STATEMENT BY EFFRA COMMITTEE ON DRAFT NEIGHBOURHOOD PLAN
During the next few days each household will be delivered two copies of a leaflet from EFFRA with a short questionnaire to fill in and additional copies will be available for other members of the household wishing to respond. Consultation documents for the draft Neighbourhood Plan (NP) prepared by the Parish Council (EPC) will also soon be delivered. Later in June, Guildford Borough Council’s consultation on its draft Local Plan will begin, which contains proposals for Effingham which differ to the draft EPC Neighbourhood Plan.
We urge residents to respond to each of these consultations as they will decide the future of your village. In particular, we ask you to return the EFFRA short questionnaire by 27th June so that we can represent your views.
EFFRA has been supportive of the preparation of a Neighbourhood Plan for Effingham. Whilst we believe that the draft contains much that is good for the village we strongly do not agree with the housing policies and the sites identified for development. We agree that the village needs more houses, in particular smaller starter homes, but we also believe that residents live here because they value our Green Belt location and wish this to be protected. We consider that the Neighbourhood Plan, in asking residents to agree to sites on the Green Belt that we believe cannot presently be built on legally under the Green Belt Regulations, will set a precedent for further building on the Green Belt in Effingham.
In contrast, Guildford’s draft Local Plan’s most important proposal for Effingham is to “inset” the centre of the village along with neighbouring villages I.e. take them out of the Green Belt, which makes development within them easier. Three sites are proposed in Effingham in this inset area totalling 43 homes.
Our issues of disagreement with the Parish Council are:
1 Their target of a minimum 62 homes in Effingham in the draft NP is based on dubious statistics. The Guildford draft Local Plan has 43 new homes in Effingham and as both plans do not preclude further developments receiving planning approval why set a minimum target of 62?
2 Residents should not be asked to agree to building on the two sites Church Street Field and The Barn on The Street. These sites are outside the Settlement Area and we believe that they are not eligible for development under the Green Belt Regulations as the number of houses is too great to qualify as infilling (contrary to what EPC claims). Agreement to building on the protected Green Belt sets a precedent for further building. Only when, and if, the Local Plan is agreed, and these sites are inset, i.e. out of the Green Belt, will they be eligible for development.
3 No building should be proposed on Effingham Lodge Farm. EPC is proposing 6 houses on what it terms as “previously developed land” which can be built on. BUT this site was the subject of the Howard/Berkeley Planning Application, is outside the Settlement area and the proposed inset area and is on what the Local Plan categorises as highest sensitivity Green Belt. Berkeley Homes is highly unlikely to agree to just 6 homes and why risk setting a precedent for more building?
4 A further site, Lyons Field on Effingham Common Road, has been included in the EPC questionnaire. It, similarly in our view, is not eligible for building on under Green Belt Regulations as the numbers are too great for infilling and would constitute “ribbon development.” It is also outside the Settlement Area, outside the proposed inset area and on the highest sensitivity Green Belt.
EFFRA has made many representations and held meetings with the Parish Council over the past year to try and reconcile differences. We have been hopeful at times that they could be reconciled. In October 2015 the Health Check of the draft Neighbourhood Plan organised by Guildford Borough Council was highly critical and in effect said that the draft failed to meet the basic conditions on the Green Belt, “The Neighbourhood Plan has not been properly thought out with regards to Green Belt and the allocation of land.” We believe it still does not and that the next Health Check will say the same. The draft Guildford Local Plan was then published with proposals to inset the centre of Effingham (i.e. to take it out of the Green Belt, making development easier) and proposed a minimum of 43 homes on three sites, not including Effingham Lodge Farm. We had hoped, as the Local Plan is of greater legal status than the Neighbourhood Plan, that EPC would accept the Local Plan proposals. However, EPC continue to promote building on the Green Belt sites.
In the EPC draft Neighbourhood Plan, protecting the Green Belt is indicated, but we believe it is doing quite the opposite. By supporting development on sites in the Green Belt outside the Settlement Area Effingham would be sending a message that it does not value its Green Belt and this would likely lead to much more development within our village.
The draft Neighbourhood Plan is out for consultation to residents under what is called Regulation 14. So now it is up to residents to decide and to respond to EPC. EFFRA also need your views to represent residents. Please return the short questionnaire we will be delivering to you by 27th June and use the back sheet for any additional comments. Effingham is our village and we need to express our views to help determine its future.