1. Unit 11 Bridge Wharf
156 Caledonian Road
London N1 9UU
Tel: 0845 481 8136
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www.sarahyouren.com
Planning Department
Mole Valley District Council
Pippbrook
Dorking
Surrey
RH4 1SJ
30 May 2011
Dear Sirs,
Planning Application Reference MO/2011/0528
Development of land at Springfield Road, Westcott, Surrey
We act for the Westcott Meadow Action Group (“WMAG”) which represents 757
members who are residents of the village of Westcott. 44 of those members are on
the committee of WMAG and the names of the committee members are listed on a
document appended to this letter. We trust this illustrates the breadth of objection to
the proposed development throughout the village and that the views of local
residents will be given significant weight in the determination of this application.
The proposed development
Taylor Wimpey have submitted an application for planning permission to construct
14 dwellings (including affordable housing) together with vehicle and pedestrian
access from Westcott Street, associated parking, landscaping and public open
space.
The application proposes 2 x 3 bed houses and 8 x 4 bed houses plus 4 affordable
units however the submitted plans do not show this mix of dwellings rather they
show 5 x 5 bed houses, 5 x 4 bed houses and 2 x 2 bed affordable houses and 2 x 3
bed affordable houses. The exact mix and size of houses should be clarified.
1. Prematurity based on overall housing target
One of the fundamental flaws with this application is that it would be premature to
grant planning permission for this site at this time. The site remains a reserve
housing site. It has not been released for development for housing and should not be
developed until other more suitable sites identified in the Strategic Housing Land
Availability Assessment (“SHLAA”) as being currently available for development for
housing have been exhausted. Only then should the Council consider releasing the
reserve housing sites in the order required by policy HSG6 as set out in the Mole
Valley District Local Plan 2000 which is the adopted local plan for the area within
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2. which the application site is located. We set out below a more detailed explanation of
why this is the case as it is important that committee members are very clear about
the actual current status of this site which has been misrepresented in the supporting
statement submitted with the planning application.
Policy HSG 6 in the Mole Valley District Local Plan 2000
Planning applications must be determined in accordance with the policies of the
current development plan and any other material considerations (section 70 of the
Town and Country Planning Act 1990). The current development plan for the
application site is the Mole Valley District Local Plan 2000 (“the Local Plan”) which
prevails until such time as the replacement policies in the Local Development
Documents have been adopted.
When the Local Plan was adopted the housing policies were based on the housing
targets set out in the Surrey Structure Plan 1994 (“the Structure Plan”). Policy DP4 of
the Structure Plan required that provision was made for a net increase in the
dwelling stock of Mole Valley of about 1,900 units in the fifteen years between 1991
and 2006 and it highlighted the need to provide smaller dwellings in the 1 or 2
bedroom range.
The Local Plan therefore aimed to identify sufficient land to allow for a net increase
in dwelling stock in the period to 2006 in line with the requirements of the Surrey
Structure Plan. To safeguard the land supply position in case identified housing
requirements could not be met from land within the built up areas, Policy HSG6 in
the Local Plan identifies five reserve housing sites of which the application site is
one.
Policy HSG6 states that the District Council will continue to monitor housing land
supply on an annual basis. If, as a result of this process, the Council is satisfied that
land is required in addition to that allocated in Policy HSG5 to meet the identified
housing requirements of the Surrey Structure Plan 1994 for the period between 1991
and 2006, one or more of the reserve housing sites will be released: the plan lists
five sites of which the application site is the fifth. It goes on to say that if, as a result
of monitoring, a deficit is anticipated then the sites will be released so far as possible
in proportion to that deficit but with a safety margin in favour of exceeding the
requirement as follows:
Anticipated deficit sites to be released
25-50 site 1
50-75 sites 1 and 2
75-100 sites 1, 2 and 3
100-150 sites 1, 2, 3 and 4
Over 150 All sites (ie including site 5)
Therefore site 5, which is the application site, should only be released for housing if
there is a deficit of over 150 dwellings in the Plan period against the numbers
required by the Structure Plan. Paragraph 6.32 in the Local Plan explained that the
order for release of the sites has been arrived at by taking account of their locational
characteristics and respective relationships to the District’s major urban centres as

3. well as their size and potential contribution to affordable and other identified housing
needs. In other words, the application site was to be released last as it was
considered that sites1-4 were preferable housing sites in planning terms.
The supporting statement submitted by the developer with the planning application is
disingenuous as it states that the site is one of 5 reserve housing sites which are to
be released if based on the results of monitoring housing delivery there is likely to be
a deficit. The applicant fails to mention that Policy HSG6 relates strictly to the
housing target of provision of 1900 dwellings in Mole Valley as set out in the
Structure Plan and that in fact on those figures there is no deficit. The 2009 SHLAA
was finalised on 20 October 2009 and identified that if the housing figures in the
Structure Plan were used, there would be no shortfall of available housing land for
the period 1 April 2009 to 31 March 2014. As there is no shortfall of housing land
over the five year plan period to 2014 any release of the application site for
development would be contrary to Policy HSG6. It is therefore premature to even
consider the release of any of the reserve housing sites for development.
MVDC Statement March 2010
The supporting statement submitted with the planning application is misleading in
that it states that the MVDC statement dated March 2010 justifies the release of the
application site, confirming the principle of providing for the development of the site
as a result of its long standing allocation as a housing site is well established.
It is important that committee members are made aware that the statement referred
to was based on a decision by the Council in October 2009 to release the reserve
housing sites because the Executive had received a report that based on the
housing targets in the South East Plan the Council could not show a five year supply
of housing land sufficient to meet this target. However, that decision was then
rescinded in June 2010 because the housing targets in the South East Plan have
been revoked by central Government using their powers under section 79(6) of the
Local Democracy Economic Development and Construction Act 2009. The
Government expressly stated in a letter dated 6 July 2010 from the Department for
Communities and Local Government to all local planning authorities in England that,
with immediate effect, regional plans no longer form part of the development plan for
the purposes of section 38(6) of the Planning and Compulsory Purchase Act 2004.
Whilst the Courts subsequently decided that the Government could not abolish the
South East Plan without enacting primary legislation, that primary legislation is the
current Localism Bill which is expected to become law toward the end of this year. In
the meantime the Government issued a statement in November 2010 to all planning
authorities to say that RSSs including the South East Plan are re-established as part
of the development plan at present but that the Government expects local planning
authorities to have regard to the Government’s intention to abolish RSSs in the
Localism Bill. This statement of intent is a material planning consideration that must
be taken into account in planning decisions being taken now. The Courts ruled that
this is entirely appropriate and the Government’s statement of intention is a material
planning consideration. In addition, in line with the desire to see housing targets set
by local people rather than central Government Mole Valley District Council is in the
process of revising the housing targets in the Core Strategy to reflect what local

4. people in the area want and need rather than the current target which simply states
the central Government housing target for the area.
Committee members must therefore take into account and give weight to the fact
that the Core Strategy is based on central Government housing targets set out in the
South East Plan, by the end of 2011 the South East Plan will be abolished and with
that in mind the Council is currently revising the housing targets in the Core Strategy
to reflect the needs and wants of local people. It would be premature to release land
for housing at this point based on a housing target figure which the Council itself is in
the process of revising and the revision of which has the full support of the
Government.
Core Strategy October 2009
In the Core Strategy adopted on 1 October 2009 in paragraph 6.1.6 it states that “the
indicative housing trajectory in appendix C of the Core Strategy illustrates the
forecast supply of housing land over the period to 2026 based on the 2008 Strategic
Housing Land Availability Assessment. It shows that there is sufficient land to meet
the five year housing requirements for the period to 2014. It also demonstrates that
there is potentially sufficient previously developed land in the built up areas to meet
the District’s housing requirements until 2015-2016.” This is a greenfield site and it
ought not therefore to be released for housing development at a time when it is clear
that there is sufficient brownfield land to accommodate housing development until
2016.
Setting new housing targets for the District
Paragraph 10 of the letter of 6 June 2010 from central Government is absolutely
clear that it is now the Council’s responsibility to set their own housing targets to
establish the right level of local housing provision for their area without the burden of
regional housing targets. The Council is now undertaking a review to decide what
level of housing would be appropriate in Mole Valley and justify that decision with
evidence to support it. This will then reflect local people’s aspirations.
Once that work has been done by the Council to decide on the new housing target
for Mole Valley, the Council may in fact be able to show a five year supply of housing
land if their new housing target is lower than that in the former South East Plan.. If so
then there is no justification to release the site for housing development at the
present time. The planning statement submitted by the applicant is fundamentally
flawed, if the Council does not yet know what its housing target is then the developer
cannot assert that it is self evident that MVDC cannot demonstrate an up to date 5
year supply of deliverable housing and accordingly applications for housing should
be considered favourably.
In fact it is premature to consider releasing any of the reserve housing sites until
such time as the Council has decided on an overall target for housing provision
which it considers is suitable for its area, supported by evidence and reflecting the
aspirations of local people in line with the new Government agenda. Once that target
has been decided then it will be formalised through the Land Allocations
Development Plan Document and then those policies will replace Policy HSG6. Until

