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Observations by Michael Flower, Lower Springfield Farmhouse, Westcott Street, RH4 3NY
To
Planning Office, Mole Valley District Council – 26th May 2011
On
PROPOSED DEVELOPMENT BY TAYLOR WIMPEY
MO/2011/0528
LOCAL PLAN POLICIES:
POLICY ENV4 - LANDSCAPE CHARACTER
The Council will seek to ensure that development proposals and forestry schemes in
the countryside and rural settlements conserve and will not detract from the character
of the local landscape. In determining planning applications account will be taken of
the visual impact of the proposed development on the landscape, the extent to which
the impact of new buildings has been softened and integrated into the landscape by
careful consideration of siting, design, colour and associated planting and whether
any existing landscape features such as trees and hedgerows should be retained.
This development is inappropriate and unsympathetic in size and scale. It takes
no account of its setting in either form or layout. It visually extends into the green
belt and the access drive is within the curtilage of a listed building.
The site coverage is virtually the same as a previous application MO/2010/ 0917,
set on just over 50% of the present field. This is a dense, suburban development not
in keeping with the adjacent open greenbelt land and countryside. It goes against
the Mole Valley District Council Core policy for villages in rural settings regarding
urbanisation and encroachment into the countryside.
For these reasons the proposed development, if permitted, would
be contrary to the provisions of this policy.
POLICY ENV8 - THE RIVER MOLE, THE TILLING BOURNE AND THE PIPP BROOK
Development which would have a significant or adverse effect on fisheries, the nature
conservation, landscape and recreational value of the River Mole, the Tilling Bourne,
the PippBrook and other areas of open water will not be permitted.
There are currently + - 400 species of birds, mammals and reptiles on the site,
some of which are protected at varying levels. There is plentiful bird life down on
the edges of the Pippbrook which will be affected by the development and this in
itself will affect the bio-diversity of the adjoining greenbelt land. The development
does not respect the village: does not respect the landscape and does not
respect the bio-diversity of the area. The applicant’s surveys are incomplete and
do not fully address the possible impact of such a large housing area and hard
landscaping on this wild-life and, therefore:
the proposed development, if permitted, would be contrary to the
provisions of this policy.
POLICY ENV13 - FEATURES OF LOCAL IMPORTANCE FOR NATURE CONSERVATION
The Council will seek to safeguard sites and features of nature conservation
importance that are not identified on the Proposals Map but which contribute to the
natural heritage of the District. The development of such features will not be permitted
unless either:
1. The development would not significantly and adversely affect the features or
2. The features will be protected from harm or transferred to another habitat or
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3. The importance of the development outweighs the nature conservation value of
the features.
The applicant’s surveys relating to the significant water natural water feature of the
Pippbrook and more specifically the interruption of surface and subterranean
water flow into this waterway is incomplete and, therefore:
the proposed development, if permitted, would be contrary to the
provisions of this policy.
POLICY ENV15 - SPECIES PROTECTION
Where it is evident that a proposed development would be likely to result in harm to a
protected species or its habitat, a thorough site investigation will be necessary by the
applicant and the relevant nature conservation bodies will be consulted.
Development that would materially harm a protected species or its habitat will not be
permitted.
The applicant’s surveys are incomplete and do not fully address the possible
impact of such a large housing area and hard landscaping and importantly night
light levels specifically on the Bat and Badger colonies and, therefore:.
the proposed development, if permitted, would be contrary to the
provisions of this policy.
POLICY ENV22 - GENERAL DEVELOPMENT CONTROL CRITERIA
Where the principle of proposed development accords with the other policies of this
Plan a design and layout will be required which:
1. is appropriate to the site in terms of its scale, form and appearance and external
building materials;
2. does not significantly harm the amenities of the occupiers of neighbouring
properties by reason of overlooking or its overshadowing or overpowering
effect, noise, traffic or other adverse environmental impact;
3. respects the character and appearance of the locality;
4. has regard to attractive features of the site such as trees, hedges, walls or
buildings that contribute to the character of the locality;
5. provides any necessary screening and landscaping suitable to the character of
the locality;
6. provides safe access to the site and adequate parking to adopted standards;
7. provides a satisfactory environment for occupiers of the new development.
The proposed ‘built’ and hard landscape area of this proposed development
covers the same as the previous application MO/2010/0917. The very large
‘executive’ homes with cars backing into a public right of way is completely
inappropriate. The access way through the cluster of farm buildings ( see more
comment below) is inappropriate and will cause significant harm to the amenity
and setting of the neighbouring properties and, therefore:
the proposed development, if permitted, would be contrary to the
provisions of this policy.
