FARNHAM TOWN COUNCIL D Annex I Responses to the Pre-Submission Waverley Local Plan Part 1: Strategic Policies and Sites Farnham Town Council is pleased to see progress on the Waverley Local Plan and welcomes the step change it represents in the planning of the Borough and of Farnham being genuinely plan-led and moving away from the current appeal-led system. The Council recognises the significant endeavour on behalf of the Borough to produce the Plan and welcomes the supportive and collaborative approach that has been taken. The Local Plan has been developed alongside Farnham Town Council’s Neighbourhood Plan and shows significant synergy. The Town Council recognises the strategic significance of the Local Plan and is supportive of key policies such as the use of Dunsfold Park as a large strategic mixed-use site. The Town Council also welcomes the positive presumption within the Local Plan in favour of sustainable development and acknowledgement of the potentially negative impact of planned land- use on public health and environmental matters such as congestion and air pollution. It is of critical importance though that the Local Plan is fully aligned with the Farnham Neighbourhood Plan, particularly given the extensive evidence base and consultation supporting the Neighbourhood Plan (noting that Farnham Town Council is still awaiting promised evidence regarding the effectiveness of SANGS). Because of the significance of the two plans Farnham has sought specialist technical advice to support its response to the Local Plan consultation. Having reviewed the Pre-Submission Waverley Local Plan Part 1: Strategic Policies and Sites and accompanying evidence, the following commentary sets out the support for and requests for modification of relevant policies and paragraphs in the order of the Local Plan. The Town Council’s requests for modification and proposed changes and for appearance at the oral part of the examination are as follows: Policy SP2: modification and appearance Paragraph 6.16: modification Policy ALH1: appearance Table 6.1: modification and appearance Policy ICS1: modification Policy EE1: modification Policy TCS1: modification Policy LRC1: modification Policy RE2: modification and appearance Policy RE3: modification and appearance Paragraphs 13.44 and 13.45: modification and appearance a Policy SS1: modification and appearance Policy SS2: modification and appearance Policy SS3: modification and appearance These are complex issues with potential significant impact on the Farnham Neighbourhood Plan and require participation of representatives of the Town Council. The detailed rationale and suggested modifications are set out further below along with details of areas that Farnham Town Council would specifically support. Policy SP2: Spatial Strategy The Policy is fundamental to the distribution of development within the Borough but can’t be considered sound until justified and consistent with national policy. In relation to consistency with national policy, criterion 1 refers to avoiding major development on land of the highest amenity value such as the Surrey Hills Area of Outstanding Natural Beauty. AONB’s are not designated for their amenity value but their landscape and scenic beauty. In order to be consistent with the NPPF, this criterion should be reworded. The NPPF also states that the planning system should contribute to and enhance the natural and local environment by protecting and enhancing valued landscapes (Para 109). In a Borough with a number of local landscape designations, a policy which seeks to direct development should also include reference to designated areas of local landscape value. In order to be the most appropriate strategy and consistent with the NPPF, criterion 1 should be reworded. There is an important omission from Policy SP2 in relation to the significance of the Thames Basin Heaths SPA and its impact on the spatial strategy. The NPPF recognises such areas of restraint and retained South East Plan Policy NRM6 states that priority should be given to directing development to those areas where potential adverse effects can be avoided without the need for mitigation measures. The reasoned justification (Para 6.13) correctly refers to a number of factors which influence the location (and timing) of new housing including Special Protection Areas. In order to comply with the national framework and the retained regional policy, it is imperative that a further criterion be added to Policy SP2. Finally, as currently worded the policy does not appear to be the most appropriate strategy. Dunsfold Aerodrome is as much of a focus for development as Farnham, Godalming, Haslemere and Cranleigh and is therefore more appropriately listed with these settlements rather than as an example of redevelopment of suitable brownfield sites under criterion 6. Change(s) considered necessary to make the Local Plan sound Reword Policy SP2 as follows: Policy SP2: Spatial Strategy To maintain Waverley’s character whilst ensuring that development needs are met in a sustainable manner, the