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Runnymede Borough Council, for submissions. My contact details are all in the WORD letter attached....

Date post: 25-Mar-2018
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Page 1: Runnymede Borough Council, for submissions. My contact details are all in the WORD letter attached. But I will provide my telephone number here too, which …

Runnymede Borough Council Civic Centre Addlestone Surrey KT16 2AH

For the attention of the Plannin

Dear SirMadam

Runnymede 2030 Draft Local Plan

Planning Services H~lndon Crescent

Virginia Water 5

1 rrey GU25 4RF

I write in response to the proposals contained in the 2030 Runnymede draft Local Plan in respect of the Virginia Water ward and surrounding areas

I do not consider that the consultation process in relation to the draft Local Plan to be adequate or even fair given that you have given the public only 6 weeks within which to respond to such an important document

You will be aware that the Prime Minister the Secretary of State for Homes Communities and Local Government and the Housing Minister have all gone on record as saying that the Green Belt was safe in their hands and that all Local Authorities including RBC should only consider building on Green Belt land if all other options were exhausted

You will also be aware that national planning policy directs you to apply a policy of sustainable development which meets the needs for new housing but without depleting our natural resources including ancient woodland and our Open Spaces

You will further be aware that any proposed development site contained within your draft Local Plan must be sense-checked against the above requirements

Furthermore any development site must pay proper regard to any noise traffic and road infrastructure implications of that development before such development can even considered to be suitable

However I realise that there is a need for additional housing across England and therefore the reluctantly accept building of 2000 new homes at Longcross Garden Village as this development is already underway However as a resident of Virginia Water for 34 years I demand that adequate road safety is provided Currently Wellington Avenue and the junction of Harpesford Avenue is a death trap and a serious accident is just waiting to happen With an increase of around 2000 homes this traffic will obviously increase and it is imperative that traffic calming measures and traffic lights are installed This is required now at the junctions of Trumps Green Road and Wellington Avenue and Harpesford Avenue and Wellington Avenue

However I do reject the plan to build 120 houses at Virginia Water North and 130 houses at Virginia Water South in circumstances where there are existing legal building restrictions in place and where the existing road network could not cope

In respect of Virginia Water North there is no adequate protection of the Dell Ancient Woodland situated adjacent to the site

I ask Runnymede Borough Council and the Planning Inspector to consider further the impact on local traffic and facilities and feel that an additional 2000 homes at Longcross Garden Village is by far enough development for the area to cope with

I ask Runnymede Borough Council to acknowledge receipt of this letter and also to confirm that it will take into account my views and also ensure that this letter is placed before the Planning Inspector

Yours faithfully

FromTo Planning PolicySubject FW Objection to Runnymede Local Plan 2030Date 21 February 2018 165222Attachments Stephen R Miles Objection to Runnymede Local Plan 2030 at Feb 2018 Version 2doc

Sent 21 February 2018 1623To PlanningSubject Objection to Runnymede Local Plan 2030

Dear Planning Dept

Following my phone calls to Julie yesterday 20th February and today regardingdifficulties sending my objection via the Planning policy link (which is not working undermy version of Internet Explorer) I would be grateful if you would forward my objectionsto the Planning policy branch dealing with your local plan 2030 before tomorrowsdeadline for submissions My contact details are all in the WORD letter attached But Iwill provide my telephone number here too which is 01420 478845 in BordonHampshire

I frequently visit Chobham Common to study its wildlife and I am very concerned aboutits future when it is so close to the Longcross Garden Village development

Please could you ask your planning policy branch to provide me with an invitation to thePlanning Inspection where I will defend my statements against all relevant partiesincluding AECOM I have already had to do similar in East Hampshire so I am to someextent familiar with the process

Thank you for your kind help

Stephen Miles FRES

1885

Stephen R Miles

21st February 2018Sandown

Drift Road

srmilesbtinternetcomWhitehill BordonHampshire

wwwcountrysideexperienceorgukGU35 9DZ

01420 478845

Planning Policy and Strategy Team

Runnymede Borough Council

Civic Centre Station Road

Addlestone Surrey KT15 2AH

Objection to Runnymede Draft Local Plan 2030 The Town and Country Planning (Local Planning) (England) Regulations 2012 Regulation 19 ndash Publication of a Local Plan

INTRODUCTION

I object to this Local Plan as currently configured as it is not sound nor does it comply with Paragraph 118 of the National Policy Planning Framework (NPPF) as it fails to secure proper protection of the site of Chobham Common SSSI and itsrsquo wildlife as a part of the Thames Basin Heaths Special Protection Area from the disturbance by people as a result of the proposed construction of the so-called Longcross Garden village south of the M3 The Expression of Bid Interest Document produced by Runnymede BC in July 2016 as follows ldquoRunnymede 2035 Locally-Led Garden Villages Towns and Cities Longcross Garden Village (forming the 2016 proposed intentions that have now been firmed up in the Local Plan) at paragraph 18 states ldquoThe Borough contains a number of Suitable Alternative Natural Green Spaces (SANGS) to encourage walkers and dog walkers away from the SPArdquo Just ldquoencouragingrdquo walkers with dogs onto a SANG is not the mitigation that AECOM claims it to be in their respective versions of their Habitats Regulations Assessment and Appropriate Assessment of the Local Plan new residents must not go straight out onto Chobham Common if they do this no mitigation will have been established

Provision is not enough SANG use must be compulsory or at least the SANG should be the first and preferred option for the new residents for their exercise in this case otherwise given the proximity of the garden village to Chobham Common it will be damaged by the sheer numbers of new residents choosing for their well-being to walk or run or exercise on this site either on their own or with pet animals

The May and December 2017 versions of the HRA Screening and Appropriate Assessment Reports produced by AECOM providing the Appropriate Assessment Report Pursuant to Regulation 102 (1) of the Habitats Regulations 2010 amp 2017 (Habitats Regulations) on the Likely Significant Effects of Runnymede Borough Councilrsquos Local Plan 2035 Issues Options and Preferred Approaches Documents are also unacceptable I ask that the Planning Inspection due in 2018 determine that AECOMrsquos findings and screening out decisions in all of their various versions of Habitats Regulations Assessments and Appropriate Assessments should be declared as unsound and non-compliant I also ask as well that the Runnymede Local Plan 2030 is determined as non-compliant with the Conservation of Habitats and Species Regulations 2017 for the following reasons

AECOM which is an international pro-development company has failed to address properly the issue of disturbance to wildlife caused by peoplersquos recreation on Chobham Common SPA site as a consequence of the development proposals for the SLAA 99 site which proposes that dwellings are to be built within or close to the 400m buffer zone When developments are proposed to be built within the 400m buffer zone as identified in the Joint Strategic Partnership Boardrsquos Delivery Framework for the Thames Basin Heaths then measures similar to The Thames Basin Heaths Special Protection Area Avoidance Strategy Supplementary Planning Document (SPD) produced by Surrey Heath Borough Council are needed This document which was adopted by that Borough Councilrsquos Executive on 4th January 2012 and forms part of the Surrey Heath Local Development Framework 2011-2028 needs an equivalent within the Runnymede Local Plan AECOM who also authored the Runnymede BC Habitats Regulations Assessment version of June 2016 have chosen in this to ignore or degrade the evidence that clearly shows that ground nesting Annex 1 birds on the immediately adjacent areas of Chobham Common will be disturbed which will mean that favourable condition of the site is impossible to achieve or improve

Table 1 of AECOMrsquos December 2017 Assessment correctly states that the Chobham Common site qualifies as a Special Protection Area (SPA) because The site qualifies under article 41 of the Directive (79409EEC) as it is used regularly by 1 or more of the Great Britain populations of the following species listed in Annex 1 in any season

Caprimulgus europaeus European nightjar (Breeding)

Lullula arborea Woodlark (Breeding)

Sylvia undata Dartford warbler (Breeding)

and they correctly state that in paragraph 27 that the broad conservation objective as stated by Natural England is to ldquoAvoid the deterioration of the qualifying natural habitats and the habitats of qualifying species and the significant disturbance of those qualifying species ensuring the integrity of the site is maintained and the site makes a full contribution to achieving Favourable Conservation Status of each of the qualifying featuresrdquo

As I have said above the Runnymede Local Plan 2030 cannot guarantee that people will use the SANGS to be provided this provision forms the basis of AECOMrsquos determination that no disturbance to these birds will occur but their conclusions are wrong as Footprint Ecology stated in the following report Nature Conservation Representations to the Secretary of State with Regard to the Regional Spatial Strategy Proposed Changes on behalf of Purbeck District Council in c 2009 that ldquoOn the Thames Basin Heaths (where visitor pressure is higher than Dorset) nightjars demonstrate a general preference for areas away from access points and from site edges and there is a clear trend for nightjar density to decline with increasing visitor pressure and nightjars appearing to avoid areas of high disturbance within sitesrdquo The proposed Longcross Garden Village on the DERA South site (and the DERA North site already having planning permission) contained in the Runnymede Local Plan 2030 will increase dramatically the disturbance pressure potentially by 7000 extra people (1750 x 4 persons) having immediate and probably preferred access to Chobham Common SPA A better plan and solution to the disturbance problem is needed nothing AECOM has written improves this potentially bad situation

Consequently I am asking the Planning Inspector at the forthcoming public inspection to find the Runnymede 2030 Local Plan unsound as a consequence

This is for the following reasons

1 SLAA 99 the former DERA south site at Longcross Road (now Longcross Garden Village under policy SD10 in the final Runnymede 2030 Draft Local Plan dated January 2018) with a so-called indicative capacity of 1300 to 1725 dwellings because it is immediately adjacent to Chobham Common will be particularly damaging bringing unacceptable numbers of people and their pet animals (dogs and cats) in contact with the European SPA site and UK nationally designated Site of Special Scientific Interest of Chobham Common All three categories human beings dogs and cats as well as the associated urbanisation effects will damage this site particularly for the ground nesting birds for but also for many other species for which Chobham Common is included in the Thames Basin Heaths European designated Special Protection Area and internationally known

The scale of this development proposal is unacceptable and its proximity will cause serious damage to the SPA site

2 In their May 2017 version of the HRA Screening and Appropriate Assessment Report at paragraph 813 AECOM are wrong to say ldquoincreasing recreational pressure is thought to increase the exposure of Annex 1 birds to disturbancerdquo saying this clearly in my opinion suits their purposes as a pro-development company to never find fault with development proposals As English Nature the predecessor organisation of Natural England stated in 2006 ldquoRecreational pressure can have a significant adverse impact on the Annex 1 Bird species for which the SPA is designated as woodlark and nightjar are ground nesting and therefore sensitive to disturbance particularly from dogs Dartford Warblers nest close to the ground and are also susceptible to disturbance however they are more vulnerable to other effects of urbanisation in particular predation by catsrdquo (Stated in Thames Basin Heaths Special Protection Area Mitigation Standards for Residential Development dated 26 May 2006) It is loose and uncontrolled dogs that disturb ground nesting birds by forcing them to leave their nestschicks unattended allowing predatorrsquos access to predate and kill them

AECOM The Secretary of State for the Department of Homes and Communities (producers of the Application Guidance for so-called Garden Villages) The Ministry of Defence in the form of the Defence Infrastructure Organisation (as site owner) and Runnymede Borough Council are all wrong in knowingly promoting the Longcross Garden Village (SLAA 99 site) for residential development and for proposing just too many homes on it when it is immediately adjacent to Chobham Common and thus in a sensitive location to peoplersquos leisure activities

This site has already been damaged in recent years since Natural England determined that all National Nature Reserves should become ldquoaccessrdquo areas for people Consequently many of the bare soil tracks that previously supported insect species named in the original SSSI citation have been hard surfaced for people damaging populations of species like the Mottled Bee-fly With the DERA South proposals there is the very real danger that the whole Chobham Common site ends up being managed for peoplersquos leisure instead of itsrsquo special wildlife for which it is internationally designated Policies SD4 and especially SD10 by encouraging cycling on Chobham Common will be particularly damaging as this activity results in the continuous churning up of bare ground tracks and footpaths to the detriment of the invertebrates and sand lizards that nest in the bare sandy ground of lowland heathlands These species need the holes they dig as breeding sites to remain accessible each summer cycling by humans destroys this But of course AECOM do not know about this as they are not proper heathland ecologists

In AECOMrsquos paras 817 and 818 of the May 2017 HRA they are clearly ignoring the local geography with the Trumps Farm SANG site being only adjacent to the most easternmost housing of this DERA South development site For those dwellings proposed for the western and middle parts of this development site Chobham Common is immediately adjacent Nowhere in the documents provided by Runnymede Borough Council or AECOM or in paragraphs 818 or 819 is it explained what will cause new residents of the dwellings proposed to be built on the SLAA 99 site adjacent to Chobham Common to get into their cars to travel east for approximately 15 miles or nearly 2 kilometres away with their dogs to reach the proposed Trumpsrsquo Farm SANG Equally nor is it explained how roaming cats will be stopped from crossing the B386 and visiting Chobham Common when their homes are right next door or very close to the dry lowland heathland of Chobham Common Paragraph 835 of the AECOM AA informs us that the development site at DERA South will be as close as 280m to the SPA yet the nearest the proposed SANG to be used to divert new residents away from the SPA is over 1km to 15km to the east So I repeat how will this development stop the occupants from walking the shorter distance to take both themselves and their dogs or allow their roaming cats especially of a night via cat-flaps onto Chobham Common In their evidence to the Surrey Heath Borough Council Local Plan in 2011 RSPB pointed out that domestic cats may range beyond any 400m buffer that is set up so fencing of any on-site SANG provision as well as fencing in any adjacent housing built up to the 400m buffer and within at least half a mile distance from the start of the public access to the Chobham Common site at Ordnance Survey Grid Reference SU979651 is essential

Para 416 of AECOMrsquos AA states that ldquothe Delivery Framework continues to restrict all new residential development within an area some 400 metres from the boundary of the TBH SPArdquo If this is the case with SLAA 99 that housing will be kept at 400m from Chobham Common this is still too near because people will go the shorter distance and on sunny weather days as is promoted by so manyorganisations for peoplersquos well-being which is also mentioned in Section 6 under Supporting Local People and Health amp Wellbeing of the Local Plan Thus they will walk straight out onto Chobham Common adding to the high numbers of people already visiting this site and damaging it by their presence this is unacceptable

Noting AECOMrsquos paragraph 810 ldquoThe Thames Basin Heaths SPA is considered sensitive to the effects of recreational disturbance Natural England considers that the threat of development pressure particularly housing on neighbouring land and preferred sites within 5km results in increased recreational use of this site and has potential to disturb bird feeding and breeding behaviourrdquo These pathways to damage in AECOMrsquos so-called Appropriate Assessment are then conveniently screened out just because there is a Runnymede Policy to provide SANG as related to the TBH Delivery Framework The fact that Trumps Farm is in the wrong place to provide effective green space as mitigation in paragraphs863 to 868 of AECOMrsquos conclusions as an alternative for peoplersquos recreation with their dogs is wrong Also the effect of roaming cats is completely ignored by this organisation so that any cats present in the 1750 nearby proposed dwellings will be at liberty to kill the Annex 1 birds present on the adjoining Chobham Common as well as the reptiles and amphibians they encounter

The dictionary definition of mitigation is to alleviate diminish or moderate I cannot see how a mitigation site 15 kilometresrsquo away will provide proper mitigation when so many people are being toldto forsake their cars and to get out and exercise An on-site SANG must be provided at the west end of the DERA South site where the Longcross Barracks were and the Longcross Garden Village itself must be double fenced at itsrsquo boundary with the B386 road to exclude people and their animals from walking straight out onto Chobham Common if the development of SLAA 99 goes ahead as specified in the Local Plan A large on-site SANG will help reduce lighting spread and other urbanisation effects associated with this development and identified by AECOM elsewhere in their various HRAs for this Local Plan Any visible lighting on Chobham Common SPA will damage this site from their statements I am not sure this fact has registered with AECOMrsquos HRA writers

In the latest version of the AECOM HRA for the Runnymede Local Plan dated December 2017 and taking account of the Conservation of Habitats and Species Regulations 2017 one has to ask what has AECOM and all the promoters of Longcross Garden Village got to hide when the SANG site to divert residents away from the adjacent Chobham Common site within the Thames Basin Heaths SPA is not even mentioned Are Runnymede Borough Council providing a mitigation site or not The Conservation of Habitats and Species Regulations 2017 states in paragraph 63 (5) ldquoIn the light of the conclusions of the assessment and subject to regulation 64 the competent authority may agree to the plan or project only after having ascertained that it will not adversely affect the integrity of the European siterdquo If no named SANG site is to be provided than the competent authority Runnymede Borough Council cannot conclude that no damage will occur to the integrity of the Chobham Common site as a result of the approval of itsrsquo Local Plan in its current format

3 Natural England used to be a proper nature conservation organisation before 2010 before the previous coalition Government of David Cameron and particularly Owen Paterson when Secretary of State for

The Environment Food and Rural Affairs from 2012 ruined it and turned into another pro-development organisation negating itsrsquo roles via the 2012 statement that it could no longer campaign to objectively protect wildlife Itsrsquo role always was to shout loudly to protect wildlife and it should in my opinion now be recording objections to stop adverse developments such as SLAA 99 But with AECOMrsquos statement in paragraph 817 of the AECOM June 2016 HRA that Natural England already have an agreement with Crest Nicholson that a ldquowhole site SANG strategy has been agreedrdquo and that an ldquoadverse effect on the integrity on the Thames Basin Heaths would not ariserdquo subject to the delivery of the agreed SANGS shows Natural England has already been compromised in the negotiations Clearly there is a conflict with the statement in paragraph 817 in the summary ldquoLocating housing more than 400m from the SPA boundaryrdquo and para 835 which states that DERA South site is only 280m from the SPA boundary What is not clear from this early HRA and subsequent updated versions by AECOM is whether housing will be developed and established at a point of only 280m or less from the SPA boundary conforming to the boundary of the DERA South site or at the 400m buffer distance Which is it

It is clear that Natural Englandrsquos role in protecting Chobham Common has been compromised already they should be sticking to their 2006 position clearly if this development goes ahead referral to European Courts of Justice is necessary Already before BREXIT is completed the UK Government cannot be trusted to ensure our richest wildlife sites are protected when the same UK Government own ldquobrownfieldrdquo sites

such as DERA South adjacent to these SPA sites The HS2 in England proposals and the Gwent Levels development proposals for the M4 in Wales are already evidence of their despicable and cavalier record of damage to Sites of Special Scientific Interest Such damage is not acceptable I urge Runnymede Borough Council and the UK Government to think again about a different policy for this sensitive location of DERA South

4 Natural England should be putting Englandrsquos wildlife considerations first NOT the Governmentrsquos economic development initiatives I ask here that both DEFRA and Natural England intervene in this consultation and the subsequent inspection (as a consequence this objection will be sent to both of them) because the SLAA 99 development proposals and the so-called mitigation make a travesty of nature conservation and will only further damage the Chobham Common SSSI and its wildlife species

5 Clearly AECOMrsquos conclusion with regard to disturbance of the Annex 1 birds on Chobham Common in their paragraphs 863 and 868 of the May 2017 HRA and also in paragraphs 851 to 853 of the December 2017 version is wrong and seriously flawed because it fails to take in the proximity of the DERA South development to the SPA site of Chobham Common Also when the Trumps Farm SANG is over one mile distant and the originally proposed of a 55 hectare woodland SANG mentioned in paragraph 817 of the June 2016 HRA version does not fit to the Natural Englandrsquos preferred SANG size for a large development Nor is a woodland SANG normally safe for women walking alone with a dog the original preference for a SANG was that it should replicate the open nature of the heathland sitesrsquo the public like to use for dog-walking

Runnymede Borough Councilrsquos policy for the provision of SANG is not sufficient for it to work as mitigation it must be easier to get to and access the SANG than the adjoining SPA site and the Trumps Farm site fails in this provision Clearly Natural England and the UK Government are conveniently failing to understand what must be staring them in the face if they were honest that SLAA 99 development proposals will both damage and cause disturbance to the wildlife of Chobham Common As a part of the Thames Basin Heaths SPA and with an agreed Delivery Framework for SANGS in the Thames Basin Area if SLAA 99 is accepted in this Local Plan with the existing SANG proposals this will be unacceptable to me This will then form a part of a complaint to the European Commission as currently we are still subject to the judgements of the European Court of Justice

6 AECOMrsquos conclusions in paragraph 865 of the June 2016 HRA 868 of the May 2017 HRA and AA and lastly in paragraphs 851 to 853 of the December 2017 HRA and AA is what you expect from AECOM a complete disregard for the issues based on just a Council policy of the provision of SANG irrespective of itsrsquo location and proximity to the proposed development Equally as the Planning Inspectorate is under the same UK Government ldquocoshrdquo as Natural England to enable the provision of more housing for the so-called housing crisis It is not a shortage of housing that is evident in England it is a clear case of overpopulation with successive governments failing to govern and do anything about excessive breeding of the native human population and uncontrolled inward migration of human numbers into the UK particularly in southern England Before the next round of housing proposals in this area post 2030 the UK Government must act to reduce the excessive human population growth in the Runnymede area and the excessive expansion of the London region I can already see the claims for the forthcoming Planning Inspection and future ones probably by the Housebuilderrsquos Federation and the agents or QCs for the private housebuilding companies (a QC was employed by one developerrsquos agent for the East Hampshire Joint Core Strategy to argue for more housing to be achieved within that area and Local Plan) that people are more important than wildlife and that we must build on the SPAs or very close to them as in the current Runnymede Local Plan This failure to properly mitigate for the development of the so-called Longcross Garden Village is the start of the destruction of one of Britainrsquos best remaining lowland heathland sites A national disgrace

The SLAA 99 proposal and the proposals to remove land from the greenbelt in this Local Plan are as clear evidence of the overpressure of people numbers on the finite land resource of England (ldquoThe UKs population is projected to reach 70 million by 2030 ndash thatrsquos nine million more people than in 2008rdquo Ref Forum for the Future in 2010 ldquoUK population grows by over 400000 in the last year the largest absolute increase of any European countryrdquo Ref Population Mattersrsquo research in August 2013 ldquoEnglandrsquos population is already twice that of Germany per square mile and four times that of France It is our quality of life that is being affectedrdquo Ref Lord Horam speaking in February 2018 in the House of Lordrsquos debate on ldquoBrexit and the labour marketrdquo As the Planning Inspector stated at the commencement of the Inspection of the East Hampshire Joint Core Strategy that I was present at in 2013 ldquoI have been given a growth agendardquo With this type of pressure by the UK Government I am not sure that I or nature conservation can expect a fair and objective hearing in 2018 when I object to Runnymede Borough Councilrsquos Local Plan 2030 we will see

7 For the proximity of the DERA South development to the SPA site of Chobham Common there is one potential solution and that is to reduce the number of houses in the DERA South (Longcross Garden Village) proposal and to make a new large SANG out of the land at the western end of the DERA South site This would require the ldquoDuty of Cooperationrdquo to be observed as the extreme west end of the DERA South site as it is within the land area of Surrey Heath Borough Council but I am sure this could be achievable This area would have to be fenced with dense mesh topped with rolled razor wire or similar to prevent free roaming dogs and cats from going onto the Chobham Common site south of the M3 and B386 roads If this fence was sufficiently high and doubled up to make two fences these could be used to keep the public and their animals away from and out of the SPA of Chobham Common and also necessarily to confine the loose running dogs a requirement for SANGS from being run-over on the B386 and the other connecting roads

8 The SPD issued and adopted by Surrey Heath Borough Council states I paragraph 57 ldquoIn the period up to 2028 Surrey Heath is expected to grant planning permission for 324010 new homes and this will require the provision of over 60 hectares of SANG Major or large new developments will be expected to provide bespoke on-site SANG rather than relying on the suite of SANGs being developed by the Borough Councilrdquo SLAA 99 is a large development so it should lose some of its housing land to provide on-site SANG to separate itsrsquo housing provision from Chobham Common

Similarly for Runnymede a large amount of new homes will result from the conclusions of the Planning Inspection Almost certainly more than proposed at the moment (this was the experience in East Hampshire in 2013) In this case and similar to the proposals adopted for SLAA 97 SANG provision for SLAA 99 (which appears to be scheduled to provide the largest number of homes and something like 7000 extra people in Runnymede Borough) the SANG needs to be onsite and the solution I propose in this paragraph would cater for this Hoping new residents will all get in their cars to take the dog or cat for a walk over one mile away on Trumps Farm is not sustainable practicable or likely AECOMrsquos HRA and AA of both May and December 2017 completely fail to address the roaming catrsquos issue Despite AECOMrsquos clearly different point-of-view I do not believe that Runnymede Borough Council in their role as lsquocompetent authorityrsquo can conclude that no adverse effect on the integrity of internationally important wildlife sites of the Thames Basin Heathrsquos SPA will result from their proposals in their Local Plan 2030 as a consequence of what I consider are flawed conclusions proposed by AECOM The only light at the end of the tunnel of flawed conclusions in my opinion by AECOM is their final paragraph in the Dec 2017 HRA and AA that at paragraph 93 ldquoHowever it is recommended that the potential for further bespoke or strategic SANG later in the plan period is explored by the Council in time for Examination in Publicrdquo

I suggest to the Planning Inspector and Runnymede Borough Council that an on-site large SANG at the west end of the DERA South site should be provided as greenspace which would help to alleviate the potential for disturbance by residents of the new garden village from having to go or preferring to go to Chobham Common with the dog because this SANG site would be nearer Housing development adjacent to heathland always damages it especially if local arsonists are imported nearby but my proposals would go a long way to making the proposed Local Plan sound Though it would be far better if this garden village was scrapped and the DERA South site restored to heathland or just converted to another employment site as that would do far less damage to the Chobham Common SSSI and SPA site

____________________

Stephen R Miles21st February 2018

Page 2: Runnymede Borough Council, for submissions. My contact details are all in the WORD letter attached. But I will provide my telephone number here too, which …

In respect of Virginia Water North there is no adequate protection of the Dell Ancient Woodland situated adjacent to the site

I ask Runnymede Borough Council and the Planning Inspector to consider further the impact on local traffic and facilities and feel that an additional 2000 homes at Longcross Garden Village is by far enough development for the area to cope with

I ask Runnymede Borough Council to acknowledge receipt of this letter and also to confirm that it will take into account my views and also ensure that this letter is placed before the Planning Inspector

Yours faithfully

FromTo Planning PolicySubject FW Objection to Runnymede Local Plan 2030Date 21 February 2018 165222Attachments Stephen R Miles Objection to Runnymede Local Plan 2030 at Feb 2018 Version 2doc

Sent 21 February 2018 1623To PlanningSubject Objection to Runnymede Local Plan 2030

Dear Planning Dept

Following my phone calls to Julie yesterday 20th February and today regardingdifficulties sending my objection via the Planning policy link (which is not working undermy version of Internet Explorer) I would be grateful if you would forward my objectionsto the Planning policy branch dealing with your local plan 2030 before tomorrowsdeadline for submissions My contact details are all in the WORD letter attached But Iwill provide my telephone number here too which is 01420 478845 in BordonHampshire

I frequently visit Chobham Common to study its wildlife and I am very concerned aboutits future when it is so close to the Longcross Garden Village development

Please could you ask your planning policy branch to provide me with an invitation to thePlanning Inspection where I will defend my statements against all relevant partiesincluding AECOM I have already had to do similar in East Hampshire so I am to someextent familiar with the process

Thank you for your kind help

Stephen Miles FRES

1885

Stephen R Miles

21st February 2018Sandown

Drift Road

srmilesbtinternetcomWhitehill BordonHampshire

wwwcountrysideexperienceorgukGU35 9DZ

01420 478845

Planning Policy and Strategy Team

Runnymede Borough Council

Civic Centre Station Road

Addlestone Surrey KT15 2AH

Objection to Runnymede Draft Local Plan 2030 The Town and Country Planning (Local Planning) (England) Regulations 2012 Regulation 19 ndash Publication of a Local Plan

INTRODUCTION

I object to this Local Plan as currently configured as it is not sound nor does it comply with Paragraph 118 of the National Policy Planning Framework (NPPF) as it fails to secure proper protection of the site of Chobham Common SSSI and itsrsquo wildlife as a part of the Thames Basin Heaths Special Protection Area from the disturbance by people as a result of the proposed construction of the so-called Longcross Garden village south of the M3 The Expression of Bid Interest Document produced by Runnymede BC in July 2016 as follows ldquoRunnymede 2035 Locally-Led Garden Villages Towns and Cities Longcross Garden Village (forming the 2016 proposed intentions that have now been firmed up in the Local Plan) at paragraph 18 states ldquoThe Borough contains a number of Suitable Alternative Natural Green Spaces (SANGS) to encourage walkers and dog walkers away from the SPArdquo Just ldquoencouragingrdquo walkers with dogs onto a SANG is not the mitigation that AECOM claims it to be in their respective versions of their Habitats Regulations Assessment and Appropriate Assessment of the Local Plan new residents must not go straight out onto Chobham Common if they do this no mitigation will have been established

Provision is not enough SANG use must be compulsory or at least the SANG should be the first and preferred option for the new residents for their exercise in this case otherwise given the proximity of the garden village to Chobham Common it will be damaged by the sheer numbers of new residents choosing for their well-being to walk or run or exercise on this site either on their own or with pet animals

The May and December 2017 versions of the HRA Screening and Appropriate Assessment Reports produced by AECOM providing the Appropriate Assessment Report Pursuant to Regulation 102 (1) of the Habitats Regulations 2010 amp 2017 (Habitats Regulations) on the Likely Significant Effects of Runnymede Borough Councilrsquos Local Plan 2035 Issues Options and Preferred Approaches Documents are also unacceptable I ask that the Planning Inspection due in 2018 determine that AECOMrsquos findings and screening out decisions in all of their various versions of Habitats Regulations Assessments and Appropriate Assessments should be declared as unsound and non-compliant I also ask as well that the Runnymede Local Plan 2030 is determined as non-compliant with the Conservation of Habitats and Species Regulations 2017 for the following reasons

AECOM which is an international pro-development company has failed to address properly the issue of disturbance to wildlife caused by peoplersquos recreation on Chobham Common SPA site as a consequence of the development proposals for the SLAA 99 site which proposes that dwellings are to be built within or close to the 400m buffer zone When developments are proposed to be built within the 400m buffer zone as identified in the Joint Strategic Partnership Boardrsquos Delivery Framework for the Thames Basin Heaths then measures similar to The Thames Basin Heaths Special Protection Area Avoidance Strategy Supplementary Planning Document (SPD) produced by Surrey Heath Borough Council are needed This document which was adopted by that Borough Councilrsquos Executive on 4th January 2012 and forms part of the Surrey Heath Local Development Framework 2011-2028 needs an equivalent within the Runnymede Local Plan AECOM who also authored the Runnymede BC Habitats Regulations Assessment version of June 2016 have chosen in this to ignore or degrade the evidence that clearly shows that ground nesting Annex 1 birds on the immediately adjacent areas of Chobham Common will be disturbed which will mean that favourable condition of the site is impossible to achieve or improve

Table 1 of AECOMrsquos December 2017 Assessment correctly states that the Chobham Common site qualifies as a Special Protection Area (SPA) because The site qualifies under article 41 of the Directive (79409EEC) as it is used regularly by 1 or more of the Great Britain populations of the following species listed in Annex 1 in any season

Caprimulgus europaeus European nightjar (Breeding)

Lullula arborea Woodlark (Breeding)

Sylvia undata Dartford warbler (Breeding)

and they correctly state that in paragraph 27 that the broad conservation objective as stated by Natural England is to ldquoAvoid the deterioration of the qualifying natural habitats and the habitats of qualifying species and the significant disturbance of those qualifying species ensuring the integrity of the site is maintained and the site makes a full contribution to achieving Favourable Conservation Status of each of the qualifying featuresrdquo

As I have said above the Runnymede Local Plan 2030 cannot guarantee that people will use the SANGS to be provided this provision forms the basis of AECOMrsquos determination that no disturbance to these birds will occur but their conclusions are wrong as Footprint Ecology stated in the following report Nature Conservation Representations to the Secretary of State with Regard to the Regional Spatial Strategy Proposed Changes on behalf of Purbeck District Council in c 2009 that ldquoOn the Thames Basin Heaths (where visitor pressure is higher than Dorset) nightjars demonstrate a general preference for areas away from access points and from site edges and there is a clear trend for nightjar density to decline with increasing visitor pressure and nightjars appearing to avoid areas of high disturbance within sitesrdquo The proposed Longcross Garden Village on the DERA South site (and the DERA North site already having planning permission) contained in the Runnymede Local Plan 2030 will increase dramatically the disturbance pressure potentially by 7000 extra people (1750 x 4 persons) having immediate and probably preferred access to Chobham Common SPA A better plan and solution to the disturbance problem is needed nothing AECOM has written improves this potentially bad situation

Consequently I am asking the Planning Inspector at the forthcoming public inspection to find the Runnymede 2030 Local Plan unsound as a consequence

This is for the following reasons

1 SLAA 99 the former DERA south site at Longcross Road (now Longcross Garden Village under policy SD10 in the final Runnymede 2030 Draft Local Plan dated January 2018) with a so-called indicative capacity of 1300 to 1725 dwellings because it is immediately adjacent to Chobham Common will be particularly damaging bringing unacceptable numbers of people and their pet animals (dogs and cats) in contact with the European SPA site and UK nationally designated Site of Special Scientific Interest of Chobham Common All three categories human beings dogs and cats as well as the associated urbanisation effects will damage this site particularly for the ground nesting birds for but also for many other species for which Chobham Common is included in the Thames Basin Heaths European designated Special Protection Area and internationally known

The scale of this development proposal is unacceptable and its proximity will cause serious damage to the SPA site