POLICY ENV23 - RESPECT FOR SETTING
Development will normally be permitted where it respects its setting taking account of
the following:
1. the scale, character, bulk, proportions and materials of the surrounding built
environment. Developments will not be permitted where it is considered they
would constitute over-development of the site by reason of scale, height or bulk
or in relation to the boundaries of the site and/or surrounding developments;
The original release of the site in 1982 recommended small 1 or 2 bedroom units .
This release was ratified through an enquiry in 2000 at which the release was not
supported by the local authority. The present submission by a national developer
completely disregards this recommendation and any housing needs of the village.
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Application is made for large ‘executive ‘homes that simply seek to maximise
profit. This pursuit is on record having been made by a representative of the
developer. The proposal is thus considered over development and, therefore:
the proposed development, if permitted, would be contrary to the
provisions of this policy.
POLICY ENV24 - DENSITY OF DEVELOPMENT AND THE SPACE ABOUT BUILDINGS
Development will not be permitted where it would result in a cramped appearance
having regard to the general space around buildings in the locality.
Having been advised that development would be inappropriate in the eastern
section of the site due to significant risk of flooding, the developers have cramped
the proposed ‘built’ section on the higher section and created, therefore, a more
obvious and obtrusive appearance and, therefore:
the proposed development, if permitted, would be contrary to the
provisions of this policy.
POLICY ENV57 - LIGHTING PROPOSALS
Proposals for the illumination of buildings, golf driving ranges, sports pitches, swimming
pools, tennis courts, sand schools, car parks and other facilities will not be permitted
where they would significantly and adversely affect the amenities of residential
properties, Conservation Areas or Listed Buildings, or the character and appearance of
the countryside.
The development proposed envisages a majority of larger homes which
inevitably will lead to a concentration of illumination and therefore light pollution
in what is presently an unlit area. This will have a detrimental effect on local wild-
life.
By necessity of vehicular access in front of the Grade II listed farmhouse and the
adjacent occupied farm buildings, there will be a significant loss of amenity to the
living conditions therein. Extended road lighting will also be detrimental and,
therefore:
the proposed development, if permitted, would be contrary to the
provisions of this policy.
POLICY ENV67 - GROUNDWATER QUALITY
Development will not be permitted which in the opinion of the Council, after
consultation with the Environment Agency, may have an adverse impact on the
quality of groundwater.
The water table is extremely high on the proposed development land, within
0.76M, and has springs. The development foundings and pollution by run off from
car forecourts will have significant adverse impact on the site run off and the
permeation into the Pippbrook and , therefore:
the proposed development, if permitted, would be contrary to the
provisions of this policy.
POLICY RUD4 - NEW HOUSING IN VILLAGES
Within the boundaries of the villages defined in Policies RUD1, RUD2 and RUD3, housing
development will be permitted only where:
1. it is at an appropriate scale in relation to the size and character of the village;
9 large executive homes are neither in keeping with the local environment nor do
they satisfy the original reservation of the land for ‘small dwellings’ and, therefore:
the proposed development, if permitted, would be contrary to the
provisions of this policy.
2. it takes account of the setting, form and layout of the village and in particular:
- is not a form of development which extends into the surrounding countryside;
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The setting of the proposed condensed form of development will have a significant
detrimental impact on the surrounding countryside. If it was not for the release of
the land as HSG6, resisted in 2000 by MVDC, any development on this meadow
would be regarded as extending in the countryside and, therefore:
the proposed development, if permitted, would be contrary to the
provisions of this policy.
3. it takes account of the historic character of the village, the local style of building
and is in accordance with Policies ENV39 and ENV40;
The proposed development seeks to maximise profit by introducing very large
modern ‘executive’ properties that will have a significant detrimental impact on
the historic character of the village and, therefore:
the proposed development, if permitted, would be contrary to the
provisions of this policy.
POLICY HSG6 - RESERVE HOUSING LAND
The District Council will continue to monitor housing land supply on an annual basis.
No evidence is shown that this review has taken place ?
Rear of Springfield Road, Westcott (2.2ha/5.4 acres)
There is no evidence that the other housing allocations have been developed in
sequence and , more importantly, occupied. This proposed development of a
majority of larger sized houses is at variance with the intentions of the original
release of this meadow for development with small 1 and 2 bed-roomed homes.
Until the sites are needed to meet possible longer-term development requirements,
they will be safeguarded from premature development.
