! CRANLEIGH PARISH COUNCIL Draft Responses to the Pre-Submission Waverley Local Plan Part 1: Strategic Policies and Sites Cranleigh Parish Council is delighted to see progress on the Waverley Local Plan as it is considered that planning of the Borough and Cranleigh in particular should be genuinely plan-led so that it will be possible to move away from the current appeal-led system. 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 objections to, relevant policies and paragraphs in the order that they are presented in the Local Plan. The Parish Council arranged an open evening on 15 September 2016 in Cranleigh for residents to learn more about, and comment on, the Waverley Local Plan Part 1 pre-submission. Whilst residents are able to make their comments independently on the Local Plan, the Parish Council’s comments are informed by the comments made at the open evening (Appendix 3). Object to Para 3.2 Vision for Waverley in 2032; Local Plan Objective 2; Paragraph 5.15 and Policy SP2: Spatial Strategy Policy SP2: Spatial Strategy is fundamental to the distribution of development within the borough but is not considered sound as it is not justified. The policy is not justified as it is not based on up-to-date evidence and does not represent the most appropriate strategy in terms of the focus of development at Cranleigh. The Local Plan (Para 5.16) states that the approach to development within the villages is derived from a combination of factors, namely: • the Waverley Settlement Hierarchy; • the landscape and other constraints that apply; and • the potential availability of sites. The Waverley Settlement Hierarchy Factual Update 2012 has been used to determine the level of development at existing settlements. This draft hierarchy refers to (Para 1.5): • national and regional policy; • community facilities and services; • accessibility to higher order centres; • ability to accommodate new development whilst limiting the environmental impact. The evidence has not been updated to take the following into consideration: • services or employment opportunities; • the planning context set by the emerging Local Plan; and • the correct application of the criteria used. In terms of services, the absence of a state sector sixth form provision in Cranleigh is a major gap in the social infrastructure of the village. The nearest state sixth form college is at Godalming College some 9 miles away with poor public transport options available to students. The Sustainability Appraisal seeks to ensure access to education and skills development opportunities (Para 10.4) and this makes significant development at Cranleigh less sustainable than other settlements at the top of the hierarchy. In terms of employment opportunities, employment land is one of the determining criteria which allowed Cranleigh to be ranked alongside the larger settlements in the borough although it appears that this continues to be based on out of date and factually incorrect information. The Settlement Hierarchy Factual Update 2012 was based on the 2009 Employment Land Review (ELR) which is out of date for Local Plan purposes. The 2009 ELR stated that Cranleigh had 32.4ha of employment land (17% of total assessed land within the borough) and this has been confirmed by Waverley Planning Department as being the figure used as an evidence base for the analysis in the Local Plan. This relied on a number of sites with poor prospects for employment; sites such as Swallow Tiles (0.9ha) (now redeveloped for housing), Cranleigh Brickworks (20ha) (full planning application for residential use approved and under development) and Hewitt’s Industrial Estate (3 ha) (subject to an appeal for residential use October 12th 2016); all of which may be viewed as no longer available as viable areas for employment. Please see Appendix 1 for background information. These areas were still included in the ELR review of August 2014, together with other employment locations which have been put forward in the Cranleigh Neighbourhood Plan “Call for Sites” for potential housing development, some of which are no longer at full capacity. It would appear that far more employment opportunities and employment sites are being reported than actually exist. The Sustainability Appraisal states that there is a need to deliver housing in proximity to employment growth areas and avoid traffic congestion (Para. 10.5.1). Taking into account a more accurate and up-to-date amount of employment land in Cranleigh (Appendix 1) this should be reported as approximately 7ha out of a total for the borough of 206ha, which is 3.4% of the borough’s total employment land should Hewitt’s Industrial Estate be allowed on appeal in October 2016 and 4.9% should this application be refused. The decline in employment opportunities in Cranleigh makes the proposed quantum of housing development