2 In their May 2017 version of the HRA Screening and Appropriate Assessment Report at paragraph 813 AECOM are wrong to say ldquoincreasing recreational pressure is thought to increase the exposure of Annex 1 birds to disturbancerdquo saying this clearly in my opinion suits their purposes as a pro-development company to never find fault with development proposals As English Nature the predecessor organisation of Natural England stated in 2006 ldquoRecreational pressure can have a significant adverse impact on the Annex 1 Bird species for which the SPA is designated as woodlark and nightjar are ground nesting and therefore sensitive to disturbance particularly from dogs Dartford Warblers nest close to the ground and are also susceptible to disturbance however they are more vulnerable to other effects of urbanisation in particular predation by catsrdquo (Stated in Thames Basin Heaths Special Protection Area Mitigation Standards for Residential Development dated 26 May 2006) It is loose and uncontrolled dogs that disturb ground nesting birds by forcing them to leave their nestschicks unattended allowing predatorrsquos access to predate and kill them

AECOM The Secretary of State for the Department of Homes and Communities (producers of the Application Guidance for so-called Garden Villages) The Ministry of Defence in the form of the Defence Infrastructure Organisation (as site owner) and Runnymede Borough Council are all wrong in knowingly promoting the Longcross Garden Village (SLAA 99 site) for residential development and for proposing just too many homes on it when it is immediately adjacent to Chobham Common and thus in a sensitive location to peoplersquos leisure activities

This site has already been damaged in recent years since Natural England determined that all National Nature Reserves should become ldquoaccessrdquo areas for people Consequently many of the bare soil tracks that previously supported insect species named in the original SSSI citation have been hard surfaced for people damaging populations of species like the Mottled Bee-fly With the DERA South proposals there is the very real danger that the whole Chobham Common site ends up being managed for peoplersquos leisure instead of itsrsquo special wildlife for which it is internationally designated Policies SD4 and especially SD10 by encouraging cycling on Chobham Common will be particularly damaging as this activity results in the continuous churning up of bare ground tracks and footpaths to the detriment of the invertebrates and sand lizards that nest in the bare sandy ground of lowland heathlands These species need the holes they dig as breeding sites to remain accessible each summer cycling by humans destroys this But of course AECOM do not know about this as they are not proper heathland ecologists

In AECOMrsquos paras 817 and 818 of the May 2017 HRA they are clearly ignoring the local geography with the Trumps Farm SANG site being only adjacent to the most easternmost housing of this DERA South development site For those dwellings proposed for the western and middle parts of this development site Chobham Common is immediately adjacent Nowhere in the documents provided by Runnymede Borough Council or AECOM or in paragraphs 818 or 819 is it explained what will cause new residents of the dwellings proposed to be built on the SLAA 99 site adjacent to Chobham Common to get into their cars to travel east for approximately 15 miles or nearly 2 kilometres away with their dogs to reach the proposed Trumpsrsquo Farm SANG Equally nor is it explained how roaming cats will be stopped from crossing the B386 and visiting Chobham Common when their homes are right next door or very close to the dry lowland heathland of Chobham Common Paragraph 835 of the AECOM AA informs us that the development site at DERA South will be as close as 280m to the SPA yet the nearest the proposed SANG to be used to divert new residents away from the SPA is over 1km to 15km to the east So I repeat how will this development stop the occupants from walking the shorter distance to take both themselves and their dogs or allow their roaming cats especially of a night via cat-flaps onto Chobham Common In their evidence to the Surrey Heath Borough Council Local Plan in 2011 RSPB pointed out that domestic cats may range beyond any 400m buffer that is set up so fencing of any on-site SANG provision as well as fencing in any adjacent housing built up to the 400m buffer and within at least half a mile distance from the start of the public access to the Chobham Common site at Ordnance Survey Grid Reference SU979651 is essential

Para 416 of AECOMrsquos AA states that ldquothe Delivery Framework continues to restrict all new residential development within an area some 400 metres from the boundary of the TBH SPArdquo If this is the case with SLAA 99 that housing will be kept at 400m from Chobham Common this is still too near because people will go the shorter distance and on sunny weather days as is promoted by so manyorganisations for peoplersquos well-being which is also mentioned in Section 6 under Supporting Local People and Health amp Wellbeing of the Local Plan Thus they will walk straight out onto Chobham Common adding to the high numbers of people already visiting this site and damaging it by their presence this is unacceptable

Noting AECOMrsquos paragraph 810 ldquoThe Thames Basin Heaths SPA is considered sensitive to the effects of recreational disturbance Natural England considers that the threat of development pressure particularly housing on neighbouring land and preferred sites within 5km results in increased recreational use of this site and has potential to disturb bird feeding and breeding behaviourrdquo These pathways to damage in AECOMrsquos so-called Appropriate Assessment are then conveniently screened out just because there is a Runnymede Policy to provide SANG as related to the TBH Delivery Framework The fact that Trumps Farm is in the wrong place to provide effective green space as mitigation in paragraphs863 to 868 of AECOMrsquos conclusions as an alternative for peoplersquos recreation with their dogs is wrong Also the effect of roaming cats is completely ignored by this organisation so that any cats present in the 1750 nearby proposed dwellings will be at liberty to kill the Annex 1 birds present on the adjoining Chobham Common as well as the reptiles and amphibians they encounter

The dictionary definition of mitigation is to alleviate diminish or moderate I cannot see how a mitigation site 15 kilometresrsquo away will provide proper mitigation when so many people are being toldto forsake their cars and to get out and exercise An on-site SANG must be provided at the west end of the DERA South site where the Longcross Barracks were and the Longcross Garden Village itself must be double fenced at itsrsquo boundary with the B386 road to exclude people and their animals from walking straight out onto Chobham Common if the development of SLAA 99 goes ahead as specified in the Local Plan A large on-site SANG will help reduce lighting spread and other urbanisation effects associated with this development and identified by AECOM elsewhere in their various HRAs for this Local Plan Any visible lighting on Chobham Common SPA will damage this site from their statements I am not sure this fact has registered with AECOMrsquos HRA writers

In the latest version of the AECOM HRA for the Runnymede Local Plan dated December 2017 and taking account of the Conservation of Habitats and Species Regulations 2017 one has to ask what has AECOM and all the promoters of Longcross Garden Village got to hide when the SANG site to divert residents away from the adjacent Chobham Common site within the Thames Basin Heaths SPA is not even mentioned Are Runnymede Borough Council providing a mitigation site or not The Conservation of Habitats and Species Regulations 2017 states in paragraph 63 (5) ldquoIn the light of the conclusions of the assessment and subject to regulation 64 the competent authority may agree to the plan or project only after having ascertained that it will not adversely affect the integrity of the European siterdquo If no named SANG site is to be provided than the competent authority Runnymede Borough Council cannot conclude that no damage will occur to the integrity of the Chobham Common site as a result of the approval of itsrsquo Local Plan in its current format

3 Natural England used to be a proper nature conservation organisation before 2010 before the previous coalition Government of David Cameron and particularly Owen Paterson when Secretary of State for

The Environment Food and Rural Affairs from 2012 ruined it and turned into another pro-development organisation negating itsrsquo roles via the 2012 statement that it could no longer campaign to objectively protect wildlife Itsrsquo role always was to shout loudly to protect wildlife and it should in my opinion now be recording objections to stop adverse developments such as SLAA 99 But with AECOMrsquos statement in paragraph 817 of the AECOM June 2016 HRA that Natural England already have an agreement with Crest Nicholson that a ldquowhole site SANG strategy has been agreedrdquo and that an ldquoadverse effect on the integrity on the Thames Basin Heaths would not ariserdquo subject to the delivery of the agreed SANGS shows Natural England has already been compromised in the negotiations Clearly there is a conflict with the statement in paragraph 817 in the summary ldquoLocating housing more than 400m from the SPA boundaryrdquo and para 835 which states that DERA South site is only 280m from the SPA boundary What is not clear from this early HRA and subsequent updated versions by AECOM is whether housing will be developed and established at a point of only 280m or less from the SPA boundary conforming to the boundary of the DERA South site or at the 400m buffer distance Which is it

It is clear that Natural Englandrsquos role in protecting Chobham Common has been compromised already they should be sticking to their 2006 position clearly if this development goes ahead referral to European Courts of Justice is necessary Already before BREXIT is completed the UK Government cannot be trusted to ensure our richest wildlife sites are protected when the same UK Government own ldquobrownfieldrdquo sites

such as DERA South adjacent to these SPA sites The HS2 in England proposals and the Gwent Levels development proposals for the M4 in Wales are already evidence of their despicable and cavalier record of damage to Sites of Special Scientific Interest Such damage is not acceptable I urge Runnymede Borough Council and the UK Government to think again about a different policy for this sensitive location of DERA South

4 Natural England should be putting Englandrsquos wildlife considerations first NOT the Governmentrsquos economic development initiatives I ask here that both DEFRA and Natural England intervene in this consultation and the subsequent inspection (as a consequence this objection will be sent to both of them) because the SLAA 99 development proposals and the so-called mitigation make a travesty of nature conservation and will only further damage the Chobham Common SSSI and its wildlife species

5 Clearly AECOMrsquos conclusion with regard to disturbance of the Annex 1 birds on Chobham Common in their paragraphs 863 and 868 of the May 2017 HRA and also in paragraphs 851 to 853 of the December 2017 version is wrong and seriously flawed because it fails to take in the proximity of the DERA South development to the SPA site of Chobham Common Also when the Trumps Farm SANG is over one mile distant and the originally proposed of a 55 hectare woodland SANG mentioned in paragraph 817 of the June 2016 HRA version does not fit to the Natural Englandrsquos preferred SANG size for a large development Nor is a woodland SANG normally safe for women walking alone with a dog the original preference for a SANG was that it should replicate the open nature of the heathland sitesrsquo the public like to use for dog-walking

Runnymede Borough Councilrsquos policy for the provision of SANG is not sufficient for it to work as mitigation it must be easier to get to and access the SANG than the adjoining SPA site and the Trumps Farm site fails in this provision Clearly Natural England and the UK Government are conveniently failing to understand what must be staring them in the face if they were honest that SLAA 99 development proposals will both damage and cause disturbance to the wildlife of Chobham Common As a part of the Thames Basin Heaths SPA and with an agreed Delivery Framework for SANGS in the Thames Basin Area if SLAA 99 is accepted in this Local Plan with the existing SANG proposals this will be unacceptable to me This will then form a part of a complaint to the European Commission as currently we are still subject to the judgements of the European Court of Justice

6 AECOMrsquos conclusions in paragraph 865 of the June 2016 HRA 868 of the May 2017 HRA and AA and lastly in paragraphs 851 to 853 of the December 2017 HRA and AA is what you expect from AECOM a complete disregard for the issues based on just a Council policy of the provision of SANG irrespective of itsrsquo location and proximity to the proposed development Equally as the Planning Inspectorate is under the same UK Government ldquocoshrdquo as Natural England to enable the provision of more housing for the so-called housing crisis It is not a shortage of housing that is evident in England it is a clear case of overpopulation with successive governments failing to govern and do anything about excessive breeding of the native human population and uncontrolled inward migration of human numbers into the UK particularly in southern England Before the next round of housing proposals in this area post 2030 the UK Government must act to reduce the excessive human population growth in the Runnymede area and the excessive expansion of the London region I can already see the claims for the forthcoming Planning Inspection and future ones probably by the Housebuilderrsquos Federation and the agents or QCs for the private housebuilding companies (a QC was employed by one developerrsquos agent for the East Hampshire Joint Core Strategy to argue for more housing to be achieved within that area and Local Plan) that people are more important than wildlife and that we must build on the SPAs or very close to them as in the current Runnymede Local Plan This failure to properly mitigate for the development of the so-called Longcross Garden Village is the start of the destruction of one of Britainrsquos best remaining lowland heathland sites A national disgrace

The SLAA 99 proposal and the proposals to remove land from the greenbelt in this Local Plan are as clear evidence of the overpressure of people numbers on the finite land resource of England (ldquoThe UKs population is projected to reach 70 million by 2030 ndash thatrsquos nine million more people than in 2008rdquo Ref Forum for the Future in 2010 ldquoUK population grows by over 400000 in the last year the largest absolute increase of any European countryrdquo Ref Population Mattersrsquo research in August 2013 ldquoEnglandrsquos population is already twice that of Germany per square mile and four times that of France It is our quality of life that is being affectedrdquo Ref Lord Horam speaking in February 2018 in the House of Lordrsquos debate on ldquoBrexit and the labour marketrdquo As the Planning Inspector stated at the commencement of the Inspection of the East Hampshire Joint Core Strategy that I was present at in 2013 ldquoI have been given a growth agendardquo With this type of pressure by the UK Government I am not sure that I or nature conservation can expect a fair and objective hearing in 2018 when I object to Runnymede Borough Councilrsquos Local Plan 2030 we will see

7 For the proximity of the DERA South development to the SPA site of Chobham Common there is one potential solution and that is to reduce the number of houses in the DERA South (Longcross Garden Village) proposal and to make a new large SANG out of the land at the western end of the DERA South site This would require the ldquoDuty of Cooperationrdquo to be observed as the extreme west end of the DERA South site as it is within the land area of Surrey Heath Borough Council but I am sure this could be achievable This area would have to be fenced with dense mesh topped with rolled razor wire or similar to prevent free roaming dogs and cats from going onto the Chobham Common site south of the M3 and B386 roads If this fence was sufficiently high and doubled up to make two fences these could be used to keep the public and their animals away from and out of the SPA of Chobham Common and also necessarily to confine the loose running dogs a requirement for SANGS from being run-over on the B386 and the other connecting roads

8 The SPD issued and adopted by Surrey Heath Borough Council states I paragraph 57 ldquoIn the period up to 2028 Surrey Heath is expected to grant planning permission for 324010 new homes and this will require the provision of over 60 hectares of SANG Major or large new developments will be expected to provide bespoke on-site SANG rather than relying on the suite of SANGs being developed by the Borough Councilrdquo SLAA 99 is a large development so it should lose some of its housing land to provide on-site SANG to separate itsrsquo housing provision from Chobham Common

Similarly for Runnymede a large amount of new homes will result from the conclusions of the Planning Inspection Almost certainly more than proposed at the moment (this was the experience in East Hampshire in 2013) In this case and similar to the proposals adopted for SLAA 97 SANG provision for SLAA 99 (which appears to be scheduled to provide the largest number of homes and something like 7000 extra people in Runnymede Borough) the SANG needs to be onsite and the solution I propose in this paragraph would cater for this Hoping new residents will all get in their cars to take the dog or cat for a walk over one mile away on Trumps Farm is not sustainable practicable or likely AECOMrsquos HRA and AA of both May and December 2017 completely fail to address the roaming catrsquos issue Despite AECOMrsquos clearly different point-of-view I do not believe that Runnymede Borough Council in their role as lsquocompetent authorityrsquo can conclude that no adverse effect on the integrity of internationally important wildlife sites of the Thames Basin Heathrsquos SPA will result from their proposals in their Local Plan 2030 as a consequence of what I consider are flawed conclusions proposed by AECOM The only light at the end of the tunnel of flawed conclusions in my opinion by AECOM is their final paragraph in the Dec 2017 HRA and AA that at paragraph 93 ldquoHowever it is recommended that the potential for further bespoke or strategic SANG later in the plan period is explored by the Council in time for Examination in Publicrdquo

I suggest to the Planning Inspector and Runnymede Borough Council that an on-site large SANG at the west end of the DERA South site should be provided as greenspace which would help to alleviate the potential for disturbance by residents of the new garden village from having to go or preferring to go to Chobham Common with the dog because this SANG site would be nearer Housing development adjacent to heathland always damages it especially if local arsonists are imported nearby but my proposals would go a long way to making the proposed Local Plan sound Though it would be far better if this garden village was scrapped and the DERA South site restored to heathland or just converted to another employment site as that would do far less damage to the Chobham Common SSSI and SPA site

____________________

Stephen R Miles21st February 2018

Page 3: Runnymede Borough Council, for submissions. My contact details are all in the WORD letter attached. But I will provide my telephone number here too, which …

FromTo Planning PolicySubject FW Objection to Runnymede Local Plan 2030Date 21 February 2018 165222Attachments Stephen R Miles Objection to Runnymede Local Plan 2030 at Feb 2018 Version 2doc

Sent 21 February 2018 1623To PlanningSubject Objection to Runnymede Local Plan 2030

Dear Planning Dept

Following my phone calls to Julie yesterday 20th February and today regardingdifficulties sending my objection via the Planning policy link (which is not working undermy version of Internet Explorer) I would be grateful if you would forward my objectionsto the Planning policy branch dealing with your local plan 2030 before tomorrowsdeadline for submissions My contact details are all in the WORD letter attached But Iwill provide my telephone number here too which is 01420 478845 in BordonHampshire

I frequently visit Chobham Common to study its wildlife and I am very concerned aboutits future when it is so close to the Longcross Garden Village development

Please could you ask your planning policy branch to provide me with an invitation to thePlanning Inspection where I will defend my statements against all relevant partiesincluding AECOM I have already had to do similar in East Hampshire so I am to someextent familiar with the process

Thank you for your kind help

Stephen Miles FRES

1885

Stephen R Miles

21st February 2018Sandown

Drift Road

srmilesbtinternetcomWhitehill BordonHampshire

wwwcountrysideexperienceorgukGU35 9DZ

01420 478845

Planning Policy and Strategy Team

Runnymede Borough Council

Civic Centre Station Road

Addlestone Surrey KT15 2AH

Objection to Runnymede Draft Local Plan 2030 The Town and Country Planning (Local Planning) (England) Regulations 2012 Regulation 19 ndash Publication of a Local Plan

INTRODUCTION

I object to this Local Plan as currently configured as it is not sound nor does it comply with Paragraph 118 of the National Policy Planning Framework (NPPF) as it fails to secure proper protection of the site of Chobham Common SSSI and itsrsquo wildlife as a part of the Thames Basin Heaths Special Protection Area from the disturbance by people as a result of the proposed construction of the so-called Longcross Garden village south of the M3 The Expression of Bid Interest Document produced by Runnymede BC in July 2016 as follows ldquoRunnymede 2035 Locally-Led Garden Villages Towns and Cities Longcross Garden Village (forming the 2016 proposed intentions that have now been firmed up in the Local Plan) at paragraph 18 states ldquoThe Borough contains a number of Suitable Alternative Natural Green Spaces (SANGS) to encourage walkers and dog walkers away from the SPArdquo Just ldquoencouragingrdquo walkers with dogs onto a SANG is not the mitigation that AECOM claims it to be in their respective versions of their Habitats Regulations Assessment and Appropriate Assessment of the Local Plan new residents must not go straight out onto Chobham Common if they do this no mitigation will have been established

Provision is not enough SANG use must be compulsory or at least the SANG should be the first and preferred option for the new residents for their exercise in this case otherwise given the proximity of the garden village to Chobham Common it will be damaged by the sheer numbers of new residents choosing for their well-being to walk or run or exercise on this site either on their own or with pet animals

The May and December 2017 versions of the HRA Screening and Appropriate Assessment Reports produced by AECOM providing the Appropriate Assessment Report Pursuant to Regulation 102 (1) of the Habitats Regulations 2010 amp 2017 (Habitats Regulations) on the Likely Significant Effects of Runnymede Borough Councilrsquos Local Plan 2035 Issues Options and Preferred Approaches Documents are also unacceptable I ask that the Planning Inspection due in 2018 determine that AECOMrsquos findings and screening out decisions in all of their various versions of Habitats Regulations Assessments and Appropriate Assessments should be declared as unsound and non-compliant I also ask as well that the Runnymede Local Plan 2030 is determined as non-compliant with the Conservation of Habitats and Species Regulations 2017 for the following reasons

AECOM which is an international pro-development company has failed to address properly the issue of disturbance to wildlife caused by peoplersquos recreation on Chobham Common SPA site as a consequence of the development proposals for the SLAA 99 site which proposes that dwellings are to be built within or close to the 400m buffer zone When developments are proposed to be built within the 400m buffer zone as identified in the Joint Strategic Partnership Boardrsquos Delivery Framework for the Thames Basin Heaths then measures similar to The Thames Basin Heaths Special Protection Area Avoidance Strategy Supplementary Planning Document (SPD) produced by Surrey Heath Borough Council are needed This document which was adopted by that Borough Councilrsquos Executive on 4th January 2012 and forms part of the Surrey Heath Local Development Framework 2011-2028 needs an equivalent within the Runnymede Local Plan AECOM who also authored the Runnymede BC Habitats Regulations Assessment version of June 2016 have chosen in this to ignore or degrade the evidence that clearly shows that ground nesting Annex 1 birds on the immediately adjacent areas of Chobham Common will be disturbed which will mean that favourable condition of the site is impossible to achieve or improve

Table 1 of AECOMrsquos December 2017 Assessment correctly states that the Chobham Common site qualifies as a Special Protection Area (SPA) because The site qualifies under article 41 of the Directive (79409EEC) as it is used regularly by 1 or more of the Great Britain populations of the following species listed in Annex 1 in any season

Caprimulgus europaeus European nightjar (Breeding)

Lullula arborea Woodlark (Breeding)

Sylvia undata Dartford warbler (Breeding)

and they correctly state that in paragraph 27 that the broad conservation objective as stated by Natural England is to ldquoAvoid the deterioration of the qualifying natural habitats and the habitats of qualifying species and the significant disturbance of those qualifying species ensuring the integrity of the site is maintained and the site makes a full contribution to achieving Favourable Conservation Status of each of the qualifying featuresrdquo

As I have said above the Runnymede Local Plan 2030 cannot guarantee that people will use the SANGS to be provided this provision forms the basis of AECOMrsquos determination that no disturbance to these birds will occur but their conclusions are wrong as Footprint Ecology stated in the following report Nature Conservation Representations to the Secretary of State with Regard to the Regional Spatial Strategy Proposed Changes on behalf of Purbeck District Council in c 2009 that ldquoOn the Thames Basin Heaths (where visitor pressure is higher than Dorset) nightjars demonstrate a general preference for areas away from access points and from site edges and there is a clear trend for nightjar density to decline with increasing visitor pressure and nightjars appearing to avoid areas of high disturbance within sitesrdquo The proposed Longcross Garden Village on the DERA South site (and the DERA North site already having planning permission) contained in the Runnymede Local Plan 2030 will increase dramatically the disturbance pressure potentially by 7000 extra people (1750 x 4 persons) having immediate and probably preferred access to Chobham Common SPA A better plan and solution to the disturbance problem is needed nothing AECOM has written improves this potentially bad situation

Consequently I am asking the Planning Inspector at the forthcoming public inspection to find the Runnymede 2030 Local Plan unsound as a consequence

This is for the following reasons

1 SLAA 99 the former DERA south site at Longcross Road (now Longcross Garden Village under policy SD10 in the final Runnymede 2030 Draft Local Plan dated January 2018) with a so-called indicative capacity of 1300 to 1725 dwellings because it is immediately adjacent to Chobham Common will be particularly damaging bringing unacceptable numbers of people and their pet animals (dogs and cats) in contact with the European SPA site and UK nationally designated Site of Special Scientific Interest of Chobham Common All three categories human beings dogs and cats as well as the associated urbanisation effects will damage this site particularly for the ground nesting birds for but also for many other species for which Chobham Common is included in the Thames Basin Heaths European designated Special Protection Area and internationally known

The scale of this development proposal is unacceptable and its proximity will cause serious damage to the SPA site

2 In their May 2017 version of the HRA Screening and Appropriate Assessment Report at paragraph 813 AECOM are wrong to say ldquoincreasing recreational pressure is thought to increase the exposure of Annex 1 birds to disturbancerdquo saying this clearly in my opinion suits their purposes as a pro-development company to never find fault with development proposals As English Nature the predecessor organisation of Natural England stated in 2006 ldquoRecreational pressure can have a significant adverse impact on the Annex 1 Bird species for which the SPA is designated as woodlark and nightjar are ground nesting and therefore sensitive to disturbance particularly from dogs Dartford Warblers nest close to the ground and are also susceptible to disturbance however they are more vulnerable to other effects of urbanisation in particular predation by catsrdquo (Stated in Thames Basin Heaths Special Protection Area Mitigation Standards for Residential Development dated 26 May 2006) It is loose and uncontrolled dogs that disturb ground nesting birds by forcing them to leave their nestschicks unattended allowing predatorrsquos access to predate and kill them

AECOM The Secretary of State for the Department of Homes and Communities (producers of the Application Guidance for so-called Garden Villages) The Ministry of Defence in the form of the Defence Infrastructure Organisation (as site owner) and Runnymede Borough Council are all wrong in knowingly promoting the Longcross Garden Village (SLAA 99 site) for residential development and for proposing just too many homes on it when it is immediately adjacent to Chobham Common and thus in a sensitive location to peoplersquos leisure activities

This site has already been damaged in recent years since Natural England determined that all National Nature Reserves should become ldquoaccessrdquo areas for people Consequently many of the bare soil tracks that previously supported insect species named in the original SSSI citation have been hard surfaced for people damaging populations of species like the Mottled Bee-fly With the DERA South proposals there is the very real danger that the whole Chobham Common site ends up being managed for peoplersquos leisure instead of itsrsquo special wildlife for which it is internationally designated Policies SD4 and especially SD10 by encouraging cycling on Chobham Common will be particularly damaging as this activity results in the continuous churning up of bare ground tracks and footpaths to the detriment of the invertebrates and sand lizards that nest in the bare sandy ground of lowland heathlands These species need the holes they dig as breeding sites to remain accessible each summer cycling by humans destroys this But of course AECOM do not know about this as they are not proper heathland ecologists

In AECOMrsquos paras 817 and 818 of the May 2017 HRA they are clearly ignoring the local geography with the Trumps Farm SANG site being only adjacent to the most easternmost housing of this DERA South development site For those dwellings proposed for the western and middle parts of this development site Chobham Common is immediately adjacent Nowhere in the documents provided by Runnymede Borough Council or AECOM or in paragraphs 818 or 819 is it explained what will cause new residents of the dwellings proposed to be built on the SLAA 99 site adjacent to Chobham Common to get into their cars to travel east for approximately 15 miles or nearly 2 kilometres away with their dogs to reach the proposed Trumpsrsquo Farm SANG Equally nor is it explained how roaming cats will be stopped from crossing the B386 and visiting Chobham Common when their homes are right next door or very close to the dry lowland heathland of Chobham Common Paragraph 835 of the AECOM AA informs us that the development site at DERA South will be as close as 280m to the SPA yet the nearest the proposed SANG to be used to divert new residents away from the SPA is over 1km to 15km to the east So I repeat how will this development stop the occupants from walking the shorter distance to take both themselves and their dogs or allow their roaming cats especially of a night via cat-flaps onto Chobham Common In their evidence to the Surrey Heath Borough Council Local Plan in 2011 RSPB pointed out that domestic cats may range beyond any 400m buffer that is set up so fencing of any on-site SANG provision as well as fencing in any adjacent housing built up to the 400m buffer and within at least half a mile distance from the start of the public access to the Chobham Common site at Ordnance Survey Grid Reference SU979651 is essential

Para 416 of AECOMrsquos AA states that ldquothe Delivery Framework continues to restrict all new residential development within an area some 400 metres from the boundary of the TBH SPArdquo If this is the case with SLAA 99 that housing will be kept at 400m from Chobham Common this is still too near because people will go the shorter distance and on sunny weather days as is promoted by so manyorganisations for peoplersquos well-being which is also mentioned in Section 6 under Supporting Local People and Health amp Wellbeing of the Local Plan Thus they will walk straight out onto Chobham Common adding to the high numbers of people already visiting this site and damaging it by their presence this is unacceptable

Noting AECOMrsquos paragraph 810 ldquoThe Thames Basin Heaths SPA is considered sensitive to the effects of recreational disturbance Natural England considers that the threat of development pressure particularly housing on neighbouring land and preferred sites within 5km results in increased recreational use of this site and has potential to disturb bird feeding and breeding behaviourrdquo These pathways to damage in AECOMrsquos so-called Appropriate Assessment are then conveniently screened out just because there is a Runnymede Policy to provide SANG as related to the TBH Delivery Framework The fact that Trumps Farm is in the wrong place to provide effective green space as mitigation in paragraphs863 to 868 of AECOMrsquos conclusions as an alternative for peoplersquos recreation with their dogs is wrong Also the effect of roaming cats is completely ignored by this organisation so that any cats present in the 1750 nearby proposed dwellings will be at liberty to kill the Annex 1 birds present on the adjoining Chobham Common as well as the reptiles and amphibians they encounter

The dictionary definition of mitigation is to alleviate diminish or moderate I cannot see how a mitigation site 15 kilometresrsquo away will provide proper mitigation when so many people are being toldto forsake their cars and to get out and exercise An on-site SANG must be provided at the west end of the DERA South site where the Longcross Barracks were and the Longcross Garden Village itself must be double fenced at itsrsquo boundary with the B386 road to exclude people and their animals from walking straight out onto Chobham Common if the development of SLAA 99 goes ahead as specified in the Local Plan A large on-site SANG will help reduce lighting spread and other urbanisation effects associated with this development and identified by AECOM elsewhere in their various HRAs for this Local Plan Any visible lighting on Chobham Common SPA will damage this site from their statements I am not sure this fact has registered with AECOMrsquos HRA writers

In the latest version of the AECOM HRA for the Runnymede Local Plan dated December 2017 and taking account of the Conservation of Habitats and Species Regulations 2017 one has to ask what has AECOM and all the promoters of Longcross Garden Village got to hide when the SANG site to divert residents away from the adjacent Chobham Common site within the Thames Basin Heaths SPA is not even mentioned Are Runnymede Borough Council providing a mitigation site or not The Conservation of Habitats and Species Regulations 2017 states in paragraph 63 (5) ldquoIn the light of the conclusions of the assessment and subject to regulation 64 the competent authority may agree to the plan or project only after having ascertained that it will not adversely affect the integrity of the European siterdquo If no named SANG site is to be provided than the competent authority Runnymede Borough Council cannot conclude that no damage will occur to the integrity of the Chobham Common site as a result of the approval of itsrsquo Local Plan in its current format

3 Natural England used to be a proper nature conservation organisation before 2010 before the previous coalition Government of David Cameron and particularly Owen Paterson when Secretary of State for

The Environment Food and Rural Affairs from 2012 ruined it and turned into another pro-development organisation negating itsrsquo roles via the 2012 statement that it could no longer campaign to objectively protect wildlife Itsrsquo role always was to shout loudly to protect wildlife and it should in my opinion now be recording objections to stop adverse developments such as SLAA 99 But with AECOMrsquos statement in paragraph 817 of the AECOM June 2016 HRA that Natural England already have an agreement with Crest Nicholson that a ldquowhole site SANG strategy has been agreedrdquo and that an ldquoadverse effect on the integrity on the Thames Basin Heaths would not ariserdquo subject to the delivery of the agreed SANGS shows Natural England has already been compromised in the negotiations Clearly there is a conflict with the statement in paragraph 817 in the summary ldquoLocating housing more than 400m from the SPA boundaryrdquo and para 835 which states that DERA South site is only 280m from the SPA boundary What is not clear from this early HRA and subsequent updated versions by AECOM is whether housing will be developed and established at a point of only 280m or less from the SPA boundary conforming to the boundary of the DERA South site or at the 400m buffer distance Which is it

It is clear that Natural Englandrsquos role in protecting Chobham Common has been compromised already they should be sticking to their 2006 position clearly if this development goes ahead referral to European Courts of Justice is necessary Already before BREXIT is completed the UK Government cannot be trusted to ensure our richest wildlife sites are protected when the same UK Government own ldquobrownfieldrdquo sites

such as DERA South adjacent to these SPA sites The HS2 in England proposals and the Gwent Levels development proposals for the M4 in Wales are already evidence of their despicable and cavalier record of damage to Sites of Special Scientific Interest Such damage is not acceptable I urge Runnymede Borough Council and the UK Government to think again about a different policy for this sensitive location of DERA South

4 Natural England should be putting Englandrsquos wildlife considerations first NOT the Governmentrsquos economic development initiatives I ask here that both DEFRA and Natural England intervene in this consultation and the subsequent inspection (as a consequence this objection will be sent to both of them) because the SLAA 99 development proposals and the so-called mitigation make a travesty of nature conservation and will only further damage the Chobham Common SSSI and its wildlife species

5 Clearly AECOMrsquos conclusion with regard to disturbance of the Annex 1 birds on Chobham Common in their paragraphs 863 and 868 of the May 2017 HRA and also in paragraphs 851 to 853 of the December 2017 version is wrong and seriously flawed because it fails to take in the proximity of the DERA South development to the SPA site of Chobham Common Also when the Trumps Farm SANG is over one mile distant and the originally proposed of a 55 hectare woodland SANG mentioned in paragraph 817 of the June 2016 HRA version does not fit to the Natural Englandrsquos preferred SANG size for a large development Nor is a woodland SANG normally safe for women walking alone with a dog the original preference for a SANG was that it should replicate the open nature of the heathland sitesrsquo the public like to use for dog-walking

Runnymede Borough Councilrsquos policy for the provision of SANG is not sufficient for it to work as mitigation it must be easier to get to and access the SANG than the adjoining SPA site and the Trumps Farm site fails in this provision Clearly Natural England and the UK Government are conveniently failing to understand what must be staring them in the face if they were honest that SLAA 99 development proposals will both damage and cause disturbance to the wildlife of Chobham Common As a part of the Thames Basin Heaths SPA and with an agreed Delivery Framework for SANGS in the Thames Basin Area if SLAA 99 is accepted in this Local Plan with the existing SANG proposals this will be unacceptable to me This will then form a part of a complaint to the European Commission as currently we are still subject to the judgements of the European Court of Justice

6 AECOMrsquos conclusions in paragraph 865 of the June 2016 HRA 868 of the May 2017 HRA and AA and lastly in paragraphs 851 to 853 of the December 2017 HRA and AA is what you expect from AECOM a complete disregard for the issues based on just a Council policy of the provision of SANG irrespective of itsrsquo location and proximity to the proposed development Equally as the Planning Inspectorate is under the same UK Government ldquocoshrdquo as Natural England to enable the provision of more housing for the so-called housing crisis It is not a shortage of housing that is evident in England it is a clear case of overpopulation with successive governments failing to govern and do anything about excessive breeding of the native human population and uncontrolled inward migration of human numbers into the UK particularly in southern England Before the next round of housing proposals in this area post 2030 the UK Government must act to reduce the excessive human population growth in the Runnymede area and the excessive expansion of the London region I can already see the claims for the forthcoming Planning Inspection and future ones probably by the Housebuilderrsquos Federation and the agents or QCs for the private housebuilding companies (a QC was employed by one developerrsquos agent for the East Hampshire Joint Core Strategy to argue for more housing to be achieved within that area and Local Plan) that people are more important than wildlife and that we must build on the SPAs or very close to them as in the current Runnymede Local Plan This failure to properly mitigate for the development of the so-called Longcross Garden Village is the start of the destruction of one of Britainrsquos best remaining lowland heathland sites A national disgrace

