Effingham Residents Association letter of Objection to Berkeley Homes/ Howard of Effingham Planning application


EFFRA LOGO

 

 

 

Mr. J. Busher,

Senior Planning Officer,

Guildford Borough Council,

Millmead House, Millmead,

Guildford, Surrey,

GU2 4BB 

12th January 2015

Dear Mr. Busher

Re: Planning application 14/P/02109

 

Hybrid planning application for outline permission (only access to be considered) for the erection of a replacement secondary school for Howard of Effingham and up to 258 residential dwellings with means of access at Howard of Effingham School and Lodge Farm, Lower Road following demolition of all existing buildings; and full permission for the erection of 37 dwellings, with access, parking and landscaping works on land at Brown’s Field, Brown’s Lane, Effingham.

This letter registers the strong objection of the Effingham Residents Association (EFFRA) to the development proposed in the above Planning Application 14/P/02109 submitted by Berkeley Homes (Southern) Ltd and the Howard of Effingham School and requests Guildford Borough Council to refuse it planning permission. We believe that we represent the majority of Effingham residents in requesting planning refusal due to extensive consultations with residents during 2014 and 2015 (see Annex). Our position is further underlined by the high volume of individual letters of objections submitted by residents and we urge Guildford Borough Council to give proper weight to residents’ concerns in considering the planning application and to refuse it planning permission.

SUMMARY OF EFFRA’s RESPONSE

  1. GROUNDS FOR OBJECTION

1.1 Negative impact of proposed development on the village and its infrastructure

  • The proposed development is totally out of scale for a small rural village representing a major 27% increase in size or 90% of the size of the current Settlement Area and changing it from a rural urban to an urban settlement against residents’ wishes and GBC policy for the village.

  • The new building density would be much higher than the existing buildings

  • The new buildings’ character especially the proposal of many three storey buildings would destroy the character of the village and its Conservation Area

  • It would cause major traffic, pedestrian safety and infrastructure problems.

1.2 The Application is in serious breach of Planning Guidelines including NPPF Guidelines on the Green Belt.

  • The proposed development is on Green Belt and outside the village Settlement Area. The applicants claim the application of the sixth listed exception case in paragraph 89 of the NPPF ie: “limited infilling or the partial or complete redevelopment of previously developed sites (brownfield land).” However, it does not apply as only one of the three sites (the existing school site) is brownfield, with the majority of the land proposed for building being green field and the large size of the development cannot constitute “limited infilling.”

  • The size of the proposed development would necessitate a change in Green Belt boundaries and therefore the stricter test of “exceptional circumstances” should apply which it would not meet.

  • The development would not be sustainable and it would cause major harm to the Green Belt. The land proposed for building meets all five purposes of the Green Belt. It is particularly important in checking unrestricted urban sprawl through the south west corridor from London and preventing the merging of the rural village of Effingham with Little Bookham and the urban conurbation of Bookham/Fetcham in Mole Valley.

  • The Application does not establish a case of special educational need to rebuild the Howard School and increase its size. Public information shows that its buildings are good, it is meeting current demand and future demand is in other areas of Surrey which is due to be met by other new schools which have been given public funding, which has been denied to the Howard because of lack of proven need.

  • The proposed housing would not be sustainable and does not meet the needs of the village, being too large and comprising mainly family housing instead of housing with one and two bedrooms as revealed by the Village 2013 Housing Requirements Survey.

  • As the proposed development is within 7km of an SPA (Special Protection Area) it also requires a large SANG (Suitable Alternative Natural Greenspace) for it to be considered. This does not currently exist and proposals to make Effingham Common a large SANG are inappropriate on environmental grounds, contrary to the purposes of common land and against the wishes of Effingham residents.

  • The applicants contend that the Draft Guildford Local Plan should be taken into account in considering the application and that it gives weight to the application citing paragraph 216 of Annex 1 of the NPPF. However, proper application of the paragraph would give weight to refusing the application as the Plan is now being reviewed, the major unresolved objections to it including on this specific proposal, together with the fact that it is not consistent with the NPPF.

