides a clear reason for refusing the development proposal.”
• Part i. refers to footnote 6, which notes that “the policies referred to are those in (the NPPF) relating to: … land designated as Green Belt…”
4.64 On that basis, the proposal must first be considered against the Green Belt policies in the NPPF before any consideration can be given to the “tilted balance” in part ii.
4.65 NPPF chapter 13 deals with “Protecting Green Belt land”. It begins, in paragraph 133, by explaining that:
4.66 Paragraph 134 sets out the five purposes of the Green Belt:
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4.67 Paragraphs 145 and 146 specify which buildings and other forms of development are not inappropriate in the Green Belt. None of these apply to this proposal so the proposed development is, by definition, inappropriate development in the Green Belt.
4.68 Paragraphs 143 and 144 explain what this means:
4.69 Therefore, on the basis that the proposed development is by definition inappropriate in this location, it can only be approved where “very special circumstances” exist, and these “will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm resulting from the proposal, is clearly outweighed by other considerations.” (emphasis added). From a reading of the application and supporting documents, it is understood that the applicant accepts this formulation of policy.
4.70 The applicant claims that very special circumstances do exist, and that these clearly outweigh harm to the Green Belt and other harm. The next section demonstrates that the applicant is wrong in this conclusion.
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5 Fairoaks 2020’s critique of the applicant’s Very Special Circumstances Assessment
5.1 The applicant has submitted an addendum to the Green Belt Assessment and Very Special Circumstances report produced by CBRE and submitted with the original application.
5.2 The Addendum notes23 that “This VSC Addendum does not impact the assessment or conclusions drawn from the Green Belt Assessment and Very Special Circumstances report prepared by CBRE. It simply provides an update on the benefits of the proposals.”
5.3 We explain below that neither the information provided in the Addendum, nor any of the other changes proposed or updated reports provided fundamentally alters the planning balance such that the application should be approved.
5.4 In essence, the applicant’s case is that harm to the Green Belt and other harm is clearly outweighed by the benefits of the scheme, and that very special circumstances apply as a result.
5.5 We demonstrate that very special circumstances do not outweigh the totality of the harm that the proposal would cause to the Green Belt and other factors, as would be required for the application to be approved.
5.6 The applicant claims that harm to the Green Belt is minimal because they seek to suggest that the site does not meet any of the purposes of the Green Belt, and because the proposals would not have a material effect upon openness.
5.7 We will demonstrate that this argument is totally flawed.
5.8 The application proposes a significant mixed use development on 155.5
23 Para 1.7, Very Special Circumstances Addendum, Savills, September 2019
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hectares of Green Belt land, of which only 11.1 hectares is previously developed. The applicant’s contention that the site includes 49 hectares of previously developed land is plainly wrong, and the Dunsfold Aerodrome decision does not alter this conclusion. Only 11.1 ha is previously developed land in accordance with the NPPF Annex 2 definition24.
5.9 Further, as the applicant claims that the use of PDL “is an important contribution in the balance of the VSC case"25, this material error plainly undermines the applicant’s case which relies heavily on this claim.
5.10 This is explained in more detail in paragraphs 5.163 to 5.178.
5.11 The site makes a significant contribution to the fundamental aim and purposes of the Green Belt, so the harm that the proposal would cause to the Green Belt is also significant.
5.12 The benefits that the applicant puts forward (other than meeting a housing shortage which is not as severe as the applicant claims) are merely mitigation of the impacts of the proposal. The recent additions and amendments do not change this conclusion.
Rebuttal of Applicant’s Assessment of Harm to the Green Belt
5.13 As set out above, paragraphs 143 and 144 of the NPPF explain that:
• “Inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances”; and
24 Definition in NPPF Annex 2 “Previously developed land: Land which is or was occupied by a permanent structure, including the curtilage of the developed land (although it should not be assumed that the whole of the curtilage should be developed) and any associated fixed surface infrastructure. This excludes: land that is or was last occupied by agricultural or forestry buildings; land that has been developed for minerals extraction or waste disposal by landfill, where provision for restoration has been made through development management procedures; land in built-up areas such as residential gardens, parks, recreation grounds and allotments; and land that was previously developed but where the remains of the permanent structure or fixed surface structure have blended into the landscape.” 25 Para 3.22, Green Belt Assessment and Very Special Circumstances
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• “Very special circumstances will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm resulting from the proposal, is clearly outweighed by other considerations.”
5.14 On that basis, between paragraph 5.16 and 5.63 we demonstrate that the proposal would cause significant harm to the fundamental aim and purposes of the Green Belt.
5.15 In paragraphs 5.64 to 5.160 we assess other harm and, in paragraphs 5.161 to 5.230 we assess the benefits claimed by the applicant of the proposal.
Contribution of and harm to the Green Belt and Openness
5.16 In order to assess the harm to the Green Belt it is first necessary to consider how the site contributes to the fundamental aim and purposes of the Green Belt set out in paragraphs 133 and 134 of the NPPF.
5.17 The applicant claims26 that “the openness of the existing site is diminished, most obviously in the north-western corner, and in a more limited nature spreading east and south from there across the operational airfield.”
5.18 That the openness of the site is diminished by the existence of the airport buildings in the North West corner (only) of the site is not disputed. This is why Surrey Heath Borough Council has included these buildings within a Major Developed Site boundary and why saved adopted plan policy M21 allows for limited development of business aviation facilities within this limited area, subject to a number of provisos including that any development does not have a materially adverse effect on adjacent areas. The impact of the existing buildings on the site on openness is confined to the North West corner and does not extend over the whole airfield, as is suggested by the applicant.
5.19 The applicant is in particular wrong to suggest that the at-grade infrastructure at the airport, i.e. the runway and taxiways, significantly
26 Para 3.44, Green Belt Assessment and Very Special Circumstances, CBRE, July 2018
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diminish the site’s openness. They do not.
5.20 Openness in Green Belt policy is a reference principally to an absence of buildings and built development, i.e. areas without vertical built form. The at-grade runways and taxiways do not compromise the site’s openness.
5.21 In particular when the proposed built development of the site with 1000 dwellings and large industrial buildings are considered, the impact on openness of the existing site and its facilities do not compare. The applicant fails to carry out this comparison properly and reach this clear and obvious conclusion which is unavoidable.
5.22 The word “openness” is open-textured and a number of factors are capable of being relevant when it comes to applying it to the particular facts of a specific case. Prominent among these will be factors relevant to how built up the Green Belt is now and how built up it would be if redevelopment occurs (in the context of which, volumetric matters may be a material concern, but are by no means the only one) and factors relevant to the visual impact on the aspect of openness which the Green Belt presents.27
5.23 The NPPF explains28 that “the fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.”
5.24 By being open, the airfield contributes to this fundamental aim. The built form of the airport buildings adjacent to the airfield are limited in their extent and impact on the openness of adjacent areas of the airfield. They do not impact on the airfield’s openness any more than buildings on the edge of an existing urban area hinder the openness of open fields adjoining that urban area.
5.25 If the applicant’s argument were to be applied in such a case, it would mean that areas of Green Belt adjacent to urban areas within the Green
27 See Turner v Secretary of State for CLG [2016] EWCA Civ 466 (Court of Appeal) at [14] 28 Para 133, NPPF
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Belt would become vulnerable to being released for development as, on the applicant’s argument, the openness of all open fields would be compromised. The applicant’s approach to Green Belt policy interpretation is wholly wrong in principle.
5.26 The applicant appears to accept the inter-relationship between a lack of vertical built form and openness when they refer to “the proposed buildings of larger scale, height and mass associated with the proposed employment uses (being) focussed in the north-westernmost corner of the site” and then note that “this is the location of the existing vertical built form on the site and so any additional physical effect on openness from the proposed built form is diminished in this location.”29
5.27 The applicant then explains that “this approach of locating buildings in replacement of existing buildings to negate a loss of openness is not applicable to other areas of the site where vertical mass and scale is proposed to be introduced where it is currently horizontal and linear, such as the runway and taxiways. There is in this case a physical impact on the openness of the site.”30
5.28 This is a correct conclusion. The vertical built form in the north west of the site is not open; the rest of the site is, and the impact of additional vertical built form on the currently open airfield would clearly have a significant impact on the openness of the Green Belt, and therefore cause harm to the Green Belt’s fundamental purpose. The applicant is wrong to conclude that there is a limited impact on openness or harm to the Green Belt.
5.29 On that basis it is clear that the site’s openness is far greater than the applicant claims, that its contribution to the fundamental aim of the Green Belt is far greater than the applicant claims, and therefore that the harm that the development would cause to the fundamental purpose of the Green Belt is far greater than the applicant claims.
5.30 The applicant then goes on to assess the site’s contribution to the Green Belt against the five purposes of the Green Belt. We demonstrate below
29 Para 5.27, Green Belt Assessment and Very Special Circumstances, CBRE, July 2018 30 Para 5.28, Green Belt Assessment and Very Special Circumstances, CBRE, July 2018
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that the applicant significantly underestimates the contribution of the site to the Green Belt, and therefore the harm that the development would cause to these 5 purposes.
5.31 Nevertheless, it must be noted at the outset that the applicant accepts that the proposal would cause harm to purpose 3, “to assist in safeguarding the countryside from encroachment”. The applicant also accepts that the development is inappropriate in the Green Belt. The NPPF31 explains that “inappropriate development is, by definition, harmful to the Green Belt and should not be approved in very special circumstances.” There is no reference here to degrees of harm. It is clear that the application would cause harm to the Green Belt and can only be approved in very special circumstances. These have not been demonstrated by the applicant.
5.32 It is not the role of a planning application process to consider whether the Green Belt boundary should be amended; that is the role of the development plan and statutory process alone. Once established, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans.32 Surrey Heath Borough Council is reviewing its Local Plan and does not propose to release this application site from the Green Belt.
Purpose 1: To check the unrestricted sprawl of large built-up areas
5.33 The applicant claims that the site does not contribute to this Green Belt purpose, and relies on the SHBC Green Belt Review in making its case.
5.34 The first point to note is the flawed basis of the applicant’s approach to their argument, namely that a site which is wholly within the Green Belt and separated from the urban area of a large town (here the northern edge of Woking) by less than 2kms of countryside does not contribute to Green Belt Purpose 1.
5.35 As a matter of principle this is wrong. Taking the applicant’s approach, it
31 Para 143, NPPF 32 Para 136, NPPF
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would only be land which lies immediately adjacent to the urban area which would meet this criterion. If this were so, then it raises the question at what point does the width of Green Belt stop contributing to this purpose. The Green Belt in this location is many kilometres wide and is highly vulnerable to development pressures. There is no doubt that the belt of land to the north of Woking, including the application site, contributes to this purpose.
5.36 It must be noted that the SHBC Green Belt Review has still not yet been tested at examination, so its content and conclusions carry limited weight at this stage and cannot be relied upon in determining planning applications. In any event, the purpose of the Green Belt Review is to inform the emerging Local Plan, and the emerging Local Plan does not propose to amend the Green Belt boundary at Fairoaks.
5.37 The applicant notes that the site is separated from Woking by the Thames Basin Heaths33, but that “the McLaren Technology Centre, immediately south of the site, sits as a standalone built element…”34.
5.38 That Woking is constrained from expanding to the north by the SPA does not justify development “leapfrogging” the SPA and developing to its north. On that basis, we would argue that the development would continue the sprawl of Woking to the north, so the site also contributes to this purpose by controlling this.
Purpose 2: To prevent neighbouring towns merging into one another
5.39 The applicant claims that the site does not contribute to this Green Belt purpose, and prays the SHBC Green Belt Review in aid.
5.40 As a matter of principle, this too is wrong for very much the same reasons as are set out in relation to GB Purpose 1. It is to be noted that the addition of the word “large” before “towns” does not appear in the policy. The Green Belt in this location prevents Woking from merging with the
33 Para 4.23, Green Belt Assessment and Very Special Circumstances, CBRE, July 2018 34 Para 4.21, Green Belt Assessment and Very Special Circumstances, CBRE, July 2018
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urban areas of Camberley, Lightwater, Bagshot and Chobham to the west of the site, Ascot, Sunningdale and Virginia Water to the north, Weybridge/Walton-on-Thames, Chertsey, Addlestone and Ottershaw to the east and Woking to the south.
5.41 Even though by reason of the services available some of these smaller areas are classed as villages, such settlements are separated from adjacent towns and urban areas by short distances and have populations often found in small towns elsewhere35. The Green Belt prevents the merging of such neighbouring towns and urban areas. The development of the site would further fragment the Green Belt and by reason of its location near the centre of these areas have a particularly damaging effect on the Green Belt.
5.42 The SHBC Green Belt Review, which has not been tested at examination as noted above and therefore is to be given limited weight, explains that the airfield buildings make a weak contribution to this purpose and the open parts make a stronger contribution36.
5.43 The adopted Local Plan allows development on the area where buildings are currently located, and it is correct to conclude that the north-west corner of the site makes a weak contribution to the Green Belt. However, the open parts of the airfield and the non-developed parts of the site clearly make a greater and indeed significant contribution to this purpose.
5.44 The applicant notes37 that “the site is located between (Chobham, Ottershaw and Woking) and therefore makes up part of their separation.” To conclude that the development of a large site that separates these settlements has no impact on the purpose of the Green Belt to prevent neighbouring towns merging into one another is plainly flawed.
35 2011 Census population data: Chobham 2,771; Ascot 5,753; Ottershaw 2,853; Addlestone 11,501. 36 Para 5.141, Surrey Heath Local Plan Appraisal of Sites: Green Belt Sites, LUC, March 2018 37 Para 4.27, Green Belt Assessment and Very Special Circumstances, CBRE, July 2018
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Purpose 3: To assist in safeguarding the countryside from encroachment
5.45 In relation to purpose 3, the applicant concludes that the site makes a moderate contribution to the Green Belt.
5.46 That the applicant accepts that the proposal causes some level of harm to the Green Belt is therefore not in doubt and, as noted above, this means very special circumstances must apply for permission to be granted.
5.47 However, the applicant’s argument that the site makes only a moderate contribution to the site is based on their conclusions about the site’s openness which we have demonstrated above to be wrong. It does not have a limited impact on the Green Belt purpose to safeguard the countryside from encroachment, as claimed. What is proposed is a large physical encroachment of 1,000 houses and mixed use development on some 40ha and development of large areas of employment land on some 12 ha of the site, in total some 55 ha of built development, all proposed in the countryside in the Green Belt.
5.48 The applicant’s reference38 to “balancing” the different characteristics across the site implies that it is somehow appropriate to average the different contributions to reach the conclusion that the site as a whole contributes moderately overall. This logic is flawed.
5.49 The area included within the existing Major Developed Site boundary alone (some 4.4 ha) is built up with buildings, and not open, whereas the airfield (some 50 ha) is not built up and is open. The contributions that each area makes cannot be “balanced” in the way the applicant seeks to argue that the effect of the development is minimal. This is a novel and totally wrong approach to Green Belt policy, demonstrating the degree to which compromises in and departures from such policy application need to be made to justify the development of the site.
38 Para 4.72, Green Belt Assessment and Very Special Circumstances, CBRE, July 2018
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5.50 The majority of the proposed development is on open Green Belt land which contributes strongly to this Green Belt purpose. This is where the most significant harm would occur.
5.51 Even if we were to accept the applicant’s interpretation of openness at the airfield itself, which we emphasise we do not, they still acknowledge that “the proposals do extend beyond this into currently undeveloped areas of the site that contribute towards purpose 3.”39
Purpose 4: To preserve the setting and special character of historic towns
5.52 The applicant and SHBC in its Green Belt Review conclude that the site does not contribute to this purpose.
5.53 The applicant refers to page 7 of “Planning on the Doorstep: The Big Issues – Green Belt”, PAS Feb 2015. This section is entitled “Green Belt Reviews”, i.e. those which occur through the Local Plan process, where one site is compared with another to justify alterations to particular parts of the Green Belt where exceptional circumstances exist.
5.54 In this case, as this is a planning application, very special circumstances must exist for permission to be granted, and these have not been demonstrated.
Purpose 5: To assist in urban regeneration by encouraging the recycling of derelict and other urban land
5.55 The applicant concludes that the site does not contribute to purpose 5 by arguing that there is a shortage of housing land in Surrey Heath Borough.
5.56 This misses the point of this purpose, which is to assist in urban regeneration. The development of a large site in the open countryside with 1,000 homes and employment development does nothing to assist urban regeneration. In fact, it would do the opposite, by resulting in the development of a significant area of unallocated greenfield land in the
39 Para 5.55, Green Belt Assessment and Very Special Circumstances, CBRE, July 2018
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Green Belt countryside in preference to derelict and urban land, contrary to the strict policies of government and in the development plan.
5.57 The site is an isolated location within the Green Belt countryside. Restricting its development significantly contributes to this purpose.
Purpose Assessment Conclusions
5.58 The assessment above demonstrates that the site contributes significantly to a number of Green Belt purposes, and that a development which affects this contribution to the Green Belt must result in significant harm.
5.59 The applicant’s conclusion that “the site as a whole makes a weak contribution overall to the Green Belt purposes”40 defies logic when one considers the site’s openness today, and its location in the centre of an open area of countryside between several settlements to the north of Woking.
5.60 The applicant claims41 that “the western portion of the site has a greater ability to absorb development given its reduced Green Belt function and quality. Conversely, the eastern portion of the site has a lower ability to absorb development given its greater Green Belt function and quality.”
5.61 In response, we would note that it is not possible for a Green Belt site to “absorb” development. While some development in accordance with the development plan may be appropriate within the defined Major Developed Site, the airfield itself, and the land to its east and south, are open and contribute significantly to the fundamental aim and purposes of the Green Belt. Development here would harm the Green Belt significantly; it cannot be absorbed.
5.62 We simply cannot understand how the effect of building 1,000 homes plus a range of related infrastructure on this open site in the Green Belt will be reduced by a Strategic Design Code, a “village like feel of generous landscaping and separation between development plots”, the “generous
40 Para 5.13 Green Belt Assessment and Very Special Circumstances, CBRE, July 2018 41 Para 5.16, Green Belt Assessment and Very Special Circumstances, CBRE, July 2018
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separation between (employment) buildings” and “pitched roofs to reduce the physical bearing of the buildings”42, as suggested by the applicant.
5.63 Landscaping is also suggested as a mitigation in relation to Green Belt impact, and the development of the site for housing with landscaping is argued to be a landscape and Green Belt benefit. This is simply not possible in planning policy terms and if accepted would permit many other unacceptable developments to be argued to be permitted in the countryside in the Green Belt.
Other Harm
5.64 The next stage in the very special circumstances assessment is to assess “any other harm resulting from the proposal”43. We undertake that assessment below.
5.65 The applicant summarises its assessment of other harm using the following chart, from its “Green Belt Assessment and Very Special Circumstances”. As the applicant notes44, the VSC Addendum they provided in September 2019 does not alter this assessment.
42 Para 5.31, Green Belt Assessment and Very Special Circumstances, CBRE, July 2018 43 Paragraph 144, NPPF 44 Para 1.7, Very Special Circumstances Addendum, Savills, September 2019
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5.66 We explain in the Benefits of the Proposal section below (paragraphs 5.161 to 5.230), that we take issue with the applicant’s assessment of benefits in relation to ecology and biodiversity/ Thames Basin Heaths SPA, and socio-economics.
5.67 In this section we explain how the effects of the proposal will be more harmful than the applicant suggests in relation to the following factors:
• Aviation
• Landscape and Visual
• Transport and Movement
• Flood Risk and Drainage
Loss of Aviation
5.68 We responded to this issue in detail in our November 2018 objection, and then in a response to a letter from Savills in August 2019. We set out a
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summary of our case in this regard below.
Summary of Harm
5.69 In the original Very Special Circumstances Assessment the applicant claimed that the impact of the development proposal on this issue is neutral45, and the Very Special Circumstances Addendum does not alter the applicant’s view in this regard.
5.70 It does not take any particularly detailed analysis to conclude that the closure of a fully functioning airfield will inevitably have a harmful effect on aviation per se. Flights will not be possible where they currently are. Even if other benefits outweighed this harm, which they do not, it is illogical on the face of it for the applicant to claim that the impact of the closure of an airport on aviation is neutral.
General Aviation Network
5.71 We noted in our November 2018 objection that:
• Fairoaks Airport plays an important role as a key part of the general aviation network, and that this has been underestimated/discounted by York Aviation. York Aviation fails to consider the implications of runway closure on the currently rapid travel times for people, goods and emergency and medical services.