The SLAA 99 proposal and the proposals to remove land from the greenbelt in this Local Plan are as clear evidence of the overpressure of people numbers on the finite land resource of England (ldquoThe UKs population is projected to reach 70 million by 2030 ndash thatrsquos nine million more people than in 2008rdquo Ref Forum for the Future in 2010 ldquoUK population grows by over 400000 in the last year the largest absolute increase of any European countryrdquo Ref Population Mattersrsquo research in August 2013 ldquoEnglandrsquos population is already twice that of Germany per square mile and four times that of France It is our quality of life that is being affectedrdquo Ref Lord Horam speaking in February 2018 in the House of Lordrsquos debate on ldquoBrexit and the labour marketrdquo As the Planning Inspector stated at the commencement of the Inspection of the East Hampshire Joint Core Strategy that I was present at in 2013 ldquoI have been given a growth agendardquo With this type of pressure by the UK Government I am not sure that I or nature conservation can expect a fair and objective hearing in 2018 when I object to Runnymede Borough Councilrsquos Local Plan 2030 we will see

7 For the proximity of the DERA South development to the SPA site of Chobham Common there is one potential solution and that is to reduce the number of houses in the DERA South (Longcross Garden Village) proposal and to make a new large SANG out of the land at the western end of the DERA South site This would require the ldquoDuty of Cooperationrdquo to be observed as the extreme west end of the DERA South site as it is within the land area of Surrey Heath Borough Council but I am sure this could be achievable This area would have to be fenced with dense mesh topped with rolled razor wire or similar to prevent free roaming dogs and cats from going onto the Chobham Common site south of the M3 and B386 roads If this fence was sufficiently high and doubled up to make two fences these could be used to keep the public and their animals away from and out of the SPA of Chobham Common and also necessarily to confine the loose running dogs a requirement for SANGS from being run-over on the B386 and the other connecting roads

8 The SPD issued and adopted by Surrey Heath Borough Council states I paragraph 57 ldquoIn the period up to 2028 Surrey Heath is expected to grant planning permission for 324010 new homes and this will require the provision of over 60 hectares of SANG Major or large new developments will be expected to provide bespoke on-site SANG rather than relying on the suite of SANGs being developed by the Borough Councilrdquo SLAA 99 is a large development so it should lose some of its housing land to provide on-site SANG to separate itsrsquo housing provision from Chobham Common

Similarly for Runnymede a large amount of new homes will result from the conclusions of the Planning Inspection Almost certainly more than proposed at the moment (this was the experience in East Hampshire in 2013) In this case and similar to the proposals adopted for SLAA 97 SANG provision for SLAA 99 (which appears to be scheduled to provide the largest number of homes and something like 7000 extra people in Runnymede Borough) the SANG needs to be onsite and the solution I propose in this paragraph would cater for this Hoping new residents will all get in their cars to take the dog or cat for a walk over one mile away on Trumps Farm is not sustainable practicable or likely AECOMrsquos HRA and AA of both May and December 2017 completely fail to address the roaming catrsquos issue Despite AECOMrsquos clearly different point-of-view I do not believe that Runnymede Borough Council in their role as lsquocompetent authorityrsquo can conclude that no adverse effect on the integrity of internationally important wildlife sites of the Thames Basin Heathrsquos SPA will result from their proposals in their Local Plan 2030 as a consequence of what I consider are flawed conclusions proposed by AECOM The only light at the end of the tunnel of flawed conclusions in my opinion by AECOM is their final paragraph in the Dec 2017 HRA and AA that at paragraph 93 ldquoHowever it is recommended that the potential for further bespoke or strategic SANG later in the plan period is explored by the Council in time for Examination in Publicrdquo

I suggest to the Planning Inspector and Runnymede Borough Council that an on-site large SANG at the west end of the DERA South site should be provided as greenspace which would help to alleviate the potential for disturbance by residents of the new garden village from having to go or preferring to go to Chobham Common with the dog because this SANG site would be nearer Housing development adjacent to heathland always damages it especially if local arsonists are imported nearby but my proposals would go a long way to making the proposed Local Plan sound Though it would be far better if this garden village was scrapped and the DERA South site restored to heathland or just converted to another employment site as that would do far less damage to the Chobham Common SSSI and SPA site

____________________

Stephen R Miles21st February 2018

Page 4: Runnymede Borough Council, for submissions. My contact details are all in the WORD letter attached. But I will provide my telephone number here too, which …

1

Stephen R Miles 21st February 2018 Sandown

Drift Road Whitehill Bordon

Hampshire GU35 9DZ

Planning Policy and Strategy Team Runnymede Borough Council Civic Centre Station Road Addlestone Surrey KT15 2AH

Objection to Runnymede Draft Local Plan 2030 The Town and Country Planning (Local Planning) (England) Regulations 2012 Regulation 19 ndash Publication of a Local Plan

INTRODUCTION

I object to this Local Plan as currently configured as it is not sound nor does it comply with Paragraph 118 of the National Policy Planning Framework (NPPF) as it fails to secure proper protection of the site of Chobham Common SSSI and itsrsquo wildlife as a part of the Thames Basin Heaths Special Protection Area from the disturbance by people as a result of the proposed construction of the so-called Longcross Garden village south of the M3 The Expression of Bid Interest Document produced by Runnymede BC in July 2016 as follows ldquoRunnymede 2035 Locally-Led Garden Villages Towns and Cities Longcross Garden Village (forming the 2016 proposed intentions that have now been firmed up in the Local Plan) at paragraph 18 states ldquoThe Borough contains a number of Suitable Alternative Natural Green Spaces (SANGS) to encourage walkers and dog walkers away from the SPArdquo Just ldquoencouragingrdquo walkers with dogs onto a SANG is not the mitigation that AECOM claims it to be in their respective versions of their Habitats Regulations Assessment and Appropriate Assessment of the Local Plan new residents must not go straight out onto Chobham Common if they do this no mitigation will have been established

Provision is not enough SANG use must be compulsory or at least the SANG should be the first and preferred option for the new residents for their exercise in this case otherwise given the proximity of the garden village to Chobham Common it will be damaged by the sheer numbers of new residents choosing for their well-being to walk or run or exercise on this site either on their own or with pet animals

The May and December 2017 versions of the HRA Screening and Appropriate Assessment Reports produced by AECOM providing the Appropriate Assessment Report Pursuant to Regulation 102 (1) of the Habitats Regulations 2010 amp 2017 (Habitats Regulations) on the Likely Significant Effects of Runnymede Borough Councilrsquos Local Plan 2035 Issues Options and Preferred Approaches Documents are also unacceptable I ask that the Planning

2

Inspection due in 2018 determine that AECOMrsquos findings and screening out decisions in all of their various versions of Habitats Regulations Assessments and Appropriate Assessments should be declared as unsound and non-compliant I also ask as well that the Runnymede Local Plan 2030 is determined as non-compliant with the Conservation of Habitats and Species Regulations 2017 for the following reasons

AECOM which is an international pro-development company has failed to address properly the issue of disturbance to wildlife caused by peoplersquos recreation on Chobham Common SPA site as a consequence of the development proposals for the SLAA 99 site which proposes that dwellings are to be built within or close to the 400m buffer zone When developments are proposed to be built within the 400m buffer zone as identified in the Joint Strategic Partnership Boardrsquos Delivery Framework for the Thames Basin Heaths then measures similar to The Thames Basin Heaths Special Protection Area Avoidance Strategy Supplementary Planning Document (SPD) produced by Surrey Heath Borough Council are needed This document which was adopted by that Borough Councilrsquos Executive on 4th January 2012 and forms part of the Surrey Heath Local Development Framework 2011-2028 needs an equivalent within the Runnymede Local Plan AECOM who also authored the Runnymede BC Habitats Regulations Assessment version of June 2016 have chosen in this to ignore or degrade the evidence that clearly shows that ground nesting Annex 1 birds on the immediately adjacent areas of Chobham Common will be disturbed which will mean that favourable condition of the site is impossible to achieve or improve

Table 1 of AECOMrsquos December 2017 Assessment correctly states that the Chobham Common site qualifies as a Special Protection Area (SPA) because The site qualifies under article 41 of the Directive (79409EEC) as it is used regularly by 1 or more of the Great Britain populations of the following species listed in Annex 1 in any season

Caprimulgus europaeus European nightjar (Breeding)

Lullula arborea Woodlark (Breeding)

Sylvia undata Dartford warbler (Breeding)

and they correctly state that in paragraph 27 that the broad conservation objective as stated by Natural England is to ldquoAvoid the deterioration of the qualifying natural habitats and the habitats of qualifying species and the significant disturbance of those qualifying species ensuring the integrity of the site is maintained and the site makes a full contribution to achieving Favourable Conservation Status of each of the qualifying featuresrdquo

As I have said above the Runnymede Local Plan 2030 cannot guarantee that people will use the SANGS to be provided this provision forms the basis of AECOMrsquos determination that no disturbance to these birds will occur but their conclusions are wrong as Footprint Ecology stated in the following report Nature Conservation Representations to the Secretary of State with Regard to the Regional Spatial Strategy Proposed Changes on behalf of Purbeck District Council in c 2009 that ldquoOn the Thames Basin Heaths (where

3

visitor pressure is higher than Dorset) nightjars demonstrate a general preference for areas away from access points and from site edges and there is a clear trend for nightjar density to decline with increasing visitor pressure and nightjars appearing to avoid areas of high disturbance within sitesrdquo The proposed Longcross Garden Village on the DERA South site (and the DERA North site already having planning permission) contained in the Runnymede Local Plan 2030 will increase dramatically the disturbance pressure potentially by 7000 extra people (1750 x 4 persons) having immediate and probably preferred access to Chobham Common SPA A better plan and solution to the disturbance problem is needed nothing AECOM has written improves this potentially bad situation

Consequently I am asking the Planning Inspector at the forthcoming public inspection to find the Runnymede 2030 Local Plan unsound as a consequence

This is for the following reasons

1 SLAA 99 the former DERA south site at Longcross Road (now Longcross Garden Village under policy SD10 in the final Runnymede 2030 Draft Local Plan dated January 2018) with a so-called indicative capacity of 1300 to 1725 dwellings because it is immediately adjacent to Chobham Common will be particularly damaging bringing unacceptable numbers of people and their pet animals (dogs and cats) in contact with the European SPA site and UK nationally designated Site of Special Scientific Interest of Chobham Common All three categories human beings dogs and cats as well as the associated urbanisation effects will damage this site particularly for the ground nesting birds for but also for many other species for which Chobham Common is included in the Thames Basin Heaths European designated Special Protection Area and internationally known

The scale of this development proposal is unacceptable and its proximity will cause serious damage to the SPA site

2 In their May 2017 version of the HRA Screening and Appropriate Assessment Report at paragraph 813 AECOM are wrong to say ldquoincreasing recreational pressure is thought to increase the exposure of Annex 1 birds to disturbancerdquo saying this clearly in my opinion suits their purposes as a pro-development company to never find fault with development proposals As English Nature the predecessor organisation of Natural England stated in 2006 ldquoRecreational pressure can have a significant adverse impact on the Annex 1 Bird species for which the SPA is designated as woodlark and nightjar are ground nesting and therefore sensitive to disturbance particularly from dogs Dartford Warblers nest

4

close to the ground and are also susceptible to disturbance however they are more vulnerable to other effects of urbanisation in particular predation by catsrdquo (Stated in Thames Basin Heaths Special Protection Area Mitigation Standards for Residential Development dated 26 May 2006) It is loose and uncontrolled dogs that disturb ground nesting birds by forcing them to leave their nestschicks unattended allowing predatorrsquos access to predate and kill them

AECOM The Secretary of State for the Department of Homes and Communities (producers of the Application Guidance for so-called Garden Villages) The Ministry of Defence in the form of the Defence Infrastructure Organisation (as site owner) and Runnymede Borough Council are all wrong in knowingly promoting the Longcross Garden Village (SLAA 99 site) for residential development and for proposing just too many homes on it when it is immediately adjacent to Chobham Common and thus in a sensitive location to peoplersquos leisure activities

This site has already been damaged in recent years since Natural England determined that all National Nature Reserves should become ldquoaccessrdquo areas for people Consequently many of the bare soil tracks that previously supported insect species named in the original SSSI citation have been hard surfaced for people damaging populations of species like the Mottled Bee-fly With the DERA South proposals there is the very real danger that the whole Chobham Common site ends up being managed for peoplersquos leisure instead of itsrsquo special wildlife for which it is internationally designated Policies SD4 and especially SD10 by encouraging cycling on Chobham Common will be particularly damaging as this activity results in the continuous churning up of bare ground tracks and footpaths to the detriment of the invertebrates and sand lizards that nest in the bare sandy ground of lowland heathlands These species need the holes they dig as breeding sites to remain accessible each summer cycling by humans destroys this But of course AECOM do not know about this as they are not proper heathland ecologists

In AECOMrsquos paras 817 and 818 of the May 2017 HRA they are clearly ignoring the local geography with the Trumps Farm SANG site being only adjacent to the most easternmost housing of this DERA South

5

development site For those dwellings proposed for the western and middle parts of this development site Chobham Common is immediately adjacent Nowhere in the documents provided by Runnymede Borough Council or AECOM or in paragraphs 818 or 819 is it explained what will cause new residents of the dwellings proposed to be built on the SLAA 99 site adjacent to Chobham Common to get into their cars to travel east for approximately 15 miles or nearly 2 kilometres away with their dogs to reach the proposed Trumpsrsquo Farm SANG Equally nor is it explained how roaming cats will be stopped from crossing the B386 and visiting Chobham Common when their homes are right next door or very close to the dry lowland heathland of Chobham Common Paragraph 835 of the AECOM AA informs us that the development site at DERA South will be as close as 280m to the SPA yet the nearest the proposed SANG to be used to divert new residents away from the SPA is over 1km to 15km to the east So I repeat how will this development stop the occupants from walking the shorter distance to take both themselves and their dogs or allow their roaming cats especially of a night via cat-flaps onto Chobham Common In their evidence to the Surrey Heath Borough Council Local Plan in 2011 RSPB pointed out that domestic cats may range beyond any 400m buffer that is set up so fencing of any on-site SANG provision as well as fencing in any adjacent housing built up to the 400m buffer and within at least half a mile distance from the start of the public access to the Chobham Common site at Ordnance Survey Grid Reference SU979651 is essential

Para 416 of AECOMrsquos AA states that ldquothe Delivery Framework continues to restrict all new residential development within an area some 400 metres from the boundary of the TBH SPArdquo If this is the case with SLAA 99 that housing will be kept at 400m from Chobham Common this is still too near because people will go the shorter distance and on sunny weather days as is promoted by so many organisations for peoplersquos well-being which is also mentioned in Section 6 under Supporting Local People and Health amp Wellbeing of the Local Plan Thus they will walk straight out onto Chobham Common adding to the high numbers of people already visiting this site and damaging it by their presence this is unacceptable

Noting AECOMrsquos paragraph 810 ldquoThe Thames Basin Heaths SPA is considered sensitive to the effects of recreational disturbance Natural England considers that the threat of development pressure particularly

6

housing on neighbouring land and preferred sites within 5km results in increased recreational use of this site and has potential to disturb bird feeding and breeding behaviourrdquo These pathways to damage in AECOMrsquos so-called Appropriate Assessment are then conveniently screened out just because there is a Runnymede Policy to provide SANG as related to the TBH Delivery Framework The fact that Trumps Farm is in the wrong place to provide effective green space as mitigation in paragraphs 863 to 868 of AECOMrsquos conclusions as an alternative for peoplersquos recreation with their dogs is wrong Also the effect of roaming cats is completely ignored by this organisation so that any cats present in the 1750 nearby proposed dwellings will be at liberty to kill the Annex 1 birds present on the adjoining Chobham Common as well as the reptiles and amphibians they encounter

The dictionary definition of mitigation is to alleviate diminish or moderate I cannot see how a mitigation site 15 kilometresrsquo away will provide proper mitigation when so many people are being told to forsake their cars and to get out and exercise An on-site SANG must be provided at the west end of the DERA South site where the Longcross Barracks were and the Longcross Garden Village itself must be double fenced at itsrsquo boundary with the B386 road to exclude people and their animals from walking straight out onto Chobham Common if the development of SLAA 99 goes ahead as specified in the Local Plan A large on-site SANG will help reduce lighting spread and other urbanisation effects associated with this development and identified by AECOM elsewhere in their various HRAs for this Local Plan Any visible lighting on Chobham Common SPA will damage this site from their statements I am not sure this fact has registered with AECOMrsquos HRA writers

In the latest version of the AECOM HRA for the Runnymede Local Plan dated December 2017 and taking account of the Conservation of Habitats and Species Regulations 2017 one has to ask what has AECOM and all the promoters of Longcross Garden Village got to hide when the SANG site to divert residents away from the adjacent Chobham Common site within the Thames Basin Heaths SPA is not even mentioned Are Runnymede Borough Council providing a mitigation site or not The Conservation of Habitats and Species Regulations 2017 states in paragraph 63 (5) ldquoIn the light of the conclusions of the assessment and subject to regulation 64 the competent authority may agree to the plan or project only after having ascertained that it will not adversely affect

7

the integrity of the European siterdquo If no named SANG site is to be provided than the competent authority Runnymede Borough Council cannot conclude that no damage will occur to the integrity of the Chobham Common site as a result of the approval of itsrsquo Local Plan in its current format

3 Natural England used to be a proper nature conservation organisation before 2010 before the previous coalition Government of David Cameron and particularly Owen Paterson when Secretary of State for The Environment Food and Rural Affairs from 2012 ruined it and turned into another pro-development organisation negating itsrsquo roles via the 2012 statement that it could no longer campaign to objectively protect wildlife Itsrsquo role always was to shout loudly to protect wildlife and it should in my opinion now be recording objections to stop adverse developments such as SLAA 99 But with AECOMrsquos statement in paragraph 817 of the AECOM June 2016 HRA that Natural England already have an agreement with Crest Nicholson that a ldquowhole site SANG strategy has been agreedrdquo and that an ldquoadverse effect on the integrity on the Thames Basin Heaths would not ariserdquo subject to the delivery of the agreed SANGS shows Natural England has already been compromised in the negotiations Clearly there is a conflict with the statement in paragraph 817 in the summary ldquoLocating housing more than 400m from the SPA boundaryrdquo and para 835 which states that DERA South site is only 280m from the SPA boundary What is not clear from this early HRA and subsequent updated versions by AECOM is whether housing will be developed and established at a point of only 280m or less from the SPA boundary conforming to the boundary of the DERA South site or at the 400m buffer distance Which is it

It is clear that Natural Englandrsquos role in protecting Chobham Common has been compromised already they should be sticking to their 2006 position clearly if this development goes ahead referral to European Courts of Justice is necessary Already before BREXIT is completed the UK Government cannot be trusted to ensure our richest wildlife sites are protected when the same UK Government own ldquobrownfieldrdquo sites such as DERA South adjacent to these SPA sites The HS2 in England proposals and the Gwent Levels development proposals for the M4 in Wales are already evidence of their despicable and cavalier record of

8

damage to Sites of Special Scientific Interest Such damage is not acceptable I urge Runnymede Borough Council and the UK Government to think again about a different policy for this sensitive location of DERA South

4 Natural England should be putting Englandrsquos wildlife considerations first NOT the Governmentrsquos economic development initiatives I ask here that both DEFRA and Natural England intervene in this consultation and the subsequent inspection (as a consequence this objection will be sent to both of them) because the SLAA 99 development proposals and the so-called mitigation make a travesty of nature conservation and will only further damage the Chobham Common SSSI and its wildlife species

5 Clearly AECOMrsquos conclusion with regard to disturbance of the Annex 1 birds on Chobham Common in their paragraphs 863 and 868 of the May 2017 HRA and also in paragraphs 851 to 853 of the December 2017 version is wrong and seriously flawed because it fails to take in the proximity of the DERA South development to the SPA site of Chobham Common Also when the Trumps Farm SANG is over one mile distant and the originally proposed of a 55 hectare woodland SANG mentioned in paragraph 817 of the June 2016 HRA version does not fit to the Natural Englandrsquos preferred SANG size for a large development Nor is a woodland SANG normally safe for women walking alone with a dog the original preference for a SANG was that it should replicate the open nature of the heathland sitesrsquo the public like to use for dog-walking

Runnymede Borough Councilrsquos policy for the provision of SANG is not sufficient for it to work as mitigation it must be easier to get to and access the SANG than the adjoining SPA site and the Trumps Farm site fails in this provision Clearly Natural England and the UK Government are conveniently failing to understand what must be staring them in the face if they were honest that SLAA 99 development proposals will both damage and cause disturbance to the wildlife of Chobham Common As a part of the Thames Basin Heaths SPA and with an agreed Delivery Framework for SANGS in the Thames Basin Area if SLAA 99 is accepted in this Local Plan with the existing SANG proposals this will be unacceptable to me This will then form a part of a complaint to the European Commission as currently we are still subject to the judgements of the European Court of Justice

9

6 AECOMrsquos conclusions in paragraph 865 of the June 2016 HRA 868 of the May 2017 HRA and AA and lastly in paragraphs 851 to 853 of the December 2017 HRA and AA is what you expect from AECOM a complete disregard for the issues based on just a Council policy of the provision of SANG irrespective of itsrsquo location and proximity to the proposed development Equally as the Planning Inspectorate is under the same UK Government ldquocoshrdquo as Natural England to enable the provision of more housing for the so-called housing crisis It is not a shortage of housing that is evident in England it is a clear case of overpopulation with successive governments failing to govern and do anything about excessive breeding of the native human population and uncontrolled inward migration of human numbers into the UK particularly in southern England Before the next round of housing proposals in this area post 2030 the UK Government must act to reduce the excessive human population growth in the Runnymede area and the excessive expansion of the London region I can already see the claims for the forthcoming Planning Inspection and future ones probably by the Housebuilderrsquos Federation and the agents or QCs for the private housebuilding companies (a QC was employed by one developerrsquos agent for the East Hampshire Joint Core Strategy to argue for more housing to be achieved within that area and Local Plan) that people are more important than wildlife and that we must build on the SPAs or very close to them as in the current Runnymede Local Plan This failure to properly mitigate for the development of the so-called Longcross Garden Village is the start of the destruction of one of Britainrsquos best remaining lowland heathland sites A national disgrace

The SLAA 99 proposal and the proposals to remove land from the greenbelt in this Local Plan are as clear evidence of the overpressure of people numbers on the finite land resource of England (ldquoThe UKs population is projected to reach 70 million by 2030 ndash thatrsquos nine million more people than in 2008rdquo Ref Forum for the Future in 2010 ldquoUK population grows by over 400000 in the last year the largest absolute increase of any European countryrdquo Ref Population Mattersrsquo research in August 2013 ldquoEnglandrsquos population is already twice that of Germany per square mile and four times that of France It is our quality of life that is being affectedrdquo Ref Lord Horam speaking in February 2018 in the House of Lordrsquos debate on ldquoBrexit and the labour marketrdquo As the Planning

10

Inspector stated at the commencement of the Inspection of the East Hampshire Joint Core Strategy that I was present at in 2013 ldquoI have been given a growth agendardquo With this type of pressure by the UK Government I am not sure that I or nature conservation can expect a fair and objective hearing in 2018 when I object to Runnymede Borough Councilrsquos Local Plan 2030 we will see

7 For the proximity of the DERA South development to the SPA site of Chobham Common there is one potential solution and that is to reduce the number of houses in the DERA South (Longcross Garden Village) proposal and to make a new large SANG out of the land at the western end of the DERA South site This would require the ldquoDuty of Cooperationrdquo to be observed as the extreme west end of the DERA South site as it is within the land area of Surrey Heath Borough Council but I am sure this could be achievable This area would have to be fenced with dense mesh topped with rolled razor wire or similar to prevent free roaming dogs and cats from going onto the Chobham Common site south of the M3 and B386 roads If this fence was sufficiently high and doubled up to make two fences these could be used to keep the public and their animals away from and out of the SPA of Chobham Common and also necessarily to confine the loose running dogs a requirement for SANGS from being run-over on the B386 and the other connecting roads

8 The SPD issued and adopted by Surrey Heath Borough Council states I paragraph 57 ldquoIn the period up to 2028 Surrey Heath is expected to grant planning permission for 324010 new homes and this will require the provision of over 60 hectares of SANG Major or large new developments will be expected to provide bespoke on-site SANG rather than relying on the suite of SANGs being developed by the Borough Councilrdquo SLAA 99 is a large development so it should lose some of its housing land to provide on-site SANG to separate itsrsquo housing provision from Chobham Common

Similarly for Runnymede a large amount of new homes will result from the conclusions of the Planning Inspection Almost certainly more than proposed at the moment (this was the experience in East Hampshire in 2013) In this case and similar to the proposals adopted for SLAA 97 SANG provision for SLAA 99 (which appears to be scheduled to provide

11

the largest number of homes and something like 7000 extra people in Runnymede Borough) the SANG needs to be onsite and the solution I propose in this paragraph would cater for this Hoping new residents will all get in their cars to take the dog or cat for a walk over one mile away on Trumps Farm is not sustainable practicable or likely AECOMrsquos HRA and AA of both May and December 2017 completely fail to address the roaming catrsquos issue Despite AECOMrsquos clearly different point-of-view I do not believe that Runnymede Borough Council in their role as lsquocompetent authorityrsquo can conclude that no adverse effect on the integrity of internationally important wildlife sites of the Thames Basin Heathrsquos SPA will result from their proposals in their Local Plan 2030 as a consequence of what I consider are flawed conclusions proposed by AECOM The only light at the end of the tunnel of flawed conclusions in my opinion by AECOM is their final paragraph in the Dec 2017 HRA and AA that at paragraph 93 ldquoHowever it is recommended that the potential for further bespoke or strategic SANG later in the plan period is explored by the Council in time for Examination in Publicrdquo

I suggest to the Planning Inspector and Runnymede Borough Council that an on-site large SANG at the west end of the DERA South site should be provided as greenspace which would help to alleviate the potential for disturbance by residents of the new garden village from having to go or preferring to go to Chobham Common with the dog because this SANG site would be nearer Housing development adjacent to heathland always damages it especially if local arsonists are imported nearby but my proposals would go a long way to making the proposed Local Plan sound Though it would be far better if this garden village was scrapped and the DERA South site restored to heathland or just converted to another employment site as that would do far less damage to the Chobham Common SSSI and SPA site

____________________

Stephen R Miles 21st February 2018

From Caroline CravenTo Planning PolicySubject Representation for Local PlanDate 22 February 2018 092519Attachments Representation_form_for_Regulation_19_Caroline_Cravendocx

Please find attached my representation form in response to the Runnymede 2030 Local PlanConsultation

Regards helliphellip Caroline Craven

1886

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full contact details of the agent in 2

Part B (1) ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

XParagraph PolicyPolicies Map

X

X

X

4 Do you consider the Local Plan is

x

4 (1) Legally compliant Yes No

X

4 (2) SoundYes No

x

4 (3) Complies with the Duty to co-operateYesNo

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the duty to co-operate please also use this box to set out your comments

I believe the Local Plan does not comply with the duty to co-operate with neighbouring Boroughs The previous version was not deemed to be compliant as I understand it and there does not appear to be any significant changes that allow this plan to be compliant

RBC seems to have relied on the former Statement of Community Involvement (SCI) of 2014 In a digital age 15 lines in a local (The Villager Feb 9th) on page 11 is a poor means of communication to the Runnymede Borough residents on something that will affect them so deeply

In addition the views expressed at the RBC meeting by the attending RBC councillors were essentially that they accepted it wasnrsquot as good as it should be but was lsquothe best wersquore going to get at the momentrsquo and if not submitted then a Government Inspector would be appointed and they would lose control ndash a view I can fully understand but does not give the Runnymede residents a feeling of confidence in the legality or the integrity of the plan nor that the council truly want the best for the Borough

With regard to the Longcross site improvements to the station do not address the capacity issue The impact to commuters further up the line will be significant Peak times will be heavily impacted If additional trains are being proposed on this line the impact to the residents of Egham who already have to wait some 35-40 minutes in the hour whilst gates are down would therefore have even less opportunity to transverse the line at the crossing points Longcross station has no accessible car parking or drop off points This would necessitate commuters travelling to Virginia Water Egham whose own parking capability is limited Virginia Water has lost a large number of station car park spaces due to a new development This would also cause increased congestion in already known problem junctions The additional burden to the A320 which is already operating over practical capacity at several junctions and expected to deteriorate over the coming years would be significant (A320 Corridor Study ndash Feasibility Study ndash Interim report February 2018)

(Continue on a separate sheetexpand box if necessary)

The Longcross site will also need medical facilities ndash GPrsquos and potentially NHS drop in centre to ensure the current burden on the NHS is not exacerbated

With regard to the Traveller pitches they appear to amount to 35 within the scope of the development areas However the council plan to deliver 131 net additional plotspitches ndash 96 of which are not covered in this local plan This is an extremely emotive subject and needs to be identified properly in the plan and not almost hidden to avoid confrontation with angry residents that this County is already over run with these communities Integration with new developments is not the answer ndash Allocation of Traveller sites and pitches is according to the Government guidelines ldquoinappropriate within the Green beltrdquo and trying to slide this surreptitiously into new developments is a totally inappropriate solution

The Hurst Lane development was dismissed by the Council despite the residents being on board and a sustainable and acceptable plan being put forward for c 800-1000 homes on 80 -100 acres Over time this Lane has deteriorated to the point that Planning Inspectors described it as an lsquoindustrial wastelandrsquo In addition the Council resources are being tied up with the numerous issues generated by the Lane and the inability to resolve with the resources available The primary reason given is that the land is lsquoGreen Beltrsquo although under exceptional circumstances (which I believe this would come under) the council are able to and plan to in other areas use this land It is effectively a brownfield site which could be permitted fi connected to a SANG trade off which the residents plan was

6 Please set out what modification (s) you consider necessary to make the Local Plan legally compliant or sound having regard to the Matter you have identified at 5 above where this relates to soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of modification at examination) You will need to say why this modification will make the Local Plan legally compliant or sound It will be helpful if you are able to put forward your suggested revised wording of any policy or text Please be as precise as possible

For the plan to be sound I believe that

1) Review the inclusion of the Hurst Lane site ndash SLAA 59 ndash within the plan Appendix B states the capacity of 10 for Hurst Lane and 5 for Padd Farm If this relates to additional properties the number does not reflect the plans of up to 800 houses Access and infrastructure are addressed and the reduction in headcount in the councilrsquos Customer Services (I believe there is a dedicated resource looking after Padd Farm Hurst Lane) would be an additional benefit

2) Greater publicity is required over the consultation process The council appear to work on a lsquopullrsquo basis in that residents of the borough (other than those in the Residents Associations) have to actively seek out any updates from the council Local newspapers are not a good way of disseminating information in the digital age

3) Identify the additional travellergypsy site plans and move outside of the Green Belt area

If these steps were taken the residents would all have ample opportunity to contribute to the development of the local plan

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further representations based on the original representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

7 If your representation is seeking a modification do you consider it necessary to participate at the oral part of the examination

No I do not wish to participate Yes I wish to participate

X

at the oral examinationat the oral examination

8 If you wish to participate at the oral part of the examination please outline why you consider this to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who have indicated that they wish to participate at the oral part of the examination

9 Signature Date

21st February 2018

Caroline Craven

Notes to Accompany Model Representation Form

1 Introduction

11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 2004[footnoteRef1] (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound [1 View at httpwwwlegislationgovukukpga20045contents ]

2 Legal Compliance and Duty to Co-operate

21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness

22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)[footnoteRef2] it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices [2 LDDs are defined in regulation 5 ndash see link below ]

bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications

bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)[footnoteRef3] On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified [3 View at httpwwwlegislationgovukuksi2012767contentsmade ]

bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy)

23 You should consider the following before making a representation on compliance with the duty to co-operate

bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty

bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

3 Soundness

31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy

bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development

bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence

bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities

bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF

32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations

bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included

bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan

bull If the policy is not covered elsewhere in what way is the plan unsound without the policy

bull If the plan is unsound without the policy what should the policy say

4 General advice

41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

6

image1png

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full contact details of the agent in 2

Title Mrs First Name Caroline Last Name Craven Job Title (where relevant)

Organisation (where relevant)

Address Line 1 Southover Line 2 Hurst Lane Line 3 Egham Line 4 Surrey Post Code TW20 8QJ Telephone Number Email Address (where relevant)

2

Part B (1) ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

XParagraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails to comply with the duty to co-operate Please be as precise as possible If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

X X X

x

X

x

I believe the Local Plan does not comply with the duty to co-operate with neighbouring Boroughs The previous version was not deemed to be compliant as I understand it and there does not appear to be any significant changes that allow this plan to be compliant

RBC seems to have relied on the former Statement of Community Involvement (SCI) of 2014 In a digital age 15 lines in a local (The Villager Feb 9th) on page 11 is a poor means of communication to the Runnymede Borough residents on something that will affect them so deeply

In addition the views expressed at the RBC meeting by the attending RBC councillors were essentially that they accepted it wasnrsquot as good as it should be but was lsquothe best wersquore going to get at the momentrsquo and if not submitted then a Government Inspector would be appointed and they would lose control ndash a view I can fully understand but does not give the Runnymede residents a feeling of confidence in the legality or the integrity of the plan nor that the council truly want the best for the Borough