  1. SERIOUS INCONSISTENCIES AND INACCURACIES IN THE PLANNING APPLICATION

Much of the information on which the application is based is incorrect or flawed including planning status, traffic and environmental data which must seriously affect the credibility of the planning application.

EFFRA considers that this application represents a new and disturbing initiative by a developer ie. the purchase of Green Belt land for the specific purpose of offering to rebuild a school on it solely in order to be able to build residential homes on land which would normally have complete protection from such development. If approved it would not only be a major breach of Green Belt policy and the NPPF Guidelines, but would set a precedent for other developers to buy up Green Belt land and rebuild existing or new schools in order to gain permission for residential development on Green Belt, even where there is no established need for the rebuilding of the school and the Department of Education has previously denied funding for it.

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1   GROUNDS FOR OBJECTION

1.1   Negative impact of proposed development on the village and its infrastructure

The proposed development would represent seriously disproportionate development. The proposals are wholly out of scale for a small rural village with only 1,000 homes and limited existing infrastructure which has historic constraints on growth. The density and character of the development would destroy the character of the village and its Conservation Area and exacerbate existing issues with peak time traffic congestion, pedestrian safety and infrastructure capability.

1.1.1 Disproportionate development resulting in urbanisation of village

  • The proposed development would disproportionately increase the size of Effingham by 295 dwellings, representing a major 27% increase in size or 90% of the size of the current Settlement Area. Such an increase would change Effingham from a rural to an urban settlement, which is the stated intention of the application, viz: The Application’s Design and Access Statement defines its vision as “a sustainable urban extension to the existing settlement of Effingham..” and the Mission Statement defines Effingham as “an attractive town..” It would be against residents’ wishes and also be against Guildford Borough Council’s (GBC’s) current planning policy for Effingham which is currently classified as a “rural medium sized village” where expansion should be limited to infilling.

  • Effingham is a surviving example of a typical Surrey village with a small historic centre and dispersed rural settlement around it and the GBC Landscape Assessment Report in January 2007 prescribed maintaining “the existing dispersed nature of rural settlement avoiding expansion of settlement along roads (for instance northwards from Effingham..”

  • Effingham residents do not share the applicants’ urban vision and wish the village to remain rural and to continue to grow organically. Effingham is currently preparing its own village plan. As part of this a Housing Requirements Survey was made in 2013 which showed that the village requires a much smaller number of houses – a maximum of 157 houses in the next 15 years.

1.1.2 Inappropriate housing as density, type and style does not meet local need

  • Density of proposed dwellings inappropriate The density of the proposed dwellings is much higher density than existing nearby housing at between 8.8 and 11.4 units per acres whereas the surrounding roads are no higher than 5 units per acre. This would destroy the rural character of the village as it is characterised by small scale low density housing, interspersed with green fields, small footpaths and rural lanes.

  • The type of housing proposed does not meet the needs of the village The 295 new dwellings appear to be mainly family housing, although numbers of bedrooms are not specified for 258 of them (Planning Application Form Section 17). No affordable or rentable housing is specified and Berkeley Homes has since confirmed that it will not be building affordable homes. The Effingham Housing Requirements Survey in 213 found that most of the 157 houses required were for single and dual person households. Effingham already has sufficient family housing and more will be available from future downsizing. An increase would require more infrastructure and be self-fulfilling in requiring more school places.

  • The style and character of the buildings are inappropriate. Much of the proposed new school and a large proportion of the residential development is proposed to be three storey or up to 13.5 metres in height. Three storey buildings are out of character for the village. GBC has turned down proposals to build a three storey building on the existing school site as inappropriate. The height of these proposed buildings would be visible from the Conservation Area and the urban style of the new school buildings unsuited to the rural character of the area. Drawings of the proposed residential units have only been submitted for Browns Field, which is the only site without proposed three storey buildings, whereas the other two sites are proposed to have a high proportion of three storey buildings.

1.1.3 Unnecessary overexpansion of school causing problems to the village.

  • The proposed size of the school would make it the largest secondary school in Surrey. It is currently already in the 92th percentile nationally and the proposed increase would put it in the 95th (Source: OFSTED) It is quite inappropriate to a rural village. Most large schools are in urban areas with high and dense populations, with school journeys by walking or public transport.   Most of the Howard pupils do not live close to the school and have to be either bussed in or brought in by car. The size of the current school, which has been allowed to grow piecemeal, already causes traffic and infrastructure problems in the village and on local roads. A larger school would exacerbate these problems as it would draw pupils from a wider area.

