wa/2018/1239 erection of 262 dwellings (use class c3 ... a… · recommendation b that, in the...

WA/2018/1239Ashill Land Limited26/07/2018

Committee:Meeting Date:

Erection of 262 dwellings (Use Class C3) including 78 affordable dwellings together with a 131sqm building for community use (Use Class D1) and associated works including informal and formal open space, internal road network, landscape enhancement and access; following demolition of existing buildings (as amended by plans received 02/11/2018) at Ockford Wood Farm, No.19 and No.21 Aarons Hill at Land Between New Way And Aarons Hill, Godalming

Joint Planning Committee09/01/2019

Public Notice: Was Public Notice required and posted: YesGrid Reference: E: 495955 N: 143848

Town: GodalmingWard: Godalming Central and OckfordCase Officer: Rebecca ClarkeExpiry Date: Time Extended Date:

24/10/201811/01/2019

Neighbour Notification Expiry Date: 31/08/2018Neighbour Notification Amended Expiry Date:

19/11/2018

RECOMMENDATION A That, subject to the applicant entering into an appropriate legal agreement within 6 months of the date of the committee resolution to grant planning permission, to secure the provision of/contributions towards: 30% affordable housing and market housing mix, education infrastructure, SuDS management/maintenance, off site GP capacity, public open space and play space provision and maintenance, public access, off site highways improvements, travel plan, car club, leisure and green space areas, environmental enhancements, recycling facilities, Surrey Police recruitment and equipment, self build plots, and provision and maintenance of the SANG (as identified in the Appropriate Assessment); subject to conditions and informatives, permission be GRANTED.

RECOMMENDATION B That, in the event that the requirements of Recommendation A are not met, permission be REFUSED.

Site Description

The application site measures approximately 12.2 hectares and is located to the north of Aarons Hill and to the south of Halfway Lane. The site comprises an area of agricultural land. The western section of the site comprises an open field, whilst the eastern section is wooded in nature. The western section of the site is relatively flat, however land levels within the eastern section of the site are sloping.

The developed area of Godalming lies to the south of the site with residential development beyond. The area to the immediate north, west and east is largely undeveloped. However, there is sporadic development in the locality, notably that of ‘Fitzpatrick Referrals’ (veterinary specialist subject of ‘The Supervet’ television series) which borders the northern site line.

There are several public rights of way adjacent to, or in close proximity, to the application site. These include Bridleway No.6, which runs along the northern and eastern site boundaries, and Public Footpaths Nos. 577, 44 and 5 which run through the site, adjacent to the north east corner of the site and to the east of the site respectively.

Westbrook House (Grade II* Listed) and its associated gardens (Grade II Listed) are located to the north of the site. The house lies approximately 210m away from the northern corner of the application site. The Meath (Grade II Listed) lies approximately 370m away from the eastern boundary of the application site. There are a number of Listed Buildings set within Godalming Town Centre to the east of the site on the other side of railway line.

The railway line runs adjacent to the south eastern site boundary, beyond the Public Footpath. Green Oak Primary School lies to the south of the application site, on the opposite side of Eashing Lane, approximately 115m away from the proposed site entrance.

Location Plan

Aerial Photograph

Proposal

Full permission is sought for the erection of 262 dwellings (Use Class C3), including 78 affordable (30%) and a community building, following demolition of three existing dwellings. The community building would be located to the west of the site, adjacent to an area of open space and would have a gross external area of 131m2 and an internal floorspace of 88m2. Its intended use would be for Class D1 (non-residential institutions), which includes uses such as clinics, health centres, crèches, day nurseries, libraries, halls, museums, places of worship and non-residential education and training centres.

Of the three dwellings to be demolished, two of these would be at the entrance of the site (Nos. 19 and 21 Aarons Hill) and the other to the north of the site (Ockford Wood Farm). These dwellings are two storey privately owned dwellings, Ockford Wood Farm is a detached dwelling and Nos. 19 and 21 Aarons Hill are semi-detached dwellings.

Access to the site would be provided from Aarons Hill to the south of the site, following demolition of Nos 19 and 21 Aarons Hill. A new footway would be provided on both sides of the access point, which would tie in with existing pathways along Aarons Hill. The proposed access would provide for 2.4m x 43m visibility splays to the east and west and a 5.5m wide access arm, having regard to the 30mph speed limit of the road. The visibility splay to the west would extend across land falling within the ownership of the Council, and ensuring no obstruction to this visibility splay would be secured as part of a S106 Agreement should permission be granted.

The application proposes the following housing mix:

Market Affordable Rent

Shared Ownership

Total

1 bedroom flat 0 12 8 202 bedroom flat2 bedroom house

0 32

1512

100

2544

3 bedroom house 95 15 6 1164 bedroom house 51 0 0 515 bedroom house 6 0 0 6Total 184 54 24 262

Five flatted buildings would be located towards the southern section of the site. Each of these buildings would contain 9 units. There would be a mixture of detached, semi-detached and terraced dwellings across the remainder of the site. The majority of the dwellings would be two storeys in height, with the

exception of the flatted units which would be three storeys in height, and the ‘woodland’ dwellings which would be two storey to the front and three storey to the rear owing to the sloping land levels.

In total, there would be 21 different dwelling types, excluding flatted units. These would be set out over four different character areas within the site – ‘Field Edge’, ‘Mews Streets’, ‘Woodland Lanes’ and ‘Main Street’.

A total of 3% of the private plots proposed as part of the scheme would be provided as self build plots. This would amount to 6 units and they are proposed to be located in two areas towards the north of the site (see ‘Self Build section’ for proposed location plan).

A number of the dwellings would benefit from garages and there would be parking courts featuring pergolas to serve the flatted units. In total, there would be 585 allocated parking spaces and 13 unallocated spaces for visitors and the community building.

Cycle parking would be provided to serve the dwellings in either garden sheds or garages. The flatted units would have access to secure, sheltered cycle parking within the communal areas.

Each dwelling would be provided with waste and recycling bins and storage areas. The flatted units would be served by a communal bin storage area.

An area of open space would be provided in the eastern section of the site where the land level is naturally sloping. This area is referred to as the ‘Valley Park’. A pathway would be provided within this area of the site, which would connect the residential development with the Public Bridleway running along the eastern site boundary.

There would also be an area of open space to the west of the site within the ‘village green’, in which a proposed single storey community building (Use Class D1) and a Locally Equipped Area for Play (LEAP) would be located. A further five Local Areas for Play (LAP) are proposed within central areas of the site, and an informal ‘The Crows of Pearl Blossom Play Trail’ would run along the northern site boundary. A landscape buffer comprising the planting of new trees would be provided to the north and west of the site.

An area adjacent to the eastern open space and Public Bridleway 577 would be provided as community gardens.

Proposed Block Plan

J-1

H-2 AND I-2

H-1 AND I-1

F-1 AND G-1

F-2 AND G-2

C-4

2-1 and 1-1 and B- 1

1-2, 2-2, B-2 and P (with some slight window differences)

Heads of Terms

Section 278 highway works Construction of site access Construction of emergency access onto Halfway Lane Improvements to Public Bridleway No.6 and Public Footpath No.577 Improvement scheme at Eashing Lane junction with the A283

Highways: £922,236 to be broken down as follows: £6,150 towards Travel Plan auditing fee £30,000 towards Eashing Lane highway safety

improvements £20,000 towards Traffic Regulation Orders

(TROs) £18,000 towards Lower Eashing highway safety

improvements £9,600 towards surfacing improvements to

Public Bridleway No.6 £2,500 towards Westbrook Road safety

improvements £318,881 towards Godalming Sustainable

Transport improvements £517,105 towards A3100 Corridor improvements

Non-financial Submission of a Travel Plan Details of a Car Club

Travel Plan Provision of £100 voucher per dwelling for sustainable transport modes

Education: £174,320 – Early Years – towards the setting up of a new nursery in the local area.£939,306 – Secondary – towards a project at Broadwater School to provide additional capacity.

The Education Authority has not requested a contribution towards Primary Education. However, the Diocese of Guildford and The Good Shepherd Trust, with the County Council’s support, have requested a contribution of £864,452.00 towards:

Re-positioning and re-modelling of the main entrance to Green Oak CE Primary School

Internal changes to the layout of the teaching

and support areas of Green Oak CE Primary School

Leisure: £213,530 towards the refurbishment of Godalming Leisure Centre – involving an extension to gym, second studio and extended changing facilities.

Green Spaces/Playing pitches:

£307,850 towards a new skate/bike park facility including relocation of trim trail to assist in increasing the area of the facility; improvements to access and general greenspace at Aarons Hill Recreation Ground and Aarons Hill areas.

Recycling Containers:

£7,137.50 towards the provision of recycling containers to serve the residential units.

Environmental Enhancements

£200,000 towards Wiggins Yards improvements

Surrey Police £35,589.88 to be broken down as follows: £7,325.50 towards start-up equipment,

recruitment and training of an additional Officer in the Ockford Ridge, Aarons Hill, Busbridge & Godalming Town Centre SNT to deliver policing to the site and surrounding area.

£1,856.14 towards start-up equipment and recruitment of an additional Support Staff member to be based at Waverley Safer Neighbourhood Team (SNT) Office or Guildford Police Station.

£18,679.24 towards the cost of accommodating the additional Officer and Support Staff member.

£7,729 towards fleet investment to give 8-year life of provision.

Guildford and Waverley Clinical Commissioning Group (CCG)

£168,298.00 towards off-site development of GP capacity within Milford/Godalming.

Affordable Housing Provision of 30% affordable units on siteSelf build plots Provision of 3% self build plots on site. SuDS and open space

Provision and maintenance via a Management Company on site

Total £3,832,719.38

Details of Community Involvement by Applicant before and during submission

The applicant has provided details of the community consultation which took place prior to the submission of the application within a Statement of Community Involvement.

The proposal was presented to local Councillors on 26th March 2018 in a non-decision making, information gathering briefing.

A public exhibition took place on 11th May 2018 at St Mark’s Community Hall in Godalming. Invitation letters to circa 850 households were sent out in relation to this. Letters were also sent to local businesses; the invitation letter was publicised at Godalming & Villages Community Board and on a Facebook page for local residents. In addition, an article was published in the Surrey Advertiser informing its readers of the exhibition. The event was attended by 200 stakeholders.

A project website was set up, along with a dedicated email address to which to direct any queries about the proposal. Stakeholders were encouraged to provide feedback either via forms at the public exhibition or via the project website. A total of 55 feedback forms were received and verbal feedback was also collected from Councillors and members of local community groups. A range of comments were received. Overall, 52% of the comments either fully supported the proposal or supported it with some reservations.

Pre-application meetings were also held with Waverley Borough Council Planning Officers and Surrey County Council Highways. Additionally, an independent Design Review was undertaken by Design South East.

Relevant Planning History

Guildford Borough Council: 18/P/01958.

Land at Eashing Lane: Change of use from agricultural land to public open space and nature reserve with associated hard and soft landscaping, circular pedestrian walk, car parking and highways access to facilitate a Suitable Alternative Natural Greenspace (SANG).

Pending Decision

SO/2018/0007 Request for Screening Opinion for up to 270 dwellings.

EIA Not Required14/06/2018

Planning Policy Constraints

Green Belt – eastern wooded section of site onlyDeveloped area of Godalming – western section of site onlyArea of Great Landscape Value (AGLV) – eastern section of site onlyGodalming Hillsides – eastern section of site onlyAdjacent Ancient WoodlandAdjacent Area of Strategic Visual Importance (ASVI)Public Footpath – No. 577Adjacent Bridleway – No. 6AQMA Buffer Zone Wealden Heaths I SPA 5km Buffer ZoneTPO – group Ref: 650Section 106 Agreement – relates to Ockford Wood Farm (dwelling to be demolished within site) and permission WA/1996/0584 for an outbuilding within the grounds to remain ancillary to the occupation of the main dwelling. Neighbourhood Plan Designation

Development Plan Policies and Proposals

The Development Plan includes: Waverley Borough Local Plan, Part 1, Strategic Policies and Sites

(adopted February 2018) Waverley Borough Local Plan 2002 (retained policies February 2018) South East Plan (saved policy NMR6)

In accordance with paragraph 213 of the National Planning Policy Framework (NPPF) due weight has been given to relevant retained policies in the Waverley Borough Local Plan 2002. The weight is made clear in the appropriate paragraphs of the report.

The Godalming and Farncombe Neighbourhood Plan was formally submitted to the Council on 19 October 2018. A statutory six week consultation period was conducted from 19 October 2018 to 30 November 2018. As such, the Neighbourhood Plan has completed its Regulation 16 stage and all representations made during the consultation period have been submitted to the Independent Examiner appointed to examine the Neighbourhood Plan. The Neighbourhood Plan is currently within the examination process. However, given that it is not yet made, full weight cannot be attributed to its policies.

The Waverley Borough Local Plan Part 2: Site Allocations and Development Management Policies was subject to a Preferred Options consultation which ran from 25 May 2018 to 9 July 2018. In November 2018, the publication of

the Local Plan Part 2 was deferred to enable further consultation with stakeholders. It is anticipated that the Council will be in a position to publish Local Plan Part 2 for its Pre-Submission Consultation in summer 2019. Given this position, it is considered that very limited weight can be attributed to the emerging Local Plan Part 2.

Relevant Policies in relation to the determination of the current application include:

Local Plan, Part 1, Strategic Policies and Sites:

Policy SP1 Presumption in Favour of Sustainable DevelopmentPolicy SP2 Spatial StrategyPolicy ALH1 The Amount and Location of HousingPolicy ST1 Sustainable TransportPolicy ICS1 Infrastructure and Community ServicesPolicy AHN1 Affordable Housing on Development SitesPolicy AHN3 Housing Types and SizesPolicy LRC1 Leisure and Recreation Facilities Policy RE2 Green BeltPolicy RE3 Landscape CharacterPolicy TD1 Townscape and DesignPolicy HA1 Protection of Heritage AssetsPolicy NE1 Biodiversity and Geological ConservationPolicy NE2 Green and Blue InfrastructurePolicy CC1 Climate ChangePolicy CC2 Sustainable Construction and DesignPolicy CC3 Renewable Energy DevelopmentPolicy CC4 Flood Risk Management

Local Plan 2002 retained Policies:

Policy D1 Environmental Implications of developmentPolicy D4 Design and LayoutPolicy D6 Tree ControlsPolicy D7 Trees, Hedgerows and DevelopmentPolicy D8 Crime PreventionPolicy D9 AccessibilityPolicy C5 Areas of Strategic Visual ImportancePolicy C7 Trees, Woodlands and HedgerowsPolicy BE5 Godalming Hillsides Policy HE14 Sites and Areas of High Archaeological PotentialPolicy HE15 Unidentified Archaeological Sites

Policy CF2 Provision of New Community Facilities Policy LT11 Walking, Cycling and Horseriding Policy RD9 Agricultural LandPolicy M5 Provision for CyclistsPolicy M7 Footpaths and CyclewaysPolicy M9 Provision for People with Disabilities and Mobility

Problems

Other guidance: National Planning Policy Framework (2018) National Planning Practice Guidance (as updated) Land Availability Assessment (2016) West Surrey Strategic Housing Market Assessment (2015) Infrastructure Delivery Plan (2012) Climate Change Background Paper (2011) Statement of Community Involvement (2014 Revision) Strategic Flood Risk Assessment (2015/2016) Planning Infrastructure Contributions SPD (2008) Cycling Plan SPD (April 2005) Council’s Parking Guidelines (2013) Density and Size of Dwellings SPG (2003) Residential Extensions SPD (2010) Vehicular and Cycle Parking Guidance (Surrey County Council 2018) Waverley Local Plan Strategic Highway Assessment (Surrey County

Council, 2016) Surrey Design Guide (2002)

Consultations and Town Council Comments

County Highway Authority (Full response is attached at Appendix 1)

No objection subject to Infrastructure Contributions, conditions and informatives.

Godalming Town Council Objection - Whilst Godalming Town Council recognises the housing need of the Waverley Borough area, the Town Council objects to this application on the grounds that it is an overdevelopment of the site with an inadequate housing mix and insufficient social housing provision. Moreover, its lack of environmental consideration relating to surface water control and environmental impact on the local area including roads, traffic access and traffic generation.

Additionally, the Town Council considers that the effect of the development on listed buildings and gardens in the area have not been adequately considered. The Town Council is concerned that the public consultation over this application has been inadequate and that it should be considered as a whole site plan and not two individual applications split by Borough boundaries.

Guildford Borough Council Subject to no objection from any statutory consultees, Guildford Borough Council raises no objection to the development. It is considered that the proposal would not have any material impact on the strategic interests of Guildford Borough Council.

In terms of an update on the adjacent site within Guildford:

The Guildford Local Plan: strategy and sites was submitted to the Secretary of State in December 2017 for examination. A series of hearing sessions were held during June/July 2018 following which the Inspector concluded that additional sites were necessary in order to increase early delivery. The Council proposed a number of additional sites, including one for 200 homes at Aaron’s Hill. The Council consulted on the main modifications during September/October 2018. Since then, the Council has published a number of examination documents analysing the impact of the recently published 2016-based household projections. This concludes that the housing requirement for Guildford should be reduced and that the new Green Belt site allocations proposed in the main modifications consultation are no longer necessary. The Inspector has indicated that he wishes to have further hearing sessions to discuss this matter. No timetable has been set, however

the Council envisages that this is likely to be held in late January/February 2019. The Aaron’s Hill site allocation Policy A61 in the Submission Local Plan 2018 therefore holds very limited weight.

GBC SANGs Officer The Guildford SANGs Officer has commented on the current application due to its proposed use of SANG facilitated by a separate planning application to Guildford Borough Council: 18/P/01958.

The Guildford SANGs Officer has commented that, given the site’s location in proximity to designated sites and proposed use as residential development, it cannot be excluded not to have a likely significant effect on European designated sites, either individually or in combination with other plans or projects. This determines the need for an Appropriate Assessment. It is likely that mitigation for adverse impacts identified in an Appropriate Assessment may include SANG to alleviate visitor disturbance. However other adverse impacts such as pollution and the validity of estimates of reduced NOx based on improved vehicle efficiency may also need to be addressed.

If the GBC separate application for SANG is unsuccessful, the initial SANG identified within the current application (eastern section of the site) may be unsuitable. Those SANG plans have been superseded and the Guildford SANGs Officer is in agreement with Surrey Wildlife Trust’s concern with securing carefully managed future use of this land to avoid potential negative impacts of unmanaged visitors and dogs on a habit of principle importance or impact on its use as part of a green corridor supporting species within the adjacent irreplaceable habitat (ancient woodland). Such impacts may potentially limit net biodiversity gain towards

sustainable development.

In respect to mitigation proposals for SANG in the separate application to Guildford Borough Council, Natural England consider the measures are acceptable ‘in principle’ and as such do not raise objections to any outstanding negative impacts in respect to increased recreational disturbance on Thursley, Hankley and Frensham Commons SPA. Given this response it is likely that the mitigation which includes SANG may similarly alleviate recreational impacts on the nearby SAC, RAMSAR sites and Charterhouse to Eashing SSSI; however this should be clarified. Details on the management, funding, path length and layout of the SANG remain subject to ongoing discussion.

To provide realistic prospects that a Grampian condition for SANG is achievable in the planning permission timeframe, determination of this application (WA/2018/1239) should await successful authorisation of 18/P/01958. It would then be practicable for a Grampian condition to be applied to the present application to ensure that no associated residential accommodation is occupied until the required SANG capital works 18/P/01958 are complete and it is operational, accessible and signed off by the local authority. It is essential that the quantity of SANG available has capacity to account for the population increase based on occupancy of new dwellings and therefore confirmation is required on the exact size and number of dwellings.

Access improvements and existing links between the SANG 18/P/01958 and development have been proposed however

the SANG is a considerable distance from the development following the route indicated in the application. Local residents have also raised concerns that parts of the route along the roadside may not be entirely safe or inviting for dog walkers. Therefore in effect the SANG functions as Strategic SANG and consequently is proposed with an appropriate parking capacity of one space per hectare for this purpose and additional strategic capacity for other development in Guildford and Waverley. It is not unusual or unacceptable for a development of this size to have a strategic off-site SANG rather than a SANG on adjacent land. However the transport assessment should therefore include appropriate numbers of SANG visits by car. Although journeys are likely to be low depending on the exact housing mix they may amount to 5 visits to and from the SANG per hour in daylight hours based on 5ha of SANG required for the indicative population increase of 629, parking availability and duration of visit.

Thames Water (Full response is attached at Appendix 2)

Thames Water has identified an inability of the existing water network infrastructure to accommodate the needs of this development proposal. The following condition is therefore recommended should permission be granted.

ConditionNo properties shall be occupied until confirmation has been provided that either:- all water network upgrades required to accommodate the additional flows from the development have been completed; or - a housing and infrastructure phasing plan has been agreed with Thames Water to allow additional properties to be occupied. Where a housing and infrastructure phasing plan is agreed no occupation shall take place other than in accordance with the agreed housing

and infrastructure phasing plan.

ReasonThe development may lead to no / low water pressure and network reinforcement works are anticipated to be necessary to ensure that sufficient capacity is made available to accommodate additional demand anticipated from the new development

Informatives are recommended with regard to water mains, underground assets, public sewers, and a groundwater risk management permit.

Thames Water is unable to comment regarding foul network capacity as no foul strategy has been provided for the proposal.

Southern Water The site is not located within Southern Water’s statutory area for water supply, drainage and wastewater services.

South East Water No objection.County Rights of Way Officer(Full response is attached at Appendix 3)

No objection, subject to recommended conditions and informatives.

County Archaeologist No objection, subject to recommended condition.

Natural England (Full response is attached at Appendix 4)

Comments dated 16/10/2018Further information is required to determine the impacts on protected species (Hazel Dormouse). Further mitigation measures may be required pending the results of proposed aerial climbing assessments of trees identified as containing roosts or having bat roosting potential.

Natural England are aware of a separate application submitted to Guildford Borough Council for SANG, with the intention that capacity at this SANG will be allocated to the development proposed within Waverley. Natural England has reviewed the proposals and consider that they are acceptable in

principle and that the SANG will effectively mitigate for increased recreational disturbance on Thursley, Hankley and Frensham Commons SPA. A Grampian condition is recommended should permission be granted to ensure that no associated residential accommodation is occupied until the required SANG capital works are complete and it is operational and accessible.

Further comments dated 19/11/2018No objection, subject to mitigation – Natural England has reviewed the additional information submitted and, subject to mitigation, is satisfied that the proposal would not result in a significant impact on protected species.

Natural England would like to take the opportunity to clarify that, based on the submitted plans, it is considered that the proposal would not damage or destroy the interest features for which the Charterhouse to Eashing Site of Special Scientific Interest (SSSI) has been notified. No objection is raised in this respect.

Forestry Commission Refer to Standing AdviceEnvironment Agency No objectionLead Local Flood Authority (LLFA)

Comments dated 09/08/2018Clarification is sought from the developer with regard to the discharge rate used and discharge of surface water.

Comments dated 21/08/2018The LLFA is satisfied that the proposed drainage scheme meets the requirements of the NPPF, its accompanying PPG and Technical Standards, and recommends that permission is granted subject to conditions and informatives.

Surrey Wildlife Trust Comments dated 24/10/2018Clarification should be sought that an

appropriate buffer is retained at tree T51. A climbed bat roost assessment should be undertaken. No objection is raised, subject to recommended conditions.

Comments dated 13/12/2018The Bat Aerial Tree Assessment Report is appropriate in scope and methodology. Works should proceed in accordance with the recommended actions contained therein.

Surrey Hills AONB Advisor Objection – if the area of the field within Guildford Borough Council is not removed from the AGLV, the proposed western boundary treatment would be inadequate to provide a tree screen to mitigate the landscape impact of the proposed development. If it is removed, the schemes should be considered together.

The LVIA underplays the landscape sensitivity. The site should be considered with regard to the relationship with the AGLV. Any planting scheme approved should include native tree and shrub species and be sufficiently dense to screen the site.

The site should provide more affordable housing to justify the development within a protected landscape/Green Belt. The layout, form and design do not meet the enhanced requirements in the new Government NPPF, set out in Section 12 – Achieving well-designed places. Three storey buildings are out of place in the setting.

The proposed mitigation measures would not overcome the harm to the landscape. Developer funding should be sought to contribute toward the needs of improving the road cycle network.

British Driving Society No objectionByways and Bridleways Trust No objectionRamblers Association – No objection

LondonRamblers Association – Godalming, Busbridge & Bramley

No objection

Surrey Police Designing Out Crime Officer

No objection, subject to a recommended planning condition that the development achieves a Secure by Design Accreditation.

Highways England No objection – it is unlikely that the proposal would have significant impact to the safe and efficient operation of the strategic road network, in this case the A3.