• Fairoaks Airport has a number of different functions and facilities, all of which are relevant to its strategic importance in aviation terms. These have been underestimated or discounted by York Aviation in its consideration of the implications of the runway’s closure.
5.72 York Aviation takes issue with ASA’s suggestion that a general aviation network will be created46. At one point, York Aviation suggests that:
“… the All-Party Parliamentary Group (APPG) on General Aviation … does not favour publishing a list of airfields covered by a strategic network, but
45 Para 5.73 & Fig 3, Green Belt Assessment and Very Special Circumstances, CBRE, July 2018 46 Paras 6.14, 8.6 etc., Aviation Report Addendum, York Aviation, August 2019
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recommends that when airfields are considered for closure, they should be assessed against the criteria set out in the GA Champions Report.”47
5.73 This is disingenuous. The recently updated NPPF now refers to a “… network of general aviation airfields …”48.
5.74 The GA Champion’s Report concludes that:
“Much debate has taken place about whether a comprehensive list of airfields in order of merit, should be drawn up in the Aviation Strategy… This could for example result in the top scoring 20% being identified as worthy of protection, which would perhaps amount to some 110 airfields as a result of employing York Aviation’s combined weighted score formula and the qualitative criteria.
While such a process would generate a protected list it would also of necessity create a mirrored list of less protected airfields. The effect of this could be to encourage the consideration of these locations as redevelopment sites which is not the aim of this exercise.”49
5.75 Similarly, the Government’s Aviation 2050 consultation document summarises the issue as follows:
“The GA Champion’s report concluded that the GA sector is losing airfields to property developers and that there is a risk to the long-term viability of UK airfields.”50
5.76 It then notes that:
“The Government believes that there are potential advantages and disadvantages to identifying and protecting a GASN which identifies a subset of airfields…”51
5.77 The disadvantages include:
47 Para 6.15, Aviation Report Addendum, York Aviation, August 2019 48 Para 104 f, NPPF 49 Paras 89 & 90, General Aviation Strategic Network Recommendations, Byron Davies, GA Champion 50 Para 7.20, Aviation 2050: The future of UK Aviation – A Consultation, HM Government, December 2018 51 Para 7.24, Aviation 2050: The future of UK Aviation – A Consultation, HM Government, December 2018
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“aerodromes that are not in the network might be more exposed to development and the consequent negative impacts on the GA sector could outweigh the benefits that those that are part of the network benefit from”52
5.78 Therefore, the concern of both the GA Champion and indeed the Government about whether or not to define a network of GA airfields stems from a concern that doing so would protect the network less well than not doing so. This does not support the redevelopment of Fairoaks Airport.
5.79 ASA, in its advice to the LPAs, notes that:
“Although the precise methodology for the selection of airfields in the GASN is still be to finalised, we have endeavoured to assess the likelihood that Fairoaks would be included in this network based on the weighted score formula and the qualitative criteria proposed by York Aviation… Based on the methodology given in York Aviation’s report for DfT, we conclude that Fairoaks would meet all the necessary standards in terms of airfield facilities and services for most types of fixed wing and helicopter operations excluding those by complex business jets. The airfield also adds value to the network through its associated business park which provides financial stability to the airfield as a whole and provides facilities for a range of aviation and nonaviation related businesses… We recognise that there are other airfields within a 35 mile radius of Fairoaks which might be considered as alternatives – although many of these have operational or other restrictions. Fairoaks is also closer to London than most of these alternatives, giving it a larger population catchment area. In our view, based on the overall weighted score formula and the qualitative criteria proposed by York Aviation, Fairoaks would be included in the top 30 GA airfields in the UK and would undoubtedly included in the proposed network, which has indicatively been suggested might comprise around 110 airfields across the country.”53
5.80 York Aviation continues to assess Fairoaks Airport against the process it proposed as part of the GA Champion’s work54. In summary, this process
52 Para 7.25, Aviation 2050: The future of UK Aviation – A Consultation, HM Government, December 2018 53 Para 17, Executive Summary, Aviation-related implications of the proposed garden village scheme at Fairoaks Airport, ASA, August 2019 54 Paras 0.20 to 0.27 & section 6, Research into a Strategic Network of General Aviation Aerodromes, York Aviation, October 2018
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is as follows:
• To assess the airfield against two “gate criteria”55:
• Does it have a suitable runway in terms of length and surface?56 or
• Is it identified as a specialist site either by Pooley’s or a representative organisation?57
• If the answer to either is yes, move to 2.
• Airfield given unweighted score based on facilities available58:
• Whether or not relevant training is available at the airfield;
• Whether there is maintenance available on site;
• Whether there is fuel available on site;
• Whether customs are available or can be arranged;
• The type of ATC in operation, i.e. tower, information, radio or safetycom.
• Weighted score for each GA sub-sector59 calculated by:
• Multiplying unweighted score by population within 35 miles60 of airfield;
• Dividing product from above by number of airfields within 35
55 Para 0.21/6.41, Research into a Strategic Network of General Aviation Aerodromes, York Aviation, October 2018 56 Paras 6.20 to 6.22, Research into a Strategic Network of General Aviation Aerodromes, York Aviation, October 2018 57 Para 6.23, Research into a Strategic Network of General Aviation Aerodromes, York Aviation, October 2018 58 Paras 0.22 & 0.23/6.41 & 6.42, Research into a Strategic Network of General Aviation Aerodromes, York Aviation, October 2018 59 i.e. Business - Light, Business - Complex, Business - Helicopters, Leisure - Fixed Wing, Leisure - Gliding, Leisure - Microlights, Leisure - Hang-Gliding & Practising, Leisure - Parachuting, Leisure - Balloons, Leisure – Other, see Research into a Strategic Network of General Aviation Aerodromes, York Aviation, October 2018, e.g. table 6.1 60 Paras 6.18 & 6.19, Research into a Strategic Network of General Aviation Aerodromes, York Aviation, October 2018
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miles that pass the gate criteria.
• Total score for airfield = sum of weighted scores for each GA sub- sector x economic contribution of GA sub-sector to UK economy.
5.81 York Aviation notes that “… some element of judgement may also be required in determining the value of an individual airfield compared with an alternative use …”61, and sets out the following qualitative criteria to assess these factors:
• Viability
• Hangarage
• Specialised Engineering
• Emergency Services Use
• Heritage Value
• Community Engagement and Education
• Environment
• Surface Access
• Non-Aviation Activity
5.82 A database appears to have been produced62 but has not been publicly released as far as we are aware, so it is not clear what score York Aviation attributes to Fairoaks Airfield or any other airfield.
5.83 Fairoaks must score well, however, because of its proximity to London. Fairoaks’ 35 mile catchment includes the whole of London within the M25 (other than a very small area north east of Romford). Blackbushe’s 35 mile catchment only extends to Southwark, thereby excluding half of London, or about 4.5 million people who are within Fairoaks catchment.
61 Paras 0.26 & 6.52, Research into a Strategic Network of General Aviation Aerodromes, York Aviation, October 2018 62 E.g paras 6.1/6.4, Research into a Strategic Network of General Aviation Aerodromes, York Aviation, October 2018
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White Waltham’s 35 mile catchment extends to about Greenwich, thereby also excluding a large proportion of London’s population. The measure of catchment population is important when considering the strategic role an airport fulfils.
5.84 There is an element missing from York Aviation’s assessment of airports, which is surprising. York Aviation’s criteria do not include any assessment of the amenity impacts of flying on an airport’s neighbours, including residential areas overflown on approach and departure. The qualitative criterion “environment” refers more to environmental designations and Green Belt.
5.85 As we noted in our 12th August 2019 response to Savills’ 15th May 2019 letter, Fairoaks is much more suitable for use as an airport than all of the airfields that York Aviation suggests as alternatives, simply because of its relative isolation and lack of residential areas overflown on approach and departure.
5.86 The images overleaf63 show firstly that low level approaches to Fairoaks Airport do not overfly any existing major settlements; whereas at Blackbushe, westerly approaches, which are predominant for c70% of the time because of the prevailing wind direction, fly over the settlements of Cricket Hill and Frogmore. This results in a significantly greater impact on residential amenity and consequently a much more sizeable anti-flying lobby at Blackbushe which will make any increase in the number of flights more challenging to deliver.
63 Google Maps, at the same scale
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Fairoaks Airport and surrounds
Blackbushe Airport and surrounds
5.87 All other airfields suggested as “alternatives” by York Aviation in its July 2018 report64 are also materially worse in terms of impact on residential amenity and communities lying under flight approach and departure routes, as described below:
• Biggin Hill (with a NNE to SSW runway), over Orpington to its north north east, including a major hospital (Princess Royal University
64 Table 6.1, Aviation Report, York Aviation, July 2018 (noting that YA accepts that Dunsfold, Farnborough, Luton and Northolt are not realistic alternatives)
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Hospital);
• Denham, over Gerrards Cross to its west and Harefield to its east, including a major hospital (Harefield);
• Elstree, over Bushey to its west and Borehamwood to its east;
• Redhill, over White Bushes to its west;
• White Waltham, over Maidenhead to its east;
• Wycombe, over Cressex area of High Wycombe to its east.
5.88 The impact of overflying aircraft on residents and communities is a matter of great concern to the Government in its aviation policy and to the relevant local authorities. This impact is particularly intrusive at night.
5.89 This is a vitally important factor which is very much in Fairoaks’ favour. Ignoring it fundamentally skews York Aviation’s analysis.
5.90 It is clear that York Aviation’s advice in support of the FGVL application focusses on the first of the qualitative criteria it proposes to Government: viability.
5.91 In this regard, we note that ASA’s advice to the LPAs assesses the current financial position of Fairoaks Airport in section 5 and the future financial viability of the airport in section 6, and concludes that “… it is not true to say, as asserted in York Aviation’s report, that Fairoaks is financially unsustainable as a going concern.”65
5.92 While York Aviation in its Aviation Report Addendum challenge a number of specific points made in sections 5 and 6 of ASA’s report, it does not further challenge ASA’s fundamental conclusion in this regard. As a lack of financial viability would appear to be York Aviation’s main argument that Fairoaks airport is “failing” in its contribution to the overall GA network, this is significant. We agree with ASA’s analysis and conclusion on Fairoak Airport’s financial viability. There is little doubt that its
65 Exec Summary, 14, Aviation-related implications of the proposed garden village scheme at Fairoaks Airport, ASA, August 2019
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relatively run-down appearance is due to a lack of investment from its owners over many years, not a lack of potential economic return from investment in a high quality redeveloped site, a factor supported by its Local Plan policy designation and sought to be carried out by investors and developers in the event of planning permission being refused.
5.93 It is also worth noting the following statements by York Aviation in its advice to Government:
“… we clearly identified the need for any evaluation process to rely on objective data and to be transparent. Issues around the GA sector and the GA network and the pressure it is under are contentious. There are competing interests involved both internally within the GA community and externally with the wider market. It was therefore vital that any evaluation approach in relation to airfields or the network as a whole be as devoid as possible of subjective judgements. This is why the core of our approach is based on quantitative measures. We have also included below our thinking on a range of potential qualitative factors that would give a more rounded view of any given airfield but these are by their nature more open to subjective judgement.”66
“In looking to the future and any assessment of the potential value of individual airfields by 2030, we believe that a simpler approach is more appropriate. Our view is that consideration should only be given to the fundamental capability of the airfield (the results of the gate criteria analysis) rather than a consideration of the features of the airfield. The primary reason for this is that by 2030 features of airfields can and probably will change. Operators will react to the market and the needs of customers. Changes in the network in particular are likely to result in changes in features at other airfields as operators seek to invest and capture market share. It is not sensibly possible to predict how this will play out across the network and so it is more appropriate to focus on the key feature of airfields that will in the great majority of cases not change and ultimately defines who can use them, their runway capability.”67
5.94 We would suggest that York Aviation’s assessment of Fairoaks Airport results from the competing interests it itself refers to, and that its
66 Para 6.6, Research into a Strategic Network of General Aviation Aerodromes, York Aviation, October 2018 67 Para 6.51, Research into a Strategic Network of General Aviation Aerodromes, York Aviation, October 2018
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conclusions are not at all devoid of subjective judgements as a result. By ignoring the impact of flying on neighbours’ amenity, York Aviation ignores a major factor in the fundamental capability of each airport to continue to operate and expand. Fairoaks Airport happens to score well against this missing criterion, as it does against the catchment population criterion, a measure of its economic stability.
5.95 Further, York Aviation continues to downplay other harmful impacts, as we have described previously and as we summarise below.
Value of Business Flights
5.96 York Aviation considers the importance to the economy of Fairoaks Airport without considering the value of business flights because they say, in effect, that these are too difficult to value.
5.97 We suggested in our November 2018 objection that the value to business may be in the region of £20,000 to £100,000 per flight, giving a total value of business flights from Fairoaks as £36-£72 million68.
5.98 In our 12th August 2019 letter we noted that the applicant does “not dispute that there is a value to business aviation flights … and that some flights to and from Fairoaks are being made for business purposes (but) … the extent to which Fairoaks is used by flights operating for business purposes is difficult to determine and … no specific evidence … has been obtainable.”
5.99 Our response is that it may be difficult to estimate the value per flight to business, but that does not mean the value does not exist, and this value would be lost if the airport were to close. For the impact of the application to be properly considered, some estimate of this value must be made, and we have attempted to do so. It cannot simply be ignored because it is too difficult to estimate.
5.100 Ignoring these factors underestimates the airport’s benefits and therefore underestimates the cost of its closure. This fundamentally skews the very
68 Para 60, Appendix 1, Objection to Planning Application, Vision Planning, November 2018
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special circumstances test balance, so is unacceptable.
Medical Flights
5.101 The applicant continues to underestimate and ignore the impact that the closure of Fairoaks Airport would have on medical emergency flights.
5.102 The Updated Planning Statement downplays the importance of Synergy’s role in operating medical flights from Fairoaks because “… North West Surrey CCG has confirmed that the loss of this function from the site would not have a material impact on the area …” and it suggests that “Medical flights operating out of the site … could continue to be serviced by alternative aerodromes, such as Blackbushe.”69
5.103 The Aviation Report Addendum refers to a letter from Savills to SHBC dated 25th February 2019 which, it says, “concluded that any medical flights which utilise Fairoaks are carried out as a matter of economic convenience rather than an operational requirement. Although the potential closure of the Fairoaks runway would impact Synergy Aviation, it would have no impact on local hospitals and Ashford and St Peter's Hospitals NHS Foundation Trust has no requirements for emergency medical flights to operate at Fairoaks Airport.”
5.104 As we explained in our 12th August 2019 letter to SHBC, Synergy Aviation operates c200 medical flights per year to and from Fairoaks using fixed winged aircraft. We spoke to several contacts at Synergy Aviation, who stated that they wish strongly to remain at Fairoaks, and explained the following.
5.105 A small proportion (estimated at 3-5%) of these flights involve the transfer of patients. Of the remaining large majority, flights are split roughly evenly between the transfer of organs as part of an organ transplant, and the transfer of specialist medical teams required for a medical emergency.
5.106 The process for the transfer of organs is that the organ is removed from
69 Para 8.218, Updated Planning Statement, Savills, September 2019
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a deceased patient, transported by road to an airport, flown to another airport, transported by road to a hospital where a recipient patient is operated upon to receive the donated organ. It is worth noting that a single deceased person can provide up to five organs so, typically, five aircraft are required to transfer the range of organs to a range of recipient locations.
5.107 For a heart, this process, from the fatality occurring to the organ being transplanted into the recipient patient, must be undertaken within 3 hours; for lungs, 3½ to 4 hours; for kidneys, 7 hours.
5.108 A large proportion of medical emergency flights (estimated at 90%) operated by Synergy are from or to Newcastle, Belfast, Edinburgh or Glasgow. By fixed wing aircraft, the flight time from Edinburgh, for example, is 1 hour with direct routing at night, and 1hour 15 minutes to 1hour 30 minutes during the daytime. In comparison, flights by helicopter would take 3 to 4 hours, so the applicants proposed helipad would not provide a viable alternative given the time requirements set out above.
5.109 The nature of Synergy’s medical flights is therefore more strategic than implied by the applicant. Synergy’s medical flights are not intended to serve local airports; they provide a national and international medical emergency flight service connecting patients, transplant organs and medical teams.
5.110 Strategically, Fairoaks is ideally located to meet medical emergencies across the UK and Ireland, and into France and sometimes beyond. An airport elsewhere would not be able to meet the needs of the same catchment, and there are no viable alternative airports available in the south east of England.
5.111 Fairoaks is also better located than Blackbushe because it is more isolated, with fewer neighbours to disturb.
5.112 In any event, Savills 25th February 2019 letter to SHBC states that “… we understand the Blackbushe Airport Manager has indicated a reluctance to
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accept flights by Synergy during the night period …”.
5.113 Savills letter also suggests Farnborough, Biggin Hill, Luton and Oxford as alternatives. The landing fees at all these airports would be significantly higher than at Fairoaks, with knock on effects on health service costs, and the strategic coverage achieved from Fairoaks would not be achievable from these alternatives. Road access to Biggin Hill airport is also notoriously poor.
5.114 This is just one example of the importance of Fairoaks airport in terms of transporting valuable freight quickly and demonstrates that Fairoaks Airport is a nationally important strategic asset. It is certainly true to say that this value is difficult to quantify but, when the cost of not delivering this freight quickly would result in the death or continued suffering of a patient, it is not reasonable to suggest that this value should be ignored.
Helipad
5.115 Bizarrely, the Updated Planning Statement suggests that “The aerodrome is not set to close, rather the aviation activities will be concentrated on Rotary Wing aircraft with the provision of more usable hangarage than exists today. Should the runway close then FGVL are aware of only one tenant that will be adversely affected.”70
5.116 If these planning applications were to be approved, the airfield would close and be redeveloped with 1,000 homes, the hangars would be redeveloped and the air traffic control tower would be removed. There would be no airport.
5.117 The applicant suggests that the airport would continue because they propose to provide a helipad, now in phase 1.
5.118 However, as we have previously noted, the proposed location of the helipad means that helicopter flights may well be restricted, and perhaps not viable at all.
5.119 The helipad would be immediately to the east of housing and to the south
70 Executive Summary, Updated Planning Statement, Savills, September 2019
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of commercial uses, all of which would be disturbed by helicopters taking off and landing.
5.120 ASA’s aviation report commissioned by the LPA explains that “… even if (the helipad) were to be initially established, it is unlikely to be commercially viable in the medium to long term, particularly if better financial returns could be made by converting the hangarage into other commercial uses.”71 We agree.
5.121 The ASA report goes on to say “We believe that the FGVL heliport would not be suitable for both helicopter and drone activities as a larger site, such as a full sized airfield… Furthermore, in the case of drones, there are no particular advantages of the FGVL location. It is not, for example, adjacent to a major distribution centre…”72
5.122 In essence this summarises our point. The applicant claims that the loss of the airport would have a neutral effect on aviation. They propose a helipad. There is a helipad now, so this is no improvement. The proposed helipad may well not be viable but, even in the unlikely event that is was licensed, the new location amongst residential and commercial developments would not be as favourable as its current location within an operational airfield. The impact on rotary winged aircraft operations alone would be harmful. Harm to fixed winged aircraft aviation is inevitable.
5.123 York Aviation’s Aviation Report Addendum suggests that “The helipad is positions to allow helicopters to approach from the south east over the unoccupied flood plain and leave towards to (the) south west, again over the unoccupied flood plain. This route is likely to have the least possible impact on the surrounding area and the future residential development. Further work is being undertaken on potential flight paths.”73
5.124 It is noted that further work is being undertaken on potential flight paths
71 Para 4.20, Aviation-related implications of the proposed garden village scheme at Fairoaks Airport, ASA, August 2019 72 Para 4.22, Aviation-related implications of the proposed garden village scheme at Fairoaks Airport, ASA, August 2019 73 Para 7.8, Aviation Report Addendum, York Aviation, August 2019
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which suggests that these flight paths are not certain to be viable. In any event, these flight paths would affect the proposed SANG and potentially the Thames Basin Heaths SPA at Horsell Common. The ASA report notes the impact on a bridleway used by the local equestrian centre and walkers74.
5.125 The applicant has suggested that “Companies including Starspeed and Elite Helicopters have indicated that they wish to remain on the site given the inclusion of a helipad.”75 The ASA report for the LPA explains that Starspeed were not in favour of the FGVL proposals76 and that Elite Helicopters decision to stay or otherwise would depend on cost and possible movement limitations77. It is therefore by no means certain that these two existing operators would remain.