With regard to the Longcross site improvements to the station do not address the capacity issue The impact to commuters further up the line will be significant Peak times will be heavily impacted If additional trains are being proposed on this line the impact to the residents of Egham who already have to wait some 35-40 minutes in the hour whilst gates are down would therefore have even less opportunity to transverse the line at the crossing points Longcross station has no accessible car parking or drop off points This would necessitate commuters travelling to Virginia Water Egham whose own parking capability is limited Virginia Water has lost a large number of station car park spaces due to a new development This would also cause increased congestion in already known problem junctions The additional burden to the A320 which is already operating over practical capacity at several junctions and expected to deteriorate over the coming years would be significant (A320 Corridor Study ndash Feasibility Study ndash Interim report February 2018)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally compliant or sound having regard to the Matter you have identified at 5 above where this relates to soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of modification at examination) You will need to say why this modification will make the Local Plan legally compliant or sound It will be helpful if you are able to put forward your suggested revised wording of any policy or text Please be as precise as possible

For the plan to be sound I believe that

1) Review the inclusion of the Hurst Lane site ndash SLAA 59 ndash within the plan Appendix B states the capacity of 10 for Hurst Lane and 5 for Padd Farm If this relates to additional properties the number does not reflect the plans of up to 800 houses Access and infrastructure are addressed and the reduction in headcount in the councilrsquos Customer Services (I believe there is a dedicated resource looking after Padd Farm Hurst Lane) would be an additional benefit

2) Greater publicity is required over the consultation process The council appear to work on a lsquopullrsquo basis in that residents of the borough (other than those in the Residents Associations) have to actively seek out any updates from the council Local newspapers are not a good way of disseminating information in the digital age

3) Identify the additional travellergypsy site plans and move outside of the Green Belt area

If these steps were taken the residents would all have ample opportunity to contribute to the development of the local plan

The Longcross site will also need medical facilities ndash GPrsquos and potentially NHS drop in centre to ensure the current burden on the NHS is not exacerbated

With regard to the Traveller pitches they appear to amount to 35 within the scope of the development areas However the council plan to deliver 131 net additional plotspitches ndash 96 of which are not covered in this local plan This is an extremely emotive subject and needs to be identified properly in the plan and not almost hidden to avoid confrontation with angry residents that this County is already over run with these communities Integration with new developments is not the answer ndash Allocation of Traveller sites and pitches is according to the Government guidelines ldquoinappropriate within the Green beltrdquo and trying to slide this surreptitiously into new developments is a totally inappropriate solution

The Hurst Lane development was dismissed by the Council despite the residents being on board and a sustainable and acceptable plan being put forward for c 800-1000 homes on 80 -100 acres Over time this Lane has deteriorated to the point that Planning Inspectors described it as an lsquoindustrial wastelandrsquo In addition the Council resources are being tied up with the numerous issues generated by the Lane and the inability to resolve with the resources available The primary reason given is that the land is lsquoGreen Beltrsquo although under exceptional circumstances (which I believe this would come under) the council are able to and plan to in other areas use this land It is effectively a brownfield site which could be permitted fi connected to a SANG trade off which the residents plan was

4

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further representations based on the original representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

7 If your representation is seeking a modification do you consider it necessary to participate at the oral part of the examination

No I do not wish to participate Yes I wish to participate at the oral examination at the oral examination

8 If you wish to participate at the oral part of the examination please outline why you consider this to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who have indicated that they wish to participate at the oral part of the examination

9 Signature Date

X

Caroline Craven 21st February 2018

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan 1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination 42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

FromPolicy

Subject FW New Housing Plans 2015-2030Date 21 February 2018 164919

Sent 21 February 2018 1608To PlanningSubject New Housing Plans 2015-2030

To

Policy Planning and Strategy Team

Runnymede Borough Council

Station Road

Addlestone

21022018

Dear Sirs

As an Ottershaw resident of nearly 30 years i would like you to read and take on board my objections to yourproposal to take land out of the green belt for housing and your plan to build so many houses in ourcommunity

Of course new houses have to be built right across the country now and in the future but i feel the plans youhave are for far too many houses The infrastructure of our community will just not sustain the extra amount ofpeople and cars and the general traffic that would entail

There are other possibilities available before your irreversible plans are put into action Are these possibilitiesbeing resourced

When i drive around the borough now and for a long long time i see so many empty office blocks Some ofthese have stood empty for yearsWhy has permission been given continuosly from what i can see on a huge scale for these to be built

This building of offices has to stop and the ones that have remained empty for years could be converted tohousing as in flats starter homes for young people

If Planning Practice Guidlines state that the use of Green Beltshould only occur in very special circumstances these and the Brownfield sites in Runnymede must be extensively researched

I live in Wilson Drive and for many years now when i leave my house to go into the village or elsewhere thereis often gridlock in every direction The roads in our community are so heavily used by cars and lorries headingtoward the M25 Can you imagine the impact so many more of these will bring Driving has not been a pleasurefor a long time and i do walk wherever possible Parking is a problem in the village as so many people use theone car park I believe there may be a plan in the pipeline to even get rid of that for road widening

We have a GP practice in the village that is getting harder to book an appointment for also i have been waitingmonths for an appointment at St Peters hospital and just keep getting apologetic letters

Quality of life is very important for your residents and that quality has already deteriorated lately

1888

In order to accomodate so many new residents you will be making the ones you have feel very disappointedand frustated that no one listens

There is no going back once the desicion has been made and so many houses built Please take my feelings and iam sure very many more residents comments and pleas into account before you make the irreversible decisionto go ahead with your plans

Yours Faithfully

Margaret Wensley and the Wensley family

Beechwood

Wilson Drive

Ottershaw

Surrey

KT16 0NT

----------- middotn==middot =

Planning Services

DELIVERED BY HAND

Runnymede Borough Council ~--------------=-middot ---------middot------~

Planning Dept Runnymede Borough Council Civic Offices Station Road Addlestone KT15 2AH

Dear Sirs

Catherine Brunton-Green 20The Glen Addlestone

KT151AQ

15th February 2018

Runnymede Draft local Plan 2015- 2030- Final Consultation

I have serious concerns in respect of this draft plan Runnymede Borough Council (RBC) have a duty of care to consult with listen and act upon the wishes of its residents There has been some consultation but this has not effectively reached all Runnymede residents Communication is unnecessarily legally complex and full of unexplained acronyms The basic Runnymede Voice delivered to every home has been abandoned There has been no flyer delivered to every home stating in a simplified way what is happening so that all abilities may be catered for Many people are isolated for numerous reasons and do not have internet access Neither is there evidence of full in depth cross boundary consultation with adjacent boroughs This local plan is driven primarily by a developers charter promoted by RBCS Head of Planning It is both unfair unjust and I question its soundness

The Strategic Housing Market Assessment has not taken leaving the EU into account and makes a blanket assumption on Heathrow expansion

I strongly object to the proposed loss of c 560 acres of Green Belt Our Prime Minister and government have recently stated that they are quote committed to protecting and enhancing our natural environment for successive generations therefore Green Belt land would only be lost as a last resort 11

bull Detailed evidence based research by The Council for The Protection of Rural England confirms that by fully utilising brownfield land 12 million homes could be built in London and the South East without the loss of any Green Belt

I have objection to building on the Veterinary Laboratory Green Belt Land Parcel BRow Town (Policy SL11 8283) is not justified for development This is designated for 150 additional dwellings and 2 gypsyTraveller pitches This site provides a natural demarcation between developments either side Designated SANG area is privately owned and not available The density of proposed build is unacceptable and above all an area of outstanding natural beauty would be destroyed

Our infrastructure is unable to cope at present A320 suffers perpetual gridlock now Equally gridlock is evidenced through Ottershaw Addlestone Station Road and A317 Addlestone Weybridge We already have unhealthily dangerous levels of roadside nitrogen dioxide concentrations in many areas such as Station Road RBC has made a lame submission in respect of

tackling roadside nitrogen dioxide concentrations in the South East (UK00310) Incidence of exacerbated breathing illnesses in this vicinity has increased dramatically in the past 7 years All age groups are affected

All GP surgeries across Runnymede have great difficulty in recruiting doctors Two practices in the immediate area are merging due to unprecedented numbers of doctors leaving and retiring Practice lists and capacity is stretched Patient access to services and patient safety has to be the highest priority Our schools are similarly affected

RBC infrastructure is totally reliant upon Surrey County Council who declare they are not in a financial position to fund the necessary support to develop the infrastructure for this Local Plan

I am prepared to speak at Public Enquiry

Yours faithfully

bull i I I bull bull

From Brian PickettTo Planning PolicySubject Runnymede 2030 Local Plan - submission of viewsDate 22 February 2018 090921Attachments Ottershaw development Objection letter February 2018docx

Please find attached the submission of my views on the Runnymede 2030 LocalPlan

Kind RegardsBrian Pickett

1891

planningrunnymedegovuk planningrunnymedegovuk

21022018

Re Runnymede 2030 Local Plan Ottershaw East ndash Objection to planning

Dear Sirs

We are writing to you again as we strongly object to the Runnymede Borough Councils plans to remove land behind houses along Brox Road known as lsquoOttershaw Eastrsquo from the Green Belt We are objecting for a number of reasons listed below

middot The Green Belt is precious once it is gone it is gone forever The removal of this land from the Green Belt does not comply with Planning Policy which states ldquothat Green Belt boundaries should only be altered in exceptional circumstancesrdquo there are no such circumstances that can justify the removal of this piece of land

middot The Green Belt should be an area that is preserved for future generations to enjoy and appreciate and many statements have been made by both the Government and members of Parliament on their commitment to protect the Green Belt ndash these statements now need to be converted into action in the Local Borough Plans The roll out of Green Belt to local councils in the 1950rsquos was to prevent urban sprawl and the merging of settlements thereby helping to preserve and protect the character of communities it encompassed protect the country setting and encourage development through regeneration of sites within towns and cities not villages

middot The description of Ottershaw by the council itself in the lsquoUrban Characteristicsrsquo publication on the Runnymede Borough Council website states ldquoOttershaw has its own identity and sense of place which is partly derived from the clearly identifiable heart of the urban area focused on The Otter and adjoining local shopping parade and community facilities as well as being surrounded by open greenbelt countryside Removing this green belt that is part of the identifiable heart of Ottershaw would destroy this villagersquos identity and community

middot The planning proposals and building on this part of the green belt land would lead to a considerable population increase in the village Services and facilities will struggle or fail to cope space is already limited at the doctorrsquos surgery and school places are at capacity The transport infrastructure is already stretched with limited bus services busy roads poorly maintained pavements and road surfaces Brox road is already used as a shortcut to avoid traffic congestion Given that Ottershaw does not have a train station it is reasonable to assume that the majority of houses would have at least one car the added traffic from the new development would put a severe strain on the road network and users Available information on mitigation is very vague and very open to interpretation and misguided assumptions

middot The Green Belt land is a habitat to an array of plants and animals including important pollinator species and larger animals such as birds foxes and deer There should be no assumption that animals will simply move to another area habitats are established over many years and this development will be another loss to the maintenance of biodiversity I enjoy the fauna and flora in these areas going for walks along the public footpaths Having such wonderful access to a relaxing escape so close to home is priceless and something I hold dear to myself my family and community What is now a beautiful scenic view will become a spoilt urban sprawl of modern housing

middot I moved to Ottershaw with my wife in 2016 to settle down and start a family The relaxed quiet village sense of community and safety surrounded by beautiful countryside were its appeal I are very concerned and disappointed that this planning proposal is still being considered which will undoubtedly destroy this idyllic setting

There are no ldquoexceptional or very special circumstancesrdquo that justify the removal of Ottershaw East from the Green Belt We trust that the Council will therefore not remove ldquoOttershaw Eastrdquo and ldquoThe Fieldrdquo from the Green Belt

Yours faithfully

Dr Brian Pickett

To Policy Planning and Strategy Team Runnymede Borough Council Civic Centre Station Road Addlestone Surrey KT15 2AH planningrunnymedegovuk

From Dr Brian Pickett 139 Brox Road Ottershaw Surrey KT16 0LG planningrunnymedegovuk

21022018 Re Runnymede 2030 Local Plan Ottershaw East ndash Objection to planning Dear Sirs We are writing to you again as we strongly object to the Runnymede Borough Councils plans to remove land behind houses along Brox Road known as lsquoOttershaw Eastrsquo from the Green Belt We are objecting for a number of reasons listed below bull The Green Belt is precious once it is gone it is gone forever The removal of this

land from the Green Belt does not comply with Planning Policy which states ldquothat Green Belt boundaries should only be altered in exceptional circumstancesrdquo there are no such circumstances that can justify the removal of this piece of land

bull The Green Belt should be an area that is preserved for future generations to enjoy

and appreciate and many statements have been made by both the Government and members of Parliament on their commitment to protect the Green Belt ndash these statements now need to be converted into action in the Local Borough Plans The roll out of Green Belt to local councils in the 1950rsquos was to prevent urban sprawl and the merging of settlements thereby helping to preserve and protect the character of communities it encompassed protect the country setting and encourage development through regeneration of sites within towns and cities not villages

bull The description of Ottershaw by the council itself in the lsquoUrban Characteristicsrsquo

publication on the Runnymede Borough Council website states ldquoOttershaw has its own identity and sense of place which is partly derived from the clearly identifiable heart of the urban area focused on The Otter and adjoining local shopping parade and community facilities as well as being surrounded by open greenbelt countryside Removing this green belt that is part of the identifiable heart of Ottershaw would destroy this villagersquos identity and community

bull The planning proposals and building on this part of the green belt land would lead

to a considerable population increase in the village Services and facilities will struggle or fail to cope space is already limited at the doctorrsquos surgery and school places are at capacity The transport infrastructure is already stretched with limited bus services busy roads poorly maintained pavements and road surfaces Brox road is already used as a shortcut to avoid traffic congestion Given that Ottershaw does not have a train station it is reasonable to assume that the majority of houses would have at least one car the added traffic from the new development would put a severe strain on the road network and users Available information on mitigation is very vague and very open to interpretation and misguided assumptions

bull The Green Belt land is a habitat to an array of plants and animals including important pollinator species and larger animals such as birds foxes and deer There should be no assumption that animals will simply move to another area habitats are established over many years and this development will be another loss to the maintenance of biodiversity I enjoy the fauna and flora in these areas going for walks along the public footpaths Having such wonderful access to a relaxing escape so close to home is priceless and something I hold dear to myself my family and community What is now a beautiful scenic view will become a spoilt urban sprawl of modern housing

bull I moved to Ottershaw with my wife in 2016 to settle down and start a family The

relaxed quiet village sense of community and safety surrounded by beautiful countryside were its appeal I are very concerned and disappointed that this planning proposal is still being considered which will undoubtedly destroy this idyllic setting

There are no ldquoexceptional or very special circumstancesrdquo that justify the removal of Ottershaw East from the Green Belt We trust that the Council will therefore not remove ldquoOttershaw Eastrdquo and ldquoThe Fieldrdquo from the Green Belt Yours faithfully Dr Brian Pickett

FromTo Planning PolicySubject Runnymede Local Plan 2030 - consultation responseDate 21 February 2018 163608Attachments Runnymede LP Response - EE15pdf

Please find attached a consultation response form

________________________________________Christian Leigh BSc(Hons) MPhil MRTPIDirectorLeigh amp Glennie Ltd6 All Souls RoadAscotBerkshire SL5 9EA

1893

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number 01344 297094 Email Address (where relevant)

mailchristianleighcouk

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number Email Address (where relevant)

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

From MCNAB DouglasTo Planning PolicySubject Runnymede Draft Local Plan consultation - Representation from Education and Skills Funding AgencyDate 21 February 2018 091407Attachments Runnymede Reg 19 response ESFADOC

Dear Runnymede Planning Policy Team

Please see attached a representation from the Education and Skills Funding Agency on theRunnymede Local Plan consultation

I would be grateful if you could confirm receipt

Best regardsDoug

Douglas McNab MRTPIForward Planning Manager ndash South East

Planning Team Free Schools CapitalEducation and Skills Funding AgencyDepartment for Education 5th floor Sanctuary Buildings 20 Great Smith Street London SW1P 3BT

Email douglasmcnabeducationgovukMobile 07990 082877Web wwwgovukesfa

1895

image1pngOur Ref ESFALocal PlanRunnymede 2018 21st February 2018

Dear SirMadam

Re Runnymede Local Plan

Consultation under Regulation 19 of Town and Country Planning (Local Planning) (England) Regulations 2012

Submission of the Education and Skills Funding Agency

1 The Education and Skills Funding Agency (ESFA) welcomes the opportunity to contribute to the development of planning policy at the local level

2 The ESFA launched on 1st April 2017 bringing together the existing responsibilities of the Education Funding Agency (EFA) and the Skills Funding Agency (SFA) to create a single funding agency accountable for funding education and training for children young people and adults The ESFA are accountable for pound61 billion of funding a year for the education and training sector including support for all state-provided education for 8 million children aged 3 to 16 and 16 million young people aged 16 to 19

3 Under the provisions of the Education Act 2011 and the Academies Act 2010 all new state schools are now academiesfree schools and the ESFA is the delivery body for many of these rather than local education authorities As such we aim to work closely with local authority education departments and planning authorities to meet the demand for new school places and new schools We do this through a variety of means including by supporting the adoption of sound local plan policies site allocations and guidance (all based on robust evidence) that facilitate the delivery of education infrastructure where and when it is needed and maximise developer contributions for schools In this capacity we would like to offer the following comments in response to the proposals outlined in the above consultation document

Comments on the Local Plan

4 As you will be aware the primary focus at this stage of the Local Planrsquos preparation is on the soundness of the plan with regard to it being positively prepared justified effective and consistent with national policy The following detailed comments set out the ESFArsquos view of the planrsquos soundness in respect of education provision

5 The ESFA notes that the local plan will make provision for a minimum of 7413 net additional dwellings over the plan period Development will generally complement the existing settlement pattern focusing the largest amounts of residential growth primarily in Chertsey (1950 homes) Addlestone (936 homes) and Egham (812 homes) A new ldquolocally led garden villagerdquo is also proposed at Longcross providing a further 1718 homes This level of development will put pressure on existing education infrastructure

6 The plan recognises that ldquoIt is important that infrastructure is delivered in a timely manner to ensure that the needs of the occupiers of new development can be met without placing undue burdens on existing infrastructure facilities and servicesrdquo (para 560) The ESFA supports Policy SD6 Infrastructure Provision amp Timing particularly the signposting of the Infrastructure Delivery Plan (IDP) and the need for development to deliver this either on-site or through s106 or CIL financial contributions off-site and the need for development to be phased in line with the provision of important supporting infrastructure

7 The latest version of the IDP states that there is an ongoing programme of primary school expansions this will help to meet the forecast need for 4-6FE of new capacity over the plan period The need for one new build school project is identified a 2FE primary school at the Longcross Garden Village (estimated cost pound99M to pound15M) this is referred to in the site allocation policies (see below) With respect to secondary school places it is anticipated that up to six additional FE could be required in the Borough by 2021 Additional places will be delivered through the new 6FE Runnymede Free School (which opened in temporary accommodation in 2017) development of additional FE within Salesian School (Catholic faith school) and expansion of another school in the Chertsey area (to accommodate demand from generated by the Longcross Garden Village site)

8 It would be useful if the background data informing these projections of need could be clarified particularly the pupil yield factors used and the evidence base supporting this This would help to demonstrate more clearly to the Inspector that the approach to the planning and delivery of education infrastructure has been positively prepared based on a strategy which seeks to meet objectively assessed infrastructure requirements and is justified based on proportionate evidence The ESFA notes that the Runnymede S106 SPG sets out pupil yield figures however this document dates from December 2007 so the figures may be outdated

9 The ESFA supports the Councilrsquos allocation and safeguarding of land for schools as set out in the following policies

middot Policy SD10 Longcross Garden Village - 2FE primary school with preschoolearly years settings

middot Policy SL2 to SL18 ndash series of housing allocation policies that highlight the need to make a financial contribution to early years primary and secondary school infrastructure ldquoeither through S106 or CIL (or its successor)rdquo

Developer Contributions and CIL

10 One of the tests of soundness is that a Local Plan is lsquoeffectiversquo ie the plan should be deliverable over its period In this context and with specific regard to planning for schools there is a need to ensure that education contributions made by developers are sufficient to deliver the additional school places required to meet the increase in demand generated by new developments The ESFA notes that the council has not adopted CIL and that the Planning Obligations SPG sets out how developer contributions to education provision will be secured via section 106 agreements The ESFA supports the Councilrsquos approach to ensure developer contributions address the impacts arising from growth However the ESFA recommends that the Local Plan includes a commitment to revise the Planning Obligations SPG in line with the latest evidence of the boroughrsquos infrastructure needs pupil yields and build costs (including the cost of school expansion new build and SEN provision) Any such review should be prepared in consultation with the county council as local education authority This will help to ensure appropriate rates are levied and the right infrastructure is secured across the borough

11 The ESFA would be particularly interested in responding to any update to the Infrastructure Delivery Plan or review of infrastructure requirements As such please add the ESFA to the database for future CIL consultations

Forward funding

12 In light of the proposed Longcross Garden Village emerging ESFA proposals for forward funding schools as part of large residential developments may be relevant for example if viability becomes an issue The ESFA aims to be able to clarify forward funding options for schools in 2018 We would be happy to meet to discuss this opportunity further once the options have been finalised and ifwhen relevant Any offer of forward funding would seek to maximise developer contributions to education infrastructure provision while supporting delivery of schools where and when they are needed

Conclusion

13 Finally I hope the above comments are helpful in finalising the Runnymede Local Plan with specific regard to the provision of land for new schools

14 Please notify the ESFA when the Local Plan is submitted for examination the Inspectorrsquos report is published and the Local Plan is adopted

15 Please do not hesitate to contact me if you have any queries regarding this response The ESFA looks forward to continuing to work with Runnymede Borough Council to develop a sound Local Plan that will aid in the delivery of new schools

Yours faithfully

DC McNab

Douglas McNab MRTPI

Forward Planning Manager

Tel 07990 082877

Email

douglasmcnabeducationgovuk

Web

wwwgovuk esfa

Education and Skills Funding Agency13

Department for EducationSanctuary BuildingsGreat Smith StreetLondonSW1P 3BT13

13

Tel 0207 340 700013

13

wwwgovukesfa13

13

13

To

Policy Planning and Strategy Team

Runnymede Borough Council

Civic Centre

Station Road

Addlestone

Surrey

KT15 2AH

From

Dr Brian Pickett

139 Brox Road

Ottershaw

Surrey

KT16 0LG

Title

Mrs

First Name

Caroline

Last Name

Craven

Job Title

(where relevant)

Organisation

(where relevant)

Address Line 1

Southover

Line 2

Hurst Lane

Line 3

Egham

Line 4

Surrey

Post Code

TW20 8QJ

Telephone Number

07770999572

Email Address

(where relevant)

Carolinecraven911hotmailcom

Page 5: Runnymede Borough Council, for submissions. My contact details are all in the WORD letter attached. But I will provide my telephone number here too, which …

2

Inspection due in 2018 determine that AECOMrsquos findings and screening out decisions in all of their various versions of Habitats Regulations Assessments and Appropriate Assessments should be declared as unsound and non-compliant I also ask as well that the Runnymede Local Plan 2030 is determined as non-compliant with the Conservation of Habitats and Species Regulations 2017 for the following reasons

AECOM which is an international pro-development company has failed to address properly the issue of disturbance to wildlife caused by peoplersquos recreation on Chobham Common SPA site as a consequence of the development proposals for the SLAA 99 site which proposes that dwellings are to be built within or close to the 400m buffer zone When developments are proposed to be built within the 400m buffer zone as identified in the Joint Strategic Partnership Boardrsquos Delivery Framework for the Thames Basin Heaths then measures similar to The Thames Basin Heaths Special Protection Area Avoidance Strategy Supplementary Planning Document (SPD) produced by Surrey Heath Borough Council are needed This document which was adopted by that Borough Councilrsquos Executive on 4th January 2012 and forms part of the Surrey Heath Local Development Framework 2011-2028 needs an equivalent within the Runnymede Local Plan AECOM who also authored the Runnymede BC Habitats Regulations Assessment version of June 2016 have chosen in this to ignore or degrade the evidence that clearly shows that ground nesting Annex 1 birds on the immediately adjacent areas of Chobham Common will be disturbed which will mean that favourable condition of the site is impossible to achieve or improve

Table 1 of AECOMrsquos December 2017 Assessment correctly states that the Chobham Common site qualifies as a Special Protection Area (SPA) because The site qualifies under article 41 of the Directive (79409EEC) as it is used regularly by 1 or more of the Great Britain populations of the following species listed in Annex 1 in any season

Caprimulgus europaeus European nightjar (Breeding)

Lullula arborea Woodlark (Breeding)

Sylvia undata Dartford warbler (Breeding)

and they correctly state that in paragraph 27 that the broad conservation objective as stated by Natural England is to ldquoAvoid the deterioration of the qualifying natural habitats and the habitats of qualifying species and the significant disturbance of those qualifying species ensuring the integrity of the site is maintained and the site makes a full contribution to achieving Favourable Conservation Status of each of the qualifying featuresrdquo

As I have said above the Runnymede Local Plan 2030 cannot guarantee that people will use the SANGS to be provided this provision forms the basis of AECOMrsquos determination that no disturbance to these birds will occur but their conclusions are wrong as Footprint Ecology stated in the following report Nature Conservation Representations to the Secretary of State with Regard to the Regional Spatial Strategy Proposed Changes on behalf of Purbeck District Council in c 2009 that ldquoOn the Thames Basin Heaths (where

3

visitor pressure is higher than Dorset) nightjars demonstrate a general preference for areas away from access points and from site edges and there is a clear trend for nightjar density to decline with increasing visitor pressure and nightjars appearing to avoid areas of high disturbance within sitesrdquo The proposed Longcross Garden Village on the DERA South site (and the DERA North site already having planning permission) contained in the Runnymede Local Plan 2030 will increase dramatically the disturbance pressure potentially by 7000 extra people (1750 x 4 persons) having immediate and probably preferred access to Chobham Common SPA A better plan and solution to the disturbance problem is needed nothing AECOM has written improves this potentially bad situation

Consequently I am asking the Planning Inspector at the forthcoming public inspection to find the Runnymede 2030 Local Plan unsound as a consequence

This is for the following reasons

1 SLAA 99 the former DERA south site at Longcross Road (now Longcross Garden Village under policy SD10 in the final Runnymede 2030 Draft Local Plan dated January 2018) with a so-called indicative capacity of 1300 to 1725 dwellings because it is immediately adjacent to Chobham Common will be particularly damaging bringing unacceptable numbers of people and their pet animals (dogs and cats) in contact with the European SPA site and UK nationally designated Site of Special Scientific Interest of Chobham Common All three categories human beings dogs and cats as well as the associated urbanisation effects will damage this site particularly for the ground nesting birds for but also for many other species for which Chobham Common is included in the Thames Basin Heaths European designated Special Protection Area and internationally known

The scale of this development proposal is unacceptable and its proximity will cause serious damage to the SPA site

2 In their May 2017 version of the HRA Screening and Appropriate Assessment Report at paragraph 813 AECOM are wrong to say ldquoincreasing recreational pressure is thought to increase the exposure of Annex 1 birds to disturbancerdquo saying this clearly in my opinion suits their purposes as a pro-development company to never find fault with development proposals As English Nature the predecessor organisation of Natural England stated in 2006 ldquoRecreational pressure can have a significant adverse impact on the Annex 1 Bird species for which the SPA is designated as woodlark and nightjar are ground nesting and therefore sensitive to disturbance particularly from dogs Dartford Warblers nest

4

close to the ground and are also susceptible to disturbance however they are more vulnerable to other effects of urbanisation in particular predation by catsrdquo (Stated in Thames Basin Heaths Special Protection Area Mitigation Standards for Residential Development dated 26 May 2006) It is loose and uncontrolled dogs that disturb ground nesting birds by forcing them to leave their nestschicks unattended allowing predatorrsquos access to predate and kill them

AECOM The Secretary of State for the Department of Homes and Communities (producers of the Application Guidance for so-called Garden Villages) The Ministry of Defence in the form of the Defence Infrastructure Organisation (as site owner) and Runnymede Borough Council are all wrong in knowingly promoting the Longcross Garden Village (SLAA 99 site) for residential development and for proposing just too many homes on it when it is immediately adjacent to Chobham Common and thus in a sensitive location to peoplersquos leisure activities

This site has already been damaged in recent years since Natural England determined that all National Nature Reserves should become ldquoaccessrdquo areas for people Consequently many of the bare soil tracks that previously supported insect species named in the original SSSI citation have been hard surfaced for people damaging populations of species like the Mottled Bee-fly With the DERA South proposals there is the very real danger that the whole Chobham Common site ends up being managed for peoplersquos leisure instead of itsrsquo special wildlife for which it is internationally designated Policies SD4 and especially SD10 by encouraging cycling on Chobham Common will be particularly damaging as this activity results in the continuous churning up of bare ground tracks and footpaths to the detriment of the invertebrates and sand lizards that nest in the bare sandy ground of lowland heathlands These species need the holes they dig as breeding sites to remain accessible each summer cycling by humans destroys this But of course AECOM do not know about this as they are not proper heathland ecologists

In AECOMrsquos paras 817 and 818 of the May 2017 HRA they are clearly ignoring the local geography with the Trumps Farm SANG site being only adjacent to the most easternmost housing of this DERA South

5

development site For those dwellings proposed for the western and middle parts of this development site Chobham Common is immediately adjacent Nowhere in the documents provided by Runnymede Borough Council or AECOM or in paragraphs 818 or 819 is it explained what will cause new residents of the dwellings proposed to be built on the SLAA 99 site adjacent to Chobham Common to get into their cars to travel east for approximately 15 miles or nearly 2 kilometres away with their dogs to reach the proposed Trumpsrsquo Farm SANG Equally nor is it explained how roaming cats will be stopped from crossing the B386 and visiting Chobham Common when their homes are right next door or very close to the dry lowland heathland of Chobham Common Paragraph 835 of the AECOM AA informs us that the development site at DERA South will be as close as 280m to the SPA yet the nearest the proposed SANG to be used to divert new residents away from the SPA is over 1km to 15km to the east So I repeat how will this development stop the occupants from walking the shorter distance to take both themselves and their dogs or allow their roaming cats especially of a night via cat-flaps onto Chobham Common In their evidence to the Surrey Heath Borough Council Local Plan in 2011 RSPB pointed out that domestic cats may range beyond any 400m buffer that is set up so fencing of any on-site SANG provision as well as fencing in any adjacent housing built up to the 400m buffer and within at least half a mile distance from the start of the public access to the Chobham Common site at Ordnance Survey Grid Reference SU979651 is essential

Para 416 of AECOMrsquos AA states that ldquothe Delivery Framework continues to restrict all new residential development within an area some 400 metres from the boundary of the TBH SPArdquo If this is the case with SLAA 99 that housing will be kept at 400m from Chobham Common this is still too near because people will go the shorter distance and on sunny weather days as is promoted by so many organisations for peoplersquos well-being which is also mentioned in Section 6 under Supporting Local People and Health amp Wellbeing of the Local Plan Thus they will walk straight out onto Chobham Common adding to the high numbers of people already visiting this site and damaging it by their presence this is unacceptable

Noting AECOMrsquos paragraph 810 ldquoThe Thames Basin Heaths SPA is considered sensitive to the effects of recreational disturbance Natural England considers that the threat of development pressure particularly

6

housing on neighbouring land and preferred sites within 5km results in increased recreational use of this site and has potential to disturb bird feeding and breeding behaviourrdquo These pathways to damage in AECOMrsquos so-called Appropriate Assessment are then conveniently screened out just because there is a Runnymede Policy to provide SANG as related to the TBH Delivery Framework The fact that Trumps Farm is in the wrong place to provide effective green space as mitigation in paragraphs 863 to 868 of AECOMrsquos conclusions as an alternative for peoplersquos recreation with their dogs is wrong Also the effect of roaming cats is completely ignored by this organisation so that any cats present in the 1750 nearby proposed dwellings will be at liberty to kill the Annex 1 birds present on the adjoining Chobham Common as well as the reptiles and amphibians they encounter

The dictionary definition of mitigation is to alleviate diminish or moderate I cannot see how a mitigation site 15 kilometresrsquo away will provide proper mitigation when so many people are being told to forsake their cars and to get out and exercise An on-site SANG must be provided at the west end of the DERA South site where the Longcross Barracks were and the Longcross Garden Village itself must be double fenced at itsrsquo boundary with the B386 road to exclude people and their animals from walking straight out onto Chobham Common if the development of SLAA 99 goes ahead as specified in the Local Plan A large on-site SANG will help reduce lighting spread and other urbanisation effects associated with this development and identified by AECOM elsewhere in their various HRAs for this Local Plan Any visible lighting on Chobham Common SPA will damage this site from their statements I am not sure this fact has registered with AECOMrsquos HRA writers

In the latest version of the AECOM HRA for the Runnymede Local Plan dated December 2017 and taking account of the Conservation of Habitats and Species Regulations 2017 one has to ask what has AECOM and all the promoters of Longcross Garden Village got to hide when the SANG site to divert residents away from the adjacent Chobham Common site within the Thames Basin Heaths SPA is not even mentioned Are Runnymede Borough Council providing a mitigation site or not The Conservation of Habitats and Species Regulations 2017 states in paragraph 63 (5) ldquoIn the light of the conclusions of the assessment and subject to regulation 64 the competent authority may agree to the plan or project only after having ascertained that it will not adversely affect

7

the integrity of the European siterdquo If no named SANG site is to be provided than the competent authority Runnymede Borough Council cannot conclude that no damage will occur to the integrity of the Chobham Common site as a result of the approval of itsrsquo Local Plan in its current format