5. that time, Policy HSG6 stands and under that policy there is no housing deficit and
therefore none of the reserve housing sites can be released including the application
site.
We consider that the above argument is so compelling that the application must for
this reason alone be refused. Should the Council decide to grant permission there
would be clear grounds for legal challenge. However, for completeness we have also
assessed the application against the existing development plan policies below.
2. Location of development
Whilst the application site is within the defined settlement boundary for Westcott, as
a result of its reserved housing status, it is nonetheless a green field site. Policy CS1
in the adopted Core Strategy states that development should take place on
previously developed land within the built up areas of the most sustainable locations
within the district. It goes on to specifically identify the most sustainable locations in
the district as being Leatherhead, Dorking, Ashtead, Bookham and Fetcham. It
explains that they have been identified as being the most sustainable locations in
planning terms due to the level of community services and facilities available, access
to public transport and supporting infrastructure. It is clear therefore that new
development should first be located towards these locations as they are more
sustainable than the application site.
Policy CS1 then goes on to say that limited development and infilling will take place
on previously developed land within the identified larger rural villages of which
Westcott is one. As explained, the application site is a green field site and does not
constitute previously developed land.
It would clearly be contrary to policy CS1 to grant permission for housing
development on the application site when there are more sustainable sites available
in Leatherhead, Dorking, Ashtead, Bookham and Fetcham which should be brought
forward first. Even when such sites are exhausted, policy CS1 requires the use of
previously developed land within the larger rural villages so development of a green
field site would still be contrary to policy CS1.
The supporting statement that accompanied the planning application is misleading
when it states that policy CS2 states that the Council must make provision for at
least 3,760 dwellings in the period 2006-2026. The supporting statement fails to
mention that policy CS2 specifically states that this target was set purely to accord
with the South East Plan which is soon to be be revoked and the target is currently
under review by the Council. As explained above, it is entirely possible that when the
Council complete their review of housing targets for their area they may in fact
impose a lower housing target for Mole Valley than the target imposed through the
South East Plan. Policy CS2 also states that “the Council’s indicative housing
trajectory shows that the District’s housing requirement can be met without the need
to use green belt/ green field land until around 2016-2017”. As the application site is
a green field site, it is clear that, even if the Council were to choose to continue to
require the same number of additional new dwellings as in the South East Plan when
they set their own housing targets for Mole Valley, the current application is still 6-7

6. years premature as there are sufficient previously developed sites which should be
brought forward before green field land is used.
The text that accompanies policies CS1 and CS2 makes it clear at paragraph 6.1.7
that the Land Allocations Development Plan Document will allocate sufficient land to
meet the housing needs of the District and will include a policy mechanism to
manage the release of land so that priority is given to previously developed land in
the built up areas in accordance with policy CS1.
Paragraph 6.1.10 in the Core Strategy says that “in accordance with the principles of
sustainability, the Settlement Hierarchy (October 2008), and the results of the
Sustainability Appraisal, it is proposed that development will be focused on the
defined built-up areas of Leatherhead and Dorking (including North Holmwood)
followed by Ashtead, Bookham and Fetcham, where there is the greatest potential
for the re-use of previously developed land and access to services and facilities”.
The use of the application site for housing is not therefore considered to accord with
Policy HSG6 in the local plan nor with Policies CS1 and CS2 in the Core Strategy at
this time and any grant of permission for residential use would, at present, be
premature.
3. Density of development
The developer is proposing to construct 14 dwellings on the application site. Only
1.75 hectares of the application site is developable as the remainder is unavailable
due to flood zoning. We object to the proposal as it attempts to construct too many
houses on the site in disregard of the unique constraints that restrict the application
site. Whilst the number of dwellings has been reduced from the previous application
for 34 dwellings, the amount of built floorspace remains remarkably similar as the
individual dwellings are considerably larger. In addition, several two storey garages
are proposed which would not strictly count as dwellings yet they are similar in size
to a two bed house and indeed could easily be converted to such accommodation
given that they have toilets, sinks and in some cases showers shown on the
submitted plans. The development therefore remains crowded and committee
members should make enquiries as to how much of a reduction in built floorspace
this revised proposal actually achieves.
Dorking Area Local Plan 1982
In considering the original designation of the site as a reserve housing site as part
of the Dorking Area Plan in 1982 it was envisaged that it could accommodate up to
20 houses which would consist of 1 and 2 bedroom units. This would have been
likely to result in about 30 residents on the site.
At this time the Chief Planning Officer of the Mole Valley District Council indicated
that “the location and nature of the site is such that it would be suitable for about 20
small dwellings which is the type of development most needed. It is not anticipated
that about 20 one and two bedroom dwellings will make an appreciable difference
to any existing problems as it will only constitute a marginal increase in traffic

7. generation. In the Council’s view the need for more small dwellings in the Westcott
area during the 1990’s outweighs any net traffic problems that might arise from this
small proposal.”
The current proposals are for 5 x 5 bed houses, 5 x 4 bed houses plus 2 x 2 bed
affordable houses and 2 x 3 bed affordable houses. If all properties are full occupied
this would result in approximately 55 residents. However when one looks closely at
the submitted plans it is clear that the 4 bed unit on plot 11 has a study with shower
room that is separate to the remainder of the living accommodation at ground floor
so would easily be converted to a 5 bed dwelling. In addition, 4 double height double
garages are proposed with accommodation over which is labeled as a work shop but
would easily accommodate a bedroom and living room and the plans already show
shower rooms on the first floor of the garages. Each garage is the size of a two
bedroom house. This has the potential to add a further 5 residents to the site
bringing the total number of residents to approximately 60 which is twice the number
of residents originally anticipated by the Dorking Plan and therefore twice the
number of traffic movements. It should be noted that the size of dwellings proposed
differ on the submitted plans to those presented elsewhere in the application
documents and this should be clarified with the applicant.
Mole Valley Local Plan 2000
The local plan Inspector’s report relating to the allocation of the Springfield Road site
as a reserve housing site from the Local Plan 2000 inquiry states at paragraph 7.176
that the site is not suitable for high density development.
Paragraph 7.195 acknowledges the difficulties posed by the traffic and highways
context, in particular the limited width of both Westcott Street and Springfield Road.
Paragraph 7.197 states the Inspector’s view that development of the site should be
modest in view of the locational, highways and policy context of the site and whilst
he does not suggest an appropriate density, he does note that the objector’s
suggestion of about 26 dwellings may prove appropriate albeit that such a limit
cannot be binding. This is considerably less than the 34 dwellings now proposed.
In addition, in the Local Plan stated at paragraph 6.5 that there was a need for small
1 and 2 bed dwellings at this time. As above, this would generate approximately half
the number of residents and therefore traffic movements compared to the current
proposals.
Core Strategy
Paragraph 6.1.12 in the Core Strategy does allow for limited development within
the boundaries of Beare Green, Brockham, Capel, Charlwood and Westcott (as
shown in the Local Plan 2000) providing that the proposed development is at an
appropriate scale in relation to the size and character of the village. As explained in
this statement we believe that 14 dwellings is an inappropriately large number of
units for this site and does not constitute limited development which would be an
appropriate scale in relation to the size and character of Westcott. As such it does
not accord with the Core Strategy.

8. In terms of the appropriate housing mix, Policy CS3 in the Core Strategy is very
clear that “in seeking to provide a balanced housing market, the Council will require
housing proposals to take into account and reflect local housing needs in terms of
the tenure, size and type of dwellings. The Council will particularly seek the
provision of two and three bedroom dwellings suitable for occupation for all sectors
of the community including newly forming households, young couples and
expanding families”.
In fact the applicant is proposing 5 x 5 bed houses and 5 x 4 bed houses which are
too large to meet the Council’s stated requirements and which significantly increase
the likely number of residents on the site and the cost of the housing on the site
making it unsuitable for many existing residents of Westcott.
Policy ENV24 in the Core Strategy also addresses density of development stating
that “development will not be permitted where it would result in a cramped
appearance having regard to the general space around buildings in the locality.”
Paragraph 4.118 notes in particular that “the larger the property the larger the space
that there should be around it.” It notes that larger detached houses should have at
least 2m between them. Whilst the current proposal reduces the number of dwellings
in the same space as the previous proposal, the dwellings themselves are far larger
and together with the double height double garages proposed leave little space
between each plot which is undeveloped resulting in a cramped layout.
Strategic Housing Market Assessment
The applicant has proposed that the market housing should be 5 x 5 bed houses and
5 x 4 bed houses. It is not in accordance with the Strategic Housing Market
Assessment which recommends that the Council should encourage a mix of market
housing of 10% 1 bed, 20% 2 bed, 50% 3 beds and 20% 4 beds. If the Council were
minded to allow 14 dwellings on the application site, which we would argue is in fact
too many, then on this calculation the appropriate sizes of dwelling would be 1 x 1
bed house, 2 x 2 bed house, 5 x 3 bed house and 2 x 4 bed house with no 5 bed
houses at all.
Making this change to bring the proposed scheme in line with SHMA
recommendations would result in a more appropriate mix of housing on the site to
bring it in line with the SHMA, reduce the number of occupants and allow for
provision of small market starter homes to allow the young people in the village the
opportunity to purchase their first home and stay within the village rather than
catering predominantly to large family homes which are simply not affordable for the
majority of people on the open market. It would not however overcome the
insurmountable problems regarding flooding, harm to a listed building, highways
safety, harm to bats and badgers, development on a Greenfield site, insufficient
availability of public transport and the premature release of a reserve housing site
associated with the proposal for residential development of this site.
Mole Valley Housing Needs Study 2007
The Mole Valley Housing Needs Study 2007 confirmed that the largest demand for
market housing is for two and three bedroom homes. It also confirmed that the