Historic England(Full response is attached at Appendix 5)

Objection – the application does not adequately assess the harm to the Grade II* Listed Westbrook House and its associated Grade II garden. Historic England considers that the quantum and density proposer particularly to the north of the development site would likely negatively impact on the setting of Westbrook by eroding the established rural character of the landscape in which it sits. It would be harmful to the listed building’s significance and special interest. The degree of this identified harm would be less than substantial.

There may be opportunities to further mitigate harmful impacts arising from the development. Further information should be sought from the developer. The harm must be fully justified in NPPF terms and the scheme only permitted if public benefits exist that would outweigh the harm.

Further comments dated 21/11/2018The supplementary built heritage statement has been reviewed. Historic England is disappointed that a visual assessment has not been submitted and has commented that the assessment undertaken is largely desk-based, produced without visiting Westbrook.

The significance of the heritage asset has not been satisfactorily addressed by the

applicants. There would be no heritage public benefits of the proposal. However, it is for the Local Planning Authority to consider whether there are any other public benefits.

Scottish and Southern Electric (SSE)

No objection

Species Recovery Trust No objection subject to financial contributions being secured by way of a S106 Legal Agreement.

National Grid No objectionBritish Horse Society No objectionCouncil’s Environmental Health – contaminated land

No objection

Council’s Environmental Health – noise and disturbance

No objection subject to conditions and in formatives

Council’s Environmental Health – Air Quality

No objection subject to conditions

Council’s Waste and Recycling co-ordinator

No objection – financial contrition sought.

Additional non-statutory consultee responses:

Shackleford Parish Council Objection – The development would cause harm to the environment, the openness of the Countryside and to road congestion.

Recent WBC decisions have been overly influenced by the need to provide for the massive and unrealistic housing requirement demanded by the new Local Plan. The current scheme would not provide enough affordable housing. Existing traffic problems would be exacerbated.

Issues will be further aggravated when the ‘other half’ of the site within Guildford Borough is developed. The overall density will have significant impacts on local infrastructure, traffic and road systems. The submitted Traffic Assessment conclusions are challenged by the Parish Council. There is a lack of assessment of traffic through

Lower Eashing. The Parish Council asks that a second Traffic Assessment is undertaken.

Witley Parish Council Objection – the Parish Council is concerned about the overall impact of this site in conjunction with neighbouring proposals in the Guildford site. Not enough research has been done into the cumulative impacts. Particular concern is raised regarding the traffic impact. The roads are not suitable for large volumes of traffic or heavy goods vehicles. The use of trip rates from the TRICS database does not seem realistic. The release of the Secretts site from the Green Belt would have been preferable to many in the locality. A thorough independent assessment needs to be undertaken relating to rare species highlighted by community groups.

Victorian Society Objection – the submitted heritage information does not provide a proper assessment of the impact of the proposal on Westbrook House and its Registered Park and Garden. The baseline requirements of national legislation and policies have not been met and the application should be refused on this basis.

The Society for the Protection of Ancient Buildings

Objection – the submitted heritage statement seems to recognise the importance of Westbrook House but downplays the impact of the proposal on the setting of the building and its Registered Garden. The impact could be quite considerable and harmful. Due weight should be attached to this issue, which is material to the consideration of the application.

Campaign to Protect Rural England

Object – The Local Plan is subject of judicial review and the principles of removing the site from the AGLV/AONB and the Green Belt are flawed and should therefore be treated as being within them.

Policy DS4 of Local Plan Part 2 preferred options requires a masterplan setting out

how the high quality development be achieved across the wider site (including Guildford land) and should not be considered until a single plan is submitted.

The site is high quality agricultural land currently used for farming, and its loss would not protect the best and most versatile agricultural land The site is a valued landscape as per paragraph of 170 of the NPPF and it does not protect or enhance the valued landscape.

The development is considered to be unsustainable as it is not well connected to the town centre. The site would require extensive car journeys and the impact could not be resolved easily.

The use of three storey buildings is inappropriate and the housing figure is too high

The amount of affordable housing is inadequate for a Green Belt location.

The Inspector in Local Plan Part 1 did not mandate the use of the site for housing.

Further comments received 19/11/2018The application should be refused until allocations are determined under Local Plan Part 2. Pre-application policy considerations between Guildford and Waverley Councils as to the overall strategy should take place.

The development is not sustainable and the proposal would conflict with paragraph 170 of the NPPF.

There would be inadequate affordable housing and the proposed housing figure is too high.

The Local Plan Inspector did not and could not mandate the use of the site for housing.

Diocese of Guildford Support - Through the number of children likely to attend Green Oaks primary school, the development would make a significant vitality and viability of the school and allow the school to become financially sustainable in the long term. The housing development is a critical part of securing the school’s future and key to the school being saved from closure.

The Gardens Trust Comments dated 26/09/2018Objection – the Heritage Statement is not sufficient to determine the application and should therefore be refused. The Gardens Trust considers that the proposal does not conform to the Local Development Plan.

Comments dated 23/11/2018The Gardens Trust does not accept the interpretation put forward in the built heritage clarification statement and would endorse the comments from Historic England.

Forestry Commission Referred to Natural England standing advise regarding the Ancient Woodland

Woodland Trust Concern regards the impact of the development on the Root Protection Area of Tree 51.

National Trust Concern is raised regarding the potential increase in traffic using of Eashing Bridge. The Trust welcomes the proposal by Surrey County Council as Highway Authority to make the route between Eashing Lane and the A3 slip road access only. It is expected that any Construction Transport Management Plan should include provision to preclude the use of Eashing Lane by all construction vehicles and for alternative routes to be agreed and used.

Representations

In accordance with the statutory requirements and the “Reaching Out to the Community – Local Development Framework – Statement of Community Involvement – August 2014” the application was advertised in the newspaper on 10/08/2018, site notices were displayed around the site on 03/08/2018 and neighbour notification letters were sent on 01/08/2018 and 05/11/2018.

245 letters have been received raising objection on the following grounds:

Landscape The land was suddenly removed from the Green Belt and shouldn’t be

built on, Brownfield sites are still available within the borough and should be prioritized.

The site is an Area of Outstanding Natural Beauty and should remain free of development

Unsuitable topography for further development Change from green field to developed site Urban creep

Ecological/Biodiversity Impact on a wide range of wildlife including badgers, hedgehogs and

dormice. The site is close to a SSSI and will result in harm to it Impact on the endangered Starved Wood-Sedge one of two known

populations in the UK. Does not take into account the diverse nature of the area

Design The scale and design is out of character with the local area and the

surrounding landscape. There is a lack of green common space Loss of character in the area Designed to be a different community to Aarons Hill rather than adding

to it The design is too dense and much greater than other local settlements

Residential Impact Noise impact from the construction process which will be timely The site is in close proximity to The Meath and will impact on the

access of wheelchair users Loss of privacy and light

Heritage Insufficient level of heritage assessment provided Harm to Grade II* listed building Westbrook House and garden Harm to historic town

Highways Increased traffic and congestion due to greater volume of cars despite

the road design Concerns over works proposed to Eashing Lane Would reduce air quality to the detriment of health Concerns over the safety of cyclists and pedestrians particularly on

Westbrook Road Excess traffic from the A3 would be made worse Construction vehicles would be dangerous for the locals Concerns over the potential damage to Eashing Bridge Loss of resident parking on Eashing Lane Insufficient road access to the site given the site density Inappropriate models have been used to predict traffic increases Extra stress on the Eashing Lane/Portsmouth Road junction Pollution currently sits in this area as its located in a valley Damaged roads from heavy construction vehicles Already dense housing estates being built in the Guildford area Estimates of car travel should be greater as Waverley is a wealthy area Current roads are not suitable for HGVs required during construction

and after

Infrastructure Increased pressure on local schools, doctors and parking. Insufficient school places in the area Concerns about how sewage and water would be connected The park/play areas are too small to compensate for the very small

private gardens Refuse and recycling demands will all increase Increase in light and noise pollution from occupation Negative impact on local business Will contribute to food shortages in light of Brexit Insufficient capacity on the rail network for the amount of likely

commuters

Flooding The built form would result in flooding by way of removing green

fields

Other Will result in an increase of crime This is a cash grab from the developer Who will be responsible for policing the open space with regards to

anti-social behavior. Alcohol should be banned from the area Inadequate community engagement particularly in the removal of

the land from the Green Belt The perimeter gap between the site and Aarons Hill create a divide

and at risk of use for illegal activities Local homes resale value will drop as a result Misleading statement on the socio-economic and financial benefits Insufficient Affordable Housing which isn’t aimed at those who

need it Reports are inaccurate to varying degrees Increase in pressure on local area from Guildford and Dunsfold

development Application should be coming forward alongside the Guildford side

of the field Local people won’t be able to afford the site Will impact on Fitzpatrick Vets Not enough jobs in the local area No need for a community building as there is one in the area Application shouldn’t be considered until outcome of the Judicial

Review

6 letters have been received expressing support for the following reasons: Good for local businesses who need support Filling the need for housing Site has good local transport networks The Aaron’s Hill area will be enhanced Green Oaks is staying open More local spaces for family to spend time together Numbered parking spaces for Eashing Lane residents Hedgehog highways

15 letters have been receiving making general comments.

A separate petition, dated 31/08/2018, has been submitted on behalf of Godalming Community Members and contains 175 signatories. This petition has been followed by further objections on behalf of Godalming Community

Members, which are accompanied by a number of independent reports/surveys relating to ecology, transport and heritage.

The petition and subsequent objections raise the following points: The Planning Application and its associated documents are inadequate

and flawed. The local plan is subject to a legal challenge. The draft LPP2 policy requires the applicant ‘to submit a masterplan

setting out the design principles for the site,’ including land with Guildford Borough Council – Waverley has no such plan.

The Waverley planning decision should not be reached in isolation without consideration of the Guildford half of the site – including layout and infrastructure demands.

There has been inadequate community and stakeholder consultation in relation to the proposed development prior to submission and insufficient opportunity for stakeholders to comment on the application

The application is based on inaccurate, incomplete and inadequate reports, in particularly the Transport Assessment, Heritage Report, LVIA and Ecology Report.

The reports do not meet the requirements of the NPPF, LPP1 or draft LPP2. Waverley therefore requires additional reports prior to determination.

The vehicular, pedestrian and bicycle traffic from the development will be unsafe.

The reports do not provide appropriate habitat assessment or appropriate consideration of alternative natural green space sufficient to meet its own impacts.

The proposal is premature.

Determining Issues

Principle of developmentPrematurityLocation of developmentLoss of agricultural landHousing land supplyHousing mixAffordable housingGreen Belt considerationsLandscape considerationsDesign and impact on visual amenityImpact on residential amenityHighways considerations

Self build provisionHeritage considerationsStandard of accommodationProvision of amenity spaceTrees and landscapingFlooding and drainageUtilitiesNoiseLand contaminationAir QualityArchaeologyRefuse and recyclingImpact on SPA and SACRights of WayInfrastructure considerationsCrime and DisorderBiodiversity and compliance with Habitat Regulations 2017Accessibility and Equalities Act 2010SustainabilityHealth and wellbeingHuman Rights ImplicationsEnvironmental Impact Regulations 2017Pre Commencement ConditionsWorking in a positive/proactive mannerResponse to Town Council and Third Party comments

Planning Considerations

Principle of development

The consideration of planning applications takes place in the context of a plan-led system. Planning law requires that applications for planning permission be determined in accordance with the development plan unless material considerations indicate otherwise.

The western section of the application site, where the development itself is proposed, falls within the settlement of Godalming, following its removal from the Green Belt and the Area of Great Landscape Value (AGLV) through the Local Plan 2018 (Part 1). The eastern section of the application remains within the Green Belt and AGLV.

The issue of the removal of part of the site from the Green Belt through the Local Plan 2018 (Part 1) was addressed by the Inspector who examined the

Local Plan in his report. In relation to the Plan’s Spatial Strategy and implications for the Green Belt, he states:-

“At the strategic level, the need to provide adequate housing through the spatial strategy would lead to difficulties at Godalming unless some land was released from the Green Belt. The supply of sites within the town and on brownfield land is limited by the town’s character and topography, and the town is surrounded by Green Belt. Godalming is one of the largest towns in the Borough and it would not be possible to provide adequately for the amount of growth commensurate with the spatial strategy without releasing some land from the Green Belt. The plan therefore includes the release of two sites; the details of these are addressed under the heading Godalming below.” (Paragraph 73)

In relation to the land at Aaron’s Hill, the Inspector goes on to state:-

“The Green Belt review identified land at Aaron’s Hill, on the western side of the town, as being suitable for removal from the Green Belt. However, the submitted plan indicates that the matter will be considered in Part 2 of the Plan, following discussion with Guildford Borough Council, since the Borough boundary runs along the western side of the site. This leaves an unnecessary degree of uncertainty as to the Plan’s intentions. The site is suitable for removal from the Green Belt: it is not of particularly high landscape quality, being flat and rather featureless, the existing urban edge is rather hard and the site would present the opportunity of establishing a better edge to the built up area and a better-defined Green Belt boundary. The Council endorses MM12, which removes this land from the Green Belt, a sound modification that makes clear the Plan’s intentions and provides the opportunity for the site to be brought forward for housing, subject to appropriate access and other considerations to help meet the overall housing requirement and housing need in Godalming.” (Paragraph 111)

As the western part of the site has been removed from the Green Belt and AGLV and incorporated within the settlement area of Godalming through the Local Plan 2018 (Part 1), the principle of development on the site is acceptable. Moreover, as the Local Plan Inspector states, the removal of this land from the Green Belt provides the opportunity for the site to be brought forward for housing to help to meet the overall housing requirement as well as meeting housing need in Godalming.

The amended Green Belt boundary in respect of the application site, as set out within Policy RE2 of the Local Plan 2018 (Part 1), can be seen in the plan below:

In relation to that part of the site that remains within the Green Belt, Policy RE2 of Local Plan 2018 (Part 1) states that the Green Belt will continue to be protected from inappropriate development and such development will not be permitted unless very special circumstances can be demonstrated. In relation to the AGLV, Policy RE3 of the Local Plan 2018 (Part 1) states that new development must respect and, where appropriate, enhance the character of the landscape in which it is located. It says that in the AGLV the same principles will apply as apply in the AONB, whilst recognising that the protection of the AGLV is commensurate with its designation as a local landscape designation.

Policy SP1 of the Local Plan 2018 (Part 1) states that when considering development proposals the Council will take a positive approach that reflects the presumption in favour of sustainable development contained in the NPPF.

Policy SP2 of the Local Plan 2018 (Part 1) sets out the Council’s Spatial Strategy for where development should be located. Part of the spatial strategy is to focus development at the four main centres of Farnham, Godalming, Haslemere and Cranleigh. The strategy also seeks to avoid major development on land of the highest amenity and landscape value and to safeguard the Green Belt. Local Plan also allocates some strategic sites for development. In addition, other site allocations will be contained in either Local Plan Part 2: Site Allocations and Development Management Policies, or neighbourhood plans. Although Godalming Town Council is producing a

neighbourhood plan, it does not contain site allocations. Therefore, any allocations that are required to ensure delivery of the housing requirement for Godalming set out in Local Plan 2018 (Part 1) will be contained in Local Plan Part 2.

The application site is not one of the allocations in Local Plan 2018 (Part 1). Therefore it is intended that the allocation will be made through Local Plan Part 2. The Council consulted on a ‘Preferred Options’ version of Local Plan Part 2 in spring/summer 2018. The Preferred Options included the proposed allocation of that part of the site that has been removed from the Green Belt for housing. It is recognised that, at this stage, the proposed allocation of the site through Local Plan Part 2 can only have very limited weight in view of the stage that that Plan has reached.

The application site adjoins the boundary with Guildford Borough. The land within Guildford Borough has also been promoted for development. The land was not included as a proposed allocation in the Guildford Local Plan that was submitted for examination. However, following the examination hearings, one of the main modifications required by the Inspector was the identification of some additional sites capable of delivering housing in the early years of the Plan. One of these sites was the Guildford Aaron’s Hill site. Consultation on the proposed Main Modifications to the Guildford Plan took place in September/October 2018.

The Local Plan Inspector also invited Guildford Borough Council to comment on the implications of the latest household projections, which indicated a reduction in the projected level of household growth. As a result, the Leader of Guildford Borough Council wrote to the Inspector asking the Inspector to consider removing the additional Green Belt sites from the Plan in the light of the evidence pointing to a reduced need for housing. In response, the Inspector has decided to hold further examination hearings to discuss the issue of the housing requirement further and the implications for the additional sites that were included in the Main Modifications. The Hearings are scheduled to take place on the 12th and 13th of February.

Irrespective of the position relating to land within Guildford Borough, the fact that the principle of development of the current application site before Members has been established through the removal of the land from the Green Belt and AGLV and its incorporation in the settlement area means it is not necessary for the land to be formally allocated under the Development Plan in order for an application to be considered on its normal planning merits. The assessment as to the acceptability of the development proposal will take place in following sections of this report.

Prematurity

Annex 1 of the National Planning Policy Framework explains how weight may be given to policies in emerging plans. However, in the context of the Framework and in particular the presumption in favour of sustainable development – arguments that an application is premature are unlikely to justify a refusal of planning permission other than where it is clear that the adverse impacts of granting permission would significantly and demonstrably outweigh the benefits, taking the policies in the Framework and any other material considerations into account. Such circumstances are likely, but not exclusively, to be limited to situations where both:

a) the development proposed is so substantial, or its cumulative effect would be so significant, that to grant permission would undermine the plan-making process by predetermining decisions about the scale, location or phasing of new development that are central to an emerging Local Plan or Neighbourhood Planning; and

b) the emerging plan is at an advanced stage but is not yet formally part of the development plan for the area.

Refusal of planning permission on grounds of prematurity will seldom be justified where a draft Local Plan has yet to be submitted for examination, or in the case of a Neighbourhood Plan, before the end of the local planning authority publicity period. Where planning permission is refused on grounds of prematurity, the local planning authority will need to indicate clearly how the grant of permission for the development concerned would prejudice the outcome of the plan-making process.

The second part of the Council’s Local Plan process (Local Plan Part 2) is currently being considered and the Council anticipates being in a position to publish Local Plan Part 2 for its Pre-Submission Consultation in Summer 2019. Within the draft Local Plan Part 2, Draft Policy DS4 proposes allocation of the application site for housing.

Under Policy RE2 of the Local Plan 2018 (Part 1), the western section of the application site was removed from the Green Belt and AGLV and is seen to form part of the settlement of Godalming. Whilst the eastern section of the site remains within the Green Belt and AGLV, no residential development would take place within this area and it would serve as public open space. It is considered that the proposed residential development in the western section would be acceptable in principle, subject to consideration of material planning considerations.

http://planningguidance.planningportal.gov.uk/blog/policy/achieving-sustainable-development/annex-1-implementation/

http://planningguidance.planningportal.gov.uk/blog/policy/achieving-sustainable-development/#paragraph_14

http://planningguidance.planningportal.gov.uk/blog/policy/achieving-sustainable-development/#paragraph_14

http://planningguidance.planningportal.gov.uk/blog/guidance/local-plans/

http://planningguidance.planningportal.gov.uk/blog/guidance/neighbourhood-planning/

It is noted that Third Party representations have put forward an argument that it would be premature to determine the current application on the grounds that the site is allocated within Draft Local Plan Part 2, for which a public consultation will be forthcoming in the near future. It is claimed that the determination of the current application would prejudge the outcome of the public consultation, which would be inconsistent with the principles set out in R v Brent London BC, ex p Gunning (1985) 84 LGR 168. The Third Party suggestion put forward is that the current application should be rejected on the grounds that it would be premature, having regard to paragraph 49 of the NPPF 2018, and a fresh application should be made, consistent with the conclusions of the Council’s Local Plan Part 2.

Fundamentally, it is considered that the proposal would be consistent with the principles of Local Plan 2018 (Part 1) and it would not predetermine a decision in respect of the allocation of the site within Local Plan Part 2.

Officers have nevertheless sought advice from Counsel with regard to the position on prematurity in terms of the proposals relationship with the pre-submission Local Plan Part 2.

The advice received concludes that the assessment of, and weight to be attached to, the issue of prematurity are matters of planning judgment. Here, the site is one of a number of proposed allocations in the preferred options consultation draft. It is for the Council to consider whether it is so substantial, or its cumulative effect so significant, that to grant permission would undermine the plan-making process by predetermining decisions about the scale, location or phasing of new development that are central to the emerging Local Plan Part 2. In Counsel’s opinion, it would be open to the Council to conclude that the application was not so substantial. Furthermore, the emerging plan is not at an advanced stage. In light of the guidance in the Planning Practice Guidance, it is the view of Counsel that the Council can properly give little weight to the prematurity argument.

Location of development

Paragraph 91 of the NPPF confirms that planning policies and decisions should aim to achieve healthy, inclusive and safe places.

Paragraph 92 of the NPPF states that to provide the social, recreational and cultural facilities and services the community needs, planning policies and decisions should:

plan positively for the provision and use of shared space, community facilities (such as local shops, meeting places, sports venues, open

space, cultural buildings, public houses and places of worship) and other local services to enhance the sustainability of communities and residential environments;

take into account and support the delivery of local strategies to improve health, social and cultural well-being for all sections of the community;

guard against the unnecessary loss of valued facilities and services, particularly where this would reduce the community’s ability to meet its day-to-day needs;

ensure that established shops, facilities and services are able to develop and modernise, and are retained for the benefit of the community; and

ensure an integrated approach to considering the location of housing, economic uses and community facilities and services.

Paragraph 103 of the NPPF states that significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes. The opportunities available to maximise sustainable transport solutions will vary between urban and rural areas, which should be taken into account in both plan-making and decision-making.

The Key Note Policy of the Waverley Borough Local Plan aims, amongst other matters, to make provision for development, infrastructure and services which meet the needs of the local community in a way which minimises impacts on the environment.

The text states that opportunities for development will be focused on the four main settlements (Farnham, Godalming, Haslemere and Cranleigh), mainly through the re-use or redevelopment of existing sites.

Policy SP2 of the Local Plan 2018 (Part 1) refers to the Council’s Spatial Strategy to 2032 and the need to maintain Waverley’s character whilst ensuring development needs are met in a sustainable manner. Policy SP2 sets out the following:

Major development on land of the highest amenity value will be avoided Development will be focused at the four main settlement Moderate levels of development will be allowed in larger villages Limited levels of development will be allowed in and around other

specified villages Modest levels of development will be allowed in all other villages. Opportunities for the redevelopment of suitable brownfield sites will be

maximised.

Strategic and Non-Strategic sites will be identified and allocated through Local Plan Part 2 and Neighbourhood Plans

Infrastructure, where needed, will be provided alongside new development including funding through the Community Infrastructure Levy (CIL)

As previously stated, the western section of the application site, in which the residential development is proposed, was removed from the Green Belt and AGLV under Policy RE2 of the Local Plan 2018 (Part 1) and is seen to form part of the settlement of Godalming.

The application is supported by a Planning Statement and Design and Access Statement, which set out that the application site is within 0.3 miles (equating to 3 minutes cycle or 10 minutes walk) of Godalming Train Station, which provides connections to Guildford, Woking, London Waterloo and Portsmouth. It is also set out that the site is within close proximity to Godalming Town Centre, which provides a good level of facilities including education, employment, travel and entertainment. Bus services are located on Aarons Hill and Eashing Lane, which provide transport to Godalming Town Centre, Guildford and other nearby settlements. In addition, there are vehicular transport links with the A3 which is accessible from the site via Eashing Lane and A283.

When assessed against the accessibility criteria benchmark for New Development, established by Shaping Neighbourhoods, the site largely meets expectations of access to facilities for new neighbourhoods. An audit carried out by the Applicant has revealed opportunities to enhance local services such as GP services and community facilities. As set out in the ‘Heads of Terms’ section, a financial contribution would be secured towards GP services and the proposal would provide for a flexible-use community building, play areas and play trails, public open space and community gardens.

Officers are satisfied that the site is in a sustainable location for the provision of residential development.

Loss of agricultural land

Paragraph 170 of the NPPF 2018 states that ‘planning policies and decisions should contribute to and enhance the natural and local environment by: recognising the intrinsic character and beauty of the of the countryside and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland.’ For these purposes, best and most versatile

agricultural land means land in grades 1, 2 and 3a of the Agricultural Land Classification.

Retained Policy RD9 of the Local Plan 2002 states that development will not be permitted which would result in the loss or alienation of the best and most versatile agricultural land unless it can be demonstrated to the satisfaction of the Local Planning Authority that there is a strong case for development on a particular site which overrides the needs to protect such land. This policy is awarded significant weight owing to its consistency with the NPPF.

The application is supported by an Agricultural Land Classification Report, dated July 2018 and a letter dated 18/09/2018 from Mark Franklin, Agronomist. The submitted report states that although the site area is approximately 12.23 hectares, only 5.7 hectares is in agricultural use. The report concludes that the application site is classified as Grade 3 – Good to moderate. The applicant has confirmed that the classification of land would specifically fall under Grade 3a.

