I would like to register my objections to the Mole Valley Local Plan ‘Future Mole Valley’ submitted for your approval by Mole Valley District Council.
It seems obvious to me that the world is facing what has been called by scientists to be a climate emergency where now more than ever we should be caring for the green spaces which provide the planet with clean air and openness and preserve nature and wildlife. To consider reducing the size of the green belt at this time seems to be utter madness when we should be looking for ways to increase its size not reduce it. If we, as a planet and a species, are going to survive then we must prevent any and all erosion to our green spaces no matter how compelling the reasons are for not doing so. We owe that much at least to our children and grandchildren to ensure they have somewhere habitable to live out their lives into their future.
The council have seen fit to re-designate 12.4 ha (30.64 acres) on the western edge of Dorking town from green belt land to former green belt/built up area. This re-designation has taken place despite an initial assessment of the land by MVDC as making a ‘moderate’ contribution to the green belt. They have applied subjective criteria in order to downgrade this assessment in two categories to making a ‘minimal’ contribution to the green belt thereby allowing the land to be re-classified. The initial classification carried out by MVDC was in itself very subjective and applied a heavy negative bias to its subsequent re-assessment paving the way for downgrading the assessment of the land.
The council have treated two distinctly separate areas as one in their initial assessment making it quite difficult to identify which area the comments in their assessment apply to.
Regarding ‘Sprawl.’
It is true to say that these two areas play a large part in restricting the sprawl of a large built up area, there is undoubtedly sporadic development in several areas but these developments are built in sympathy with the local surroundings and in no way detract from the green belt land surrounding them. It is not true to say that there are ‘a number of areas which are enclosed on three sides by existing well-established development’ and so it is not true to say that this would limit ‘the extent to which further development could be regarded as “unrestricted sprawl” of the urban area.’ Any building on this land will add to the urban sprawl of Dorking town and will have a negative impact on the areas beyond those two being considered.
Regarding ‘Merging.’
The only land separating the communities of Dorking and Westcott is a school playing field and Milton Heath. If these parcels of land are built on then there will be nothing separating the two communities and so merging of communities is a real danger in re-classifying these two areas.
Regarding ‘Encroachment.’
These two fields make an enormous contribution to the openness of the green belt both from the entrance to the town from the west and also to the views from both Ranmore and the Nower over the western edge of the town. It is true to say that the existing green belt boundary is well defined by physical features and so it follows that it does not require any amendment and should be re-categorised as making a ‘significant’ contribution to the green belt.
Regarding ‘Setting/Character.’
The assessment in this section recognises the important part these two parcels of land play in their contribution to the green belt. They are part of the Pipp Brook Valley and there are extensive views from the land rising to both the north and south of the town as well as over the Dorking Conservation Area. Both of these areas should be recognised for the part they play in the landscape of the local area and should be designated as both areas of outstanding natural beauty (AONB) and areas of great landscape value (AGLV) for the part they play in breaking up the built form of the western edge of the town. These two areas should be re-categorised under this heading as making a ‘significant’ contribution to the green belt.
In the ‘Exceptional Circumstances Assessment: 18-DK-003 – Land at Milton Court Lane, Dorking, RH4 3EQ Part 1(c). It is not true to say that this area has built development on three sides, it certainly has built developments around it but that can be said of the whole town in general. As previously stated it makes a major contribution to breaking up the hard boundary of the western edge of the town and adds significantly to the openness of the views from both Ranmore to the north and the Nower to the south. It also adds perspective to the entry to Dorking along the Westcott Road when travelling from the west. Any development on this site would add significantly to the harm to the green belt and so the answer in this category should have been NO and there should have been no further assessment past this point. All further discussion on this site within this appraisal is heavily biased towards suggesting that potential developers include mitigation measures to offset the damage that development on this site would have. Bear in mind that these are only suggestions to developers and will have no bearing on planning permission being granted if this area is taken out of the green belt and so therefore hold no substantive weight in this debate.