9. largest need for dwellings by type is for flats and semi-detached homes. The
proposed mix and type of housing (all market housing is proposed to be detached)
in this application is not reflective of market needs and as such is contrary to Core
Strategy policy CS3.
In summary therefore, we object to the size of the proposed development at
Springfield Road. The whole site was originally designated in 1982 for 20 x 1 and 2
bed houses and then 26 x 1 and 2 bed houses when the site was increased in size
in 2000. The number of dwellings now proposed is 14 dwellings but such large
dwellings that the resulting numbers of occupants are more than this site can
comfortably sustain and twice what it was originally intended to house.
The original scheme proposed in 2010 for 34 houses which was refused
permission by the Council would have contained about 90 bedrooms on site
compared to about 30 bedrooms envisaged when the original designation was
made. The existing scheme significantly reduces the number of dwellings on site
but they are so large that the number of bedrooms only falls to approximately 60
which is still twice the number of occupants originally envisaged. The Council want
to see 2 and 3 bed houses. This scheme proposed 4 and 5 bed market houses
which are larger than those required by the Council therefore increasing the
number of occupants on site. If the need now is for 2 and 3 bed houses rather than
1 and 2 beds as originally proposed when the site was allocated then the number
of properties proposed should decrease in order that the number of occupants on
site and affecting the highway network remains similar.
4. Transport
Sustainable development and public transport
The Core Strategy notes at paragraph 2.40 that Surrey has the highest level of car
ownership and the most congested roads in the country outside London. Nearly half
of Mole Valley's households own two or more cars compared to the national average
of 29.5%. Emissions from car use contribute toward green house gas emissions
which in turn accelerate climate change. As a result one of the key goals of the Core
Strategy is to create sustainable development which minimises the need to use the
private motor car.
Paragraph 2.56 of the Core Strategy states that “the impact of climate change on the
global environment is recognised as a serious threat to communities. The
Government expects local authorities to play an important part in reducing emissions
that contribute to climate change and reducing the consumption of natural resources
to limit climate change. For example, the impact of new development on climate
change can be reduced by locating it in places where it is not entirely necessary to
rely on having access to a car”. It then goes on to say at paragraph 4.9 that “the
private car is the principal means for getting about the District. This is not sustainable
in the long term. Alternative transport modes will be supported and new development
provided in sustainable locations where access is not solely dependent on use of the
private car.”

10. In addition, paragraph 6.1.2 of the Core Strategy explains that “within the context of
national and regional guidance and based on the principles of Core Strategy Policy
CS 1 'Where Development will be Directed' (A Spatial Strategy), the Council will
seek to provide the majority of new homes within the most sustainable locations of
the District. By adopting an 'urban focus' this approach will contribute towards the
South East Plan's objective of an urban renaissance and will foster accessibility to
employment, retail and other services, thereby avoiding unnecessary travel”.
The planning statement submitted by the developer claims that the site is accessible
to public transport links to Dorking and beyond and the developer states that the site
is ‘sustainable’ because it has access to non-car modes. In fact the centre of the
proposed housing area is 600m from the nearest bus stop, walking either via
Westcott Street or from the eastern end of the site and alongside the recreation
ground. This exceeds the recommended (Surrey County Council) maximum walk
distance of 400m to a bus stop. The developer quotes figures from the edge of the
site, which is not where the housing is located and those figures are therefore
misleading.
The proposed development of the application site is contrary to these important
policies in the Core Strategy. There is virtually no employment in Westcott, so all
these new residents will have to travel to Dorking, Guildford or Gatwick to work. In
addition there arelimited retail facilities, the school and the doctors surgery are
approaching maximum capacity and any increased demand would impose
unreasonable demands on Westcott’s amenities. This means that occupants of the
proposed new scheme will have to travel to service even their basic needs. There is
limited opportunity for them to do so by public transport because there is no train
station in Westcott, one must first travel to Dorking or Guildford before being able to
catch the train.
There is a bus service to both Dorking and Guildford however the bus service from
Guildford stops at 17.55 in the evening having left Guildford at 17.20 on a weekday.
The last bus service from Dorking goes at 18.14 for route 21 and 18.48 for route 32
in the evening on a weekday. This means that future occupiers of the development
could only realistically use public transport if they finish work either in Dorking or
Guildford sufficiently early to catch the last bus or if they work further afield, that they
can then finish early enough to travel to Guildford or Dorking to then catch the last
bus. It would be impossible for anyone who worked in London for example to catch
the train to Guildford or Dorking and then the bus to Westcott to get home after work
in the evenings unless they finished work well before the last connecting train from
London at 17.29 to Dorking or 16.30 to Guildford.
Reference is made repeatedly throughout the application to Westcott lying on the
Sustrans/National Cycle Route 22 linking Westcott to Dorking. However committee
members should be made aware that this is misleading as it is not yet a continuous
route and stops in Westcott. It is necessary to cycle along the A25 to reach Dorking.
There is no indication as to when works to complete the cycle way will be completed

11. and the development makes no improvements whatsoever to the cycle facilities of
the area.
Capacity of local highway network
The planning statement and traffic statement try to argue that it is not necessary to
consider the capacity of the local highway network in the context of the proposed
development. This is fundamentally wrong as serious concerns were raised about
the capacity of the local highway network when the site was originally designated as
a reserve housing site and again when it was expanded so this clearly was a
material consideration at the time that the site became a reserve housing site and it
is important to note that the number of occupants that the site was considered to be
able to accommodate was based primarily on the capacity of the local highway
network. It is important therefore for committee members to be fully aware of the
significantly larger size of houses and therefore number of occupants that are now
proposed for the site as compared to those envisaged and assessed when policy
HSG6 was conceived.
In fact, during the public inquiry into the Dorking Area Local Plan in 1982 it was
considered that about twenty 1 and 2 bedroom dwellings should not “make an
appreciable difference to any existing problems as it will only constitute a marginal
increase in traffic generation”. During the public inquiry into the Local Plan in 2000
the inspector acknowledged the difficulties posed by the traffic and highways
context, in particular the limited width of both Westcott Street and Springfield Road.
Paragraph 7.197 of the Inspector’s report stated that development of the site
should be modest in view of the locational, highways and policy context of the site
and whilst he does not suggest an appropriate density, he does note that the
objector’s suggestion of about 26 x 1 and 2 bed dwellings may prove appropriate.
At the public inquiry in 2000 when considering the enlargement of the reserve
housing site at Springfield Road, Jack Straw gave evidence for the Council to the
inspector and clearly states at paragraph 5.2 that “the Council considers its
capacity is between 17-20 dwellings depending on the layout of the site and the
type and size of dwellings”. Mr Straw then went on to explain at paragraphs 5.5 and
5.6 the constraints presented by the width of Westcott Street, the presence of
parked vehicles and the risk that the development posed to highway safety
concluding at paragraph 5.7 that “it is clear that an enlargement of the site is likely
to result in a level of development in excess of that which the local road network
can reasonably and safely accommodate”.
Our estimate that the proposal could result in up to 60 occupiers on site rather than
the approximately 30 originally envisaged when the application site was first
allocated and then expanded as a reserve housing site will mean a potential twofold
increase in traffic movements over those actually considered to be the amount that
the local highway network could accommodate in 1982 and 2000. The applicant
acknowledges that they have made provision for 43 parking spaces on the site with
additional parking available on the estate road.
In addition, in recent years additional housing has been built in Westcott at
Springfield Farm (3 dwellings), Rokefield (20 dwellings), Pinehurst in Springfield

12. Road (6 dwellings), the Old Dairy (20 dwellings), The Paddock (2 dwellings), Chapel
Lane (4 dwellings) and The Pound (currently under construction 7 dwellings)
increasing the number of residents in the village, adding to the traffic on the local
highway network and reducing the already limited capacity that was considered to be
available in 1982 and 2000. It is clear therefore that the local highway network
cannot possibly support 14 new dwellings with 60 new occupants on the site. The
planning inspector considered there to be sufficient capacity to accommodate 26
new 1 and 2 bed dwellings in 1982 and the Council considered the site’s capacity to
be 17-20 1 and 2 bed dwellings in 2000 however given that an additional 62 new
dwellings have been built in Westcott in recent years the capacity that was available
in the local highway network in 1982 and 2000 has long since been used and
surpassed. In particular we would point out that the 20 dwellings at Rokefield have
been built after 2000 so after Mr Straw’s comments on behalf of the Council
indicating that any more than 17-20 dwellings would result in unsafe levels of traffic
on the local highway network.
In addition to concerns regarding the highway network within and immediately
adjacent to Westcott there are also problems with the A25 to Dorking which is the
principal road leading to and from Westcott and the road on which the future
occupiers of the development would need to commute to work and local services.
The A25 is already suffering from serious traffic congestion on the approach to
Dorking. In the evening peak times this regularly results in a solid line of traffic
stretching from Dorking all the way back to Westcott. The access onto the A25 on
both sides of the village green is potentially dangerous as there are places where the
sight lines are poor, in particular on the east side of the village green and by the
entrance to Cradhurst Close.
It is abundantly clear that the local highway network is already at saturation point
with long traffic queues at times and there simply is no way to accommodate
additional car movements from new housing development.
Westcott Street
The developer has said in their planning statement and in their traffic statement that
“the very small number of additional cars will have no perceptible impact on local
streets”. We believe this to be a potentially dangerous attempt to gloss over a very
serious issue. As we have demonstrated it will not be possible for people to
commute to jobs some distance from Westcott by public transport so the vast
majority of people entering and leaving the site are likely to do so by private car.
There are essentially two major concerns regarding the location of the development
in terms of using Westcott Street to access it. The first is the width of Westcott Street
and the second is the location of the junction of the access road with Westcott
Street.
Westcott Street is a narrow village lane. There are nine existing dwellings along the
250m section of Westcott Street between Springfield Road and the village green that
have no off-street parking. Some are able to park outside their houses but others
have to park in Springfield Road. Others have narrow off-street parking areas in