  • Very large schools are not beneficial for pupils and research shows that performance falls in very large schools.

  • The school is currently meeting the demand in its catchment area and no unmet growth in pupil numbers is forecast in this part of Surrey. The increased places in the school would be taken by the new houses or pupils travelling in from outside the area adding to the traffic problems on local roads. The current school buildings are fit for purpose and could be upgraded by other means in a sustainable programme of work.

  • Funding for other new schools in the area have been agreed which will increase places available and parental choice.

1.1.4 Infrastructure limitations including traffic, safety, flooding and water supply concerns

  • The proposed development would cause major traffic congestion especially in peak periods. The proposed measures to avoid it are inadequate and in some cases inappropriate. The Application states that there is currently traffic congestion in the area due to on street parking at the school, bussing in of pupils and parent drop-offs and pick-ups and that the proposed development would improve this. However, it would exacerbate the situation as 295 new houses and 400 additional school places would result in approximately 2,000 more car journeys a day in the village. There are no sufficient measures to alleviate such an increase. During construction the problem will be worse as the village roads are ill-equipped to deal with heavy vehicles. Effingham Common Road has a bad accident record, with heavy morning queuing to the station carpark and the junction with Forest Road. The proposed mini roundabout will increase congestion and waiting times (including CO₂ generation) on that road.

  • The proposed development would increase safety dangers to pedestrians. The village has limited pedestrian access and footways which cannot be increased without harming its Conservation Area. The proposed traffic calming, giving northbound traffic priority and increased pedestrian footway in The Street at its current pinch point near the old surgery at Crossways, will cause major traffic back up in The Street and will lead to the neighbouring roads of Church Street and Manor House Lane being used as cut throughs. The above lanes are unsuitable for increased traffic and would increase safety risks to pedestrians. Browns Lane, Church Street lead to and from St Lawrence School and the Howard School and Manor House Lane leads to and from Manor House School and the Howard School. Neither of these narrow lanes have continuous footpaths, both are unlit and have limited road markings. They are both historic lanes at the heart of Effingham and Little Bookham Conservation Areas respectively. Increased traffic in these roads (especially heavy construction vehicles) would be very damaging to the old buildings and flint walls and present a significant risk to life.

  • Increased risk of flooding. The Application seeks to build on an area on a known spring line with a history of flooding. This is acknowledged by the proposed use of piling on the existing school site. However, there is a similar history on the Effingham Lodge Farm site, but which to date has not been exacerbated by major building on the site and it is similarly registered as an area of high flooding risk. Despite this, the Application falsely states that Effingham Lodge Farm has “no significant risk or history of flooding” (page 35 Design & Access Statement. Site Analysis). The site drains to the east which had major flooding in the winter of 2013. The measures proposed to mitigate this are considered by experts as inadequate.

  • Water supply and sewage provision to the area is already under strain and Thames Water has stated that it is concerned that the network in the area would be unable to support the increased demand (EIA Screening Response, Thames Water 30 December 2013), a view supported by the local water company.

1.1.5 Effect on Historic Setting and conservation considerations

  • Effect on Historic Setting of village. The dwellings are proposed to be built on three sites close to the village’s important Conservation Area and the Conservation Area of the neighbouring village of Little Bookham. Whilst Effingham has no written Conservation Policy apart from the GBC Landscape Assessment Report in January 2007, Little Bookham Conservation area has an Appraisal & Management Plan published in June 2011 which is relevant also to the neighbouring Effingham Conservation Area which shares many of its characteristics. This emphasises the importance of its rural character and setting and the open views across the fields. Effingham Lodge Farm is an important green space to the north of the village and provides views from the Conservation Area to the ancient woodland and Commons beyond. Building on Effingham Lodge Farm would adversely affect the two Conservation Areas and join the two historic villages which are currently separated by a field which enhances the rural character of the adjoining Conservation Areas. Browns Field forms an important green space in the village, contributing to the rural character of the village and the Conservation Area of which it is part.