Spatial Strategy to 2032 is to: 1. avoid major development on land of the highest amenity landscape value, such as the Surrey Hills Area of Outstanding Natural Beauty and other designated areas of local landscape value and to safeguard the Green Belt; b 2. direct development to those areas where potential adverse effects to the Thames Basin Heaths SPA can be avoided without the need for mitigation measures; 3. focus development at the four main settlements3 (Farnham, Godalming, Haslemere and Cranleigh) and Dunsfold Aerodrome which is identified as a new settlement… 6. maximise opportunities for the redevelopment of suitable brownfield sites for housing, business or mixed use, including at Dunsfold Aerodrome which is identified as a new settlement. More details are given in Policy SS7; Paragraph 6.16 The Town Council requests modification of Para 6.16 to enable it to be considered sound, justified and consistent with national policy. The paragraph does not refer to retained South East Plan Policy NRM6 which states that priority should be given to directing development to those areas where potential adverse effects can be avoided without the need for mitigation measures. In order to comply with the national framework and this policy, this paragraph must refer to retained South East Plan Policy NRM6 and its effect on the distribution of development. Change(s) considered necessary to make the Local Plan sound Reword Para 6.16 6.16 There is not enough suitable land for housing within existing settlements to meet the need for new homes in Waverley. Therefore, the Council’s strategy for housing delivery includes making selected releases of greenfield land around settlements to deliver around 2,300 dwellings. Most of this will be directed to Farnham and Cranleigh. Farnham is the largest of the main settlements but is close to the Thames Basin Heaths Special Protection Area (SPA). A key element of the Thames Basin Heaths Avoidance Strategy is to direct development to those areas where potential adverse effects can be avoided without the need for mitigation measures the provision of Suitable Alternative Natural Greenspace (SANG). Additional SANG capacity has been identified in order to deliver the new housing planned in the Farnham area. This issue is dealt with in Chapter 16. Support Policy ALH1: The Amount and Location of Housing Policy ALH1 is considered sound in respect of the amount of new housing planned for Farnham (2,330 dwellings). This is considered as the maximum deliverable number of dwellings during the Plan period given the limitations of the SPAs and available SANG; landscape and Green Belt designations; protection against the coalescence of the distinct individual areas of Farnham and traffic congestion and associated air pollution. This provides the synergy with the Farnham Neighbourhood Plan which the Town and Borough Councils have sought. c Table 6.1 – Potential Housing Land Supply (as at April 2016) Table 6.1 Row H sets out the amount of housing from suitable LAA sites, to deliver residue of 6,925 homes allocated to parishes in Policy ALH1. The source of this housing supply is the SHLAA, 2016 which details the various sources of supply that are expected to contribute to the delivery of the required housing. The SHLAA states (Para 1.2) that the LAA identifies a future supply of land which is suitable, available and achievable for housing and other uses over the plan period covered by the Local Plan and provides evidence to support Table 6.1. It is also intended to provide evidence for Part 2 of the Local Plan, which will allocate non strategic sites and for neighbourhood plans produced by town and parish councils in Waverley. It is recognised that the LAA does not in itself determine whether a site should be allocated for development, but the inclusion of sites as suitable within the LAA would appear to predetermine the principle of development either as an allocation of the site in a Local Plan Part 2 or in determining a planning application or appeal. The latter is of particular relevance in a borough where a 5 year housing land supply is disputed. The NPPG states that developers, landowners, promoters, local communities, businesses, town and parish councils and others should be involved in plan preparation, including evidence on land availability. The NPPF states that there should be early and meaningful engagement and collaboration with neighbourhoods so that Local Plans, as far as possible, reflect a collective vision and a set of agreed priorities for the sustainable development of the area, including those contained in any neighbourhood plans that have been made (Para 155). However, evidence and policies of the Farnham Neighbourhood Plan have not been taken account of as the LAA contains sites considered to be suitable by the Borough Council which the Neighbourhood Plan considers unsuitable. In the case of Farnham, Table 6.1 Row H is made up of sites which do not comply with the NPPF and/or the Neighbourhood Plan and for that reason are not suitable, available and achievable.