13. their front gardens. Consequently there are always a number of vehicles parked on
Westcott Street, which effectively reduces it to a single-width carriageway, with cars
and delivery vans having to weave their way through, avoiding any pedestrians. The
presence of a large lorry or the weekly refuse vehicle has the effect of bringing
everything to a halt. At weekends the parking is even worse, because Westcott is an
attractive base for the many mountain bikers who cycle in the Surrey Hills. These
day visitors do not always appreciate the difficulties caused by their sometimes
indiscriminate on-street parking on Westcott Street, sometimes at narrow points,
sometimes part parked on the footway. No account has been taken by WSP in the
transport statement of the additional cars parked on Westcott Street at the weekends
as the majority of their parking surveys were carried out on weekdays when people
are at work. This does not give a full and accurate picture of the real situation.
No thought has been given to construction vehicles as large lorries carrying building
materials will not be able to weave past the parked cars in Westcott Street. The
consequence of two lorries meeting is unimaginable. Balchins Lane is even less
suitable as it; a) has no footway at all, b) is even more narrow, c) twists and turns
so the forward visibility is less and d) has a very sub-standard junction onto a
40mph section of the A25. The damage construction vehicles from The Pound
development are causing to The Green is evidence of what effect contractors
vehicles are likely to have. Whilst the developer has submitted a construction
management statement but this does not overcome the need to get a certain number
of lorries to and from the site along roads that are not suitable for this.
The emergency services must be consulted as the additional risk from an extra 14
dwellings is not insignificant with fire engines trying to negotiate along Westcott
Street.
In January / February 2010, Westcott Street was impassable for 4/5 days due to
snow and ice and the inability for the Council to access with gritting vehicles and
snowploughs.
The narrow width of Westcott Street and the existing parked vehicles mean that even
with the existing level of residents in Westcott there are often queues of cars waiting
to pass each other along Westcott Street. When an additional 43-60 car movements
are added to this at peak times going to work and school in the morning and
returning home in the evening, it is likely to result in extreme difficulties for both
vehicles travelling along Westcott Street and for future occupiers of the development
trying to enter or leave the site.
Notwithstanding our objection to the whole development, we are extremely
disappointed that the development of 14 houses does nothing to enhance our village
or address some of the existing problems. There are no proposals to improve or
extend pedestrian facilities or to try and reduce the existing conflicts on our roads.

14. The developers argue (unsuccessfully in our view) that the 14 houses would ‘have
no perceptible impact on the local streets’. They have tried to argue that the addition
of 8 or 8 extra vehicles (an unrealistically low estimate given the likely car ownership
in this area) in the two peak hours on Westcott Street will have no impact. This
completely misses the point as they have ignored the existing conflicts along this
road, most notably by pedestrians. Most of Westcott Street and all of Balchins Lane
have no footways, so all pedestrians have to walk in the carriageway, so within a
road that is less than 4m wide in places there is the juxtaposition of cars, vans,
cyclists, parked cars and pedestrians. It is always the pedestrians who have to
move.
We consider the proposed development unacceptable on highway and transport
grounds alone, as there is no solution to providing a satisfactory means of access.
The proposal to feed all vehicles onto the northern end of Westcott Street, adding to
the conflict between cars, delivery vehicles, pedestrians, cyclists and parked vehicles
is unacceptable. We note the developer concludes ‘no alterations are proposed or
needed on Westcott Street ... ’ which is merely an acknowledgement that they are
unable to offer any improvement or enhancement on this section as it wholly outside
their control. Instead they try and minimize the problem by stating ‘there is no
perceptible impact on Westcott Street’. Similarly there is no acknowledgement that
Westcott Street (south of Springfield Road) lies within a Conservation Area, and that
the additional traffic and conflict between opposing vehicles will harm this area,
which is supposed to be protected, preserved and enhanced by the Council. The
impact on the conservation area was not addressed by the committee when they
considered the previous application for 34 dwellings yet this is an important part of
the role of the Council to protect the conservation area and it must be taken into
account during the decision making process.
We note that in the submitted Transport Statement, which extends to 246 pages yet
contains no information whatsoever on pedestrian counts or usage.
It should also be noted that the doctors surgery is on Westcott Street. The entrance
to the surgery is only a few metres north of the access road to the proposed
development on a shared access drive with Rokefield. Existing residents of Westcott
walk along Westcott Street to go to and from the surgery and dispensary. There is no
pavement along a long stretch of Westcott Street nor is there room to provide one.
This means patients including elderly people with mobility issues and mothers with
small children and pushchairs have no choice but to walk in the road itself. This adds
to the obstacles that vehicles driving along Westcott Street must navigate and
presents a highways safety risk to pedestrians. The surgery sees approximately 200-
300 patients per week of whom the doctor estimates about 60% walk to the surgery.
While traffic speeds along Westcott Street are likely to be very low due to the sheer
volume of traffic we are nonetheless extremely concerned that this will inevitably
result in road traffic accidents.

15. An additional concern in terms of highways safety for both drivers and pedestrians
using Westcott Street is that the junction of the proposed access road with Westcott
Street is extremely close to the junction of the access to Rokefield with Westcott
Street and the junction with Hole Hill. In addition there is a blind bend on Balchins
Lane immediately before the junction with Hole Hill which has caused numerous
vehicles to nearly collide on the bend and the concern is that a large increase in
vehicles using this road would greatly increase the chances of a collision. Westcott
Street is the natural route to and from Westcott from the A25 and as such it already
has a significant amount of traffic travelling along it. We note that the Transport
Survey states that traffic levels along Westcott Street are low however that may well
be as a result of the timing of their traffic counting which was done at the start of
February 2010 when the extreme adverse conditions meant that far fewer people
were on the roads than normal and immediately prior to the Easter break when again
many people are away on holiday reducing the normal amount of traffic.
The Transport Statement refers to a document called “Manual for Streets” but
ignores the advice in the same document that a carriageway width of 4.8m with a
separate footway is required to enable a car to pass a lorry. This is not available over
most of Westcott Street between the A25 and Springfield Road. Even the narrower
width of 4.1m would only permit a car to pass another car, assuming any pedestrians
get out of the way.
In addition the construction phase is likely to produce more traffic in peak hours as
operatives arrive on site between 07.30 and 08.00 and try to get down Westcott
Street against the flow of residents trying to leave for work and school. This should
be accounted for within the transport statement but is completely ignored.
Westcott Street is substandard at present so it is inherently unacceptable to add any
additional traffic to an already sub-standard road.
Width of the access road
The developer has stated in their application that the existing access from Westcott
Street is to be retained with only nominal widening proposed. This is a concern
because there is a pinch point by the Old Buttery and the Dairy along the access
road where it is proposed to keep this as a single lane. This pinch point means that if
there are several vehicles trying to enter and exit the site at the same time there is a
risk that vehicles trying to enter the site may have to reverse out onto Westcott
Street. This would be very dangerous given the nearby junctions with Rokefield, Hole
Hill and the blind bend on Balchins Lane and the number of pedestrians that are also
using Westcott Street.
Parking
The developer has proposed 43 parking spaces and additional parking available on
the estate roads. Given the type of dwellings on the site with the high number of
larger 4 bed and 5 bed dwellings and the difficulties in taking public transport from

16. the site there is concern that future occupiers of the proposed development may in
fact own more than 3 vehicles per dwelling and may therefore try to park elsewhere
on the street in Westcott. Given the existing number of dwellings in Westcott that do
not have off road parking, the on street parking in the village is already at saturation
point.
Transport Statement
The developer has submitted a transport statement on the basis that less than 50
dwellings are proposed. However, this is only one of the criteria that determines
whether a transport statement is sufficient or whether in fact a transport assessment
is required. In fact the Department for Transport advise that in certain circumstances
a more thorough degree of assessment of the traffic impact of a proposed
development is required through the production of a transport assessment or a travel
plan. This development meets three of the Department for Transport criteria, namely
that (1) the development is not in conformity with the development plan, (2) the
development is likely to increase accidents or conflicts amongst motorized users and
non motorized users, particularly vulnerable users such as children, disabled and
elderly people and (3) the location is one where the local transport infrastructure is
inadequate, for example, substandard roads, poor pedestrian/cycle facilities and
inadequate public transport facilities. This means that at the very least a transport
assessment should have been done as the transport statement submitted is
insufficiently detailed to enable the Council to have adequate information in front of
them when determining the application.
We have also been informed, by those who advise us, that there are a number of
technical deficiencies in the Transport Statement accompanying the application.
The proposed access into the site is sub-standard as it has reduced visibility out of
the access along Westcott Street and lies within 20m of an adjoining access into
Riverbank (a private access serving some 26 flats and houses). The proposed
access will only be 3.5m wide (ie single –vehicle width) , yet will serve 19 dwellings
(5 existing and 14 proposed). This access is also a much-used Public Footpath,
which seems to have been largely ignored by the developer with a simple statement
that there will be no conflict between walkers and vehicles due to the low number of
traffic movements, however this only holds true if the number of traffic movements
predicted are accurate which we doubt as 8 vehicular movements are unrealistic in
peak times when there are 43 parking spaces and 60 residents on site. The impact
on adjoining properties (particularly the Lower Springfield Farm House, which is a
Listed Building) of vehicles stopping and starting to give way to other vehicles seems
to have been ignored.
The pre-application discussion with the highway authority resulted in the advice that
the Transport Statement should address, inter alia, ‘the suitability of Westcott Street
and Balchins Lane to accommodate additional traffic given their restricted width’.
We note the Transport Statement makes no mentioned whatsoever of Balchins