  • Loss of Wildlife Corridor and Negative Effect on Protected Species. Effingham Lodge Farm forms part of a wildlife corridor between the Surrey Hills and Effingham and Bookham Commons, which is particularly important as it is the first such corridor since Epsom. Effingham Lodge Farm contains a diverse mix of wildlife including a number of protected species noted in the short four day survey carried out for the application and is highly valued by local residents. The loss of the farmland at Effingham Lodge Farm would not only mean the loss of the wildlife and ecology there, but would affect the neighbouring Effingham Common

1.2   The Application is in serious breach of Planning Guidelines

The applicants propose to build on Green Belt land by citing the clauses in the NPPF that allows development in certain circumstances. In order to build on Green Belt land the NPPF states that there must be “very special circumstances.”   The new planning guidance adds that “Once established, Green Belt boundaries should only be altered in exceptional circumstances” and development must be “sustainable.” The Application is based on the “very special circumstances” test, but as such a large and dense development on Green Belt would change Green Belt boundaries clearly the “exceptional circumstances” test should apply. The Guidance adds that ‘very special circumstances’ will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations. EFFRA does not believe that this application established either “special” or “exceptional circumstances,” it believes the proposed development does not meet the criteria of a sustainable development and it believes that the harm to the Green Belt by agreeing to it would be very high.

1.2.1     The Application does not meet any of the listed “exceptions” in the NPPF. Only one of the three sites is “previously developed land” and it cannot be considered as “infilling”.

The applicants argue that the application meets the sixth exception case in paragraph 89 of the NPPF ie: “limited infilling or the partial or complete redevelopment of previously developed sites (brownfield land), whether redundant or in continuing use (excluding temporary buildings), which would not have a greater impact on the openness of the Green Belt and the purpose of including land within it than the existing development.”

However, the application clearly does not meet this criteria as:

  • Only one of the three sites (site 1 the existing school) is a “previously developed site” or a brownfield site. Site 2 Browns Field has never been developed. Site 3 Effingham Lodge Farm is 60 acres of good agricultural land. It has only 12,815 sqm of buildings according to the applicants (which represent 19% of the total area) and these are almost entirely temporary which are specifically excluded from the exception above. Two buildings are residential built for agricultural workers and the greenhouses which cover the largest area were specifically defined as temporary by GBC (letter of 30 May 2000 signed by the Head of Development) when permission was given for permanent use of the small office building for B1 use against the wishes of Effingham Parish Council.

  • The building of 295 houses representing 27% of the size of the current village cannot be categorised as “infilling,” especially as it is beyond the settlement boundary of the village.

  • The proposed development would obviously have a greater impact on the openness of the Green Belt and the purpose of including land within it. This development would destroy the open views from the village to the north of the village and Conservation Areas and replace them by dense residential development and school buildings. It would physically join Effingham with the neighbouring village of Little Bookham by building over the current field that separates them which currently has no buildings on it and build over an important field at the centre of the village.

1.2.2     The school does not have a need for rebuilding that is “special” or “exceptional.”

The Application makes six major claims for special circumstances based on a claimed need to rebuild and expand the size of the school in paras 1.11-1.17 of its Planning Statement. These are weak and are not supported by the Educational Needs Statement which contains misleading and unreliable data as detailed in rebuttal of the six claims as follows:

  • School Buildings are good, the provision of playing fields is more than sufficient and there is no need for an Increase in the Size of the school

     The School Buildings The Application’s claims that the standard and maintenance of the school buildings are very poor are not supported by information from Surrey County Council (SCC). In a recent prioritisation of needs assessment for rebuilding SCC ranked the school 52 of 53 schools in priority of needs, based on the condition of its buildings and the quality of its classroom size. The Maintenance of the buildings is also good as the last SCC audit in 2011 highlighted only £656,000 of work was required of which about £300,000 was regular ongoing maintenance. Based on its current pupil size, it also currently more than meets standard BB103 for the amount of buildings recommended. As the school is currently rated outstanding and it is the academy’s duty to maintain its buildings it is not surprising that the current buildings are considered more than adequate. The school was denied public funding by the EFA (Education Funding Agency) to rebuild on Effingham Lodge Farm in 2013, which, as funding has been available for new schools in the area, shows that it was not considered a priority. The Department of Education Survey of July 2103 which underlay this decision showed that 66.3% of the school’s buildings were good and 22.7% were adequate The desire for a new buildings appears to be based on a “want” rather than a “special need” and is obviously insufficient to justify the relocation of the school and the development of 295 houses on Green Belt land.