However, the submitted letter sets out that the application site is predominantly light Greensand Loam, a type of soil which is very free draining and suffers from drought on a regular basis. Significant irrigation is required to successfully grow any root or vegetable crops, which is not possible for the application site. Crops which have been grown on the application site in the past have struggled to reach their full yield potential as a result. Further, the soil lacks organic matter, which helps the uptake of fertilisers and enables the plants to grow a viable root structure. In addition, the site features overhead power cables, which makes moving farm machinery around the site safely very challenging. An electricity sub-station is present to the north east corner and there are underground cables which make ground works dangerous.

It is acknowledged that the proposal would result in the loss of Grade 3a agricultural land, which would comprise the ‘best and most versatile agricultural land’ having regard to paragraph 170 of the NPPF. However, the loss of such land would amount to under half of the overall application site area.

Retained Policy RD9 of the Local Plan 2002 allows for development proposals to be granted in the event that there is a strong case for development on a particular site, which overrides the need to protect the agricultural land. In this instance, taking into account the area of agricultural land to be lost, the constraints on the agricultural land and the weight to be attached to the delivery of housing, officers are of the view that there would be a strong case for development of the application site which would override the loss of Grade

3a land. On this basis, it is considered that the proposal would accord with retained Policy RD9 of the Local Plan 2002.

Housing land supply

The Council published its 5 year housing land supply statement in September, with a base date of 1st April 2018. This document confirms that, with an additional buffer of 5%, the Council has 5.8 years’ worth of housing supply. Therefore the Council can demonstrate the requirement of paragraph 73 of the NPPF. This figure of five year housing land supply includes a contribution of 165 homes on the application site, on the grounds that the site has been removed from the Green Belt and AGLV and incorporated within the settlement area of Godalming in Local Plan 2018 (Part 1) and is proposed to be allocated in the Local Plan Part 2. Therefore, it has been assessed that this number of homes on it will potentially be delivered within five years.

Within the recent appeal decision for Land west of Folly Hill, Farnham (APP/R3650/W/17/3171409) dated 12 December 2018, the Inspector states that the appropriate additional buffer used to calculate the Council’s housing land supply position will be put beyond doubt as and when the Government’s Housing Delivery Test (HDT) results are published. At the time of the appeal decision, and writing this report, the results are still awaited and therefore the HDT does not confirm whether a buffer of 5% or 20% should be used.

The Appeal Inspector did not give a determinative view as to the Council’s ability to demonstrate a 5 year housing land supply within the appeal decision, He conveyed that, in advance of the publication of the HDT figures, the quantum of delivery over the last 3 years would seem to point towards the need to apply a 20% buffer in accordance with paragraph 73 of the NPPF 2018. This opinion was expressed by the Inspector having regard to the ‘significant under-delivery over the past 3 years’. Nevertheless, in the event that a 20% buffer is applicable, using a base date of 1 April 2018, officers consider that a 5 year housing land supply can still be demonstrated, although it should be recognised that the Inspector viewed the Council’s stance on supply as “somewhat optimistic”.

Housing mix

Policy AHN3 of the Local Plan 2018 (Part 1) sets out that proposals will be required to make provision for an appropriate range of different types and sizes of housing to meet the needs of the community, reflecting the most up to date evidence in the West Surrey Strategic Housing Market Assessment (SHMA).

Paragraph 61 of the NPPF states that the size, type and tenure of housing needed for different groups in the community should be assessed and reflected in planning policies.

The table below provides a comparison of the SHMA requirement and the proposed housing mix.

1 Bed 2 Bed 3 Bed 4 + BedSHMA 10% 30% 40% 20%MarketSite 0 (0%) 32 (17.4%) 95 (51.6%) 57 (31%)SHMA 40% 30% 25% 5%AffordableSite 20 (25.6%) 37 (47.4%) 21 (30%) 0 (0%)SHMA 20% 30% 35% 15%TotalSite 8% 31% 40% 21%

The development, having regard to the SHMA requirement, would result in an overall under provision of 1 bed units and an over provision of 3 and 4+ bedroom units.

Within the appeal decision for Land west of Folly Hill, the Inspector commented that the supporting text for Policy AHN3 of the Local Plan 2018 (Part 1) is not prescriptive and that the mix of homes should be able to react to changing circumstances to ensure that it contributes towards the needs of the wider area (the Borough) as well as a development site itself. In addition, the Inspector noted that Policy AHN3 reflects an approach which enables the market to judge the most appropriate profile of homes to deliver at any point in time.

In considering the proposed housing mix for the Land west of Folly Hill site, the Inspector noted that the appeal scheme would deliver a lower provision of one and two-bedroomed dwellings and a greater provision of four-bedroomed dwellings than the SHMA requirements. He accepted that the development responded to site-specific circumstances of being edge-of-settlement, whereas more centrally-situated proposals might be expected to have a higher proportion of one- and two-bedroomed units. In considering the mathematical shortfall in the mix of units, the Inspector was clearly mindful of a higher number of affordable units being provided which would equate to 40% of the total units (10% above Policy AHN1 requirement) and considered that this weighed heavily in favour of the proposal in terms of supporting a mixed community.

The current proposal would provide for a policy compliant level of affordable housing (30%), which will be discussed further within the next section of the

report. Notwithstanding the fact that this would differ from the 40% provision in the abovementioned appeal, rigid compliance with the SHMA was nevertheless not given complete support by the Inspector.

The proposed affordable housing mix is discussed further within the next section of this report. However, it should be noted that the mix has been put forward following negotiations with the Council’s Housing Strategy and Enabling Manager having regard to the Council’s Housing Register.

The applicant has set out within the submitted Planning Statement that the supporting text for Policy AHN3 notes the need for the mix of homes to reflect changing circumstances. In this sense, policies relating to housing mix are said to be ‘fluid’ and they need to be considered in this context. The applicant has stated that it is important that development proposals are considered in the context of the wider locality, not just the development site itself. On this basis, the applicant has reviewed schemes which have been approved in Godalming from 2016 onwards (post SHMA publication) involving the development of 5 of more units. This assessment has revealed that approvals of major development proposals in Godalming have resulted in a significant provision of one and two-bed units compared with that identified in the SHMA. It is acknowledged that this, in part, has been as a result of prior approval consents involving the conversion of office buildings to residential units. However, there are several planning permissions which include a significant amount of smaller units (Craven House, Former Batemans Laboratories and Woodside Park). The applicant has therefore put forward an argument that a reduced level of smaller units (1 bed) is justified and is an appropriate response to the context of the site and surrounding area to ensure that a balance of housing for Godalming is provided. Further, it is argued that the proximity of the site to Green Oak Primary School supports an increased provision of large units on site in order to promote more sustainable transport patterns with larger family housing being located close to key infrastructure.

Whilst noting the divergence between the proposed mix and the SHMA, Officers nevertheless consider that, on balance, the site as a whole would be reflective of the greatest requirement within the Borough being for 2 and 3 bed dwellings. Officers are of the opinion that the proposal would provide for a range of unit sizes that would go towards meeting the housing needs of the community and the mix would be acceptable in this instance.

As the proposal includes 6 self-build plots, which would be subject to their own separate planning applications, it is anticipated that there could be some very minor alteration to the mix specified in the above table. Notwithstanding this, the conclusion with regard to housing mix stated above would remain unaltered in light of the small number of units.

Affordable housing

Policy AHN1 of the Local Plan (Part 1) 2018 states that the Council will require a minimum provision of 30% affordable housing on all housing developments that meet required criteria.

There is a considerable need for affordable housing across the Borough and securing more affordable homes is a key corporate priority within the Waverley Borough Corporate Plan 2016-2019. As a strategic housing authority, the Council has a role in promoting the development of additional affordable homes to meet local housing need, particularly as land supply for development is limited. Planning mechanisms are an essential part of the Council’s strategy of meeting local housing needs.

The West Surrey SHMA 2015 indicates a high need for affordable housing in Waverley, with an additional 314 additional affordable homes required per annum. New affordable homes are needed for a broad spectrum of households in Waverley, including people struggling to get on the housing ladder and family homes, as proposed on this site.

The SHMA (2015) provides the following information with regard to the indicative requirements for different dwelling size affordable units:Unit type 1 bed 2 bed 3 bed 4+ bedAffordable 40% 30% 25% 5%

The proposal would provide for 78 affordable units within the site, which would equate to 30% of the overall housing provision in accordance with Policy AHN1 of the Local Plan 2018 (Part 1).

The proposed mix would be as follows:

Unit type 1 bed 2 bed 3 bed 4+ bedAffordable 20 (26%) 36 (46%) 22 (28%) 0 (0%)

The proposed mix has been put forward following recommendations from the Council’s Housing Strategy and Enabling Manager, having regard to the Council’s Housing Register and the identified needs of the Borough. It is considered that the proposed mix in this instance would be acceptable.

In terms of the proposed tenure, of the 78 units, 54 would be affordable rent and 24 would be shared ownership. This would comply with the SHMA, which

recommends a 70:30 tenure split of intermediate tenures and rent. The mix for each tenure would be as follows:

Unit type 1 bed 2 bed 3 bed 4+ bedAffordable Rent

12 26 16 0

Shared Ownership

8 10 6 0

With regard to the location of the affordable housing within the site, this would be as follows:

The Council’s aspiration for inclusive development and for the affordable housing to be appropriately distributed throughout the site has been acknowledged by the Applicants. Taking this into account, but also the operational requirements of the proposed Registered Providers and the advice of the Council’s Housing Strategy and Enabling Manager, Officers consider that the location of the affordable units within the site would be acceptable. Furthermore, the clusters of affordable units within the site are considered to have been appropriately balanced by a mix of shared ownership and affordable rent units in each area.

Subject to an appropriate mechanism in a Section 106 Agreement to secure the provision of the affordable housing proposed, Officers consider that the proposal would satisfactorily contribute to meeting local needs in line with the Development Plan.

Green Belt considerations

As stated previously within this report, the main part of the application site (western section) does not fall within the Green Belt. A smaller part of the application site (eastern section) is within the Green Belt outside any defined settlement area.

Policy RE2 of the Local Plan 2018 (Part 1) outlines that the Green Belt will continue to be protected from inappropriate development. Inappropriate development will not be permitted unless very special circumstances can be demonstrated.

Certain forms of development are considered to be appropriate, and will be permitted provided they do not conflict with the exceptions listed in paragraphs 145 and 146 of the NPPF.

Local planning authorities are required to give substantial weight to any harm which might be caused to the Green Belt by the inappropriate development.

It is important to note that the eastern area of the site, within the Green Belt, would serve as public open space and would be free from any residential development. The area would feature footpaths which would connect with the adjacent Public Right of Way, comprising relatively minor engineering operations.

Paragraph 145 of the NPPF 2018 gives as one of the exceptions, ‘the provision of appropriate facilities (in connection with the existing use of land or a change of use) for outdoor sport, outdoor recreation, cemeteries and burial grounds and allotments; as long as the facilities preserve the openness of the Green Belt and do not conflict with the purposes of including land within it.’

The provision of footpaths within the eastern area would, in officers’ view, provide for appropriate outdoor recreational purposes which would not result in any material harm to the openness of the Green Belt. Having regard to this, it is considered that the proposal would accord with Policy RE2 of the Local Plan 2018 (Part 1) and paragraph 145 of the NPPF 2018.

Landscape considerations

The eastern part of the site, in which public open space is proposed, is located in the AGLV. The AGLV also borders the site to the north.

Whilst the site does not fall within the AONB, it is nevertheless important to consider the wider visual impacts of the proposed development on this landscape. At its closest point, the edge of the Surrey Hills AONB is located approximately 1.4km to the west of the site.

Policy RE3 of the Local Plan (Part 1) 2018 sets out that new development must respect and, where appropriate, enhance the character of the landscape in which it is located, commensurate with its designation as a local landscape designation.

National guidance, ‘The Character of England: Landscape, Wildlife and Natural Features’, prepared by Natural England (2014) identifies the site as falling within the Wealden Greensand.

The site is identified within county guidance ‘Surrey Landscape Character Assessment Waverley Borough’ (2015). The application site falls within landscape character area ‘GO1: Shackleford Open Greensand Hills’, which has a characteristic of being ‘a rural, peaceful landscape with wooded hills beyond’. The landscape area wraps around the developed area of Godalming to the south and along the western margin up to the river, where it continues into the Borough of Guildford covering a relatively large tract of land from which the North Downs rise along its northern margin.

The application is supported by a Landscape and Visual Impact Assessment (LVIA), prepared by Landscape Visual, dated 5th July 2018.

With regard to the landscape value of the site, the LVIA concludes this to be medium, and the site and its surroundings would have a low to medium susceptibility to the proposed development. Combined, these result in the site having a medium sensitivity to the proposed development.

The development would result in a change from open agricultural land to residential development, which would mean that the effects on the on-site landscape features would be long-term and irreversible. However, the LVIA considers that with the retention and reinforcement of existing hedgerows, creation of landscape buffer zones, and planted western site boundary, the development would result in an improvement to the settlement boundary and the definition of the urban edge.

The submitted LVIA concludes that the development would result in large scale, adverse landscape effects of major/moderate significance during construction. On completion and in the longer term, the landscape effects would be large to medium in scale and of major to moderate significance. However, these effects are said to be beneficial at completion and in the long-

term due to the improvement of settlement boundaries; the onsite green infrastructure; and the implementation of a long-term landscape management plan in particular for the Valley Park. The LVIA also concludes that there would be minor beneficial effects on the landscape of the AGLV, and negligible indirect effects on the landscape of the Surrey Hills AONB.

As to visual effects, the LVIA states that the effect on the views of residents of Aaron’s Hill, users of the local footpaths and local roads would be adverse during construction but beneficial and of minor to moderate significance in the long term.

Officers have consulted the Surrey Hills AONB advisor, who has raised an objection. This view includes an in principle objection based on the release of the land from the AGLV and Green Belt. The response received states that the proposed planting and design of the buildings would be more suitable for an intensively developed urban location and that the mitigation measures would not overcome the harm to protected landscapes. In addition, it is the view of the Surrey Hills AONB Advisor that the application needs to be considered in full alongside any future plans submitted within Guildford Borough Council.

Whilst the comments of the Surrey Hills AONB Advisor are noted, Members should note that the area to be developed with houses does not form part of a protected landscape. Local Plan 2018 (Part 1) Policy RE2 released the western section of the site, on which the residential development is proposed, from both the Green Belt and the AGLV. Officers consider that it would be in breach of the CIL Regulations 122 to request an additional sum over and above that which could be justified within the Regulations. It is also important to note that the application is to be considered on its own merits and any future schemes on land adjacent to the current application site would be considered without prejudice. To request sums to support the impact of the development upon the land within Guildford Borough Council would be premature and unreasonable given this development is not before the Committee and there is no certainty in relation to this adjacent proposal at present.

Officers agree with the LVIA, and acknowledge that the proposal would introduce built form into an area of open agricultural land which would undeniably result in an irreversible change to the landscape. However, the proposed residential development would abut the existing developed area of Godalming and would visually relate to the existing residential development in this context.

Within the supporting text for Policy RE2 of the Local Plan 2018 (Part 1), the land is described as “open, arable landscape with extensive views to the north-west”. With reference to the site’s removal from the Green Belt and AGLV the subtext states, “there is opportunity to re-define the urban edge using Halfway Lane/Westbrook Lane to the north without significant intrusion into open countryside”.

On this basis, officers consider that the proposed residential development of the site would not be viewed in isolation from existing built form, but rather as a natural extension to the edge of the developed area. Notwithstanding this, the impact on site and the surrounding landscape is nevertheless a matter to be weighed in the planning balance.

Design and impact on visual amenity

Policy TD1 of the Local Plan (Part 1) 2018 requires development to be of high quality design and to be well related in size, scale and character to its surroundings. Retained Policies D1 and D4 of the Local Plan 2002 are attributed substantial and full weight respectively due to their level of consistency with the NPPF 2018.

As part of the pre-application process, the Applicants engaged with Design South East to seek an independent paneled assessment of the proposed design approach. The outcome of the advice received was largely supportive subject to amendment. These have been taken on board by the developer in the evolution of the scheme.

Layout:

The scheme has been designed in such a manner so as to have three distinct areas of character filtering off for a central spine road. On the western boundary of the site there would be a village green and community building positioned adjacent to a row of trees. Surrounding the site to the west and north would be a greened trail which would include pedestrian and cycle pathways. To the south east, the existing green space would be utilised so as to provide an accessible park and improved pedestrian and cycle access to the station. Throughout the site, there would be a number of pedestrianised paths and ‘green fingers.’ The green finger approached is emphasised by the use of landscaping throughout the scheme including the planting of trees and hedgerows to add interest.

The vehicular access to the site would be through Aarons Hill with the spine road running in a predominately west to east direction. On entrance views towards the new ‘village green,’ community building and play area would be

enjoyed. As the site is transitioned from west to east there would be a number of roads filtering off predominately to the north and south. The design of these routes, including the main street, provides pinch points for interest and allows for permeability of the site. The layout of the site is therefore considered to be appropriate to the size of the site, in that it provides a good design standard whilst providing a good degree of functionality.

Design:

The design approach to the scheme is one which has taken inspiration from a number of buildings and areas in the town of Godalming, most notably the High Street. The result of such a design approach is for the development to be characterised by three distinct areas.

Southern Mews

To the south of the main street ‘The Southern Mews’ would be reflective of the historic terraces development that exists within Godalming and more locally within Aarons Hill. This area would have the highest density of all of the areas, reflective of its position immediately adjacent to the existing built form of Aarons Hill.

The design approach is reflective of a typical Mews development where in there is a blending between vehicular and pedestrian access including the use of similar materials and a variety of parking strategies including parking in front of dwellings and to the side. In some instances parking courts would be used to provide space. Pergolas and planting have been included in the parking courts to soften the inevitable amount of hardstanding.

Architecturally, the buildings are reflective of their terraced nature and include rows of 4 to 5 dwellings. The design approach is one that is reflective of its context within Godalming including changes of form to create interest on corners of roads. Whilst the pattern is reflective of the historic environment a number of contemporary features such as materials and fenestration details have been included to prevent the scheme appearing as a pastiche of Godalming.

The Field Edge

To the north of the main street, the density of the building would reduce and continue to peter out as it approaches the countryside beyond. The result of which is to create a softer edge to the landscape beyond than that which exists at Aarons Hill. Throughout the area there would be a number of ‘Green Fingers’ that provide linear green access and views to the landscape beyond.

These fingers would also incorporate the “play along the way” facilities reflecting the more pedestrianised and less dense philosophy of the distinct area.

Architecturally, the area is characterised by semi-detached and detached units. Again the design of these units is reflective of the Godalming area and has been designed in such a manner to create areas of visual interest. The units would also utilise contemporary detailing linking it to the Southern Mews area. The materials in both areas would be similar, but include variations so as to not result in an over concentration of one material preventing the scheme from appearing monotonous

The Woodland Edge.

The final distinct character area is positioned to the east of the site, the backdrop of which is the woodland on the other side of the bridleway and the proposed park. To be reflective of these landscape characteristics, the units would be noticeably different to the other areas of the development.

The difference is most evident in the proposed use of timber cladding as opposed to brick as the main external surface. The dwellings in these areas are of the lowest density and are positioned in such a manner so as to integrate them with the woodland and landscape contours. The result of such an approach has meant that some of the units are three storey as they include a lower ground level as the contours of the land slopes away towards the south east.

The form of these units is somewhat reflective of the Surrey agricultural vernacular allowing the development to transition from its edge of settlement location to the landscape constraints to the east.

Landmark buildings

Throughout the site there would be a number of landmark buildings. These would be at the entrance to the site and in the form of the flatted development. The buildings would act as gate ways to the areas of the site.

In place of the two properties in Aarons Hill proposed for demolition, a pair of semi detached units is proposed. These buildings would flank the entrance providing a clear indication of the transition from Aarons Hill and the development site. The area would also benefit from improved landscaping at the existing grassed island drawing the site into the wider community. Whilst these buildings would appear opposed to the surrounding properties it would

be a welcome juxtaposition that would also enable the area to be integrated with the more traditional properties to the south of Eashing Lane.

Within the site to both the north and the south of main street there would be a total of four building containing flats. These flats are ‘L’ shaped in form and together form a square. These flats would also coincide with the pinch points along the main street resulting in wayfinding markers or architectural interest.

The flats in themselves would be well designed and well proportioned so as to not over dominate the area. Architecturally, they fit well with the surrounding development.

Overall the development is considered to be of a high quality design that responds well within its distinct areas. Through taking inspiration from the wider architectural and landscape topography of the area, the scheme would relate well to the Godalming area. It would provide a transition between Aarons Hill/Eashing Lane and the landscape beyond, softening the edge of the settlement as the density peters out. Architecturally, the design is considered to be appropriate for its setting reflecting contemporary design features within traditional form.Street furniture

In terms of street furniture, timber would be the primary material used. Traditional timber seats and timber clad bins would be provided within the village green and areas of open space. Timber picnic benches are proposed within the community garden and village green, and tree logs are proposed to provide informal seating at regular intervals in areas of open space. In addition to the timber, bicycle and scooter racks would be provided outside the proposed community building and within the community garden area.

Boundary treatment

In terms of boundary treatment, a variety of different treatments are proposed to suit each particular area within the site. To the north of the site, adjacent to Halfway Lane, the existing hedgerow would be strengthened in areas where there are existing gaps. The same would apply to the north eastern section of the site down to Footpath 277. Low estate-style fencing, comprising metal posts and railings, would be erected along the western site boundary and there would be timber picket-style fencing adjacent to the community garden area. Internally, the residential units would be demarcated using a mixture of 1.8m high close boarded fencing and 2m high brick walls to match the dwellings. The rear of the parking areas would feature 1.8m high ‘green screen’ fencing.

Hard landscaping

The site would feature areas of shared surface block paving and asphalt streets. The central spine road would be dark in colour; however the secondary streets and pathways within the open space to the east of the site would be light in colour. Private driveways and other parking areas would feature permeable block paving to contrast with the roadways. Entrances to the dwellings would also be paved, with clay bricks to match the materials used in the external surfaces of the dwellings.

Overall, officers are satisfied that the proposed hard landscaping approach within the site would be acceptable. It would be important to secure samples of the proposed materials by means of a planning condition should permission be granted to ensure they would be of a high quality and appearance.

Lighting scheme

The supporting documents acknowledge the sensitive positioning of the development, on the edge of surrounding open farmland. As such, it is proposed that, if permission is granted, lighting would be focused around the main streets within the site, with low level lighting to perimeter paths. Some of the key trees which are proposed to be planted along the main street would feature uplighters.

Overall, officers are satisfied that the proposed lighting approach would be acceptable. However, it would be important to secure full details of the lighting specification by means of a planning condition should permission be granted. Impact on residential amenity

Policy TD1 of the Local Plan (Part 1) 2018 seeks to ensure that new development is designed to create safe and attractive environments that meet the needs of users and incorporate the principles of sustainable development. Retained Policies D1 and D4 of the Local Plan 2002 are given substantial and full weight respectively due to their consistency with the NPPF 2018.

The site would adjoin existing residential development within Aarons Hill to the south. The majority of existing properties adjacent to the southern site boundary run south to north, resulting in their rear amenity gardens backing on to the development site. Having regard to this orientation and separation distance between built form, it is considered that the proposed residential development to the north of existing dwellings would not result in any material loss of light to the properties and would not appear materially overbearing.

Existing properties along Field View Cottages (Nos. 3 & 6), which is perpendicular to Aarons Hill, would have northern gable ends facing onto the development site. Whilst this is the case, there are no primary windows in these elevations, and officers are satisfied that there would be no material harmful impact to the occupants of these properties.

It is acknowledged that the greatest impact of the development proposal would be to the private amenity gardens serving properties along Aarons Hill. Owing to the design approach of back to back gardens, there would be a resultant degree of overlooking to these areas. However, the relationship of having back to back gardens is not an uncommon feature within residential developed areas. Furthermore, officers consider that the resultant impact would not result in material loss of privacy harm which would warrant an objection to be raised.

The potential impact to neighbouring occupiers of the site by means of noise is discussed within the ‘Noise’ section of this report.

Highways considerations

Policy ST1 of the Local Plan 2018 (Part 1) states that development schemes should be located where it is accessible by forms of travel other than by private car; should make necessary contributions to the improvement of existing and provision of new transport schemes and include measures to encourage non-car use. Development proposals should be consistent with the Surrey Local Transport Plan and objectives and actions within the Air Quality Action Plan. Provision for car parking should be incorporated into proposals and new and improved means of public access should be encouraged.

The application is supported by a Transport Assessment, prepared by i-Transport, dated 6th July 2018.

Site Access

Vehicular access to the site would be provided via Aarons Hill, using land currently occupied by Nos. 19 and 21 Aarons Hill which would be demolished as part of the proposal. The access would comprise a priority junction with a 5.5m wide access arm and 2.4m x 43m visibility splays to the east and west as set out in the plan below:

The submission sets out that the proposed site access point has been the subject of a Stage 1 Independent Road Safety Audit by Surrey County Council.

