Guildford Borough Council’s (GBC) barrister, Charles Streeten, has submitted his concluding remarks to the Planning Inspector into the appeal by Berkeley Homes for 110 additional homes on the Green Belt (see our post Public Inquiry ends into 110 Homes on the Green Belt), with copies for Effingham Parish Council (EPC), and Berkeley Homes. His statement can be read on the EPC website here. Needless to say, he found numerous reasons to conclude the appeal should be dismissed.
Appeal APP/Y3615/W/22/3298390 for the detailed design of 99 homes on the existing school site, was concerned with “…the harm the tranquillity, setting and significance of the Little Bookham Conservation Area, and the listed building (and its curtilage) known as All Saints Church…” The GBC case was that the harm could be reduced by a redesign of the planning application (which already has outline planning permission).
Appeal APP/Y3615/W/22/3298341 for an additional 110 homes on the Green Belt on the Effingham Lodge Farm site, was concerned with the harm to the Green Belt, and the overly urban form of development harming the character and appearance of the rural character of the area, especially along Effingham Common Road.
Berkeley Homes case rested on Very Special Circumstance which would allow them to build on the Green Belt to enable them to rebuild the school. There was agreement that there were two issues to resolve:
- Is the proposal necessary to enable delivery of the school?
- Is there an alternative ways the school consented by the 2018 permission can be provided?
Winesses to the Inquiry agreed that there had been considerable scope creep since the 2018 decision. The school was larger than necessary. And that the school had been designed to a brief, rather than to a budget as is standard practice. Consequently the costs for the replacement school are significantly greater than they need to be, and that an alternative design of the school could meet the educational needs of a replacement school at significantly lower cost. The current cost of the replacement school is significantly larger than that which the Department for Education would pay for.
Serious questions were raised about the cost model used, to justify the costs of the replacement school. Mistakes were identified, and a sample of the costs were found to be inflated above the standard industry figures.
Berkeley Homes claimed that GBC did not have a 5 year-housing supply. However, an independant expert has concluded that GBC conservatively has a 5.8 housing supply.
The evidence presented at the Inquiry failed to demonstrate that the development was necessary and unavoidable to enable delivery the replacement school consented in the 2018 permission. Consequently GBC submission concludes that the Very Special Circumstances simply do not exisit, and that the appeal should be dismissed.