3 Natural England used to be a proper nature conservation organisation before 2010 before the previous coalition Government of David Cameron and particularly Owen Paterson when Secretary of State for The Environment Food and Rural Affairs from 2012 ruined it and turned into another pro-development organisation negating itsrsquo roles via the 2012 statement that it could no longer campaign to objectively protect wildlife Itsrsquo role always was to shout loudly to protect wildlife and it should in my opinion now be recording objections to stop adverse developments such as SLAA 99 But with AECOMrsquos statement in paragraph 817 of the AECOM June 2016 HRA that Natural England already have an agreement with Crest Nicholson that a ldquowhole site SANG strategy has been agreedrdquo and that an ldquoadverse effect on the integrity on the Thames Basin Heaths would not ariserdquo subject to the delivery of the agreed SANGS shows Natural England has already been compromised in the negotiations Clearly there is a conflict with the statement in paragraph 817 in the summary ldquoLocating housing more than 400m from the SPA boundaryrdquo and para 835 which states that DERA South site is only 280m from the SPA boundary What is not clear from this early HRA and subsequent updated versions by AECOM is whether housing will be developed and established at a point of only 280m or less from the SPA boundary conforming to the boundary of the DERA South site or at the 400m buffer distance Which is it

It is clear that Natural Englandrsquos role in protecting Chobham Common has been compromised already they should be sticking to their 2006 position clearly if this development goes ahead referral to European Courts of Justice is necessary Already before BREXIT is completed the UK Government cannot be trusted to ensure our richest wildlife sites are protected when the same UK Government own ldquobrownfieldrdquo sites such as DERA South adjacent to these SPA sites The HS2 in England proposals and the Gwent Levels development proposals for the M4 in Wales are already evidence of their despicable and cavalier record of

8

damage to Sites of Special Scientific Interest Such damage is not acceptable I urge Runnymede Borough Council and the UK Government to think again about a different policy for this sensitive location of DERA South

4 Natural England should be putting Englandrsquos wildlife considerations first NOT the Governmentrsquos economic development initiatives I ask here that both DEFRA and Natural England intervene in this consultation and the subsequent inspection (as a consequence this objection will be sent to both of them) because the SLAA 99 development proposals and the so-called mitigation make a travesty of nature conservation and will only further damage the Chobham Common SSSI and its wildlife species

5 Clearly AECOMrsquos conclusion with regard to disturbance of the Annex 1 birds on Chobham Common in their paragraphs 863 and 868 of the May 2017 HRA and also in paragraphs 851 to 853 of the December 2017 version is wrong and seriously flawed because it fails to take in the proximity of the DERA South development to the SPA site of Chobham Common Also when the Trumps Farm SANG is over one mile distant and the originally proposed of a 55 hectare woodland SANG mentioned in paragraph 817 of the June 2016 HRA version does not fit to the Natural Englandrsquos preferred SANG size for a large development Nor is a woodland SANG normally safe for women walking alone with a dog the original preference for a SANG was that it should replicate the open nature of the heathland sitesrsquo the public like to use for dog-walking

Runnymede Borough Councilrsquos policy for the provision of SANG is not sufficient for it to work as mitigation it must be easier to get to and access the SANG than the adjoining SPA site and the Trumps Farm site fails in this provision Clearly Natural England and the UK Government are conveniently failing to understand what must be staring them in the face if they were honest that SLAA 99 development proposals will both damage and cause disturbance to the wildlife of Chobham Common As a part of the Thames Basin Heaths SPA and with an agreed Delivery Framework for SANGS in the Thames Basin Area if SLAA 99 is accepted in this Local Plan with the existing SANG proposals this will be unacceptable to me This will then form a part of a complaint to the European Commission as currently we are still subject to the judgements of the European Court of Justice

9

6 AECOMrsquos conclusions in paragraph 865 of the June 2016 HRA 868 of the May 2017 HRA and AA and lastly in paragraphs 851 to 853 of the December 2017 HRA and AA is what you expect from AECOM a complete disregard for the issues based on just a Council policy of the provision of SANG irrespective of itsrsquo location and proximity to the proposed development Equally as the Planning Inspectorate is under the same UK Government ldquocoshrdquo as Natural England to enable the provision of more housing for the so-called housing crisis It is not a shortage of housing that is evident in England it is a clear case of overpopulation with successive governments failing to govern and do anything about excessive breeding of the native human population and uncontrolled inward migration of human numbers into the UK particularly in southern England Before the next round of housing proposals in this area post 2030 the UK Government must act to reduce the excessive human population growth in the Runnymede area and the excessive expansion of the London region I can already see the claims for the forthcoming Planning Inspection and future ones probably by the Housebuilderrsquos Federation and the agents or QCs for the private housebuilding companies (a QC was employed by one developerrsquos agent for the East Hampshire Joint Core Strategy to argue for more housing to be achieved within that area and Local Plan) that people are more important than wildlife and that we must build on the SPAs or very close to them as in the current Runnymede Local Plan This failure to properly mitigate for the development of the so-called Longcross Garden Village is the start of the destruction of one of Britainrsquos best remaining lowland heathland sites A national disgrace

The SLAA 99 proposal and the proposals to remove land from the greenbelt in this Local Plan are as clear evidence of the overpressure of people numbers on the finite land resource of England (ldquoThe UKs population is projected to reach 70 million by 2030 ndash thatrsquos nine million more people than in 2008rdquo Ref Forum for the Future in 2010 ldquoUK population grows by over 400000 in the last year the largest absolute increase of any European countryrdquo Ref Population Mattersrsquo research in August 2013 ldquoEnglandrsquos population is already twice that of Germany per square mile and four times that of France It is our quality of life that is being affectedrdquo Ref Lord Horam speaking in February 2018 in the House of Lordrsquos debate on ldquoBrexit and the labour marketrdquo As the Planning

10

Inspector stated at the commencement of the Inspection of the East Hampshire Joint Core Strategy that I was present at in 2013 ldquoI have been given a growth agendardquo With this type of pressure by the UK Government I am not sure that I or nature conservation can expect a fair and objective hearing in 2018 when I object to Runnymede Borough Councilrsquos Local Plan 2030 we will see

7 For the proximity of the DERA South development to the SPA site of Chobham Common there is one potential solution and that is to reduce the number of houses in the DERA South (Longcross Garden Village) proposal and to make a new large SANG out of the land at the western end of the DERA South site This would require the ldquoDuty of Cooperationrdquo to be observed as the extreme west end of the DERA South site as it is within the land area of Surrey Heath Borough Council but I am sure this could be achievable This area would have to be fenced with dense mesh topped with rolled razor wire or similar to prevent free roaming dogs and cats from going onto the Chobham Common site south of the M3 and B386 roads If this fence was sufficiently high and doubled up to make two fences these could be used to keep the public and their animals away from and out of the SPA of Chobham Common and also necessarily to confine the loose running dogs a requirement for SANGS from being run-over on the B386 and the other connecting roads

8 The SPD issued and adopted by Surrey Heath Borough Council states I paragraph 57 ldquoIn the period up to 2028 Surrey Heath is expected to grant planning permission for 324010 new homes and this will require the provision of over 60 hectares of SANG Major or large new developments will be expected to provide bespoke on-site SANG rather than relying on the suite of SANGs being developed by the Borough Councilrdquo SLAA 99 is a large development so it should lose some of its housing land to provide on-site SANG to separate itsrsquo housing provision from Chobham Common

Similarly for Runnymede a large amount of new homes will result from the conclusions of the Planning Inspection Almost certainly more than proposed at the moment (this was the experience in East Hampshire in 2013) In this case and similar to the proposals adopted for SLAA 97 SANG provision for SLAA 99 (which appears to be scheduled to provide

11

the largest number of homes and something like 7000 extra people in Runnymede Borough) the SANG needs to be onsite and the solution I propose in this paragraph would cater for this Hoping new residents will all get in their cars to take the dog or cat for a walk over one mile away on Trumps Farm is not sustainable practicable or likely AECOMrsquos HRA and AA of both May and December 2017 completely fail to address the roaming catrsquos issue Despite AECOMrsquos clearly different point-of-view I do not believe that Runnymede Borough Council in their role as lsquocompetent authorityrsquo can conclude that no adverse effect on the integrity of internationally important wildlife sites of the Thames Basin Heathrsquos SPA will result from their proposals in their Local Plan 2030 as a consequence of what I consider are flawed conclusions proposed by AECOM The only light at the end of the tunnel of flawed conclusions in my opinion by AECOM is their final paragraph in the Dec 2017 HRA and AA that at paragraph 93 ldquoHowever it is recommended that the potential for further bespoke or strategic SANG later in the plan period is explored by the Council in time for Examination in Publicrdquo

I suggest to the Planning Inspector and Runnymede Borough Council that an on-site large SANG at the west end of the DERA South site should be provided as greenspace which would help to alleviate the potential for disturbance by residents of the new garden village from having to go or preferring to go to Chobham Common with the dog because this SANG site would be nearer Housing development adjacent to heathland always damages it especially if local arsonists are imported nearby but my proposals would go a long way to making the proposed Local Plan sound Though it would be far better if this garden village was scrapped and the DERA South site restored to heathland or just converted to another employment site as that would do far less damage to the Chobham Common SSSI and SPA site

____________________

Stephen R Miles 21st February 2018

From Caroline CravenTo Planning PolicySubject Representation for Local PlanDate 22 February 2018 092519Attachments Representation_form_for_Regulation_19_Caroline_Cravendocx

Please find attached my representation form in response to the Runnymede 2030 Local PlanConsultation

Regards helliphellip Caroline Craven

1886

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full contact details of the agent in 2

Part B (1) ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

XParagraph PolicyPolicies Map

X

X

X

4 Do you consider the Local Plan is

x

4 (1) Legally compliant Yes No

X

4 (2) SoundYes No

x

4 (3) Complies with the Duty to co-operateYesNo

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the duty to co-operate please also use this box to set out your comments

I believe the Local Plan does not comply with the duty to co-operate with neighbouring Boroughs The previous version was not deemed to be compliant as I understand it and there does not appear to be any significant changes that allow this plan to be compliant

RBC seems to have relied on the former Statement of Community Involvement (SCI) of 2014 In a digital age 15 lines in a local (The Villager Feb 9th) on page 11 is a poor means of communication to the Runnymede Borough residents on something that will affect them so deeply

In addition the views expressed at the RBC meeting by the attending RBC councillors were essentially that they accepted it wasnrsquot as good as it should be but was lsquothe best wersquore going to get at the momentrsquo and if not submitted then a Government Inspector would be appointed and they would lose control ndash a view I can fully understand but does not give the Runnymede residents a feeling of confidence in the legality or the integrity of the plan nor that the council truly want the best for the Borough

With regard to the Longcross site improvements to the station do not address the capacity issue The impact to commuters further up the line will be significant Peak times will be heavily impacted If additional trains are being proposed on this line the impact to the residents of Egham who already have to wait some 35-40 minutes in the hour whilst gates are down would therefore have even less opportunity to transverse the line at the crossing points Longcross station has no accessible car parking or drop off points This would necessitate commuters travelling to Virginia Water Egham whose own parking capability is limited Virginia Water has lost a large number of station car park spaces due to a new development This would also cause increased congestion in already known problem junctions The additional burden to the A320 which is already operating over practical capacity at several junctions and expected to deteriorate over the coming years would be significant (A320 Corridor Study ndash Feasibility Study ndash Interim report February 2018)

(Continue on a separate sheetexpand box if necessary)

The Longcross site will also need medical facilities ndash GPrsquos and potentially NHS drop in centre to ensure the current burden on the NHS is not exacerbated

With regard to the Traveller pitches they appear to amount to 35 within the scope of the development areas However the council plan to deliver 131 net additional plotspitches ndash 96 of which are not covered in this local plan This is an extremely emotive subject and needs to be identified properly in the plan and not almost hidden to avoid confrontation with angry residents that this County is already over run with these communities Integration with new developments is not the answer ndash Allocation of Traveller sites and pitches is according to the Government guidelines ldquoinappropriate within the Green beltrdquo and trying to slide this surreptitiously into new developments is a totally inappropriate solution

The Hurst Lane development was dismissed by the Council despite the residents being on board and a sustainable and acceptable plan being put forward for c 800-1000 homes on 80 -100 acres Over time this Lane has deteriorated to the point that Planning Inspectors described it as an lsquoindustrial wastelandrsquo In addition the Council resources are being tied up with the numerous issues generated by the Lane and the inability to resolve with the resources available The primary reason given is that the land is lsquoGreen Beltrsquo although under exceptional circumstances (which I believe this would come under) the council are able to and plan to in other areas use this land It is effectively a brownfield site which could be permitted fi connected to a SANG trade off which the residents plan was

6 Please set out what modification (s) you consider necessary to make the Local Plan legally compliant or sound having regard to the Matter you have identified at 5 above where this relates to soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of modification at examination) You will need to say why this modification will make the Local Plan legally compliant or sound It will be helpful if you are able to put forward your suggested revised wording of any policy or text Please be as precise as possible

For the plan to be sound I believe that

1) Review the inclusion of the Hurst Lane site ndash SLAA 59 ndash within the plan Appendix B states the capacity of 10 for Hurst Lane and 5 for Padd Farm If this relates to additional properties the number does not reflect the plans of up to 800 houses Access and infrastructure are addressed and the reduction in headcount in the councilrsquos Customer Services (I believe there is a dedicated resource looking after Padd Farm Hurst Lane) would be an additional benefit

2) Greater publicity is required over the consultation process The council appear to work on a lsquopullrsquo basis in that residents of the borough (other than those in the Residents Associations) have to actively seek out any updates from the council Local newspapers are not a good way of disseminating information in the digital age

3) Identify the additional travellergypsy site plans and move outside of the Green Belt area

If these steps were taken the residents would all have ample opportunity to contribute to the development of the local plan

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further representations based on the original representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

7 If your representation is seeking a modification do you consider it necessary to participate at the oral part of the examination

No I do not wish to participate Yes I wish to participate

X

at the oral examinationat the oral examination

8 If you wish to participate at the oral part of the examination please outline why you consider this to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who have indicated that they wish to participate at the oral part of the examination

9 Signature Date

21st February 2018

Caroline Craven

Notes to Accompany Model Representation Form

1 Introduction

11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 2004[footnoteRef1] (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound [1 View at httpwwwlegislationgovukukpga20045contents ]

2 Legal Compliance and Duty to Co-operate

21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness

22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)[footnoteRef2] it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices [2 LDDs are defined in regulation 5 ndash see link below ]

bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications

bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)[footnoteRef3] On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified [3 View at httpwwwlegislationgovukuksi2012767contentsmade ]

bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy)

23 You should consider the following before making a representation on compliance with the duty to co-operate

bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty

bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

3 Soundness

31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy

bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development

bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence

bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities

bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF

32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations

bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included

bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan

bull If the policy is not covered elsewhere in what way is the plan unsound without the policy

bull If the plan is unsound without the policy what should the policy say

4 General advice

41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

6

image1png

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full contact details of the agent in 2

Title Mrs First Name Caroline Last Name Craven Job Title (where relevant)

Organisation (where relevant)

Address Line 1 Southover Line 2 Hurst Lane Line 3 Egham Line 4 Surrey Post Code TW20 8QJ Telephone Number Email Address (where relevant)

2

Part B (1) ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

XParagraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails to comply with the duty to co-operate Please be as precise as possible If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

X X X

x

X

x

I believe the Local Plan does not comply with the duty to co-operate with neighbouring Boroughs The previous version was not deemed to be compliant as I understand it and there does not appear to be any significant changes that allow this plan to be compliant

RBC seems to have relied on the former Statement of Community Involvement (SCI) of 2014 In a digital age 15 lines in a local (The Villager Feb 9th) on page 11 is a poor means of communication to the Runnymede Borough residents on something that will affect them so deeply

In addition the views expressed at the RBC meeting by the attending RBC councillors were essentially that they accepted it wasnrsquot as good as it should be but was lsquothe best wersquore going to get at the momentrsquo and if not submitted then a Government Inspector would be appointed and they would lose control ndash a view I can fully understand but does not give the Runnymede residents a feeling of confidence in the legality or the integrity of the plan nor that the council truly want the best for the Borough

With regard to the Longcross site improvements to the station do not address the capacity issue The impact to commuters further up the line will be significant Peak times will be heavily impacted If additional trains are being proposed on this line the impact to the residents of Egham who already have to wait some 35-40 minutes in the hour whilst gates are down would therefore have even less opportunity to transverse the line at the crossing points Longcross station has no accessible car parking or drop off points This would necessitate commuters travelling to Virginia Water Egham whose own parking capability is limited Virginia Water has lost a large number of station car park spaces due to a new development This would also cause increased congestion in already known problem junctions The additional burden to the A320 which is already operating over practical capacity at several junctions and expected to deteriorate over the coming years would be significant (A320 Corridor Study ndash Feasibility Study ndash Interim report February 2018)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally compliant or sound having regard to the Matter you have identified at 5 above where this relates to soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of modification at examination) You will need to say why this modification will make the Local Plan legally compliant or sound It will be helpful if you are able to put forward your suggested revised wording of any policy or text Please be as precise as possible

For the plan to be sound I believe that

1) Review the inclusion of the Hurst Lane site ndash SLAA 59 ndash within the plan Appendix B states the capacity of 10 for Hurst Lane and 5 for Padd Farm If this relates to additional properties the number does not reflect the plans of up to 800 houses Access and infrastructure are addressed and the reduction in headcount in the councilrsquos Customer Services (I believe there is a dedicated resource looking after Padd Farm Hurst Lane) would be an additional benefit

2) Greater publicity is required over the consultation process The council appear to work on a lsquopullrsquo basis in that residents of the borough (other than those in the Residents Associations) have to actively seek out any updates from the council Local newspapers are not a good way of disseminating information in the digital age

3) Identify the additional travellergypsy site plans and move outside of the Green Belt area

If these steps were taken the residents would all have ample opportunity to contribute to the development of the local plan

The Longcross site will also need medical facilities ndash GPrsquos and potentially NHS drop in centre to ensure the current burden on the NHS is not exacerbated

With regard to the Traveller pitches they appear to amount to 35 within the scope of the development areas However the council plan to deliver 131 net additional plotspitches ndash 96 of which are not covered in this local plan This is an extremely emotive subject and needs to be identified properly in the plan and not almost hidden to avoid confrontation with angry residents that this County is already over run with these communities Integration with new developments is not the answer ndash Allocation of Traveller sites and pitches is according to the Government guidelines ldquoinappropriate within the Green beltrdquo and trying to slide this surreptitiously into new developments is a totally inappropriate solution

The Hurst Lane development was dismissed by the Council despite the residents being on board and a sustainable and acceptable plan being put forward for c 800-1000 homes on 80 -100 acres Over time this Lane has deteriorated to the point that Planning Inspectors described it as an lsquoindustrial wastelandrsquo In addition the Council resources are being tied up with the numerous issues generated by the Lane and the inability to resolve with the resources available The primary reason given is that the land is lsquoGreen Beltrsquo although under exceptional circumstances (which I believe this would come under) the council are able to and plan to in other areas use this land It is effectively a brownfield site which could be permitted fi connected to a SANG trade off which the residents plan was

4

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further representations based on the original representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

7 If your representation is seeking a modification do you consider it necessary to participate at the oral part of the examination

No I do not wish to participate Yes I wish to participate at the oral examination at the oral examination

8 If you wish to participate at the oral part of the examination please outline why you consider this to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who have indicated that they wish to participate at the oral part of the examination

9 Signature Date

X

Caroline Craven 21st February 2018

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan 1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination 42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

FromPolicy

Subject FW New Housing Plans 2015-2030Date 21 February 2018 164919

Sent 21 February 2018 1608To PlanningSubject New Housing Plans 2015-2030

To

Policy Planning and Strategy Team

Runnymede Borough Council

Station Road

Addlestone

21022018

Dear Sirs

As an Ottershaw resident of nearly 30 years i would like you to read and take on board my objections to yourproposal to take land out of the green belt for housing and your plan to build so many houses in ourcommunity

Of course new houses have to be built right across the country now and in the future but i feel the plans youhave are for far too many houses The infrastructure of our community will just not sustain the extra amount ofpeople and cars and the general traffic that would entail

There are other possibilities available before your irreversible plans are put into action Are these possibilitiesbeing resourced

When i drive around the borough now and for a long long time i see so many empty office blocks Some ofthese have stood empty for yearsWhy has permission been given continuosly from what i can see on a huge scale for these to be built

This building of offices has to stop and the ones that have remained empty for years could be converted tohousing as in flats starter homes for young people

If Planning Practice Guidlines state that the use of Green Beltshould only occur in very special circumstances these and the Brownfield sites in Runnymede must be extensively researched

I live in Wilson Drive and for many years now when i leave my house to go into the village or elsewhere thereis often gridlock in every direction The roads in our community are so heavily used by cars and lorries headingtoward the M25 Can you imagine the impact so many more of these will bring Driving has not been a pleasurefor a long time and i do walk wherever possible Parking is a problem in the village as so many people use theone car park I believe there may be a plan in the pipeline to even get rid of that for road widening

We have a GP practice in the village that is getting harder to book an appointment for also i have been waitingmonths for an appointment at St Peters hospital and just keep getting apologetic letters

Quality of life is very important for your residents and that quality has already deteriorated lately

1888

In order to accomodate so many new residents you will be making the ones you have feel very disappointedand frustated that no one listens

There is no going back once the desicion has been made and so many houses built Please take my feelings and iam sure very many more residents comments and pleas into account before you make the irreversible decisionto go ahead with your plans

Yours Faithfully

Margaret Wensley and the Wensley family

Beechwood

Wilson Drive

Ottershaw

Surrey

KT16 0NT

----------- middotn==middot =

Planning Services

DELIVERED BY HAND

Runnymede Borough Council ~--------------=-middot ---------middot------~

Planning Dept Runnymede Borough Council Civic Offices Station Road Addlestone KT15 2AH

Dear Sirs

Catherine Brunton-Green 20The Glen Addlestone

KT151AQ

15th February 2018

Runnymede Draft local Plan 2015- 2030- Final Consultation

I have serious concerns in respect of this draft plan Runnymede Borough Council (RBC) have a duty of care to consult with listen and act upon the wishes of its residents There has been some consultation but this has not effectively reached all Runnymede residents Communication is unnecessarily legally complex and full of unexplained acronyms The basic Runnymede Voice delivered to every home has been abandoned There has been no flyer delivered to every home stating in a simplified way what is happening so that all abilities may be catered for Many people are isolated for numerous reasons and do not have internet access Neither is there evidence of full in depth cross boundary consultation with adjacent boroughs This local plan is driven primarily by a developers charter promoted by RBCS Head of Planning It is both unfair unjust and I question its soundness

The Strategic Housing Market Assessment has not taken leaving the EU into account and makes a blanket assumption on Heathrow expansion

I strongly object to the proposed loss of c 560 acres of Green Belt Our Prime Minister and government have recently stated that they are quote committed to protecting and enhancing our natural environment for successive generations therefore Green Belt land would only be lost as a last resort 11

bull Detailed evidence based research by The Council for The Protection of Rural England confirms that by fully utilising brownfield land 12 million homes could be built in London and the South East without the loss of any Green Belt

I have objection to building on the Veterinary Laboratory Green Belt Land Parcel BRow Town (Policy SL11 8283) is not justified for development This is designated for 150 additional dwellings and 2 gypsyTraveller pitches This site provides a natural demarcation between developments either side Designated SANG area is privately owned and not available The density of proposed build is unacceptable and above all an area of outstanding natural beauty would be destroyed

Our infrastructure is unable to cope at present A320 suffers perpetual gridlock now Equally gridlock is evidenced through Ottershaw Addlestone Station Road and A317 Addlestone Weybridge We already have unhealthily dangerous levels of roadside nitrogen dioxide concentrations in many areas such as Station Road RBC has made a lame submission in respect of

tackling roadside nitrogen dioxide concentrations in the South East (UK00310) Incidence of exacerbated breathing illnesses in this vicinity has increased dramatically in the past 7 years All age groups are affected

All GP surgeries across Runnymede have great difficulty in recruiting doctors Two practices in the immediate area are merging due to unprecedented numbers of doctors leaving and retiring Practice lists and capacity is stretched Patient access to services and patient safety has to be the highest priority Our schools are similarly affected

RBC infrastructure is totally reliant upon Surrey County Council who declare they are not in a financial position to fund the necessary support to develop the infrastructure for this Local Plan

I am prepared to speak at Public Enquiry

Yours faithfully

bull i I I bull bull

From Brian PickettTo Planning PolicySubject Runnymede 2030 Local Plan - submission of viewsDate 22 February 2018 090921Attachments Ottershaw development Objection letter February 2018docx

Please find attached the submission of my views on the Runnymede 2030 LocalPlan

Kind RegardsBrian Pickett

1891

planningrunnymedegovuk planningrunnymedegovuk

21022018

Re Runnymede 2030 Local Plan Ottershaw East ndash Objection to planning

Dear Sirs

We are writing to you again as we strongly object to the Runnymede Borough Councils plans to remove land behind houses along Brox Road known as lsquoOttershaw Eastrsquo from the Green Belt We are objecting for a number of reasons listed below

middot The Green Belt is precious once it is gone it is gone forever The removal of this land from the Green Belt does not comply with Planning Policy which states ldquothat Green Belt boundaries should only be altered in exceptional circumstancesrdquo there are no such circumstances that can justify the removal of this piece of land

middot The Green Belt should be an area that is preserved for future generations to enjoy and appreciate and many statements have been made by both the Government and members of Parliament on their commitment to protect the Green Belt ndash these statements now need to be converted into action in the Local Borough Plans The roll out of Green Belt to local councils in the 1950rsquos was to prevent urban sprawl and the merging of settlements thereby helping to preserve and protect the character of communities it encompassed protect the country setting and encourage development through regeneration of sites within towns and cities not villages

middot The description of Ottershaw by the council itself in the lsquoUrban Characteristicsrsquo publication on the Runnymede Borough Council website states ldquoOttershaw has its own identity and sense of place which is partly derived from the clearly identifiable heart of the urban area focused on The Otter and adjoining local shopping parade and community facilities as well as being surrounded by open greenbelt countryside Removing this green belt that is part of the identifiable heart of Ottershaw would destroy this villagersquos identity and community

middot The planning proposals and building on this part of the green belt land would lead to a considerable population increase in the village Services and facilities will struggle or fail to cope space is already limited at the doctorrsquos surgery and school places are at capacity The transport infrastructure is already stretched with limited bus services busy roads poorly maintained pavements and road surfaces Brox road is already used as a shortcut to avoid traffic congestion Given that Ottershaw does not have a train station it is reasonable to assume that the majority of houses would have at least one car the added traffic from the new development would put a severe strain on the road network and users Available information on mitigation is very vague and very open to interpretation and misguided assumptions

middot The Green Belt land is a habitat to an array of plants and animals including important pollinator species and larger animals such as birds foxes and deer There should be no assumption that animals will simply move to another area habitats are established over many years and this development will be another loss to the maintenance of biodiversity I enjoy the fauna and flora in these areas going for walks along the public footpaths Having such wonderful access to a relaxing escape so close to home is priceless and something I hold dear to myself my family and community What is now a beautiful scenic view will become a spoilt urban sprawl of modern housing

middot I moved to Ottershaw with my wife in 2016 to settle down and start a family The relaxed quiet village sense of community and safety surrounded by beautiful countryside were its appeal I are very concerned and disappointed that this planning proposal is still being considered which will undoubtedly destroy this idyllic setting

There are no ldquoexceptional or very special circumstancesrdquo that justify the removal of Ottershaw East from the Green Belt We trust that the Council will therefore not remove ldquoOttershaw Eastrdquo and ldquoThe Fieldrdquo from the Green Belt

Yours faithfully

Dr Brian Pickett

To Policy Planning and Strategy Team Runnymede Borough Council Civic Centre Station Road Addlestone Surrey KT15 2AH planningrunnymedegovuk

From Dr Brian Pickett 139 Brox Road Ottershaw Surrey KT16 0LG planningrunnymedegovuk

21022018 Re Runnymede 2030 Local Plan Ottershaw East ndash Objection to planning Dear Sirs We are writing to you again as we strongly object to the Runnymede Borough Councils plans to remove land behind houses along Brox Road known as lsquoOttershaw Eastrsquo from the Green Belt We are objecting for a number of reasons listed below bull The Green Belt is precious once it is gone it is gone forever The removal of this

land from the Green Belt does not comply with Planning Policy which states ldquothat Green Belt boundaries should only be altered in exceptional circumstancesrdquo there are no such circumstances that can justify the removal of this piece of land

bull The Green Belt should be an area that is preserved for future generations to enjoy

and appreciate and many statements have been made by both the Government and members of Parliament on their commitment to protect the Green Belt ndash these statements now need to be converted into action in the Local Borough Plans The roll out of Green Belt to local councils in the 1950rsquos was to prevent urban sprawl and the merging of settlements thereby helping to preserve and protect the character of communities it encompassed protect the country setting and encourage development through regeneration of sites within towns and cities not villages

bull The description of Ottershaw by the council itself in the lsquoUrban Characteristicsrsquo

publication on the Runnymede Borough Council website states ldquoOttershaw has its own identity and sense of place which is partly derived from the clearly identifiable heart of the urban area focused on The Otter and adjoining local shopping parade and community facilities as well as being surrounded by open greenbelt countryside Removing this green belt that is part of the identifiable heart of Ottershaw would destroy this villagersquos identity and community

bull The planning proposals and building on this part of the green belt land would lead

to a considerable population increase in the village Services and facilities will struggle or fail to cope space is already limited at the doctorrsquos surgery and school places are at capacity The transport infrastructure is already stretched with limited bus services busy roads poorly maintained pavements and road surfaces Brox road is already used as a shortcut to avoid traffic congestion Given that Ottershaw does not have a train station it is reasonable to assume that the majority of houses would have at least one car the added traffic from the new development would put a severe strain on the road network and users Available information on mitigation is very vague and very open to interpretation and misguided assumptions

bull The Green Belt land is a habitat to an array of plants and animals including important pollinator species and larger animals such as birds foxes and deer There should be no assumption that animals will simply move to another area habitats are established over many years and this development will be another loss to the maintenance of biodiversity I enjoy the fauna and flora in these areas going for walks along the public footpaths Having such wonderful access to a relaxing escape so close to home is priceless and something I hold dear to myself my family and community What is now a beautiful scenic view will become a spoilt urban sprawl of modern housing

bull I moved to Ottershaw with my wife in 2016 to settle down and start a family The

relaxed quiet village sense of community and safety surrounded by beautiful countryside were its appeal I are very concerned and disappointed that this planning proposal is still being considered which will undoubtedly destroy this idyllic setting

There are no ldquoexceptional or very special circumstancesrdquo that justify the removal of Ottershaw East from the Green Belt We trust that the Council will therefore not remove ldquoOttershaw Eastrdquo and ldquoThe Fieldrdquo from the Green Belt Yours faithfully Dr Brian Pickett

FromTo Planning PolicySubject Runnymede Local Plan 2030 - consultation responseDate 21 February 2018 163608Attachments Runnymede LP Response - EE15pdf

Please find attached a consultation response form

________________________________________Christian Leigh BSc(Hons) MPhil MRTPIDirectorLeigh amp Glennie Ltd6 All Souls RoadAscotBerkshire SL5 9EA

1893

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number 01344 297094 Email Address (where relevant)

mailchristianleighcouk

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number Email Address (where relevant)

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

From MCNAB DouglasTo Planning PolicySubject Runnymede Draft Local Plan consultation - Representation from Education and Skills Funding AgencyDate 21 February 2018 091407Attachments Runnymede Reg 19 response ESFADOC

Dear Runnymede Planning Policy Team

Please see attached a representation from the Education and Skills Funding Agency on theRunnymede Local Plan consultation

I would be grateful if you could confirm receipt

Best regardsDoug

Douglas McNab MRTPIForward Planning Manager ndash South East

Planning Team Free Schools CapitalEducation and Skills Funding AgencyDepartment for Education 5th floor Sanctuary Buildings 20 Great Smith Street London SW1P 3BT

Email douglasmcnabeducationgovukMobile 07990 082877Web wwwgovukesfa

1895

image1pngOur Ref ESFALocal PlanRunnymede 2018 21st February 2018

Dear SirMadam

Re Runnymede Local Plan

Consultation under Regulation 19 of Town and Country Planning (Local Planning) (England) Regulations 2012

Submission of the Education and Skills Funding Agency

1 The Education and Skills Funding Agency (ESFA) welcomes the opportunity to contribute to the development of planning policy at the local level

2 The ESFA launched on 1st April 2017 bringing together the existing responsibilities of the Education Funding Agency (EFA) and the Skills Funding Agency (SFA) to create a single funding agency accountable for funding education and training for children young people and adults The ESFA are accountable for pound61 billion of funding a year for the education and training sector including support for all state-provided education for 8 million children aged 3 to 16 and 16 million young people aged 16 to 19

3 Under the provisions of the Education Act 2011 and the Academies Act 2010 all new state schools are now academiesfree schools and the ESFA is the delivery body for many of these rather than local education authorities As such we aim to work closely with local authority education departments and planning authorities to meet the demand for new school places and new schools We do this through a variety of means including by supporting the adoption of sound local plan policies site allocations and guidance (all based on robust evidence) that facilitate the delivery of education infrastructure where and when it is needed and maximise developer contributions for schools In this capacity we would like to offer the following comments in response to the proposals outlined in the above consultation document

Comments on the Local Plan

4 As you will be aware the primary focus at this stage of the Local Planrsquos preparation is on the soundness of the plan with regard to it being positively prepared justified effective and consistent with national policy The following detailed comments set out the ESFArsquos view of the planrsquos soundness in respect of education provision

5 The ESFA notes that the local plan will make provision for a minimum of 7413 net additional dwellings over the plan period Development will generally complement the existing settlement pattern focusing the largest amounts of residential growth primarily in Chertsey (1950 homes) Addlestone (936 homes) and Egham (812 homes) A new ldquolocally led garden villagerdquo is also proposed at Longcross providing a further 1718 homes This level of development will put pressure on existing education infrastructure