Pedestrian access points will be provided by footways adjacent to the vehicular access and via footpaths off the public rights of way. An emergency access point is to be provided to the north of the site onto Halfway Lane. Swept path analysis has confirmed that the site can be accessed by refuse and emergency vehicles.

Traffic generation

The Transport Assessment sets out that a comprehensive suite of traffic surveys have been undertaken in order to obtain an understanding of the existing highway conditions on the local highway network. This includes parking surveys to establish parking demands and a review of accident data.

Census data is said to confirm that a high proportion of local residents already use non-car modes to travel to work in the Godalming, Guildford, Woking and London areas. A significant proportion of existing residents also use rail travel.

It is conveyed that the proposed development would generate around 145 peak hour two-way movements during the weekday network peak hours. This

would equate to an additional vehicle every two to three minutes within the local highway network.

Any increase in queuing and delay arising from the development is stated to be modest, falling well below what might constitute a ‘severe’ impact having regard to paragraph 109 of the NPPF. It is concluded that the proposal would not result in any material impact on the safety or operation of the local highway network during peak hour periods. Notwithstanding this, as part of the proposal, a package of highway improvements is proposed which aim to minimise traffic impact and enhance road safety.

Highways improvement package

The following highway improvements are proposed as part of the current application:

A283/Eashing Lane junction – a flared approach to the junction to separate right and left turners is proposed, together with a left-turn diverge lane which would enable traffic turning out of Eashing Lane to distinguish between ahead and left turning eastbound traffic.

A3100 Portsmouth Road/Eashing Lane junction – parking restrictions are proposed to ensure that the junction is not obstructed by parking.

A283 approaching Milford (west of Eashing Lane) – introduction of gateway features at the change of speed limit.

Reduction in speed limit on the straight section of Eashing Lane from national speed limit to 40mph and introduction of gateway features at the change of speed limit.

Replacement of white lining on the straight sections of Eashing Lane with white edge markings.

Speed reducing features on Eashing Lane within the 30mph section, including repeater signs, roundels and visual narrowings.

Formalisation of car parking on Eashing Lane and creation of prohibited parking stretches to create gaps to allow vehicles to pass oncoming vehicles.

Safety enhancements at the road under the rail bridge on Westbrook Road.

Overall, the Assessment concludes that in conjunction with the off site mitigation strategy by way of infrastructure contributions the development would not result in material harm to the highway network. The site is confirmed to be in a sustainable location transport-wise.

The County Highway Authority has reviewed the proposal and submitted documents and has raised no objection, subject to the securing of financial contributions, S278 works, conditions and informatives on any grant of permission.

The County Highway Authority is satisfied that the proposed access and movement strategy would enable safe and suitable access to the site for all users. Further, the submitted traffic impact assessment undertaken by the Applicant is considered to provide a robust and realistic assessment of the likely impact of the development on the local highway network. In line with good practice, it is noted that the submitted Transport Assessment assesses the ‘worst case’ morning and evening peak hours. This is considered to be fit-for-purpose in terms of assessing the likely impact.

The package of mitigation measures to mitigate the impact of the traffic generated by the proposed development would, in the County Highway Authority’s opinion, improve accessibility to the site by non-car modes of travel and contribute to wider infrastructure requirements in Godalming. This would

satisfactorily address the cumulative impact of the proposal and other developments in Godalming.

Parking

The NPPF supports the adoption of local parking standards for both residential and non-residential development. The Council has adopted a Parking Guidelines Document which was prepared after the Surrey County Council Vehicular and Cycle Parking Guidance in January 2012. Policy ST1 of the Local Plan (Part 1) 2018 states that development schemes should have appropriate provision for car parking. Development proposals should comply with the appropriate guidance as set out within these documents.

The Council’s Parking Guidelines set out the following requirement:1 bed unit 1 parking space2 bed unit 2 parking spaces3+ bed unit 2.5 parking spaces

The application proposes a total of 585 parking spaces, this would be a total provision of 20 spaces for the 20 one beds, 162 spaces for the 81 two beds, and 403 spaces for the 161 3+ bed properties. This would provide sufficient parking to accord with the Council’s Parking Guidelines. The Guidelines would be met.

The scheme would provide for two car club spaces, which would be secured through a S106 Agreement. It is proposed that one car club vehicle would be provided by the developer at the development prior to first occupation of the residential units, and its use would be monitored to assess the demand for a second vehicle. The supporting documents set out that future residents of the site would receive three years free membership to the car club and a £50 ‘drive time credit’ in order to encourage use of the scheme. This would be secured as part of a S106 Agreement should permission be granted.

In addition to vehicular parking, bicycle and scooter racks are proposed outside the community building and within the community garden. The proposal would provide for in-curtilage cycle parking in the form of spaces within garden sheds and/or garages. The flatted buildings would be provided by secure, sheltered cycle parking within or close to the blocks. The number of spaces would accord with the County Council guidance of 1 space per 1-2 bed unit and 2 spaces per 3+ bed unit.

Electric vehicle charging

Surrey County Council’s Vehicular and Cycle Parking Guidance (January 2018) sets out the three speeds currently available for electric vehicle charging – trickle (3kw), fast (7kw) and rapid (40kw+). New styles of charging units, for example wall mounted units, are set out to have increased the ease with which they can be integrated into new housing development. The Guidance sets out the following requirements:

Dwellings 1 fast charge socket per house – 7kwFlats/Apartments 20% of available spaces to be fitted

with a fast charge socket – 7kw

The current proposal would provide for the following: 133 trickle charging and 53 fast charging points to serve dwellings – to

be provided within a driveway or garage 1 trickle charging point per 5 flats (equivalent to 20%, total of 9 points)

– to be provided within communal car parking area 2 fast charging points for the car club spaces next to the community

building 11 fast charging points on visitor spaces throughout the site TOTAL – 208 EV charge points (75 fast charge and 133 trickle charge)

This approach would be fully compliant with the County Council’s Guidance in respect of the provision of charging points for the flatted buildings. However, the charging points for dwellings would primarily be trickle, and not all fast charge, which Officers acknowledge would not accord with the Guidance. The Council’s Environmental Health Officer (Air Quality) has also raised this.

Whilst this is the case, the County Highway Authority has reviewed the proposed electric vehicle charging strategy and has advised that they consider the approach to be acceptable in this particular instance on the following basis:

Trickle charging will be sufficient for most users – with a residential use, vehicles will tend to be parked overnight and therefore will be trickle charged.

Trickle charging is also particularly suitable for cars that are not used on a daily basis, i.e. those owned by rail commuters.

Having a series of fast charging points for unallocated spaces around the site will allow those who occasionally need to fast charge to have appropriate access to a fast charging point.

Notwithstanding the views expressed by the County Highway Authority, the Council’s aspiration for development proposals to include fast charge points for all dwellings has been conveyed to the Applicant.

The applicant has set out the following comments in respect of why the level of electric vehicle charging has been proposed in this instance:

The current number of light-duty electric vehicle registrations in the UK totals circa 180,000; in comparison, the number of cars registered in the UK is 31,000,000, equating to some 0.58% of the fleet (Society Motor Manufacturers and Traders, September 2018). Assuming an average car ownership on the site of 1.5 per dwelling for 262 dwellings, this rounds up to three (2.2) electric vehicle on the site. By 2025, it is estimated that only 8% of the UK car fleet could be electric vehicles, and even in 22 years’ time when the ban on the sales of new petrol and diesel cars is to be introduced, we will still be some way off a fleet comprising entirely of electric vehicles. Effectively, providing fast charging at all properties would result in the provision of infrastructure that would be likely to lie dormant for years, if not decades. During this time, given that investment in technology in this sector is likely to be significant, it’s highly likely that advances in technology would render such provision obsolete. Providing fast charging at all properties would also significantly increase the required electrical capacity, and therefore the infrastructure required to accommodate such provision. However, given the limited number of registrations in the UK, there is not enough data on usage patterns for electricity providers to establish appropriate peaking factors, so they err on the side of caution. Again, with advances in technology, means to balance potential peaks in demand will also develop (and many measures are already developing, such as smart meters etc.) and it is unlikely that the peak demands forecasted today will actually be realised. Therefore, providing for such capacity would be a significant overprovision of infrastructure. Whilst the need to ‘future proof’ the development is recognised, this doesn’t mean that 100% capacity of fast charge should be provided at the outset. The approach proposed provides an appropriate and proportional infrastructure for both the current time and immediate future of electric vehicles. It provides any owners of electric vehicles the facility to charge their vehicle (noting that evidence suggests that typical EV owners chargers less than twice a week and rarely from empty to full at any time). Importantly, it enables the infrastructure to be adapted as the technology in the electric vehicle sector develops – electrical connections in the form of trickle chargers will be provided at the outset, which is often the most prohibitive element of

provision. Grants, such as the Electric Vehicle Homecharge Scheme are available to enable homeowners to upgrade provision to suit their personal needs, thus resources are used to deliver targeted demand rather than blanket coverage, which could quickly become obsolete.

The applicant is therefore of the opinion that the provision should be considered in two parts (1) to respond and address current needs and (2) to ensure that ‘future proofing’ is embedded into the scheme to ensure improvements in technology.

Having carefully considered the submission and views of statutory consultees, Officers consider that the provision of electric vehicle charging points, as proposed, would be acceptable in this instance. However, it is considered reasonable to impose a condition on any grant of planning permission to secure the implementation of the charging points prior to the first occupation of the development.

Self build provision

The Council has a statutory responsibility to maintain a register of individuals and associations seeking land to construct a self or custom build house for use as their primary residence. Based on this register, the Council is required to grant sufficient permission to meet demand. In order to achieve this, the Council is proposing a policy in its emerging Local Plan Part 2 which will require development proposals of 20 or more dwellings (net) to make at least 5% of plots available for sale to self or custom builders.

Having regard to the Council’s statutory obligation, it is considered that the provision of self build plots forms a highly material planning consideration and the Council is well placed to require an element of self-build on development proposals.

The proposal would provide 3% of the private plots as self build plots, which would equate to 6 units within the site. These plots would be subject to their own separate planning applications in respect of the proposed housing type and design. It is proposed that they be located in the following areas:

The applicant has set out that, whilst the provision would be less than that proposed within the emerging Local Plan Part 2, as part of the planning balance it reflects the relatively low number of individuals on the Council’s register, the characteristics of the site and its suitability in principle for the development of self-build units.

The level of demand for self build and custom housebuilding in Waverley is established by the number of entries added to the Council’s Register during a base period. At the end of each base period, the Council has 3 years in which to give an equivalent number of planning permissions to plots of land suitable for self-build and custom housebuilding, as there are entries for that base period.

Having regard to the first base period of 1 January 2016 – 30 October 2016, the Council needs to grant permission for 12 self build units by 30 October 2019.

Officers consider that the provision of 6 self build plots (3% of proposal) within the application site would be a considerable benefit to the proposal which should be weighed in the planning balance.

Heritage considerations

Section 66 of the Planning (Listed Buildings and Conservation Areas) Act 1990 states that in considering applications which affect Listed Buildings, Local Planning Authorities must have special regard to the desirability of preserving the building or its setting or any features of special architectural or historic interest which it possesses.

Section 72 of the Planning (Listed Buildings and Conservation Areas) Act 1990 states that in considering applications within a Conservation Area, Local Planning Authorities must pay special attention to the desirability of preserving, or enhancing the character and appearance of the area.

Retained Policy HE8 of the Local Plan 2002 is afforded substantial weight due to its level of consistency with the NPPF and seeks to ensure that the development preserves or enhances the character of Conservation Areas.

Policy HA1 of the Local Plan (Part 1) 2018 outlines that the Council will ensure that the significance of heritage assets are conserved or enhanced to ensure the continued protection and enjoyment of the historic environment. Retained Policies HE3 and HE5 of the Local Plan 2002 are afforded significant weight owing to their consistency with the NPPF 2018.

Paragraph 189 of the NPPF 2018 states that ‘Local Planning Authorities should require an applicant to describe the significance of any heritage assets affected, including any contribution made to their setting. The level of detail should be proportionate to the assets’ importance and no more than is sufficient to understand the potential impact of the proposal on their significance’.

Paragraph 190 of the NPPF states that ‘Local Planning Authorities should identify and assess the particular significance of any heritage asset that may be affected by a proposal (including by development affecting the setting of a heritage asset) taking account of the available evidence and any necessary expertise. They should take this assessment into account when considering the impact of a proposal on a heritage asset, to avoid or minimise conflict between the heritage assets conservation and any aspect of the proposal.

The NPPF defines ‘significance’ as the value of a heritage asset to this and future generations because of its heritage interest. That interest may be archaeological, architectural, artistic or historic. Significance derives not only from a heritage asset’s physical presence, but also from its setting.

Paragraph 192 of the NPPF states that, ‘in determining planning applications, local planning authorities should take account of the desirability of sustaining and enhancing the significance of heritage assets and putting them to viable uses consistent with their conservation; the positive contribution that conservation of heritage assets can make to sustainable communities including their economic vitality; and the desirability of new development making a positive contribution to local character and distinctiveness’.

Paragraph 193 of the NPPF states that, ‘when considering the impact of a proposed development on the significance of a designated heritage asset, great weight should be given to the asset’s conservation. The more important the asset, the greater the weight should be. This is irrespective of whether any potential harm amounts to significant harm, total loss or less than substantial harm to its significance’.

As conveyed within paragraph 194 of the NPPF, significance can be harmed or lost through alteration or destruction of the heritage asset or development within its setting. As heritage assets are irreplaceable, any harm or loss should require clear and convincing justification. Substantial harm to or loss of, inter alia, a Grade II listed building or Grade II registered parks or gardens should be exceptional.

Paragraph 195 of the NPPF states that ‘where a proposed development will lead to substantial harm to or total loss of significance of a designated heritage asset, local planning authorities should refuse consent, unless it can be demonstrated that the substantial harm or total loss is necessary to achieve substantial public benefits that outweigh that harm or loss, or all of the following apply:

The nature of the heritage asset prevents all reasonable uses of the site; and

No viable use of the heritage asset itself can be found in the medium term through appropriate marketing that will enable its conservation; and

Conservation by grant funding or some form of charitable or public ownership is demonstrably not possible; and

The harm or loss is outweighed by the benefit of bringing the site back into use.

Paragraph 196 states that ‘where a development proposal will lead to less than substantial harm to the significance of a designated heritage asset, this harm should be weighed against the public benefits of the proposal, including securing its optimum viable use.’

The NPPG 2014 (as updated) provides guidance under the Section titled ‘Conserving and Enhancing the Historic Environment’. Whilst this is not a policy document, it does provide further general advice to policies in the NPPF.

Pursuant to the decision of the High Court in Barnwell Manor Wind Energy, the Decision Maker should give considerable importance and weight to the preservation of the setting of the Listed Building. If the harm is found to be less than substantial, it does not follow that the S66 duty can be ignored, although this would lessen the strength of the presumption against the grant of planning permission.

Pursuant to the decision of the Court of Appeal in Forge Field Society, the finding of harm to the setting of a Listed Building or a Conservation Area gives rise to a strong presumption against planning permission being granted. If harm is identified then the decision maker should acknowledge that there is a presumption against permission.

The definition of ‘heritage asset’ in the NPPF includes a Listed Building and a Registered Park and Garden.

Whilst the site does not contain any designated heritage assets, there are a number of Grade II listed properties towards and within the centre of Godalming, to the north-east and east of the site. Meath Home (Grade II) and The Little Fort (Grade II) are the closest of these heritage assets to the east of the site, being located approximately 160m and 370m respectively to the north-east of the site. Having considered the separation distances, intervening topography and woodland, Officers consider that there would be no resultant harm to their significance arising from the development proposal.

Godalming Conservation Area and the Ockford Road Conservation Area are located 230m and 100m away from the application site respectively, on the eastern side of the railway line. Officers consider that the proposal would not result in any harm to these areas, given the separation distance and visual disconnection with the site.

Westbrook House is a Grade II* listed property located approximately 210m to the north of the site. The surrounding garden is Grade II listed in its own right. The significance and impact on this heritage asset will be discussed later within this section.

There are also a number of Grade II listed properties and Scheduled Monuments including an Anglo-Saxon fort and a historic double bridge, Eashing Bridges, (which is Grade I Listed), falling within the neighbouring

Borough of Guildford to the west of the application site. Officers consider that the neighbouring Borough’s Grade II listed properties and Anglo-Saxon fort are sufficient distance from the development proposal, such that there would be no resultant harm to their significance. It is noted that third parties have referred to the impact on Eashing Bridge within their representations and the significance of, and impact to, this heritage asset will be discussed later within this section.

The application is supported by the following documents: Letter dated 30th November 2018, prepared by CgMs Heritage –

setting out the Applicant’s response to Historic England comments Supplementary Built Heritage Clarification Statement, prepared by

CgMS Heritage, dated 1st October 2018 Built Heritage Statement, prepared by CgMS Heritage, dated July 2018

These supporting documents conclude that, having considered the significance of the listed Westbrook House and its registered park and garden, including setting contribution, the development proposal would likely have a harmful effect on the significance of these heritage assets. However, the effect is concluded to not be more than a minor-to-moderate level of less than substantial harm. It is concluded that this identified harm should be weighed against the public benefits of the scheme, as set out in the supporting planning statement.

Historic England has reviewed the proposal and has identified a degree of harm to the Grade II* listed Westbrook and its associated Grade II listed garden. The degree of harm identified is concluded to be less than substantial. The Local Planning Authority is advised that harm must be fully justified in NPPF terms and the scheme only permitted if public benefits exist that would outweigh the harm. It is Historic England’s opinion that the submitted heritage statement has inadequately assessed both Westbrook’s significance and setting. It is noted that the submissions are largely desk-based assessments and Historic England consider it regrettable that they have been produced without visiting Westbrook and its garden. On this basis, Historic England is of the view that the supporting documentation is unable to fully articulate the likely impact of the development proposal on Westbrook and its garden. In accordance with this, Historic England has commented that the applicant has not complied with the requirements of paragraph 189 of the NPPF.

The Council’s Historic Buildings Officer shares the view of Historic England and has commented that the supporting documentation shows little evidence

of having visited Westbrook, and incompletely and poorly describes the significance of the designated heritage asset.

Officers, having carefully considered the abovementioned expressed views of consultees, are in agreement that the Applicant has not sufficiently complied with the requirements of paragraph 189 of the NPPF. Officers are aware that the Applicant has not visited Westbrook and its associated gardens and the submitted statement is incomplete in terms of its ability to define the significance of the heritage asset. In order to ensure full procedural compliance with paragraph 189 of the NPPF, it is Officers understanding that the applicant intends to submit a further heritage statement prior to the Council’s Committee meeting.

Notwithstanding this, and having regard to paragraph 190 of the NPPF, the Council’s Historic Buildings Officer and Principal Planning Officer having visited Westbrook and its associated garden, are in a position to set out the significance of the designated heritage asset and undertake the required assessment as to the impact of the development proposal on this significance.

Westbrook was built in 1899 by the architect Hugh Thackeray Turner for his own family occupation. He was the first secretary of The Society for the Protection of Ancient Buildings. The house is Grade II* listed (which places it among the most important 6% of all listed buildings). The garden, which Turner designed in collaboration with Gertrude Jekyll is registered Grade II. Much of the carved and modelled decoration within the house is likely considered to be the work of Turner’s brother Laurence, a distinguished craftsman/sculptor as well as an architect in his own right.

The house, including its interior, and garden together are an important example of the Arts and Crafts principles of design. The ensemble is highly significant, even in a Borough famed for its Lutyens/Jekyll collaborations. Much of the garden layout survives, and the original division into linked outdoor “rooms” and vistas is clearly evident. There is, however, also a clear and intentional link with the countryside beyond with the belvedere platform that was intended to give panoramic views across the farmland to the hills beyond.

The upper floors of the house give further generous views across the surrounding countryside. These are enjoyed, not only through the larger windows, but also through tiny casements located with the sole purpose of affording extra glimpses across the wider landscape. It is a house intended to celebrate outward views, both if its own domain but of the wider rural setting.

The Council’s Heritage Officer has referred to Westbrook as being a ‘jewel-like country house in miniature, rather than a mere handsome suburban villa indifferent to its setting’.

With regard to the impact of the proposal on the significance of the heritage asset, it is considered that the experience of Westbrook itself would be affected by changes in outward views which informed its design. The introduction of the proposed residential built form, and associated lighting, would be visible from the heritage asset and, in this manner, would intrude on the essential rural views afforded from there. To this end, the rural setting of this important country house would be diminished and the significance of the designated heritage asset would be harmed.

The Council’s Historic Buildings Officer is in agreement with Historic England, that the level of resultant harm to the significance of the designated heritage asset would be less than substantial. In accordance with paragraph 196 of the NPPF, this identified harm should be weighed against the public benefits of the proposal. This assessment will be carried out below.

With regard to the impact to Eashing Bridges, the Council’s Historic Buildings Officer has commented that they are of 13th Century origin and their Grade I listing emphasises their importance. However, it is considered that the setting of the bridge would not be affected so directly as that of Westbrook. In considering the volume of traffic along the narrow lanes in the area and the bridge itself, Officers would comment that construction related traffic and means of access to and from the site could be appropriately conditioned on any grant of permission, to secure the appropriate controls. It is considered that the proposal would not materially harm the setting or structure of the bridge.

The Applicant has put forward the following public benefits within supporting documents:

The provision of 262 homes The provision of 78 affordable homes (policy compliant at 30%) in an

area of severe affordable housing need Investment in an identified Priority Neighbourhood for Regeneration The provision of 4 hectares of Public Open Space Over £1m in transport improvements £500k towards open space and environmental improvements Education contributions Supporting the vitality and viability of Green Oak School through the

additional child yield associated with the proposed development Ecological contributions and enhancements

£500,000 per year in Council Tax revenue £1.37m New Homes Bonus £3.5m in local spend to support the vitality of Godalming Town Centre

In considering the weight which could be afforded to the abovementioned planning benefits, Officers have had regard to an appeal decision dated 31st March 2016 (Ref: APP/R3650/W/15/3129019) in relation to a site within the Waverley Borough (village of Cranleigh), in which the Inspector concluded that, when considering the planning balance, weight should not be attributed to anything that would merely mitigate the impacts of a development.

Paragraph 72 of the appeal decision reads, “I have found the proposal to be acceptable on the grounds of its highways and transport impacts, as well as acceptable on the basis that the contributions secured through the planning obligation would mitigate the infrastructure pressures brought about it by a development of this scale. The absence of harm on these points does not add to the case for the development nor tell against it. The weight to be attached to these matters is neutral”.

Paragraph 80 of the appeal decision adds, “The financial contributions towards open space, education and improving the Downs Link arise largely from the need to mitigate the effects of the development. Such matters do not weigh in favour of it”.

In this context, officers consider that weight could not be afforded to the fact that the proposal would provide financial contributions towards open space, environmental improvements, ecology and education.

Section 70 subsection 2 of the Town and Country Planning Act 1990 (as amended) states that local financial considerations are a matter to which local planning authorities must have regard in determining planning applications, so far as they are material to the application. Local financial considerations are defined as grants from Government or sums payable to the authority under the Community Infrastructure Levy (CIL). This means that the New Homes Bonus (NHB), which is Government funding that matches Council Tax receipts from new homes, is capable of being a material consideration where relevant. However, the New Homes Bonus is at best a modest contribution to the Council’s general finances, and is something to which very limited weight is given.

In terms of the highway improvements, the County Highway Authority has confirmed that the requested financial contribution towards improvements to the A3100 corridor through Godalming would go over and above that which

would be required to mitigate the impact of the development proposal alone. The development is required to provide a contribution towards the proposed improvements; however the amount which the Applicant has agreed to pay would go over and above that which is required. All other highway contributions are considered necessary to make the proposal acceptable in planning terms. It is considered that weight can therefore be afforded to the public benefit arising from the proposed A3100 corridor improvements.

Officers consider that the proposal would deliver local economic gains from a number of sources, including construction-based employment and increases in local spending. The provision of public open space would comprise a public benefit, and there would be notable social public benefits in terms of the delivery of a considerable number of new dwellings, including affordable homes for which there is a recognised need within the Borough.

The weight to be attributed to the delivery of market and affordable housing within the Borough is considered to be significant. In weighing the identified public benefits against the identified harm, Officers are of the view that the public benefits of the proposal would be sufficient to outweigh the less than substantial harm to the designated heritage asset in accordance with paragraph 196 of the NPPF 2018.

Standard of accommodation

Policy TD1 of the Local Plan (Part 1) 2018 seeks to maximise the opportunity to improve the quality of life, health and well-being of current and future residents through, inter alia, appropriate internal space standards for new dwellings.

The Government’s policy on the setting of technical standards for new dwellings is set out in the Ministerial Statement of 25th March 2015.This statement should be taken into account in applying the NPPF. New homes need to be high quality, accessible and sustainable.