5.126 On that basis it is clear that the proposal to provide a helipad to replace the current aviation use of the airfield will not have a neutral effect on aviation; it will have a harmful effect.
Impact of Split Ownership
5.127 York Aviation continues to argue that the split ownership of Fairoaks Airport is a hindrance to its viability.
5.128 ASA has responded to this issue in detail, and we continue to believe that the split ownership of the site per se is not the problem, as evidenced by the fact that an alternative development in accordance with the development plan is possible.
Alternative Airports
5.129 Our November 2018 objection noted that York Aviation’s 2018 report states throughout that alternatives to the use of Fairoaks exist for both recreational and business flights. However, York Aviation admits that
74 Para 4.20, Aviation-related implications of the proposed garden village scheme at Fairoaks Airport, ASA, August 2019 75 Para 2.13, Very Special Circumstances Addendum, Savills, September 2019 76 Para 4.14, Aviation-related implications of the proposed garden village scheme at Fairoaks Airport, ASA, August 2019 77 Para 4.15, Aviation-related implications of the proposed garden village scheme at Fairoaks Airport, ASA, August 2019
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many of these alternative aerodromes are not suitable, and our analysis at appendix 1 of the November 2018 objection demonstrates that none of the alternatives are suitable as a result of significant constraints and journey times that can be substantially longer than York Aviation claims.
5.130 It is also noteworthy that, in its October 2018 advice to DfT, York Aviation explains that “… GA is not and should not be seen a homogenous. Different parts of the GA community require different things from different airfields and one airfield is not necessarily interchangeable with another.”78 This point has been ignored by York Aviation in its advice relating to the FGVL application.
5.131 A similar exercise to our November 2018 analysis was undertaken by ASA in its report for the LPA, and ASA came to a similar conclusion79. York Aviation does not dispute ASA’s conclusions80 and, by implication, does not dispute ours either.
Economic Impact
5.132 York Aviation’s has updated its assessment of net job and GVA losses resulting from the closure of the runway at Fairoaks Airport, although it concludes that this “… does not differ substantially from our previous report.”81
5.133 Our conclusion remains that York Aviation significantly over-estimates the number of jobs that would remain if the runway were to close, and therefore significantly underestimates the harm that this would cause.
5.134 Our conclusion, therefore, is that the applicant has significantly underestimated that harm that would result to aviation from the airport closing. The impact will not be neutral; it will be significantly harmful. It
78 Para 6.3, Research into a Strategic Network of General Aviation Aerodromes, York Aviation, October 2018 79 Paras 8.1 to 8.11, Aviation-related implications of the proposed garden village scheme at Fairoaks Airport, ASA, August 2019 80 Para 8.28, Aviation Report Addendum, York Aviation, August 2019 81 Para 4.8, Aviation Report Addendum, York Aviation, August 2019
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is illogical to suggest otherwise.
Landscape and Visual Impact
5.135 The applicant claims that the application results in landscape and visual benefits82. The Very Special Circumstances Addendum submitted by the applicant in September 2019 does not refer to this factor.
5.136 Landscape Visual has produced a Landscape and Visual Impact Assessment to support the application. This does not appear to have been updated.
5.137 Key references from the Updated Planning Statement include (with emphasis added):
• “The new Garden Village would sit within a discrete pocket of existing landscape. The settlement would be strongly contained… and landscape and visual effects arising from the proposed development would not be widespread… While the proposed development would reduce the open character in the south of the existing airfield, some of the existing sense of openness in the centre of the site would be retained, and there would be an overall increase in the sense of openness in the east of the site.”83
• “The proposed development responds to the sensitivities of The Bourne river corridor and there would be no significant harm to the character of the views along the river valley floor in the long-term.”84
• “The creation of the Fairoaks Parkland and Bourne Meadows SANGs … would result in significant beneficial effects arising on the landscape character in the east and south of the site.”85
• “There would be no significant adverse effects on views seen from
82 Figure 3 and para 5.99, Green Belt Assessment and Very Special Circumstances, CBRE, July 2018 83 Para 8.300, Updated Planning Statement, Savills, September 2019 84 Para 8.302, Updated Planning Statement, Savills, September 2019 85 Para 8.303, Updated Planning Statement, Savills, September 2019
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residential dwellings as a consequence of the proposed development in the long-term, and there would be long-term, beneficial effects on the main axial view seen from The Mansion, Ottershaw Park…”86
• “The LVIA identifies a reduction in the availability of distant views towards the series of wooded ridgelines to the south and west seen from the PROWs extending through the Site and along the Site’s western boundary, and of the landmark features of The Mansion, Ottershaw Park and Christ Church spire. However,… this would be compensated (in part) through the views that would be offered by the landscape corridor of the Rills, the Fairoaks Parkland SANG, and through new near and middle-distance views from the proposed footpath network in the east of the Site.”87
• “The LVIA identifies the nature of changes to long distance views along an approximate 0.9km length of Chobham Footpath 1 although explains that this would be counterbalanced, in part, by the set back of built form and the high-quality landscape to either side of this route.”88
• “For footpath users, the public access to and permeability of the area currently occupied by the site would be greatly enhanced with direct access to a range of open landscapes.”89
5.138 Our assessment by Pleydell Smithyman, at Appendix 2 of our November 2018 objection, has not altered. It critiques the applicant’s landscape and visual impact assessment. It strongly contradicts the applicant’s conclusion that the proposed development would result in landscape and visual benefits, and notes that further technical and assessment work is required to enable decision makers to weigh the true impacts in the planning balance.
5.139 The Pleydell Smithyman assessment notes a number of flaws in the
86 Para 8.304, Updated Planning Statement, Savills, September 2019 87 Para 8.305, Updated Planning Statement, Savills, September 2019 88 Para 8.306, Updated Planning Statement, Savills, September 2019 89 Para 8.307, Updated Planning Statement, Savills, September 2019
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applicant’s methodology and conclusions, summarised as follows:
• Methodology and Assessment Approach
• “The Landscape and Visual Impact assessment (LVIA) that was submitted with the Environmental Statement (ES) is based on a flawed methodology that does not fully comply with best practice guidance. The assessment is incomplete and frequently opaque and consequently the conclusions reached cannot be considered robust.
• No areas of new strategic planting within the open space are illustrated on the Parameter Plans or the LVIA photomontages. Despite this absence of detail, the LVIA reaches conclusions that there would be a significant improvement in visual amenity to a number of landscape and visual receptors as a result of the growth of proposed planting over a 15 year+ period.
• The permanent loss of the open character of any views has particular importance given the Green Belt context of the Site. Frequent reference in the LVIA to ‘high quality’ buildings and ‘high quality’ landscaping implies assessment of a level of detail that is not part of the outline application.”
• Landscape Receptors
• “Best practice guidance states that the published Landscape Character Assessments should be critically reviewed, and historic landscape characterisation considered. There is no evidence that the LVIA has addressed either of these requirements. Consequently, it is unclear how the authors of the LVIA have reached robust conclusions on baseline landscape value. The Design Review Panel heavily criticised the proposals for overlooking historic landscape aspects of the site and for not considering the scheme in its wider landscape context.
• The CPRE tranquillity mapping has been incorrectly analysed. The Site exhibits some of the highest tranquillity in the local area being situated within a larger area of lower relative tranquillity surrounded by urban development of very low tranquillity.
• The division of the Site into ‘site character areas’ is not adequately explained and does not appear to take into account best practice
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guidance or the historic landscape character areas. There is also a requirement to assess individual landscape components, which has not been undertaken e.g. there is no assessment of the loss of existing trees which comprise a number of ‘A’ grade specimens.
• The LVIA recognises that the proposal would have an adverse impact on landscape character by increasing built development, reducing agricultural land and being of a form that would not follow the characteristic settlement pattern in the locality. The positive effects of new planting associated with the development are exaggerated to the extent that they cancel out and, in some cases, exceed the aforementioned adverse effects.
• The majority of the Site is covered by the Chobham East Settled and Wooded Farmland Landscape Character Area (LCA). Best practice guidance advises that where there are no landscape designations, judgements of landscape value should be based on specific criteria. There are a number of serious omissions in the assessment of landscape value of the host LCA including no analysis of scenic quality, rarity, representativeness, conservation interests or associations. Consequently, as value combines with susceptibility to determine landscape sensitivity, the assessment conclusions in the LVIA cannot be considered robust.
• There is no critical analysis of the published key landscape characteristics for each LCA or any structured or objective analysis of what effect, if any, the proposed development would have upon the baseline key characteristics.
• Judgements on value, susceptibility, sensitivity and magnitude frequently fall between the defined assessment categories results in an opaque, over-complicated and difficult to follow assessment
• There are inexplicable assessment conclusions. One example is the assessed effects upon the Wentworth to Sheerwater Settled and Wooded Sandy Farmland (SS4), which comprises a small part of the overall Site in the vicinity of Wey Farm. This area would accommodate the initial section of the proposed access road and the overall assessment is that there would be a Major/Moderate and Adverse direct effect upon landscape character that is Significant upon completion. By
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contrast, the direct impact upon the Chobham East Settled and Woody Sandy Farmland (SS8) where almost all of the new built development is located is only assessed as Major/Moderate and Neutral.”
• Visual Receptors
• “The Design and Access statement highlights the importance of long- range views stating that ‘Views from and across Fairoaks are marked as strategic views in the Local Plan’.
• The Zones of Theoretical Visibility (ZTV) have been constructed with a small number of target points which potentially under-represents visibility of built development. The omission of existing built up areas as visual barriers within the ZTV is also confusing as significant areas of Chobham still fall within the screened ZTV, although no illustrative viewpoints have been included to demonstrate actual visibility.
• The June 2018 scoping report states that viewpoints had not been agreed with the Council with the benefit of ZTVs. Given that the authors of the LVIA had been involved in the project since at least 2015 this is somewhat surprising.
• Following review in the field, the selection of viewpoints and the decision on which views should be presented as photomontages has resulted in some questionable decisions. There are no photoviewpoints for a circa 500m long section of the northern boundary of the Site adjacent to the Chertsey Road. A number of viewpoints are not taken in the best location to illustrate the maximum effect of the proposed development. Consequently, the photomontages submitted cannot provide a full representation of how the proposed development would appear.
• Many of the illustrative views were also taken more than 3 years ago in areas where the landscape may have subsequently changed. In addition, a number of the views were only taken when leaves were on the trees, noting that less restricted views would be available in winter.
• The technique adopted for preparation and presentation of photoviews is out of date with latest best practice. Pleydell Smithyman and many other practices have been producing visualisations in accordance with the 2017 SNH guidance on LVIA for all major development projects
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where there are likely to be significant landscape and visual effects.
• There are a number of technical discrepancies with the visualisations that need clarification and/or correction before the photography and photomontages can be relied upon to give an accurate and consistent representation of the views and visual effects.
• The reduction in openness and adverse impact from the introduction of substantial new built development from the public footpath through the site, rights of way adjacent to the site boundary and surrounding roads has been incorrectly assessed as resulting in a beneficial long-term effect upon visual amenity. Evidence to the contrary is clearly seen in the photomontages, notwithstanding the aforementioned technical presentation concerns.
• The public footpath that passes through the centre of the Site is a key component of a number of promoted local walks where views of the airfield and understanding of war history are important. This has not been recognised and the sensitivity of the route is assessed as being no greater than any other public right of way in the area.
• Circular walks that include the footpath through the site are promoted by a number of organisations, with the history of the airfield recognised and close links to nearby Horsell Common which forms part of the route. The author H. G. Wells, who lived in nearby Maybury, used the sandpit on Horsell Common as the landing site for alien space craft in his novel ‘War of the Worlds’. Today the site of pilgrimage for many science fiction fans that travel from all over the world. The circular walk that passes through the Fairoaks site is titled: ‘Planes, Racing Cars and Spaceships’.
• The residential assessment was carried out without any access to private dwellings. Given the potential for Significant effects it is advised that the Local Planning Authorities will be unable to determine the impact upon residential amenity without a detailed assessment from selected properties.
• As part of the residential assessment it is recommended that a photomontage from each property is prepared including a view from an upper floor apartment balcony in Ottershaw Mansion. In the event that access is not granted, cross sections could be prepared to demonstrate
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typical viewlines. Alternatively, a desktop ‘line of sight’ mapping technique incorporating Lidar data to reflect existing tree planting could be used.”
• Cumulative Assessment
• “It is not clear if the list of schemes to be assessed was agreed with the determining authorities in line with best practice guidance. There is very limited supporting material to support the cumulative assessment conclusions. Best practice guidance recommends the inclusion of paired ZTV’s and cumulative visualisations. This material will indicate the change in the views and visual amenity compared with the appearance of the project being assessed on its own.”
Transport and Movement
5.140 The applicant claims that the proposed development will “give rise to benefits”90 overall.
5.141 Our assessment, at appendix 3 of our November 2018 objection, concludes that the application’s benefits “have not been demonstrated, are overstated, or flawed.” This has not changed.
5.142 Transport related amendments at this stage are to propose to deliver a longer length of the link road and the entire length of footway/cycleway along the link road in phase 1, and to alter some highway junctions around the site.
5.143 The applicant now claims that the “… sustainable transport corridor/ link road should be a VSC on the basis of the wider benefits arising from enhancements to physical infrastructure. The provision of this important further permeability to the transport network in the are could not otherwise be made without the development of FGV. Hence, it is a VSC as it makes a valuable contribution to enhancing the opportunity for access and movement by all travel modes in a constrained part of the transport network, which could not otherwise be brought forward.”91
90 Para 5.97, Green Belt Assessment and Very Special Circumstances, CBRE, July 2018 91 Para 2.24, Very Special Circumstances Addendum, Savills, September 2019
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5.144 The applicant does not explain how these claimed benefits affect the planning balance as required by NPPF paragraph 144. The applicant already claims a significant transport benefit in the Green Belt Assessment and Very Special Circumstances report92, and we explained in our November 2018 objection that this was significantly estimated and that the transport impact would in fact be harmful.
5.145 If connecting the A319 to the A320 was considered to be of such a strategic benefit it could be delivered in other ways and in other locations in any event, so we do not consider this to be a very special circumstance.
As the applicant notes “… since the original planning application submission, RBC submitted a Housing Infrastructure Fund (HIF) bid in March 2019.”93
5.146 The HIF Bid includes significant improvements to a number of junctions in the vicinity of Fairoaks94 which will improve highway capacity without the need to develop 1,000 homes at Fairoaks, causing further highway capacity issues.
5.147 It is clear that the highways works proposed including the construction of a link road are extensive and would overall have a harmful effect on the Green Belt.
5.148 Further, as noted in our detailed Review of Road Transport Matters at Appendix 1, the application does not meet the following key transport aspects of national local planning policy:
• The proposal fails to provide adequate or safe off-site highway infrastructure to reasonably enable development residents, occupiers and visitors to walk and cycle, particularly along the A320 corridor.
• The design of the proposed site highway accesses and offsite junction works proposal fails to provide safe highway infrastructure for the development residents, occupiers and visitors, as well as the road using public at large. Despite Fairoaks 2020 raising safety issues
92 Figure 3, Green Belt Assessment and Very Special Circumstances, CBRE, July 2018 93 Para 8.432, Updated Planning Statement, Savills, September 2019 94 See: 1.1.3, https://www.runnymede.gov.uk/media/20259/RBCLP-44-A320-North-HIF-Bid-April- 2019-/pdf/RBCLP_44_A320_North_HIF_Bid.pdf?m=636906717587770000
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during the course of this application, road safety problems with the design of the proposed site highway accesses and offsite junction and the county council conducting road safety audits, many of the site access and offsite junction works designs still have significant unresolved highway safety problems.
• It has not demonstrated that the significant traffic generation of the development can be effectively limited. Notwithstanding the significant discrepancies, errors and omissions still present in the applicant’s road transport assessment work, it is clear that the traffic impact in Chobham village is unlikely to be able to be acceptably limited by the proposed junction schemes, banned turns and diversion routes. A severe cumulative impact is likely. Further, the applicant has only now released mitigation proposals for M25 junction 11 and M3 junction 3, which F2020 understand have not yet been processed or agreed by Highways England.
5.149 The harm caused against the sustainable development transport objectives of both national and local planning policy remains as F2020 originally reported in December 2018 - that:
• sustainable transport is not adequately promoted, facilitated or delivered,
• highway safety is not sufficiently ensured or delivered, and
• the significant road transport impacts created have not been (demonstrated to be) effectively limited and significant cumulative impacts maybe created.
5.150 The remainder of our assessment has not altered from our November 2018 objection, and is as follows.
5.151 The applicant claims95 that the development “is intended to create a largely self-sufficient village which serves most day-to-day needs, and therefore
95 Para 8.415, Updated Planning Statement, Savills, September 2019
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reduces the need to travel outside of the site” and refers to the introduction of “Mobility as a Service”, with reference to internet based bus connectivity etc.96
5.152 In response, we would argue that the proposed development is by no means self-sufficient and, in any event, self-sufficiency, enhanced public transport and walking and cycling measures are a means of mitigating the adverse effects of the development; they are not benefits.
5.153 Out-commuting from the site and in-commuting to the proposed employment development on the site would occur with very few of the journeys being intra-site or internal journeys by residents commuting to work. There is no sound evidential basis in the application as to how internal journeys to the employment area would be controlled or even likely, let alone significantly reduce out-commuting.
5.154 The applicant concludes97 that, “overall, the anticipated impacts of the proposed development can be appropriately mitigated by the highways works referenced above. Importantly, the proposed development does not result in ‘severe’ residual transport impacts and so meets the test set for these effects by the (2012) NPPF paragraph 32. Further details contained within the accompanying Transport Assessment by PBA.” Our analysis at appendix 3 of our November 2018 objection demonstrates that the applicant has failed to demonstrate this.
Flood Risk and Drainage
5.155 The applicant claims that “… the wider benefits for drainage betterment and hydrological management remain as described in (the original Green Belt Assessment)”98. This original Green Belt Assessment claimed that the application results in a significant benefit in this regard.
5.156 The Updated Planning Statement claims that “A Sequential Test for the proposed development has been passed and is to be submitted
96 Para 8.421, Updated Planning Statement, Savills, September 2019 97 Para 8.441, Updated Planning Statement, Savills, September 2019 98 Para 2.20, Very Special Circumstances Addendum, Savills, September 2019
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separately as part of this planning application.”99 The sequential test does not form part of the Environmental Statement, either in Volume 1 Chapter 9, dealing with Water Resources and Flood Risk, or in Technical Appendix 9.1, the Addendum to the FRA.
5.157 The Updated Planning Statement also concedes that part of the site lies within Flood Zone 3100.
5.158 Paragraph 157 of the NPPF explains that:
“All plans should apply a sequential, risk-based approach to the location of development – taking into account the current and future impacts of climate change – so as to avoid, where possible, flood risk to people and property. They should do this, and manage any residual risk, by: a) applying the sequential test and then, if necessary, the exception test…”
5.159 The fundamental point that appears not to have been addressed is that these homes need not be developed in this location. This site lies within the Green Belt and also relies upon development within Flood Zone 3. We have seen no justification for this.
5.160 The focus of the EA’s assessment to date has instead been on the betterment created by the drainage proposals included in the development.
Benefits of the Proposal
5.161 The applicant claims that the proposal results in five benefits:
• “Utilisation of Previously Developed Land within the Green Belt
• Continued and Enhanced Economic Role
• Creating a Mixed Residential Community with No Affordability Gaps
• Provision of Strategic Open Space Providing Wider Local Benefits
• Significant Surface Water Drainage Betterment and Hydrological
99 Para 8.495, Updated Planning Statement, Savills, September 2019 100 Para 8.494, Updated Planning Statement, Savills, September 2019
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Management”
5.162 In each case, the benefits are not as great as the applicant claims, or the benefits claimed are largely mitigation for the effects of the development itself, or the benefits can be delivered in an alternative, less harmful way.
Utilisation of Previously Developed Land within the Green Belt
5.163 The applicant continues to claim101 that 49 hectares, or 32% of the site, is previously developed land (PDL). This claim consists of:
• “6.1 hectares of permanent structures and their immediate curtilage;
• 5 hectares of runway and taxiways;
• 14.4 hectares of intensively managed grassland buffer to the runway and taxiways in place as run-off for aircraft and a grassed area for the parking of aircraft; and
• 23.6 hectares of managed, mown grassland within the operational airfield between the runway, taxiways and aircraft apron, which supports the operational activities, provides unrestricted access for aviation related vehicles and unregistered sightlines for air traffic control and ground crew.”