     It is clear from the sparse details in the application that detailed examination of improving and expanding the school buildings and increasing their energy efficiency on its present site have not been adequately carried out. The only sites assessed as alternatives in the application are significantly outside the catchment area compared to the four other sites currently identified by the Department for Education and GBC.

     The Schools’ Playing Fields The applicants claim that the school has inadequate playing fields with the amount quoted varying between 25% and 45% of the required amount in their documents. This is more than disingenuous as the school has the use of the Effingham King George V Playing Fields, which give it more than 100% of the playing fields it needs. The school claims these do not count as they are licenced, but Department of Education figures show that over 60% of secondary school playing fields are leased or licensed and that this is not a problem.

     The Application’s claims that “Essential teaching and learning provision has been lost by having to travel to Browns Field and King George V fields for lessons” is obviously untrue as at a 200 metre walk (also according to the applicant but in fact somewhat less) from the school they are at a similar distance to the proposed playing fields. They belong to the village and are managed by Trustees who are sympathetic to the school’s needs and would consider any upgrading necessary. Safety is also mentioned, but there has been only one recorded incident and the village has an excellent safety record. The future of these playing fields would be put in jeopardy by the school having separate playing fields on Effingham Lodge Farm. Such duplication would not make sense in a small rural village where both sets of playing fields could not both be fully utilised. Playing fields are not environmentally friendly and destroying the ecology of the Effingham Farm fields to duplicate the existing playing field makes no sense. Additionally, the KGV playing fields have good drainage, whereas this is likely to be a major problem for the proposed playing fields.

     Comments have also been made by the applicant about the cost of use. However, the fee charged by the Trustees is much less than the costs that would be incurred by the school for maintaining playing fields for their majority use.

     Size of the School. The school at 1,600 pupils is already one of the largest in Surrey. It is also one of the largest nationwide to be based in a rural village, as schools are supposed to be located close to their pupils’ homes to avoid unsustainable travelling to school in the interests of the pupils themselves, minimising school traffic on local roads and the local community. Only about 10% of the School’s pupils are from Effingham. Increasing the school to 2,000 would not only make it the largest school in Surrey, but one of the largest schools in the UK to be based in a small village. To justify such an increase there should be an overriding need, but this does not exist. SCC figures show that it has offered places to all pupils selecting it in first place during the last five years and there have been an average of 19 unmet 1st preference applications from outside the catchment area. Contrary to what the application says increasing the size of the school will therefore not meet unmet demand or increase parental choice. No increase in demand is forecast in this part of Surrey and there is currently spare capacity, unless the enabling development is approved and provides it. Increased demand is forecast in other areas such as north and east Guildford and plans are in place to expand or build new schools to the west, east and north of Effingham which will increase parental choice and may well reduce demand for the school, removing any justification for any further spaces at the Howard.

  • The Location is Inappropriate for a Dedicated Autism Centre

     EFFRA is supportive of dedicated autism centres, but believes that this proposal has been added to attempt to bolster up a weak case of “special need,” as the Howard does not have a good track record or known interest in Special Need pupils. Effingham is a rural village with relatively poor local transport links and cannot be the ideal site for such a centre which should be in a more populated area to avoid excess travelling by those who require these services.

  • Enabling Housing development is not necessary to rebuild schools

     EFFRA believes that the Application’s statement that “enabling housing development is required to deliver the school” is untenable. The building and rebuilding of schools is the responsibility of the local authority and the Department for Education which in law is resourced to do this and therefore enabling housing development cannot be a requirement. The Department for Education has declined to fund the expansion of the school due to lack of proven need.