The Council does not have a current Local Plan Policy that allows it to require compliance with these standards. A policy is proposed within Draft Local Plan Part 2 (Policy DM3: Safeguarding Amenity) which would secure new housing developments to provide adequate internal and external space to ensure appropriate living environments for future occupiers, in accordance with the Technical Housing Standards. However, at present, very limited weight can be afforded to Local Plan Part 2 Policies.

Nevertheless, the standards provide useful guidance which assists in the assessment of new development. Further, notwithstanding the very limited

weight afforded to Local Plan Part 2, Officers have advised the Applicants of the Council’s aspiration for development proposals to fully accord with the Technical Space Standards.

The proposal would provide for the following:

Market UnitsHouse Type

No. of units in site

Bed No. and Person No.

Technical Space Standard

Proposed floorspace

Does it accord?

A (1-4) 32 2 bed, 4 per 79 83.95

B (1-2) 22 3 bed, 5 per 93 95.75

C (1-4) 33 3 bed, 5 per 93 101.65

D 9 3 bed, 6 per 102 107.32

E (1-2) 15 3 bed, 5 per 93 111.45

F (1-2) 2 3 bed, 5 per 93 106.02

G (1-2) 2 3 bed, 5 per 93 108.44

H (1-2) 8 4 bed, 6 per 106 122.37

I (1-2) 8 4 bed, 6 per 106 121.66

J (1-2) 8 4 bed, 5 per 97 120.42

K 2 4 bed, 7 per 115 130.66

L (1-3) 9 4 bed, 7 per 115 135.49

M (1-2) 16 4 bed, 7 per 115 139.28

N 2 5 bed, 9 per 128 166.89

O 4 5 bed, 9 per 128 174.46

P (1-2) 12 2 bed, 4 per 79 80

Affordable UnitsHouse Type

No. of units

Bed No. Technical Space Standard

Proposed floorspace

Does it accord?

1-1 9 2 bed, 4 per 79 80

1-2 3 2 bed, 4 per 79 80

2-1 5 3 bed, 5 per 93 95.75

2-2 8 3 bed, 5 per 93 95.75

B-2 6 3 bed, 5 per 93 95.75

3 2 3 bed, 5 per 93 101.65

Apartment Block

2025

1 bed, 2 per2 bed, 3 per

5061

50.05 – 52.3962.52 – 67.10

As set out in the tables above, all of the proposed units (market and affordable) would comply with the Technical Space Standards, which Officers consider to be a significant merit of the proposal.

One of the key design features of the proposal is the use of large and feature windows, the result of which is that the proposed dwellings would benefit from a sufficient light and outlook, which officers consider would result in an attractive living environment for future occupiers.

Provision of amenity space

Policy LRC1 states that proposals for new residential development will be expected to make provision for play space in accordance with the Fields in Trust (FIT) standard. For the size of the development proposed, the FIT Benchmark guidelines sets out a requirement of an on-site Local Area of Play (LAP), Local Equipped Area for Play (LEAP) and a Multi Use Games Area/skate park (MUGA).

Policy TD1 of the Local Plan 2018 (Part 1) states that development should maximise opportunities to improve the quality of life and health and well-being of current and future residents. Specifically, these should be opportunities for:

private, communal and public amenity space; appropriate internal space standards; and on site playspace

A LEAP would be provided within the western section of the site in close proximity to the village green and community building. In addition, LAPs would be placed throughout the site and there would also be a play trail provided along the northern site boundary. The submitted Design and Access Statement states that the facilities to be provided within this trim trail area would take reference from the Aldous Huxley’s children’s book The Crows of Pearlblossom. Officers consider this to be a positive design approach and the space provided to be sufficient to meet the LEAP and LAP FIT guidance. The positioning of the playspace areas within the site would be such that natural surveillance would be afforded and they would be accessible to future occupants of the site as well as residents in the wider area. The management of the proposed play areas would be via a Management Company and this would be secured as part of a S106 Agreement should permission be granted.

The proposal would not provide an on site MUGA. However, given the often urbanising form of such facility, it is considered that, in this particular instance and having regard to the location of the site, the exclusion of a MUGA would be of benefit to the overall landscaping and design value of the scheme. Furthermore, a financial contribution has been sought in connection with the proposal by the Council’s Parks & Countryside Service in relation to upgrading works to an off site skate park which is located approximately 100m from the

entrance of the application site. Having regard to this, no concern is raised by Officers in respect of the MUGA requirement.

With regard to amenity space, each dwelling on site would benefit from its own private amenity space in the form of rear garden. These areas would be of varying shapes and sizes, but it is considered that all would be of an adequate size for the properties which they would serve. Areas of communal space would be provided adjacent to the flatted buildings and some of the flatted units would benefit from private balconies to provide additional private amenity space.

In light of the above, it is considered that the proposal would provide for a suitable level of playspace and amenity space in accordance with Policies LRC1 and TD1 of the Local Plan 2018 (Part 1).

Trees and landscaping

Policy NE2 of the Local Plan (Part 1) 2018 states that the Council will seek, where appropriate, to maintain and enhance existing trees, woodland and hedgerows within the Borough. Retained Policies D6 and D7 of the Local Plan 2002 are attributed full and significant weight respectively due to their level of consistency with the NPPF 2018.

Paragraph 170(b) of the NPPF 2018 states that planning policies and decisions should contribute to and enhance the natural and local environment by, inter alia, recognising the intrinsic character and beauty of the countryside including trees and woodland.

Paragraph 175(c) of the NPPF 2018 sets out that, when determining planning applications, development resulting in the loss or deterioration of irreplaceable habitats (such as ancient woodland and ancient or veteran trees) should be refused, unless there are wholly exceptional reasons and a suitable compensation strategy exists.

Retained Policy D7 of the Local Plan 2002 broadly support the aims of the NPPF stating that the Council will protect significant trees and groups of trees and hedgerows through planning control.

The application is supported by the following: Tree Report (Tree survey and constraint advice), prepared by ACD

Environmental Ltd, dated 17th November 2017 Arboricultural Impact Assessment & Method Statement, prepared by

ACD Environmental Ltd, dated 18th May 2018

The site contains trees subject to a Tree Preservation Order, which are located in the eastern section of the site. As no development is proposed within this area, there would be no loss of, or direct impact to, these protected trees.

As part of the proposal, 17 trees are proposed to be removed and over 200 trees are proposed to be planted. Of the 17 trees to be removed, 15 of these would be category C trees (low quality), 1 would be category B (moderate quality) and 1 would be category U (poor quality).

The category B tree proposed to be removed is a whitebeam growing within the front garden of No.21 Aarons Hill, which is a dwelling proposed to be demolished as part of the proposal. The loss of this tree would come as a result of the proposed site access off Aarons Hill. Whilst the loss of this moderate quality tree is acknowledged, the Council’s Tree Officer considers that such loss could be reasonably mitigated as part of the wider soft landscaping planting strategy for the site. With the exception of this tree, all other moderate to high quality trees would be retained within the site.

With regard to the other direct tree loss within the site (category C and U trees), the Council’s Tree Officer considers the loss would not be of significant landscape impact within the overall scheme and it could be reasonably mitigated as indicated by the landscape details provided.

In its initial form, the proposal included the provision of an emergency access route across the root protection area of an oak tree (T51), which has veteran characteristics. However, the proposal has been amended to ensure that no works would take place within the root protection area. The Council’s Tree Officer has commented that, with regard to oak tree T51, whilst it is considered to be of a significant size and age, it would not currently meet the minimum requirements for the species to be a ‘true’ veteran in terms of its features. The tree has been heavily reduced by lopping in the past and this has likely, to some degree, contributed to its increased girth. Notwithstanding this, it should be considered a significant constraint on development and is considered to be very important in terms of its continuity as a foreseeable habitat and as a landscape feature. The minimum recommended radial root protection area for a tree of this size is 15m, which the proposed layout complies with.

Having regard to the specific advice of the Council’s Tree Officer, no objection is raised to the proposal subject to a number of recommended conditions. These would secure the protection of retained trees on site, an agreed scheme of supervision for Arboricultural protection measures, landscaping,

and details of services and levels to ensure that there would be no harm to retained trees.

Soft landscaping

Soft landscaping would be incorporated into the proposed scheme to seek to soften the visual appearance of the built form. Areas of grassland with parkland trees and areas of shrub and swale planting would take place in between the areas of residential housing and front gardens serving the plots would feature a mixture of hedge, shrub and tree planting. The native hedgerow along the northern boundary would be strengthened.

Within the eastern section of the site, the proposed community garden would feature raised beds and a small orchard. An area of meadow grassland and a skylark plot protected by native Berberis Vulgaris (Barberry) would also be provided within the eastern section of the site, adjacent to public footpath 577

A variety of trees would be planted throughout the site, including locations adjacent to the roadways, along the site boundaries and within garden areas. A number of ‘key feature’ trees would be positioned in prominent locations to frame views within the site, particularly off the main spine road towards the site boundaries.

At present, the submitted landscape information is predominantly illustrative, and full details of the specific planting strategy and species could be secured by means of a planning condition should permission be granted. Notwithstanding this, Officers are satisfied that the proposal is capable of providing sufficient soft landscaping within the site which would help to soften areas of built form and provide for a visually attractive site.

Ancient Woodland and Godalming Hillsides

The eastern area of the site is located within the Godalming Hillsides, and areas of Ancient Woodland (Ockford Wood) adjoin the eastern section boundaries.

Paragraph 175(c) of the NPPF 2018 sets out that, when determining planning applications, development resulting in the loss or deterioration of irreplaceable habitats (such as ancient woodland and ancient or veteran trees) should be refused, unless there are wholly exceptional reasons and a suitable compensation strategy exists.

Retained Policy BE5 of the Local Plan 2002, relating to the Godalming Hillsides, carries full weight. This states that development will not be

acceptable where it would diminish the wooded appearance of the hillside, to the detriment of the character and setting of the town.

Given that the eastern section of the site would not be the subject of residential development and would serve as open space, Officers are satisfied that the wooded appearance of the hillside would be preserved and the proposal would not result in any loss of, or harm to, the adjacent Ancient Woodland.

Flooding and drainage

Policy CC4 of the Local Plan (Part 1) 2018 states that in order to reduce the overall and local risk of flooding, development must be located, designed and laid out to ensure that it is safe; that the risk from flooding is minimised whilst not increasing flood risk elsewhere and that residual risks are safely managed. In those locations identified as being at risk of flooding, planning permission will only be granted where it can be demonstrated that it is located in the lowest appropriate flood risk location, it would not constrain the natural function of the flood plain and where sequential and exception tests have been undertaken and passed. Sustainable drainage systems (SuDS) will be required on major development proposals.

Paragraph 155 of the NPPF 2018 states that inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at high risk, but where development is necessary, make it safe without increasing flood risk elsewhere.

The NPPG states that whether SuDS should be considered will depend on the proposed development and its location, for example, where there are concerns about flooding. SuDS may not be practicable for some forms of development. New development should only be considered appropriate in areas at risk of flooding if priority has been given to the use of SuDS. When considering major development, SuDS should be provided unless demonstrated to be inappropriate. Whether a SuDS system is appropriate to a particular development proposal is a matter of judgement for the Local Planning Authority and advice should be sought from relevant flood risk management bodies, principally the LLFA.

The site falls within Flood Zone 1. The proposed development for residential purposes is classified as ‘More Vulnerable’ and as such, the use is consistent with the appropriate uses for Flood Zone 1, as outlined in Table 2 of the NPPF – Technical Guidance Document. It is not therefore necessary to consider the sequential or exception tests in this instance.

However, the application relates to a major development and the site area exceeds 1 hectare. As such, a site specific Flood Risk Assessment (FRA) is required and has been submitted with the application, entitled ‘Flood Risk Assessment & Surface Water Drainage Strategy’ prepared by RSK LDE Ltd, dated 12th July 2018.

Surface water drainage

The FRA confirms that the site is underlain by Sandstone bedrock geology. Soakaway tests have revealed that infiltration rates are poor in some areas of the site. As such, rather than using infiltration in isolation to drain surface water, a staged discharge approach is proposed in line with recommendations based on Greenfield discharge rates.

Whilst there are no surface water sewers within the application site itself, there are multiple surface water sewers located within the vicinity of Aarons Hill to the south of the site, which flow towards Eashing Lane.

Given the topography of the site, any surface water would likely runoff towards the southwest and southeast. Any surface water generated from surrounding areas would be unlikely to flow towards the site, so the risk of surface water flooding at the site itself is considered to be low. In order to control the surface water generated on-site, and prevent surface water flooding occurring elsewhere, the SuDS features proposed for the site include infiltration basins, permeable paving, modular storage and soakaways. Due to the lack of watercourses within the surrounding area, it is considered that discharging surface water to a local watercourse would not be feasible.

However, as the infiltration rates for the western section of the site are lower than required to achieve favourable drainage times for soakaways, it is proposed to connect to an existing Thames Water sewer within Aarons Hill to the south of the site. Where infiltration can be relied upon, infiltration basins would be strategically located within areas of open space where the topography is suitable for SuDS features.

Permeable paving would be incorporated within all of the minor roads within the site and communal car parking areas which are not proposed to be adopted. Main roads within the site would not feature permeable paving owing to ownership and future maintenance issues.

Modular storage tanks are proposed to be located beneath shared permeable paved areas to provide for storm volumes.

As the site falls within Flood Zone 1, the Environment Agency has confirmed that it does not wish to be consulted on the proposal.

The LLFA has reviewed the proposed development and its supporting documents and is satisfied that the proposed drainage scheme would meet the requirements set out within the NPPF, NPPG and Technical Standards. As such, no objection is raised subject to inclusion of recommended conditions should permission be granted, to ensure that the SuDS scheme is properly implemented and maintained throughout the lifetime of the development. The on-going management, maintenance and financial responsibilities to ensure the ongoing ability for these systems to serve the development in perpetuity would be secured by a S106 Agreement.

Foul water drainage

The application is also supported by a ‘Foul Drainage & Utilities Statement’ prepared by RSK LDE Ltd.

This document confirms that there is a foul water sewer located within Aarons Hill to the south of the site, which flows towards Eashing Lane. There is an additional foul water sewer located within the southeastern woodland which flows towards the railway line.

A survey of the site has revealed that there is a rising main traversing the application site which provides drainage for the small number of buildings on the northern side of Halfway Lane. Thames Water has confirmed to the applicant that this main, which was originally private, has now been publically adopted. Thames Water has also confirmed that the existing sewer network could accommodate the predicted flows from the proposed residential housing, provided a minimum of two separate outfalls are used. It is therefore proposed to sub-divide the onsite network into two catchments with gravity connections to manholes in Aarons Hill.

In a letter to the applicant, Thames Water has confirmed their position following an assessment of the foul water flows based on the information submitted as part of the current application. It is concluded that the sewerage network to the south east of the site would have capacity for connection of the first 87 properties and the network to the south of the site would have capacity for connection of a further 50 properties. This would not accommodate the needs of the whole proposed development, resulting in the need for Thames Water to undertake modelling work to identify necessary improvements to serve the remainder of the proposed development. This work would be carried out at the cost of Thames Water. Thames Water has confirmed that the typical

timeframe for such works could extend to 20 months, and they could be undertaken during the construction of the first 137 homes.

Utilities

Owing to the size of the development, there would be additional pressures on existing utilities infrastructure.

The proposed utility infrastructure for the development is set out within a submitted ‘Foul Drainage & Utilities Statement’ document prepared by RSK Environment Ltd. This report considers foul drainage, electricity, gas, water supply and telecommunications.

Foul drainage has been discussed in the ‘Flooding and drainage’ section of this report.

In terms of electricity, there are Scottish & Southern Energy (SSE) networks in the immediate area. An electricity overhead cable route traverses the land to the west of the application site. It would be necessary to divert the overhead cables as part of the proposed scheme. The applicant has confirmed that SSE intends to ground and re-route these cables within the proposed estate roads and landscaped margins.

In terms of gas, there is a low-pressure Scotia Gas Networks (SGN) mains network to the south of the application site. The applicant has confirmed that SGN intends to carry out analysis of the existing network in the event that permission is granted. However, it is likely that reinforcement works of the existing network would need to be carried out to accommodate the predicted load demand from the proposed dwellings. The cost of any offsite reinforcement works would fall to SGN.

With regard to potable water supply, the network for the application site is provided by Thames Water. The Applicant has confirmed that Thames Water intends to carry out modelling work to determine what, if any, offsite reinforcement works would be required as the existing network may not have capacity to meet requirements of the proposed development. This modelling work is estimated to take 8 months to complete and the cost of this would fall to Thames Water. It is considered that this approach for a strategic development is not unusual and it could be mitigated by means of a Grampian condition if permission is granted. In strategic terms, Thames Water has raised no objection to the development proposal and it would not be reasonable to refuse the application on grounds of water supply on this basis.

With regard to telecommunications, British Telecom (BT) has underground apparatus in Eashing Lane and Aarons Hill. There are cable routes in Halfway Lane and in New Way. It is envisaged that there would be no problem connecting to a BT telephone service for the proposed development and there are several options in terms of broadband connections. A strategy for the provision of high speed broadband would be required and this could be secured by condition should permission be granted.

On the above basis, Officers are satisfied that appropriate utilities could be provided to serve the proposed development without adversely impacting on existing infrastructure.

Noise

Paragraph 180 of the NPPF states that planning decisions should ensure that new development is appropriate for its location by taking into account the effects (including cumulative effects) of pollution on health, living conditions and the natural environment, as well as the potential sensitivity of the site or the wider area to impacts that could arise from the development. This includes, inter alia, mitigating and reducing to a minimum the potential adverse impacts resulting from noise from new development and to avoid noise giving rise to significant adverse impacts on health and the quality of life.

Retained Policy D1 of the Local Plan 2002 states that the Council will have regard to the environmental implications of development and will promote and encourage enhancement of the environment. Development will not be permitted where it would result in material detriment to the environment by virtue of noise and disturbance or potential pollution of air, land or water, including that arising from light pollution.

The application is supported by a Noise Assessment, undertaken by Grant Acoustics, dated 26th June 2018. This assessment explores how existing and new noise sensitive premises could be affected by the proposed development. It concludes that the increase in noise from road traffic flow would not be detrimental and would have an insignificant impact on the surrounding area. Noise limits are recommended for demolition and construction related processes, which should be adhered to, and glazing and ventilation specifications are recommended with regard to internal noise impacts.

The Council’s Environmental Health Officer (noise and disturbance) has reviewed the submitted information and has raised no objection subject to inclusion of a number of recommended conditions should permission be

granted. These relate to the operation of plant and machinery, and the securing of a Construction Environmental Management Plan.

Subject to the imposition of conditions on any grant of permission, it is considered that the proposal would accord with retained Policy D1 of the Local Plan 2002 and the NPPF in this respect.

Land contamination

Paragraph 180 of the NPPF states that planning decisions should ensure that new development is appropriate for its location by taking into account the effects (including cumulative effects) of pollution on health, living conditions and the natural environment, as well as the potential sensitivity of the site or the wider area to impacts that could arise from the development.

Where a site is affected by contamination or land stability issues, responsibility for securing a safe development rests with the developer and/or landowner in accordance with paragraph 179 of the NPPF.


The application is supported by a Geo-Environmental Site Assessment (Project No. 28902 R01 (02)), undertaken by RSK Environment Ltd, dated July 2018, which concludes that there is a very low risk of contamination on site.

The Council’s Environmental Pollution Control Officer has reviewed the submitted report and is in agreement that no significant land contamination issues are identified. On this basis, it is considered that no further action would be required and the proposal would accord with retained Policy D1 of the Local Plan 2002 and the NPPF 2018.

Air Quality

Paragraph 180 of the NPPF states that planning decisions should ensure that new development is appropriate for its location by taking into account the effects (including cumulative effects) of pollution on health, living conditions and the natural environment, as well as the potential sensitivity of the site or the wider area to impacts that could arise from the development.


The site is not located within a designated Air Quality Management Area (AQMA). Notwithstanding this, having regard to the scale of the proposed development, it has the potential to impact on the designated AQMA within Godalming which is located approximately 180m to the west of the application site. As such, air quality remains an important material consideration.

The application is supported by an Air Quality Assessment (Project No. 442811/AQ/01 (03)) undertaken by RSK Environment Ltd, dated July 2018.

This report sets out that the risk of construction related impacts is predicted to range from low risk to medium risk depending on the type of works. Subject to appropriate mitigation measures, however, the report concludes that there would be no significant impacts during the construction phase.

Once the development is completed, the report confirms that the main impact on air quality would relate to emissions from road traffic. Modelling has predicted that the development would cause changes in pollutant concentrations of negligible significance. The overall impact on local air quality once the development is operational, and prior to any mitigation, is concluded to be negligible in relation to human receptors. The impact on ecological receptors is concluded to be insignificant. With appropriate mitigation measures, the report sets out that there would be no air quality constraints.

The Council’s Environmental Health Officer (Air Quality) has reviewed the submitted information and accepts the overall findings and conclusion of the assessment. However, it is considered that there would be further opportunity to minimise the impact on air pollution associated with additional vehicle movements. No objection has been raised subject to inclusion of recommended conditions in relation to burning of waste, details of electric vehicle charging points and dust management should permission be granted.

Subject to the imposition of these recommended conditions on any grant of permission, it is considered that the proposal would accord with retained Policy D1 of the Local Plan 2002 and the NPPF 2018 in this respect.

Archaeology

Policy HA1 of the Local Plan 2018 (Part 1) states that the Council will ensure that the significance of heritage assets within the Borough are conserved or enhanced to ensure the continued protection and enjoyment of the historic environment by, inter alia, facilitating and supporting the identification and review of heritage assets of local historic, architectural and archaeological significance.

Retained Policies HE14 and HE15 of the Local Plan 2002 require that appropriate desk based or field surveys should be submitted with an application and appropriate measures taken to ensure any important remains are preserved. These policies are afforded full weight owing to their consistency with the NPPF.

Paragraph 189 of the NPPF 2018 sets out that in determining applications, local planning authorities should require an applicant to describe the significance of any heritage assets affected, including any contribution made by their setting. The level of detail should be proportionate to the assets’ importance and no more than is sufficient to understand the potential impact of the proposal on their significance. As a minimum the relevant historic environment record should have been consulted and the heritage assets assessed using appropriate expertise where necessary.

Where a site on which development is proposed includes or has the potential to include heritage assets with archaeological interest, local planning authorities should require developers to submit an appropriate desk-based assessment and, where necessary, a field evaluation.

The application site does not fall within an identified Site of Archaeological Importance. However, owing to the size of the application site, it is expected that an archaeological assessment takes place.

The application is supported by an Archaeological Desk Based Assessment (Ref: RvKM/23872), prepared by CgMs Heritage dated July 2018. The scope of the works carried out within the assessment included an examination of evidence in the Surrey Historic Environment Record (SHER), consideration of results of nearby archaeological investigations, examination of published and unpublished material, charting historic land-use through a map regression exercise and review of geophysical survey and archaeological monitoring of site investigation works within the application site.

The report sets out that, on the basis of the available information, the site is perceived as likely to have an archaeological potential for the later prehistoric,

Roman and Anglo-Saxon periods. The geophysical survey undertaken within the site did not detect any anomalies of archaeological provenance. The archaeological monitoring of site investigation works identified some potential plough damage within the site, presence of colluvial material and a single piece of prehistoric flint from the ploughsoil. The report concludes that further archaeological mitigation measures would be required prior to commencement of development.

The County Archeologist has reviewed the submitted information and is of the opinion that the desk based assessment includes a comprehensive overview of the site and surrounding area in order to identify whether heritage assets would be impacted on by the proposal. It is acknowledged that the geophysical survey did not identify any obvious archaeological features. However, it is considered that this does not definitively mean that archaeology is not present. Therefore, the results of the survey would need to be further tested by a programme of archaeological field evaluation. This work would involve the excavation of a series of trial trenches across the part of the site proposed to be developed, which would clarify the archaeological potential of the site and allow appropriate mitigation works to be developed.

The County Archaeologist considers it to be reasonable and proportionate that, given that the site has been disturbed to some extent by previous activities, for the archaeological evaluation and mitigation works to be carried out following determination of the planning application. On this basis, no objection is raised by the County Archaeologist subject to the inclusion of a recommended condition to secure the implementation of a programme of archaeological work prior to the commencement of development.

Subject to the imposition of this condition on any grant of permission, Officers are satisfied that the proposal would accord with Policy HA1 of the Local Plan 2018 (Part 1),retained Policies HE14 and HE15 of the Local Plan 2002 and the NPPF in this respect.

Refuse and recycling

The proposed internal layout has been designed in a manner to accommodate refuse, delivery and emergency vehicles. Swept path analysis has been submitted in support of the application in relation to this.

The proposed units have been designed in a manner to include provision for refuse and recycling storage, whilst not compromising the aesthetics of the scheme. Each dwelling would be provided with storage areas for refuse and recycling. These would include areas within private amenity space and some

of the mid-terrace plots would include a bin store within the front entrance porch.

