Wood Strreet News on GBC Plabnning problems with a SANG (defined below)

Wood Street – Local Plan Update 30 – 16th December 2015 – SANG on Russell Place Farm 

Wood Street

Dear Wood Street Villagers

Apologies for sending a local plan updates out at this time of the year, but once again we have something to do which affect our village!

Most of you will be aware (indeed many of you objected as I did) of the planning application (13/P/01453) made for a SANG (Suitable Alternative Natural Greenspace) on Russell Place Farm, on Frog Grove Lane  in 2013.  You might also remember that this went on hold while the concept was evaluated by Guildford Borough Council (GBC).   Well things are moving…. as usual right at a key holiday time

A SANG is a planning concept, designed to allow building in areas which would otherwise be protected (e.g. in Greenbelt), by providing “green spaces” as alternatives to walk dogs etc,  in our case such as Whitmoor Common. 

Recently planning applications in Greenbelt such as North Wyke Farm, Normandy have been refused in part because there is no SANG to cater for the additional population. It seems now the land owner has decided to try and get this application through, and if successfull increase the risk of Greenbelt land being built upon. The position of GBC is at this time unknown, but GBC are duty bound to make a decision on this application, as failure to do so would be balance in favour of success.

One of the key respondents to this application are Natural England. Their extract is below and quite telling..

“We have doubts as to whether the SANG will successfully draw visitors away from the SPA due to the contrived nature of the route under phase 1. As it is, the proposed route may lead to visitors creating desire lines at the obvious pinch points thereby making the walk shorter. This may ultimately result in the deterioration of quality of the SANG, such that it would be unlikely to act as a suitable alternative to the SPA.” Well the route has not changed but this will still apply.

“Natural England does not object to this planning application despite the fact that it currently fails to address the concerns detailed above and in our previous responses. This is because at its most basic level the application represents the conversion of a piece of agricultural land to a publicly accessible green space. However, it is Natural England’s view that the information submitted with the application is insufficient to provide certainty that the site will be maintained and managed effectively as a SANG in perpetuity. Due to these concerns the site cannot at this time be considered as a measure to avoid recreational pressure impacts on the Thames Basin Heaths SPA and until such time as these concerns are fully addressed Natural England is likely to object to any applications for new housing which propose to make use of capacity at this site.” i.e While not objecting NE are saying it won’t work, AND the critical thing is that the onus is still all on builders who want to build must always PROVE the SANG will work for their application. If they cannot prove it will work – they cannot use the SANG as offset and NE are saying the cannot prove it…. This is in part due to the open access areas we already have.

Unfortunately the applicant has now decided to proceed anyway.

SO PLEASE CAN YOU before next week ( responses must be in by 25th December)


1.     For those who objected last time please reaffirm your objections, and include the term OBJECT or STRONGLY OBJECT


2.     Please write and object for the first time. It is important that the strength of feeling be known.

Write letters or emails to….

Case Office                           Lisa Botha

GBC Planning :                    Email address         planningenquiries@guildford.gov.uk

GBC Application Websitehttp://www2.guildford.gov.uk/publicaccess/          and enter 13/P/01453

Copy of my proposed Wood Street Village Association (WSVA) letter for review and the Worplesdon Parish Council (WPC) last objection points are written in below.

Please, an you register your objections in the next few days.

Many Thanks

Neville Bryan

WSVA Chairman



Lisa Botha

The Planning Department

Guildford Borough Council

Millmead House




United Kingdom


7th February 2013


Dear Mrs Botha


On behalf of WSVA, I wish to reiterate our Strong Objection to Application 13/P/01453 Change of use from agricultural land to Suitable Alternative Natural Greenspace on land at, Frog Grove Lane, Wood Street Village, Worplesdon, Guildford, GU3 3EZ


We note the Natural England response, which while not objecting, appears to be saying this location can NEVER work!  We cannot therefore see how GBC can endorse this application.


That aside, I wish to STRONLY OBJECT on the following grounds :-


Section 1 – The Village.

Wood Street Village does not need £2.5 on another recreation area.  It already has plenty of green and woodland amenities, which are not overly used within 750 metres of the proposed site. Examples as floows

–           The Village Green 300 metres

–           The Cricket Club on Backside Common area 100 metres

–           Bridleways on each side and path through < 100 metres and on site

–           Broadstreet Common, 750 metres

–           SWT maintained woodland on Backside Common etc… 500 metres (already a surrey wildlife wood land)

A land change in this scale will change the character of Wood Street. It is in a high visibility area. This is something the Local Plan process seeks to AVOID, and will allow an additional 1738 homes in the area, and change character of the area. This is a matter for the local plan FIRST.


Section 2 – GBC Do not need a SANG Either

‘The Thames Basis Heath Special Protection Avoidance Strategy 2009 to 2014’ states ‘Once designated SANGS are in place the SANG sites will provide adequate public green space for the whole of the borough of Guildford’.

There are already plenty of SANGs. A Guildford Borough Council with regard to existing SANG sites stated recently ‘There is still a significant amount of SANG available in the borough’. Plus from what I understand

–           Riverside nature reserve has been extended by a further 9 hectares which will cover future development for approximately 450 dwellings.

–           There is further land already in the pipeline to become SANGS.  One being council owned Tyting Farm with surrounding farmland of 46 hectares. Even if only half of this farmland is converted to SANGS it would equate to further development of 1200 dwellings.