  • No alternative site for the school is necessary and enabling development is inappropriate to fund a new school

     The application does not establish the need for an alternative site for the school and it does not appear that any real alternatives to Effingham Lodge Farm have been properly examined. Other alternative sites have been found which have not been considered.

  • Effingham already has socially inclusive recreational facilities in its King George V Playing Field and new playing fields would threaten their viability

     The proposition that the development would allow for “the provision of socially inclusive facilities in the form of enhanced recreational and community facilities for the local area” is obviously incorrect, when this is already provided by the community owned King George V Playing Fields, the future of which would be jeopardised by alternative playing fields so close by.

  • The Housing Need is not established and Guildford Residents’ Adverse Response to the Inclusion of this location in the Draft Local Plan and the lack of consistency of the policies to those of the NPPF weigh against the application

     The applicants contend that paragraph 216 of Annex 1 of the NPPF states that the Draft Guildford Local Plan should be taken into account in considering the application and that it gives weight to the application. However, correctly applying the whole paragraph to the application would instead weigh against it as the Plan is not advanced in preparation as its now being reviewed, the unresolved objections to it weigh against it, together with the fact that it is not consistent with the NPPF. The Draft Local Plan is currently being revised following a consultation process which produced over 20,000 responses and opposition to the excessive projection of housing need and pro-development policies and revision of Green Belt boundaries in the Draft Plan. The identification and registration of these Effingham locations in the Draft Local Plan at a very late stage initiated by the applicants, against the wishes and without the knowledge of the Effingham Parish Council or Borough Councillor for Effingham, and the high number of objections to them by residents during the consultation process (making it a key theme in the document: “Summary of key themes from the draft Guildford borough Local Plan”) should mean according to the above paragraph that weight is given to the opposition to it. Housing need in Guildford is still being established and Effingham has carried out its own establishment of its housing need (see page 2 above) which does not tally with the proposals.

1.2.3     The proposed residential development is not sustainable and does not meet the needs of the community

The proposed development is clearly not sustainable. It will cause serious environmental and social problems to the community during six years of construction and the finished development would dramatically increase current traffic and pedestrian safety issues and place a further strain on infrastructure. Two of the sites are flood prone and the proposed measures to avoid flooding are insufficient. Demolishing school buildings that are capable of upgrading and replacing them with mainly three storey structures which have been selected because of lack of space due to the enabling development can clearly not be defined as sustainable. The development and rebuilt school have also been show not to meet the needs of the community. Further, embedded carbon via demolition of existing buildings and factors such as increased traffic and car parking have not been considered.

1.2.4     The Subject Land meets all the criteria of the NPPF to be designated “Green Belt” and building on it would cause substantial harm to it

EFFRA believes that it would be difficult to find a piece of land that more fits the five criteria of the Green Belt than Effingham Lodge Farm, whilst Browns Field and the undeveloped areas of the existing school site also make important contributions:

  • Effingham checks unrestricted urban sprawl as it is the first green space after the large built-up areas of the Fetcham/Bookham conurbation and is also the first area of Green Belt open countryside in the south west route out of London. Building on Effingham Lodge Farm would effectively add Effingham to the Fetcham/Bookham conurbation.

  • The three sites and in particular Effingham Lodge Farm form a green barrier between Effingham and Little Bookham and prevent the two villages merging into each other.

  • Effingham Lodge Farm safeguards the countryside to the north of Effingham and protects the ancient woodland behind it contributing to the important ecology and wildlife of the area.

  • The land is important in maintaining the rural setting of the village and the two Conservation Areas adjacent to it.

  • Building on this land would discourage the use of brownfield land elsewhere.

1.2.5     Provision of a SANG

As the proposed development is within 7km of an SPA (Special Protection Area) we understand that it also requires a large SANG (Suitable Alternative Natural Greenspace) for it to be considered. There have been proposals to make Effingham Common a large SANG and the provision of a carpark for this purpose has been proposed. Effingham Parish Council, EFFRA and Effingham residents (in their replies to EFFRA’s survey in August 2013 (see Annex) have made it clear that they do not want a carpark on Effingham Common (and indeed it is illegal to put a carpark on common land without proper consents) and that they do not want Effingham Common to become a large SANG. A SANG is intended to draw visitors away from an SPA. Effingham Common is an area of varied and important wildlife with some protected species which should be managed for its wildlife. This is how Effingham residents understood the Common would be managed when it was purchased by GBC.  An increase in visitors for recreation rather than wildlife is not in the interests of encouraging the wildlife of the Common and especially when such species as skylarks which are ground nesting would be disturbed.