The need for development of the type proposed is not substantiated and,
therefore:
the proposed development, if permitted, would be contrary to the
provisions of this policy.
POLICY MOV2 - THE MOVEMENT IMPLICATIONS OF DEVELOPMENT and ( PPG13)
Development will normally only be permitted where it can be demonstrated that it is or
can be made compatible with the transport infrastructure and the environmental
character in the area
The principal vehicular access to the site would be Westcott Street, running south
from the A25 to its multiple junction with Balchins Lane; Hole Hill; Riverbank;
Rokefield; the driveway to High Trees and the track running in between the listed
farmhouse and the cluster of adjacent farm buildings. Approximately 260
vehicles use Westcott Street, 96 in peak morning times ( 37%). This application
indicates the provision of 43 vehicles mostly for larger ‘executive’ style houses.
Surrey has the highest car user indicators in the UK. The likelihood of even 37%
additional vehicles at this time, within a saturated road system, would lead to a
significant increase in traffic, incompatible with the village infrastructure, and
therefore:
the proposed development, if permitted, would be contrary to the
provisions of this policy.
Due to the unacceptable increase in traffic that would result from this proposed
development, some vehicles attempting to avoid the congestion in Westcott
Street will divert to Balchins lane as a means of gaining access to the A25. The
Lane is even more restricted in width and visibility than Westcott Street and
particularly at the bend abutting Stowe Maries. There have been many minor,
and therefore unreported, incidents between vehicles at this point and it is most
hazardous for pedestrians , many of which have parked in Westcott Street or
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other local roads, to gain access to the footpaths leading up to the North Downs.
Safety along this byway would be further exacerbated and therefore:
the proposed development, if permitted, would be contrary to the
provisions of this policy.
The footpath leading from north east section of Westcott Street, through the farm
buildings and eastwards has now been fully registered as a right of way. The
intended development not only shows an un-ratified deviation of this new public
footpath but several of the larger houses have driveways shown which would
entail cars reversing across this shared surface. This proposal would lead to an
unnecessary and dangerous conflict with the existing and established walkway
and , therefore:
the proposed development, if permitted, would be contrary to the
provisions of this policy.
, having regard to all forms of traffic generated by that development. Where
appropriate developers will be expected to provide for, or contribute to,
transportation initiatives or highway works that should provide adequate capacity to
at least the end of the Plan period. In particular, proposals for major developments will
only be permitted where it can be demonstrated that in order to accommodate the
traffic generated by that development appropriate measures are made to obviate
the environmental impact, and there is appropriate provision for:
1. off-street vehicular parking, and
2. suitable servicing arrangements, and
3. vehicular access and egress and movement within the site
It is surprising that this application has been registered without details of the
access to the site and integration of traffic with the existing pedestrians and
horse-riders shown. This is fundamental to any consideration of possible
development. The drawing 8909.PL.021A suspiciously omits the most important
junction with Westcott Street and the way in which the increase in vehicles will be
integrated with the rural farm setting and the unallocated use of the existing
track. There will clearly be conflict between pedestrians and the vehicles
emanating from this proposed development and would lead to conditions
prejudicial to the safety of vulnerable users and therefore:
the proposed development, if permitted, would be contrary to the
provisions of this policy.
4. capacity on the transport network and in the vicinity of the development, and
The road infrastructure leading to this site is saturated and any increase other
than by natural evolution would be significant and unacceptable.
5. access and egress to be obtained, or improved, to and from the primary route
and distributor road networks,
Westcott Street is, for the most part, within a conservation area and nothing
should be done, simply to facilitate an increase in traffic, that would spoil this
setting.
6. public transport services,
The public transport facility for the village is derisory and most residents need to
resort to vehicular access to shops, offices, railway systems etc.
7. pedestrians and cyclists
The additional vehicles as a result of this proposed development would lead to a
significant increase in conditions prejudicial to the safety of vulnerable users.
8. people with disabilities.
Nothing is shown to remove the significant hazard for those approaching the
Doctor’s surgery in Riverbank which is at the junction with the section of Westcott
Street immediately adjacent the access to the proposed site.
Where a particular part of the highway network already endures high traffic flows
significantly above its operational and environmental capacity, then only small-scale
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development or redevelopment, which leads to little or no new traffic generation, will
be permitted
Clearly , Westcott Street and Balchins Lane cannot sustain the vehicular impact
of any significant further development such as that proposed.