5.164 In continuing to claim that a large proportion of the site is previously developed, the applicant now claims that case law corroborates their case, referring102 to a March 2018 appeal decision at Dunsfold
Aerodrome103, which considered “the grassed areas in between the runways”,
later referred to as “interstitial grassland”, to be PDL
5.165 This interpretation relied on a September 2009 appeal decision104, which was dismissed. The 2018 decision related to a called in application which the LPA was minded to approve as Dunsfold Aerodrome had, by that time,
101 Para 8.15, Updated Planning Statement, Savills, September 2019 102 Para 8.17, Updated Planning Statement, Savills, September 2019 103 Appeal ref APP/R3650/V/17/3171287 104 Appeal ref APP/R3650/A/08/2089143
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been allocated in the adopted Waverley Local Plan.
5.166 As we noted in our November 2018 objection, the Wisley Airfield recovered appeal Inspector did not consider the grassed area around the runway to be PDL, noting105 that “some 29.9ha (about 26%) of the site is hard surfaced and so comprises PDL with the remainder comprising a mix of agricultural uses, woodland and scrub grassland.”
5.167 The Wisley Airfield and Dunsfold Aerodrome decisions were made three months apart, in March and June 2018, so both relied upon the 2012 NPPF definition of PDL (which is worded slightly differently but is materially identical to the current NPPF definition).
5.168 It is worth noting the runway arrangements at Dunsfold and Wisley, compared with Fairoaks, and noting the precise wording of the Dunsfold Inspector’s decision.
5.169 The location plan for the Wisley application shows that Wisley has a single east-west runway, as does Fairoaks Airport.
105 Para 20.4, Inspector’s Report, Appeal Ref: APP/Y3615/W/3159894
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5.170 On the other hand, the existing land use plan for the Dunsfold Aerodrome applications shows three runway forming a triangle.
5.171 The Dunsfold Inspector considered the interstitial grassland/ grassed areas between the runways to be previously developed.
5.172 At an airport with a single runway, as at Fairoaks and Wisley, there can be no interstitial land between the runways, there is only grassland around the runway, and in this situation, the Wisley Inspector determined that such grassland is not previously developed land.
5.173 Therefore, it continues to be the case, as we argued in our November 2018 objection, that the 14.4 hectares of managed grassland buffer and 23.6 hectares of managed, grown grassland is not previously developed land, and that only 11.1 hectares of the current Fairoaks Airport is previously developed land.
5.174 It therefore also continues to be the case that only the hard surfaces can be described as PDL, and that this represents a maximum 7%106 of the
106 Site area = 155.5 hectares according to application form; PDL = 11.1 ha (max)
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site. Therefore, the claimed benefit that 32% of the site area utilises PDL in the Green Belt is a significant overemphasis.
5.175 In any event, this is of no weight if the land is used, as here, for an existing beneficial use as an airport in accordance with Development Plan policy.
5.176 Further, even with the applicant’s incorrect re-interpretation of the definition of previously developed land, this means that the large majority of the site is greenfield. In that regard, it is to be noted that the applicant is not claiming that the proposed development is not inappropriate in the Green Belt based on the exceptions in NPPF paragraphs 145 and 146.
5.177 Harm is caused to the openness of the Green Belt regardless of whether any or all of the airfield is considered to be previously developed or greenfield. The Wisley Airfield Inspector noted that “the appellant’s attempts to downplay the harm to the Green Belt are not convincing. While the previously developed status of the land may be relevant in the overall balance it does not lessen the impact on the third Green Belt purpose.”107
5.178 Therefore, the proportion of PDL is irrelevant to the harm to the Green Belt. It is certainly not a very special circumstance (“VSC”) in green belt policy terms. The proposed development causes harm to the Green Belt (purposes 3 and 5 in particular), it is inappropriate in the Green Belt, and it can only be approved where very special circumstances clearly outweigh the harm, to the Green Belt and otherwise. As the use of PDL here is not VSC, there is no weighing to be carried out on the basis of use of PDL.
Continued and Enhanced Economic Role
5.179 The applicant’s case is set out in paragraphs 8.42 to 8.66 of the Updated Planning Statement, with reference to the Social and Economic Benefits Report by Quod.
107 Para 8.8, Inspector’s Report, Appeal Ref: APP/Y3615/W/3159894
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5.180 The applicant notes that the site currently accommodates 61 businesses and 295 jobs in 11,966 sqm GEA of general industrial and aviation related uses, and 4,609 sqm GEA of business and R&D uses. It also notes a vacancy rate of 0.9% and refers to evidence of businesses relocating elsewhere to expand108.
5.181 The proposed development includes 51,766sqm of Class B floorspace, including offices, R&D, light and general industrial uses and a small amount of warehousing, along with 13,000sqm GEA of other non- residential uses (retail, leisure, hotel and community uses)109.
5.182 The applicant’s claimed benefits of the proposal include110:
• Balance of uses – 1200 net new jobs v 1000 homes
• 1,500 additional jobs (1,200 net additional) (reduced from 1,250 net in original application)
• Displacement of existing jobs to approximately 50, i.e. 80% “reintegration”
• Incorporate helipad
• Relocation of Harvey Water Softeners
• Provision of business incubator space and an innovation centre
• Facilitate relocation of Prime Acrobatics (change since original application)
• Off site job creation at a rate of 0.19-0.95 for every on site job (was 1.19-1.95 in original application)
• Additional 700 jobs (net) through indirect and induced effects
• GVA at £78m pa, with £65m uplift (was £80m and £67m in original application)
108 Para 8.55, Updated Planning Statement, Savills, September 2018, para 8.55 109 Para 8.56, Updated Planning Statement, Savills, September 2018, para 8.56 110 Para 8.56, Updated Planning Statement, Savills, September 2018, para 8.56
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• Improved business rates, wages, tax revenue etc
5.183 In summary, therefore, since the original application, the application now provides for Prime Acrobatics, but results in lower net job numbers (1,200 from 1,250), a lower GVA (£78m from £80m) and a lower uplift in GVA (£65m from £67m). In simple terms then, the application has got worse.
5.184 The applicant’s claim that this proposal is supported by the NPPF and Core Strategy policies CP8 (which requires 7,500 new jobs in SHBC by 2027) and DM13 (which supports retention and expansion of Class B employment outside town centres and Core Employment Areas), as well as by the proposal in SHBC’s Draft Local Plan Issues and Options/Preferred Options to allocate the employment land at Fairoaks as a “Locally Important Employment Site”, is flawed because these benefits could all be delivered without the need to redevelop the whole of the airport or by development or redevelopment in accordance with Development Plan policy rather than contrary to it.
5.185 Current and emerging development plan policy for Surrey Heath Borough protects the existing employment area at the airport, and accepts its growth and expansion subject to restrictions intended to minimise harm to the Green Belt and to adjoining areas, including the airport itself.
5.186 There is no need for the airport to be closed and redeveloped for 1,000 dwellings in order to achieve these benefits. The current Major Developed Site/ proposed Locally Important Employment Site can be redeveloped while the airport remains in such use, in association with it.
5.187 On that basis, the provision of additional employment at Fairoaks Airport in association with 1,000 additional homes, with all the harm that brings to the Green Belt and to other factors, does not and cannot represent a Very Special Circumstance.
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Creating a Mixed Residential Community with no Affordability Gaps
5.188 The applicant notes that “SHBC cannot currently demonstrate a 5 year land supply as required by the NPPF”111, referring to SHBC’s most recent housing land supply paper, dated 2017, which indicated that the borough has 3.9 years of deliverable supply.
5.189 However, the applicant also accepts that “The Government’s standardised methodology for calculating local housing need results in an annual target which is slightly lower (under 8% a year) than the currently identified housing need for SHBC.”112 The requirement, in fact, is 352 dwellings per year.
5.190 It is clear, therefore, that Surrey Heath Borough’s housing land supply is not significantly below 5 years but, even if it were, this is of no material consequence as the land is in the Green Belt and the absence of land supply is not VSC. In this regard the Wisley Airfield appeal decision should be considered.
5.191 The NPPF does not permit land in the Green Belt to be released for inappropriate development in the absence of VSC. The government’s commitment to the Green Belt has been stated in the Housing White Paper 2017113 and, subsequently, both the 2018 and 2019 NPPFs emphasised that authorities should amend Green Belt boundaries only when they could demonstrate that they had examined fully all other reasonable options for meeting their identified development requirements, and then only through a statutory Local Plan review114. The commitment to strong protection of the Green Belt was recently restated by the Secretary of State115.
5.192 The Inspector in the Wisley decision concluded that the housing land supply in Guildford Borough was 2.36 years and that this “represents a
111 Para 8.98, Updated Planning Statement, Savills, September 2019 112 Para 8.92, Updated Planning Statement, Savills, September 2019 113 MHCLG, Fixing our broken housing market, Cm 9352, February 2017 114 Para 137, NPPF 115 Rt Hon Sajid Javid MP statement 5th March 2018
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significant shortfall against the annual requirement set out in the SHMA and the proposals carry significant weight in favour of the scheme.”116 Nevertheless, he concluded that helping to reduce this much more substantial shortfall did not override the harm to the Green Belt and other harm sufficiently to allow the appeal.
5.193 The housing land supply shortfall in Surrey Heath Borough is significantly less than it was in Guildford, so it has less weight in the planning balance in any event and will be made up during the Local Plan process. It is not a very special circumstance.
5.194 The applicant also refers to the mix of housing provided being a benefit. However, this only becomes relevant where housing is appropriate on the site in principle. This is not the case.
5.195 It is also noteworthy that the applicant appears to have reduced the amount of affordable housing to be provided since the original application.
5.196 The original DAS claimed that “50% of the homes will be affordable or intermediate tenure to meet local need and demand”117. Other references tended to refer to “50% of the homes will be affordable or provide a route into home ownership to meet local need and demand”118.
5.197 Now, the applicant leaves little doubt that only 45% of homes on site will meet the NPPF definition of affordable housing119.
5.198 The provision of affordable homes is not a very special circumstance in any event, but it is clear that any benefit that might have resulted from the provision of affordable housing has reduced since the application was first submitted.
116 Para 20.39, Inspector’s Report, Appeal Ref: APP/Y3615/W/3159894 117 Page 1, Design & Access Statement, JTP, July 2018 118 E.g para 2,2, Planning Statement, CBRE, July 2018 or para 6.92, Green Belt Assessment and Very Special Circumstances, CBRE, July 2018 119 Para 6.31, Updated Planning Statement, Savills, September 2019
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Provision of Strategic Open Space Providing Wider Local Benefits
Suitable Alternative Natural Greenspace
5.199 The application proposes 89.49 hectares of open space120, including 51.97 hectares of SANG, and claims that this represents a benefit. Notably, both of these areas have reduced since the application was first submitted. Therefore, any benefit has also reduced.
5.200 It is noted that the application now clearly does not seek detailed consent for the SANG121. There was some ambiguity in the original application122.
5.201 The applicant notes123 that Policy CP14A of the SHBC Core Strategy and Development Management Policies “states the Council will only permit development where it is satisfied that this will not give rise to likely significant adverse effect upon the integrity of the TBH (Thames Basin Heaths) SPA and/or the Thursley, Ash, Pirbright and Chobham Common SACs.”
5.202 The applicant then notes124 that “Policy CP14A states that all new residential (net) development within 5km of the TBH SPA is considered to give rise to the possibility of likely significant adverse effect…”
5.203 The applicant accepts that the site lies within this 5km zone of influence125. This means that, by definition, the proposal has a likely significant adverse effect.
5.204 The applicant then notes that “the supporting text to Policy CP14A explains that to date both SHBC and the development industry has experienced difficulty in identifying sufficient SANGs to enable development. As a result, from October 2005 to September 2008 no planning permissions for net new residential
120 Page 75, Design & Access Statement, JTP, July 2019 121 Para 1.22, Updated Planning Statement, Savills, September 2019 122 Para 0.15, Planning Statement, CBRE, July 2018 123 Para 8.22, Updated Planning Statement, Savills, September 2019 124 Para 8.23, Updated Planning Statement, Savills, September 2019 125 Para 8.31, Updated Planning Statement, Savills, September 2019
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development were granted.”126
5.205 The applicant is therefore arguing that a housing shortfall can override a likely significant adverse effect on the SPA. However, in the same way that the tilted balance does not apply in the Green Belt, it also does not apply where a likely significant effect on an SPA exists127. The extent of the housing shortfall is therefore irrelevant in this regard.
5.206 The applicant then makes the case that the application over-provides SANG, and claims this as a benefit.
5.207 The applicant explains that the Core Policy requires the delivery of at least 8 hectares per 1,000 occupants128 but that Natural England, in this instance, has requested a rate of 10 hectares per 1,000 occupants129. This, the applicant claims, results in a requirement for 24 hectares of SANG to mitigate the effects of the development, with a further 27.97 hectares (reduced from the original application) being provided to unlock the delivery of additional homes130.
5.208 The Ecological Objection at Appendix 3 to our November 2018 objection notes that the application claims that it is difficult to forecast whether residents and users of the proposed development will walk from the site to the SPA, but concludes that most people would use the proposed SANG rather than the SPA.
5.209 The proposed development is 470 metres at its closest point from the SPA, so our Ecological Objection concludes that providing SANG in this instance is not a reliable means of avoiding likely significant effects on a European site and an Appropriate Assessment must be undertaken prior to determining the application.
5.210 Furthermore, the provision of 24 hectares of SANG is compensation, and not even mitigation, for the likely significant adverse effects of the
126 Para 8.24, Updated Planning Statement, Savills, September 2019 127 NPPF (n6): “The policies referred to are those in this Framework (rather than those in development plans) relating to: habitats sites…” 128 Para 8.31, Updated Planning Statement, Savills, September 2019 129 Para 8.32, Updated Planning Statement, Savills, September 2019 130 Para 8.33, Updated Planning Statement, Savills, September 2019
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proposal on the Thames Basin Heaths SPA. The provision of an additional 28 hectares of SANG has effects that have not been quantified, and no Appropriate Assessment has yet been undertaken in conflict with the ECJ Judgement in People over Wind & Sweetman. The Updated Planning Assessment in fact notes131 that Natural England has requested an Appropriate Assessment.
5.211 Compensatory measures should be considered as what is in effect a last resort in this regard. First, it is incumbent on the statutory authority (here the Local Planning Authority) to seek to avoid harm or potential harm to the SPA. Only if harm is unavoidable should mitigation measures be employed so as to minimise the harm or potential harm caused and only if there is a clear case for such harm to occur which is unable to be avoided and sufficiently mitigated should compensatory measures be considered. Only if such compensatory measures override the harm should planning permission be considered to be granted. There is no case demonstrated for compensatory measures in this case.
5.212 The applicant refers to a lack of SANG capacity in SHBC132, with reference to an Executive Committee Report dated 16th July 2019133 which notes a lack of capacity now in the west of the Borough and a lack of capacity in the east of the Borough by 2028.
5.213 It is noted that Fairoaks lies in the east of Surrey Heath Borough, where there is no current SANG capacity issue. The emerging Surrey Heath Local Plan can be expected to identify additional SANG opportunities in the east of the Borough well before 2028, so there is no overriding need to permit the application in order to deliver this SANG now.
5.214 The Updated Planning Statement notes134 that the SANG at “Fairoaks is now listed as a potential strategic SANG site in the (Runnymede) Local Plan evidence base.”
131 Para 1.42, Updated Planning Statement, Savills, September 2019 132 Para 3.27, Updated Planning Statement, Savills, September 2019 and Section 3.4, SANG Strategy, LDA Design, August 2019 133 Para 3.28, Updated Planning Statement, Savills, September 2019 134 Para 1.41, Updated Planning Statement, Savills, September 2019
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5.215 It is worth clarifying that the SANG at Fairoaks is not included in the submission draft Runnymede Local Plan, nor is it included in any proposed modifications since.
5.216 Runnymede BC’s position in regard to the provision of SANGs more widely, is set out in its “Responses to the Inspector’s Matters and Questions for the Stage 2 hearings (matter 10)”, in response to question 10.4.
5.217 In summary, Runnymede BC’s response is that:
• Housing sites will be required to make financial contributions towards the delivery of SANG;
• Identified SANG will run out in 2024/25;
• The provision of SANG to mitigate the impact of 624 dwellings is as yet undefined;
• Sufficient potential sites are available to provide this SANG, and sufficient time is available to define the additional SANG needed.
5.218 Appendix 4 to the Matters, Issues, Questions document lists the potential SANG sites, and these include Fairoaks. Runnymede BC’s comments in relation to this site are:
“Application being considered by Surrey Heath and Runnymede Borough Councils. If site were granted, additional SANG land could be made available to meet Runnymede’s needs; however, delivery of SANG associated with the airport is not something the Council relies on.
If the application was refused, there is still the possibility that SANG could be delivered at this site.”
5.219 On that basis, there is no strategic need for SANG to be delivered at Fairoaks to meet Surrey Heath or Runnymede Borough’s SANG needs and, even if a strategic SANG site was required at Fairoaks Airport it does not necessarily require the closure and complete redevelopment of the airport to deliver this.
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5.220 Finally, the applicant suggests that the implementation of the SANG in this area “will act as in-perpetuity strategic buffers enhancing and safeguarding part of the site within the Green Belt.”135
5.221 This is a bizarre argument. The whole 155 hectares affected by the application is already very well protected by its Green Belt designation now. There is no particular need to further protect the eastern c52 hectares as SANG, if indeed this would provide further protection, at the cost of redeveloping the remainder. The whole of the site is worthy of protection, and is protected by the Green Belt designation.
Other Ecological Factors
5.222 In addition, Ethos Environmental Planning has reviewed the applicant’s submitted ecological assessments. This review is included at appendix 4 to our November 2018 objection, and is summarised below:
• Extended Phase 1 Habitat Survey (Austin Foot Ecology):
• Invertebrate surveys have been scoped out, but must be provided given the size and range of habitats present.
• Badger Survey Report (Austin Foot Ecology) is insufficient and cannot be relied upon for the following reasons:
• The Survey methodology was restricted to identifying potential setts. No effort has been made to identify badgers’ territories or foraging areas – for a site of this size and nature, this additional level of details would be expected;
• The Survey in 2015 identified 13 potential mammal features – only one camera trap used to confirm use – this is not sufficient;
• Survey in 2017 identified 48 holes/mammal features (tracks etc), no camera traps used to confirm use – again this is not sufficient;
• There is a lack of evidence that all mammal holes identified are
135 Paras 2.2 & 2.16, Very Special Circumstances Addendum, Savills, September 2019
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not badger – no photos or confirmation with camera traps.
• Bat Survey Report (Austin Foot Ecology). The methodology used falls significantly below that required for a development of this size and on a site with a range of suitable high quality habitats and cannot be relied upon, so the LPA is unable to discharge its statutory duties in this regard:
• Activity surveys restricted to one survey in spring, summer and autumn, when two per month are recommended;
• The number of static surveys and locations (three surveys at six locations) falls well below recommended levels (seven surveys at nine locations);
• Lack of advanced survey techniques means certain bat species are likely to be missed.
• Bat Surveys in Berwin Park Ecology Survey Report (RPS):
• Lack of advanced survey techniques means certain bat species are likely to be missed.
• Hazel Dormouse Survey Report (Austin Foot Ecology). The methodology falls short of that required and does not enable the LPA to discharge its statutory duties:
• Concerns over the number of nest tubes deployed (140) compared with standing advice (which implies at least 350);
• Concern that the survey ended in early September when the presence of dormouse is often not confirmed until October;
• Concern that the survey may be out of date (from 2015) given other issues.
• Dormouse Surveys in Berwin Park Ecology Survey Report (RPS):
• Insufficient detail provided regarding the number of dormouse tubes deployed or their location, so it is not possible to determine
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if the methodology is robust.
• Great Crested Newt Survey Report (Austin Foot Ecology):
• The traditional survey techniques used should have been supplemented by eDNA analysis;
• It is noted that later surveys at Berwin Park used the eDNA approach.
• Great Crested Newt Surveys in Berwin Park Ecology Survey Report (RPS):
• Concerns about disjointed nature of the GCN assessment and kits findings.
• Reptile Survey Report (Austin Foot Ecology):
• Surveys from 2015 are considered to be out of date
• The assessment and ES lack detail on mitigation, compensation and long term management given the status of the site as a “key reptile site”.
• Wintering Bird Survey Report (RPS) – additional information required prior to determination:
• The report concludes that the site has some site level importance for wintering red kite and lapwing, yet the assessment and ES do not put forward sufficient detail for mitigating impacts on species of site level importance;
• It is not clear how these areas will be managed for birds, particularly as new habitat is restricted to areas proposed as SANG which will be subject to high levels of disturbance.