The proposed flatted buildings would be provided with communal stores adjacent to the roads to ensure that they would be accessible to refuse collection vehicles.

In addition, composting facilities would be provided adjacent to the proposed community garden area to the east of the site.

The Council’s Waste and Recycling Officer has requested financial contributions towards bin provision and has set out the refuse and recycling container requirements for the proposed development. Accordingly, no concerns are raised in this regard. Full details of the proposed refuse strategy would be controlled by means of condition should permission be granted.

Impact on SPA and SAC

The site is located within: 2.7km of the Thursley, Hankley and Frensham Common (Wealden

Heaths Phase I SPA) 2.7km from the Thursley, Ash Pirbright and Chobham Special Area of

Conservation (SAC)

As set out by Natural England within their consultee response, the provision of additional housing development within the vicinity of the SPA has the potential to adversely affect its interest features, namely nightjar, woodlark and Dartford warbler, which are the three internationally rare bird species for which the SPA is classified.

In accordance with the requirements of regulations 63 and 70 of the Conservation of Habitats and Species Regulations 2017, the Local Planning Authority must decide whether a housing development proposal, either alone or in combination with other plans or projects, would be likely to have a significant adverse effect on the SPA, and if it would the Authority must refuse permission. Generally, this involves a two stage approach.

The first stage (the screening stage) requires the Authority to consider whether the proposal would be likely to have a significant effect on the SPA. Recent case law has determined that at this screening stage the Authority may not take into account proposed mitigation measures in assessing the likely effects of the development.

Unless the Authority is satisfied that the development would not be likely to have a significant effect, it must then make an appropriate assessment (the assessment stage) of the implications of the development for the European site. At the assessment stage mitigation measures can be taken into account. Once the appropriate assessment has been carried out, the Authority may not grant planning permission unless satisfied that the development will not adversely affect the integrity of the European site.

Natural England has commented that they are aware of a separate application which has been submitted to Guildford Borough Council for Suitable Alternative Natural Greenspace (SANG), with the intention that capacity at this proposed SANG would be allocated to the residential development which is proposed under the current application. Natural England has reviewed the SANG proposal and are of the view that it would be acceptable and would effectively mitigate for increased residential disturbance to the SPA.

Natural England recommended that a Grampian condition be included on any grant of permission for the current scheme, to ensure that no permitted residential accommodation is occupied until such time as the required SANG capital works are complete, it is operational and accessible.

However, Officers have sought confirmation from Counsel as to the acceptability of this recommended approach.

The advice received is that, contrary to Natural England’s guidance, SANG provision can effectively prevent new residential development from having an adverse effect on the SPA provided it is secured under a Section 106 Agreement, as opposed to a Grampian condition. This is considered to be the appropriate mechanism for ensuring that the proposed SANG is in place before any new dwellings are occupied. This is advised to be compliant with the Habitat Regulations 2017 and 2018 (amended).

Consequently, a Section 106 Agreement would be concluded to secure the servicing of the development by an off-site SANG located along Eashing Lane, which is the subject of a current planning application which has been submitted to Guildford Borough Council for consideration (Ref: 18/P/01958).

An Appropriate Assessment has been undertaken by the Local Planning Authority on this basis, which has been reviewed by Natural England. The Appropriate Assessment concludes that subject to securing the abovementioned SANG by means of a Section 106 Agreement, that the adverse impact on the SPA would be avoided by this mitigation.

In addition, officers consider that the proposed development would not result in a level of increase in the amount of environmental pollution which would have an adverse effect on the SAC.

Rights of Way

Policy ST1 of the Local Plan 2018 (Part 1) states that the Council will “encourage the provision of new and improved footpaths, bridleways and cycleways, provided there would be no significant effect on SPAs and other areas of importance for nature conservation”.

Paragraph 98 of the NPPF 2018 sets out that decisions should protect and enhance public rights of way and access, which could include taking opportunities to provide better facilities for users.

There are a number of Public Rights of Way that would be within close proximity of the application site:

Bridleway (No.6) – running along the northern and eastern site boundaries. This is a continuation from Bridleway (No.292) which runs along Halfway Lane.

Footpath (No.577) – running through the application site between the eastern (open space) and western (built form) dividing sections

Footpath (No. 44) – running from the north east corner of the site towards Westbrook Road.

Footpath (No.5) – running to the east of the site, between Bridleway 6 and Portsmouth Road.

The proposed development would connect to Bridleway 6 and Footpath 577 through the area of proposed open space within the eastern section of the application site.

The application proposes the following improvements to these areas: Widening of footpath 577 and provision of a year-round surface, as part

of internal site works Provision of a year-round surface along an un-surfaced stretch of

Bridleway 6, as part of Section 278 works with the County Council

The County Rights of Way Officer has reviewed the proposal and has raised no objection subject to the improvements to the Public Rights of Way being secured. These are considered to provide vital links within the development and further onto Godalming Railway Station. A number of informatives are recommended to be imposed on any grant of permission.

Subject to the securing of the proposed improvement works via the imposition of planning conditions on any grant of permission, it is considered that the proposal would be acceptable in this regard.

Infrastructure considerations

Policy ICS1 of the Local Plan 2018 (Part 1) states that infrastructure considered necessary to support new development must be provided either on or off-site or by the payment of contribution through planning obligations and/or the Community Infrastructure Levy.

Paragraph 54 of the NPPF 2018 states that Local Planning Authorities should consider whether otherwise unacceptable development could be made acceptable through the use of conditions or planning obligations. Planning obligations should only be used where it is not possible to address unacceptable impacts through a planning condition.

Paragraph 56 of the NPPF 2018 states that obligations must only be sought where they meet all of the following tests

a) necessary to make the development acceptable in planning terms;b) directly related to the development; andc) fairly and reasonably related in scale and kind to the development

From 6th April 2015, CIL Regulation 123 was amended to mean that the use of pooled contributions under Section 106 of the Town Country Planning Act is restricted.

At that point, no more may be collected in respect of a specific infrastructure project or a type of infrastructure through a Section 106 agreement, if five or more obligations for that project or type of infrastructure have already been entered into since 6th April 2010 and it is a type of infrastructure that is capable of being funded by CIL.

In the light of the above change, the infrastructure providers have been requested to identify relevant and justified contributions/projects that meet the tests of CIL Regulations 122 and 123. The final obligations to be included within the Section 106 agreement will need to satisfy the tests of the Regulations.

The applicant has indicated a willingness to enter into a suitable legal agreement to secure relevant contributions as set out in ‘Heads of Terms’ section of this report.

In drawing up the Heads of Terms, Officers have actively engaged with relevant infrastructure providers and the Town Council to identify any infrastructure requirements resulting from the development. Relevant and justified contributions/projects would be secured as part of the Section 106 Agreement. The providers have confirmed that the proposed contributions would not result in the pooling of more than five contributions towards a specific piece of infrastructure.

As of yet, a signed and completed legal agreement has not been completed However, it is anticipated that an agreement would be entered into. Subject to the receipt of a suitable, signed legal agreement to secure infrastructure contributions, it is concluded that the proposal would adequately mitigate for its impact on local infrastructure and the proposal would comply with the requirements of Policy ICS1 of the Local Plan 2018 (Part 1) and the NPPF in respect of infrastructure provision.

Crime and Disorder

S17(1) of the Crime and Disorder Act 1998 places a duty to consider crime and disorder implications on local authorities. In exercising its various functions, each authority should have due regard to the likely effect of those functions on, and the need to do all that it can to prevent, crime and disorder in its area. This requirement is reflected in the National Planning Policy Framework, which states that planning policies and decisions should promote safe and accessible environments where crime and disorder, and the fear of crime, do not undermine quality of life or community cohesion.

Paragraph 91 of the NPPF 2018 sets out that decisions should aim to achieve healthy, inclusive and safe places which, inter alia, are safe and accessible so that crime and disorder, and the fear of crime, do not undermine the quality of life or community cohesion. This can include the use of clear and legible pedestrian routes, and high quality public space, to encourage active and continual use of public areas.

The Surrey Police Crime Prevention Advisor has been consulted on the proposal and has requested that consideration be given to gaining Secured by Design certification for this development. This would ensure that the properties are constructed with a good level of basic security. A policy is proposed within Draft Local Plan Part 2 (Policy DM5: Safer Places) which would require all new development to ensure safe and attractive public and private spaces, and has been produced to ensure that designing out crime is a consideration for new development. However, very limited weight can be afforded to this draft Policy. As the Council does not have a current Local Plan Policy to require this certification, it is considered that it would not be reasonable to impose a condition to this effect. However, it is considered that it would be reasonable to recommend an informative to encourage the application to seek to achieve Secured by Design certification should permission be granted.

No objection has been raised by the Surrey Police Crime Prevention Advisor subject to the comment made in respect of the Secured by Design certification. Officers are of the view that the proposal would provide for clear and legible pedestrian routes and high quality public space, which would encourage active use. On this basis, it is considered that the site would be developed in a way which would accord with the requirements of the NPPF 2018 and the Crime and Disorder Act 1998.

Biodiversity and compliance with Habitat Regulations 2017

Policy NE1 of the Local Plan 2018 (Part 1) states that the Council will seek to conserve and enhance biodiversity. Development will be permitted provided it retains, protects and enhances biodiversity and ensures any negative impacts are avoided or, if unavoidable, mitigated.

Further, Circular 06/2005 states ‘It is essential that the presence or otherwise of protected species and the extent that they may be affected by the proposed development, is established before planning permission is granted.’

There are 3 internationally designated sites located within 5km of the site, which include the following:

2.7km of the Thursley, Hankley and Frensham Common (Wealden Heaths Phase I SPA)

2.7km from the Thursley, Ash Pirbright and Chobham Special Area of Conservation (SAC)

4.3km from the Thursley and Ockley Bogs Ramsar

The impact on these areas has been addressed within the ‘Impact on SPA and SAC’ section of this report.

In addition, there are a number of national or locally designated sites within the area, which include the following:

Charterhouse to Eashing Site of Special Scientific Interest (SSSI) (0.2km)

Wey Valley Meadows SSSI (2.2km) Thursley, Hankley and Frensham Commons SSSI (2.7km) Puttenham & Crooksbury Commons SSSI (4.3km) Charleshill SSSI (5.9km) Hankley Farm SSSI (6.2km) Rodborough Common Local Nature Reserve (2.4km) Sites of Nature Conservation Importance (SNCI) (nearest within 0.3km) Ancient & Semi-Natural Woodland (adjacent to eastern site section)

The application is supported by the following documents: Technical Note 7864: Response to Natural England (further Dormouse

Information), prepared by Ecology Solutions Ltd, dated November 2018)

Construction and Ecological Management Plan (CEMP), prepared by Wildlife Matters Consultancy Unit, dated November 2018 (updated document following initial submission)

Bat Aerial Tree Assessment Report, prepared by Darwin Ecology, dated October 2018

Phase 2 Bat and Reptile Survey Report and Mitigation Plan, prepared by Darwin Ecology, dated September 2018 and June 2018

Phase 1 Habitats Survey (extended), prepared by Wildlife Matters Consultancy Unit, dated April 2018#

The proposed development would represent an introduction of human (domestic) presence in the area, which could consequently disturb wildlife and habitat. The following sections consider the impacts on particular habitats/protected species:

SSSI

Natural England has confirmed that, on the basis of the submitted plans, the proposed development would not damage or destroy the interest features for which the Charterhouse to Eashing SSSI has been notified.

Officers are satisfied that the proposal would not result in likely adverse impacts on the ecology of the SSSIs which are located further distance away from the site.

Bats

The proposal would include the demolition of three existing dwellings. The submitted Phase 2 Bat and Reptile Survey Report and Mitigation Plan confirm the presence of roosts at Ockford Wood Farm (1 in the main dwelling and 1 in the stable block). No roosts were identified at the properties in Aarons Hill proposed to be demolished. The report also concludes that the site supports low to moderate levels of foraging and regular commuting habitat for 5 common bat species.

Surrey Wildlife Trust considers the submitted Phase 2 Report to be appropriate in scope and methodology. A European Protected Species licence from Natural England would be required prior to the commencement of works should permission be granted.

Following advice from Surrey Wildlife Trust in respect of trees within the vicinity of the site having the potential to host active bat roosts, a Bat Aerial Tree Assessment Report has been carried out. Surrey Wildlife Trust has commented that the report is appropriate in scope and methodology and has identified high bat roost potential within the tree trees subject to aerial inspection. A series of working recommendations for any works to these trees is set out within the report and, should permission be granted, Surrey Wildlife Trust has recommended that these works should be secured by means of a planning condition.

Natural England has recommended a condition to secure mitigation in relation to bat species, as outlined within the submitted CEMP dated November 2018, should permission be granted.

Both Surrey Wildlife Trust and Natural England recommend that a lighting condition is imposed on any grant of permission to ensure that dark corridors are retained within the site where required.

Reptiles

It is noted that the eastern section of the site provides optimal habitat for reptiles, and there are some suboptimal habitats for reptiles elsewhere within the site.

The submitted documents confirm low populations of grass snakes and slow worms within the site and the potential for presence of the common lizard. A number of recommended mitigation measures are proposed within the submission, relating to the timing of works, supervision of works, creation of 3 habitat piles within the site and proposed landscaping within the site.

Surrey Wildlife Trust has recommended that, should permission be granted, the development should only proceed in line with the impact avoidance measures recommended within the submitted Phase 2 Bat and Reptile Survey Report and Mitigation Plan. In addition, it is recommended that, prior to commencement of development, the applicant should be required to submit a detailed reptile impact mitigation, compensation, enhancement and translocation plan for approval.

Great Crested Newts

Surrey Wildlife Trust has commented that there are some potentially suitable aquatic breeding habitats (wet ditches) present within 1km of the site. However, they are of the view that there would be a low expectation of Great Crested Newts being present and affected by the proposed development. On this basis, it is considered unreasonable to secure presence/absence surveys for Great Crested Newts for the site. Notwithstanding this, Surrey Wildlife Trust recommends that, should permission be granted, a ‘Reasonable avoidance measures method statement for Great Crested Newts’ should be submitted and approved.

Badgers

The submitted documents set out that there are badger setts located offsite in close proximity to the site, and evidence of foraging in land adjacent to the site and the eastern section of the site itself is put forward. On this basis, it is considered that badgers are likely to be present within the development site.

Surrey Wildlife Trust has commented that badgers move setts regularly and setts which are disused may become active again on this basis. It is considered that the submitted information would be sufficient to enable a decision to be made, but it is recommended that, should permission be

granted, and prior to the commencement of any development, a site walkover survey is undertaken to confirm that active badger setts are not present within the footprint of the development. This could be appropriately secured by a planning condition on any grant of permission.

Breeding birds

The submitted documents confirm the presence of at least 25 species of birds at the application site, including 3 red listed species (skylark, startling and house sparrow). Habitat suitable for breeding and foraging would be lost as part of the development proposal.

Surrey Wildlife Trust notes that the submitted plans indicated an area within the site as a ‘skylark plot’ which would be enclosed by hedging to deter disturbance. However, it is considered questionable as to whether the plot would function as intended and provide effective compensation for the lost habitat. On this basis, Surrey Wildlife Trust has recommended that should permission be granted, and prior to the commencement of development, a Landscape and Environmental Management Plan (LEMP) is submitted. This would ensure that details of the measures proposed to avoid a net loss of bird breeding and foraging habitat are submitted and agreed.

Dormice

The proposal would result in the loss of one hedgerow which runs north-south along the eastern boundary. The submitted documents set out that this hedgerow is immature and sparse in nature, and is highly suboptimal to support dormice. The area of woodland to the south east of the site is concluded to comprise suitable habitat to support dormice populations. This area is proposed to be retained as open space and works to clear scrub within this area are proposed to take place in a sensitive manner which would not result in any significant adverse impacts on dormice.

Surrey Wildlife Trust notes that the proposal would retain the majority of hedgerows, including the more species rich hedgerows. It is recommended that should permission be granted, and prior to the commencement of development, a suitably detailed ‘Reasonable Avoidance Measures Method Statement for Dormice’ be submitted and agreed. This will document the precautionary measures to be implemented to ensure that the development would not contravene European legislation. The requested LEMP should also detail measures proposed to be taken in respect of dormice.

Natural England has reviewed the information and considers that the removal of the hedgerow would not result on impacts upon Hazel Dormouse due to its

low suitability. However, as the bramble/scrub within the eastern section of the site could be suitable for Hazel Dormouse, a condition is recommended in respect of surveys being undertaken prior to commencement of development.

Deciduous woodland/veteran trees

Surrey Wildlife Trust has commented that regard should be had to the designation of the area of deciduous woodland adjacent to the eastern section of the site as a Habitat of Principle Importance. It is recommended by Surrey Wildlife Trust that a detailed LEMP should be submitted prior the commencement of development should permission be granted. This would ensure that details of the management proposals of the semi-natural eastern section of the site could be secured in order to avoid adverse impacts of increased visitor impacts on the area.

It has also been noted by Surrey Wildlife Trust that tree T51 (common oak) appears to be of a veteran age. Standing Advice published by Natural England and the Forestry Commission states that a buffer area should be maintained between the veteran tree and the development boundary. This tree is proposed to be retained as part of the proposal.

Paragraph 175 of the NPPF 2018 states that development proposals which result in the loss or deterioration of irreplaceable habitats (such as ancient woodland and ancient or veteran trees) should be refused, unless there are wholly exceptional reasons and a suitable compensation strategy exists.

The NPPF defines an ancient or veteran tree as “a tree which, because of its age, size and condition, is of exceptional biodiversity, cultural or heritage value. All ancient trees are veteran trees. Not all veteran trees are old enough to be ancient, but are old relative to other trees of the same species. Very few trees of any species reach the ancient life-stage”.

The Council’s Tree Officer is of the opinion that whilst the oak tree (T51) is of a significant size and age, it would not meet the minimum requirements for the species to be a “true” veteran in terms of features. The tree has been heavily reduced by lopping in the past and this has likely to some degree contributed to its increased girth. Whilst it should be treated as a constraint on development, as it is considered to be important in terms of its continuity as a foreseeable habitat rarity and a landscape feature, Officers consider that it would not comprise a ‘veteran’ tree having regard to the NPPF definition. The Council’s Tree Officer advises that a 15m radial root protection area (RPA) for a tree of this size would be acceptable, which the proposal would respect.

Starved Wood-Sedge

It has been identified that a population of Starved Wood-Sedge is present on the Bridleway adjacent to the eastern site boundary. Whilst this area falls outside the application site line, it is nevertheless considered that the proposal would result in an impact on this area by virtue of the likely increased usage of the Public Right of Way.

The Starved Wood-Sedge is listed under Schedule 8 of the Wildlife and Countryside Act 1981 and is protected from being intentionally picked, uprooted or destroyed. It is also a Species of Principal Importance as listed within the Natural Environment and Rural Communities (NERC) Act 2006.

The Species Recovery Trust has commented that this population is under threat and the proposal provides ample opportunity to significantly boost the conservation status of the site, as well as the prospects for the population on a national level. Whilst concern is expressed regarding the potential impact on the species, the Species Recovery Trust is satisfied that appropriate mitigation and enhancement measures could be adhered to in order to contribute towards its conservation and enhancement. On this basis, no objection is raised subject to the measures being secured should permission be granted.

Surrey Wildlife Trust notes the Species Recovery Trust’s recommendation for a protection strategy to be submitted to the Council for approval, and this approach is supported by the Trust.

Conclusion

Having regard to the above comments, including those from consultees, Officers are satisfied that, subject to the imposition of planning conditions, the proposed development could be provided on site without causing harm to protected species.

Accessibility and Equalities Act 2010

Policy AHN3 of the Local Plan 2018 (Part 1) states that the Council will require the provision of new developments to meet Building Regulations M4 (2) Category 2 standard: “Accessible and adaptable dwellings” to meet the needs of older people and those with disabilities.

The application sets out that the dwellings have been designed in a manner which would comply with the access standards set out in Building Regulations M4 (2) Category 2 standard in order to provide accessible and adaptable

buildings for all users. With regard to the flatted buildings, a lift core is not proposed. This would not comply with the requirements. However, the Applicant has advised that discussions have been held privately with Registered Providers and, for the purposes of managing the proposed units in these buildings, a lift is not considered to be necessary.

Notwithstanding the above, the supporting text to Policy AHN3 states that this requirement would be delivered through the implementation of planning permissions. As such, this would be a matter which would be picked up by the building control process in the instance that planning permission is granted and subsequently implemented.

Sustainability

Policy CC2 of the Local Plan 2018 seeks to ensure all new development includes measures to minimise energy and water use. The Policy goes on to say that new dwellings shall meet the requirement of 110 litres of water per person per day. A condition is recommended requiring the submission of details to confirm that the dwellings have been designed and completed to meet the requirement of 110 litres of water per person per day, prior to the occupation of the dwellings.

The application is supported by a Sustainability and Energy Statement, dated 13th July 2018, prepared by Bluesky Unlimited.

The report sets out that the proposal could achieve a 10% reduction in emissions compared to the Building Regulation maximum. The strategy put forward to achieve this would incorporate a combination of improvements to the construction fabric of the buildings, together with the use of flue-gas heat recovery systems. These systems could be integrated within the boilers serving the units or installed separately. Rainwater harvesting and fixed fittings for water consumption will be considered as part of the detailed design stage for the dwellings.

The report also sets out that the provision of accommodation of varying types, tenures and sizes as part of the scheme would provide for vitality and diversification to the area. Construction of the units would be carried out to a high environmental standard and Secured by Design principles would be followed.

It is proposed that the site would be registered with the Considerate Constructors Scheme, which addressed limiting the effect on the community and effects on the environment. This scheme would monitor the site contractor’s performance against a Code for Considerate Practice.

Health and wellbeing

Section 8 of the NPPF 2018 ‘Promoting healthy and safe communities’ conveys that planning policies and decisions should aim to achieve healthy, inclusive and safe places, which should promote social interaction, are safe and accessible, and should enable and support healthy lifestyles.

The vision of the Waverley Borough Council Corporate Strategy 2018 – 2023 confirms the importance of ensuring that Waverley Borough is a place where residents can take pride in their communities and where opportunities exist for all to thrive and lead healthy lives. The Corporate Plan is capable of constituting a material consideration in the determination of planning applications.

The NPPG sets out a range of issues which could be considered through the plan-making and decision-making processes in relation to health and healthcare infrastructure, including:

development proposals can support strong, vibrant and healthy communities and help create healthy living environments which should, where possible, include making physical activity easy to do and create places and spaces to meet to support community engagement and social capital;

the Local Plan promotes health, social and cultural wellbeing and supports the reduction of health inequalities;

the Local Plan considers the local health and wellbeing strategy and other relevant health improvement strategies in the area;

the healthcare infrastructure implications of any relevant proposed local development have been considered;

opportunities for healthy lifestyles have been considered (e.g. planning for an environment that supports people of all ages in making healthy choices, helps to promote active travel and physical activity, and promotes access to healthier food, high quality open spaces and opportunities for play, sport and recreation);

potential pollution and other environmental hazards, which might lead to an adverse impact on human health, are accounted for in the consideration of new development proposals; and

access to the whole community by all sections of the community, whether able-bodied or disabled, has been promoted.

The need to maximise opportunities in respect of health and wellbeing is echoed in Policy TD1 of the Local Plan 2018 (Part 1), which states that the Council will seek to maximise opportunities to improve the quality of life and

health and well-being of current and future residents. For example, this could be achieved through the provision of:

private, communal and public amenity space appropriate internal space standards for new dwellings on site play provision appropriate facilities for the storage of waste private clothes drying facilities

With regard to the current application, the proposal includes aspects which would contribute to health and wellbeing including:

provision of public open space provision of private and communal areas of amenity space provision of on-site play facilities pedestrian and cycle routes

Officers consider that these would be positive elements of the scheme in terms of the health and wellbeing of future residents and also existing residents near the site who would be able to benefit from use of the proposed facilities. Additionally, the risks of pollution or other adverse impacts on the amenities of future residents of the site would be minimised through the suggested mitigation measures.

The Guildford and Waverley Clinical Commissioning Group has reviewed the application and has requested a financial contribution from the applicant to mitigate the impact of the development on local health services. This contribution is set out in more detail within the ‘Heads of Terms’ section of this report and would be for offsite development of GP capacity.

Overall, having regard to the proposed layout of the site and the elements to be provided within the site, Officers are satisfied that the proposal would adequately provide for the health and well-being of its future residents.

Human Rights Implications

It is considered that the proposal would have no material impact on human rights, going beyond the material planning considerations set out within this report.

Environmental Impact Regulations 2017

A request for Screening Opinion from the Council was requested by the Applicant on 25 May 2018 in relation to residential development of up to 270 dwellings (Ref: SO/2018/0007).