The cumulative effects of existing and committed development on the operational
capacity and environmental character of congested areas as a whole will be taken
into account in the determination of development proposals. The provision of new
accesses onto principal traffic routes will not normally be permitted where access can
only be gained from those networks.
Westcott Street is already overloaded and congested and there is no facility for
new access points other than this existing roadway.
the proposed development, if permitted, would be contrary to the
provisions of this policy.
CORE STRATEGY POLICIES:
Policy CS 3 = Balancing Housing Provision
1. In seeking to provide a balanced housing market, the Council will require housing
proposals to take into account and reflect local housing needs in terms of the tenure,
size and type of dwellings.
Large ‘executive’ houses for occupiers from outside the village will strain all
existing access and service facilities and neither reflects the intentions of the
release of the reserved land nor the needs ( not yet established) of the village
and , therefore:
the proposed development, if permitted, would be contrary to the
provisions of this policy.
2. The Council will particularly seek the provision of two and three bedroom dwellings
suitable for occupation for all sectors of the community including newly forming
households, young couples and expanding families.
3. New housing for the elderly, and supported and specialist accommodation will be
encouraged in suitable locations.
4. The Council will encourage new dwellings to include “Lifetime Homes” principles
within their design so that they can be readily adapted to meet the needs of those with
disabilities and the elderly.
None of this is catered for in the proposals for this development and, therefore:
the proposed development, if permitted, would be contrary to the
provisions of this policy.
Policy CS 4 - The Provision of Affordable Housing
1. In order to increase the provision of affordable homes the Council will aim to secure
a minimum of 950 net affordable units within the District between the period 2006 and
2026 (contributing towards the sub-regional target of 40% of all new homes being
affordable).
2. In order to achieve this target the District Council will require where viable:
a. that on all housing developments of 1 to 9 gross dwellings, a financial contribution
equivalent to providing 20% of the total number of dwellings as affordable is made;
b. that on all housing developments of 10 to 14 gross dwellings, 30% of the total number
of dwellings are affordable;
30% of 14, being 4.2, is higher than that allocated on the proposed development.
The proposals fall short of this requirement and, therefore:
the proposed development, if permitted, would be contrary to the
provisions of this policy.
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Policy CS 13 = Landscape Character
1. All new development must respect and, where appropriate, enhance the character
and distinctiveness of the landscape character area in which it is proposed. Landscape
enhancement works may be required to avoid adverse impacts associated with new
developments.
2. The Surrey Hills Area of Outstanding Natural Beauty (AONB) is of national significance,
and as such,the conservation of the natural beauty of the landscape will be a priority in
this area. The AONB will be protected in accordance with the objectives in Planning
Policy Statement 7 (Sustainable Development in Rural Areas) and the Surrey Hills
Management Plan, with particular focus on the impact of development on ridgelines,
significant views, peace, tranquillity and levels of artificial light.
The impact of the proposed development in this location has been criticized by
all interested bodies relating to protection of the significant vista of and from the
north downs and, therefore:
the proposed development, if permitted, would be contrary to the
provisions of this policy.
Policy CS 14 = Townscape, Urban Design and the Historic Environment
1. All new development must respect and enhance the character of the area in which
it is proposed whilst making the best possible use of the land available. This will be
assisted through the work on Built-Up Area Character Appraisals.
2. The Council will resist development of a poor quality of design and will expect to see
sufficient detail set out in the Design and Access Statements, where required, to enable
planning applications to be properly determined.
3. Development must incorporate appropriate landscaping with particular attention to
the use of trees and hedges native to the locality.
4. Areas and sites of historic or architectural importance will be protected
Concern was raised by the Historic Buildings and Conservation officer of MVDC
regarding the access to the proposed development site through the cluster of
farm buildings within application MO/2010/0917. Nothing has changed. The
access is still scything through the curtilage of the Grade II listed farmhouse,
Lower Springfield farmhouse and the adjacent converted farm buildings. Taylor
Wimpey attempt to mitigate criticism by omitting any road or boundary features
along this existing track within their application. Clearly, if permitted, traffic
calming measures and containment will be necessary which would adversely
impact on the setting of this listed building, and thereefore:
the proposed development, if permitted, would be contrary to the
provisions of this policy.
and, where appropriate enhanced in accordance with the legislation, national and
regional guidance.