Sports Field Provision
5.223 In terms of sports field provision, the applicant notes136 that “RBC’s
136 Para 7.334, Planning Statement, CBRE, July 2018
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standard for outdoor sports is set at 2.4 ha per 1,000 population, which is lower than SHBC’s requirement. The sports provision proposed falls below SHBC’s standard, however, SHBC has acknowledged that policy standards are high and has agreed that a bespoke solution may be appropriate for Fairoaks Garden Village, with an emphasis on flexibility and quality. This is also in conformity with Policy DM16’s supporting text, which states that the standards will be used as the basis for negotiations on a base by case basis.” (emphasis added).
5.224 Therefore, the application proposes less sports provision than is required by policy to meet the need that the development itself generates. Even if it were meeting its own needs this would only be a mitigation, not a benefit, and this mitigation would receive the same response as similar measures proposed at Wisley Airfield, referred to in paragraph 5.228 below.
5.225 That the applicant proposes not to meet its own needs is likely to generate additional travel, the effects of which have not been assessed.
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Creation of a New Sustainable Community Enshrining Garden Village Principles
5.226 The final benefit claimed by the applicant wraps up proposals for the governance of the project with community facility provision, a reprisal of the biodiversity enhancements measures, sustainable transport measures, the A319/A320 link road, and on-site renewable energy and sustainability measures137.
5.227 Many of these are merely mitigation of the likely adverse effects of the development; they are not benefits in themselves. If the development was not built there would be no need for them. In any event, many of the claimed benefits would be likely to be included albeit in a different form in alternative development proposals elsewhere.
5.228 Similar benefits were put forward by the appellant in the Wisley Airfield appeal, and the Inspector responded that “many of the alleged benefits are little more than mitigation for the proposed housing and to ensure that it comprises a sustainable form of development…”138. The same response applies here.
5.229 Furthermore, it is noted that:
• the application proposes a 2FE primary school on site, which would cater for 420 primary school children139 when the development would generate a need for 235 primary school places140. This will result in some 185 primary school aged children141, and no doubt their parents, commuting to the site from elsewhere. The impact of this has not been assessed. Furthermore, the original application claimed to result in an overprovision of 180 primary school places142, so the
137 Paras 6.142 to 6.186, Green Belt Assessment and Very Special Circumstances, CBRE, July 2018 138 Para 22.12, Inspector’s Report, Appeal Ref: APP/Y3615/W/3159894 139 Para 8.184, Updated Planning Statement, Savills, September 2019 140 Para 8.183, Updated Planning Statement, Savills, September 2019 141 Para 8.184, Updated Planning Statement, Savills, September 2019 142 Para 3.8, Planning Statement, CBRE, July 2018
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harm has increased since the original application;
• the application proposes to provide a financial contribution towards local secondary education facilities143 to cater for the 175 secondary school aged students that will be generated144. This is required by CIL in any event and will result in secondary school aged students leaving the development for secondary education schools elsewhere. The impact of this has not been assessed;
• the application proposes to provide a financial contribution towards local primary health care off-site despite the development generating a need for 1.3 GPs145. This will result in the development’s residents needing to leave the site even for primary health care in a different location. The impact of this has not been assessed;
5.230 This in summary does not suggest “the creation of a balanced mixed-use new community with a range of land uses and supporting facilities within a walkable settlement, (that) reduces the need to travel and enables and encourages the use of sustainable modes of transport” as espoused by the applicant146.
5.231 The applicant continues to claim, wrongly, that the proposed development is somehow a “Garden Village”. It is not.
5.232 The Updated Planning Statement147 assesses the site against garden village principles and notes that scale required for a Garden Village is 1,500 to 10,000 dwellings. This application is for 1,000 dwellings, significantly fewer than the lower end of this range.
5.233 The applicant explains that “… the reason for the minimum figure is to ensure a self-sustaining settlement …”148. This is indeed the case, and it is precisely because this proposal is not self-sustaining that it does not meet the criteria for a Garden Village.
143 Para 8.186, Updated Planning Statement, Savills, September 2019 144 Para 8.183, Updated Planning Statement, Savills, September 2019 145 Para 8.187, Updated Planning Statement, Savills, September 2019 146 Para 6.167, Green Belt Assessment and Very Special Circumstances 147 Para 4.71, Updated Planning Statement, Savills, September 2019 148 Para 4.71, Updated Planning Statement, Savills, September 2019
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6 Conclusion
6.1 This objection demonstrates that application reference 18/0642 does not accord with the relevant adopted development plans for Surrey Heath and Runnymede so, according to the NPPF, it can only be approved if very special circumstances exist.
6.2 The development would result in a significant quantity of inappropriate development in the Green Belt. NPPF explains that “very special circumstances will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations.”
6.3 We demonstrate that harm by reason of inappropriateness and the other harm created is not clearly outweighed by other considerations, so the application should be refused. This conclusion has not altered as a result of the applicant’s recent submissions.
6.4 We demonstrate that the site contributes to the fundamental aim and purposes of the Green Belt.
6.5 We demonstrate that other harm is greater than the applicant suggests, in particular in relation to loss of aviation, landscape and visual impact, transport and movement, and flood risk and drainage.
6.6 We also note that the applicant’s biodiversity assessment, landscape and visual impact assessment, transport assessment and flood risk assessment are inadequate to enable the LPA to determine the application.
6.7 In terms of the applicant’s suggested benefits, we demonstrate that the applicant misunderstands and misapplies Green Belt policy in a number of respects. In addition:
• Merely 7% at most of the site, and not 32% as the applicant claims, is previously developed land (and the Dunsfold appeal decision does not change this), but we also demonstrate that this is irrelevant to
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the consideration of harm to the Green Belt, which is a separate policy consideration altogether;
• The economic benefits of the proposal have been significantly overstated by the applicant, and that this benefit does not amount to the very special circumstances needed to justify the development in any event; in particular the airport use is not unviable and the use is able to be retained and enhanced fully in accordance with current Development Plan policy;
• The housing land supply in Surrey Heath may not be as low as the applicant claims; in any event housing shortfall does not itself amount to very special circumstances justifying release of Green Belt land;
• The proposed development is 470 metres at its closest point from the SPA, so SANG in this instance is not a reliable means of avoiding likely significant effects on a European site and an Appropriate Assessment must be undertaken prior to determining the application; and
• The self-sufficiency of the proposal is a mitigation of the effects of the proposal rather than a benefit in and of itself and, in any event, the extent of the proposal’s self-sufficiency is overstated.
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Appendix 1: Review of Road Transport Matters
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Planning Applications: (Surrey Heath Borough Council) ref. 18/0642, (Runnymede Borough Council) ref. RU.18/1615 and (Woking Borough Council ref. PLAN/2019/0923 & 0925).
Mixed use development at Fairoaks Airport, Chobham
Review of road transport matters by Fairoaks 2020 following the September 2019 release of revised application information.
(edition date =) 16 October 2019
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Overall Summary Fairoaks 2020 (F2020) has again reviewed road transport matters following the release of revised application information by Surrey Heath and Runnymede Borough Councils in September 2019. Despite the substantial time now elapsed since the application registration, the application still does not meet the following key transport aspirations of both national and local planning policy, because:
• The proposal still does not provide adequate or safe off-site highway infrastructure to reasonably enable development residents, occupiers and visitors to walk and cycle, particularly along the A320 corridor. Despite F2020 comprehensively listing the shortcomings in the local pedestrian and cyclist infrastructure over ten months ago, the application still includes no definite proposals to resolve those problems, to deliver adequate and safe walking and cycling infrastructure for development residents, occupiers and visitors.
• The design of the proposed site highway accesses and offsite junction works proposal still does not provide adequately safe highway infrastructure for the development residents, occupiers and visitors, as well as the road using public at large. Despite F2020 listing road safety problems with the design of the proposed site highway accesses and offsite junction works over ten months ago and the county council conducting road safety audits, many of the site access and offsite junction works designs still have significant unresolved highway safety problems.
• It has not demonstrated that the significant traffic generation of the development can be effectively limited. Notwithstanding the significant discrepancies, errors and omissions still present in the applicant’s road transport assessment work, it is becoming clear that the traffic impact in Chobham village is unlikely to be able to be acceptably limited by the proposed junction schemes, banned turns and diversion routes. A severe cumulative impact maybe created. And the applicant has only now released mitigation proposals for M25 junction 11 and M3 junction 3, which F2020 understand have not yet been processed or agreed by Highways England.
The harm caused against the sustainable development transport objectives of both national and local planning policy remains as F2020 originally reported in December 2018 - that: • sustainable transport is not adequately promoted, facilitated or delivered, • highway safety is not sufficiently ensured or delivered, and • the significant road transport impacts created have not been (demonstrated to be) effectively limited and significant cumulative impacts maybe created.
Due to the number and nature of the unresolved transport problems and the time elapsed since application registration, F2020 respectfully requests that the local planning authorities now refuse the development on the road transport grounds; we have included refusal reasons.
End of summary.
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Contents
Overall Summary page 2 1.0 Contents page 3 2.0 Introduction & purpose page 4 3.0 Section summaries lifted from sections below page 5 4.0 Review of transport-related matters, under headings: page 9 4.1 Sustainable transport infrastructure, including: 4.1.1 Walking & cycling page 9 4.1.2 Trains page 10 4.1.3 Buses page 10 4.1.4 Car clubs page 11 4.2 Traffic surveys page 12 4.3 Road collisions analysis page 13 4.4 Development phasing page 14 4.5 Development road traffic generation page 15 4.6 Development road traffic distribution page 16 4.7 Performance modelling of site accesses & offsite junctions, including page 17 4.7.1 Missing junctions page 17 4.7.2 Overarching junction performance modelling problems page 17 4.7.3 A319 site access roundabout page 18 4.7.4 A319 secondary site access T-junction page 18 4.7.5 A319 / Young Stroat Lane site access T-junction page 18 4.7.6 A320 traffic site access signaled T-junction page 19 4.7.7 A319 Chertsey Road / High Street / B383 Windsor Road page 19 T-junction 4.7.8 A319 High Street / Vicarage Road roundabout page 22 4.7.9 B383 Windsor Road / Bowling Green Road mini roundabout page 23 4.7.10 A319 Chertsey Road / Delta Road T-junction page 23 4.7.11 A319 / Philpot Lane T-junction page 24 4.7.12 A3046 / Philpot Lane T-junction page 24 4.7.13 Six crossroads roundabout page 25 4.7.14 A320 / Martyrs Lane / McLaren roundabout page 25 4.7.15 A245 Woodham Lane / Martyrs Lane T-junction page 26 4.7.16 A320 / A319 / B3121 (Ottershaw) roundabout page 27 4.7.17 A320 Guildford Road / St. Peters Way signalled roundabout page 28 4.8 Chobham village proposed right turn bans & diversion routes page 29 4.9 Site Access & Offsite Highway Works Design / Road Safety Auditing page 32 4.10 Motorway Junctions - M25 Jct.11 & M3 Jct. 3 page 37 4.11 Highway works implementation timetable / triggers page 38 5.0 Framework Travel Plan (OPA18) page 39 6.0 Draft S106 Heads of Terms page 40 7.0 Very Special Circumstances Addendum page 41 8.0 Suggested road transport refusal reasons page 42
Appendices 1.0 List of technical terms / abbreviations used page 43
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2.0 Introduction & Purpose
Fairoaks 2020 (F2020) has updated its review of road transport related matters associated with Fairoaks development planning applications (SH)18/0642 and RU.18/1615. This follows both Surrey Heath and Runnymede Borough Councils’ September 2019 release of revised application information.
In December 2018, F2020 first circulated its first road transport review to and both Surrey Heath and Runnymede local planning authorities and also to Surrey County Council (SCC) and Highways England (HE). An updated review was circulated in June 2019 following information received from SCC under Freedom of Information.
The purpose of this updated road transport review is to (re)identify to - the planning applicant, the planning authorities, the county council and Highways England - the large number of outstanding road transport issues present in the application, which have not been addressed or resolved.
At this late stage in the application lifetime, F2020 respectfully request that SCC reviews this list of outstanding transport matters and without further delay or evasion, makes comprehensive application response(s) to the local planning authorities.
Responsibility for deciding whether the Fairoaks applications meet the requirements of road transport policy and guidance falls on the respective local planning authorities – SHBC and RuBC. If the advice that they receive from the county council as a planning consultee is insufficient, they must make their own assessment. Therefore, irrespective of the road transport application responses supplied by SCC, F2020 respectfully requests that the local planning authorities themselves review the outstanding transport matters. F2020 hopes that this critique assists with that process.
The format of the body text this report is similar to F2020’s previous road transport reports and is typically as follows:
Problem title. Problem description – A detailed description of the problem(s) identified. • Benchmarking – Applicable guidance and standards that have been referred to and underpin each item listed, including where relevant text extracts.
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3.0 Section Summaries.
For reader convenience, below a summary is provided for each main section heading of this review. To emphasise the key outstanding problems, the text below is written in traffic light colours – red, amber, green – to indicate:
• red indicates a problem or issue that does not obviously appear capable of being resolved, • amber indicates significant issue(s) yet to be addressed / resolved, which may turn to red if not adequately addressed / solved, and • green indicates a subject where F2020 has no further comments.
Sustainable transport infrastructure. Walking & Cycling - There are still includes no definite proposals to improve the substantial deficiencies that exist in the off-site footway / cycling infrastructure routes that the development wholly relies upon to accommodate the ‘all members of society’ pedestrian and cyclist movements generated. Due to the presence of third party land and environmentally sensitive common land, we suggest that fixing many of the deficiencies maybe infeasible or impossible.
Rail - There is neither information estimating the train patronage the development generates, nor any information if existing rail services from the local stations can accommodate that demand. We suggest that the LPA consults the railway companies / operators.
Bus - There is neither information estimating the bus ridership the development generates, nor any information if existing bus services the development might utilize can accommodate that demand. Consequently, it is unclear whether the proposed bus service options set out are capable of accommodating the bus ridership demand generated by the development.
Car Club - No further comments.
Traffic Surveys. The actual traffic survey data relied on is still not included and consequently F2020 has not been able to review the data in its review, which may identify further snags.
Road collisions analysis. The road collision data used is now two and a half year out of date and more recent collision data should be considered.
Development phasing. The delivery trigger for a pedestrian / cycleway link to the A320 is unclear and without prejudice we suggest ‘on first occupation’ trigger(s) is adopted. The delivery of the vehicular link to the A320 is similarly vague. There is still no obvious logical correlation between the two traffic assessment scenarios in the TA and the three development phases listed in the Planning Statement.
Development Road Traffic Generation Information. No further comments. Development road traffic distribution. The (re)routing of vehicles remains mostly based on unsupported assumptions about drivers’ possible route choices, particularly in the ‘with link road’ scenario. Little empirical information underpins the routing assumptions used. Without prejudice, F2020 suggest ‘sensitivity testing’ be done to understand the possible impacts of different driver routing than currently considered.
5
Performance modelling of site accesses & offsite junctions. Missing junctions - The development traffic impact has still not been studied at three main road junctions and at a single lane road bridge.
Overarching junction performance modelling problems - There are many discrepancies in the performance modelling input and output data, which combine to render the estimated performance of a proposed site access and offsite junctions unreliable.
A320 site access signal junction - The correction of missing and unsafe staging arrangements will likely show a capacity overload and consequently, it has not been demonstrated that the proposed signal junction has adequate capacity to accommodate the traffic generated by the development, without adversely affecting existing A320 traffic flows.
A319 High Street / Chertsey Road / Windsor Road T-junction - The performance modelling has not demonstrated that either - the proposed right turning lane T-junction alteration or the proposed signal junction alteration - effectively mitigate the development traffic impact, because of traffic blocking back from the adjacent junction through this junction and because the alterations involve banned turns and traffic diverting through unsuitable roads, the proposals maybe infeasible – see below.
A319 High Street / Vicarage Road junction – The performance modelling has not demonstrated that the proposed minor alterations to the roundabout geometry will effectively mitigate the development traffic impact, because of traffic blocking back from a nearby junction through this junction.
A319 Chertsey Road / Philpot Lane junction - The performance modelling has missed out one of the junction give ways and hence the development traffic impact has not yet been demonstrated at this junction.
A3046 / Philpot Lane junction - The performance of this junction has still not been modelled, despite the development significantly loading the heavy turn movements that cause congestion and delay in peak hours, and hence the development traffic impact has not yet been demonstrated at this junction.
Six crossroads roundabout junction - The performance of this junction has not been modelled and is in part based on unsupported traffic distribution information. Also, a development at nearby McLarens and the A320 Corridor Study both found this roundabout significantly overloaded and in need of improvement. Furthermore, introducing necessary pedestrian/cyclist crossing facilities at the roundabout is likely to worsen its capacity and increase congestion. Hence, the development traffic impact has not yet been demonstrated at this junction.
A320 / Martyrs Lane / McLaren roundabout - We query the listed performance data for this junction, because TAs submitted for other development indicated significantly worse junction performance results. There is another peak traffic period that affects this junction which is unstudied. Hence, the development traffic impact has not yet been demonstrated at this junction.
A320 / A319 / B3121 (Ottershaw) Roundabout – We query the listed performance data for this junction, because it omits a number of existing / proposed features, which have the potential to affect roundabout performance. Hence, the development traffic impact has not yet been demonstrated at this junction.
A320 Guildford Road / St. Peters Way signalled roundabout junction - Traffic queuing back from the
6
Ottershaw roundabout affects exiting from this roundabout, which renders the modelled performance results or this roundabout unreliable. Hence, the development traffic impact has not yet been demonstrated at this junction.
B383 Windsor Road / Bowling Green Road mini roundabout junction - We query the listed performance data for this junction, because it omits the adjacent Zebra crossing that has the potential to affect roundabout performance. Hence, the development traffic impact has not yet been demonstrated at this junction.
A319 Chertsey Road / Delta Road junction - The included performance modelling results are worthless, as the input measurement data is from a different junction.
A245 Woodham Lane / Martyrs Lane junction - The performance of this junction has not been modelled, despite the development significantly loading the heavy turning movements in peak hours, and hence the development traffic impact has not yet been demonstrated at this junction
Chobham village right turn bans & diversion routes - The implications of banning right turns and diverting main road traffic, including HGVs, along minor residential and rural roads has been inadequately considered and consequently the feasibility of the banned turns and diversions has not been demonstrated. The banned turns and diversion routes appear infeasible
Site Access & Offsite Highway Works Design / Road Safety Auditing. None of the four site access designs meets / passes SCC stage 1 road safety audit (St1RSA) standard. The main A319 site access roundabout has not yet been St1RSAed. Also two of the three offsite highway works designs in Chobham village don't meet / pass SCC St1RSA standard. F2020 suggest further design/safety issues, carried forward from F2020’s previous reports, which were not included in SCC’s RSA reports.
Motorway Junctions - M25 Jct. 11 & M3 Jct. 3. F2020 understands that Highways England (HE) has not previously been presented with the proposals at M25 J11 and M3 J3. F2020 is concerned whether it is feasible for HE to review and approve the proposed motorway junctions works, before the timetabled Jan/Feb 2020 application decision date. In the meantime F2020 has identified a number of problems with the proposed motorway junction designs.
Highway works implementation timetable / triggers. The timetable / implementation triggers for the various highway works, as set out in the application documents, are vague and uncertain. Framework Travel Plan. Without adequate non-car travel road infrastructure available to the development residents, occupiers and visitors, as described above, the FTP is unlikely to meet its sustainable travel objectives and remains ‘greenwash’. Draft Section 106 Agreement Heads of Terms (S106 Hot). The S106 HoT is generally vague and incomplete in its inclusions about transport and highway contribution(s) and physical highway works. By reference to the NPPF, planning conditions should be used to secure the highway works, not a S106. Very Special Circumstances Addendum. The development brings about no transport-related VSC.
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Suggested transport refusal reasons In view of the outstanding transport problems and the time elapsed, we request the application now be refused and have included transport refusal reasons.
End of section.
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4.0 Review of transport-related matters:
The following subsections set out F2020’s findings following a review of the revised / updated transport- related application documents. The main document reviewed here is the revised transport assessment (RevTA), but other documents such as the planning statement (PS) are touched upon. The text of the review is set out under simple headings that reflect the transport-related subject matter of the RevTA and issues arising.
4.1 Sustainable transport infrastructure. 4.1.1 Walking & cycling. Problem description. The RevTA still includes no proposals to improve off-site footway / cycling infrastructure. We understand from FOI information that as at September 2019 and at this date stage in the application lifetime, the county council had not yet to advise about this aspect of the development.