17. Lane, which is less than 3m wide in places and has a very unsatisfactory junction
with the A25. As set out above, Balchins Lane is even less suitable to accommodate
additional traffic than Westcott Street. There are only two routes out of the proposed
development. One is along Balchins Lane and the other along Westcott Street. In the
Council’s consideration of the previous application they recognised in reasons for
refusal 1 and 2 that a significant increase in traffic along Westcott Street would be
detrimental to amenity. The additional traffic levels that the current development
proposes would be equally unacceptable as the true number of predicted traffic
movements would be only slightly less than those predicted for the previous scheme.
This additional traffic would have an unacceptable impact on the Conservation Area,
on the current amenity experienced by existing users of the street, both vehicular
and pedestrian and by the users of Balchins Lane.
The traffic diagrams in the Transport Statement concentrate on the traditional peak
hours (8am-9am and 5pm and 6pm) but the traffic counts reveal Westcott Street is
busier at other times (namely 9am-10am and 4pm-5pm). At its peak the existing
flows exceed 100 vehicles per hour on the narrowest section of Westcott Street
between Springfield Road and the village green.
The traffic generation estimates from the new houses are unrealistically low as they
are based on data taken from sites in Durham, Great Yarmouth amongst others,
where car ownership is likely to be lower than in Westcott. In addition the consultants
WSP have incorrectly applied the TRICS figures and used the same figures as they
did before without taking into account the house sizes in the current scheme
becoming much larger and therefore the number of residents on site per house
increasing. The current WSP estimate is now 8 extra vehicles in the AM peak and 9
in the PM peak. These figures are low for the proposed amount of parking and
should be 11-12 for this size of development. The estimates by WSP for the 34
dwelling scheme were 15 and 17 and it would appear that WSP have simply worked
backwards to reduce the number of traffic movements to approximately half as
suggested by SCC rather than assessing the current proposal from scratch. In
addition the transport statement is flawed as it fails to take account of new traffic
from The Pound which was under construction when their surveys were carried out.
Hence traffic flows will be higher than the transport statement suggests.
The Transport statement includes the comment that SCC would accept about half
the previous additional traffic however in the committee report for the previous
application for 34 dwellings in 2010 SCC are quoted as saying that unless there is a
substantial reduction in traffic we are likely to recommend refusal. The current
proposal does not represent a significant reduction. The larger sized dwellings and
increased number of parking spaces per dwelling mean that vehicular movements
will not be substantially reduced. The previous scheme would have resulted in
approximately 90 residents whereas the current scheme would result in

18. approximately 60 residents which is only a 1/3rd reduction in traffic movements. The
previous scheme proposed 77 parking spaces whereas the current scheme
proposes 43 parking spaces which would be 56% of what was originally rejected by
SCC however this scheme also provides informal parking on the estate road so
given the size of the dwellings car ownership is likely to be higher and vehicular
movements correspondingly higher than the 43 parking spaces would suggest.
The transport statement fails to undertake any pedestrian surveys along Westcott
Street hence WSP are unable to make any judgement on the effect of additional
traffic on existing pedestrian flows. At para 4.6.2 the transport statement says that
the increase in traffic represents a change from one vehicle every 37 seconds to one
every 35 seconds. This misrepresents and tries to minimise the effect on
pedestrians. As there is no footway wide enough to accommodate a mother and
child or a mother and buggy all pedestrian movement along Westcott Street from
The Pound to the site entrance will be in the carriageway. As the length of road
between The Pound and the site entrance is about 400m, a pedestrian walking at the
standard speed of 4.8km per hour (ie 3mph) will take 5 minutes to walk this length of
road. This suggests that every pedestrian walking along Westcott Street from the site
to The Pound (where the footway is a bit wider) will be passed by 8 cars. Parents
with small children will take longer and be passed by 10-12 cars. This is totally
unacceptable.
In addition, the effect of construction vehicles on pedestrians will be considerable yet
this has not been considered in the transport statement.
The proposed design of the site is poor for pedestrians and this is an issue which
committee members must give serious consideration to. The site is not sustainable
as it is remote from a low frequency bus service. The bus stop is quoted ‘as 450m
south of the site ‘but this misses the point that the pedestrian route is circuitous and
over 650m from a bus stop. SCC guidance is that all housing sites should be within
400m of a bus stop so this is non-compliant with current highways guidance.
Construction traffic
The developer has submitted an environmental Management Plan to address the
impact of construction however this does not provide sufficient information to allow
committee members to fully assess the impacts of the proposal. For example, it says
that a dedicated construction traffic route has been identified but does not say where
so it is impossible to assess whether there is actually a feasible route available or
not. It says that they will specify permitted delivery times but does not say what those
are so it is impossible to assess what impact these deliveries will have on residents
trying to use Westcott Street and Balchins Lane. It says that they will use a
banksman near Westcott Village Green and on Westcott Street to control traffic but

19. this will not prevent traffic jams for local people. It says that the size of delivery trucks
will be agreed with the Council but gives no indication as to the minimum size of
truck that could be used so it is impossible to assess the true impact of the
construction traffic.
Right of Way
We note that one of the reasons for refusal on the previous scheme for 34 dwellings
on this site was that the development if permitted would have led to an increase in
traffic along an alleged public right of way impacting the safety of vulnerable users –
contrary to policies MOV2 and PPG13. Public footpath No.602 was recently
confirmed on 26th January 2011, and follows the track leading from Westcott Street
through the northern part of the site to join with the Greensand Way further west.
The proposed scheme would lead to a substantial increase in vehicular traffic along
this recognised right of way as we anticipate that there will be up to 60 residents
living on the site and the applicant proposes creating 43 parking spaces. This will
inevitably lead to conflict from vehicular traffic with the vulnerable users walking and
riding along this right of way therefore this proposed development should not be
permitted.
Local Plan Policy
Policy MOV2 in the Local Plan states that development will only be permitted where
it can be demonstrated that it is or can be made compatible with the transport
infrastructure and the environmental character in the area having regard to all forms
of traffic generated by that development. In particular there must be appropriate
provision for off street vehicular parking, vehicular access, capacity on the transport
network and in the vicinity of the development, public transport services and
pedestrians and cyclists. It notes that the cumulative effects of existing and
committed development on the operational capacity and environmental character of
congested areas as a whole will be taken into account in the determination of
development proposals.
We believe that the level of development proposed on the site would result in
potential traffic levels which would exacerbate the already dangerous situation along
Westcott Street for the reasons set out above and therefore that the proposed
development does not accord with policy MOV2.
The proposed level of traffic is also contrary to Policy RUD4 – new housing in
villages as the traffic generated is incompatible with the environmental character of
the village and in particular the conservation area and cannot be adequately
accommodated on the surrounding road network.
5. Flooding
We would also draw committee members attention to the following issues and policy
considerations.

20. PPS25:Development and Flood Risk is a material planning consideration when local
planning authorities are deciding whether to grant planning permission for new
development. Paragraph 1 of PPS25 reminds us that flooding threatens life and
causes substantial damage to property. PPS25 requires local authorities to manage
flood risk by only permitting development in areas of flood risk where there are no
reasonably available sites in areas of lower flood risk and the benefits of the
development outweigh the risks from flooding.
The site is a sensitive location with regard to the protection of controlled waters.
Paragraph 16 of PPS25 states that when Councils are allocating land in local
development documents for development they should “apply the sequential test to
demonstrate that there are no reasonably available sites in areas with a lower
probability of flooding that would be appropriate to the type of development or land
use proposed”. The same approach should be taken here, in that the Council should
not be releasing a reserve housing site which is susceptible to flooding unless they
can demonstrate that there are no reasonably available sites for housing with a lower
probability of flooding. No evidence has been supplied to show that all of the
potential housing land sites identified as available in the SHLAA 2009 have a higher
probability of flooding than the application site. In the absence of such evidence the
Council should not grant planning permission for housing for this site as to do so
would be contrary to PPS25.
We are most concerned that the sequential test does not appear to have been
carried out correctly as the Council appears to have done the assessment on the
basis that the application site cannot be compared with other sites and that it must
be compared on its own. This makes a nonsense of the sequential test. It is not a
case of simply comparing the site to the Environment Agency flood risk boundaries.
The Council’s assessment is deficient as it fails to take into account all possible
sources of flooding. The Environment Agency’s flood map only maps model fluvial
flooding. It does not map model groundwater flooding. The first question asked in the
sequential test is “can development be allocated in zone 1? (other sources of
flooding need to be considered in Flood Zone 1)”. It is clear therefore that all sources
of flooding need to be considered not just the fluvial flooding shown on the
Environment Agency’s map.
The site is at high risk of groundwater flooding as stated by the British Geological
Survey. Taylor Wimpey/WSP’s own initial test results show groundwater rising by
over 1m in 3 weeks under proposed dwelling number 12 (borehole WS101) and also
groundwater only 0.76 m below ground level in some areas of the site. It should also
be noted that the access route into the proposed housing site and other
infrastructure will be in flood zone 3b (1 in 20 year flood risk) and the proposed
escape route runs adjacent to the Pipp Brook on the boundary of the flood zone 3b.
The model which sets the boundary of the flood zones can never precisely determine
exactly where the flooding would reach and therefore Councillors should themselves
attend the site to see for themselves the fragility of this proposed escape route.
PPS25 section 4.59 states that “4.59: PPS25 requires that, where important to the
overall safety of a proposed development, safe access and escape is available to
and from new developments in flood risk areas (paragraph 8 of PPS25). This is likely
to be part of a requirement to pass the Exception Test. Where access and egress is

