West Dorking Resident's Group

Representation on proposed Future Mole Valley Local Plan[1]

Objection on the basis of Soundness

 

The case for the number of houses upon which this plan is based is unproven. Further, in attempting to implement this target, the council has not considered sustainability, whether that be measured by the effects on the environment, the economy, infrastructure or the well-being of the local population. I object to this plan in the strongest terms and believe that the council should adopt a top-down approach that truly balances what the area can accept in terms of population and housing growth. Further it needs to proactively seek to achieve the needed level of housing, by more creative sustainable means.

In relation to the details of the plan, there are many areas that documents where impacts of the planned development are skirted over, contradictory or at least poorly explained. I would have liked in this response, to have avoided concentrating on specific areas, for fear of being criticised of Nimbyism. Rather I would have preferred to provide a comprehensive response spanning the whole plan. But, with the vast quantity of documentation associated with this plan, this was impossible. Thus, I have to illustrate my points I have largely had to make reference to sites with which I am familiar e.g. the planned development to the West of Dorking. However, any reader will appreciate that the points are generic in nature and could be applied to many of the areas of proposed development.

1.    Objection on the basis that there is a lack of strategy for the UK or our local area

The assertion that we need 6000 homes built in Mole Valley is based on the status quo of allowing the current economic situation in the UK to continue. We all know the South-East is attractive to business and people alike. It’s a negative spiral of more people, means the area is more attractive to business, equals more jobs, equals more people. And the consequence of this is a need for high levels of house building, but this can’t continue. If we do continue to accept this, the South-East will be concreted over. The UK, and our area, needs a sensible economic and political plan to generate jobs and housing in areas currently struggling and have brownfield sites that can accommodate the growth.

We can start this by pushing back, demonstrating on sustainability grounds that we cannot accommodate this level of growth in Mole Valley and demanding that a proper plan is developed at a National level. Locally, we need to work out what growth in housing is really needed and then make the right decisions to achieve that growth. For example, the areas for development identified here have been arrived at by asking local landowners what they would sell, rather than identifying land that should be used and compulsory purchasing it for development. Why not re-develop, rather than build on agricultural land? Let’s lose a golf course in preference to farmland if we really must. But first, let’s incentivise owners of under-occupied housing to free up that space, so that a family can have a home.  

2.    Objection relating to the evidence for the housing need – the plan is based on the wrong housing numbers

The plan is based upon attempting to meet a Government algorithm demanding construction of 456 homes per annum, 6000 total. There is evidence presented of actual need buried within the evidence pack, but not used or even mentioned in the Local Plan. This evidence[2] can be summarised as a need for:

• Affordable homes 143 pa
• Actual total home need 193 units pa the referenced Scenario 1

The plan should be built upon the actual need as asserted above.

3.    Objection on the basis that all options for brown belt development have not been exhausted

As noted above, this plan has been built bottom up, the areas being considered development being offered by local landowners, rather than being the “right” areas for development. Furthermore, there are other options that have not been considered to provide the housing that the area needs (whatever that actual need is). For example there are:

1. Empty homes in the area. There are 680000 in the UK according to government figures[3]
2. Many underoccupied homes (8 million in the UK[4])

There is no evidence that in developing this plan the council has looked at compulsory purchase of existing brownfield and housing stock land selected for good strategic reasons to increase housing density. An approach such as this, where the council work with a housing trust to build social housing, could successfully solve the apparent social housing need. Others are doing this[5].

Further the plan discourages the use of some Brown-field sites (Class E commercial sites). This seems non-sensical given those large amounts of the office space in Dorking has remained empty for many years on the Dorking Business Park and businesses are reducing their office usage in the “new normal”. This aspect of the plan needs to be adjusted making more brown-field space available for housing.

4.    Objections on the basis of Sustainability   

I strongly object on the basis the proposal is not sustainable. Indeed, it affects our local environment, the UK and in turn the planet, from a number of perspectives including:

• It increases CO2 by building on our green areas - Reducing our “green” areas upon which we are reliant to reduce our CO2 impact. A site developed for property, cannot absorb the CO2 levels of an agricultural or other green site. Indeed it is even possible for agriculture to reduce CO2 in our atmosphere[6].
• Increasing food miles - The proposed plan includes significant development of Agricultural land (circa 0.9 million Sq. meters) currently in the Green Belt i.e. farmland used for food production (e.g., DS8 DS 24 DS 26 DS 41 DS 42). This will reduce food production in the local area and in the UK. We already import 50% of our food in the UK[7]. We cannot let this proposal happen, it makes a bad situation worse. Amazingly this factor has not been considered in the Sustainability appraisal associated with the plan, making it a flawed document.
• It reduces biodiversity Reducing biodiversity of the green belt sites – by no measure can an agricultural site be developed in a manner that continues to support the huge range of wildlife currently observed in the area and on the sites proposed. For example on DS24 (18-DK-020) Sondes Place farm, current wildlife is as wide ranging as Red Kites, Sparrowhawks, Deer, Common Lizards, Grass Snakes, Foxes, bats etc. And the Green belt assessment document[8] states “It is unlikely that development of the site will provide biodiversity net gain”
• Reduction in resilience of local infrastructure to global warming. From both the aspect of reducing the water absorption of the area and increasing the local population and traffic, the proposal will further stress our already overstretched infrastructure. Indeed, Surrey County Council recognise the risk is already here without further population growth and development²