The development relies on the A320 shared footway / cycleway (NCR223) and also existing public rights of way, particularly the Young Stroat Lane bridleway, for pedestrian / cyclist connectivity to the urban areas and mainly into Woking.
F2020’s previous two road transport objections comprehensively listed the deficiencies with the existing A320 NCR223 footway/cycleway and the rights of way. These deficiencies - summarised below - remain unresolved.
A320 NCR223 footway/cycleway • Substandard narrow section across Dunford Bridge. • Substandard narrow / depressed section between Dunford Bridge and McLaren roundabout. • Grossly substandard narrow section at Anthonys. • Only uncontrolled road crossings available at the Six Ways roundabout to the south and likewise at Ottershaw roundabout to the north. • Apart from a handful of properties at Anthonys and north of Dunford Bridge, the route has no natural surveillance by adjoining premises. • Except for two small pockets of street lighting at the McLaren roundabout and Anthonys, the section between Dunford Bridge and the Six Ways roundabout is unlit.
Young Stroat Lane • Rural in character, unmade, unlit, no natural surveillance. • No road crossing facilities at the southern end, at the complicated A3046/A245 road junction.
We suggest that the RevTA consider the feasibility of undertaking improvements to resolve the deficiencies present. However, we think that it may not be possible or at least be very difficult to overcome some of the deficiencies. Examples: • Fixing the narrow point at Anthonys might well involve unavailable third party land. • Introducing road crossing points at Six Ways roundabout and at the A3046/A245 road junction may well involve the adjacent environmentally constrained and privately owned common land. • Installing street lighting along the unlit section of the A320 between Anthonys and the Six Ways roundabout may affect the adjacent environmentally constrained and privately owned common land. 9
In the meantime, the RevTA has not yet demonstrated that adequate infrastructure is available to safely and reasonably accommodate the ‘all members of society’ pedestrian and cyclist movement that the development will generate.
The RevTA contains no information *estimating the amount of footfall that the development will generate, both per phase and in total.
*Benchmarking. From www.GOV.uk, 'Travel Plans, Transport Assessments and Statements' >> “… What information should be included in Transport Assessments and Statements? .... a qualitative and quantitative description of the travel characteristics of the proposed development, including movements across all modes of transport that would result from the development and in the vicinity of the site ...."
End of subsection.
4.1.2 (Sustainable transport infrastructure) Trains. Problem Description. The RevTA contains no information *estimating the train patronage the development will generate. Nor any information to indicate whether existing rail services from the local station(s) are capable of accommodating that train travel demand. We suggest that the LPA consults the railway companies / operators concerned.
*Benchmarking. from www.GOV.UK >> “Transport evidence bases in plan making and decision taking” >> *www.GOV.uk "Travel Plans, Transport Assessments and Statements” >> ".... Key issues to consider at the start of preparing a Transport Assessment or Statement .... assessment of public transport capacity ...."
End of subsection.
4.1.3 (Sustainable transport infrastructure) Buses. Problem description. The RevTA contains no information *estimating the bus ridership the development will generate, both per phase and in total. Nor any information to indicate whether existing bus services that the development might utilise - i.e. the 446 bus - is capable of accommodating that bus travel demand. Consequently, it is unclear whether the proposed bus service options set out in RevTA sections 3.6 / 3.7 are capable of accommodating the bus ridership demand generated by the development.
*Benchmarking. From www.GOV.UK >> “Transport evidence bases in plan making and decision taking” and “Travel Plans, Transport Assessments and Statements” >> ".... Key issues to consider at the start of preparing a Transport Assessment or Statement .... assessment of public transport capacity, walking/cycling capacity ...." And. ".... Capacity assessments for .... bus should also be obtained. .... The first step in quantifying the impact of proposed land allocations in the Local Plan on the transport system is to provide an estimate of the person trips (for all types of transport) that are likely to be generated by it ....".
And from SCC “Transport Development Planning Good Practice Guide” >> “… Information detailing the all modes trip generation of the development site …” and “… Information about the transport system(s) / area(s) that will be studied, to decide about the transport impact of the development proposal. And for
10
those system(s) / area(s): … survey or other information about the patronage and capacity of public transport during period(s) of normal operation …”
End of subsection.
4.1.4 (Sustainable transport infrastructure) Car club. No further comments.
End of section.
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4.2 Traffic surveys. Problem description. 4.2.1 The RevTA Appendices do not contain the actual traffic survey data, so this could not be considered by F2020 in reviewing the RevTA, which has limited F2020’s review. For example, we have not been able to:
• consider if the peak periods chosen by the TA author are correct,
• review whether the surveyed junction queues reasonably correlate with the results produced by the junction performance modelling for vehicle queuing, and
• decide if the traffic surveys correctly counted the vehicles travelling along the network and through congested junctions; note the following text from TRL on this matter –
from ‘TRL Software’ > Training & Support > Knowledge Base > Has demand been measured correctly? >> “… ARCADY/PICADY need to know the volume of traffic that wants to use the junction - i.e. the demand. This should be measured upstream of any queueing. If, instead, you count vehicles crossing the give-way line, you have measured the throughput instead of the demand. If you enter this as the demand then the predicted queues will be very small, because you will just be telling ARCADY/PICADY that the amount of traffic wanting to use the junction is the same as the amount that you have observed flowing through it. …”
4.2.2 Lastly, we note from the list of junctions in RevTA paragraph 6.21, that the three main junctions not performance modelled – see below – were not surveyed.
End of section.
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4.3 Road collisions analysis.
Problem description. 4.3.1 From RevTA paragraph 6.11.1, the included road collision data considered is from 01 January 2012 to 30 April 2017 and hence is now two and a half year out of date. More recent collision data should be considered.
Benchmarking. From www.GOV.UK >> “Travel Plans, Transport Assessments and Statements” >> “.... an analysis of the injury accident records on the public highway in the vicinity of the site access for the most recent 3-year period, or 5- year period if the proposed site has been identified as within a high accident area ...."
End of section.
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4.4 Development phasing.
Problem description. 4.4.1 We note from RevTA paragraph 2.6.3 and PS paragraphs 1.9, 1.35, 6.9 that the creation of the pedestrian / cycle link from the site to the existing A320 shared footway / cycleway (NCR223) is now proposed in development phase 1.
PS paragraph 6.9 lists the following development proposed under phase 1. "... this phase is likely to include the delivery of most of the business premises and the hotel ... approximately one quarter of the total number of homes proposed ... a temporary shop ... Prime Acrobatics ... the helipad ...”
Without prejudice to F2020’s overarching and other objections, we suggest that this pedestrian / cyclist link to the A320 be constructed and be open to public use, before first occupation of the first additional dwelling built on the site and before first occupation of more non-residential floorspace than currently exists; whichever is triggered first. Reason - to deliver pedestrian / cyclist infrastructure to the development residents, occupiers and visitors.
4.4.2 We also suggest that the delivery of “ … the remainder of the sustainable transport corridor/link road, to connect with the A320 …” in phase 2 is a wide time window and a more certain trigger should be stated. (*from PS paragraph 6.11).
4.4.3 We remain concerned that the two traffic assessment scenarios set out RevTA section 8 - half the development by 2025 and all of it by 2030 - correlate poorly with the proposed completion under three phases described in the PS. The RevTA presents no information to illustrate a logical connection between its two scenarios and the three described in the PS. To illustrate the problem, below we have set out summarized development information from the RevTA and PS.
RevTA scenarios • 2025 scenario – 500 homes, 32,502sqm non-residential floorspace including half the:- employment floorspace, hotel, school, shops, etc. and no A320 link road vehicular access. • 2030 scenario – 1000 homes, 65,004sqm non-residential floorspace including all the:- employment floorspace, hotel, school, shops, etc. and inc. the A320 link road vehicular access.
PS three phases • Phase 1 - "... this phase is likely to include the delivery of most of the business premises and the hotel ... approximately one quarter of the total number of homes proposed ... a temporary shop ... Prime Acrobatics ... the helipad …” (no link road vehicular access the A320). • Phase 2 – “… southern-most part of the employment area; … approximately half of the total homes proposed, older people’s housing, the High Street, Village Green and primary school; sports pitches, sports hub and SANG visitor centre … the *link road, to connect with the A320 …” (*i.e. link road vehicular access the A320 built sometime during phase 2). • Phase 3 – “…the southern part of the Site, and the eastern-most element of the developable area …” (presumably the remainder).
Benchmarking. Nil.
End of section.
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4.5 Development Road Traffic Generation Information.
No further comments.
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4.6 Development road traffic distribution.
Problem Description. 4.6.1 As previously reported by F2020, the (re)routing of vehicles in the traffic distribution sections of the RevTA remains mostly based on unsupported assumptions about drivers’ possible route choices, particularly so in the ‘with A319 to A320 link road’ scenario. The RevTA uses little empirical information, such as - journey length information, surveyed journey times, journey origins and destinations, surveyed turns at junctions – to underpin the routing assumptions used.
Where there is uncertainty about driver behavior, ‘sensitivity testing’ – where different traffic flows and turning proportions are allocated to the network being studied – can be used to understand the possible impacts of different driver routing than currently considered in the RevTA. Without prejudice, F2020 suggests such sensitivity testing be undertaken. We note from FOI information that SCC has not considered this possibility.
Benchmarking. Nil.
End of section.
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4.7 Performance modelling of site accesses & offsite junctions.
4.7.1 Missing junctions.
Problem description. As per F2020’s previous report, the Rev TA has still not considered the development traffic impact at the following three junctions that, as above, were not surveyed. Hence, the RevTA has still not demonstrated the development traffic impact at these nodes. Why not?
• A3046 / Littlewick Road roundabout. We note the A3046 junctions to either side of that roundabout were considered, and the traffic impact at this roundabout is expected to be material before the A319 to A320 link road is open to vehicles. We note that the roundabout is abutted on all sides by privately owned common land.
• A319 / A322 / Red Road roundabout. We note that the junctions to either side of that roundabout - the A319 / Chobham High Street roundabout and M3 junction 3 - were considered. Furthermore, under application (SH)12/0546 for major development at Princess Barracks in Deepcut, this roundabout was found to be traffic sensitive and that permission included improvements to this roundabout. We also note that all main road junctions between the development site and M25 junction 11 have been considered.
• A320 / Brox Road T-junction. As previously identified by F2020, following the opening of the proposed A319-A320 link road, there seems to be potential for A319 north-eastbound drivers headed towards Murray Road to avoid the Ottershaw roundabout, by using the ‘link road to A320 to Brox Road/Slade Road’ route instead and visa versa. Hence, we suggest the need to assess the A320 / Brox Road junction for the ‘rat run’ that the link road might create.
• Philpot Lane hump back bridge. As previously reported by F2020, we also suggest that consideration of the single lane hump back river bridge in Philpot Lane which is a throttle to road link capacity in Philpot Lane. The traffic impact at this bridge maybe material before the A319 to A320 link road is open to vehicles.
Benchmarking. Nil
End of subsection.
4.7.2 (Performance modelling of site accesses & offsite junctions) Overarching junction performance modelling problems.
Problem description The following generic problems render many of the junction performance results listed in the RevTA as unreliable. Hence, the RevTA has not yet demonstrated that these results can safely be used as a yardstick to gauge the performance of existing junctions and also the proposed junction improvements. Consequently, at many junctions it is uncertain what the impact the development traffic will be and also what level of mitigation the proposed improvements will actually deliver. See the sections below about individual junctions for further information and examples.
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• The above listed problems concerning traffic distribution render the input information junction performance modelling ‘base’ scenarios potentially unreliable.
• The information for some of the junction modelling outputs indicates that the programs are being used outside of their design parameters - such as for high levels of capacity overload - and consequently the output information may be unreliable.
• In some cases, the congested operation of road networks can result in traffic from one junction queuing back to the upstream junction and affecting its operation. We think that this is likely to be the case with the A320 junctions on the approach to M25 junction 11 and the A319 junctions in Chobham village. Where this occurs, the RevTA is using the standalone junction performance modelling programs outside of their design parameters.
• Again we question whether the (Rev)TA authors have calibrated the 2017 ‘base’ models for the existing junctions studied with reliable surveyed junction queuing and vehicle journey time information. However, we think that this is unlikely because some of the modelling output queuing information looks suspect for some junctions. (Note that F2020 is unable to verify either way, because the developer has still not included the 2017 application traffic survey data, which RevTA paragraph 6.2.1 states included “… Queue data at the end of each 5 minute period was also recorded. …”).
Benchmarking. Nil.
End of subsection.
4.7.3 (Performance modelling of site accesses & offsite junctions) A319 site access roundabout.
No junction performance modelling comments.
End of subsection.
4.7.4 (Performance modelling of site accesses & offsite junctions) A319 secondary site access T-junction.
No junction performance modelling comments.
End of subsection.
4.7.5 (Performance modelling of site accesses & offsite junctions ) A319 / Young Stroat Lane site access T-junction.
No junction performance modelling comments.
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End of subsection.
4.7.6 (Performance modelling of site accesses & offsite junctions) A320 site access signllled T- junction.
Problem description. We have (re)identified the following issues concerning the junction performance modelling in RevTA section 29 and RevTA appendix 29:
• The modelling results in RevTA table 29.1 lists that the junction only has 0.5% PRC in the p.m. peak hour scenario, which is of particular concern because of the above generic and below specific modelling snags; there is insufficient junction capacity freeboard.
• The appended LINSIG information indicates that the junction is staged to allow right turners to ‘gap seek’ rather than be positively signal controlled, as recommended by signal junction design guidance and the RSA. And the pedestrian / cyclist crossing over the proposed junction side arm is also not included in the LINSIG staging. Including both of these features within the LINSIG model will reduce the junction performance and likely overload it.
Consequently, the RevTA has yet to demonstrate that this proposed site access can effectively accommodate the development traffic impact with causing congestion and safety problems on the A320.
Benchmarking. Nil.
End of subsection.
4.7.7 (Performance modelling of site accesses & offsite junctions) A319 Chertsey Road / High Street / B383 Windsor Road junction performance modelling.
Problem description: The TA includes two forms of junction improvements. Issues affecting both proposals are described below and then each junction form is considered individually. The consequence of the problems set out below is that the RevTA has not demonstrated that the development traffic impact at this junction can be effectively mitigated.
Issues affecting both junction alteration schemes • Both junction schemes rely on banning vehicle right turns at the junction, to achieve performance improvements sufficient to mitigate the traffic impact of the development. If right turns cannot be banned, then the junction performance gains set out in the RevTA will not be able to be realized and the development will have a significantly higher traffic impact than currently set out. Consequently, the developer’s ability to deliver the banned right turns is a critical factor. As set out below in this critique, the developer has yet to demonstrate the feasibility banning turns and creating diversions.
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• The RevTA compares the modelled performance of the proposed alterations to the PIDADY modelled performance of the existing T-junction, to gauge whether the proposed junction works acceptably mitigate the development traffic impact. This relies on the modelled performance of the existing T-junction being competently reflected in the RevTA and we think it is not reliable and not fit for purpose for the following reasons:
o The ‘base’ performance of the existing junction in RevTA table 10.1 lists a RFC of 11.1 (i.e. about 1000% over capacity) on one arm and 1.29 (i.e. 29% over capacity) on another. Also, there are obvious problems in the PICADY model outputs for the a.m. period covering the 2017, 2025, 2030 ‘base’ scenarios, where the number ‘999999….’ appears in the TA Appendix 10a output tables for RFC and delay time and this error is carried forwards into the missing data in TA tables 10.3 to 10.6. Again and as above, we question the PICADY’s reliability at such gross levels of overload.
o RevTA table 10.1 lists queue length of 98 vehicles, about 600m long (i.e. 98 vehicles x c.6m/vehicle) on the A319 Chertsey Road, which is from the High Street back to Mincing Lane. And 223 vehicles, about 1.3km long (i.e. 223 vehicles x c.6m/vehicle) on the A319 High Street, which if taken back south along the A319 will extend from Chertsey Road back and well past Pennypot Lane, obviously blocking through the downstream High Street roundabout junction to the south. Again as above, we question about calibration between modelled and actual queue lengths. We note that PICADY author TRL states the following on this matter-
from ‘TRL Software > Training & Support > Knowledge Base > PICADY modelling’ >> “Consider applying calibration factors (intercept adjustments) ... If all else fails then you can apply factors to calibrate the model. ... If you find that you need to apply very large adjustments to reproduce the observed queues, this suggests that there is something wrong with the model data ..”
o The existing T-junction has a stop line, but PICADY is set up to model give way line junctions. How has the RevTA author considered and calibrated for this issue? We note that PICADY author TRL states the following on this matter -
from ‘TRL Software > Training & Support > Knowledge Base > PICADY modelling’ >> “… Modelling a stopline instead of a give-way in PICADY ... Unfortunately there is no research that compares the capacity of a give-way line and that of a stopline in the context of a PICADY junction. ... If using PICADY to assess a junction that has stoplines instead of give-way lines, all you can really do is to model the junction as usual and then assume that the real capacity will be slightly lower, i.e., the PICADY results will be on the optimistic side (everything else being equal). …”
o Programs like PICADY that model standalone junctions rely on vehicles being able to exit junctions and proceed downstream unobstructed. In the case on this junction, queuing back occurs on the southbound approach to the A319 High Street / Vicarage Road roundabout, which can block back through this T-junction. How has the RevTA author calibrated the PICADY results for this issue?
Ghosted right tuning lane junction improvement performance modelling. We have identified the following issues concerning the junction performance modelling in RevTA section 10 and RevTA appendix 10. From these findings, the RevTA has not demonstrated that this form of proposed junction alteration effectively mitigates the development traffic impact.
• The PICADY modelling outputs listed in RevTA include *RFCs for the High Street junction arm of
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well over unity, with correspondingly very long queues: (*Note the industry standard RFC rule of thumb is that above 0.85 RFC (85%) T-junction queuing and delay start to increase sharply).
o tables 10.9, RFC = 1.12 (112%) and queue 132 vehicles about 800m (i.e. 132 x 6m/vehicle) and if stretched back along the A319 from Chertsey Road to Pennypot Lane, obviously blocking through the A319 High Street/Vicarage Road roundabout, and
o table 10.10, RFC = 1.34 (134%) and queue 313 vehicles about 1.9km (i.e. 313 x 6m/vehicle) and if stretched back along the A319, from Chertsey Road to Brook Place near Halebourne Lane, obviously blocking through the A319 High Street/Vicarage Road roundabout.
Again and as above, we ask the TA author(s) to clarify whether the PICADY modelling outputs concerning queuing and delay for this junction remain reliable for these levels of overload. Furthermore from these results, it is plain that the proposed approx. 20m long A319 High Street right turning lane is far too short to contain right turners.
Signalled junction alteration performance modelling. We have identified the following issues concerning the junction performance modelling in RevTA section 10 and RevTA appendix 10. From these findings, the RevTA has not demonstrated that this form of proposed junction alteration effectively mitigates the development traffic impact.
• The appended LINSIG modelling does not include a signaled pedestrian crossing stage across the A319 Chertsey Road arm as recommended by SCC’s RSA and as per F2020’s previous report. The inclusion of a pedestrian stage will reduce the junction performance set out in the RevTA.
• The LINSIG modelling outputs listed in RevTA include negative *PRCs for signal junction option 2, meaning the junction is over capacity. (*Note the industry standard RFC rule of thumb is to design to a maximum 90% PRC to limit excessive queuing and delay).
o table 10.13, PRC = -42% (i.e. 42% over capacity) o table 10.14, PRC = -77% (i.e. 77% over capacity).
• And the consequent junction a.m. peak hour degree of junction saturation (DoS) and queuing results for the 77% overload in table 10.14 are:
o Chertsey Road junction arm = 158% DoS and 104 vehicles queued, about 600m (i.e. 104 x 6m/vehicle) which stretches back along the A319 to Mincing Lane, and
o High Street junction arm = 159% DoS and *350 vehicles queued, about *2.1km (i.e. 350 x 6m/vehicle) and if stretched back along the A319 from Chertsey Road to near Halebourne Lane, obviously blocking back through the A319 High Street / Vicarage Road roundabout.
• Furthermore from these results, it is plain that the proposed approx. 20m long A319 High Street right turning lane is far too short to contain right turners for this junction design option.