Planning Policy Statement No 5 – Determination of applications relating to Heritage
Assets
HE7.1 In decision-making local planning authorities should seek to identify and assess
the particular significance of any element of the historic environment that may be
affected by the relevant proposal (including by development affecting the setting of a
heritage asset) taking account of:
(i) evidence provided with the application
(ii) any designation records
(iii) the historic environment record and similar sources of information
(iv) the heritage assets themselves
(v) the outcome of the usual consultations with interested parties; and
(vi) where appropriate and when the need to understand the significance of the
heritage asset demands it, expert advice (from in-house experts, experts
available through agreement with other authorities, or consultants, and
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complemented as appropriate by advice from heritage amenity societies).
Again, concern was raised by the Historic Buildings and Conservation officer
during the last application that the proposed access would lead to a significant
increase in vehicular movements and associated disturbance between the
Grade II listed buildings and its former outbuildings. Since the last application,
specialist advice has been sought from one of the most eminent historic building
conservation engineers in the UK, Brian Morton, MBE,C.Eng FICE Dip Conservation
(AA) IHBC. His detailed report reference BAM/BEB/13353 is attached herewith. In
his view any increase in traffic immediately in front of this 477 year old property,
without foundations , would put its structural stability at significant risk possibly
leading to collapse and, therefore:
the proposed development, if permitted, would be contrary to the
provisions of this policy.
HE7.2 In considering the impact of a proposal on any heritage asset, local planning
authorities should take into account the particular nature of the significance of the
heritage asset and the value that it holds for this and future generations. This
understanding should be used by the local planning authority to avoid or minimise
conflict between the heritage asset’s conservation and any aspect of the proposal
The farm building cluster gives a meaningful architectural transition between the
varied housing of the village and the countryside. The listed farmhouse is one of
the oldest in Westcott and , given it’s exposed corner location, visible to all and
therefore:
the proposed development, if permitted, would be contrary to the
provisions of this policy.
HE9.2 Where the application will lead to substantial harm to or total loss of significance
local planning authorities should refuse consent........
Its possible isolation from the farm buildings opposite by an estate road leading
to the proposed development and , more alarmingly, its possible collapse or
destruction by the vibration by either construction traffic or continuous adjacent
vehicular traffic would be a significant loss of a heritage asset and , therefore:
the proposed development, if permitted, would be contrary to the
provisions of this policy.
Policy CS 18 = Transport Options and Accessibility
1. The availability of travel options and access will be given significant weight in
allocating land for development and in considering development proposals.
The development can presently only be accessed by way of the existing track
from Westcott Street and its isolation from significant public transport means an
intensity of the use of vehicles within, to and from the site. There is a lack of
variable access and, therefore
the proposed development, if permitted, would be contrary to the
provisions of this policy.
2. Transport schemes that lead to improvements in accessibility and give priority to the
needs of pedestrians, cyclists and users of public transport will be supported.
The proposals are completely at odds with the needs of pedestrians, cyclists and
users of public transport and, indeed, will be significantly prejudicial to the safety
of these vulnerable users and , therefore:
the proposed development, if permitted, would be contrary to the
provisions of this policy.
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Policy CS 20 = Flood Risk Management
1. The Council will determine planning applications in accordance with the guidance
contained within Planning Policy Statement 25 (Development and Flood Risk) and
policy NRM4 (Sustainable Flood Risk Management) in the South East Plan. The SFRA will
inform the application of the Sequential and Exceptional Test set out in Annex D of
PPS25.
The developer has not satisfied the Environmental Agency with full information
from adequate sequential and Exceptional testings.
the proposed development, if permitted, would be contrary to the
provisions of this policy.
2. The Council will not be seeking to allocate sites or permit applications for housing
within Flood Zones 3a or 3b as it considers, after undertaking the SFRA, that there is
sufficient land available to meet the requirements of the South East Plan outside of
these areas. Applications or allocations within Flood Zone 2 will only be considered if it
can be demonstrated that there are no suitable alternatives in areas at lower risk.
3. The Council will expect to see the use of appropriate sustainable drainage systems
(SUDS) as part of any development proposals. A Flood Risk Assessment will be required
for sites within or adjacent to areas at risk of surface water flooding as identified in the
SFRA. To further reduce the risk from surface water flooding all development should
work towards mimicking greenfield run-off situations.
The proposal development will penetrate the ground water levels at average
0.76M below ground level and, as yet undiscovered by the developers, the
natural springs in the area – Springfield Farm. This will not only have a
detrimental effect on the natural waterways of the site but will manifest in
localised flooding within the site.
Any reservoir intended for sustainable and managed drain off in this area will
soon fill and breach into overflows which, in turn will flow into the Pippbrook
causing contamination.
For these reasons the proposed development, if permitted, would
be contrary to the provisions of this policy.
-end-