Waverley Borough Council's Local Plan Part 2

Dear Members,

We hope you are keeping safe in these strange and worrying times. As previously mentioned, we have been busy reviewing WBCs Local Plan Part 2 (LPP2) which opened for consultation in November and closes 29th January. There is much in LPP2 to support; it retains the Haslemere Hillsides policy and seeks to protect heritage and non-heritage buildings, assets and landscapes.  

The below are areas of concern only, so may read negatively, however there are serious issues to bring to your attention and we strongly suggest members respond to the consultation directly. To this end, please feel free to cut/paste/use any of the text below that reflects your own concerns. You can also refer to the full HV response to WBC (http://haslemerevision.org.uk/wp-content/uploads/Haslemere-Vision-LPP2-Consultation-Response-.pdf) and should you wish to discuss or clarify any of the comments or recommendations, please do not hesitate to contact us at info@haslemerevision.org.uk. 

You can view the LPP2 document and respond to the consultation here:
https://waverley.inconsult.uk/consult.ti/LPP2/consultationHome. If you prefer to respond by letter or email, please include the LPP2 paragraph or policy number and send to planningpolicy@waverley.gov.uk or Planning Policy Team, WBC, The Burys, Godalming, GU7 1HR.

Settlement boundaries  (Policy DM13)

There is substantial community support in the Haslemere area, demonstrated by several public consultations, for redeveloping brownfield sites before greenfield and for building at medium to high densities to protect the environment and provide homes in sustainable locations, closer to amenities, so local businesses thrive and there is less need to travel. The Haslemere Neighbourhood Plan (HNP) has therefore set settlement boundaries that exclude areas important to wildlife, to landscape value and to leisure use and strongly recommends LPP2 adopt these thoroughly reviewed boundaries instead of imposing the ones set out in LPP2 Policy DM13. The areas of difference/objection are as follows:  

1. Despite record-breaking levels of local objection and representations from significant ecological and wildlife groups, the Red Court site (DS06) is included in LPP2 site allocations. It is situated in an Area of Great Landscape Value and is a candidate Area of Outstanding Natural Beauty (AONB) pending a decades-overdue review. There are sufficient brownfield sites to deliver housing in excess of the housing target without including this site (ref the Haslemere Plan Settlement boundaries and windfall topic paper) and its inclusion is in opposition to National and WBC policies. Strongly recommend removal from LPP2.  
2. The LPP2 boundary also includes two AONB sites on the northern edge of the Beacon Hill settlement. One spur forms part of the golf course and the other a piece of steeply wooded and habitat rich woodland. It is likely these have been included within LPP2 boundaries in error as no rationale for their removal from AONB is included within LPP2 or supporting documents.  
3. The settlement boundary (and the Area of Strategic Visual importance – ASVI – on which it was based) along the western side of Weydown Road has been adjusted in LPP2 to exclude some gardens but not others. The garden boundaries do not form a neat boundary to the adjacent ancient woodland tracts and Site of Nature Conservation (SNCI). The 2002 Local Plan therefore choose a more or less straight course that respected the buffer needed by the SNCI, the woodland and the aquatic wildlife corridor that forms its heart. We recommend holding the 2002 line as the best and most diplomatic way to protect this green finger of land and the views down the valley from the Greensands Way which abuts it at its highest and northernmost point.

Site densities   

Taking a firm approach to building outside settlement boundaries (Policy DM13 and supported by the HNP) means sites within must make the best possible use of scarce land. The HNP sets out appropriate densities within settlements to achieve this. While there may be constraints (primarily sloping sites, drainage and parking) that reduce yield, the policy must always be to explore options such as adding more storeys than traditionally accepted or including underground parking. This is to ensure the future is not sacrificed to please the present.   

Brownfield sites in central village/town locations, such as DS10 which proposes a very low density of 12dph (dwellings per hectare) and DS04 at 40dph (where 75dph would suit its central location and fit with nearby higher density developments) should therefore be examined very carefully to see if they are following this principle. In the case of DS10, many of the surrounding houses have been converted to apartment blocks and are therefore much higher density than they appear.   

In light of the above, and as it has not proved accurate for 3 of the 4 major settlements in the borough, the methodology used in LPP1 to calculate windfall numbers requires review. Continuing to pursue this methodology allows unsuitable greenfield sites to be put forward without proper consideration of alternative higher density strategies by developers.

Ecological Networks  (Policies DM1 and DM11)

Many sites allocated in LPP1&2 are on previously greenfield land. Whilst housing priorities are clearly understood we should also look to see land inappropriate for development being given back to wildlife. Selective re-wilding is the term being used by the National Trust.   

Policy DM1 (Environmental implications of development) is welcome but disappointingly limited to “Avoid negative impacts upon biodiversity and maximise opportunities to deliver net gain in relation to ecological and geological assets through the design, structure and landscaping of the development”.  It is not possible to develop land for housing and expect conditions for wildlife to be maintained without considerably raising standards. DM11 (Trees, Woodland, Hedgerows) is a step in the right direction but it lacks teeth and in practice is unlikely to have impact.  

The Haslemere Neighbourhood Plan sets a target for net biodiversity gain of 20% on development sites and has established the Haslemere Ecological Network which maps out key wildlife corridors. This exercise has provided the foundation to improve the network that enables movement between habitats. We would very much like to see LPP2 contribute more positively to ecological networks borough-wide through a similar exercise and through allocating land to replace habitats lost to development.

Individual site allocations 

There was a call for sites in July 2020 but no evidence of the outcome has been shared publicly or with Neighbourhood Planning group, which is an oversight. The comments below therefore only include concerns on sites included in LPP2 that have not already been raised above.  

DS01 – the Key Site at West Street has had its boundaries much extended and now includes Waitrose and the BT building (among others). It may be that plans for this site have been much discussed and extended, but the Neighbourhood Planning group are not aware of any such discussions.  

DS04 – there is an understanding that this site is to be developed for 100% affordable housing but this is not stated within the LPP2 draft. Clarification should be published and if it indeed intended for affordable housing then offering a percentage for self-build is potentially inappropriate (DM36) and may compromise feasibility as well as the number of units that the site could deliver.  

DS09 – abuts important habitats and wildlife corridors and proposes a density of 30dph. It is currently used for parking and where that parking will move to should be a consideration. If another area is to be hard landscaped then this is effectively a greenfield development outside the settlement boundary. In addition, whilst physically close to the settlement boundary, access is via a route a way out of town which makes it much less sustainable than it looks. Caution is required in developing this site and should have regard for the important habitats that surround it.

Thank you.