The proposed scheme was assessed in line with the EIA Regulations and Government Guidance and it was considered that the proposed scheme would exceed the relevant thresholds given in Schedule 2 of the EIA Regulations for urban development projects as the proposal would exceed 5 hectares and would provide for more than 150 dwellings. In terms of the relevant thresholds given in the official guidance on EIA (within the NPPG), it was considered that the proposal would exceed the relevant threshold of a site area exceeding 5 hectares, but it would not exceed guidance in terms of commercial floorspace or development having significant urbanising effects in a previously non-urbanised area (new development of more than 1,000 dwellings).

The likely significant effects of the development on the environment were assessed by Officers having regard to Part 3, Schedule 3 of the EIA Regulations and no significant impacts in EIA terms were anticipated by Officers. On this basis, it was concluded that the proposed scheme would not constitute EIA development.

Having regard to the above, Officers are satisfied that the current application proposal does not constitute EIA development.

Development Management Procedure Order 2015 - Working in a positive/proactive manner

In assessing this application, officers have worked with the applicant in a positive and proactive manner consistent with the requirements of paragraph 38 of the NPPF. This included:-

Provided or made available pre application advice to seek to resolve problems before the application was submitted and to foster the delivery of sustainable development.

Provided feedback through the validation process including information on the website, to correct identified problems to ensure that the application was correct and could be registered;

Have suggested/accepted/negotiated amendments to the scheme to resolve identified problems with the proposal and to seek to foster sustainable development.

Have proactively communicated with the applicant through the process to advise progress, timescales or recommendation.

Response to Town Council and Third Party Representations

The objections which have been raised regarding the proposal by the Town Council and Third Party representations are noted by Officers and have been carefully considered as part of the assessment which has been undertaken by Officers.

The majority of areas of concern raised have been fully considered as part of the assessment undertaken in relevant sections of this report. However, Officers would comment as follows with regard to areas of concern which have been raised:

Town Council comments

Overdevelopment of siteThis has been discussed within the ‘Design and impact on visual amenity’ section of this report, wherein the varying densities of the different character areas proposed within the site has been referred to.

MixThis has been discussed within the ‘Housing Mix’ section of this report, wherein the proposed mix has been set out having regard to the SHMA requirements and an assessment as to the acceptability of the mix has been undertaken by Officers.

Lack of Social HousingThis has been discussed within the ‘Affordable Housing’ section of the report, wherein it is confirmed that the proposal would provide for a policy compliant 30% affordable housing provision in accordance with Policy AHN3 of the Local Plan 2018 (Part 1).

Surface water controlThis has been discussed within the ‘Flooding and drainage’ section of the report, wherein the proposed drainage strategy has been set out and it is confirmed that the Lead Local Flood Authority has raised no objection to the proposal subject to the inclusion of planning conditions on any grant of permission. Roads and trafficThis has been discussed within the ‘Highways considerations’ section of the report, wherein the proposed highways improvement package has been set out and it is confirmed that the County Highway Authority has raised no objection to the proposal subject to the inclusion of planning conditions and securing of works as part of a S106 Agreement on any grant of permission.

Impact on Listed Buildings and gardensThis has been discussed within the ‘Heritage considerations’ section of the report, wherein Officers have set out the significance of the designated heritage assets and have undergone an assessment as to the impact of the proposal on the significance. As stated within this section, it is anticipated that further information will be provided by the applicant ahead of the Committee.

Public ConsultationThe application has been advertised in accordance with the Town and Country Planning (Development Management Procedure) (England) Order 2015. As set out in the ‘Representations’ section of this report, the application was advertised in the newspaper on 10/08/2018, site notices were displayed around the site on 03/08/2018 and neighbour notification letters were sent on 01/08/2018 and 05/11/2018. With regard to the site notices displayed by Officers, a total of 6 site notices were displayed in the following public locations:

At disused car park area adjacent to No.85 Aarons Hill (start of Public Footpath 577)

At the eastern-most corner of the site adjacent to No.2 Oakbank (along Bridleway 6 and near the start of Public Footpath 5)

On the green in front of Nos. 19 and 21 Aarons Hill (where site access is proposed)

On the corner of Eashing Lane and Franklyn Road, adjacent to Green Oaks Primary School

On the corner of Eashing Lane and Halfway Lane (within GBC, but at the start of Bridleway 292)

At the very north of the site, adjacent to Far Cottage (at junction of Bridleway 6 and Public Footpath 44)

Third Party comments

LandscapeThe removal of the western section of the site from the Green Belt and AGLV has been set out within this report, as has the principle of development the site for residential development. To confirm, the site does not fall within the AONB and the eastern part of the site, which features steep topography, is not proposed to be built upon. The landscape change, impact and relationship with the existing developed area is discussed within the ‘Landscape considerations’ section of this report.

Ecological/Biodiversity

The impact to ecology, including the impact to Starved Wood-Sedge, is discussed within the ‘Biodiversity’ section of this report.

DesignThe visual impact of the proposed development, along with the architectural design of the proposal, and its acceptability in connection with the surrounding area is discussed within the ‘Design and visual impact’ of this report.

Residential ImpactThe impact of the proposed development is discussed within the ‘Impact on residential amenity’ and ‘noise’ sections of this report. It is acknowledged that The Meath is located approximately 380m to the north east of the application site. However, Officers consider that the proposal would not impact on wheelchair users. As part of the proposed scheme, there would be improvements to public rights of way and the site would feature several connections to the surrounding rights of way network to encourage accessibility to and within the site.

HeritageThe impact on designated heritage assets is discussed within the ‘Heritage considerations’ section of this report.

HighwaysThe matters of traffic, highway improvements, highway safety and parking have been discussed within the ‘Highways considerations’ section of this report. Air Quality has been discussed within the ‘Air Quality’ section of this report.

InfrastructureThe matters of refuse, noise, play space and utilities connections have been discussed within relevant sections of this report. The proposal would secure financial contributions towards education and off-site GP development. Officers consider that the site is within a sustainable location with good access to the rail network. The matter of food shortages would not comprise a material planning consideration.

FloodingThe matter of flooding has been discussed in the ‘Flooding and drainage’ section of this report.

OtherWith regard to concerns regarding crime and anti-social behaviour, Surrey Police has been consulted and no concern has been raised. The policing of

the site would not comprise a material planning considerations, and this would fall to be enforced under separate legislation.

Similarly, the matter of surrounding property values would not form a material planning consideration.

The scheme would provide for a policy-compliant level of affordable housing, which would be secured through a S106 Agreement. Whilst noting the comments with regard to high property prices, this would be a matter for the developer of the site should permission be granted.

In respect of the concerns that the scheme is a cash grab from the developer, Officers would comment that it is open to anyone to submit an application and each application is to be judged on its own merits accordingly.

The submitted reports have been reviewed by statutory consultees and their content has been carefully reviewed. Where additional information has been required by statutory consultees in terms of the content of the report, this has been submitted. Whilst noting the procedural discrepancy as set out within the ‘heritage section’ of this report, Officers are nevertheless satisfied that the submitted information allows for a full and thorough assessment to be carried out as to the acceptability of the proposed scheme.

Full details of the proposed community building could be secured by means of a planning condition should permission be granted.

The comments made regarding the application coming forward alongside the Guildford site of the site are noted. However, Officers are required to assess the application proposal as put forward by the Applicant at the current time. It is acknowledged that the draft allocation of the site within Local Plan Part 2 refers to the “submission of a masterplan setting out the design principles for the site including how a high quality development which integrates with the existing townscape, and can be achieved both in conjunction with and without development of the adjoining land between Eashing Lane and Halfway Lane within Guildford Borough”. However, at this time, weight cannot be afforded to this draft Policy. Furthermore, Officers are mindful that an independent review by Design South East of a Masterplan put forward at the pre-application stage concluded that a high quality development could satisfactorily come forward either separately or in conjunction with a future Guildford development.

Conclusion/Planning Balance

Paragraph 11 of the NPPF defines the presumption in favour of sustainable development as approving development proposals that accord with the

development plan without delay; and where there are no relevant Development Plan Policies or the policies which are most important for determining the application are out-of-date, granting permission unless: inter alia, the application of policies within the Framework that protect areas or assets of particular importance provides a clear reason for refusing the development proposal, or any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole.

In this instance, the Council has an up to date Development Plan and, as such, a planning balance weighing the harm against the benefits of the proposal is applicable.

In terms of the benefits of the scheme, it is considered that the proposal would provide dwellings in a sustainable location and would deliver 30% affordable housing to contribute towards housing needs. Delivery of affordable and market homes in the context of the constraints that apply to the Borough would comprise the most significant social benefit to the proposed development, which would be consistent with the NPPF’s basic imperative of delivery.

The proposal would also deliver economic gains from sources including construction-based employment (both direct and in-direct jobs), and contributions more generally to the economy through activity and spending of future occupiers of the site. Whilst it is acknowledged that such economic benefits may arise from any residential development scheme, Officers nevertheless consider that weight can be attached to these benefits.

Officers consider that the scheme would function well within the context of the surrounding area, and it would be of a high quality design incorporating sufficient amenity space and play space within its layout. The potential for landscaping and the provision of public open space where none currently exists are other beneficial considerations to which weight can be attached. Similarly, it is considered that the provision of residential units which would all accord with the Technical Space Standards would be a significant merit and, in combination with the amenity space provision and site layout, this would deliver a scheme which provides for a good standard of accommodation for its future occupiers.

Having regard to the expert opinion of the County Highway Authority, Officers are satisfied that the proposed development could be accessed in safe manner and, that subject to securing highway improvements within the locality, the scheme could be provided without prejudice to highway safety or

capacity and the traffic movements associated with the development could be appropriately accommodated within the road network.

The proposal has demonstrated, subject to control by way of planning conditions if permission were to be granted, that in terms of flood risk the development would be safe for its lifetime taking into account its users without increasing flood risk elsewhere. Further, and subject to the same control by way of planning conditions, the proposal would not result in any ecology, archaeology or air quality concerns.

Officers are satisfied that, subject to securing the specific SANG provision outlined in this report, it would completely mitigate the risk of adverse effect to the SPA.

Notwithstanding the above, it does remain that the proposed development would introduce built form into an undeveloped area of land, albeit within the settlement area of Godalming; the proposal would not strictly be compliant with the housing mix indicated by the SHMA; there would be a loss of some Grade 3a agricultural land; and less than substantial harm would be caused to the setting of a designated heritage asset.

The introduction of built form to the application site would inevitably result in a change to the visual appearance of the site and views would be afforded of the residential development from public vantage points. However, the proposed residential development would be built out on land falling within the developed area of Godalming and, in officers’ opinion, the scheme would visually relate to existing adjacent built form. In this context, Officers consider that the proposal would not prejudice the openness, character and appearance of the surrounding Green Belt, AGLV and wider AONB.

There is no dispute that the proposal would deliver a lower provision of one bedroomed dwellings and a greater provision of four bedroomed dwellings than the recommended SHMA mix. However, Officers consider that Policy AHN3 of the Local Plan 2018 (Part) allows for the housing mix to react to changing circumstances in the wider area. Having regard to the justification put forward by the applicant, and the considerable provision of smaller sized units within the Godalming area as part of other residential development schemes since the introduction of the SHMA, Officers consider that, on balance, the proposal would deliver an appropriate profile of homes to serve the community.

The proposal would result in the loss of an area of the best and most versatile agricultural land. Whilst this is the case, as set out within the ‘Loss of agricultural land’ section of this report, it is considered that there is a strong

case for development of the application site which overrides the needs to protect such land.

It has been concluded that the proposal would result in less than substantial harm to the significance of a designated heritage asset (Westbrook House and its associated Registered Park and Garden). However, as set out within the ‘Heritage considerations’ section of this report, this harm is considered to be outweighed by the public benefits of the proposal, principally the significant delivery of housing that this scheme would provide.

Overall, it is considered that the development would be in accordance with the Development Plan and the harm which has been identified as resulting from the proposal is considered to be outweighed by the benefits which the proposal would provide.

Officers therefore consider that the scheme could be supported subject to the completion of an appropriate legal agreement and inclusion of appropriate planning conditions.

RECOMMENDATION A

That, subject to the applicant entering into an appropriate legal agreement within 6 months of the date of the committee resolution to grant planning permission, to secure the provision of/contributions towards: 30% affordable housing and market housing mix, education infrastructure, SuDS management/maintenance, off site GP capacity, public open space and play space provision and maintenance, public access, off site highways improvements, travel plan, car club, leisure and green space areas, environmental enhancements, recycling facilities, Surrey Police recruitment and equipment, self build plots and provision and maintenance of the SANG (as identified in the Appropriate Assessment), subject to conditions and informatives, permission be GRANTED.

1. Condition The plan numbers to which this permission relates are:

Site Plans:01245_S01 Ground Floor Site Plan Rev P701245_S02 Roof Plan Rev P701245_S03 Block Plan Rev P701245_S04 Block Plan (A) Rev P601245_S05 Block Plan (B) Rev P601245_S06 Block Plan (C) Rev P601245_S07 Block Plan (D) Rev P7

01245_S08 Location Plan Rev P3 01245_S09 Proposed Street Elevations A-A_B-B Rev P201245_S10 Proposed Street Elevations C-C_D-D Rev P201245_S11 Proposed Street Elevations E-E Rev P101245_S12 Section H-H and I-I Existing and Proposed Rev P201245_S13 Section J-J and K-K Existing and Proposed Rev P201245_S14 Tenure Plan Rev P101245_S15 Self Build Plan Rev P101245_S16 Chimney Strategy Rev P1

Apartments01245_AB_A_01 Block Type A – Plans Rev P201245_AB_A_02 Block Type A – Elevations Rev P201245_AB_B_01 Block Type B – Plans Rev P201245_AB_B_02 Block Type B – Elevations Rev P2

Housetypes01245_HT_1-1_1-2_01 Housetype 1-1(2B4P) & 1-2 (2B4P) Rev P201245_HT_2-1_2-2_01 Housetype 2-1(3B5P) & 2-2 (3B5P) Rev P301245_HT_3_01 Housetype 3(3B5P) Rev P101245_HT_A-1_A-2_01 Housetype A-1(2B4P) & A-2 (2B4P) Rev P101245_HT_A-3_A-4_01 Housetype A-3(2B4P) & A-4 (2B4P) Rev P101245_HT_B-1_B-2_01 Housetype B-1(3B5P) & B-2 (3B5P) Rev P101245_HT_C-1_C-2_01 Housetype C-1(3B5P) & C-2 (3B5P) Rev P101245_HT_C-3_C-4_01 Housetype C-3(3B5P) & C-4 (3B5P) Rev P101245_HT_D_E-1_01 Housetype D (3B6P) and E-1 (3B5P) Rev P101245_HT_E-2_01 Housetype E-2 (3B5P) Rev P101245_HT_F-1_G-1_01 Housetype F-1 (3B5P) and G-1 (3B5P) Rev P201245_HT_F-2_G-2_01 Housetype F-2 (3B5P) and G-2 (3B5P) Rev P201245_HT_H-1_I-1_01 Housetype H-1 (4B6P) and I-1 (4B6P) Rev P301245_HT_H-2_I-2_01 Housetype H-2 (4B6P) and I-2 (4B6P) Rev P301245_HT_J-1_01 Housetype J-1 (4B5P) Rev P201245_HT_J-2_01 Housetype J-2 (4B5P) Rev P201245_HT_K_01 Housetype K (4B7P) Rev P201245_HT_L-1_L-2_01 Housetype L_1 (4B7P) and L-2 (4B7P) Rev P201245_HT_L-3_01 Housetype L_3 (4B7P) Rev P101245_HT_M-1_01 Housetype M-1 (4B7P) Rev P301245_HT_M-2_01 Housetype M-2 (4B7P) Rev P201245_HT_N_01 Housetype N (5B9P) P301245_HT_O_01 Housetype O (5B9P) Rev P301245_HT_P_01 Housetype P (2B4P) Rev P1

Ancillary Drawings 01245_CB_01 Community Building Rev P2

01245_BT_01 Boundary Treatments - Plans and Elevations Rev P101245_CS_CP_01 Cycle Store & Car Port - Plans & Elevations Rev P101245_G_01 Single & Double Garages (Red Brick) - Plans & Elevations Rev P101245_G_02 Double Garages (Natural Grey Brick) and Substation - Plans and Elevations Rev P101245_OWC_01 Ockford Wood Cottage - Plans and Elevations Rev P201245_OWF_01 Ockford Wood Farm - Plans and Elevations Rev P201245_AH_01 19 and 21 Aarons Hill - Plans and Elevations Rev P1

The development shall be carried out in accordance with the approved plans. No material variation from these plans shall take place unless otherwise first agreed in writing with the Local Planning Authority.

ReasonIn order that the development hereby permitted shall be fully implemented in complete accordance with the approved plans and to accord with Policy TD1 of the Local Plan 2018 (Part 1) and retained Policies D1 and D4 of the Local Plan 2002.

2. ConditionPrior to commencement of development a detailed Landscape and Environmental Management Plan (LEMP) shall be submitted to and approved in writing by the Local Planning Authority. The LEMP shall make specific reference to the following

management of proposals of the semi-natural eastern spur in order to avoid adverse impacts of increased visitor impacts on the Habitat of Principle Importance Deciduous Woodland Habitats,

measures taken to avoid a net loss of bird breeding and foraging habitat through retention of existing habitats as far as possible and measures to mitigate and compensate for habitat lost or deteriorated as a result of development

Description and evaluation of features to be managed and created Ecological enhancements to be incorporated within the fabric of the

new built development (such as numbers and locations of bat and bird boxes, including provision integral to the design of the new buildings),

Aims and objectives of the management proposals Appropriate management options to achieve the aims and

objectives Prescriptions for management actions Preparation of a work schedule for securing biodiversity

enhancements in perpetuity

Details of the body or organisation responsible for implementation of the LEMP

Ongoing monitoring and remedial measures Details of any relevant legal/funding mechanisms required for

effective implementation

ReasonTo safeguard the ecological interests of the site in accordance with Policy NE1 of the Waverley Borough Council Local Plan 2018 (Part 1).

3. ConditionThe development shall be carried out in accordance with the actions detailed in the Method Statement, based on the mitigation, compensation and enhancement actions presented within Section 6 ‘Bats’ of the above referenced Phase 2 Bat and Reptile Survey Report and Mitigation Plan report.

ReasonTo safeguard the ecological interests of the site in accordance with

Policy NE1 of the Waverley Borough Council Local Plan 2018 (Part 1).

4. ConditionPrior to the commencement of development a site walkover survey shall be undertaken to confirm that there are no active badger setts within the footprint of the development. The results shall be submitted to and approved in writing by the Local Planning Authority. Should the walkover survey find any active badgers setts a detailed method statement for dealing with them shall be submitted to and approved in writing by the Local Planning Authority prior to the commencement of development. The development shall be carried out in strict accordance with the approved details.


5. ConditionPrior to the commencement of development a suitably detailed ‘Reasonable Avoidance Measures Method Statement for Dormice’ shall be submitted to and approved by the Local Planning Authority in writing. The method statement shall comply with best practise guidance and document the precautionary measures to be implemented to ensure that development construction will not contravene European legislation The

development shall be carried out in strict accordance with the approved details.


6. ConditionIf Dormice and/or Great Crested Newts are identified to be present within the footprint of the development, all works should cease immediately and Natural England contacted to establish the need for a European Protected Species License.


7. Condition Prior to the commencement of development, a suitably detailed reptile impact mitigation, compensation, enhancement and translocation plan shall be submitted to and approved in writing by the Local Planning Authority. The development shall be carried out in strict accordance with the approved details.


8. ConditionPrior to the commencement of development a ‘Reasonable Avoidance Measures Method Statement for Great Crested Newts’ shall be submitted to and approved in writing by the Local Planning Authority. The statement shall comply with best practice guidance and document the precautionary measures to be implemented to ensure that development construction will not contravene European legislation. The development shall be carried out in strict accordance with the approved details


9. ConditionPrior to commencement of the development, details of the construction access shall be submitted to and approved in writing by the Local Planning Authority, in consultation with the Highway Authority, and implemented in accordance with the approved details.

ReasonIn order that the development should not prejudice highway safety nor cause inconvenience to other highway users in accordance with Policy ST1 of the Local Plan 2018 (Part 1) and the NPPF.

10. ConditionPrior to first occupation of the development the proposed vehicular access onto Aarons Hill shall be constructed and provided with 2.4m x 43m visibility splays in accordance with Drawing No. ITB12206-GA-013 Rev D. The visibility splays shall thereafter be permanently provided with no obstruction between 0.6m and 2.0m above ground level.


11. ConditionPrior to occupation of the 100th dwelling the proposed emergency access onto Halfway Lane (Public Bridleway No. 6) shall be constructed in accordance with the approved plans and thereafter permanently maintained for its designated purpose.


12. ConditionPrior to occupation of the 50th dwelling the improvements to Public Bridleway No. 6 and Public Footpath No. 577 shall be constructed in general accordance with Drawing No. ITB12206-GA-024 Rev B, and subject to the Highway Authority’s technical and safety requirements. For the avoidance of doubt, the improvements to land outside of the ‘red’ and ‘blue’ boundaries will be implemented by SCC at the developer’s expense via a S106 contribution.


13. ConditionPrior to occupation of the 100th dwelling the highway improvement scheme at the Eashing Lane priority junction with the A283 shall be constructed in general accordance with Drawing No. ITB12206-GA-005 Rev B, and subject to the Highway Authority’s technical and safety requirements.


14. Condition No dwelling hereby approved shall be first occupied unless and until space for the parking of vehicles and space for vehicles to turn so that they may enter and leave the site in a forward gear has been provided for that dwelling in accordance with the approved plans.


15. Condition No development shall commence until a Construction Transport Management Plan, to include detail of: (a) parking for vehicles of site personnel, operatives and visitors (b) loading and unloading of plant and materials (c) storage of plant and materials (d) programme of works (including measures for traffic management) (e) provision of boundary hoarding behind any visibility zones (f) HGV deliveries and hours of operation (g) vehicle routing (h) measures to prevent the deposit of materials on the highway (i) before and after construction condition surveys of the highway and a commitment to fund the repair of any damage caused (j) no HGV movements to or from the site shall take place between the hours of 8.30 and 9.15 am and 3.15 and 4.00 pm nor shall the

contractor permit any HGVs associated with the development at the site to be laid up, waiting, on the public highway during these times (k) on-site turning for construction vehicles

has been submitted to and approved in writing by the Local Planning Authority. The development shall be carried out in strict accordance with the approved details.


16. ConditionThe development hereby approved shall not be first occupied unless and until secure cycle parking for the flats and houses has been provided in accordance with the approved plans and shall thereafter be permanently provided for its designated purpose.

17. Condition Prior to the commencement of development a management plan/scheme for the mitigation of harm to and enhancement of the Starved Wood-Sedge shall be submitted to and approved in writing by the Local Planning Authority. The plan/scheme shall include:

Details of the scheme of supervision for within 20m radius of the plant

Replanting and relocation of plants where appropriate Maintenance of any trees and hedge required for the

enhancement of the species 10 year plan for monitoring and management Creation of a bespoke area where a new population of Starved

Wood-Sedge can growThe development shall be carried out in strict accordance with the approved details.

ReasonIn order that the development protect and enhance the ecological interest of the site in accordance with Policy NE1 of the Local Plan Part 1 2018.

18. Condition The development shall be carried out in strict accordance with the mitigation measures and sounds level to adhere to, contained within the noise assessment produced by Grant Acoustics dated 26th June 2018.

ReasonIn order that the development not result in harm by way of noise to the residential amenity of the area in accordance with Policy TD1 of the Local Plan Part 1 2018 and retained Policy D1 of the Local Plan 2002.

19. ConditionNo machinery or plant shall be operated, no process shall be carried out and no deliveries taken at or dispatched from the site except between the hours 08:00 – 18:00 Monday to Friday, 08:00 - 13:00 Saturday and not at any time on Sundays, Bank or Public Holidays.

ReasonIn order that the development not result in harm by way of noise to the residential amenity of the area in accordance with Policy TD1 of the Local Plan Part 1 2018 and retained Policy D1 of the Local Plan 2002.

20. Condition All vehicles, plant and machinery used on site and those under the applicant’s control moving to and from the site that are required to emit reversing warning noise, shall use white noise alarm as opposed to single tone “bleeping” alarms throughout the operation of the development hereby permitted.

ReasonTo protect residential amenity in accordance with Policy TD1 of the Local Plan 2018 (Part 1) and retained Policies D1 and D4 of the Local Plan 2002.