6 The plan recognises that ldquoIt is important that infrastructure is delivered in a timely manner to ensure that the needs of the occupiers of new development can be met without placing undue burdens on existing infrastructure facilities and servicesrdquo (para 560) The ESFA supports Policy SD6 Infrastructure Provision amp Timing particularly the signposting of the Infrastructure Delivery Plan (IDP) and the need for development to deliver this either on-site or through s106 or CIL financial contributions off-site and the need for development to be phased in line with the provision of important supporting infrastructure

7 The latest version of the IDP states that there is an ongoing programme of primary school expansions this will help to meet the forecast need for 4-6FE of new capacity over the plan period The need for one new build school project is identified a 2FE primary school at the Longcross Garden Village (estimated cost pound99M to pound15M) this is referred to in the site allocation policies (see below) With respect to secondary school places it is anticipated that up to six additional FE could be required in the Borough by 2021 Additional places will be delivered through the new 6FE Runnymede Free School (which opened in temporary accommodation in 2017) development of additional FE within Salesian School (Catholic faith school) and expansion of another school in the Chertsey area (to accommodate demand from generated by the Longcross Garden Village site)

8 It would be useful if the background data informing these projections of need could be clarified particularly the pupil yield factors used and the evidence base supporting this This would help to demonstrate more clearly to the Inspector that the approach to the planning and delivery of education infrastructure has been positively prepared based on a strategy which seeks to meet objectively assessed infrastructure requirements and is justified based on proportionate evidence The ESFA notes that the Runnymede S106 SPG sets out pupil yield figures however this document dates from December 2007 so the figures may be outdated

9 The ESFA supports the Councilrsquos allocation and safeguarding of land for schools as set out in the following policies

middot Policy SD10 Longcross Garden Village - 2FE primary school with preschoolearly years settings

middot Policy SL2 to SL18 ndash series of housing allocation policies that highlight the need to make a financial contribution to early years primary and secondary school infrastructure ldquoeither through S106 or CIL (or its successor)rdquo

Developer Contributions and CIL

10 One of the tests of soundness is that a Local Plan is lsquoeffectiversquo ie the plan should be deliverable over its period In this context and with specific regard to planning for schools there is a need to ensure that education contributions made by developers are sufficient to deliver the additional school places required to meet the increase in demand generated by new developments The ESFA notes that the council has not adopted CIL and that the Planning Obligations SPG sets out how developer contributions to education provision will be secured via section 106 agreements The ESFA supports the Councilrsquos approach to ensure developer contributions address the impacts arising from growth However the ESFA recommends that the Local Plan includes a commitment to revise the Planning Obligations SPG in line with the latest evidence of the boroughrsquos infrastructure needs pupil yields and build costs (including the cost of school expansion new build and SEN provision) Any such review should be prepared in consultation with the county council as local education authority This will help to ensure appropriate rates are levied and the right infrastructure is secured across the borough

11 The ESFA would be particularly interested in responding to any update to the Infrastructure Delivery Plan or review of infrastructure requirements As such please add the ESFA to the database for future CIL consultations

Forward funding

12 In light of the proposed Longcross Garden Village emerging ESFA proposals for forward funding schools as part of large residential developments may be relevant for example if viability becomes an issue The ESFA aims to be able to clarify forward funding options for schools in 2018 We would be happy to meet to discuss this opportunity further once the options have been finalised and ifwhen relevant Any offer of forward funding would seek to maximise developer contributions to education infrastructure provision while supporting delivery of schools where and when they are needed

Conclusion

13 Finally I hope the above comments are helpful in finalising the Runnymede Local Plan with specific regard to the provision of land for new schools

14 Please notify the ESFA when the Local Plan is submitted for examination the Inspectorrsquos report is published and the Local Plan is adopted

15 Please do not hesitate to contact me if you have any queries regarding this response The ESFA looks forward to continuing to work with Runnymede Borough Council to develop a sound Local Plan that will aid in the delivery of new schools

Yours faithfully

DC McNab

Douglas McNab MRTPI

Forward Planning Manager

Tel 07990 082877

Email

douglasmcnabeducationgovuk

Web

wwwgovuk esfa

Education and Skills Funding Agency13

Department for EducationSanctuary BuildingsGreat Smith StreetLondonSW1P 3BT13

13

Tel 0207 340 700013

13

wwwgovukesfa13

13

13

To

Policy Planning and Strategy Team

Runnymede Borough Council

Civic Centre

Station Road

Addlestone

Surrey

KT15 2AH

From

Dr Brian Pickett

139 Brox Road

Ottershaw

Surrey

KT16 0LG

Title

Mrs

First Name

Caroline

Last Name

Craven

Job Title

(where relevant)

Organisation

(where relevant)

Address Line 1

Southover

Line 2

Hurst Lane

Line 3

Egham

Line 4

Surrey

Post Code

TW20 8QJ

Telephone Number

07770999572

Email Address

(where relevant)

Carolinecraven911hotmailcom

Page 6: Runnymede Borough Council, for submissions. My contact details are all in the WORD letter attached. But I will provide my telephone number here too, which …

3

visitor pressure is higher than Dorset) nightjars demonstrate a general preference for areas away from access points and from site edges and there is a clear trend for nightjar density to decline with increasing visitor pressure and nightjars appearing to avoid areas of high disturbance within sitesrdquo The proposed Longcross Garden Village on the DERA South site (and the DERA North site already having planning permission) contained in the Runnymede Local Plan 2030 will increase dramatically the disturbance pressure potentially by 7000 extra people (1750 x 4 persons) having immediate and probably preferred access to Chobham Common SPA A better plan and solution to the disturbance problem is needed nothing AECOM has written improves this potentially bad situation

Consequently I am asking the Planning Inspector at the forthcoming public inspection to find the Runnymede 2030 Local Plan unsound as a consequence

This is for the following reasons

1 SLAA 99 the former DERA south site at Longcross Road (now Longcross Garden Village under policy SD10 in the final Runnymede 2030 Draft Local Plan dated January 2018) with a so-called indicative capacity of 1300 to 1725 dwellings because it is immediately adjacent to Chobham Common will be particularly damaging bringing unacceptable numbers of people and their pet animals (dogs and cats) in contact with the European SPA site and UK nationally designated Site of Special Scientific Interest of Chobham Common All three categories human beings dogs and cats as well as the associated urbanisation effects will damage this site particularly for the ground nesting birds for but also for many other species for which Chobham Common is included in the Thames Basin Heaths European designated Special Protection Area and internationally known

The scale of this development proposal is unacceptable and its proximity will cause serious damage to the SPA site

2 In their May 2017 version of the HRA Screening and Appropriate Assessment Report at paragraph 813 AECOM are wrong to say ldquoincreasing recreational pressure is thought to increase the exposure of Annex 1 birds to disturbancerdquo saying this clearly in my opinion suits their purposes as a pro-development company to never find fault with development proposals As English Nature the predecessor organisation of Natural England stated in 2006 ldquoRecreational pressure can have a significant adverse impact on the Annex 1 Bird species for which the SPA is designated as woodlark and nightjar are ground nesting and therefore sensitive to disturbance particularly from dogs Dartford Warblers nest

4

close to the ground and are also susceptible to disturbance however they are more vulnerable to other effects of urbanisation in particular predation by catsrdquo (Stated in Thames Basin Heaths Special Protection Area Mitigation Standards for Residential Development dated 26 May 2006) It is loose and uncontrolled dogs that disturb ground nesting birds by forcing them to leave their nestschicks unattended allowing predatorrsquos access to predate and kill them

AECOM The Secretary of State for the Department of Homes and Communities (producers of the Application Guidance for so-called Garden Villages) The Ministry of Defence in the form of the Defence Infrastructure Organisation (as site owner) and Runnymede Borough Council are all wrong in knowingly promoting the Longcross Garden Village (SLAA 99 site) for residential development and for proposing just too many homes on it when it is immediately adjacent to Chobham Common and thus in a sensitive location to peoplersquos leisure activities

This site has already been damaged in recent years since Natural England determined that all National Nature Reserves should become ldquoaccessrdquo areas for people Consequently many of the bare soil tracks that previously supported insect species named in the original SSSI citation have been hard surfaced for people damaging populations of species like the Mottled Bee-fly With the DERA South proposals there is the very real danger that the whole Chobham Common site ends up being managed for peoplersquos leisure instead of itsrsquo special wildlife for which it is internationally designated Policies SD4 and especially SD10 by encouraging cycling on Chobham Common will be particularly damaging as this activity results in the continuous churning up of bare ground tracks and footpaths to the detriment of the invertebrates and sand lizards that nest in the bare sandy ground of lowland heathlands These species need the holes they dig as breeding sites to remain accessible each summer cycling by humans destroys this But of course AECOM do not know about this as they are not proper heathland ecologists

In AECOMrsquos paras 817 and 818 of the May 2017 HRA they are clearly ignoring the local geography with the Trumps Farm SANG site being only adjacent to the most easternmost housing of this DERA South

5

development site For those dwellings proposed for the western and middle parts of this development site Chobham Common is immediately adjacent Nowhere in the documents provided by Runnymede Borough Council or AECOM or in paragraphs 818 or 819 is it explained what will cause new residents of the dwellings proposed to be built on the SLAA 99 site adjacent to Chobham Common to get into their cars to travel east for approximately 15 miles or nearly 2 kilometres away with their dogs to reach the proposed Trumpsrsquo Farm SANG Equally nor is it explained how roaming cats will be stopped from crossing the B386 and visiting Chobham Common when their homes are right next door or very close to the dry lowland heathland of Chobham Common Paragraph 835 of the AECOM AA informs us that the development site at DERA South will be as close as 280m to the SPA yet the nearest the proposed SANG to be used to divert new residents away from the SPA is over 1km to 15km to the east So I repeat how will this development stop the occupants from walking the shorter distance to take both themselves and their dogs or allow their roaming cats especially of a night via cat-flaps onto Chobham Common In their evidence to the Surrey Heath Borough Council Local Plan in 2011 RSPB pointed out that domestic cats may range beyond any 400m buffer that is set up so fencing of any on-site SANG provision as well as fencing in any adjacent housing built up to the 400m buffer and within at least half a mile distance from the start of the public access to the Chobham Common site at Ordnance Survey Grid Reference SU979651 is essential

Para 416 of AECOMrsquos AA states that ldquothe Delivery Framework continues to restrict all new residential development within an area some 400 metres from the boundary of the TBH SPArdquo If this is the case with SLAA 99 that housing will be kept at 400m from Chobham Common this is still too near because people will go the shorter distance and on sunny weather days as is promoted by so many organisations for peoplersquos well-being which is also mentioned in Section 6 under Supporting Local People and Health amp Wellbeing of the Local Plan Thus they will walk straight out onto Chobham Common adding to the high numbers of people already visiting this site and damaging it by their presence this is unacceptable

Noting AECOMrsquos paragraph 810 ldquoThe Thames Basin Heaths SPA is considered sensitive to the effects of recreational disturbance Natural England considers that the threat of development pressure particularly

6

housing on neighbouring land and preferred sites within 5km results in increased recreational use of this site and has potential to disturb bird feeding and breeding behaviourrdquo These pathways to damage in AECOMrsquos so-called Appropriate Assessment are then conveniently screened out just because there is a Runnymede Policy to provide SANG as related to the TBH Delivery Framework The fact that Trumps Farm is in the wrong place to provide effective green space as mitigation in paragraphs 863 to 868 of AECOMrsquos conclusions as an alternative for peoplersquos recreation with their dogs is wrong Also the effect of roaming cats is completely ignored by this organisation so that any cats present in the 1750 nearby proposed dwellings will be at liberty to kill the Annex 1 birds present on the adjoining Chobham Common as well as the reptiles and amphibians they encounter

The dictionary definition of mitigation is to alleviate diminish or moderate I cannot see how a mitigation site 15 kilometresrsquo away will provide proper mitigation when so many people are being told to forsake their cars and to get out and exercise An on-site SANG must be provided at the west end of the DERA South site where the Longcross Barracks were and the Longcross Garden Village itself must be double fenced at itsrsquo boundary with the B386 road to exclude people and their animals from walking straight out onto Chobham Common if the development of SLAA 99 goes ahead as specified in the Local Plan A large on-site SANG will help reduce lighting spread and other urbanisation effects associated with this development and identified by AECOM elsewhere in their various HRAs for this Local Plan Any visible lighting on Chobham Common SPA will damage this site from their statements I am not sure this fact has registered with AECOMrsquos HRA writers

In the latest version of the AECOM HRA for the Runnymede Local Plan dated December 2017 and taking account of the Conservation of Habitats and Species Regulations 2017 one has to ask what has AECOM and all the promoters of Longcross Garden Village got to hide when the SANG site to divert residents away from the adjacent Chobham Common site within the Thames Basin Heaths SPA is not even mentioned Are Runnymede Borough Council providing a mitigation site or not The Conservation of Habitats and Species Regulations 2017 states in paragraph 63 (5) ldquoIn the light of the conclusions of the assessment and subject to regulation 64 the competent authority may agree to the plan or project only after having ascertained that it will not adversely affect

7

the integrity of the European siterdquo If no named SANG site is to be provided than the competent authority Runnymede Borough Council cannot conclude that no damage will occur to the integrity of the Chobham Common site as a result of the approval of itsrsquo Local Plan in its current format

3 Natural England used to be a proper nature conservation organisation before 2010 before the previous coalition Government of David Cameron and particularly Owen Paterson when Secretary of State for The Environment Food and Rural Affairs from 2012 ruined it and turned into another pro-development organisation negating itsrsquo roles via the 2012 statement that it could no longer campaign to objectively protect wildlife Itsrsquo role always was to shout loudly to protect wildlife and it should in my opinion now be recording objections to stop adverse developments such as SLAA 99 But with AECOMrsquos statement in paragraph 817 of the AECOM June 2016 HRA that Natural England already have an agreement with Crest Nicholson that a ldquowhole site SANG strategy has been agreedrdquo and that an ldquoadverse effect on the integrity on the Thames Basin Heaths would not ariserdquo subject to the delivery of the agreed SANGS shows Natural England has already been compromised in the negotiations Clearly there is a conflict with the statement in paragraph 817 in the summary ldquoLocating housing more than 400m from the SPA boundaryrdquo and para 835 which states that DERA South site is only 280m from the SPA boundary What is not clear from this early HRA and subsequent updated versions by AECOM is whether housing will be developed and established at a point of only 280m or less from the SPA boundary conforming to the boundary of the DERA South site or at the 400m buffer distance Which is it

It is clear that Natural Englandrsquos role in protecting Chobham Common has been compromised already they should be sticking to their 2006 position clearly if this development goes ahead referral to European Courts of Justice is necessary Already before BREXIT is completed the UK Government cannot be trusted to ensure our richest wildlife sites are protected when the same UK Government own ldquobrownfieldrdquo sites such as DERA South adjacent to these SPA sites The HS2 in England proposals and the Gwent Levels development proposals for the M4 in Wales are already evidence of their despicable and cavalier record of

8

damage to Sites of Special Scientific Interest Such damage is not acceptable I urge Runnymede Borough Council and the UK Government to think again about a different policy for this sensitive location of DERA South

4 Natural England should be putting Englandrsquos wildlife considerations first NOT the Governmentrsquos economic development initiatives I ask here that both DEFRA and Natural England intervene in this consultation and the subsequent inspection (as a consequence this objection will be sent to both of them) because the SLAA 99 development proposals and the so-called mitigation make a travesty of nature conservation and will only further damage the Chobham Common SSSI and its wildlife species

5 Clearly AECOMrsquos conclusion with regard to disturbance of the Annex 1 birds on Chobham Common in their paragraphs 863 and 868 of the May 2017 HRA and also in paragraphs 851 to 853 of the December 2017 version is wrong and seriously flawed because it fails to take in the proximity of the DERA South development to the SPA site of Chobham Common Also when the Trumps Farm SANG is over one mile distant and the originally proposed of a 55 hectare woodland SANG mentioned in paragraph 817 of the June 2016 HRA version does not fit to the Natural Englandrsquos preferred SANG size for a large development Nor is a woodland SANG normally safe for women walking alone with a dog the original preference for a SANG was that it should replicate the open nature of the heathland sitesrsquo the public like to use for dog-walking

Runnymede Borough Councilrsquos policy for the provision of SANG is not sufficient for it to work as mitigation it must be easier to get to and access the SANG than the adjoining SPA site and the Trumps Farm site fails in this provision Clearly Natural England and the UK Government are conveniently failing to understand what must be staring them in the face if they were honest that SLAA 99 development proposals will both damage and cause disturbance to the wildlife of Chobham Common As a part of the Thames Basin Heaths SPA and with an agreed Delivery Framework for SANGS in the Thames Basin Area if SLAA 99 is accepted in this Local Plan with the existing SANG proposals this will be unacceptable to me This will then form a part of a complaint to the European Commission as currently we are still subject to the judgements of the European Court of Justice

9

6 AECOMrsquos conclusions in paragraph 865 of the June 2016 HRA 868 of the May 2017 HRA and AA and lastly in paragraphs 851 to 853 of the December 2017 HRA and AA is what you expect from AECOM a complete disregard for the issues based on just a Council policy of the provision of SANG irrespective of itsrsquo location and proximity to the proposed development Equally as the Planning Inspectorate is under the same UK Government ldquocoshrdquo as Natural England to enable the provision of more housing for the so-called housing crisis It is not a shortage of housing that is evident in England it is a clear case of overpopulation with successive governments failing to govern and do anything about excessive breeding of the native human population and uncontrolled inward migration of human numbers into the UK particularly in southern England Before the next round of housing proposals in this area post 2030 the UK Government must act to reduce the excessive human population growth in the Runnymede area and the excessive expansion of the London region I can already see the claims for the forthcoming Planning Inspection and future ones probably by the Housebuilderrsquos Federation and the agents or QCs for the private housebuilding companies (a QC was employed by one developerrsquos agent for the East Hampshire Joint Core Strategy to argue for more housing to be achieved within that area and Local Plan) that people are more important than wildlife and that we must build on the SPAs or very close to them as in the current Runnymede Local Plan This failure to properly mitigate for the development of the so-called Longcross Garden Village is the start of the destruction of one of Britainrsquos best remaining lowland heathland sites A national disgrace

The SLAA 99 proposal and the proposals to remove land from the greenbelt in this Local Plan are as clear evidence of the overpressure of people numbers on the finite land resource of England (ldquoThe UKs population is projected to reach 70 million by 2030 ndash thatrsquos nine million more people than in 2008rdquo Ref Forum for the Future in 2010 ldquoUK population grows by over 400000 in the last year the largest absolute increase of any European countryrdquo Ref Population Mattersrsquo research in August 2013 ldquoEnglandrsquos population is already twice that of Germany per square mile and four times that of France It is our quality of life that is being affectedrdquo Ref Lord Horam speaking in February 2018 in the House of Lordrsquos debate on ldquoBrexit and the labour marketrdquo As the Planning

10

Inspector stated at the commencement of the Inspection of the East Hampshire Joint Core Strategy that I was present at in 2013 ldquoI have been given a growth agendardquo With this type of pressure by the UK Government I am not sure that I or nature conservation can expect a fair and objective hearing in 2018 when I object to Runnymede Borough Councilrsquos Local Plan 2030 we will see

7 For the proximity of the DERA South development to the SPA site of Chobham Common there is one potential solution and that is to reduce the number of houses in the DERA South (Longcross Garden Village) proposal and to make a new large SANG out of the land at the western end of the DERA South site This would require the ldquoDuty of Cooperationrdquo to be observed as the extreme west end of the DERA South site as it is within the land area of Surrey Heath Borough Council but I am sure this could be achievable This area would have to be fenced with dense mesh topped with rolled razor wire or similar to prevent free roaming dogs and cats from going onto the Chobham Common site south of the M3 and B386 roads If this fence was sufficiently high and doubled up to make two fences these could be used to keep the public and their animals away from and out of the SPA of Chobham Common and also necessarily to confine the loose running dogs a requirement for SANGS from being run-over on the B386 and the other connecting roads

8 The SPD issued and adopted by Surrey Heath Borough Council states I paragraph 57 ldquoIn the period up to 2028 Surrey Heath is expected to grant planning permission for 324010 new homes and this will require the provision of over 60 hectares of SANG Major or large new developments will be expected to provide bespoke on-site SANG rather than relying on the suite of SANGs being developed by the Borough Councilrdquo SLAA 99 is a large development so it should lose some of its housing land to provide on-site SANG to separate itsrsquo housing provision from Chobham Common

Similarly for Runnymede a large amount of new homes will result from the conclusions of the Planning Inspection Almost certainly more than proposed at the moment (this was the experience in East Hampshire in 2013) In this case and similar to the proposals adopted for SLAA 97 SANG provision for SLAA 99 (which appears to be scheduled to provide

11

the largest number of homes and something like 7000 extra people in Runnymede Borough) the SANG needs to be onsite and the solution I propose in this paragraph would cater for this Hoping new residents will all get in their cars to take the dog or cat for a walk over one mile away on Trumps Farm is not sustainable practicable or likely AECOMrsquos HRA and AA of both May and December 2017 completely fail to address the roaming catrsquos issue Despite AECOMrsquos clearly different point-of-view I do not believe that Runnymede Borough Council in their role as lsquocompetent authorityrsquo can conclude that no adverse effect on the integrity of internationally important wildlife sites of the Thames Basin Heathrsquos SPA will result from their proposals in their Local Plan 2030 as a consequence of what I consider are flawed conclusions proposed by AECOM The only light at the end of the tunnel of flawed conclusions in my opinion by AECOM is their final paragraph in the Dec 2017 HRA and AA that at paragraph 93 ldquoHowever it is recommended that the potential for further bespoke or strategic SANG later in the plan period is explored by the Council in time for Examination in Publicrdquo

I suggest to the Planning Inspector and Runnymede Borough Council that an on-site large SANG at the west end of the DERA South site should be provided as greenspace which would help to alleviate the potential for disturbance by residents of the new garden village from having to go or preferring to go to Chobham Common with the dog because this SANG site would be nearer Housing development adjacent to heathland always damages it especially if local arsonists are imported nearby but my proposals would go a long way to making the proposed Local Plan sound Though it would be far better if this garden village was scrapped and the DERA South site restored to heathland or just converted to another employment site as that would do far less damage to the Chobham Common SSSI and SPA site

____________________

Stephen R Miles 21st February 2018

From Caroline CravenTo Planning PolicySubject Representation for Local PlanDate 22 February 2018 092519Attachments Representation_form_for_Regulation_19_Caroline_Cravendocx

Please find attached my representation form in response to the Runnymede 2030 Local PlanConsultation

Regards helliphellip Caroline Craven

1886

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full contact details of the agent in 2

Part B (1) ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

XParagraph PolicyPolicies Map

X

X

X

4 Do you consider the Local Plan is

x

4 (1) Legally compliant Yes No

X

4 (2) SoundYes No

x

4 (3) Complies with the Duty to co-operateYesNo

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the duty to co-operate please also use this box to set out your comments

I believe the Local Plan does not comply with the duty to co-operate with neighbouring Boroughs The previous version was not deemed to be compliant as I understand it and there does not appear to be any significant changes that allow this plan to be compliant

RBC seems to have relied on the former Statement of Community Involvement (SCI) of 2014 In a digital age 15 lines in a local (The Villager Feb 9th) on page 11 is a poor means of communication to the Runnymede Borough residents on something that will affect them so deeply

In addition the views expressed at the RBC meeting by the attending RBC councillors were essentially that they accepted it wasnrsquot as good as it should be but was lsquothe best wersquore going to get at the momentrsquo and if not submitted then a Government Inspector would be appointed and they would lose control ndash a view I can fully understand but does not give the Runnymede residents a feeling of confidence in the legality or the integrity of the plan nor that the council truly want the best for the Borough

With regard to the Longcross site improvements to the station do not address the capacity issue The impact to commuters further up the line will be significant Peak times will be heavily impacted If additional trains are being proposed on this line the impact to the residents of Egham who already have to wait some 35-40 minutes in the hour whilst gates are down would therefore have even less opportunity to transverse the line at the crossing points Longcross station has no accessible car parking or drop off points This would necessitate commuters travelling to Virginia Water Egham whose own parking capability is limited Virginia Water has lost a large number of station car park spaces due to a new development This would also cause increased congestion in already known problem junctions The additional burden to the A320 which is already operating over practical capacity at several junctions and expected to deteriorate over the coming years would be significant (A320 Corridor Study ndash Feasibility Study ndash Interim report February 2018)

(Continue on a separate sheetexpand box if necessary)

The Longcross site will also need medical facilities ndash GPrsquos and potentially NHS drop in centre to ensure the current burden on the NHS is not exacerbated

With regard to the Traveller pitches they appear to amount to 35 within the scope of the development areas However the council plan to deliver 131 net additional plotspitches ndash 96 of which are not covered in this local plan This is an extremely emotive subject and needs to be identified properly in the plan and not almost hidden to avoid confrontation with angry residents that this County is already over run with these communities Integration with new developments is not the answer ndash Allocation of Traveller sites and pitches is according to the Government guidelines ldquoinappropriate within the Green beltrdquo and trying to slide this surreptitiously into new developments is a totally inappropriate solution

The Hurst Lane development was dismissed by the Council despite the residents being on board and a sustainable and acceptable plan being put forward for c 800-1000 homes on 80 -100 acres Over time this Lane has deteriorated to the point that Planning Inspectors described it as an lsquoindustrial wastelandrsquo In addition the Council resources are being tied up with the numerous issues generated by the Lane and the inability to resolve with the resources available The primary reason given is that the land is lsquoGreen Beltrsquo although under exceptional circumstances (which I believe this would come under) the council are able to and plan to in other areas use this land It is effectively a brownfield site which could be permitted fi connected to a SANG trade off which the residents plan was

6 Please set out what modification (s) you consider necessary to make the Local Plan legally compliant or sound having regard to the Matter you have identified at 5 above where this relates to soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of modification at examination) You will need to say why this modification will make the Local Plan legally compliant or sound It will be helpful if you are able to put forward your suggested revised wording of any policy or text Please be as precise as possible

For the plan to be sound I believe that

1) Review the inclusion of the Hurst Lane site ndash SLAA 59 ndash within the plan Appendix B states the capacity of 10 for Hurst Lane and 5 for Padd Farm If this relates to additional properties the number does not reflect the plans of up to 800 houses Access and infrastructure are addressed and the reduction in headcount in the councilrsquos Customer Services (I believe there is a dedicated resource looking after Padd Farm Hurst Lane) would be an additional benefit

2) Greater publicity is required over the consultation process The council appear to work on a lsquopullrsquo basis in that residents of the borough (other than those in the Residents Associations) have to actively seek out any updates from the council Local newspapers are not a good way of disseminating information in the digital age

3) Identify the additional travellergypsy site plans and move outside of the Green Belt area

If these steps were taken the residents would all have ample opportunity to contribute to the development of the local plan

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further representations based on the original representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

7 If your representation is seeking a modification do you consider it necessary to participate at the oral part of the examination

No I do not wish to participate Yes I wish to participate

X

at the oral examinationat the oral examination

8 If you wish to participate at the oral part of the examination please outline why you consider this to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who have indicated that they wish to participate at the oral part of the examination

9 Signature Date

21st February 2018

Caroline Craven

Notes to Accompany Model Representation Form

1 Introduction

11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 2004[footnoteRef1] (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound [1 View at httpwwwlegislationgovukukpga20045contents ]

2 Legal Compliance and Duty to Co-operate

21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness

22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)[footnoteRef2] it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices [2 LDDs are defined in regulation 5 ndash see link below ]

bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications

bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)[footnoteRef3] On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified [3 View at httpwwwlegislationgovukuksi2012767contentsmade ]

bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy)

23 You should consider the following before making a representation on compliance with the duty to co-operate

bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty

bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

3 Soundness

31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy

bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development

bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence

bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities

bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF

32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations

bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included

bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan

bull If the policy is not covered elsewhere in what way is the plan unsound without the policy

bull If the plan is unsound without the policy what should the policy say

4 General advice

41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

6

image1png

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full contact details of the agent in 2

Title Mrs First Name Caroline Last Name Craven Job Title (where relevant)

Organisation (where relevant)

Address Line 1 Southover Line 2 Hurst Lane Line 3 Egham Line 4 Surrey Post Code TW20 8QJ Telephone Number Email Address (where relevant)

2

Part B (1) ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

XParagraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails to comply with the duty to co-operate Please be as precise as possible If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

X X X

x

X

x

I believe the Local Plan does not comply with the duty to co-operate with neighbouring Boroughs The previous version was not deemed to be compliant as I understand it and there does not appear to be any significant changes that allow this plan to be compliant

RBC seems to have relied on the former Statement of Community Involvement (SCI) of 2014 In a digital age 15 lines in a local (The Villager Feb 9th) on page 11 is a poor means of communication to the Runnymede Borough residents on something that will affect them so deeply

In addition the views expressed at the RBC meeting by the attending RBC councillors were essentially that they accepted it wasnrsquot as good as it should be but was lsquothe best wersquore going to get at the momentrsquo and if not submitted then a Government Inspector would be appointed and they would lose control ndash a view I can fully understand but does not give the Runnymede residents a feeling of confidence in the legality or the integrity of the plan nor that the council truly want the best for the Borough

With regard to the Longcross site improvements to the station do not address the capacity issue The impact to commuters further up the line will be significant Peak times will be heavily impacted If additional trains are being proposed on this line the impact to the residents of Egham who already have to wait some 35-40 minutes in the hour whilst gates are down would therefore have even less opportunity to transverse the line at the crossing points Longcross station has no accessible car parking or drop off points This would necessitate commuters travelling to Virginia Water Egham whose own parking capability is limited Virginia Water has lost a large number of station car park spaces due to a new development This would also cause increased congestion in already known problem junctions The additional burden to the A320 which is already operating over practical capacity at several junctions and expected to deteriorate over the coming years would be significant (A320 Corridor Study ndash Feasibility Study ndash Interim report February 2018)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally compliant or sound having regard to the Matter you have identified at 5 above where this relates to soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of modification at examination) You will need to say why this modification will make the Local Plan legally compliant or sound It will be helpful if you are able to put forward your suggested revised wording of any policy or text Please be as precise as possible

For the plan to be sound I believe that

1) Review the inclusion of the Hurst Lane site ndash SLAA 59 ndash within the plan Appendix B states the capacity of 10 for Hurst Lane and 5 for Padd Farm If this relates to additional properties the number does not reflect the plans of up to 800 houses Access and infrastructure are addressed and the reduction in headcount in the councilrsquos Customer Services (I believe there is a dedicated resource looking after Padd Farm Hurst Lane) would be an additional benefit

2) Greater publicity is required over the consultation process The council appear to work on a lsquopullrsquo basis in that residents of the borough (other than those in the Residents Associations) have to actively seek out any updates from the council Local newspapers are not a good way of disseminating information in the digital age

3) Identify the additional travellergypsy site plans and move outside of the Green Belt area

If these steps were taken the residents would all have ample opportunity to contribute to the development of the local plan

The Longcross site will also need medical facilities ndash GPrsquos and potentially NHS drop in centre to ensure the current burden on the NHS is not exacerbated

With regard to the Traveller pitches they appear to amount to 35 within the scope of the development areas However the council plan to deliver 131 net additional plotspitches ndash 96 of which are not covered in this local plan This is an extremely emotive subject and needs to be identified properly in the plan and not almost hidden to avoid confrontation with angry residents that this County is already over run with these communities Integration with new developments is not the answer ndash Allocation of Traveller sites and pitches is according to the Government guidelines ldquoinappropriate within the Green beltrdquo and trying to slide this surreptitiously into new developments is a totally inappropriate solution

The Hurst Lane development was dismissed by the Council despite the residents being on board and a sustainable and acceptable plan being put forward for c 800-1000 homes on 80 -100 acres Over time this Lane has deteriorated to the point that Planning Inspectors described it as an lsquoindustrial wastelandrsquo In addition the Council resources are being tied up with the numerous issues generated by the Lane and the inability to resolve with the resources available The primary reason given is that the land is lsquoGreen Beltrsquo although under exceptional circumstances (which I believe this would come under) the council are able to and plan to in other areas use this land It is effectively a brownfield site which could be permitted fi connected to a SANG trade off which the residents plan was

4

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further representations based on the original representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

7 If your representation is seeking a modification do you consider it necessary to participate at the oral part of the examination

No I do not wish to participate Yes I wish to participate at the oral examination at the oral examination

8 If you wish to participate at the oral part of the examination please outline why you consider this to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who have indicated that they wish to participate at the oral part of the examination

9 Signature Date

X

Caroline Craven 21st February 2018

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan 1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination 42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

FromPolicy

Subject FW New Housing Plans 2015-2030Date 21 February 2018 164919

Sent 21 February 2018 1608To PlanningSubject New Housing Plans 2015-2030

To

Policy Planning and Strategy Team

Runnymede Borough Council

Station Road

Addlestone

21022018

Dear Sirs

As an Ottershaw resident of nearly 30 years i would like you to read and take on board my objections to yourproposal to take land out of the green belt for housing and your plan to build so many houses in ourcommunity

Of course new houses have to be built right across the country now and in the future but i feel the plans youhave are for far too many houses The infrastructure of our community will just not sustain the extra amount ofpeople and cars and the general traffic that would entail

There are other possibilities available before your irreversible plans are put into action Are these possibilitiesbeing resourced

When i drive around the borough now and for a long long time i see so many empty office blocks Some ofthese have stood empty for yearsWhy has permission been given continuosly from what i can see on a huge scale for these to be built

This building of offices has to stop and the ones that have remained empty for years could be converted tohousing as in flats starter homes for young people

If Planning Practice Guidlines state that the use of Green Beltshould only occur in very special circumstances these and the Brownfield sites in Runnymede must be extensively researched

I live in Wilson Drive and for many years now when i leave my house to go into the village or elsewhere thereis often gridlock in every direction The roads in our community are so heavily used by cars and lorries headingtoward the M25 Can you imagine the impact so many more of these will bring Driving has not been a pleasurefor a long time and i do walk wherever possible Parking is a problem in the village as so many people use theone car park I believe there may be a plan in the pipeline to even get rid of that for road widening