unsustainable and inappropriate for the village. In terms of the planning context set by the emerging Local Plan with which the distribution of development must be consistent, the Settlement Hierarchy Factual Update 2012 states that Cranleigh has no Green Belt or AONB constraints. In fact the Borough Council’s own Green Belt Review, 2014, confirms that land to the north and west of Cranleigh continues to perform Green Belt functions. It also recommends that further land between Cranleigh and the existing Green Belt land be designated as Green Belt and the Pre-Submission Waverley Local Plan Part 1: Strategic Policies and Sites itself now proposes that further Green Belt be designated to the north of the village. Similarly, the Surrey Hills AONB extends to the north and west of the village and the context of the AONB and its setting should not be ignored as currently in the settlement hierarchy analysis. The Sustainability Appraisal states that the preferred distribution strategy would have limited impacts on conserving and enhancing distinctive landscapes provided sites were selected in line with the findings of the Waverley Landscape Study (2014) (Para 10.8.1). As some of the sites in Cranleigh are located in landscape of high value and sensitivity this is not the case and the proposed level of development is unsustainable and inappropriate. Criteria taken into account in determining the settlement hierarchy (and therefore the distribution of development) have not been correctly applied. Two of the criteria referred to as helping to determine the hierarchy of settlements are the size and form of a settlement. In relation to population, even though the 2001 Census is used, it is clear that Cranleigh (excluding Rowly) with a population of 10,606 (now approximately 11,400) is of a completely different size to Farnham (population 37,055) and Godalming (population 21,103). Nevertheless, the Local Plan groups the much smaller sized settlement of Cranleigh with Farnham and Godalming at the top of the hierarchy. In relation to form, the Waverley Settlement Hierarchy Factual Update 2012 states that a village which has a linear form with little depth beyond the road frontage is unlikely to be suitable for any development other than infilling of small gaps in the built up frontage (Para 4.22) whereas a compact settlement of some size and depth extending beyond road frontages may be able to accommodate some level of further development without harming its character or the openness of the surrounding countryside. The settlement of Cranleigh encompasses both forms of development: the linear High Street to the Common with little built-depth beyond the road frontage representing the historic part of the village and the more compact form of the more modern estates dating from the 1960’s and 1970’s, to the east. The Parish Council concurs that the historic linear pattern of development is unlikely to be suitable for any significant development other than infilling of small gaps in the built-up frontage and this should put a restriction on development in this part of the village. A further criterion referred to as helping to determine the hierarchy of settlements is transport links. • Cranleigh is some nine miles from Guildford mainline station and is the only one of the defined ‘main settlements’ that has no train station. • The sustainability appraisal mentions that Cranleigh has a good bus service, and this is based on the village being served by 4 routes: 63, 53, 42 and 24. At no point is there one pick-up every 15 minutes. The 53 and 63 provide a half-hour service throughout most of the day, with the most direct links. The 24 and 42 are intermittent and infrequent, with one taking an hour to get to Guildford. The service stops at 22:45 with a reduced service on Sunday, with no service at all to Ewhurst. For an 11,000 plus community by any definition this is not a good service. • Most of the surrounding villages are reached via narrow, congested B roads and other poor quality and narrow lanes. The proposed 1,520 dwellings would lead to a further 2,400 cars on the road (applying the average 1.58 cars per dwelling (2011 Census in Surrey Waverley Borough). In particular, there is a need to commute to work, access a secondary school and other higher-order facilities - health, shopping and leisure. The quantum of housing development proposed at Cranleigh would not reduce the reliance on journeys by car (as sought by the Sustainability Appraisal Para 10.10). Transport links alone make Cranleigh far less sustainable than the other three settlements at the top of the hierarchy. In relation to other infrastructure provision, the Parish Council is extremely concerned about the adequacy of the sewage treatment works and water supply/quality (see comments on Policy ICS1: Infrastructure and Community Facilities).