21. a potential issue this should be discussed with the LPA and Environment Agency at
the earliest stage, as this can affect the overall design of the development. It can be
difficult to ‘design in’ satisfactory access routes retrospectively. Access
considerations should include the voluntary and free movement of people during a
design flood, as well as the potential for evacuation before a more extreme flood.”
A further concern that arises from this application is that in order to avoid disturbing
wildlife and in particular bats along the buffer zone adjacent to the Pipp Brook the
applicant proposing not to light the open area in order to lessen the impact to wildlife
however this would need to be lit as it forms part of the escape route with flood
waters on either side so from a safety point of view lighting must be provided.
The Core Strategy is clear at paragraph 2.57 and goal 7 of the Core Strategy that
local authorities have a role to play in addressing the effects of climate change
through, for example, minimising flood risk to people and property. It is therefore
vitally important that the Council satisfy themselves that this development will not
pose a flood risk to people and property. If they cannot do so then the development
cannot be permitted as it would be contrary to policy.
The application site lies immediately adjacent to the Pipp Brook and is within the
Environment Agency flood zones 1, 2, 3a and 3b. In addition there is sewer pipe
which runs through the site which has been leaking sewage onto the site.
The flood report submitted by the developer states that there has been no recorded
incident of flooding outside of the areas noted as being within the flood zones and
gives an overall indication that flooding is not an issue suggesting that it only has a 1
in 100 chance of happening. We attach photographic evidence within the report
provided by WMAG members showing that the site flooded only last year. They have
confirmed from their own personal knowledge that the site floods regularly, this is by
no means a 1 in 100 occurence.
The developer has designed the site so that the houses are only in flood zone 1
however the access road and the open space are in zones 2 and 3 and are therefore
liable to flood. We would remind committee members that the Environment Agency
flood risk modelling only takes account of surface water flooding, in other words the
flooding you get from the stream overflowing or excessive rainfall events causing a
flash flood. It does not model the application site when it is developed and covered in
hardstanding and buildings. This would clearly exacerbate the flood risk greatly as
the water could not then soak away naturally. In addition, even when the site is in its
natural state, the geology does not encourage the water to naturally soak away
quickly as beneath the top 20-80 cm of topsoil is approximately 1m of clay. Instead
water discharges into the Pipp Brook.
In addition there is significant flooding on the application site on a regular basis from
groundwater. This occurs because the application site is underlain by a major aquifer
only approximately 2m below the surface and perched water tables are also most
likely to occur over the site. Please see the attached photographs showing the site
when flooded by groundwater. Please also note that the British Geological Survey
confirms that the application site is at significant risk of flooding from groundwater.

22. We would also mention that other flood risk assessment companies focus their flood
risk analysis on smaller rivers such as the Pipp Brook and their analysis shows a far
more severe risk of flooding than the Environment Agency analysis. This data
suggests a 1 in 75 year likelihood of flooding.
Paragraph 8 of PPS25 requires that when determining planning applications
Councils must ensure that all new development in flood risk areas is appropriately
flood resilient and resistant, including safe access and escape routes. The
developer’s flood risk assessment acknowledges that the access track from Westcott
Street is subject to flooding in extreme events. If this occurs then future residents
could potentially be trapped on site. Members of WMAG confirm that the track does
indeed flood and we attach a photograph showing the area flooded last year at figure
4. We would also mention that if the track is flooded then the site of the proposed
evacuation route will almost certainly be flooded too as it is only 1-2 m from the edge
of the Pipp Brook at summer levels endangering future residents should they try to
use this route to escape a flooded site.
The flood risk assessment then goes on to propose that pedestrians could evacuate
the site via the pedestrian footway but acknowledges that emergency vehicular
access may not be possible for a time. We would draw the attention of committee
members to the proposed pedestrian evacuation route and highlight that it involves
people having to walk from the housing at the far west of the site to the exit point at
the far east of the site. This may not be feasible for elderly people or young children
and makes access by emergency service staff if needed very difficult. The escape
route itself is right on the edge of the flood zone and we attach photographic
evidence at figure 1 in the attached report to show that it flooded last year, again this
is a regular occurrence.
There is a residual risk of flooding from sewers in storm events. This does not
appear to have been explored in any depth in the application submission. We would
suggest that this is an important issue on which committee members should have full
information before reaching any decision on the planning application.
The flood risk assessment submitted by the developer acknowledges that "from a
recent site visit there was evidence of minor foul effluent water logging within the
lowest point on site attributed to a section of on-site public foul water sewer between
TWUL manholes MH0001 and MH1904. It is thought that was due to the ingress of
tree routes. The report then says that this issue has been resolved by TWUL.
Members of WMAG have observed sewage escaping into the meadow on regular
occasions which would suggest that there is an urgent issue that needs to be
addressed in respect of the existing sewage pipe that crosses the application site. If
that pipe is already overloaded such that it is causing foul water to flood the meadow
then the applicant should be submitting proposals to address this as part of their
scheme and to explain how they intend to connect to the sewage system if it is
already dangerously over capacity. We would draw the committee members
attention to the fact that the Victorian sewers in Westcott Street have been blocked
on two occasions over the last eight years. In terms of the sewers on the application
site, at present the report simply proposes that if these should fail then overland flow
routes will be used to avoid the new houses flooding. The additional houses would
however have substantially increased the amount of sewage that would flood the

23. meadow and then flow straight into the Pipp Brook. This is unacceptable. Given the
close proximity to Pipp Brook this matter needs to be addressed urgently.
We would in particular draw committee members’ attention to Policy ENV 65 in the
Local Plan which provides that development will not normally be permitted unless
there is adequate capacity in the sewerage network or it will be provided in time to
serve the development. If there is not sufficient capacity in the existing sewerage
network then it would be contrary to local plan policy to grant permission for the
development until this is resolved.
The developer proposes to create an area of public open space at the eastern end of
the site and to use part of it as grassland for informal amenity use. However it is
within the flood plain envelope and the flood risk assessment confirmed that it is said
to be damp at certain times of the year. In fact WMAG members have confirmed that
this area of the meadow often floods. As such the land is not suitable for use as
amenity and recreational land.
Policy ENV66 in the Local Plan states that “development that would result in an
increased risk of flooding or have an adverse impact on the water environment as a
result of additional surface water run-off will only be permitted where appropriate
attenuation or mitigation measures are proposed”. The application site is at present a
grassy meadow. Once it is developed, a significant amount of the site will be covered
by hard standing for roads and buildings. This will increase the amount of surface
water that cannot be absorbed by the land and which will run off the site into the Pipp
Brook. We would draw the committee members attention to the fact that the area of
the Pipp Brook beyond the application site to the east is at significant risk of flooding
according the Environment Agency analysis as it is within flood zone 3.
Policy ENV67 in the Local Plan states that development will not be permitted which
in the opinion of the Council, after consultation with the Environment Agency, may
have an adverse impact on the quality of groundwater. The application site falls
within a groundwater protection zone. We trust therefore that the impact of the
proposed development on the quality of groundwater will be thoroughly explored with
the Environment Agency prior to any determination of the planning application in
order to ensure that the proposed scheme is in accordance with Policy ENV67.
The developer is proposing to create a pond on site to collect the surface water run-
off from the hard standing areas before releasing it into the Pipp Brook. There is
concern about whether this system will in fact be adequate in times of extreme
rainfall. Once the pond is full it discharges straight into the Pipp Brook so when there
is very heavy rain, both the pond itself and the Pipp Brook may overflow. In addition,
we would want to see a condition imposed on any planning permission requiring the
developer to pay for the long term maintenance of the pond so that this does not
ultimately fall on the tax payers as paragraph 22 of PPS25 requires land owners to
demonstrate that any flood risk management measures are sufficiently funded to
ensure that the site can be safely occupied throughout the lifetime of the
development.
Para 1.2.1 of the Flood Risk Assessment states that the principle of developing the
site for housing has been accepted by the LPA through the determination of an

