lollesworth, east horsley
Planning Scrutiny Group, Guildford, Surrey
Planning reference number 21/P/02394 Lollesworth Fields, East Horsley
Approval of appearance, landscaping, layout and scale for residential development | Land rear of Chicane and Quintons, Ockham Road North, East Horsley, KT24 6PU
2nd OBJECTION (25/5/22)
Overall, we object to this development. None of the points in our previous response to
this planning application have been addressed. We would like to highlight the importance of designing out the gas boilers from the development. The UK has a legal commitment to carbon neutrality by 2050, and consequently gas boilers will be banned in new builds from 2025. This will put this development on the border between inefficient, polluting gas boilers and a requirement to install greener heating options. For the sake of residents (who will be stuck with high fuel bills which will only get higher as fossil fuels inexorably increase in price during electrification) and for the climate/environment, including future generations and our wildlife, these boilers should be replaced with efficient electric boilers, or ideally designed out altogether in favour of insulation, thermal mass and/or heat pumps.
Please see the following additional comments:
The plans provide for 20% above the minimum parking requirements which encourages car ownership and use. This contradicts Guildford Borough Council’s ambition to have a modal shift to walking and cycling.
● Parking requirements to meet minimum parking requirements without additional parking
Overall, we object to this development. Our main objections are the following. Further recommendations are highlighted in the main body of our letter.
Energy: The UK has a legal commitment to carbon neutrality by 2050, and consequently gas boilers will be banned in new builds from 2025. This will put this development on the border between inefficient, polluting gas boilers and a requirement to install greener heating options. For the sake of residents (who will be stuck with high fuel bills which will only get higher as fossil fuels inexorably increase in price during electrification) and for the climate/environment, including future generations and our wildlife, these boilers should be replaced with efficient electric boilers, or ideally designed out altogether in favour of insulation, thermal mass and/or heat pumps.
Flooding: The site owners have recently changed the category of flood risk and the change is illogical as this area is prone to flooding. There are many measures to prevent flooding in the design which all have to work at the same time, which is unrealistic. Surrey County Council have found errors in the surface water calculations - these need to be corrected.
Transport: The use of e-bikes is likely to become more and more popular over the lifetime of the building, opening up the use of heavier cargo-laiden bicycles, yet these larger bicycles will not fit in the cycle storage, nor can they be manoeuvred from the cycle storage along the footpath to the road. The same is true for recumbent bicycles
(often used by disabled people). The lack of cycling infrastructure near to the site is a huge barrier to cycling. It is vital that the development financially supports community infrastructure via a section 106 agreement. A walking and cycle route through the playing fields to the north and along Weston Lea should be provided. This is the only opportunity East Horsley will have to provide a safe cycle route to the local primary school and to the station, avoiding busy and narrow Ockham Road North. Additionally, there is no provision for car club spaces. A development of this size should promote car sharing via a car club.
1.0 Green space and urban design
1.1 Site designation
It is disappointing to see this loss of green space, particularly on what was recently designated greenbelt, agricultural land, trees and hedgerows.
1.2 Biodiversity and trees
A stream and ponds run through the site, and Lollesworth Wood (adjacent to the site) is ancient woodland (see image below);
Figure 1 - Hatched green area shows ancient woodland. Source: Magic Maps.
As per the Woodland Trust, ancient woodland supports more threatened species than any other habitat in the UK. Nearby Lollesworth Wood is home to countless species, and nocturnal species in particular will be threatened directly and indirectly by this site due to light pollution. Wildlife corridors and a traditional grazing area will also be heavily impacted by this development, with far-reaching effects in the broader area.
The Woodland Trust also recognises five other major impacts on ancient woods of nearby developments, namely;
● chemical effects
● invasion by non-native plant species
● cumulative effects
These impacts are laid out in a paper titled Impacts of nearby development on the ecology of ancient woodland, available at https://www.woodlandtrust.org.uk/media/43620/impacts-of-nearby-development-on-the-ecolo gy-of-ancient-woodland.pdf To summarise, ‘it is essential that new development does not further impact upon the functional integrity of this irreplaceable biodiversity resource. It is hoped that this synthesis of information on the impacts of nearby development on ancient woodland will ensure that these are properly considered in future planning decisions’.
2.0 Sustainable Living
2.1 Lifestyle and wellbeing
Every effort should be made to ensure residents can live as sustainably as possible. This includes everything from providing active travel and public transport links through and to/from the site, to ensuring dwellings are powered and temperature-controlled passively and with green active technology, to retaining and replanting as many trees and green spaces as possible.
2.2 Transport and travel
The footpath along Ockham Rd North is extremely narrow. A pedestrian route to the north of the site, through the adjoining playing fields, with access granted through the private road of Weston Lea would make a much more attractive walking route to the north, see Figure 2. This would provide pedestrian access to the nearest primary school (The Raleigh School).
Figure 2 - proposed walking and cycling route
❖ Council to seek financial support from the development for community infrastructure via a section 106 agreement.
There is no safe cycling route along Ockham Road North for cyclists. The road is busy and narrow, and the existing footpath is too narrow to ever enable it to become shared use. The lack of local cycling infrastructure is a huge barrier to cycling. This development presents the ONLY opportunity East Horsley will have to provide a safe, quiet cycle route to link to the station. The cycle route could use the same route as the footpath described in the section above. If the route cannot be built immediately, passive provision should be included in the design.
❖ Safe cycle route to be provided.
Bicycle storage provided in the design is inadequate. With electric bikes on the increase, the number of larger cargo bicycles is likely to increase considerably over the lifetime of the development. Department for Transport’s LTN1/20 Cycle Infrastructure Design states that a cycle design vehicle should be 2.8m x 1.2m with an outer radius of 3.4m, and cycle infrastructure should be designed for this. As is shown in Figure 3, the cycle design vehicle will not fit in the cycle storage and cannot be manoeuvred from the cycle storage to the road.