In the ‘Exceptional Circumstances Assessment: 18-DK-020 – Sondes Place Farm, Westcott Road, Dorking, RH4 3EF Part 1(b). The statement in this category is plainly untrue; it makes the grossly untrue assumption that “there is no significant impact on the green belt purposes.” It has already been stated that this area contributes to the openness of the western edge of the town and adds to the reduction of a ‘hard edge’ being constructed on this western boundary.
In Part 1(c). The comments fail to mention that this area performs moderately in its contribution to the green belt not only in sprawl, encroachment and merging but also setting and character, all four classification areas. Any building on this area would extend the western edge of the town towards the village of Westcott and so therefore would close the existing gap between Westcott and Dorking.
Part 2(d) this recognises the important part this parcel of land plays in being in the “foreground of the Dorking Conservation Area and from many parts of the higher land to the north west.” It also recognises the important part this parcel of land plays in breaking up the built up form of the town. It is not true to say that the existing developments are clearly visible, there is a range of tree cover and green spaces which hide most of these developments and they are unobtrusive in the existing views. Any development on this site WILL obviously adversely impact on the setting of the town as a whole, to say it will not is disingenuous and subjective. This section recognises the importance of the heritage assets in the form of the Sondes Place model farm buildings. These heritage assets will be lost to views from the west if any development is allowed in this area, no amount of mitigation measures stipulated at this point in the process will protect these assets from development.
In section (e) the document recognises that the main impacts on any development in this area would be an extension to the built form beyond the existing settlement boundary and an impact on openness and increased urban sprawl but it suggests that “This is ameliorated somewhat by the existing development on three sides.” This statement is untrue, there isn’t any development on three sides of this parcel of land, it is bounded in a limited way on it southern edge by small row of houses and open playing fields, it’s eastern boundary is enclosed by houses and there is a small encroachment in the north east corner identified earlier as the Sondes Place model farm buildings. The western edge is completely open being enclosed by school playing fields. It would be truer to say that it does form part of a wider open tract of countryside and there is not a close relationship with the surrounding urban form. This section also recognises the importance of the open boundary lined with lime trees but ignores the views this affords as an important factor in retaining this open space. It also ignores the fact that this parcel of land rises quite steeply to the east and so any development will be highly visible from the Westcott Road when travelling east. The suggestion that a “generous buffer of open land in the north of the site would further reduce the impact on the purposes of the green belt” is farcical, the land rises to the east and so therefore any buffer of land in the north of the site would not affect the perception that this development is a highly visible encroachment into the western edge of Dorking and its existing green belt nor would it reduce the perception of merging between Dorking and Westcott and would NOT safeguard the setting of Sondes Place model farm buildings. The “existing hedgerow” on the western boundary has been in place for many, many years, to suggest that this needs reinforcement as part of the justification for re-classification is ridiculous.
Section (f) recognises the negative impact on air quality a development on this site would bring. No proper assessment of the ecological and environmental impact has been made on this tract of land. Assessment is relying on desktop surveys and occasional visits by officers who walk the boundary at various times of day often missing the wildlife activity which residents already know takes place by various important species of insects, birds and animals. Over 30 years we have seen on an annual and regular basis Stag Beetles, Bats, Owls, Jays, Fieldfares, Long Tailed Tits, Robins, Finches, various species from the Tit family, Blackbirds, Kites and Hawks, Pheasants, and Partridge, Deer, Badgers, Foxes, Rabbits, Squirrels, Harvest Mice, Voles, Field Mice, Great White Snails, Toads, Newts, Grass Snakes, Dragon Flies and a great variety of insects, Moths, Butterflies and Caterpillars. It is undoubtedly an important wildlife habitat and wildlife corridor for a wide range of mammals, birds and insects as witnessed regularly by residents whose properties border the area. What the document fails to recognise is that any development on this site will have a major impact on light pollution. A lot of the wildlife is nocturnal in nature and will suffer catastrophically if this site is used for housing development.