21. Condition No development shall take place, including any works of demolition, until a Construction Environmental Management Plan has been submitted to, and approved in writing by, the Local Planning Authority. The approved Plan shall be adhered to throughout the construction period. The Plan shall provide for:

i. An indicative programme for carrying out of the works ii. The arrangements for public consultation and liaison during the

construction works

iii. Measures to minimise the noise (including vibration) generated by the construction process to include hours of work, proposed method of piling for foundations, the careful selection of plant and machinery and use of noise mitigation barrier(s)

iv. Details of any floodlighting, including location, height, type and direction of light sources and intensity of illumination

v. the erection and maintenance of security hoarding including decorative displays and facilities for public viewing, where appropriate

vi. Wheel washing facilitiesvii. a scheme for recycling/disposing of waste resulting from demolition

and construction works

ReasonTo protect residential amenity in accordance with Policy TD1 of the Local Plan 2018 (Part 1) and retained Policies D1 and D4 of the Local Plan 2002.

22. Condition Prior to the first occupation of the units hereby approved, a lighting scheme setting out the location, type, and illumination levels of lighting to be provided on the site shall be submitted to and approved in writing by the Local Planning Authority. External lighting shall be installed on the site in strict accordance with the approved details prior to first occupation of the units and shall thereafter be retained.

ReasonTo ensure that external lighting is kept to a minimum and to comply with the recommendations of the Bat Conservation Trusts’ document entitled ‘Bats and Lighting in the UK – Bats and the Built Environment Series’, having regard to Policy NE1 of the Local Plan 2018 (Part 1).

23. Condition

There shall be no burning of any waste or other materials on the site during the demolition and construction phases.

Reason In order that the development not prejudice the air quality of the area nor the residential amenity in accordance with Policy TD1 of the Local Plan 2018 (Part 1) and retained Policy D1 of the Local Plan 2002.

24. Condition

No development shall take place, including any works of demolition, until a Dust Management Plan has been submitted to, and approved in writing by the Local Planning Authority. The plan can be part of a broader site Construction Management Plan but should detail all potential sources of particulate emissions and include appropriate mitigation measures.

Reason In order that the development not prejudice the air quality of the area nor the residential amenity in accordance with Policy TD1 of the Local Plan 2018 (Part 1) and retained Policy D1 of the Local Plan 2002.

25. Condition Prior to the commencement of development, full details of a scheme for the provision and maintenance of electric vehicle charging points within the development shall be submitted to and approved in writing by the Local Planning Authority. The electric vehicle charging points shall be provided on site to serve the units in strict accordance with the approved details prior to the occupation of the development.

ReasonsTo support users of low and ultra low emission vehicles and enable charging in convenient locations, and to ensure that the development does not prejudice the air quality of the area in accordance with Policies TD1 and ST1 of the Local Plan 2018 (Part 1), retained D1 of the Local Plan 2002, paragraph 110 of the NPPF 2018 and having regard to Surrey County Council’s Vehicular and Cycle Parking Guidance (January 2018).

26. Condition No development shall take place until the applicant has secured the implementation of a programme of archaeological work in accordance with a Written Scheme of Investigation which has been submitted by the applicant and approved by the Planning Authority.

Reason In the interests of preserving the archaeology of the site in accordance with retained Policy HE15 of the Waverley Borough Local Plan 2002.

27. ConditionThe development hereby permitted shall not commence until details of the design of a surface water drainage scheme have been submitted to and approved in writing by the planning authority. The design must satisfy the SuDS Hierarchy and be compliant with the national Non-

Statutory Technical Standards for SuDS, NPPF and Ministerial Statement on SuDS. The required drainage details shall include:

a) Evidence that the proposed solution will effectively manage the 1 in 30 & 1 in 100 (+40% allowance for climate change) storm events and 10% allowance for urban creep, during all stages of the development (Pre, Post and during), associated discharge rates and storages volumes shall be provided using a Greenfield discharge rate of 4.7l/s (as per the SuDS pro-forma or otherwise as agreed by the LPA).

b) Detailed drainage design drawings and calculations to include: a finalised drainage layout detailing the location of drainage elements, pipe diameters, levels, and long and cross sections of each element including details of any flow restrictions and maintenance/risk reducing features (silt traps, inspection chambers etc.).

c) Details of how the drainage system will be protected during construction and how runoff (including any pollutants) from the development site will be managed before the drainage system is operational.

d) Details of drainage management responsibilities and maintenance regimes for the drainage system.

e) A plan showing exceedance flows (i.e. during rainfall greater than design events or during blockage) and how property on and off site will be protected.

ReasonTo ensure the design meets the national Non-Statutory Technical Standards for SuDS and the final drainage design does not increase flood risk on or off site.

28. ConditionPrior to the first occupation of the development, a verification report carried out by a qualified drainage engineer must be submitted to and approved by the Local Planning Authority. This must demonstrate that the drainage system has been constructed as per the agreed scheme (or detail any minor variations), provide the details of any management company and state the national grid reference of any key drainage elements (surface water attenuation devices/areas, flow restriction devices and outfalls).

ReasonTo ensure the design meets the national Non-Statutory Technical Standards for SuDS and the final drainage design does not increase flood risk on or off site.

29. ConditionIn this condition 'retained tree' means an existing tree, which is shown to be retained in accordance with the approved plans and particulars referred to in Condition 1 (drawing numbers) (including ACD draft TPP); and paragraphs (a) and (b) below shall have effect until the expiration of 5 years from the first occupation of the development.

a) no retained tree shall be cut down, uprooted or destroyed, nor shall any retained tree be pruned other than in accordance with the approved plans and particulars, without the written approval of the Local Planning Authority. Any pruning shall be carried out in accordance with British Standard 3998 (tree work) and in accordance with any supplied arboricultural method statement.

b) if any retained tree is removed, uprooted, destroyed or dies, another tree shall be planted at the same place and that tree shall be of an appropriate size and species, and shall be planted at such time, as agreed in writing by the Local Planning Authority.

ReasonTo adequately protect all trees worthy of retention from development harm and to provide for their amenity contribution thereafter in line with Policy NE2 of the Local Plan 2018 (Part 1) and retained Policies D6 and D7 of the Local Plan 2002.

30. ConditionNo development shall commence, including any groundwork preparation, until a detailed, scaled Tree Protection Plan ‘TPP’ and related Arboricultural Method Statement has been submitted to and approved in writing by the Local Planning Authority. These shall include details of the specification and location of exclusion fencing, ground protection and any construction activity that may take place within the Root Protection Area of trees shown to scale on the TPP including installation of service routings and site access and addressing the heads of terms in the submitted ACD report. All works shall be carried out in strict accordance with the approved details.


31. ConditionNo development, groundworks or demolition processes shall be undertaken until an agreed scheme of supervision for the arboricultural protection measures has been submitted to and approved in writing by the Local Planning Authority. The supervision and monitoring shall be undertaken in strict accordance with the approved details. The scheme shall include details of a) a pre-commencement meeting between the Local Planning Authority Tree Officer and personnel responsible for the implementation of the approved development and b) timings, frequency & methods of site visiting and an agreed reporting process to the Local Planning Authority.


32. ConditionBefore work begins, cross sections/details indicating the proposed finished ground levels, surface materials including sub-base and depth of construction and method/materials used for edging, within protected zone around retained trees shall be submitted and approved in writing by the Local Planning Authority.


33. ConditionPrior to commencement of any works on site, details of any services to be provided or repaired including drains and soakaways, on or to the site, shall be submitted to and approved by the Local Planning Authority in writing and shall be carried out as shown. This requirement is in

addition to any submission under the Building Regulations. Any amendments to be agreed with the Local Planning Authority in writing.


34. ConditionNo development shall commence on site until a scheme for the landscaping and replacement tree planting of the site, including the retention of existing landscape features, has been submitted to and approved in writing by the local planning authority. Landscaping schemes shall include details of hard landscaping, planting plans, written specifications (including cultivation and other operations associated with tree, shrub, and hedge or grass establishment), schedules of plants, noting species, plant sizes and proposed numbers/densities and an implementation programme. All hard and soft landscaping work shall be completed in full accordance with the approved scheme, prior to occupation or use of the approved development or in accordance with a programme agreed in writing with the local planning authority. All new tree planting shall be positioned in accordance with guidelines and advice contained in the current British Standard 5837. Trees in relation to construction. Any trees, shrubs or plants planted in accordance with this condition which are removed, die or become damaged or become diseased within five years of planting shall be replaced within the next planting season by trees, and shrubs of the same size and species.

ReasonIn the interest of the character and amenity of the area in accordance with Policy TD1 of the Local Plan 2018 (Part 1) and retained Policies D1 and D4 of the Local Plan 2002.

35. ConditionNo above ground construction shall take place until samples of the materials to be used in the construction of the external surfaces of the development hereby permitted have been submitted to and approved in writing by the Local Planning Authority. Development shall be carried out in accordance with the approved details.


36. Condition No development shall take place until details have been submitted to and approved in writing by the Local Planning Authority showing the existing and proposed ground levels of the site and proposed ground levels of the buildings hereby permitted. The development shall be carried out in strict accordance with the approved details.


37. Condition Prior to the occupation of the dwellings, details shall be submitted to and be approved in writing by the Local Planning Authority to confirm that the dwellings have been completed to meet the requirement of 110 litres of water per person per day.

ReasonTo ensure sustainable construction and design in accordance with Policy CC2 of the Waverley Local Plan 2018 (Part 1).

38. Condition Prior to the first occupation, a strategy for the provision of the highest available headline speed of broadband provision to future occupants of the site shall be submitted to and approved in writing by the Local Planning Authority. The strategy shall take into account the timetable for the delivery of ‘superfast broadband’ (defined as having a headline access speed of 24Mb or more) in the vicinity of the site (to the extent that such information is available). The strategy shall seek to ensure that upon occupation of any dwelling, the provision of the highest available headline speed of broadband service to that dwelling from a site-wide network is in place and provided as part of the initial highway works, and the construction of frontage thresholds to dwellings that abut the highway. Unless evidence is put forward and agreed in writing by the Local Planning Authority that technological advances for the provision of a broadband service for the majority of potential customers will no longer

necessitate below ground infrastructure, the development of the site shall be carried out in accordance with the approved strategy.

ReasonTo ensure suitable broadband provision for all potential occupiers in accordance with Policy CC2 of the Local Plan2018 (Part 1).

39. Condition Prior to the first occupation of the units hereby permitted, full details of the proposed refuse and recycling stores to serve each unit shall be submitted to and approved in writing by the Local Planning Authority. The stores shall be provided on site prior to the first occupation of the units in strict accordance with the approved details and therefore shall be retained.

ReasonTo ensure that appropriate refuse and recycling facilities are provided for the future occupants of the site, having regard to Policy TD1 of the Local Plan 2018 (Part 1) and retained Policies D1 and D4 of the Local Plan 2002.

40. ConditionPrior to the construction of the community building the following details shall be submitted to and approved in writing by the Local Planning Authority:

Design of the building (which shall be limited to single storey) Statement of community involvement reflecting engagement with

the community in establishing its design and intended use(s) Details of who is to manage the building, including both the

physical fabric and the occupation of it Hours of use

The development shall be carried out in strict accordance with the approved details.

ReasonTo ensure that appropriate and high quality facilities are provided within the site, to accord with Policy LRC1 of the Local Plan 2018 (Part 1) and paragraph 92 of the NPPF 2018.

41. Condition The community building hereby permitted shall not be used for any purpose other than those consistent with Class D1 of the Town and Country Planning (Use Classes) Order 2987 (as amended), or in any

provision equivalent to the Class in any Statutory Instrument revoking and re-enacting that Order.

Reason To ensure that appropriate and high quality facilities are provided within the site, to accord with Policy LRC1 of the Local Plan 2018 (Part 1) and paragraph 92 of the NPPF 2018.

42. Condition Prior to the occupation of the development a detailed scheme for the management and design of the community garden shall be submitted to and approved in writing by the Local Planning Authority. The community garden shall be provided on site prior to the first occupation of the development in strict accordance with the approved details.

Reason To ensure that appropriate and high quality facilities are provided within the site, to accord with Policy LRC1 of the Local Plan 2018 (Part 1) and paragraph 92 of the NPPF 2018.

43. Condition Prior to the occupation of the development hereby approved a detailed scheme for the proposed Local Area for Play and Local Equipped Areas for Play shall be submitted to and approved in writing to the Local Planning Authority. The approved scheme shall be implemented in strict accordance with the approved details, prior to the first occupation of the development. The scheme shall include details of the equipment to be provided, its maintenance and inspections to be carried out by a qualified Inspector to check the quality of the equipment.

ReasonTo ensure that appropriate, safe and high quality play space is provided within the site, to accord with Policy LRC1 of the Local Plan 2018 (Part 1) and paragraph 96 of the NPPF 2018.

44. ConditionThe garages hereby approved shall only be used for incidental residential parking and storage as such and not for any trade, business or as ancillary accommodation

ReasonIn order to maintain sufficient parking for the development and to protect the character and residential amenities of the area in accordance with Policies ST1 and TD1 of the Local Plan 2018 (Part 1).

45. ConditionNotwithstanding the provisions of the Town and Country Planning (General Permitted Development) Order 2015 (or any other Order revoking or re-enacting that Order with or without modification), no outbuilding as defined within Part 1 of Schedule 2, Class E of that order, shall be constructed within the curtilage of units 173, 165, 154 and146 without the written permission of the Local Planning Authority.

ReasonIn order that the development does not result in harm to trees in accordance with Policy NE2 and TD1 of the Local Plan 2018 (Part 1).

46. ConditionNotwithstanding the provisions of the Town and Country Planning (General Permitted Development) Order 2015 (or any order revoking and re-enacting that Order with or without modification), no windows/dormer windows or other openings other than those expressly authorised by this permission shall be constructed in the southern elevation of units 13, 14 and 46 elevation without the written permission of the Local Planning Authority.

ReasonIn order that the development not be to the detriment to the residential amenity of neighbouring properties in accordance with Policy TD1 of the Local Plan 2018 (Part 1) and retained Policies D1 and D4 of the Local Plan 2002.

47. ConditionNotwithstanding the provisions of the Town and Country Planning (General Permitted Development) Order 2015 (or any order revoking and re-enacting that Order with or without modification), no roof extensions as defined within Part 1 of Schedule 2, Class B of that order, shall be constructed within the site without the written permission of the Local Planning Authority.

ReasonIn order that the development not be to the detriment to the residential amenity of neighbouring properties in accordance with Policy TD1 of the Local Plan 2018 (Part 1) and retained Policies D1 and D4 of the Local Plan 2002.

48. ConditionPrior to the occupation of the development details of any proposed boundary treatment shall be submitted to and approved in writing by the local planning authority. The development shall be carried out in strict accordance with the approved details.

ReasonIn order to protect the visual amenity of the area in accordance with Policy TD1 of the Local Plan 2018 (Part 1) and retained Policies D1 and D4 of the Local Plan 2002.

49. Condition The development shall not result in any obstruction to the public Rights of Way at any time. This shall include vehicles, plant, scaffolding or the temporary storage of materials and/or chemicals, and:

Any down pipes or soakaways associated with the development shall either discharge into a drainage system or away from the surface of the right of way; and

There shall be no encroachments by new fascias, soffits, gutters etc. over the boundary of the properties onto the public right of way.

ReasonIn order that the development shall not cause inconvenience to users of the Public Rights of Way, in accordance with Policy ST1 of the Local Plan 2018 (Part 1) and paragraph 98 of the NPPF 2018.

Informatives

1. ''IMPORTANT'' This planning permission contains certain conditions precedent that state 'before development commences' or 'prior to commencement of any development' (or similar). As a result these must be discharged prior to ANY development activity taking place on site. Commencement of development without having complied with these conditions will make any development unauthorised and possibly subject to enforcement action such as a Stop Notice. If the conditions have not been subsequently satisfactorily discharged within the time allowed to implement the permission then the development will remain unauthorised.

2. There is a fee for requests to discharge a condition on a planning consent. The fee payable is £116.00 or a reduced rate of £34.00 for household applications. The fee is charged per written request not per

condition to be discharged. A Conditions Discharge form is available and can be downloaded from our web site. Please note that the fee is refundable if the Local Planning Authority concerned has failed to discharge the condition by 12 weeks after receipt of the required information.

3. This permission creates one or more new units which will require a correct postal address. Please contact the Street Naming & Numbering Officer at Waverley Borough Council, The Burys, Godalming, Surrey GU7 1HR, telephone 01483 523029 or e-mail [email protected] For further information please see the Guide to Street and Property Naming on Waverley's website.

4. The applicant is reminded that it is an offence to disturb protected species under the Wildlife and Countryside Act 1981. Should a protected species be found during the course of the works, the applicant should stop work and contact Natural England for further advice on 0845 600 3078.

5. Design standards for the layout and construction of access roads and junctions, including the provision of visibility zones, shall be in accordance with the requirements of the County Highway Authority.

6. The Highway Authority has no objection to the proposed development, subject to the above conditions but, if it is the applicant’s intention to offer any of the roadworks included in the application for adoption as maintainable highways, permission under the Town and Country Planning Act should not be construed as approval to the highway engineering details necessary for inclusion in an Agreement under Section 38 of the Highways Act 1980. Further details about the post-planning adoption of roads may be obtained from the Transportation Development Planning Team at Surrey County Council

7. Details of the highway requirements necessary for inclusion in any application seeking approval of reserved matters may be obtained from the Transportation Development Planning Division of Surrey County Council

8. Notwithstanding any permission granted under the Planning Acts, no signs, devices or other apparatus may be erected within the limits of the highway without the express approval of the Highway Authority. It is not the policy of the Highway Authority to approve the erection of signs or other devices of a non-statutory nature within the limits of the highway.

mailto:[email protected]

9. The permission hereby granted shall not be construed as authority to obstruct the public highway by the erection of scaffolding, hoarding or any other device or apparatus for which a licence must be sought from the Highway Authority Local Highways Service.

10. The permission hereby granted shall not be construed as authority to carry out any works on the highway or any works that may affect a drainage channel/culvert or water course. The applicant is advised that a Streetworks permit and a Section 278 agreement must be obtained from the Highway Authority before any works are carried out on any footway, footpath, carriageway, verge or other land forming part of the highway. All works on the highway will require a Streetworks permit and an application will need to submitted to the County Council's Streetworks Team up to 3 months in advance of the intended start date, depending on the scale of the works proposed and the classification of the road. Please see http://www.surreycc.gov.uk/roads-and-transport/road-permits-and-licences/the-traffic-management-permit-scheme. The applicant is also advised that Consent may be required under Section 23 of the Land Drainage Act 1991. Please see www.surreycc.gov.uk/people-and-community/emergency-planning-and-community-safety/flooding-advice.

11. The developer is reminded that it is an offence to allow materials to be carried from the site and deposited on or damage the highway from uncleaned wheels or badly loaded vehicles. The Highway Authority will seek, wherever possible, to recover any expenses incurred in clearing, cleaning or repairing highway surfaces and prosecutes persistent offenders. (Highways Act 1980 Sections 131, 148, 149).

12. When access is required to be ‘completed’ before any other operations, the Highway Authority may agree that surface course material and in some cases edge restraint may be deferred until construction of the development is complete, provided all reasonable care is taken to protect public safety.

13. Section 59 of the Highways Act permits the Highway Authority to charge developers for damage caused by excessive weight and movements of vehicles to and from a site. The Highway Authority will pass on the cost of any excess repairs compared to normal maintenance costs to the applicant/organisation responsible for the damage.

14. The developer is advised that as part of the detailed design of the highway works required by the above condition(s), the County Highway Authority may require necessary accommodation works to street lights,

road signs, road markings, highway drainage, surface covers, street trees, highway verges, highway surfaces, surface edge restraints and any other street furniture/equipment.

15. The permission hereby granted shall not be construed as authority to erect a structure including telecommunication masts and associated equipment without a detailed design assessment. The applicant is advised that a detailed design must be approved from Surrey County Council Structures Team before any works are carried out on any footway, footpath, carriageway, or verge. Please telephone 0300 200 1003 to arrange for the detailed design to be assessed by Surrey County Council Structures Team.

16. The developer would be expected to agree a programme of implementation of all necessary statutory utility works associated with the development, including liaison between Surrey County Council Streetworks Team, the relevant Utility Companies and the Developer to ensure that where possible the works take the route of least disruption and occurs at least disruptive times to highway users.

17. It is the responsibility of the developer to ensure that the electricity supply is sufficient to meet future demands and that any power balancing technology is in place if required. Please refer to: http://www.beama.org.uk/resourceLibrary/beama-guide-to-electric-vehicle-infrastructure.html for guidance and further information on charging modes and connector types.

18. The developer is advised that Public Footpath No. 577 and Public Bridleway No. 6 cross the application site and it is an offence to obstruct or divert the route of a right of way unless carried out in complete accordance with appropriate legislation.

19. The applicant is advised that there may be protected species on site. In the event that any protected species are found work should cease immediately and Natural England contacted for further guidance.

20. The applicant’s attention is drawn to the letter from Surrey Wildlife Trust received 24/10/2018.

21. The applicant is advised that they made need a European Protected Species License before commencement of development.

22. The applicant’s attention is drawn to the letter from the Species Recovery Trust received 11/10/2018.

23. The granting of this planning permission does not in any way indemnify against statutory nuisance action being taken should substantiated complaints within the remit of the Environmental Protection Act 1990 be received. For further information please contact the Environmental Health Service on 01483 523393.

24. The applicant should take all relevant precautions to minimise the potential for disturbance to neighbouring residents during the demolition and/or construction phases of the development. The applicant should follow the guidance provided in the Construction Code of Practice for Small Developments in Waverley. The granting of this planning permission does not indemnify against statutory nuisance action being taken should substantiated noise or dust complaints be received. For further information please contact the Environmental Health Service on 01483 523393.

25. All gas-fired boilers provided in relation to this application shall meet a minimum emissions standard of 40 mg NOx/kWh.

26. If proposed site works affect an Ordinary Watercourse, Surrey County Council as the Lead Local Flood Authority should be contacted to obtain prior written Consent. More details are available on our website.

27. If proposed works result in infiltration of surface water to ground within a Source Protection Zone the Environment Agency will require proof of surface water treatment to achieve water quality standards. If there are any further queries please contact the Sustainable Drainage and Consenting team via [email protected]. Please use our reference number in any future correspondence.

28. The Developer / Management must inform Waverley Borough Council’s Environmental Services Department at least four weeks prior to the proposed date of initial occupation, in order that final arrangements for refuse and recycling collections can be made

29. With regard to the required specification for refuse provision, the Applicant’s attention is drawn to the Council’s Guidance on refuse and recycling provision for new homes http://www.waverley.gov.uk/downloads/file/4123/guidance_on_refuse_and_recycling_provision_for_new_homes

30. The applicants attention is drawn to the response from Thames Water received 13/08/2018

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http://www.waverley.gov.uk/downloads/file/4123/guidance_on_refuse_and_recycling_provision_for_new_homes

http://www.waverley.gov.uk/downloads/file/4123/guidance_on_refuse_and_recycling_provision_for_new_homes

31. The applicants attention is drawn to the response from Surrey Police dated 02/08/2018 and the Applicant is strongly encouraged to seek Secured by Design certification.

32. Safe public access must be maintained at all times. If this is not possible whilst work is in progress then an official temporary closure order will be necessary. Notice, of not less than 6 weeks, must be given and the cost is to be borne by the applicant.

33. Any alteration to, or replacement of, the existing boundary with the public right of way, or erection of new fence lines, must be done in consultation with the Rights of Way Group. Please give at least 3 weeks notice.

34. Access along a public right of way by contractors’ vehicles, plant or deliveries can only be allowed if the applicant can prove that they have a vehicular right. Surrey County Councils’ Countryside Access Group will look to the applicant to make good any damage caused to the surface of the rights of way connected with the development.

35. The applicant is reminded that the granting of planning permission does not authorise the obstruction or interference with a public right of way.

RECOMMENDATION B That, in the event that the requirements of recommendation A are not met, permission be REFUSED for the following reasons:

1. The applicant has failed to enter into an appropriate legal agreement to secure a programme of highway improvement works and Travel Plan to mitigate the impact of the traffic generated by the development. As such, the proposal would fail to limit the significant impacts of the development on the surrounding highway network. The application therefore conflicts with Policy ST1 of the Local Plan 2018 (Part 1) and fails to meet the transport requirements within Section 4: Promoting Sustainable Transport of the NPPF 2018.

2. The applicant has failed to enter into an appropriate legal agreement to secure the provision of/contributions towards: education infrastructure; recycling containers; off-site leisure and greenspace areas; off site GP capacity; Surrey Police recruitment and equipment, on-site open space and play space provision and maintenance; environmental enhancements; SuDS provision and maintenance, and self build plots. The proposal therefore conflicts with Policy ICS1 of the Local Plan 2018 (Part 1) and paragraph 92 of the NPPF 2018.

3. The applicant has failed to enter into an appropriate legal agreement to secure the provision of affordable housing within the meaning of the NPPF,

appropriate to meet Waverley Borough Council’s housing need. The proposal would therefore fail to create a sustainable, inclusive and mixed community, contrary to the requirements of Policy AHN1 of the Local Plan 2018 (Part 1) and paragraph 61 of the NPPF 2018.

wa/2018/1239 erection of 262 dwellings (use class c3 ... a… · recommendation b that, in the...

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