We have a GP practice in the village that is getting harder to book an appointment for also i have been waitingmonths for an appointment at St Peters hospital and just keep getting apologetic letters

Quality of life is very important for your residents and that quality has already deteriorated lately

1888

In order to accomodate so many new residents you will be making the ones you have feel very disappointedand frustated that no one listens

There is no going back once the desicion has been made and so many houses built Please take my feelings and iam sure very many more residents comments and pleas into account before you make the irreversible decisionto go ahead with your plans

Yours Faithfully

Margaret Wensley and the Wensley family

Beechwood

Wilson Drive

Ottershaw

Surrey

KT16 0NT

----------- middotn==middot =

Planning Services

DELIVERED BY HAND

Runnymede Borough Council ~--------------=-middot ---------middot------~

Planning Dept Runnymede Borough Council Civic Offices Station Road Addlestone KT15 2AH

Dear Sirs

Catherine Brunton-Green 20The Glen Addlestone

KT151AQ

15th February 2018

Runnymede Draft local Plan 2015- 2030- Final Consultation

I have serious concerns in respect of this draft plan Runnymede Borough Council (RBC) have a duty of care to consult with listen and act upon the wishes of its residents There has been some consultation but this has not effectively reached all Runnymede residents Communication is unnecessarily legally complex and full of unexplained acronyms The basic Runnymede Voice delivered to every home has been abandoned There has been no flyer delivered to every home stating in a simplified way what is happening so that all abilities may be catered for Many people are isolated for numerous reasons and do not have internet access Neither is there evidence of full in depth cross boundary consultation with adjacent boroughs This local plan is driven primarily by a developers charter promoted by RBCS Head of Planning It is both unfair unjust and I question its soundness

The Strategic Housing Market Assessment has not taken leaving the EU into account and makes a blanket assumption on Heathrow expansion

I strongly object to the proposed loss of c 560 acres of Green Belt Our Prime Minister and government have recently stated that they are quote committed to protecting and enhancing our natural environment for successive generations therefore Green Belt land would only be lost as a last resort 11

bull Detailed evidence based research by The Council for The Protection of Rural England confirms that by fully utilising brownfield land 12 million homes could be built in London and the South East without the loss of any Green Belt

I have objection to building on the Veterinary Laboratory Green Belt Land Parcel BRow Town (Policy SL11 8283) is not justified for development This is designated for 150 additional dwellings and 2 gypsyTraveller pitches This site provides a natural demarcation between developments either side Designated SANG area is privately owned and not available The density of proposed build is unacceptable and above all an area of outstanding natural beauty would be destroyed

Our infrastructure is unable to cope at present A320 suffers perpetual gridlock now Equally gridlock is evidenced through Ottershaw Addlestone Station Road and A317 Addlestone Weybridge We already have unhealthily dangerous levels of roadside nitrogen dioxide concentrations in many areas such as Station Road RBC has made a lame submission in respect of

tackling roadside nitrogen dioxide concentrations in the South East (UK00310) Incidence of exacerbated breathing illnesses in this vicinity has increased dramatically in the past 7 years All age groups are affected

All GP surgeries across Runnymede have great difficulty in recruiting doctors Two practices in the immediate area are merging due to unprecedented numbers of doctors leaving and retiring Practice lists and capacity is stretched Patient access to services and patient safety has to be the highest priority Our schools are similarly affected

RBC infrastructure is totally reliant upon Surrey County Council who declare they are not in a financial position to fund the necessary support to develop the infrastructure for this Local Plan

I am prepared to speak at Public Enquiry

Yours faithfully

bull i I I bull bull

From Brian PickettTo Planning PolicySubject Runnymede 2030 Local Plan - submission of viewsDate 22 February 2018 090921Attachments Ottershaw development Objection letter February 2018docx

Please find attached the submission of my views on the Runnymede 2030 LocalPlan

Kind RegardsBrian Pickett

1891

planningrunnymedegovuk planningrunnymedegovuk

21022018

Re Runnymede 2030 Local Plan Ottershaw East ndash Objection to planning

Dear Sirs

We are writing to you again as we strongly object to the Runnymede Borough Councils plans to remove land behind houses along Brox Road known as lsquoOttershaw Eastrsquo from the Green Belt We are objecting for a number of reasons listed below

middot The Green Belt is precious once it is gone it is gone forever The removal of this land from the Green Belt does not comply with Planning Policy which states ldquothat Green Belt boundaries should only be altered in exceptional circumstancesrdquo there are no such circumstances that can justify the removal of this piece of land

middot The Green Belt should be an area that is preserved for future generations to enjoy and appreciate and many statements have been made by both the Government and members of Parliament on their commitment to protect the Green Belt ndash these statements now need to be converted into action in the Local Borough Plans The roll out of Green Belt to local councils in the 1950rsquos was to prevent urban sprawl and the merging of settlements thereby helping to preserve and protect the character of communities it encompassed protect the country setting and encourage development through regeneration of sites within towns and cities not villages

middot The description of Ottershaw by the council itself in the lsquoUrban Characteristicsrsquo publication on the Runnymede Borough Council website states ldquoOttershaw has its own identity and sense of place which is partly derived from the clearly identifiable heart of the urban area focused on The Otter and adjoining local shopping parade and community facilities as well as being surrounded by open greenbelt countryside Removing this green belt that is part of the identifiable heart of Ottershaw would destroy this villagersquos identity and community

middot The planning proposals and building on this part of the green belt land would lead to a considerable population increase in the village Services and facilities will struggle or fail to cope space is already limited at the doctorrsquos surgery and school places are at capacity The transport infrastructure is already stretched with limited bus services busy roads poorly maintained pavements and road surfaces Brox road is already used as a shortcut to avoid traffic congestion Given that Ottershaw does not have a train station it is reasonable to assume that the majority of houses would have at least one car the added traffic from the new development would put a severe strain on the road network and users Available information on mitigation is very vague and very open to interpretation and misguided assumptions

middot The Green Belt land is a habitat to an array of plants and animals including important pollinator species and larger animals such as birds foxes and deer There should be no assumption that animals will simply move to another area habitats are established over many years and this development will be another loss to the maintenance of biodiversity I enjoy the fauna and flora in these areas going for walks along the public footpaths Having such wonderful access to a relaxing escape so close to home is priceless and something I hold dear to myself my family and community What is now a beautiful scenic view will become a spoilt urban sprawl of modern housing

middot I moved to Ottershaw with my wife in 2016 to settle down and start a family The relaxed quiet village sense of community and safety surrounded by beautiful countryside were its appeal I are very concerned and disappointed that this planning proposal is still being considered which will undoubtedly destroy this idyllic setting

There are no ldquoexceptional or very special circumstancesrdquo that justify the removal of Ottershaw East from the Green Belt We trust that the Council will therefore not remove ldquoOttershaw Eastrdquo and ldquoThe Fieldrdquo from the Green Belt

Yours faithfully

Dr Brian Pickett

To Policy Planning and Strategy Team Runnymede Borough Council Civic Centre Station Road Addlestone Surrey KT15 2AH planningrunnymedegovuk

From Dr Brian Pickett 139 Brox Road Ottershaw Surrey KT16 0LG planningrunnymedegovuk

21022018 Re Runnymede 2030 Local Plan Ottershaw East ndash Objection to planning Dear Sirs We are writing to you again as we strongly object to the Runnymede Borough Councils plans to remove land behind houses along Brox Road known as lsquoOttershaw Eastrsquo from the Green Belt We are objecting for a number of reasons listed below bull The Green Belt is precious once it is gone it is gone forever The removal of this

land from the Green Belt does not comply with Planning Policy which states ldquothat Green Belt boundaries should only be altered in exceptional circumstancesrdquo there are no such circumstances that can justify the removal of this piece of land

bull The Green Belt should be an area that is preserved for future generations to enjoy

and appreciate and many statements have been made by both the Government and members of Parliament on their commitment to protect the Green Belt ndash these statements now need to be converted into action in the Local Borough Plans The roll out of Green Belt to local councils in the 1950rsquos was to prevent urban sprawl and the merging of settlements thereby helping to preserve and protect the character of communities it encompassed protect the country setting and encourage development through regeneration of sites within towns and cities not villages

bull The description of Ottershaw by the council itself in the lsquoUrban Characteristicsrsquo

publication on the Runnymede Borough Council website states ldquoOttershaw has its own identity and sense of place which is partly derived from the clearly identifiable heart of the urban area focused on The Otter and adjoining local shopping parade and community facilities as well as being surrounded by open greenbelt countryside Removing this green belt that is part of the identifiable heart of Ottershaw would destroy this villagersquos identity and community

bull The planning proposals and building on this part of the green belt land would lead

to a considerable population increase in the village Services and facilities will struggle or fail to cope space is already limited at the doctorrsquos surgery and school places are at capacity The transport infrastructure is already stretched with limited bus services busy roads poorly maintained pavements and road surfaces Brox road is already used as a shortcut to avoid traffic congestion Given that Ottershaw does not have a train station it is reasonable to assume that the majority of houses would have at least one car the added traffic from the new development would put a severe strain on the road network and users Available information on mitigation is very vague and very open to interpretation and misguided assumptions

bull The Green Belt land is a habitat to an array of plants and animals including important pollinator species and larger animals such as birds foxes and deer There should be no assumption that animals will simply move to another area habitats are established over many years and this development will be another loss to the maintenance of biodiversity I enjoy the fauna and flora in these areas going for walks along the public footpaths Having such wonderful access to a relaxing escape so close to home is priceless and something I hold dear to myself my family and community What is now a beautiful scenic view will become a spoilt urban sprawl of modern housing

bull I moved to Ottershaw with my wife in 2016 to settle down and start a family The

relaxed quiet village sense of community and safety surrounded by beautiful countryside were its appeal I are very concerned and disappointed that this planning proposal is still being considered which will undoubtedly destroy this idyllic setting

There are no ldquoexceptional or very special circumstancesrdquo that justify the removal of Ottershaw East from the Green Belt We trust that the Council will therefore not remove ldquoOttershaw Eastrdquo and ldquoThe Fieldrdquo from the Green Belt Yours faithfully Dr Brian Pickett

FromTo Planning PolicySubject Runnymede Local Plan 2030 - consultation responseDate 21 February 2018 163608Attachments Runnymede LP Response - EE15pdf

Please find attached a consultation response form

________________________________________Christian Leigh BSc(Hons) MPhil MRTPIDirectorLeigh amp Glennie Ltd6 All Souls RoadAscotBerkshire SL5 9EA

1893

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number 01344 297094 Email Address (where relevant)

mailchristianleighcouk

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number Email Address (where relevant)

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

From MCNAB DouglasTo Planning PolicySubject Runnymede Draft Local Plan consultation - Representation from Education and Skills Funding AgencyDate 21 February 2018 091407Attachments Runnymede Reg 19 response ESFADOC

Dear Runnymede Planning Policy Team

Please see attached a representation from the Education and Skills Funding Agency on theRunnymede Local Plan consultation

I would be grateful if you could confirm receipt

Best regardsDoug

Douglas McNab MRTPIForward Planning Manager ndash South East

Planning Team Free Schools CapitalEducation and Skills Funding AgencyDepartment for Education 5th floor Sanctuary Buildings 20 Great Smith Street London SW1P 3BT

Email douglasmcnabeducationgovukMobile 07990 082877Web wwwgovukesfa

1895

image1pngOur Ref ESFALocal PlanRunnymede 2018 21st February 2018

Dear SirMadam

Re Runnymede Local Plan

Consultation under Regulation 19 of Town and Country Planning (Local Planning) (England) Regulations 2012

Submission of the Education and Skills Funding Agency

1 The Education and Skills Funding Agency (ESFA) welcomes the opportunity to contribute to the development of planning policy at the local level

2 The ESFA launched on 1st April 2017 bringing together the existing responsibilities of the Education Funding Agency (EFA) and the Skills Funding Agency (SFA) to create a single funding agency accountable for funding education and training for children young people and adults The ESFA are accountable for pound61 billion of funding a year for the education and training sector including support for all state-provided education for 8 million children aged 3 to 16 and 16 million young people aged 16 to 19

3 Under the provisions of the Education Act 2011 and the Academies Act 2010 all new state schools are now academiesfree schools and the ESFA is the delivery body for many of these rather than local education authorities As such we aim to work closely with local authority education departments and planning authorities to meet the demand for new school places and new schools We do this through a variety of means including by supporting the adoption of sound local plan policies site allocations and guidance (all based on robust evidence) that facilitate the delivery of education infrastructure where and when it is needed and maximise developer contributions for schools In this capacity we would like to offer the following comments in response to the proposals outlined in the above consultation document

Comments on the Local Plan

4 As you will be aware the primary focus at this stage of the Local Planrsquos preparation is on the soundness of the plan with regard to it being positively prepared justified effective and consistent with national policy The following detailed comments set out the ESFArsquos view of the planrsquos soundness in respect of education provision

5 The ESFA notes that the local plan will make provision for a minimum of 7413 net additional dwellings over the plan period Development will generally complement the existing settlement pattern focusing the largest amounts of residential growth primarily in Chertsey (1950 homes) Addlestone (936 homes) and Egham (812 homes) A new ldquolocally led garden villagerdquo is also proposed at Longcross providing a further 1718 homes This level of development will put pressure on existing education infrastructure

6 The plan recognises that ldquoIt is important that infrastructure is delivered in a timely manner to ensure that the needs of the occupiers of new development can be met without placing undue burdens on existing infrastructure facilities and servicesrdquo (para 560) The ESFA supports Policy SD6 Infrastructure Provision amp Timing particularly the signposting of the Infrastructure Delivery Plan (IDP) and the need for development to deliver this either on-site or through s106 or CIL financial contributions off-site and the need for development to be phased in line with the provision of important supporting infrastructure

7 The latest version of the IDP states that there is an ongoing programme of primary school expansions this will help to meet the forecast need for 4-6FE of new capacity over the plan period The need for one new build school project is identified a 2FE primary school at the Longcross Garden Village (estimated cost pound99M to pound15M) this is referred to in the site allocation policies (see below) With respect to secondary school places it is anticipated that up to six additional FE could be required in the Borough by 2021 Additional places will be delivered through the new 6FE Runnymede Free School (which opened in temporary accommodation in 2017) development of additional FE within Salesian School (Catholic faith school) and expansion of another school in the Chertsey area (to accommodate demand from generated by the Longcross Garden Village site)

8 It would be useful if the background data informing these projections of need could be clarified particularly the pupil yield factors used and the evidence base supporting this This would help to demonstrate more clearly to the Inspector that the approach to the planning and delivery of education infrastructure has been positively prepared based on a strategy which seeks to meet objectively assessed infrastructure requirements and is justified based on proportionate evidence The ESFA notes that the Runnymede S106 SPG sets out pupil yield figures however this document dates from December 2007 so the figures may be outdated

9 The ESFA supports the Councilrsquos allocation and safeguarding of land for schools as set out in the following policies

middot Policy SD10 Longcross Garden Village - 2FE primary school with preschoolearly years settings

middot Policy SL2 to SL18 ndash series of housing allocation policies that highlight the need to make a financial contribution to early years primary and secondary school infrastructure ldquoeither through S106 or CIL (or its successor)rdquo

Developer Contributions and CIL

10 One of the tests of soundness is that a Local Plan is lsquoeffectiversquo ie the plan should be deliverable over its period In this context and with specific regard to planning for schools there is a need to ensure that education contributions made by developers are sufficient to deliver the additional school places required to meet the increase in demand generated by new developments The ESFA notes that the council has not adopted CIL and that the Planning Obligations SPG sets out how developer contributions to education provision will be secured via section 106 agreements The ESFA supports the Councilrsquos approach to ensure developer contributions address the impacts arising from growth However the ESFA recommends that the Local Plan includes a commitment to revise the Planning Obligations SPG in line with the latest evidence of the boroughrsquos infrastructure needs pupil yields and build costs (including the cost of school expansion new build and SEN provision) Any such review should be prepared in consultation with the county council as local education authority This will help to ensure appropriate rates are levied and the right infrastructure is secured across the borough

11 The ESFA would be particularly interested in responding to any update to the Infrastructure Delivery Plan or review of infrastructure requirements As such please add the ESFA to the database for future CIL consultations

Forward funding

12 In light of the proposed Longcross Garden Village emerging ESFA proposals for forward funding schools as part of large residential developments may be relevant for example if viability becomes an issue The ESFA aims to be able to clarify forward funding options for schools in 2018 We would be happy to meet to discuss this opportunity further once the options have been finalised and ifwhen relevant Any offer of forward funding would seek to maximise developer contributions to education infrastructure provision while supporting delivery of schools where and when they are needed

Conclusion

13 Finally I hope the above comments are helpful in finalising the Runnymede Local Plan with specific regard to the provision of land for new schools

14 Please notify the ESFA when the Local Plan is submitted for examination the Inspectorrsquos report is published and the Local Plan is adopted

15 Please do not hesitate to contact me if you have any queries regarding this response The ESFA looks forward to continuing to work with Runnymede Borough Council to develop a sound Local Plan that will aid in the delivery of new schools

Yours faithfully

DC McNab

Douglas McNab MRTPI

Forward Planning Manager

Tel 07990 082877

Email

douglasmcnabeducationgovuk

Web

wwwgovuk esfa

Education and Skills Funding Agency13

Department for EducationSanctuary BuildingsGreat Smith StreetLondonSW1P 3BT13

13

Tel 0207 340 700013

13

wwwgovukesfa13

13

13

To

Policy Planning and Strategy Team

Runnymede Borough Council

Civic Centre

Station Road

Addlestone

Surrey

KT15 2AH

From

Dr Brian Pickett

139 Brox Road

Ottershaw

Surrey

KT16 0LG

Title

Mrs

First Name

Caroline

Last Name

Craven

Job Title

(where relevant)

Organisation

(where relevant)

Address Line 1

Southover

Line 2

Hurst Lane

Line 3

Egham

Line 4

Surrey

Post Code

TW20 8QJ

Telephone Number

07770999572

Email Address

(where relevant)

Carolinecraven911hotmailcom

Page 7: Runnymede Borough Council, for submissions. My contact details are all in the WORD letter attached. But I will provide my telephone number here too, which …

4

close to the ground and are also susceptible to disturbance however they are more vulnerable to other effects of urbanisation in particular predation by catsrdquo (Stated in Thames Basin Heaths Special Protection Area Mitigation Standards for Residential Development dated 26 May 2006) It is loose and uncontrolled dogs that disturb ground nesting birds by forcing them to leave their nestschicks unattended allowing predatorrsquos access to predate and kill them

AECOM The Secretary of State for the Department of Homes and Communities (producers of the Application Guidance for so-called Garden Villages) The Ministry of Defence in the form of the Defence Infrastructure Organisation (as site owner) and Runnymede Borough Council are all wrong in knowingly promoting the Longcross Garden Village (SLAA 99 site) for residential development and for proposing just too many homes on it when it is immediately adjacent to Chobham Common and thus in a sensitive location to peoplersquos leisure activities

This site has already been damaged in recent years since Natural England determined that all National Nature Reserves should become ldquoaccessrdquo areas for people Consequently many of the bare soil tracks that previously supported insect species named in the original SSSI citation have been hard surfaced for people damaging populations of species like the Mottled Bee-fly With the DERA South proposals there is the very real danger that the whole Chobham Common site ends up being managed for peoplersquos leisure instead of itsrsquo special wildlife for which it is internationally designated Policies SD4 and especially SD10 by encouraging cycling on Chobham Common will be particularly damaging as this activity results in the continuous churning up of bare ground tracks and footpaths to the detriment of the invertebrates and sand lizards that nest in the bare sandy ground of lowland heathlands These species need the holes they dig as breeding sites to remain accessible each summer cycling by humans destroys this But of course AECOM do not know about this as they are not proper heathland ecologists

In AECOMrsquos paras 817 and 818 of the May 2017 HRA they are clearly ignoring the local geography with the Trumps Farm SANG site being only adjacent to the most easternmost housing of this DERA South

5

development site For those dwellings proposed for the western and middle parts of this development site Chobham Common is immediately adjacent Nowhere in the documents provided by Runnymede Borough Council or AECOM or in paragraphs 818 or 819 is it explained what will cause new residents of the dwellings proposed to be built on the SLAA 99 site adjacent to Chobham Common to get into their cars to travel east for approximately 15 miles or nearly 2 kilometres away with their dogs to reach the proposed Trumpsrsquo Farm SANG Equally nor is it explained how roaming cats will be stopped from crossing the B386 and visiting Chobham Common when their homes are right next door or very close to the dry lowland heathland of Chobham Common Paragraph 835 of the AECOM AA informs us that the development site at DERA South will be as close as 280m to the SPA yet the nearest the proposed SANG to be used to divert new residents away from the SPA is over 1km to 15km to the east So I repeat how will this development stop the occupants from walking the shorter distance to take both themselves and their dogs or allow their roaming cats especially of a night via cat-flaps onto Chobham Common In their evidence to the Surrey Heath Borough Council Local Plan in 2011 RSPB pointed out that domestic cats may range beyond any 400m buffer that is set up so fencing of any on-site SANG provision as well as fencing in any adjacent housing built up to the 400m buffer and within at least half a mile distance from the start of the public access to the Chobham Common site at Ordnance Survey Grid Reference SU979651 is essential

Para 416 of AECOMrsquos AA states that ldquothe Delivery Framework continues to restrict all new residential development within an area some 400 metres from the boundary of the TBH SPArdquo If this is the case with SLAA 99 that housing will be kept at 400m from Chobham Common this is still too near because people will go the shorter distance and on sunny weather days as is promoted by so many organisations for peoplersquos well-being which is also mentioned in Section 6 under Supporting Local People and Health amp Wellbeing of the Local Plan Thus they will walk straight out onto Chobham Common adding to the high numbers of people already visiting this site and damaging it by their presence this is unacceptable

Noting AECOMrsquos paragraph 810 ldquoThe Thames Basin Heaths SPA is considered sensitive to the effects of recreational disturbance Natural England considers that the threat of development pressure particularly

6

housing on neighbouring land and preferred sites within 5km results in increased recreational use of this site and has potential to disturb bird feeding and breeding behaviourrdquo These pathways to damage in AECOMrsquos so-called Appropriate Assessment are then conveniently screened out just because there is a Runnymede Policy to provide SANG as related to the TBH Delivery Framework The fact that Trumps Farm is in the wrong place to provide effective green space as mitigation in paragraphs 863 to 868 of AECOMrsquos conclusions as an alternative for peoplersquos recreation with their dogs is wrong Also the effect of roaming cats is completely ignored by this organisation so that any cats present in the 1750 nearby proposed dwellings will be at liberty to kill the Annex 1 birds present on the adjoining Chobham Common as well as the reptiles and amphibians they encounter

The dictionary definition of mitigation is to alleviate diminish or moderate I cannot see how a mitigation site 15 kilometresrsquo away will provide proper mitigation when so many people are being told to forsake their cars and to get out and exercise An on-site SANG must be provided at the west end of the DERA South site where the Longcross Barracks were and the Longcross Garden Village itself must be double fenced at itsrsquo boundary with the B386 road to exclude people and their animals from walking straight out onto Chobham Common if the development of SLAA 99 goes ahead as specified in the Local Plan A large on-site SANG will help reduce lighting spread and other urbanisation effects associated with this development and identified by AECOM elsewhere in their various HRAs for this Local Plan Any visible lighting on Chobham Common SPA will damage this site from their statements I am not sure this fact has registered with AECOMrsquos HRA writers

In the latest version of the AECOM HRA for the Runnymede Local Plan dated December 2017 and taking account of the Conservation of Habitats and Species Regulations 2017 one has to ask what has AECOM and all the promoters of Longcross Garden Village got to hide when the SANG site to divert residents away from the adjacent Chobham Common site within the Thames Basin Heaths SPA is not even mentioned Are Runnymede Borough Council providing a mitigation site or not The Conservation of Habitats and Species Regulations 2017 states in paragraph 63 (5) ldquoIn the light of the conclusions of the assessment and subject to regulation 64 the competent authority may agree to the plan or project only after having ascertained that it will not adversely affect

7

the integrity of the European siterdquo If no named SANG site is to be provided than the competent authority Runnymede Borough Council cannot conclude that no damage will occur to the integrity of the Chobham Common site as a result of the approval of itsrsquo Local Plan in its current format

3 Natural England used to be a proper nature conservation organisation before 2010 before the previous coalition Government of David Cameron and particularly Owen Paterson when Secretary of State for The Environment Food and Rural Affairs from 2012 ruined it and turned into another pro-development organisation negating itsrsquo roles via the 2012 statement that it could no longer campaign to objectively protect wildlife Itsrsquo role always was to shout loudly to protect wildlife and it should in my opinion now be recording objections to stop adverse developments such as SLAA 99 But with AECOMrsquos statement in paragraph 817 of the AECOM June 2016 HRA that Natural England already have an agreement with Crest Nicholson that a ldquowhole site SANG strategy has been agreedrdquo and that an ldquoadverse effect on the integrity on the Thames Basin Heaths would not ariserdquo subject to the delivery of the agreed SANGS shows Natural England has already been compromised in the negotiations Clearly there is a conflict with the statement in paragraph 817 in the summary ldquoLocating housing more than 400m from the SPA boundaryrdquo and para 835 which states that DERA South site is only 280m from the SPA boundary What is not clear from this early HRA and subsequent updated versions by AECOM is whether housing will be developed and established at a point of only 280m or less from the SPA boundary conforming to the boundary of the DERA South site or at the 400m buffer distance Which is it

It is clear that Natural Englandrsquos role in protecting Chobham Common has been compromised already they should be sticking to their 2006 position clearly if this development goes ahead referral to European Courts of Justice is necessary Already before BREXIT is completed the UK Government cannot be trusted to ensure our richest wildlife sites are protected when the same UK Government own ldquobrownfieldrdquo sites such as DERA South adjacent to these SPA sites The HS2 in England proposals and the Gwent Levels development proposals for the M4 in Wales are already evidence of their despicable and cavalier record of

8

damage to Sites of Special Scientific Interest Such damage is not acceptable I urge Runnymede Borough Council and the UK Government to think again about a different policy for this sensitive location of DERA South

4 Natural England should be putting Englandrsquos wildlife considerations first NOT the Governmentrsquos economic development initiatives I ask here that both DEFRA and Natural England intervene in this consultation and the subsequent inspection (as a consequence this objection will be sent to both of them) because the SLAA 99 development proposals and the so-called mitigation make a travesty of nature conservation and will only further damage the Chobham Common SSSI and its wildlife species

5 Clearly AECOMrsquos conclusion with regard to disturbance of the Annex 1 birds on Chobham Common in their paragraphs 863 and 868 of the May 2017 HRA and also in paragraphs 851 to 853 of the December 2017 version is wrong and seriously flawed because it fails to take in the proximity of the DERA South development to the SPA site of Chobham Common Also when the Trumps Farm SANG is over one mile distant and the originally proposed of a 55 hectare woodland SANG mentioned in paragraph 817 of the June 2016 HRA version does not fit to the Natural Englandrsquos preferred SANG size for a large development Nor is a woodland SANG normally safe for women walking alone with a dog the original preference for a SANG was that it should replicate the open nature of the heathland sitesrsquo the public like to use for dog-walking

Runnymede Borough Councilrsquos policy for the provision of SANG is not sufficient for it to work as mitigation it must be easier to get to and access the SANG than the adjoining SPA site and the Trumps Farm site fails in this provision Clearly Natural England and the UK Government are conveniently failing to understand what must be staring them in the face if they were honest that SLAA 99 development proposals will both damage and cause disturbance to the wildlife of Chobham Common As a part of the Thames Basin Heaths SPA and with an agreed Delivery Framework for SANGS in the Thames Basin Area if SLAA 99 is accepted in this Local Plan with the existing SANG proposals this will be unacceptable to me This will then form a part of a complaint to the European Commission as currently we are still subject to the judgements of the European Court of Justice

9

6 AECOMrsquos conclusions in paragraph 865 of the June 2016 HRA 868 of the May 2017 HRA and AA and lastly in paragraphs 851 to 853 of the December 2017 HRA and AA is what you expect from AECOM a complete disregard for the issues based on just a Council policy of the provision of SANG irrespective of itsrsquo location and proximity to the proposed development Equally as the Planning Inspectorate is under the same UK Government ldquocoshrdquo as Natural England to enable the provision of more housing for the so-called housing crisis It is not a shortage of housing that is evident in England it is a clear case of overpopulation with successive governments failing to govern and do anything about excessive breeding of the native human population and uncontrolled inward migration of human numbers into the UK particularly in southern England Before the next round of housing proposals in this area post 2030 the UK Government must act to reduce the excessive human population growth in the Runnymede area and the excessive expansion of the London region I can already see the claims for the forthcoming Planning Inspection and future ones probably by the Housebuilderrsquos Federation and the agents or QCs for the private housebuilding companies (a QC was employed by one developerrsquos agent for the East Hampshire Joint Core Strategy to argue for more housing to be achieved within that area and Local Plan) that people are more important than wildlife and that we must build on the SPAs or very close to them as in the current Runnymede Local Plan This failure to properly mitigate for the development of the so-called Longcross Garden Village is the start of the destruction of one of Britainrsquos best remaining lowland heathland sites A national disgrace

The SLAA 99 proposal and the proposals to remove land from the greenbelt in this Local Plan are as clear evidence of the overpressure of people numbers on the finite land resource of England (ldquoThe UKs population is projected to reach 70 million by 2030 ndash thatrsquos nine million more people than in 2008rdquo Ref Forum for the Future in 2010 ldquoUK population grows by over 400000 in the last year the largest absolute increase of any European countryrdquo Ref Population Mattersrsquo research in August 2013 ldquoEnglandrsquos population is already twice that of Germany per square mile and four times that of France It is our quality of life that is being affectedrdquo Ref Lord Horam speaking in February 2018 in the House of Lordrsquos debate on ldquoBrexit and the labour marketrdquo As the Planning

10

Inspector stated at the commencement of the Inspection of the East Hampshire Joint Core Strategy that I was present at in 2013 ldquoI have been given a growth agendardquo With this type of pressure by the UK Government I am not sure that I or nature conservation can expect a fair and objective hearing in 2018 when I object to Runnymede Borough Councilrsquos Local Plan 2030 we will see

7 For the proximity of the DERA South development to the SPA site of Chobham Common there is one potential solution and that is to reduce the number of houses in the DERA South (Longcross Garden Village) proposal and to make a new large SANG out of the land at the western end of the DERA South site This would require the ldquoDuty of Cooperationrdquo to be observed as the extreme west end of the DERA South site as it is within the land area of Surrey Heath Borough Council but I am sure this could be achievable This area would have to be fenced with dense mesh topped with rolled razor wire or similar to prevent free roaming dogs and cats from going onto the Chobham Common site south of the M3 and B386 roads If this fence was sufficiently high and doubled up to make two fences these could be used to keep the public and their animals away from and out of the SPA of Chobham Common and also necessarily to confine the loose running dogs a requirement for SANGS from being run-over on the B386 and the other connecting roads

8 The SPD issued and adopted by Surrey Heath Borough Council states I paragraph 57 ldquoIn the period up to 2028 Surrey Heath is expected to grant planning permission for 324010 new homes and this will require the provision of over 60 hectares of SANG Major or large new developments will be expected to provide bespoke on-site SANG rather than relying on the suite of SANGs being developed by the Borough Councilrdquo SLAA 99 is a large development so it should lose some of its housing land to provide on-site SANG to separate itsrsquo housing provision from Chobham Common

Similarly for Runnymede a large amount of new homes will result from the conclusions of the Planning Inspection Almost certainly more than proposed at the moment (this was the experience in East Hampshire in 2013) In this case and similar to the proposals adopted for SLAA 97 SANG provision for SLAA 99 (which appears to be scheduled to provide

11

the largest number of homes and something like 7000 extra people in Runnymede Borough) the SANG needs to be onsite and the solution I propose in this paragraph would cater for this Hoping new residents will all get in their cars to take the dog or cat for a walk over one mile away on Trumps Farm is not sustainable practicable or likely AECOMrsquos HRA and AA of both May and December 2017 completely fail to address the roaming catrsquos issue Despite AECOMrsquos clearly different point-of-view I do not believe that Runnymede Borough Council in their role as lsquocompetent authorityrsquo can conclude that no adverse effect on the integrity of internationally important wildlife sites of the Thames Basin Heathrsquos SPA will result from their proposals in their Local Plan 2030 as a consequence of what I consider are flawed conclusions proposed by AECOM The only light at the end of the tunnel of flawed conclusions in my opinion by AECOM is their final paragraph in the Dec 2017 HRA and AA that at paragraph 93 ldquoHowever it is recommended that the potential for further bespoke or strategic SANG later in the plan period is explored by the Council in time for Examination in Publicrdquo

I suggest to the Planning Inspector and Runnymede Borough Council that an on-site large SANG at the west end of the DERA South site should be provided as greenspace which would help to alleviate the potential for disturbance by residents of the new garden village from having to go or preferring to go to Chobham Common with the dog because this SANG site would be nearer Housing development adjacent to heathland always damages it especially if local arsonists are imported nearby but my proposals would go a long way to making the proposed Local Plan sound Though it would be far better if this garden village was scrapped and the DERA South site restored to heathland or just converted to another employment site as that would do far less damage to the Chobham Common SSSI and SPA site

____________________

Stephen R Miles 21st February 2018

From Caroline CravenTo Planning PolicySubject Representation for Local PlanDate 22 February 2018 092519Attachments Representation_form_for_Regulation_19_Caroline_Cravendocx

Please find attached my representation form in response to the Runnymede 2030 Local PlanConsultation

Regards helliphellip Caroline Craven

1886

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full contact details of the agent in 2

Part B (1) ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

XParagraph PolicyPolicies Map

X

X

X

4 Do you consider the Local Plan is

x

4 (1) Legally compliant Yes No

X

4 (2) SoundYes No

x

4 (3) Complies with the Duty to co-operateYesNo

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the duty to co-operate please also use this box to set out your comments

I believe the Local Plan does not comply with the duty to co-operate with neighbouring Boroughs The previous version was not deemed to be compliant as I understand it and there does not appear to be any significant changes that allow this plan to be compliant

