MF Letter to MVDC

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MF Letter to MVDC

  1. 1. 1 of 9 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
  2. 2. 2 of 9 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.
  3. 3. 3 of 9 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;
  4. 4. 4 of 9  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
  5. 5. 5 of 9 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
  6. 6. 6 of 9 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.
  7. 7. 7 of 9 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
  8. 8. 8 of 9 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.
  9. 9. 9 of 9 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-

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