Sections 3 – Government is Promoting Home Agriculture

This is an active farm, and we need all Our Farmland to Stay Farmland. As this is good quality active farmland and it is valuable as it is to England and Great Britain. It has been used for 20 years by the current tenant, and Britain is tasked with producing more of our own food.  As it has been used for grazing for a number years, this suggests the land is of good quality.


Section 4 – Traffic. 

If the plan works as requested, it will further increased traffic on through Wood Street, on already over stretched roads.

You should be aware, WSVA are planning to ask for restrictions on loading to reduce damage from existing traffic.

The proposal suggest land to be used by horses, but there no access for horses boxes and if there were. If there was there would be risk for invasion by travellers, a known risk in the area.


Section 5 – Drainage issues.

The land soil here is clay based and does not drain well. It is a bog in winter and right now!  The lower areas (including where the car park would go ) are already saturated and unusable without foundation support. The area is unusable without fully adding foundations.   I note at this point that all the paths and access areas would have to be imported which is contrary to Natural England SANG Guidance, which says paths should “remain unsurfaced to prevent an urban feel”. Leaving them unsurfaced would make the circular walks impassable for the wither months. Health and safety implications!


Section 6 – Security

There are very serious security implications from having a large car park as designed, being hidden “out of site” car park at evening and night. I would suggest the local residents would be more than a little concerned by this.


Section 7 – Facilities

I presume 30 car park spaces and 2.5kms or walking would need some toilets facilities !


Section 8 – Existing Wildlife

Having been grazing for many years, there is an abundance of wildlife and hedgerows already in existence, and consequently existing ground nesting and feeding birds. This would all be disturbed. For the new area everything would have to be planted – these are agricultural fields today. There is nothing special to attract walkers unless imported or takes 20 years to grow. 


In summary, the area’s is not suitable, and there is already plenty of more suitable amenities of a similar type in the area. Keep our agriculture.


Yours Sincerely




Neville Bryan

Wood Street Village Association



•             Natural England’s Report NECR136 dated 13 February 2014 indicates that Whitmoor Common is the second most popular area of the TBHSPA for walking.  Paragraph 3.34 of the report states that 42% of the visitors surveyed advised that their main reason for visiting this site is its proximity to their homes.  Paragraph 3.35 advises that 30% of visitors to Whitmoor Common stated that nothing would attract them to another site.  50% of the visitors travelling to Whitmoor Common by car have travelled less than 2.7km and 75% of those travelling by car travelled less than 4.6km.  Given that Worplesdon is lucky enough to benefit from nine commons: Backside, Broad Street, Clasford, Chitty’s, Littlefield, Rickford, Rydes Hill, Stringers and Whitmoor – all of which benefit from S193 of the Law of Property Act 1925 giving the right to air and exercise; and as Whitmoor Common is only a short distance from the Riverside SANG, it is highly unlikely that the provision of a further SANG site in Frog Grove Lane will draw visitors away from Whitmoor Common.  It should borne in mind that Whitmoor Common is flat and sandy whereas the other commons are predominantly hilly and/or wet.

•             Paragraph 3.58 of the above report states that there is no evidence to suggest that the provision of SANG sites has reduced the number of visitors to the SPA.

•             GBC’s TBHSPA Avoidance Strategy 2009-2014 paragraph 5.3 states that GBC undertakes monitoring of the SPA and reports monthly to Natural England.  What evidence does GBC have to indicate that the current SANG sites draw visitors away from the SPA?

•             The Parish Council has already provided a community car park which is available to anyone in the borough who wants to walk on Broad Street and Backside Commons.  These commons cover 128 hectares and people can already walk over the commons with their dogs.  The need for a SANG at this particular location cannot therefore be justified due to its proximity to these commons.

•             Public footpath 377 already provides pedestrian access to the proposed SANG, which is currently used by dog walkers and ramblers.

•             The proposed SANG site is located outside the settlement boundary within the Metropolitan Green Belt.  A 30 space car park at this location would be inappropriate and will generate additional traffic which is unacceptable.  Surrey Police have already recognised that speeding traffic is an issue through the village.

•             Very special circumstances for the development of Green Belt land have not been demonstrated.

•             Loss of biodiversity especially bird life as a result of increased disturbance  – The tenant farmer uses conservation farming techniques, as a result of which a number of red list species utilise these fields including :  Linnets, Song Thrushes, Field Fares, Skylarks and the rare overseas visitor the Cattle Egret.  The current grazing regime obviously suits these rare birds.  If lots of people visit this land it will have a detrimental impact on their habitat especially when dogs are allowed to run off lead.

•             GBCs Infrastructure Baseline July 2013 para. 4.1.10 – Agricultural land is excluded from green-space assessment.

•             This farmland is working, viable agricultural grazing land that should not be lost under any circumstances.

•             If the SANG is approved it would enable 1,738 houses to be built within 5km of Russell Place Farm.  There is insufficient infrastructure to cope with this number of properties.

•             The application presumes a need that is not justified.

•             There is no requirement for this SANG in the Local Plan.

•             The artificial parkland is more suited to an urban environment and is therefore inappropriate within a rural setting.

•             Negative impact on the area including attracting antisocial behaviour in the car park – existing anti-social behaviour already experienced along the track to Russell Place Farm, of which the police are already aware.

•             If large developments are planned SANG should be created within that development.

•             There is no local support, but many objections from residents.

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