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Response to GB Site Allocations Development Plan Document (DPD) Regulation 19 Representation Form 1. Personal details Sheila Carroll 2. Agent details n/a 3. Name of document: Site Allocations: Woking Borough Council (WBC) Site Allocations Development Plan Document (DPD) Regulation 19 Consultation 4. Do you consider the site allocations is: I do not believe the proposed plan is legally compliant or sound for reasons given below. 5. Please give details of why you consider the Site Allocations DPD is / is not legally compliant or is sound / unsound, or has met / not met the requirements of the Duty to Cooperate. Please be as precise as possible. Include any references to relevant legislation, policies and/or regulations. Not sound or legally compliant. For example: - HS4 Air: no consideration has been given to the most well known proposal from Heathrow Southern Railway Ltd which would link to the existing South West Mainline between Byfleet and Woking which goes through West Byfleet. WBC has failed completely to consider the potential compromising impact of its proposals in its assessments on this National Transport Infrastructure project. - Transport infrastructure linked to GB10 and GB11 both currently in the green belt- limited scope to introduce sustainable transport mitigation measures to address the traffic impacts of the development: anyone who lives in the local area will attest to the traffic problems on the A245 Parvis Road which passes through the heart of West Byfleet. This same road would see over 800 new homes built on the green belt that runs alongside (these would be in addition to the 255 new homes already agreed for the centre of West Byfleet). The West Byfleet Neighbourhood Development Plan 2017-27 adopted by WBC in 2017 refers to the existing traffic problems on the A245 and states that an earlier A245/A320 Multi Modal Traffic Study carried out by SCC concluded that the A245 was 'over-trafficked' and 'burdensome to local communities'. It also confirms that the Strategic Transport Assessment 2015 published by WBC addresses the impact of any proposed 'West Hall' housing development and shows that the levels used to categorise the performance and capacity of sections of a road, giving the desirable maximum congestion, would be exceeded on Parvis Road by housing development on the West Hall site. Surrey CC has acknowledged that the A245 is already an overloaded traffic corridor and the traffic impact of large scale housing development would worsen this existing situation. - Pollution assessments: inadequate. Given the issues mentioned re the transport infrastructure concerns around Parvis Road A245, it is important to note that the pollution sensors on this stretch of road showed the highest pollution readings in Woking. Increased traffic numbers will further impact on pollution levels. Not only has WBC failed to address the issues around pollution but it has also ignored that the A245 runs alongside the only park/ open recreation land in West Byfleet. - Education infrastructure in West Byfleet (linked to GB 10, GB11 and GB18): inadequate mitigation. It is unclear how any additional demand for new school places would be met with the proposal for over 800 new homes in GB10 and GB11 and the agreed plans for Sheer House Development in the centre of West Byfleet (with 255 homes planned) i.e over 1000 new homes/ households.With over 1000 new households being proposed in West Byfleet it is likely that demand for local school places would outstrip supply. According to Surrey Council’s School Places in 2018-2027, the West Byfleet Infant School has recently had to permanently increase its planned admission number from 60 to 90; followed by a similar increase in planned admissions at the West Byfleet junior school. Even if local school applications in 2019-2020 followed trends in other parts of the Borough and saw a small drop of 4.2% in admissions, the proposed overdevelopment would in all likelihood create significant additional demand. WBC’s Infrastructure Delivery Plans are inadequate. We know that WBC does not have the funds to build a new school; Surrey CC has stated that its own medium term budget plan “highlights the serious financial situation faced by the county council and the outlook for future years”; WBC Planners admitted (at a public meeting) that any CIL/ Section 106 funding from the proposed development is unlikely to be sufficient to fully fund/build a new school and so it appears to be the Council’s plan to rely on/draw on central Government funds to deliver essential infrastructure. The “where” is another issue. - Inadequate reasons for excluding Martyrs Lane greenbelt: frankly this is odd. This is a much larger area of land that already includes 3 sites that are almost unused, partly pre-developed and derelict. In 2012 planning permission was granted to McLarens for a 60,000 sq m factory facility on an area extending to over 22 hectares. The factory was cancelled but at the time there was no concerns about the development being a risk to unsightly merger of buildings or urban sprawl which would harm the greenbelt. This site should have been prioritised by WBC but instead WBC has overlooked it and instead sought to remove West Byfleet sites from the greenbelt and add to local traffic congestion and other infrastructure problems. - Inadequate reasons for excluding Pyrford Greenbelt: in the recent Greenbelt Review Report commissioned by WBC, Pyrford was identified as having good access to local communities and whilst some areas may be unsuitable for development, that same report noted sites with minor constraints that could accommodate development with design or mitigation. - Level of Development proposed for GB10 and GB11 alongside GB4 and GB5 is too high: in addition to the reasons given above, the amount of planned development will inevitably merge the villages of West Byfleet and Byfleet. They are distinctly separate villages, each with their own centres and communities. The Green Belt Review noted that GB10 (West Hall site) is particularly sensitive in landscape terms and if it was prioritised over other sites, it would need green infrastructure. - Removal of Greenbelt for West Byfleet Infant & Junior Schools including playing fields (GB18 Reg19): other than a requirement for WBC to create additional Suitable Access to Natural Green space (SANGs) there is no good reason to remove the schools and their playing fields from the greenbelt. The schools and playing fields should be retained in the greenbelt. National Planning Policy highlights the importance of promoting healthy and safe communities and only altering greenbelt boundaries where exceptional. No exceptional reason is given but instead assumptions are made about the level of development. And in looking at open space, it is important to note that WBC does not have a good record on open space in West Byfleet and has already admitted it is encouraging a pub chain to build on the West Byfleet recreation ground (which incidentally was gifted in perpetuity to the people in the parishes of West Byfleet and Byfleet). Under no definition is a pub a good use of open recreational space. 6. Please set out what modification(s) you consider necessary to make the Site Allocations DPD legally compliant and/or to strengthen its compliance; or to make the DPD sound and/or strengthen its soundness, having regard to the Matter(s) you have identified at 5 above where this relates to compliance or soundness. (NB. Please note that any non-compliance with the duty to co-operate is incapable of modification at examination). You will need to say why this modification will make the DPD legally compliant / strengthen its legal compliance; or make the DPD sound / strengthen its soundness. It will be helpful if you are able to put forward your suggested revised wording of any policy or text. Please be as precise as possible. Included in responses. 7. If your representation is seeking a modification, do you consider it necessary to participate at the oral part of the examination? No. 8. If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary: No. 9. Do you wish to be informed when the Site Allocations DPD progresses to the next stages? Yes. .
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