CPRE takes aim at Waverley Council’s ‘flawed’ Local Plan

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Countryside campaigners have denounced Waverley Borough Council’s new draft Local Plan as “fundamentally flawed” and have warned that the Plan risks being declared “unsound” by the Planning Inspector as it relies on the inclusion of “unsustainable” development sites to meet its housebuilding targets.

The local branch of the Campaign to Protect Rural England (CPRE) says that the Plan, which was adopted by the Borough Council last week, has “many serious defects”. These include:

  • insufficient weight given to countryside protection due to excessive and unrealistic housing numbers
  • the Area of Outstanding Natural Beauty, Areas of Great Landscape Value, the Green Belt, and important heritage assets, all put at risk
  • inclusion of unsustainable development sites such as Dunsfold
  • reliance on unspecified and un-costed infrastructure improvements for major development sites
  • failure to give adequate weight to planning constraints, especially building on the Green Belt, contrary to clear Government Guidance.
  • heavy reliance on a flawed consultation exercise

Anthony Isaacs, Chairman of CPRE Waverley, says: “We have serious concerns that the draft Local Plan cannot be achieved without serious and irreparable damage to the countryside. The target of 9,861 houses (519 per annum) is far too high and means that large swathes of our local countryside are at risk of being lost for ever.”

He adds: “The target housing number is based on flawed central government methodology which has resulted in unreliable, unachievable and fanciful long-term predictions of population growth, mainly due to inward migration from London, which make no sense for a rural area such as Waverley, particularly in the current uncertain political and economic climate. The Plan does not give sufficient priority to affordable or low-cost housing for which there is genuine local need.

Green Belt

“The draft Plan erodes the Green Belt, ignoring Government policy which gives the strongest possible protection to the Green Belt, and disregards the recent ministerial statement that ‘demand for housing alone will not change Green Belt boundaries’. Waverley should be strengthening its countryside protection, not weakening it. CPRE has long argued that the Surrey Hills AONB needs to be extended to include the Area of Great Landscape Value.”


CPRE points out that the Plan is not achievable without using the former Dunsfold aerodrome for housing. Dunsfold was previously rejected as a site for large-scale housing development by a Planning Inspector, and by the then Secretary of State for Communities & Local Government, who said they considered it to be “unsuitable” and “unsustainable”. The Secretary of State’s decision stated that the development “would have a severe and unacceptable impact on an overstretched local road network and that the scheme is unsustainable in transport terms.”

Even if practically achievable, the cost of infrastructure required by the Plan would be colossal, Anthony Isaacs says. “The Plan is largely silent on what infrastructure is needed and where finance will be found, but it is unlikely that more than a small proportion will be supplied by developers and the balance will need to be found from central or local government.

“How should Waverley choose between its ‘Objectively Assessed Need’ (OAN) of 519 houses every year and what the borough can reasonably accommodate? The National Planning Policy Framework (NPPF) states that the OAN is the ‘starting point’ and refers to meeting the full OAN ‘so far as consistent with the policies set out in this Framework’. That allows the council to do what is best for the borough and community as a whole by taking account of other provisions in the policy framework which are designed to protect the Green Belt, the AONB, the AGLV, biodiversity, the heritage of Waverley’s countryside and its towns and villages, the countryside at large, and its capacity to provide for leisure pursuits, tranquillity, relaxation and enjoyment.” 

His views are echoed by CPRE Surrey Branch Director, Andy Smith, who says: “Waverley Borough Council is asking for approval of new housing estates without any firm plans for new transport services or infrastructure to support these new communities. Dunsfold and Cranleigh are expected to absorb 45 per cent of the total ‘Objectively Assessed Need’ for the whole borough but are currently in an area of little infrastructure, with no railway, no trunk roads, and a network of vulnerable rural lanes.

“Surrey County Council, in its recent Infrastructure Study, has already identified a substantial funding gap between what is required to meet existing needs in Waverley and what is actually available. There just isn’t the money to provide the infrastructure and services needed for the borough’s current population, let alone the scale of increase projected in the Local Plan.”

CPRE will be responding in detail to the Local Plan in the coming weeks.