24. earlier application for the development of the site for 34 dwellings. That is incorrect
as that application was refused by the Council.
The EA commented in 27 August 2010 that the Council must decide whether the
proposed access route is considered safe taking account of all relevant
considerations and in consultation with their emergency planners. If they are not
satisfied that the proposed measures adequately address the identified flood hazard
then permission should be refused on that basis advises the EA. The EA notes that
the main vehicular access point to the site lies within flood zone 3b which has a 1 in
20 annual average probability of flooding. The EA pointed out that for the
emergency services to be unable to access the site during extreme rainfalls is
contrary to para 4.60 of the Practice Guide to PPS25 which states that vehicular
access to allow the emergency services to safely reach the development during flood
conditions will normally be required. The EA also point out that the secondary access
route requires the residents to travel between the surface water attenuation pond
and an area that is likely to be flooded and the entrance to this footpath may be
restricted due to floodwater during an extreme event. It is abundantly clear therefore
that the access route is not safe and as such permission should not be granted for
this development.
6. Protected Areas
Paragraph 4.7 of the Core Strategy states that “the District's natural, built and
historic environment and biodiversity and green infrastructure will be safeguarded
and enhanced and new development will be accommodated to avoid prejudicing
these attributes in a way that is sustainable, safe and accessible”.
Paragraph 6.4.1 of the Core Strategy goes on to explain that “the landscape of
Mole Valley is one of its greatest assets, appreciated by residents and visitors alike
and the source of inspiration for writers, composers and artists throughout history.
Safeguarding and enhancing the highly attractive and diverse environment is
therefore a key objective of both the LDF (including Sustainability Appraisal) and
the Mole Valley Community Plan and is strongly supported by the community as a
whole”.
Paragraph 6.4.4 of the Core Strategy states that “the Surrey Hills is a landscape of
national importance. It is designated as an Area of Outstanding Natural Beauty
(AONB) and therefore has the highest level of protection in relation to landscape and
scenic beauty. Planning Policy Statement 7 (2004) states that 'The conservation of
the natural beauty of the landscape and countryside should therefore be given great
weight in planning policies and development control decisions in these areas. The
conservation of wildlife and the cultural heritage are important considerations in all
these areas.' The area is covered by the Surrey Hills AONB Management Plan
which guides the future management and enhancement of the area. It is also a
consideration in the determination of planning applications in and around that area.”
Policy CS13 in the Core Strategy states that

25. “1. All new development must respect and where appropriate enhance the
character and distinctiveness of the landscape character area in which it is
proposed. Landscape enhancement works may be required to avoid adverse
impacts associated with new developments.
2. The Surrey Hills Area of Outstanding Natural Beauty (AONB) is of national
significance, and as such, the conservation of the natural beauty of the
landscape will be a priority in this area. The AONB will be protected in
accordance with the objectives in PPS7 and the Surrey Hills Management
Plan, with a particular focus on the impact of development on ridgelines,
significant views, peace, tranquility and levels of artificial light.”
We consider that this large extension of the built environment on a green field site,
immediately adjacent to the Green Belt clearly visible from views from Ranmore
Common which is a nearby Site of Special Scientific Interest and from the Surrey
Hills AONB of which the application site forms part is contrary to Policy CS13 in the
Core Strategy as it has an adverse impact on views from and across the SSSI,
AONB and the Green Belt and cannot in any way be said to respect or enhance
these protected areas. Whilst the number of dwellings have been reduced from the
previous scheme the size of those dwellings have been increased and large two
storey garages of a similar size to a 2 bedroom house have been included in the
current proposed development. The amount of built development proposed therefore
remains incongruous in this setting and has an adverse impact on the protected
areas.
The Surrey Hills AONB Management Plan
The Surrey Hills was one of the first landscapes in the country to be designated an
Area of Outstanding Natural Beauty in 1958 and it has equal status in planning terms
to a National Park. The Surrey Hills Management Plan was adopted by Mole Valley
District Council on 10 February 2009. Visitors to the Surrey Hills seek to enjoy the
remarkable range of changing scenery and diversity of landscape through the
panoramic views obtained from the many vantage points spread throughout the
AONB. This is why the Surrey Hills has views that may be considered amongst the
best and most diverse in England. The quality of views are often diminished by major
highway corridors, masts and developments outside the AONB.
Policy LU2 in the Surrey Hills Management Plan is very clear that “in balancing
different considerations associated with determining planning applications,
substantial weight will be attached to any adverse impact that the proposal would
have on the character of the AONB”. Members of WMAG are very concerned about
the adverse impact which the proposed development would have, as a large
extension of the built environment on a green field site which is immediately adjacent
to the Green Belt, on the views from and across the AONB and we trust that the
Council will, in accordance with policy LU2, accord substantial weight to the adverse
impact of the proposed development on the AONB in considering the application.
Policy LU3 in the Surrey Hills Management Plan requires development to “respect
the special landscape character, giving particular attention to potential impacts on
ridgelines, significant views, tranquility and light pollution”. As explained above, the

26. proposed development will be clearly visible from view points within the AONB
creating views of a substantial number of new houses, roads, parked vehicles and
domestic clutter in place of a green field. The local topography makes it impossible
to properly screen the proposed development from view. We consider that the
proposed development is therefore contrary to policy LU3 in that it does not respect
the special landscape character of the AONB nor significant views from and across
it.
7. Urban Design
PPS 1: Delivering Sustainable development states that design which is inappropriate
in its context will not be accepted. Applicants for planning permission therefore have
to show that they have considered the wider setting of the development proposed
and ensure that it respects and enhances local character.
Policy LU4 in the Surrey Hills Management Plan requires that “development will be
of a high quality in design, respecting local distinctiveness and use of materials and
be complementary in form, setting and scale with its surroundings. Design that fails
to take the opportunities available for improving the character and quality of the
landscape setting and the way it functions will not be accepted”.
Policy CS14 in the Core Strategy requires all new development to respect and
enhance the area in which it is proposed and says that the Council will resist
development of a poor quality of design.
Policies ENV22, ENV 23, ENV 24 and ENV25 in the Local Plan require a design and
layout which is appropriate to the site in terms of its scale, form and appearance and
external building materials, does not significantly harm the amenities of the occupiers
of neighbouring properties by reason of overlooking, respects the character and
appearance of the locality, provides any necessary screening and landscaping
suitable to the character of the locality, provides safe access to the site and a
satisfactory environment for occupiers of the new development, takes account of
public views warranting protection, the views of the development conspicuous from
the Green Belt. The proposed development is not in accordance with these policies
in particular in terms of the overcramped density caused by trying to fit too many
very large houses into one part of the site, due to the standard style of housing
proposed, the impact of the site on the adjacent Green Belt on the other side of Pipp
Brook as it does not have a rural feel unlike the converted farm buildings nearby,
overlooking into adjacent properties on Springfield Road, the inability to screen views
of the site from the AONB which is a public view warranting protection, the lack of
safe access to the site both in highways terms and as a result of flooding as set in
more detail elsewhere in this letter.
Page 12 of the Design and Access Statement submitted by the developer suggests
that the housing on site will be of different forms and styles to reflect the varied local
housing styles. However, the proposed elevations submitted by the developer show
very run of the mill dwellings which appear to be standard Taylor Wimpey designs.
They do not respect the style of housing in Westcott and are not complementary in
form with their surroundings and the rural feel of Westcott. As such we consider that
the proposed designs do not accord with PPS1, Policy LU4 in the Surrey Hills

27. Management Plan or with Policy CS14 in the Core Strategy. If planning permission
were to be granted we would expect the Council to impose a condition requiring
submission of appropriately designed dwellings for approval in order to control the
visual appearance of the development as an estate of very similar looking dwellings
albeit of different sizes would be out of keeping with the existing housing in the
village which is a mix of ages, styles and sizes and would therefore be contrary to
PPS1, Policy LU4 and Policy CS14.
Page 13 of the Design and Access Statement submitted by the developer states that
30% of all dwellings are affordable units (ie 4 out of 14 dwellings). If planning
permission were to be granted then a condition should be imposed to ensure that the
affordable housing is indistinguishable from the market housing. A high quality of
design would be required for the affordable housing in order for the scheme to be
compliant with PPS1 and Policy CS14. We note however that the proposal is to
locate all of the affordable housing on the boundary with the existing dwellings. This
is contrary to both national and local policy which requires that affordable housing
must be located amongst the market housing and not grouped together in one area
of the site.
8. Ecology and biodiversity
We would also draw committee members attention to the following issues and policy
considerations.
PPS 9 states that “Where a planning decision would result in significant harm to
biodiversity which cannot be prevented or adequately mitigated against,
appropriate compensation measures should be sought. If that significant harm
cannot be prevented, adequately mitigated against, or compensated for, then
planning permission should be refused.”
Paragraph 6.4.20 in the Core Strategy states that “all watercourses, mature hedges
and trees within development sites across the District should be, as far as
practicable, retained, protected and enhanced, particularly where they link areas of
existing green infrastructure.....The use of native species as part of planting schemes
is particularly important alongside watercourses due to the potential for non-native
seeds to be carried downstream.”
Policy CS15 in the Core Strategy states that biodiversity will be protected and
enhanced in accordance with European and National legislation and guidance. It
states that all water courses, mature hedges and trees within development sites
should be, as far as practicable, retained.
The presence of a protected species is a material consideration when a planning
authority is considering a development proposal (para 98, ODPM circular 06/2005). It
is essential that the presence or otherwise of a protected species, and the extent that
they may be affected by the proposed development is established before the
planning permission is granted, otherwise all relevant material considerations may
not have been addressed in making the decision (para 99, ODPM circular 06/2005).