As above, we ask the TA author(s) to clarify whether the LINSIG modelling outputs concerning queuing and delay for this junction remain reliable for these levels of overload. On this point, we note a planning inspectorate inspector’s remarks in paragraph of the Elmbridge appeal case for about 1000 houses at Drake Park in Walton on Thames (PINS ref. APP/K3605/W/17/3172429) “…However, the TA itself notes that queue lengths predicted by LinSig become increasingly unrealistic once 90% saturation 21
is exceeded …”
Benchmarking. Nil
End of subsection.
4.7.8 (Performance modelling of site accesses & offsite junctions) A319 High Street / Vicarage Road / roundabout junction.
Problem description. We have (re)identified the following issues concerning the junction performance modelling in RevTA section 11 and RevTA appendix 11:
• The RevTA compares the modelled performance of the proposed alterations to the ARCADY modelled performance of the existing roundabout junction, to gauge whether the proposed junction works acceptably mitigate the development traffic impact. This relies on the modelled performance of the being competently reflected in the RevTA and we think it is not reliable and not fit for purpose for the following reasons:
o The ‘base’ performance of the existing junction in RevTA table 11.4 lists a RFC of 1.16 (i.e. 16% over capacity) on one arm and 1.14 (i.e. 14% over capacity) on another. Also, this table lists queue length of 137 vehicles, about 800m long (i.e. 137 vehicles x c.6m/vehicle) on the A319 High Street southern arm, which measured back along the A3046 is from the roundabout to Sandpit Hall Road and obviously blocking through the A3046 / Castle Grove Road roundabout . And 120 vehicles, about 700m long (i.e. 120 vehicles x c.6m/vehicle) on the A319 High Street northern arm, which if taken back north along the A319 / B383 will extend from the roundabout past Leslie Road and obviously blocking through the A319 High Street / Chertsey Road / Windsor Road T-junction. Again and as above, we question ARCADY’s reliability at such levels of overload / queuing.
o Programs like ARCADY that model standalone junctions rely on vehicles being able to exit junctions and proceed downstream unobstructed. For this junction, queuing back occurs on the southbound exit from the roundabout, due to link capacity problems on this southern High Street section, which can block the southbound exit to the roundabout. Also, queuing back occurs on the northbound High Street exit from the roundabout, due to blocking back from the right turn from the right turn from the A319 High Street into A319 Chertsey Road, which can block the northbound exit to the roundabout. How has the RevTA author calibrated the PICADY results for this issue?
Because of the above problems associated with the roundabout performance modelling and blocking back through the junction, we question whether the proposed minor geometry alterations to this roundabout will deliver the traffic impact mitigation set out in the RevTA. In practical terms, we expect that the blocking back of queues from one junction to another in Chobham village is likely to negate the theoretical performance increases of the proposed minor geometry alterations.
Consequently, from these findings, the RevTA has not demonstrated that the proposed junction alteration effectively mitigates the development traffic impact.
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Benchmarking. Nil
End of subsection.
4.7.9 (Performance modelling of site accesses & offsite junctions) B383 Windsor Road / Bowling Green Road mini roundabout junction.
Problem description. The junction performance modelling of this mini roundabout, in RevTA section 31 and RevTA appendix 31, does not include the existing Zebra crossing on the Windsor Road southern arm, which has the potential to render the modelling results unreliable. As above, we note that ARCADY includes the facility to include pedestrian crossings on the roundabout arms.
When this Zebra is in use, it has the potential to cause queuing back towards and across the mini roundabout, affecting the mini roundabout capacity / performance. Proper consideration of this matter could include:
o on the ground observation of the operation of the Zebra during peak traffic hours, o survey data about how often the Zebra is used during peak hours, o the length of any queuing back from the Zebra towards / across the roundabout
We suggest that the roundabout modelling includes the missing Zebra crossing or justification to exclude it. In the meantime, the RevTA has not adequately demonstrated the ability of this junction to accommodate the traffic flows arising from banned turns at the A319 High Street / Chertsey Road / B383 Windsor Road T-junction.
Benchmarking. Nil.
End of subsection.
4.7.10 (Performance modelling of site accesses & offsite junctions) A319 Chertsey Road / Delta Road junction.
Problem description. The junction performance modelling results in RevTA section 30 and appendix 30 are worthless, because the input data has not been measured at the A319 / Delta Road junction; it is taken from a different junction.
We suggest that the RevTA uses input information from the correct junction. In the meantime, the RevTA has not adequately demonstrated the ability of this junction to accommodate the traffic flows arising from banned turns at the A319 High Street / Chertsey Road / B383 Windsor Road T-junction.
Benchmarking. Nil.
End of subsection.
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4.7.11 (Performance modelling of site accesses & offsite junctions) A319 Chertsey Road / Philpot Lane T-junction.
Problem description: The RevTA section 14 and Appendix 14 PICADY modelling of all assessment scenarios still only considers two out of the three junction give way lines.
The modelling does consider both of the give ways at the A319 interface, but not the other give way on the western Philpot Lane junction arm. On this western junction arm, vehicles having turned right into Philpot Lane from the A319, then have to give way to vehicles that have turned left into Philpot Lane from the A319 who have priority. RevTA table 14.1 estimates that the development impact on this junction ranges from +15% to +34%.
Consequently, the RevTA has yet to demonstrate the full development traffic impact at this junction and we suggest that the performance of this junction be fully modelled.
Benchmarking: Nil.
End of subsection.
4.7.12 (Performance modelling of site accesses & offsite junctions) A3046 Station Road / Philpot Lane T-junction.
Problem description: With reference to RevTA section 15, again we question the validity of not modelling the performance of this junction and instead relying on whole junction percentage traffic impact criteria. We acknowledge that RevTA table 15.1 shows a maximum +5% overall development impact on the junction in 2025.
However, a review of the existing / proposed traffic flows in RevTA Appendices 7c / 8d show that during peak hours, the junction has a heavy right turn into Philpot Lane from the A3046 and a heavy left turn out of Philpot Lane onto the A3046. The peak hour left turns into Philpot Lane and right turns out of it are both very small numbers.
The Appendices 7 and 8 2025 assessment scenarios indicate that the development increases the peak-hour heavily used turns as follows:
• a.m. right-into Philpot Lane = +41 pcus (+13%), • a.m. left-out of Philpot Lane = +36 pcus (+32%), • p.m. right-into Philpot Lane = +36 pcus (+17%), • p.m. left-out of Philpot Lane = +36 pcus (+12%).
Percentage impacts of this magnitude on turning movements warrant further consideration, on this heavy loaded simple T-junction, which we understand has capacity and queuing problems in the network peak hours.
Again note that it has not been possible to fully review the peak hour performance of this junction,
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because the RevTA does not append the raw traffic survey information to illustrate existing traffic queues.
Consequently, the RevTA has yet to demonstrate the development traffic impact at this junction and we suggest that the performance of this junction be modelled.
Benchmarking. Nil.
End of subsection.
4.7.13 (Performance modelling of site accesses & offsite junctions) Six crossroads roundabout.
Problem description. Again, we question the RevTA decision to not model this junction in the future years assessment scenarios, based on the whole junction percentage traffic impacts listed in table 18.1, because:
• these tabulated numbers are based on unsupported traffic generation and distribution information, as listed above, • the TA for the McLarens development (planning application PLAN/2014/1297) found that this roundabout was currently [1]over capacity on some arms in the peak hours and that for a modest development impact of [2]under 2%, the TA included [3]capacity improvements as development mitigation, [1] ref. PLAN/2014/1297 TA table 6.5, [2] ref. PLAN/2014/1297 TA table 6.4, [3] ref. PLAN/2014/1297 TA figure 7.17 / appendix E, • the A320 Corridor Study similarly found roundabout capacity problems and suggested a large scale roundabout improvement, and • the introduction of [4]pedestrian / cycle crossing(s) over the roundabout arm(s) to enable Fairoaks development walkers and cyclists to safely negotiate the junction will affect the roundabout capacity. [4] cross reference to section 4.1.1 ‘Sustainable transport infrastructure - Walking & cycling’ above.
Benchmarking. Nil.
End of subsection.
4.7.14 (Performance modelling of site accesses & offsite junctions) A320 Chertsey Road / Martyrs Lane / McLaren roundabout.
Problem description. Again, we query why there are significant differences in the roundabout performance between the Fairoaks development (Rev)TA and a TA for application PLAN/2014/1297 for a development by McLaren.
In the Fairoaks RevTA tables 19.3-19.6 show the McLarens development arm operates well within capacity. However, McLaren TA table 6.5 shows the McLaren arm at / over capacity. Consequently, we query the application of committed development traffic to the modelling of this junction in the Fairoaks 25
RevTA.
And, we understand that this roundabout also experiences traffic congestion during weekday early afternoons. This congestion is associated with a staff shift change at the adjacent McLaren site, during which vehicles attempting to enter that site are delayed and tail back onto the adjacent roads. We therefore suggest that the TA also considers/models the capacity of the roundabout during these early weekday afternoon periods.
In the meantime, we suggest that the RevTA has not yet adequately demonstrated the development traffic impact at this junction.
Benchmarking. Nil.
End of subsection.
4.7.15 (Performance modelling of site accesses & offsite junctions) A245 Woodham Lane / Martyrs Lane T-junction.
Problem description. With reference to RevTA section 32, again we question the validity of not modelling the performance of this junction and instead relying on whole junction percentage traffic impact criteria. We acknowledge that RevTA table 32.1 shows a maximum +1% overall development impact on the junction.
However, a review of the existing / proposed traffic flows in RevTA Appendices 7c and 8d shows that during peak hours, the junction has a heavy right turn into Martyrs Lane from the A245 and a heavy left turn out of Martyrs Lane onto the A245.
The Appendices 7 and 8 2030 assessment scenarios indicate that the development increases the peak-hour heavily used turns as follows:
• a.m. right-into Martyrs Lane = +39 pcus (+10%), • a.m. left-out of Martyrs Lane = +34 pcus (+12%), • p.m. right-into Martyrs Lane = +27 pcus (+8%), • p.m. left-out of Martyrs Lane = +127 pcus (+50%).
Percentage impacts of this magnitude on peak hour turning movements at a simple priority T-junction warrant further consideration.
Note that it has not been possible to fully review the peak hour performance of this junction, because the RevTA does not append the raw traffic survey information to illustrate existing traffic queues.
Consequently, the RevTA has yet to demonstrate the development traffic impact at this junction and we suggest that the performance of this junction be modelled.
Benchmarking. Nil.
End of subsection.
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4.7.16 (Performance modelling of site accesses & offsite junctions) A320 / A319 / B3121 Murray Road (Ottershaw) roundabout.
Problem description. We have (re)identified that the junction performance modelling of the proposed roundabout alteration scheme, in RevTA section 20 and RevTA appendix 20, does not include the following features, which have the potential to render the modelling results unreliable:
• The existing signal controlled Puffin pedestrian crossing on the roundabout A320 south arm is omitted. Note that ARCADY includes the facility to include pedestrian crossings on the roundabout arms. When this Puffin is called, it has the potential to cause queuing back towards and across the roundabout, affecting the roundabout capacity / performance. Again we question the unexplained reasoning behind SCC’s audit of the junction modelling ignoring this issue without proper consideration, which could include: o on the ground observation of the operation of the Puffin during peak traffic hours, o survey data about how often the Puffin crossing is called during peak hours, o the length of queuing back from the Puffin towards the roundabout.
• The simple priority T-junction of the A319 Chobham Road / Foxhills Road, which is located very close to the roundabout is not included. The right turn from the A319 into Foxhills Road can cause queuing back onto the roundabout, affecting the roundabout capacity / performance. Capacity improvement of the A319 roundabout arm might affect vehicle queuing and delay for vehicles emerging from Foxhills Road and extend junction queues on Foxhills Road.
• The merge of the proposed A319 northbound express lane onto the A320 northern arm, which is a priority junction is not considered. If there is delay for vehicles merging onto the A320 that tails back onto the A319 roundabout arm, this could affect the roundabout capacity / performance.
• We suggest that the introduction of a signal controlled pedestrian / cyclist crossing over the A319 roundabout arm – as per F2020’s previous reports and as set out below about the SCC RSA report for this roundabout – has the potential to affect the roundabout capacity / performance.
Lastly, again we note that RevTA table 20.8 indicates that in the 2030 p.m. peak hour, the A320 northern arm is over capacity with a queue length of 128 vehicles, about 750m long (i.e. 128 vehicles at 6m/vehicle). Measured north back up the A320, this queuing tails back to the A320 Guildford Road / St. Peters Way roundabout and will affect the exit capacity of that signaled roundabout – see below.
Because of the above discrepancies, we suggest that the RevTA has not yet adequately demonstrated the proposed alteration to the Ottershaw roundabout adequately mitigates the traffic impact of the development.
Benchmarking. Nil.
End of subsection.
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4.7.17 (Performance modelling of site accesses & offsite junctions) A320 Guildford Road / St. Peters Way signalled roundabout.
Problem description. As set out above for the Ottershaw roundabout, the modelling performance results for the A320 northern arm shows queuing that tails back to this A320 Guildford Road / St. Peters Way roundabout and will affect its southbound exit capacity. This restricted southbound roundabout exit capacity will affect the roundabout throughput and renders the performance results listed in RevTA tables 22.2 to 22.6 unreliable. Hence and as above, we question the calibration of the RevTA roundabout performance modelling results against surveyed traffic information.
In addition we question the modelled junction queue lengths listed in RevTA section 22, which look rather too short to be realistic. Again note, we are restricted in our assessment of this matter, due to the RevTA not including the traffic survey queuing data.
Benchmarking. Nil.
End of subsection.
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4.8 Chobham village proposed right turn bans & diversion routes.
Problem description. 4.8.1 As set out in RevTA section 10.7, the proposed junction alterations rely on implementing right turn bans at the A319 High Street / Chertsey Road / Windsor Road T-junction. For the proposed right turning lane priority junction alteration, right turns out of the A319 Chertsey Road arm are banned for all vehicles. And for both proposed signaled alterations, right turns out of the A319 Chertsey Road arm are banned for all vehicles and right turns into A319 Chertsey Road arm are banned for HGVs only.
4.8.2 The RevTA suggests no formal diversion route, but indicates that the Delta Road - Burr Hill Lane - Windsor Court Road - Bowling Green Road could be used by diverted vehicles. Although we think that some drivers might use the Mincing Lane - Red Lion Road route.
4.8.3 F2020 has previously reported about the deficient assessment of this proposal and the problems it may cause. These points are carried forwards and summarised below.
Banned right turns. The RevTA has not adequately demonstrated the implications of banning right turns at the junction, nor demonstrated the feasibility of actually banning the turns, because:
• The number of vehicles affected daily by the banned turns is not known, because only peak hour traffic survey information is listed and no information about vehicle types affected – i.e. HGVs - is included,
• It gives no consideration of the effect of the banned turn on bus routes - we note that the 73 bus turns right into the A319 Chertsey Road,
• None of the designs of the proposed junction alterations includes physical measures to prevent vehicles turning right,
• It does not consider how the alternative route(s) might be signed in advance of vehicles arriving at this T-junction,
• Banned turn(s) will involve promoting a post planning traffic regulation order, which involves extensive consultation particularly including with the emergency services; the Police would enforce such banned turns. The RevTA and likewise the FOI information from SCC is silent about whether a consultation to establish basic feasibility has taken place and if so what feedback has been received.
Diversion / alternative route(s). The RevTA has not adequately demonstrated that acceptable diversion / alternative routes are available for vehicles banned from turning at the junction, because:
(a) Delta Road (DRd), Burr Hill Lane (BHLa), Windsor Court Road (WCRd), Bowling Green Road (BGRd). We suggest that the following characteristics of this route render it unsuitable as a permanent vehicle diversion route, between the A319 Chertsey Road and the B383 Windsor Road, associated with banning turn(s) at the A319 Chertsey Road - High Street / B383
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Windsor Road T-junction: (i) The DRd junction with the A319 does not appear to be suitable to accommodate the swept paths of turning HGVs. (ii) Sections of the route – for example through the bend in the vicinity of 16 BHLa – are too narrow for vehicles to reasonably pass each other, particularly for HGVs to pass other HGVs and other vehicles. The route is narrowed by sporadic on-street parking throughout, in keeping with the residential nature of these roads. (iii) The route is a minor residential street throughout. (iv) We question whether the existing road pavement construction of any of these is suitably robust enough to bear the axle loading of through routed HGVs without suffering damage.
(b) Mincing Lane (MLa) and Red Lion Road (RLRd). We suggest that the following characteristics of this route render it unsuitable as a permanent vehicle diversion route, between the A319 Chertsey Road and the B383 Windsor Road, associated with banning turn(s) at the A319 Chertsey Road - High Street / B383 Windsor Road T-junction: (i) MLa is too narrow on some sections for vehicles to reasonably pass each other, particularly for HGVs to pass other HGVs and other vehicles. The southern section features on-street parking, which also narrows parts of the route. (ii) The southern section of MLa is a minor residential street and the northern section is a minor rural lane. (iii) There is no footway on the northern section of MLa, which is also unlit. (iv) In places RLRd is mostly too narrow for HGVs to pass other and particularly for HGVs to pass other HGVs. The western section features on-street parking, which also narrows parts of the route. (v) The western section of RLRd is a minor residential road and the eastern section is a minor rural lane. (vi) There are no footways on RLRd, which is also mostly unlit. (vii) The RLRd junction with the B383 does not appear to be suitable to accommodate the swept paths of turning HGVs. (viii) We question whether the existing road pavement construction of both MLa and RLRd is suitably robust enough to bear the axle loading of through routed HGVs without suffering damage.
(c) Below we have included relevant exerts from SCC’s own “Freight Strategy”, which seeks to keep HGVs on main roads and away from unsuitable, minor and residential roads, such as those listed above. … “3.3 Problems and Challenges ... HGVs diverting onto vulnerable county lanes … can cause extensive damage to the roadside environment and result in large vehicles getting stuck in inaccessible places. … 3.4 Opportunities … This approach includes: … Within Surrey, as and when opportunities arise, the county council will continue to: … Ensure that freight issues are considered as part of … major planning applications. … 4.1 Aim and objectives ... The aim and objectives for the Freight Strategy are: …Aim: To assist in the effective transportation of goods whilst minimising the impact of large goods vehicles on Surrey’s environment and its residents. … Objectives: ... 2. To reduce the adverse impact of lorries on congestion, air quality and road safety in urban areas; and, 3. To reduce incidences of lorries diverting along unsuitable lower category roads when not being used for access.”
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Benchmarking. TD42/95, TD50/04, Surrey Transport Plan, 2011-2026 - Freight Strategy, April 2011.
End of section.
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4.9 Site Access & Offsite Highway Works Design / Road Safety Auditing.
Problem description. 4.9.1 The following text is from an email sent to SCC on 26Sep19 and lists the outstanding road safety problems, associated with the design of the site highway accesses and offsite highway works.
● A319 primary roundabout site access. ○ St1RSA not ordered and to my knowledge not yet done / outstanding. Please note the following text extract from SCC “Transport Development Planning Good Practice Guide” (Annex B Interim TA Guidance) >> “… Highway Safety … 38 ... Highway Alterations ... The council assesses significant highway alterations with road safety audits ...." ○ We have the further advice that on this matter, F2020 previously outlined that this access drawing does not show sufficient lead in information on the A319 approaches to the proposed roundabout to be able to adequately assess the proposed horizontal alignment of the A319 on the roundabout approaches.
● A319 (eastern) secondary site access - your ref. 51160H20. ○ Problems A1.1, A3.1 - The need for street lighting has not been confirmed by the designer and should be confirmed in principle. ○ We have the further advice: - TA Appendix 3g now includes vehicle swept path plots at this junction, which show left turns in and out by a refuse collection vehicle travelling into the right turn lane and over the junction centreline, creating potential for unsafe conflict with oncoming traffic. The junction radii are too small as previously reported by F2020. See the following underpinning text from TD42/95. "... Corner Radii 7.17 Where no provision is made for large goods vehicles, it is recommended that the minimum circular corner radius at simple junctions should be 6m in urban areas and 10m in rural areas. ..." - And the visibility splay y-distance is wrongly dimensioned at 140m; should be 160m for a 50mph speed limit A-road.