Indeed Mole Valley’s own 2017 sustainability assessment[9] highlights many difficulties in relation to the Local Plan including:

• “the threat of development on and to heritage and cultural assets, including open spaces and views.” – a clear issue here on this site and others of a similar nature in the plan.
• “There has been no significant loss of agricultural land.” But not the case with respect of this proposal.
• “The landscape management plan for the AONB has been put into effect, protecting this landscape character resource. No indicators identify any issues contrary to the aim of landscape protection.” Clearly untrue in respect of this proposal.

Further we should note that the proposal to build 6000 homes in Mole Valley, many of which will be on green sites such as this, is in contradiction to Surrey County Councils Net Zero Policy whose recent Task Group’s final report[10] states that we must:

• 1. Ensure climate change is at the centre of the work we do
• 17. Develop a land-use strategy for Surrey focused on increasing green spaces, woodland cover in line with national targets and sustainable farming practices.
• Deal with carbon emissions from agriculture not by reducing agriculture as proposed here, but by “improved sustainable farming practices e.g. reduction in use of pesticides, crop rotation and shared land use (e.g. reforestation)”.

5.    Objections on the basis of impact to the local economy

Increased development will reduce the greenness of Mole Valley meaning less visitors to the area. This area of farmland, and those like it, are visible from nearby AONB hillsides visited by hundreds of thousands of tourists, bringing money into the local economy. They don’t visit to climb hills and get views of housing developments and large towns. They want to see green woodlands and farmland. Some will stop coming as a result of these developments, hence the assertion that our economy will be adversely affected. For example the Green belt assessment document states that “18-DK-026 The site would have a significant impact on the historic setting, appearance and views into Dorking. It would impact negatively on heritage assets in the vicinity in terms of views and the importance of their open character. There would be harm to the historic landscape and harm to attractive and significant views over Dorking from the Greensand Way. The public access and heritage objectives of the publicly-funded Deepdene project would be undermined.”

And of course, for many people this proposal will mean the area is a less attractive place to live. More houses = less green areas + more traffic = less attractive place to live. Perversely, this plan could actually lead to overcapacity in housing as less people want to live here.

6.    Objections on the basis of impact on infrastructure

Traffic

The currently terrible traffic situation in the area will be greatly worsened:

• 6000 homes = 12000 cars = 24000 or more extra car journeys per day!
• Dorking grinds to a halt four times daily – rush hour, at the start and end of the day and school drop off and pick up.
• How can we accommodate more people on our roads?

This point it proven in the evidence pack associated with this Plan[11] for example it states: “ 7.2.2 Elsewhere in the town, the A25/Vincent lane junction is impacted by the Local Plan trips and its Level of Service (LOS) deteriorates to level F indicating significant delays. The increase in delay at this site can be mainly attributed to the Sondes Place Farm and Milton Court lane developments to the west of the town. LOS also deteriorates on the A24 Deepdene Avenue northbound approach to the Deepdene Roundabout in the Do Something scenario although not to the same extent and likely to be as a result of the cumulative impact of a number of sites within the town.“

Utilities

The utilities infrastructure in the South-East of England, is already under pressure as the recent publicity regarding the sewage releases across the UK demonstrates. For example The Rivers Trust “Sewage in Rivers” data[12] shows for Dorking Sewage Treatment Works “In 2020 this sewer storm overflow spilled 118 times for a total of 2102 hours.”

We need to meet the needs of the existing population before building more housing and this plan does not address this point.

7.    Objections on the basis of the wellbeing of our population

Two issues will affect the wellbeing of our people

• Increased traffic means increased mental stress as we extend the time we spend getting anywhere. And that increased time in the car means reduced time with our families.
• This plan means building on green areas such as farm land. This is turn means:
  • Poorer air quality caused by the increase in pollution (from the larger population using more cars, more heating in the houses) and the reduction in plants absorbing CO2.
  • Less enjoyment – it’s proven that we benefit mentally from a green environment and this plan will reduce the amount of green areas.

 

 

You request for responders to state whether they wish to appear at the Local Plan Examination, but do not explain what this is or what it involves. Hence it is difficult to comment on this point, but I do wish to receive further details such that I can judge the importance and value to an involvement here.

 

Dr Mark R Dorn BSc MSc PhD CEng FIMechE

31^st October 2021