28. Further more we note, following the advice of Natural England
(http://www.naturalengland.org.uk/regions/east_of_england/ourwork/standingadvice/
protectedspecies/badger.aspx), that while badger pathways and foraging areas are
not protected under the Badgers Act, the retention of such features will be required if
any mitigation proposal is to succeed, and should therefore be viewed as a material
consideration under Planning Policy Statement 9 (PPS9) (Biodiversity and
Geological Conservation).
The applicant has carried out a protected species survey which found the following
Bats
We note that five species of bat have been recorded on site – all are European
protected species. Bat activity is concentrated along the brook corridor with trees
and shrubs along the brook corridor providing a good foraging resource. The brook
corridor is also considered to provide a dark flightline which bats are using for
dispersal from roost sites to foraging areas further afield. The survey also found that
bats are likely to be roosting close by to the site.
The survey concluded that the proposed development of 14 residential units will not
result in significant impacts to bats as no significant disturbance (i.e. disturbance at a
level that would affect the ability of bats to survive, breed, rear young or hibernate or
that would affect the local distribution or abundance of the species) is anticipated.
The consultants state that the modest number of additional night time traffic
movements along the access road will not have an impact on this roost location at
the dairy. Any existing influence from car headlights does not appear to cause
disturbance to this roost and one would not expect the tiny increase in traffic
movements after dark to alter this. It is difficult to see how it could be concluded that
there would only be a tiny increase in traffic movements given the 43 parking spaces
to be provided on site and the potential 60 residents. In the winter particularly all
vehicles returning to the site after normal school and/or work hours will be using their
headlights and may disturb the bats.
The survey goes on to say that the existing hedge and trees along the western
boundary of the site will be retained, wildlife corridors (designed to aid badger
dispersal) will be provided along the western and southern margins of the
development area and a species rich native hedgerow will also be planted all the
way along the southern boundary of the site to further strengthen this boundary.
These measures should ensure that bat flight lines and foraging opportunities are
retained and enhanced along these margins of the site, which the consultants say
will be bordered by new back gardens and associated planting. In fact the
consultants have said that the main dark flight line for the bats is along the brook
corridor and here the gardens of the dwellings along the Pipp Brook face away from
the brook and the road and it is the front of the houses that face onto the brook so
there will be disturbance to the bats both from lights within the houses and car
headlights as people arrive home.
The survey states that the existing access track and any new access roads through
the new development will remain under private ownership and there are no plans for
these roads to be adopted by the Local Authority. As roads will be under private

29. ownership there is no requirement to provide new external lighting within the
development, and therefore no disturbance impacts to bats using the site or adjacent
areas are anticipated with regards to new external lighting provision. It is
acknowledged that new home owners may want to provide their own external
lighting. However, it is suggested that private external lighting be provided by the
developer with detailed designed of such lighting being provided to and agreed by
the Local Planning Authority prior to development commencing. Any such lighting
scheme should be developed in close consultation with a suitably experienced bat
ecologist. This section of the report is very muddled and it is unclear whether there
will be lighting adjacent to the Pipp Brook or not. It is entirely likely that home owners
will want to install exterior lights to assist them when they return home after dark, the
emergency access track needs to be lit in order that it can be used safely in the
event of a flood and there will inevitably be light pollution both from lights left on
inside houses adjacent to the brook and from car headlights on the estate road. It is
clear therefore that the bats will be disturbed by new light sources from the proposed
development unless the scheme is re-designed to move all housing further away
from the brook and to move the emergency access well away from the brook.
Badgers
The survey states that no badger setts were identified within or immediately adjacent
to the proposed development site during any of the survey visits undertaken.
However, some evidence of badgers crossing and foraging within the site was noted
and badgers continue to use the well established badger setts located within
woodland on the other side of Pipp Brook and to the south within woodland
associated with the Recreation Ground. Mammal paths (some likely to be badger
trails) being noted primarily along the southern boundary of the proposed
development site, and the eastern boundary along the margin of Pipp Brook. There
is also some evidence to suggest that badgers are moving onto the site from the sett
to the south, entering the site under the fence in the south-western corner. However,
it is not clear if the same badger clan is using the setts to the north and south of the
site or not. The survey concluded that badgers from a nearby sett are likely to cross
Springfield Road and pass into the proposed development site at its south–western
corner (between 62 Springfield Road and 1 Westcott Street). Badger paths running
eastwards from the setts link up to the public footpath which passes along the
eastern margin of the recreation ground, across Springfield Road and onto land
adjacent to the eastern end of the proposed development site. It is presumed that
this also provides a route for badgers to disperse from the recreation ground setts to
land to the north and east of the proposed development site.
The survey concluded that whilst grassland within the proposed development area
would appear to form part of the home range of at least one badger clan it is not
considered that the loss of the 0.8ha of grassland under the proposed development
footprint will result in a significant impact to the local badger population as significant
areas of other suitable foraging habitat, comprising pasture, woodland and local
residents gardens, are available to them. The footprint of the new dwellings
proposed on the site will result in the loss of around 0.8ha of rough grassland, with
the remainder of the 1.9ha site being retained (e.g. brook corridor) or landscaped to
provide new grassland and wetland habitats (e.g. POS at the eastern end of the
site), thus retaining some opportunities for badger foraging within these areas. The

30. loss of this quantum of foraging habitat is not considered to be significant to this
population.
Whilst there are plenty of opportunities for badgers to disperse from the setts to the
south to grassland used at the eastern end of the site and beyond (e.g. through
existing gardens along Springfield Road and via the footpath No.’s 26 and 24
Springfield Road), badger dispersal corridors will be provided along the western and
southern margins of the new development area to allow badgers to use existing
dispersal routes from the south-western corner of the site to the north and east.
These badger dispersal corridors will be c.3m wide and planted up with a mix of
native thorny species to provide suitable cover and a new foraging resource on the
form of windfall fruit / berries. The boundaries of the site will not be subject to any
external lighting and will be fenced off from new gardens to avoid any disturbance
impacts. The dispersal corridors will provide access from the southwestern corner of
the site to the brook corridor to the north and grassland habitat to the east of the new
development.
We would point out that in fact the emergency exit track will have to be lit in order
that residents can use if safely in the event of a flood and therefore there will be light
disturbance to the badgers that currently use this site.
Reptiles
The protected species survey found that no reptiles were observed during any of the
survey visits undertaken, either under or on top of the artificial refugia, or basking in
the open. The surveys were undertaken in suitable conditions for reptile surveying
and the number of visits employed is considered to be appropriate to confirm the
presence / absence of reptiles on the site. However, it is likely, as indicated by the
new records, that reptiles will be present in close proximity to the site and could
therefore disperse onto / across the site from time to time. Whilst it is considered that
the proposed development would be unlikely to have any impacts on local reptile
populations, it is recommended that a precautionary approach to clearance of the
site be undertaken to avoid any potential direct impacts to reptiles which could result
in an infringement of the law. The adoption of this approach assumes that current
survey evidence (<2 years old) exists which indicates that reptiles remain absent
from this area. In other words, should development be delayed a new reptile survey
at the site would become appropriate in 2012. This should be secured by condition
should planning permission be granted.
Conditions for ecology and biodiversity
We note that the developer is proposing a 10 metre habitat buffer between the new
access road and the Pipp Brook. If the Council was minded to grant planning
permission we would request the imposition of a condition securing the developer’s
long term commitment to the ongoing management of the public open areas
including the habitat buffer and area alongside the Pipp Brook for the lifetime of the
development.

31. The Ecology Study proposes provision of bird and bat boxes and the creation of log
piles for mammals and invertebrates. If the Council was minded to grant planning
permission we would request the imposition of a condition securing the provision of a
sufficient number of these replacement habitat together with an obligation to require
the developer to maintain them for the lifetime of the development.
The developer is proposing to install a fence along the access road to discourage
public access to the habitat buffer. If the Council was minded to grant planning
permission WMAG would want a condition to be imposed controlling the type of
fencing used as residents of Westcott have enjoyed views of the Pipp Brook for
many generations and will still want to be able to see and enjoy the brook should the
site be developed.
We also note that the Ecology Study submitted by the developer states that the
wooded brook corridor is a strong landscape/habitat feature which foraging and
commuting bats could exploit. If the Council was minded to grant planning
permission therefore we would expect to see a condition requiring the retention of all
of the trees on the south side of Pipp Brook as they are important for wildlife
including bats.
We note that the Ecology Study found that there is Japanese knotweed in the north
west corner of the site. This can be a very difficult weed to remove from a site and
frequently strong chemicals are used in order to kill the plant. Given the very close
proximity to the Pipp Brook, if the Council was minded to grant planning permission
we would request a condition requiring the developer to submit a method statement
to remove the Japanese Knotweed to be agreed with the Council and then followed
to avoid any potential contamination of the Pipp Brook by pesticides.
In light of the habitat environments proposed immediately to the east of the
development footprint, and along the Pipp Brook corridor, we would expect to see an
Ecology and Landscape Management Plan agreed with the Council, with its
implementation secured by condition, with an agreement to manage in perpetuity
should the Council feel minded to grant planning permission for the development.
9. Public Right of Way
The Design and Access Statement submitted by the developer claims that the track
that crosses the site is a private track with a third party right of way along it. It is
important that committee members are aware that this is not correct. In fact the
Council determined in June 2010 that both the track that crosses the application site
and the access road joining the site to Westcott Street are public rights of way and
the definitive map and statement have now been amended to include them.
The developer has proposed a raised footpath through the site to Springfield Road. It
would appear that this is intended to replace the existing public footpath. If so the
developer cannot simply construct this without first going through a formal
application process to divert the public right of way. We would ask members of the
planning committee to bear this in mind when considering the planning application as