2   SERIOUS INCONSISTENCIES AND INACCURACIES IN THE PLANNING APPLICATION

Much of the information on which the application is based is incorrect or flawed including planning status, traffic and environmental data which must seriously affect the credibility of the planning application.

In addition, the documents submitted by the applicants give a misleading impression of community support for the development. Their evidence for such support consists solely of the results of a questionnaire from the first exhibition put on by Berkeley Homes on 26th April 2014, which was largely attended by school parents from outside Effingham as it was not advertised to Effingham residents as noted in their Statement of Community Involvement 5.12. Even then the support was only 69% and the results from the later exhibitions attended by Effingham residents have not been submitted by the applicants.

The most important inaccurate areas of information are:

  • Incorrect claim of use of sixth exception case in paragraph 89 of the NPPF Claim for “limited infilling or the partial or complete redevelopment of previously developed sites (brownfield land)”, as only one of three sites is brownfield.

  • Incorrect classification of Effingham Lodge Farm is a brownfield site when it is a green field site as clearly demonstrated in the GBC planning file .

  • Incorrect citing of the NPPF as regards the impact of the Guildford Draft Local Plan on the application.

  • Wrongly stating that Effingham is a town and proposing an urban extension to it when it is classified by GBC as a medium sized rural village where such development is inappropriate.

  • Claim that Site 3 has no significant risk or history of flooding.

  • Claim that development would improve Effingham’s traffic problems when they would exacerbate them.

  • Incorrect information on the state of the school buildings, demand for the school and appropriate size of the playing fields the school currently uses.

  • Conflicting information on phasing and sequence of construction.

EFFRA considers that this application represents a new and disturbing initiative by a developer ie. the purchase of Green Belt land for the specific purpose of offering to rebuild a school on it solely in order to be able to build residential homes on land which would normally have complete protection from such development. If approved it would not only be a major breach of Green Belt policy and the NPPF Guidelines, but would set a precedent for other developers to buy up Green Belt land and rebuild existing or new schools in order to gain permission for residential development on Green Belt, even where there is no established need for the rebuilding of the school and the Department of Education has previously denied funding for it.

EFFRA has cooperated in producing the supporting documentation to the Effingham Parish Council submission and fully endorses it and the comments and objections of Effingham Parish Council.

EFFRA is committed to ensuring that Effingham continues to balance appropriate growth with community need and its historic and rural characteristics and limitations. We are confident that Guildford Borough Council will view this application as constituting inappropriate development in the Green Belt and wholly lacking the required “very special” or “exceptional” circumstances required for it to be approved.

In light of the extensive local interest in this application and its importance to the future of Effingham, we would welcome the opportunity to present our case at the planning review. Contact details are provided below.

Yours sincerely

David J King

Hon. Sec.

ANNEX

 

CONSULTATIONS WITH EFFINGHAM RESIDENTS ON PROPOSALS IN PLANNING APPLICATION 14/P/02109 WITH RESIDENTS IN 2014 AND 2015

All Effingham residents over the age of 18 are EFFRA members. The following have been used to ensure EFFRA has fairly represented residents’ views in making its response to this application:

  • Questionnaire circulated to residents for their views in August 2014, following drop-in sessions in 2014 by Berkeley Homes to explain its plans and by Guildford Borough Council on the Draft Local Plan. The responses showed that 93% of the 350 respondents were against the plans and 97% were against any change in Green Belt boundaries in Effingham. (Copy of results emailed to you at Guildford Borough Council on 19th December 2014).

  • Participation in a public meeting on the proposals held with Effingham Parish Council on 9th December 2014 .

  • Informal consultations and discussions with residents – oral, letter, email and via EFFRA website.

  • Individual letters of objection from Effingham residents.