Section (g) recognises that there are important views from both the north and south of the site in addition to the views from the Westcott Road but downplays the importance of these views by suggesting incorrectly that they are negatively affected by “substantial and prominent school buildings immediately to the south.” These school buildings are not set immediately to the south of this parcel of land but are set back and are very much low rise which does not impact on the views. I would also suggest that it is not true to say that the views from the south and east are predominately from neighbouring properties and the adjacent secondary school, anyone who has walked the Nower open space would appreciate the spectacular views available from this public open space. This area of land is not bounded on three sides as suggested throughout this submission, it is an open space bounded partially on its southern and north eastern edges and fully on its eastern edge, it is bounded on one side not three.
Section (k) says that “the site promoters highlight the potential to provide transport facilities to support the adjacent secondary school, comprising a drop-off area, staff parking and a pedestrian link into the school site.” The school is now reducing in size from 11-18 to 11-16 and so these extra facilities are not needed and this section should be removed from the document. A recent Transport Survey carried out by Surrey County Council highlighted the fact that very few pupils who attend this school travel from the west, the vast majority from the south and east. In order to reach these extra facilities highlighted by the site promoters and make the potential benefit suggested by them would involve adding to the already congested Vincent Lane and Westcott Road by forcing the traffic from the south and east onto the one-way system, thereby exacerbating the already grid locked town centre and then adding further to the congestion by requiring the traffic to use the one-way system yet again for their return journey.
In its summary the document once again states incorrectly that it is bounded on three sides, this is patently untrue and is used as a subjective judgement in order to justify the re-classification of this area. It also confuses the issue by stating that “Landscape concerns are mostly confined to close-range views.” It has already been recognised in this document that this area of land is a prominent feature of the views over Dorking from the north, Ranmore and Denbies and the south, the Nower. No proper survey to ascertain biodiversity has ever been carried out. There is absolutely no community benefit in the development of this site, in order to improve access to the adjacent secondary school the answer is not to divert the traffic away from the narrow streets into the already congested Vincent Lane and Westcott Road and in the light of the reduction in the size of the school, not necessary. To say that the harm to “openness” is limited is to ignore statements already made in the document about the contribution this area makes to the green belt and the views from both the north and the south.
This site does NOT “exhibit Exceptional Circumstances justifying an amendment to the Green Belt boundary.”
In the document dealing with the re-designation of both the Milton Court Farm area (18-DK-003) and Sondes Place Farm (18-DK-020) the performance of these areas is downgraded in 2 areas, merging and encroachment, this is totally unacceptable for the reasons outlined above. Under the heading of “Potential suitability for development” the document says “Transport evidence has been submitted considering capacity issues at the Westcott Road/Vincent Lane junction. Discussions with Surrey County Council Highways conclude that the West Dorking Developments (Land at Milton Court Lane and Sondes Place Farm) would not make a material difference to existing congestion in Dorking.” This whole statement defies belief, who in their right mind doesn’t understand the potential impact 250 new homes with possibly 500 extra vehicles will have on this already traffic heavy blackspot for congestion and its access onto Westcott Road and its impact on the already grid locked Vincent Lane. This typifies the support Surrey County Council have shown for the existing traffic problems in the town and its willingness to allow it to get even worse.
The inclusion of any reference to the incorporation and improvement of facilities for the local secondary school should be withdrawn. The school has recently reduced from an 11-18 to an 11-16 school and so have reduced their pupil numbers quite significantly. Any suggestion that development on these two sites would support the school should form no part of this submission. This was known quite clearly at the time this document was published and should have been withdrawn prior to publication, it is misleading and incorrect.
I would respectfully suggest that this document is denied. It contains very worrying subjective comments which at the very least will prove that some of the judgements made are unsound in their rationale and will lead to decisions being made which are based on biased conclusions. The protection of all green areas must be our priority, any removal of land from our precious green belt must be resisted if we are to stand any chance of tackling the climate emergency which we all face and will continue to face over the next few years. Removal of areas of the green belt will only hasten the downward spiral of climate change and quite simply present our children and grandchildren with even more of a problem than they already face.
In summary this document is full of half-truths, inaccuracies and subjective judgements based on little or no evidence and should be rejected.