● A319 (western) employment site access - your ref. 51160H24. ○ Problem A3.1 - The roadside verge on the A319 south side has not been properly considered by the designer, particularly to the west of Young Stroat Lane, which is land outside the application site - hence the replacement roadside verge provision must be available within the highway boundary. Further related to this matter, F2020 previously queried if the A319 3m wide through lanes should be wider through the A319 curves - see text extract below - which might compound this problem by increasing the road widening on the A319 south side. "... both of the proposed 3m wide A319 through lanes at the junction appear to be narrower than the existing A319 lane widths and we query whether the 3m proposed width is wide enough to accommodate the swept path of HGVs through the bending A319 horizontal alignment at this location – should the through lanes include normal main road design ‘widening on bends’? ..." ○ We have the further advice: - TA Appendix 3j now includes vehicle swept path plots at this junction, which show left turns in and out by a refuse collection vehicle travelling into the right turn lane and over the junction centreline, creating potential for unsafe conflict with oncoming traffic. The
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junction radii are too small as previously reported by F2020 - See the following underpinning text from TD42/95. "... Corner Radii 7.17 ... Where provision is to be made for large goods vehicles, the recommended circular corner radius is: - ... b. 15m at rural simple junctions, with tapers of 1:10 over a distance of 25m. c. 15m at ghost island junctions, with tapers of 1:6 over a distance of 30m. 7.18 Where large goods vehicles comprise a significant proportion of the turning movements, use of the compound curve shown in Fig 7/3 is recommended. ..." And we question the sufficiency of using a refuse vehicle for this test, for an access that will serve large scale development - the application included for about 65,000 sqm of employment floorspace, featuring both industrial and warehousing from this junction. We suggest testing should be with large rigid and articulated hgvs. (Note that the swept path drawings for A320 site access and Ottershaw roundabout utilise a maximum length articulated hgv). - We query whether the RSA report should query about the need for street lighting, for the same reasons as per above RSA 51160H20 problems A1.1 and A3.1 above.
● New A320 signalled site access junction - your ref. 51160H26. ○ Problem A1.1 - the designer has not resolved the problem of grossly substandard forward visibility for A320 northbound vehicles. The access drawing notes a 110m splay, which mostly falls outside the bottom edge of the drawing and hence is unproven. We suggest that it is not likely to be possible for the developer to resolve this problem, because the land needed to provide the 50mph design 160m forward visibility splay entails land outside of the developer's control. F2020 previously snagged this in-principle problem last year. ○ Problem A3.4 - the designer has not resolved the problem and has now confirmed that A320 right turners can gap seek. TA Appendix 29a further includes LINSIG information showing the junction staging and modelling featuring gap seeking. On this point, TD50/04 paragraph 2.51 states - "... Where the 85th percentile approach speed is greater than 72kph (45mph) there is an increased risk of accidents between right-turning vehicles seeking gaps and on-coming vehicles travelling at speed. It is recommended in such situations that right-turns should be separately signalled ..." We further suggest that it is likely that removing gap seeking and changing to signalled control for A320 right turners (and also including the signalled side road pedestrian/cyclist crossing - see below) will materially reduce the junction capacity, which is already borderline overcapacity - cross reference with TA section 29 and TA Appendix 29a. ○ Problems A3.4, A3.5, A3.6 - the designer has not resolved the problem, because the Dunford House highway access remains as existing, from the A320. ○ Problem A4.5 - the designer has not resolved the problem, because the Woking Lodge highway access remains at its existing width. ○ Problem A5.2 - we suggest a closer review of the designer's response, because the 160m design forward visibility splay extends off the top of the access drawing. ○ Problem A4.3 - we note the designer's response to this problem, but the LINSIG information in TA Appendix 29a does not include positive signal control for the side road pedestrian/cyclist crossing in the junction modelling. We presume that the straight across / non-staggered crossing shown on the access drawing will entail an 'all red' stage, which will adversely affect junction capacity. ○ We have the further advice: - The A320 5m wide northbound lane is too wide against TD 50/04 paragraph 2.22 advice that signal junction lanes should be between 3m and 3.65m.
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- We suggest querying the adequacy of the proposed A320 southbound right turning lane length - only up to 4 pcus capacity - to contain the right turners into the site, particularly when gap seeking is removed / positive control is included as per A3.4 above. - F2020 previously offered the following advice about the adverse effect of the A320 east side road widening on the visibility from private accesses on the east side, which still applies. "... The proposed carriageway widening on the east side of the A320 appears to substantially reduce the available visibility to southbound A320 traffic for vehicles emerging from the property accesses to both Old Farm (Stable Cottage) and the unnamed yard on the east side immediately north of that property..."
● A319 High Street / Vicarage Road mini roundabout - your ref. 51160H18. ○ Nil.
● A319 High Street / Windsor Road T-junction - your ref. 51160H19 ○ Problem A4.3 -the designer has no resolved about providing a signal controlled crossing on the Windsor Road junction side arm. And we note that the LINSIG information in TA Appendix 10h does not include an positively controlled pedestrian crossing, which we presume will entail an 'all red' stage, which will reduce the junction capacity. ○ Problem A5.1 - the junction alterations still features *banned turns both from and into A319 Chertsey Road and the designer has not resolved this problem. Furthermore, we suggest that the RSA report expand to consider the proposed diversion routes via Delta Road - Burr Hill Lane - Windsor Court Road - Bowling Green Road and Mincing Lane - Red Lion Road, both of which are unsuitable for hgvs. (*Banned turns will involve post planning Traffic Order(s) and F2020 has seen no evidence to indicate that the feasibility has been checked out by initial engagement with the emergency services and relevant others). ○ We have further advice: - We suggest that the revised TA submission should include design vehicle swept path information, showing that the proposed signal schemes can reasonably accommodate hgv turning movements; currently this information is not included. (TD50/04 paragraphs 2.34 to 2.39 underpin). - We suggest that the RSA report also considers the positions of the primary signals on both the north and east junction arms, to ensure that sufficient footway widths remain. - F2020 has previously identified that the High Street to Windsor Road northbound lane horizontal alignment is highly substandard, deflecting drivers sharply left then right past the three iterations of the central right turning lane. The northbound alignment for one of the signalled schemes is grossly substandard. The problematic deflections stem from non-compliance with junction design standards TD42/95 and TD50/04 for flaring to develop widening and extra lanes, as per the following text extracts. (for priority junction) "... TD42/95 paragraph 7.30 Central islands ... ghost islands (Fig 7/8) ... should normally be developed ... at the tapers shown in Table 7/3 (i.e. 1 in 20). (for signal junction) "... TD50/04 paragraph 2.26 On single carriageway roads, right turn entry lanes may be accommodated by the provision of a ghost island. The ghost island should be .... developed ... with a taper of 1 in 10, as indicated in Figure 2/10. ..." - the proposed A319 High Street right turning lanes are far too short. Not long enough to contain the estimated number of queued right turning vehicles listed in the revised TA. And for the altered priority junction, the lane design does not meet the recommended ‘35m plus queued vehicles’ right turning lane length set out in TD42/95 chapter 7 tables
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7/3 and 7/5, - the existing junction has a stop line, but the proposed improvement includes a give way line, and we query why the arrangement is changed.
● Ottershaw roundabout - your ref. 51160H21 ○ Problem A3.2 - The designer has not resolved this problem, because the visibility to the right for vehicles emerging from the Foxhills Road junction onto the A319 is worse than the existing situation. The visibility is substantially worse than existing for left turning emerging vehicles, which will likely occupy the left side of the bellmouth that is the most set back. The replacement 43m visibility splay y-distance shown on the design drawing is below standard. The 43m splay dimensions - from the Manual for Streets publication - are based on a 0.45g braking force intended for light vehicles that are insufficient for hgvs present on the A319. Finally, the revised TA includes no speed survey information to demonstrate the sufficiency of the reduced 43m sightline. ○ Problem A3.3 - We note the inclusion of a drawing showing hgv swept paths through the roundabout in the revised TA Appendix. However, we suggest that this information be expanded to include both rigid and articulated hgvs turning right from Murray Road into Brox Road and left out of Brox Road. Reason - as previously reported by F2020, freight haulier Hunts Transport has a large yard at 71 Brox Road and the revised road layout must accommodate their rigid and articulated hgvs. ○ Problem A4.5 - The designer has not fully addressed this problem, because the proposed footway/cycleway widths are still drawn narrow at 2m. ○ We have the further advice: - As previously reported by F2020 for the original roundabout design and likewise the revision, the sightline to the right is greatly reduced for vehicles emerging from the village car park. The sightline y-distance reduces by about 20m to about 35m. The x-distance is also reduced to about 2m by the widening of Murray Road on the north side. The reduced sightline is well below design standard. The revised TA includes no information to justify the reduced sightline. - Also as previously reported by F2020 for the original roundabout design, there is an existing highway access to the premises Anvil Autos located on the apex between the A320 and A319, which currently accesses onto the roundabout. The revised roundabout drawing does not illustrate this access and it appears to be infeasible to reasonably accommodate it within the revised design. Has denying access been agreed with these premises? - Again, as previously reported by F2020, we generally query why the designer has included uncontrolled pedestrian (cyclist) crossing points over the A320 and A319 roundabout arms. And particularly on the route of NCR226, which travels along the west side of the A320 and crosses the A319 roundabout arm. We note by reference to the DMRB standards quoted below that uncontrolled pedestrian / cyclist crossings are not recommended for roundabouts with this level of traffic flow. We acknowledge that the existing roundabout features uncontrolled crossing points. However, we suggest that the introduction of the extra development traffic and roundabout redesign should prompt the designer to consider the use of improved crossing points over the A-road roundabout arms. We also note that the A320 Corridor Study included a signal controlled crossing over the A319 arm in the roundabout redesign. TD16/07 section 6 >> ‘… for roundabouts with speeds limits 40mph+ and high traffic volumes (i.e. as at the Ottershaw roundabout) provide signal controlled pedestrian/cyclist crossings.’
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DfT IAN195/16 paragraphs 2.4.2, 2.63, 2.65 >> ‘(as TD16/07 above) or provide grade separated pedestrian/cyclist crossings’.
Benchmarking. SCC RSA reports, TD42/95, TD50/04, TD16/07.
End of section.
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4.10 Motorway Junctions – M25 J11 & M3 J3.
Problem Description. F2020 understands from information by the developer's transport consultant that the proposals at the two motorway junctions - M25 J11 and M3 J3 - have not previously been presented to HE. The current application timetable lists a mid January to early February 2020 planning decision date by both Runnymede and Surrey Heath Borough Councils. F2020 is concerned whether it is likely to be feasible for HE to review and approve the proposed motorway junctions works, within this timetable.
In the meantime F2020 has identified the following problems with the proposed designs at the motorway junctions.
M25 J11 proposed scheme drawing (RevTA section 23 & RevTA Appendix 23b drawing). • There is no traffic island on which to site the nearside signal pole/head at the proposed new/extra signalled stop line, between the A320 express lane towards the M25 northbound on- ramp lane and the A320 eastbound roundabout approach.
• The development of the new right turn lane on the M25 southbound off-ramp looks very short / abrupt (for example by comparison with the flare length for the development of the existing A320 express lane towards the M25 northbound on-ramp lane).
• No mitigation works implementation trigger / timetable for included. (ref. RevTA para. 23.7.4)
M3 J3 proposed scheme drawing (RevTA section 25 & RevTA Appendix 25b drawing). • The flaring to develop both of the additional two lanes on the northwest bound A322 approach to the roundabout is very short. Also here, I suggest that the approach alignment of the new right hand lane is rather 'square on' to the roundabout circulatory carriageway.
• The development of the new left turn lane on the M3 eastbound off-ramp looks very short / abrupt.
• I query the (re)establishment of the second circulatory lane on the north side of the roundabout - between the M25 eastbound off-ramp and the M3 eastbound on-ramp - because upstream both the roundabout circulatory carriageway and the M3 eastbound off-ramp only direct one traffic lane into this section; currently this area of circulatory carriageway is white line hatched out.
• No mitigation works implementation trigger / timetable is included. (ref. RevTA para. 25.7.5).
And lastly concerning motorway junctions, our review has identified that another major development - application (SH)12/0546 for major development at Princess Barracks in Deepcut - included junction alteration works at M3 junction 3. We question if there is an overlap / clash between the Deepcut development junction 3 works and those now proposed by the Fairoaks developer. The RevTA / HE should consider and clarify this point.
Benchmarking. Various.
End of section.
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4.11 Highway works implementation timetable / triggers
Problem description. The timetable / implementation triggers for the various highway access, offsite junction alteration and other works, as set out in the application documents including the RevTA and S106 HoT, are vague and uncertain. As currently written, the developer has failed to demonstrate that the necessary road transport works will be delivered in a timely manner to service the development. Benchmarking. Nil.
End of section.
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5.0 Framework Travel Plan (OAP18)
Problem description. As previously reported by F2020, the Framework Travel Plan (FTP) sets out a typical range of travel plan proposals to promote sustainable travel at the development site. Much of the text is the same as the RevTA and consequently the FTP has many the same problems as set out above in the commentary on the RevTA.
The key problem with the FTP is still the deficiency in the existing off-site road infrastructure, to support walking and cycling by development residents, occupiers and visitors. The RevTA still proposes nothing definite to address these deficiencies. F2020 thoroughly describes these problems in this and previous reports about the (Rev)TA.
The FTP will not be able to meet its stated objectives and targets without adequate non-car transport infrastructure to support its sustainable travel intentions. Again, we suggest that the FTP is largely ‘green wash’ to make the development appear more transport sustainable that it actually is.
Benchmarking. www.GOV.uk, 'Travel Plans, Transport Assessments and Statements' >> “…Travel Plans … set measures to promote and encourage sustainable travel (such as walking and cycling).” … “… The primary purpose of a Travel Plan is to identify opportunities for the effective promotion and delivery of sustainable transport initiatives e.g. walking, cycling, public transport …” … “… They support national policy which sets out that planning should actively manage patterns of growth in order to make the fullest possible use of public transport, walking and cycling …”
End of section.
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6.0 Draft Section 106 Agreement Heads of Terms (S106 Hot).
Problem Description. The following comments concern the road transport related inclusions in the application S106 Hot. The paragraph numbering below is as per the S106 Hot document itself.
• 1.2 (Parties) We note that HE is not included as a S106 party, for example, concerning the proposed highway works at M25 junction 11 and M3 junction 3; also see 2.5.#, 3.# and 4.10 below.
• 2.5.# (Borough / County obligations) Carrying on from 1.2 above, we note again that HE is not included.
• 3.# (Enforcing planning obligations) Carrying on from 1.2 and 2.5.# above, we note again that HE is not included.
• 4.4.2 (Financial Contributions) The text does not state the sum of any transport contribution to be provided, nor who should pay or receive it.
• 4.9.1 (Travel) The text is vague and incomplete concerning the proposed travel proposals, for example stating nothing about - the Travel Plan, a scheduled bus service, other bus infrastructure, ‘maas’ (mobility as a service)....
• 4.10.1 (Highways) The text inclusions in this paragraph are extremely vague, for example, not listing what junctions are included, not describing the works, not stating triggers / delivery timetable.... Also it is cumbersome and unnecessary to include about post-planning highway agreements in the S106, because instead and by reference to the *NPPF, planning conditions should be utilised to secure the development highway works.
*NPPF paragraph 54 states "... Planning obligations should only be used where it is not possible to address unacceptable impacts through planning conditions ..."
• 4.10.2 (Highways) As above, the text inclusions about the proposed Link Road from the Site to the A320 Chertsey Road are extremely vague, for example, not listing about triggers / delivery timetable and generally not reflecting the corresponding statements in the RevTA or PS. As above and again reflecting NPPF paragraph 54, planning condition(s) should be used instead.
Benchmarking. NPPF.
End of section.
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7.0 Very Special Circumstances Addendum.
Problem Summary. The development brings about no transport-related VSC. The proposed A319 to A320 link road amounts at best to necessary road transport infrastructure to service the development and is not a VSC. And the statements in the original Green Belt Assessment & Very Special Circumstances’ report (OAP10) about other development road transport features – off-site junction works and sustainable transport measures – represent proposals to attempt to comply with transport policy, which again are not VSC. F02020 considers that there are no transport VSC.
Problem description. 7.1 Paragraphs 2.24 to 2.27 of this addendum include claims that the improved permeability of the existing road network brought about by the proposed A319 to A320 link road is a VSC. However, as previously reported by F2020 concerning the original Green Belt Assessment & Very Special Circumstances’ report (OAP10), any benefits are based on unproven and highly subjective assumptions about driver (re)routing. Also, any benefits may well be offset by the disadvantage to the road network associated with the traffic generation of the development.
These paragraphs also suggest that the inclusion of pedestrian / cyclist facilities on the link road, connecting to the existing facilities at the A320 end, and its earlier construction date, also amount to VSC. This is grossly overstated, because planning policy requires that development provide suitable non-car accessibility and related infrastructure to meet the need of development residents, occupiers and visitors. The link road is necessary for this latter purpose alone and is consequently not a VSC.
7.2 And lastly as reported by F2020 about the originally submitted Green Belt Assessment & Very Special Circumstances’ report (OAP10):
• (paragraph 5.97) the proposed offsite junction alterations represent limitation of the development traffic impacts only,
• (paragraphs 5.94 and 5.96, 6.170, 6.172, 6.178) the proposed inclusion of non-car travel measures – buses, travel plan, etc. - is no more than is normally necessary to help development meet the thrust of sustainable transport policy, and
• (paragraph 6.175) there are still no proposed improvements to offsite pedestrian and cyclist infrastructure.
7.3 Consequently, F2020 considers that there are no transport-related VSC.
Benchmarking. Nil.
End of section.
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8.0 Suggested road transport refusal reasons.
In view of the unresolved transport matters that F2020 has described in this and previous reports and the substantial time that has elapsed since the application registration, we suggest that the local planning authorities now refuse the application. Notwithstanding F2020’s other objections to the development, we suggest the following transport refusal reasons.
Transport refusal reason 1. It has not been demonstrated that the development can be provided with sufficient non-vehicle transport infrastructure to reasonably meet and support the sustainable transport needs of the development residents, occupiers and visitors, contrary to the objectives of the planning policy listed below.
Transport refusal reason 2. It has not been demonstrated that: (a) the road transport impact caused by the development can be safely and reasonably accommodated on the local and strategic road network, (b) the significant road transport impacts caused by the development can be effectively mitigated to an acceptable degree, and (c) the road transport impact caused by the development will not result in a severe road transport impact, contrary to the objectives of the planning policy listed below.
Applicable planning policy. • National Planning Policy Framework, • Surrey Heath policies CM11, DM11, (saved policy) M21(j). • Runnymede policies (saved policies) MV£, MV4, MV13, (draft policies) MV5, SD6.
End of section.
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Appendix 1.0
List of technical terms / abbreviations used
ANPR = automated number plate recognition. ARCADY = the Assessment of Roundabout Capacity and Delay software program, part of the Junctions software suite, by TRL. ATC = automated traffic counter. DfT = the Department for Transport. DMRB = the Design Manual for Roads & Bridges. ES = the application Environmental Statement. FOI = Freedom of Information (Act). FTP = the application Framework Travel Plan. ‘growthing’ = applying a growth factor to surveyed background road traffic flows, to make a future year traffic assessment scenario. HE = Highways England, the highway authority for motorways and trunk roads. HGV = heavy goods vehicle. IAN195/16 = Interim Advice Note no.195 of 2016 ‘Cycle Traffic and the Strategic Network’, part of the DMRB. LINSIG = a traffic signal modelling software program. LTN1/12 = Local Transport Note no. 1 of 2012 ‘Shared Routes for Pedestrians and Cyclists‘, by the DfT. MOVA = microprocessor optimised vehicle actuation, a traffic signal control system. NCR = National Cycle Route. NPPF = the National Planning Policy Framework. NPPG = the National Planning Policy Guidance. pcu = passenger car unit. PICADY = the Priority Interchange Capacity and Delay software program, part of the Junctions software suite, by TRL. PRC = the practical reserve capacity of a signal controlled junction. PS = the application Planning Statement. RevTA = the Sep19 revised application Transport Assessment. RFC = the ratio of flow to capacity of a priority junction. SVD = selective vehicle detection TA = the application Transport Assessment. TA50/04 = Technical Advice Note no. 50 of 2004 ‘The Geometric Layout of Signal Controlled Junctions and Signalised Roundabouts’, part of the DMRB. TA90/05 = Technical Advice Note no.90 of 2005 ‘The Geometric Design of Pedestrian, Cycle and Equestrian Routes‘, part of DMRB. TD16/07 = Technical Directive no. 16 of 2007 ‘Geometric Design of Roundabouts’, part of the DMRB. TD42/95 = Technical Directive no. 42 of 1995 ‘Geometric Design of Major/Minor Priority Junctions’, part of the DMRB. TEMPRO = the Trip End Model Presentation Program. TRICS = the Trip Rate Information Computer System. VSC = (green belt) very special circumstances.
End of report.
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