CPRE Surrey – Waverley District:
Further REQUEST TO CALL IN Planning application
Application WA/2015/2395 as amended. Dunsfold Aerodrome Application to build up to 2600 houses pursuant to unapproved draft Local Plan.
The Rt. Hon. Sajid Javid MP,
Secretary of State for Communities and Local Government,
2 Marsham Street,
London SW1P 4DF.
REQUEST FOR THE SECRETARY OF STATE TO CALL-IN APPLICATION NO.WA/2015/2395 MADE TO WAVERLEY BOROUGH COUNCIL
PROPOSED DEVELOPMENT OF DUNSFOLD PARK
We have reconsidered our letter to the Secretary of State dated 4 September 2016 and subsequent correspondence with Ms Bowen and feel we should comment further in the light of the decision, by a narrow majority, to approve this application subject to conditions.
Our comments are as follows:
1 We have considered the Waverley Planning Officers’ Report for the Joint Planning Committee’s Meeting on 14 December, which we think was deficient in a number of important respects in particular
The recommendation to the Committee is said to be justified by the view that the Draft Local Plan is not sufficiently advanced to support a claim that approval would be premature. Yet, the Applicant relies on the Plan to justify the Application as an exception to the clear provisions of the current 2002 Plan which in all material respects is compliant with the NPPF. This argument is, as an objective fact, incorrect and, in CPRE’s view, untenable.
The Report failed to draw to the Committee’s attention the concern that deciding the Application before the Draft Local plan was examined in public and declared to be sound was seen by some (including CPRE) as seriously , even fatally, undermining of the Plan led system. This also appeared to ignore a recent decision that little weight could be given to an unapproved Plan. (referred to in our previous letter)
The arguments put forward for distinguishing the Secretary of State’s Decision from the current situation are wholly unconvincing.
1) in the light of Surrey County Council’s repetition of its advice that the local road system cannot bear the likely additional traffic and that no adequate mitigation is possible or in contemplation.
2) the lack of evidence that the necessary infrastructure for this development can be provided or financed.
2 We do not wish to overburden this letter with further comments (of which there are many) since all the circumstances are, in our respectful view, well sufficient to justify a decision to make a call in because
a) a decision not to do so would seriously compromise the whole system of planning inspection of Local plans and b) because it is fundamental that Local Councils should be held accountable for their actions in settling local plans by proper independent public scrutiny of their proposals and not able to be a judge in their own court. The decision to grant consent to the Application is an attempt to pre-empt such scrutiny and undermines the statutory purpose of Inspection of Local plans.
3 Finally and crucially we invite the Secretary of State to take into account that in relation to the required number of houses for Waverley derived from the OAN on which it relies (Hearn’s West Surrey SHMA report) it is indisputable that, if more up to date information, such as that provided in the Macdonald report, is used, the OAN for the 19 year period of the Plan would be reduced by as much as 22% rendering the inclusion of the application site unnecessary and inappropriate.
This is such a fundamental issue, going to the root of soundness of the Plan, that it needs to be considered by the Inspector before the grant of the Application. In our respectful view, it cannot properly be withdrawn from his consideration by what amounts to predetermination.
CPRE respectfully invites the conclusion that this Application should be called in.
4 January 2017