❖ Provision for larger cargo bicycles to be provided.
Cycling among disabled people is almost as popular as among non-disabled people, with 17% of able bodied people cycling regularly and 12% of disabled people. Cycling is easier than walking for 3⁄4 of disabled cyclists, however recumbent bicycles cannot be manoeuvred along the route from the cycle storage to the road as shown in Figure 3.
❖ Provision for recumbent bicycles to be provided.
Figure 3 - cycle design vehicle (orange) cannot be manoeuvred from the cycle storage.to the road
Guildford’s climate emergency declaration requires planning to “encourage car share schemes” - however, despite the large scale of the development, there are no spaces allocated for car share/car club schemes.
❖ Allocate some spaces for car share/car club scheme.
Charging points for electric vehicles should also be provided for all dwellings - however, active travel, public transport and car-sharing should be prioritised.
With the significant impact on the environment that all new building developments bring, the council should be doing everything in its power to ensure that all housing developments are as climate- and environment-friendly as possible. This applies not only during construction and immediate impact, but also on an ongoing basis during the lifespan of any development.
The UK has a legal commitment to carbon neutrality by 2050, and consequently gas boilers will be banned in new builds from 2025. This development will therefore be close to the cut-off point for this ban. It is shameful that the energy report for a new development of 110 houses, to be completed only just before the 2025 deadline if at all, favours gas boilers simply on the matter of "capital-cost implications". Even disregarding the climate, environmental and other impacts, the claim that gas boilers are the only cost-effective solution to the problem of heating fails to take into account alternative passive and active technologies for heating.
❖ Passive heat retention methods such as improved insulation and greater thermal mass to be improved as a priority.
❖ Active heating solutions to be considered, such as solar hot water - which can be implemented far more cheaply than gas boilers, while also avoiding all or almost all of the negative impacts of 110 new gas boilers.
Bearing in mind the UK’s legal commitment to carbon neutrality by 2050, not to mention a presumed ambition to avoid the climate, environmental, ecological and human impacts of increasing emissions and air pollution, the fact that the energy report dismisses the use of air source heat pumps is especially disappointing. This technology, along with electric boilers, may currently be more expensive per unit than gas boilers, but over their lifetime will be significantly cheaper to run and maintain, especially as gas boilers are rapidly replaced by these technologies. In a development of this size, there is also potential for district heating via ground source heat pump, which when applied across all 110 units plus possibly other local buildings (either immediately or in the future) could ultimately be more cost effective than individual gas boilers. Of course, any of these three technologies will be far more cost effective in any case than gas boilers in all but the shortest of short-term calculations - before even factoring in the costs of climate, environmental, ecological and human costs.
❖ Air source heat pumps, ground source heat pumps and electric boilers to be considered.
Given the 2025 ban on gas boilers, along with inexorable increases in fossil fuel prices we will see in the coming years, installing gas boilers in this development will see residents burdened with high fuel bills which will only get higher still. The current energy crisis has brought into sharp relief once again the impact of fuel poverty on communities, even in our relatively rich area. The fact that Surrey has more older residents on average than many other counties is also important, given the surge of winter deaths and ‘heating or eating’ incidents we experience during every bout of cold weather. By contrast, implementing passive heat retention such as insulation and high thermal mass, coupled with energy-efficient and futureproof active heating such as solar hot water or heat pumps would not only reduce these incidences, but also save residents thousands of pounds on fuel bills - boosting property values and paying for any increased capital expenditure invested in these solutions.
The council should be insisting that all new developments use alternative heating methods well in advance of the 2025 cut-off point for new gas boilers.
❖ Therefore this development should not be approved until green passive and active heating methods are proposed. If the developer refuses to replace gas boilers with solutions that meet reasonable climate, environmental, ecological and human targets then the application should be rejected.
3.0 Water, Flooding and Drainage
3.1 Flooding and surface water drainage
This area is known to flood and therefore the application should be rejected. There are so many complicated and interconnected forms of mitigation proposed that have to all work to avoid flooding. We know that climate change is already causing extreme weather events and that those in this country are likely to involve heavy rain.
The site owners started by requesting a change of the category for flood risk. The bizarre situation is that the higher land to the south of the railway line now has a higher flood risk status than the lower land to the north where the development sits. The experience of local residents of flooding is more realistic than endless modelling to get the answer you want.
The water table is high. The underlying local strata is London Clay which is not very porous. Buildings and tarmac roads on the land will reduce the surface area for absorption and increase run off. The removal of trees and plants will remove their water holding capacity.
The use of swales for Watercourse B, which crosses west to east, will help the surface water absorption and provide wildlife habitats.
The attenuation ponds are critical to holding enough water to prevent flooding . Water flowing through them will deposit silt and reduce their effectiveness. The outlet rates are being controlled, so when that rate is exceeded there will be flooding. Maintenance of all the mitigation measures is an ongoing requirement to be organised and paid for.
SCC Suds have found that the surface water discharge rates have not been correctly calculated. What are implications with correct calculations?
❖ The application should not be approved until correct calculations are submitted.
The effect on adjacent houses of diverting Watercourse A (which crosses the access road) has not been fully investigated. Using the established pond for drainage is damaging to the ecology of the pond and not acceptable. Controls and changes to the main Stratford Brook may have implications for flooding to the north, in Weston Lea and Heatherdene.
3.2 Foul drainage
All foul drainage is planned to enter the run in Ockham Road North. The majority is by gravity but the northern part of the site is too low for gravity feed and a pump is required to raise the sewage. Pumps are not sustainable.
The pump house is located in the area prone to flooding and is therefore at risk of breakdown. This would cause serious problems.