RBC seems to have relied on the former Statement of Community Involvement (SCI) of 2014 In a digital age 15 lines in a local (The Villager Feb 9th) on page 11 is a poor means of communication to the Runnymede Borough residents on something that will affect them so deeply

In addition the views expressed at the RBC meeting by the attending RBC councillors were essentially that they accepted it wasnrsquot as good as it should be but was lsquothe best wersquore going to get at the momentrsquo and if not submitted then a Government Inspector would be appointed and they would lose control ndash a view I can fully understand but does not give the Runnymede residents a feeling of confidence in the legality or the integrity of the plan nor that the council truly want the best for the Borough

With regard to the Longcross site improvements to the station do not address the capacity issue The impact to commuters further up the line will be significant Peak times will be heavily impacted If additional trains are being proposed on this line the impact to the residents of Egham who already have to wait some 35-40 minutes in the hour whilst gates are down would therefore have even less opportunity to transverse the line at the crossing points Longcross station has no accessible car parking or drop off points This would necessitate commuters travelling to Virginia Water Egham whose own parking capability is limited Virginia Water has lost a large number of station car park spaces due to a new development This would also cause increased congestion in already known problem junctions The additional burden to the A320 which is already operating over practical capacity at several junctions and expected to deteriorate over the coming years would be significant (A320 Corridor Study ndash Feasibility Study ndash Interim report February 2018)

(Continue on a separate sheetexpand box if necessary)

The Longcross site will also need medical facilities ndash GPrsquos and potentially NHS drop in centre to ensure the current burden on the NHS is not exacerbated

With regard to the Traveller pitches they appear to amount to 35 within the scope of the development areas However the council plan to deliver 131 net additional plotspitches ndash 96 of which are not covered in this local plan This is an extremely emotive subject and needs to be identified properly in the plan and not almost hidden to avoid confrontation with angry residents that this County is already over run with these communities Integration with new developments is not the answer ndash Allocation of Traveller sites and pitches is according to the Government guidelines ldquoinappropriate within the Green beltrdquo and trying to slide this surreptitiously into new developments is a totally inappropriate solution

The Hurst Lane development was dismissed by the Council despite the residents being on board and a sustainable and acceptable plan being put forward for c 800-1000 homes on 80 -100 acres Over time this Lane has deteriorated to the point that Planning Inspectors described it as an lsquoindustrial wastelandrsquo In addition the Council resources are being tied up with the numerous issues generated by the Lane and the inability to resolve with the resources available The primary reason given is that the land is lsquoGreen Beltrsquo although under exceptional circumstances (which I believe this would come under) the council are able to and plan to in other areas use this land It is effectively a brownfield site which could be permitted fi connected to a SANG trade off which the residents plan was

6 Please set out what modification (s) you consider necessary to make the Local Plan legally compliant or sound having regard to the Matter you have identified at 5 above where this relates to soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of modification at examination) You will need to say why this modification will make the Local Plan legally compliant or sound It will be helpful if you are able to put forward your suggested revised wording of any policy or text Please be as precise as possible

For the plan to be sound I believe that

1) Review the inclusion of the Hurst Lane site ndash SLAA 59 ndash within the plan Appendix B states the capacity of 10 for Hurst Lane and 5 for Padd Farm If this relates to additional properties the number does not reflect the plans of up to 800 houses Access and infrastructure are addressed and the reduction in headcount in the councilrsquos Customer Services (I believe there is a dedicated resource looking after Padd Farm Hurst Lane) would be an additional benefit

2) Greater publicity is required over the consultation process The council appear to work on a lsquopullrsquo basis in that residents of the borough (other than those in the Residents Associations) have to actively seek out any updates from the council Local newspapers are not a good way of disseminating information in the digital age

3) Identify the additional travellergypsy site plans and move outside of the Green Belt area

If these steps were taken the residents would all have ample opportunity to contribute to the development of the local plan

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further representations based on the original representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

7 If your representation is seeking a modification do you consider it necessary to participate at the oral part of the examination

No I do not wish to participate Yes I wish to participate

X

at the oral examinationat the oral examination

8 If you wish to participate at the oral part of the examination please outline why you consider this to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who have indicated that they wish to participate at the oral part of the examination

9 Signature Date

21st February 2018

Caroline Craven

Notes to Accompany Model Representation Form

1 Introduction

11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 2004[footnoteRef1] (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound [1 View at httpwwwlegislationgovukukpga20045contents ]

2 Legal Compliance and Duty to Co-operate

21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness

22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)[footnoteRef2] it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices [2 LDDs are defined in regulation 5 ndash see link below ]

bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications

bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)[footnoteRef3] On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified [3 View at httpwwwlegislationgovukuksi2012767contentsmade ]

bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy)

23 You should consider the following before making a representation on compliance with the duty to co-operate

bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty

bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

3 Soundness

31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy

bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development

bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence

bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities

bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF

32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations

bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included

bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan

bull If the policy is not covered elsewhere in what way is the plan unsound without the policy

bull If the plan is unsound without the policy what should the policy say

4 General advice

41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

6

image1png

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full contact details of the agent in 2

Title Mrs First Name Caroline Last Name Craven Job Title (where relevant)

Organisation (where relevant)

Address Line 1 Southover Line 2 Hurst Lane Line 3 Egham Line 4 Surrey Post Code TW20 8QJ Telephone Number Email Address (where relevant)

2

Part B (1) ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

XParagraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails to comply with the duty to co-operate Please be as precise as possible If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

X X X

x

X

x

I believe the Local Plan does not comply with the duty to co-operate with neighbouring Boroughs The previous version was not deemed to be compliant as I understand it and there does not appear to be any significant changes that allow this plan to be compliant

RBC seems to have relied on the former Statement of Community Involvement (SCI) of 2014 In a digital age 15 lines in a local (The Villager Feb 9th) on page 11 is a poor means of communication to the Runnymede Borough residents on something that will affect them so deeply

In addition the views expressed at the RBC meeting by the attending RBC councillors were essentially that they accepted it wasnrsquot as good as it should be but was lsquothe best wersquore going to get at the momentrsquo and if not submitted then a Government Inspector would be appointed and they would lose control ndash a view I can fully understand but does not give the Runnymede residents a feeling of confidence in the legality or the integrity of the plan nor that the council truly want the best for the Borough

With regard to the Longcross site improvements to the station do not address the capacity issue The impact to commuters further up the line will be significant Peak times will be heavily impacted If additional trains are being proposed on this line the impact to the residents of Egham who already have to wait some 35-40 minutes in the hour whilst gates are down would therefore have even less opportunity to transverse the line at the crossing points Longcross station has no accessible car parking or drop off points This would necessitate commuters travelling to Virginia Water Egham whose own parking capability is limited Virginia Water has lost a large number of station car park spaces due to a new development This would also cause increased congestion in already known problem junctions The additional burden to the A320 which is already operating over practical capacity at several junctions and expected to deteriorate over the coming years would be significant (A320 Corridor Study ndash Feasibility Study ndash Interim report February 2018)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally compliant or sound having regard to the Matter you have identified at 5 above where this relates to soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of modification at examination) You will need to say why this modification will make the Local Plan legally compliant or sound It will be helpful if you are able to put forward your suggested revised wording of any policy or text Please be as precise as possible

For the plan to be sound I believe that

1) Review the inclusion of the Hurst Lane site ndash SLAA 59 ndash within the plan Appendix B states the capacity of 10 for Hurst Lane and 5 for Padd Farm If this relates to additional properties the number does not reflect the plans of up to 800 houses Access and infrastructure are addressed and the reduction in headcount in the councilrsquos Customer Services (I believe there is a dedicated resource looking after Padd Farm Hurst Lane) would be an additional benefit

2) Greater publicity is required over the consultation process The council appear to work on a lsquopullrsquo basis in that residents of the borough (other than those in the Residents Associations) have to actively seek out any updates from the council Local newspapers are not a good way of disseminating information in the digital age

3) Identify the additional travellergypsy site plans and move outside of the Green Belt area

If these steps were taken the residents would all have ample opportunity to contribute to the development of the local plan

The Longcross site will also need medical facilities ndash GPrsquos and potentially NHS drop in centre to ensure the current burden on the NHS is not exacerbated

With regard to the Traveller pitches they appear to amount to 35 within the scope of the development areas However the council plan to deliver 131 net additional plotspitches ndash 96 of which are not covered in this local plan This is an extremely emotive subject and needs to be identified properly in the plan and not almost hidden to avoid confrontation with angry residents that this County is already over run with these communities Integration with new developments is not the answer ndash Allocation of Traveller sites and pitches is according to the Government guidelines ldquoinappropriate within the Green beltrdquo and trying to slide this surreptitiously into new developments is a totally inappropriate solution

The Hurst Lane development was dismissed by the Council despite the residents being on board and a sustainable and acceptable plan being put forward for c 800-1000 homes on 80 -100 acres Over time this Lane has deteriorated to the point that Planning Inspectors described it as an lsquoindustrial wastelandrsquo In addition the Council resources are being tied up with the numerous issues generated by the Lane and the inability to resolve with the resources available The primary reason given is that the land is lsquoGreen Beltrsquo although under exceptional circumstances (which I believe this would come under) the council are able to and plan to in other areas use this land It is effectively a brownfield site which could be permitted fi connected to a SANG trade off which the residents plan was

4

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further representations based on the original representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

7 If your representation is seeking a modification do you consider it necessary to participate at the oral part of the examination

No I do not wish to participate Yes I wish to participate at the oral examination at the oral examination

8 If you wish to participate at the oral part of the examination please outline why you consider this to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who have indicated that they wish to participate at the oral part of the examination

9 Signature Date

X

Caroline Craven 21st February 2018

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan 1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination 42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

FromPolicy

Subject FW New Housing Plans 2015-2030Date 21 February 2018 164919

Sent 21 February 2018 1608To PlanningSubject New Housing Plans 2015-2030

To

Policy Planning and Strategy Team

Runnymede Borough Council

Station Road

Addlestone

21022018

Dear Sirs

As an Ottershaw resident of nearly 30 years i would like you to read and take on board my objections to yourproposal to take land out of the green belt for housing and your plan to build so many houses in ourcommunity

Of course new houses have to be built right across the country now and in the future but i feel the plans youhave are for far too many houses The infrastructure of our community will just not sustain the extra amount ofpeople and cars and the general traffic that would entail

There are other possibilities available before your irreversible plans are put into action Are these possibilitiesbeing resourced

When i drive around the borough now and for a long long time i see so many empty office blocks Some ofthese have stood empty for yearsWhy has permission been given continuosly from what i can see on a huge scale for these to be built

This building of offices has to stop and the ones that have remained empty for years could be converted tohousing as in flats starter homes for young people

If Planning Practice Guidlines state that the use of Green Beltshould only occur in very special circumstances these and the Brownfield sites in Runnymede must be extensively researched

I live in Wilson Drive and for many years now when i leave my house to go into the village or elsewhere thereis often gridlock in every direction The roads in our community are so heavily used by cars and lorries headingtoward the M25 Can you imagine the impact so many more of these will bring Driving has not been a pleasurefor a long time and i do walk wherever possible Parking is a problem in the village as so many people use theone car park I believe there may be a plan in the pipeline to even get rid of that for road widening

We have a GP practice in the village that is getting harder to book an appointment for also i have been waitingmonths for an appointment at St Peters hospital and just keep getting apologetic letters

Quality of life is very important for your residents and that quality has already deteriorated lately

1888

In order to accomodate so many new residents you will be making the ones you have feel very disappointedand frustated that no one listens

There is no going back once the desicion has been made and so many houses built Please take my feelings and iam sure very many more residents comments and pleas into account before you make the irreversible decisionto go ahead with your plans

Yours Faithfully

Margaret Wensley and the Wensley family

Beechwood

Wilson Drive

Ottershaw

Surrey

KT16 0NT

----------- middotn==middot =

Planning Services

DELIVERED BY HAND

Runnymede Borough Council ~--------------=-middot ---------middot------~

Planning Dept Runnymede Borough Council Civic Offices Station Road Addlestone KT15 2AH

Dear Sirs

Catherine Brunton-Green 20The Glen Addlestone

KT151AQ

15th February 2018

Runnymede Draft local Plan 2015- 2030- Final Consultation

I have serious concerns in respect of this draft plan Runnymede Borough Council (RBC) have a duty of care to consult with listen and act upon the wishes of its residents There has been some consultation but this has not effectively reached all Runnymede residents Communication is unnecessarily legally complex and full of unexplained acronyms The basic Runnymede Voice delivered to every home has been abandoned There has been no flyer delivered to every home stating in a simplified way what is happening so that all abilities may be catered for Many people are isolated for numerous reasons and do not have internet access Neither is there evidence of full in depth cross boundary consultation with adjacent boroughs This local plan is driven primarily by a developers charter promoted by RBCS Head of Planning It is both unfair unjust and I question its soundness

The Strategic Housing Market Assessment has not taken leaving the EU into account and makes a blanket assumption on Heathrow expansion

I strongly object to the proposed loss of c 560 acres of Green Belt Our Prime Minister and government have recently stated that they are quote committed to protecting and enhancing our natural environment for successive generations therefore Green Belt land would only be lost as a last resort 11

bull Detailed evidence based research by The Council for The Protection of Rural England confirms that by fully utilising brownfield land 12 million homes could be built in London and the South East without the loss of any Green Belt

I have objection to building on the Veterinary Laboratory Green Belt Land Parcel BRow Town (Policy SL11 8283) is not justified for development This is designated for 150 additional dwellings and 2 gypsyTraveller pitches This site provides a natural demarcation between developments either side Designated SANG area is privately owned and not available The density of proposed build is unacceptable and above all an area of outstanding natural beauty would be destroyed

Our infrastructure is unable to cope at present A320 suffers perpetual gridlock now Equally gridlock is evidenced through Ottershaw Addlestone Station Road and A317 Addlestone Weybridge We already have unhealthily dangerous levels of roadside nitrogen dioxide concentrations in many areas such as Station Road RBC has made a lame submission in respect of

tackling roadside nitrogen dioxide concentrations in the South East (UK00310) Incidence of exacerbated breathing illnesses in this vicinity has increased dramatically in the past 7 years All age groups are affected

All GP surgeries across Runnymede have great difficulty in recruiting doctors Two practices in the immediate area are merging due to unprecedented numbers of doctors leaving and retiring Practice lists and capacity is stretched Patient access to services and patient safety has to be the highest priority Our schools are similarly affected

RBC infrastructure is totally reliant upon Surrey County Council who declare they are not in a financial position to fund the necessary support to develop the infrastructure for this Local Plan

I am prepared to speak at Public Enquiry

Yours faithfully

bull i I I bull bull

From Brian PickettTo Planning PolicySubject Runnymede 2030 Local Plan - submission of viewsDate 22 February 2018 090921Attachments Ottershaw development Objection letter February 2018docx

Please find attached the submission of my views on the Runnymede 2030 LocalPlan

Kind RegardsBrian Pickett

1891

planningrunnymedegovuk planningrunnymedegovuk

21022018

Re Runnymede 2030 Local Plan Ottershaw East ndash Objection to planning

Dear Sirs

We are writing to you again as we strongly object to the Runnymede Borough Councils plans to remove land behind houses along Brox Road known as lsquoOttershaw Eastrsquo from the Green Belt We are objecting for a number of reasons listed below

middot The Green Belt is precious once it is gone it is gone forever The removal of this land from the Green Belt does not comply with Planning Policy which states ldquothat Green Belt boundaries should only be altered in exceptional circumstancesrdquo there are no such circumstances that can justify the removal of this piece of land

middot The Green Belt should be an area that is preserved for future generations to enjoy and appreciate and many statements have been made by both the Government and members of Parliament on their commitment to protect the Green Belt ndash these statements now need to be converted into action in the Local Borough Plans The roll out of Green Belt to local councils in the 1950rsquos was to prevent urban sprawl and the merging of settlements thereby helping to preserve and protect the character of communities it encompassed protect the country setting and encourage development through regeneration of sites within towns and cities not villages

middot The description of Ottershaw by the council itself in the lsquoUrban Characteristicsrsquo publication on the Runnymede Borough Council website states ldquoOttershaw has its own identity and sense of place which is partly derived from the clearly identifiable heart of the urban area focused on The Otter and adjoining local shopping parade and community facilities as well as being surrounded by open greenbelt countryside Removing this green belt that is part of the identifiable heart of Ottershaw would destroy this villagersquos identity and community

middot The planning proposals and building on this part of the green belt land would lead to a considerable population increase in the village Services and facilities will struggle or fail to cope space is already limited at the doctorrsquos surgery and school places are at capacity The transport infrastructure is already stretched with limited bus services busy roads poorly maintained pavements and road surfaces Brox road is already used as a shortcut to avoid traffic congestion Given that Ottershaw does not have a train station it is reasonable to assume that the majority of houses would have at least one car the added traffic from the new development would put a severe strain on the road network and users Available information on mitigation is very vague and very open to interpretation and misguided assumptions

middot The Green Belt land is a habitat to an array of plants and animals including important pollinator species and larger animals such as birds foxes and deer There should be no assumption that animals will simply move to another area habitats are established over many years and this development will be another loss to the maintenance of biodiversity I enjoy the fauna and flora in these areas going for walks along the public footpaths Having such wonderful access to a relaxing escape so close to home is priceless and something I hold dear to myself my family and community What is now a beautiful scenic view will become a spoilt urban sprawl of modern housing

middot I moved to Ottershaw with my wife in 2016 to settle down and start a family The relaxed quiet village sense of community and safety surrounded by beautiful countryside were its appeal I are very concerned and disappointed that this planning proposal is still being considered which will undoubtedly destroy this idyllic setting

There are no ldquoexceptional or very special circumstancesrdquo that justify the removal of Ottershaw East from the Green Belt We trust that the Council will therefore not remove ldquoOttershaw Eastrdquo and ldquoThe Fieldrdquo from the Green Belt

Yours faithfully

Dr Brian Pickett

To Policy Planning and Strategy Team Runnymede Borough Council Civic Centre Station Road Addlestone Surrey KT15 2AH planningrunnymedegovuk

From Dr Brian Pickett 139 Brox Road Ottershaw Surrey KT16 0LG planningrunnymedegovuk

21022018 Re Runnymede 2030 Local Plan Ottershaw East ndash Objection to planning Dear Sirs We are writing to you again as we strongly object to the Runnymede Borough Councils plans to remove land behind houses along Brox Road known as lsquoOttershaw Eastrsquo from the Green Belt We are objecting for a number of reasons listed below bull The Green Belt is precious once it is gone it is gone forever The removal of this

land from the Green Belt does not comply with Planning Policy which states ldquothat Green Belt boundaries should only be altered in exceptional circumstancesrdquo there are no such circumstances that can justify the removal of this piece of land

bull The Green Belt should be an area that is preserved for future generations to enjoy

and appreciate and many statements have been made by both the Government and members of Parliament on their commitment to protect the Green Belt ndash these statements now need to be converted into action in the Local Borough Plans The roll out of Green Belt to local councils in the 1950rsquos was to prevent urban sprawl and the merging of settlements thereby helping to preserve and protect the character of communities it encompassed protect the country setting and encourage development through regeneration of sites within towns and cities not villages

bull The description of Ottershaw by the council itself in the lsquoUrban Characteristicsrsquo

publication on the Runnymede Borough Council website states ldquoOttershaw has its own identity and sense of place which is partly derived from the clearly identifiable heart of the urban area focused on The Otter and adjoining local shopping parade and community facilities as well as being surrounded by open greenbelt countryside Removing this green belt that is part of the identifiable heart of Ottershaw would destroy this villagersquos identity and community

bull The planning proposals and building on this part of the green belt land would lead

to a considerable population increase in the village Services and facilities will struggle or fail to cope space is already limited at the doctorrsquos surgery and school places are at capacity The transport infrastructure is already stretched with limited bus services busy roads poorly maintained pavements and road surfaces Brox road is already used as a shortcut to avoid traffic congestion Given that Ottershaw does not have a train station it is reasonable to assume that the majority of houses would have at least one car the added traffic from the new development would put a severe strain on the road network and users Available information on mitigation is very vague and very open to interpretation and misguided assumptions

bull The Green Belt land is a habitat to an array of plants and animals including important pollinator species and larger animals such as birds foxes and deer There should be no assumption that animals will simply move to another area habitats are established over many years and this development will be another loss to the maintenance of biodiversity I enjoy the fauna and flora in these areas going for walks along the public footpaths Having such wonderful access to a relaxing escape so close to home is priceless and something I hold dear to myself my family and community What is now a beautiful scenic view will become a spoilt urban sprawl of modern housing

bull I moved to Ottershaw with my wife in 2016 to settle down and start a family The

relaxed quiet village sense of community and safety surrounded by beautiful countryside were its appeal I are very concerned and disappointed that this planning proposal is still being considered which will undoubtedly destroy this idyllic setting

There are no ldquoexceptional or very special circumstancesrdquo that justify the removal of Ottershaw East from the Green Belt We trust that the Council will therefore not remove ldquoOttershaw Eastrdquo and ldquoThe Fieldrdquo from the Green Belt Yours faithfully Dr Brian Pickett

FromTo Planning PolicySubject Runnymede Local Plan 2030 - consultation responseDate 21 February 2018 163608Attachments Runnymede LP Response - EE15pdf

Please find attached a consultation response form

________________________________________Christian Leigh BSc(Hons) MPhil MRTPIDirectorLeigh amp Glennie Ltd6 All Souls RoadAscotBerkshire SL5 9EA

1893

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number 01344 297094 Email Address (where relevant)

mailchristianleighcouk

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number Email Address (where relevant)

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

From MCNAB DouglasTo Planning PolicySubject Runnymede Draft Local Plan consultation - Representation from Education and Skills Funding AgencyDate 21 February 2018 091407Attachments Runnymede Reg 19 response ESFADOC

Dear Runnymede Planning Policy Team

Please see attached a representation from the Education and Skills Funding Agency on theRunnymede Local Plan consultation

I would be grateful if you could confirm receipt

Best regardsDoug

Douglas McNab MRTPIForward Planning Manager ndash South East

Planning Team Free Schools CapitalEducation and Skills Funding AgencyDepartment for Education 5th floor Sanctuary Buildings 20 Great Smith Street London SW1P 3BT

Email douglasmcnabeducationgovukMobile 07990 082877Web wwwgovukesfa

1895

image1pngOur Ref ESFALocal PlanRunnymede 2018 21st February 2018

Dear SirMadam

Re Runnymede Local Plan

Consultation under Regulation 19 of Town and Country Planning (Local Planning) (England) Regulations 2012

Submission of the Education and Skills Funding Agency

1 The Education and Skills Funding Agency (ESFA) welcomes the opportunity to contribute to the development of planning policy at the local level

2 The ESFA launched on 1st April 2017 bringing together the existing responsibilities of the Education Funding Agency (EFA) and the Skills Funding Agency (SFA) to create a single funding agency accountable for funding education and training for children young people and adults The ESFA are accountable for pound61 billion of funding a year for the education and training sector including support for all state-provided education for 8 million children aged 3 to 16 and 16 million young people aged 16 to 19

3 Under the provisions of the Education Act 2011 and the Academies Act 2010 all new state schools are now academiesfree schools and the ESFA is the delivery body for many of these rather than local education authorities As such we aim to work closely with local authority education departments and planning authorities to meet the demand for new school places and new schools We do this through a variety of means including by supporting the adoption of sound local plan policies site allocations and guidance (all based on robust evidence) that facilitate the delivery of education infrastructure where and when it is needed and maximise developer contributions for schools In this capacity we would like to offer the following comments in response to the proposals outlined in the above consultation document

Comments on the Local Plan

4 As you will be aware the primary focus at this stage of the Local Planrsquos preparation is on the soundness of the plan with regard to it being positively prepared justified effective and consistent with national policy The following detailed comments set out the ESFArsquos view of the planrsquos soundness in respect of education provision

5 The ESFA notes that the local plan will make provision for a minimum of 7413 net additional dwellings over the plan period Development will generally complement the existing settlement pattern focusing the largest amounts of residential growth primarily in Chertsey (1950 homes) Addlestone (936 homes) and Egham (812 homes) A new ldquolocally led garden villagerdquo is also proposed at Longcross providing a further 1718 homes This level of development will put pressure on existing education infrastructure

6 The plan recognises that ldquoIt is important that infrastructure is delivered in a timely manner to ensure that the needs of the occupiers of new development can be met without placing undue burdens on existing infrastructure facilities and servicesrdquo (para 560) The ESFA supports Policy SD6 Infrastructure Provision amp Timing particularly the signposting of the Infrastructure Delivery Plan (IDP) and the need for development to deliver this either on-site or through s106 or CIL financial contributions off-site and the need for development to be phased in line with the provision of important supporting infrastructure

7 The latest version of the IDP states that there is an ongoing programme of primary school expansions this will help to meet the forecast need for 4-6FE of new capacity over the plan period The need for one new build school project is identified a 2FE primary school at the Longcross Garden Village (estimated cost pound99M to pound15M) this is referred to in the site allocation policies (see below) With respect to secondary school places it is anticipated that up to six additional FE could be required in the Borough by 2021 Additional places will be delivered through the new 6FE Runnymede Free School (which opened in temporary accommodation in 2017) development of additional FE within Salesian School (Catholic faith school) and expansion of another school in the Chertsey area (to accommodate demand from generated by the Longcross Garden Village site)

8 It would be useful if the background data informing these projections of need could be clarified particularly the pupil yield factors used and the evidence base supporting this This would help to demonstrate more clearly to the Inspector that the approach to the planning and delivery of education infrastructure has been positively prepared based on a strategy which seeks to meet objectively assessed infrastructure requirements and is justified based on proportionate evidence The ESFA notes that the Runnymede S106 SPG sets out pupil yield figures however this document dates from December 2007 so the figures may be outdated

9 The ESFA supports the Councilrsquos allocation and safeguarding of land for schools as set out in the following policies

middot Policy SD10 Longcross Garden Village - 2FE primary school with preschoolearly years settings

middot Policy SL2 to SL18 ndash series of housing allocation policies that highlight the need to make a financial contribution to early years primary and secondary school infrastructure ldquoeither through S106 or CIL (or its successor)rdquo

Developer Contributions and CIL

10 One of the tests of soundness is that a Local Plan is lsquoeffectiversquo ie the plan should be deliverable over its period In this context and with specific regard to planning for schools there is a need to ensure that education contributions made by developers are sufficient to deliver the additional school places required to meet the increase in demand generated by new developments The ESFA notes that the council has not adopted CIL and that the Planning Obligations SPG sets out how developer contributions to education provision will be secured via section 106 agreements The ESFA supports the Councilrsquos approach to ensure developer contributions address the impacts arising from growth However the ESFA recommends that the Local Plan includes a commitment to revise the Planning Obligations SPG in line with the latest evidence of the boroughrsquos infrastructure needs pupil yields and build costs (including the cost of school expansion new build and SEN provision) Any such review should be prepared in consultation with the county council as local education authority This will help to ensure appropriate rates are levied and the right infrastructure is secured across the borough

11 The ESFA would be particularly interested in responding to any update to the Infrastructure Delivery Plan or review of infrastructure requirements As such please add the ESFA to the database for future CIL consultations

Forward funding

12 In light of the proposed Longcross Garden Village emerging ESFA proposals for forward funding schools as part of large residential developments may be relevant for example if viability becomes an issue The ESFA aims to be able to clarify forward funding options for schools in 2018 We would be happy to meet to discuss this opportunity further once the options have been finalised and ifwhen relevant Any offer of forward funding would seek to maximise developer contributions to education infrastructure provision while supporting delivery of schools where and when they are needed

Conclusion

13 Finally I hope the above comments are helpful in finalising the Runnymede Local Plan with specific regard to the provision of land for new schools

14 Please notify the ESFA when the Local Plan is submitted for examination the Inspectorrsquos report is published and the Local Plan is adopted

15 Please do not hesitate to contact me if you have any queries regarding this response The ESFA looks forward to continuing to work with Runnymede Borough Council to develop a sound Local Plan that will aid in the delivery of new schools

Yours faithfully

DC McNab

Douglas McNab MRTPI

Forward Planning Manager

Tel 07990 082877

Email

douglasmcnabeducationgovuk

Web

wwwgovuk esfa

Education and Skills Funding Agency13

Department for EducationSanctuary BuildingsGreat Smith StreetLondonSW1P 3BT13

13

Tel 0207 340 700013

13

wwwgovukesfa13

13

13

To

Policy Planning and Strategy Team

Runnymede Borough Council

Civic Centre

Station Road

Addlestone

Surrey

KT15 2AH

From

Dr Brian Pickett

139 Brox Road

Ottershaw

Surrey

KT16 0LG

Title

Mrs

First Name

Caroline

Last Name

Craven

Job Title

(where relevant)

Organisation

(where relevant)

Address Line 1

Southover

Line 2

Hurst Lane

Line 3

Egham

Line 4

Surrey

Post Code

TW20 8QJ

Telephone Number

07770999572

Email Address

(where relevant)

Carolinecraven911hotmailcom

Page 8: Runnymede Borough Council, for submissions. My contact details are all in the WORD letter attached. But I will provide my telephone number here too, which …

5

development site For those dwellings proposed for the western and middle parts of this development site Chobham Common is immediately adjacent Nowhere in the documents provided by Runnymede Borough Council or AECOM or in paragraphs 818 or 819 is it explained what will cause new residents of the dwellings proposed to be built on the SLAA 99 site adjacent to Chobham Common to get into their cars to travel east for approximately 15 miles or nearly 2 kilometres away with their dogs to reach the proposed Trumpsrsquo Farm SANG Equally nor is it explained how roaming cats will be stopped from crossing the B386 and visiting Chobham Common when their homes are right next door or very close to the dry lowland heathland of Chobham Common Paragraph 835 of the AECOM AA informs us that the development site at DERA South will be as close as 280m to the SPA yet the nearest the proposed SANG to be used to divert new residents away from the SPA is over 1km to 15km to the east So I repeat how will this development stop the occupants from walking the shorter distance to take both themselves and their dogs or allow their roaming cats especially of a night via cat-flaps onto Chobham Common In their evidence to the Surrey Heath Borough Council Local Plan in 2011 RSPB pointed out that domestic cats may range beyond any 400m buffer that is set up so fencing of any on-site SANG provision as well as fencing in any adjacent housing built up to the 400m buffer and within at least half a mile distance from the start of the public access to the Chobham Common site at Ordnance Survey Grid Reference SU979651 is essential

Para 416 of AECOMrsquos AA states that ldquothe Delivery Framework continues to restrict all new residential development within an area some 400 metres from the boundary of the TBH SPArdquo If this is the case with SLAA 99 that housing will be kept at 400m from Chobham Common this is still too near because people will go the shorter distance and on sunny weather days as is promoted by so many organisations for peoplersquos well-being which is also mentioned in Section 6 under Supporting Local People and Health amp Wellbeing of the Local Plan Thus they will walk straight out onto Chobham Common adding to the high numbers of people already visiting this site and damaging it by their presence this is unacceptable

Noting AECOMrsquos paragraph 810 ldquoThe Thames Basin Heaths SPA is considered sensitive to the effects of recreational disturbance Natural England considers that the threat of development pressure particularly

6

housing on neighbouring land and preferred sites within 5km results in increased recreational use of this site and has potential to disturb bird feeding and breeding behaviourrdquo These pathways to damage in AECOMrsquos so-called Appropriate Assessment are then conveniently screened out just because there is a Runnymede Policy to provide SANG as related to the TBH Delivery Framework The fact that Trumps Farm is in the wrong place to provide effective green space as mitigation in paragraphs 863 to 868 of AECOMrsquos conclusions as an alternative for peoplersquos recreation with their dogs is wrong Also the effect of roaming cats is completely ignored by this organisation so that any cats present in the 1750 nearby proposed dwellings will be at liberty to kill the Annex 1 birds present on the adjoining Chobham Common as well as the reptiles and amphibians they encounter

The dictionary definition of mitigation is to alleviate diminish or moderate I cannot see how a mitigation site 15 kilometresrsquo away will provide proper mitigation when so many people are being told to forsake their cars and to get out and exercise An on-site SANG must be provided at the west end of the DERA South site where the Longcross Barracks were and the Longcross Garden Village itself must be double fenced at itsrsquo boundary with the B386 road to exclude people and their animals from walking straight out onto Chobham Common if the development of SLAA 99 goes ahead as specified in the Local Plan A large on-site SANG will help reduce lighting spread and other urbanisation effects associated with this development and identified by AECOM elsewhere in their various HRAs for this Local Plan Any visible lighting on Chobham Common SPA will damage this site from their statements I am not sure this fact has registered with AECOMrsquos HRA writers

In the latest version of the AECOM HRA for the Runnymede Local Plan dated December 2017 and taking account of the Conservation of Habitats and Species Regulations 2017 one has to ask what has AECOM and all the promoters of Longcross Garden Village got to hide when the SANG site to divert residents away from the adjacent Chobham Common site within the Thames Basin Heaths SPA is not even mentioned Are Runnymede Borough Council providing a mitigation site or not The Conservation of Habitats and Species Regulations 2017 states in paragraph 63 (5) ldquoIn the light of the conclusions of the assessment and subject to regulation 64 the competent authority may agree to the plan or project only after having ascertained that it will not adversely affect

7

the integrity of the European siterdquo If no named SANG site is to be provided than the competent authority Runnymede Borough Council cannot conclude that no damage will occur to the integrity of the Chobham Common site as a result of the approval of itsrsquo Local Plan in its current format

3 Natural England used to be a proper nature conservation organisation before 2010 before the previous coalition Government of David Cameron and particularly Owen Paterson when Secretary of State for The Environment Food and Rural Affairs from 2012 ruined it and turned into another pro-development organisation negating itsrsquo roles via the 2012 statement that it could no longer campaign to objectively protect wildlife Itsrsquo role always was to shout loudly to protect wildlife and it should in my opinion now be recording objections to stop adverse developments such as SLAA 99 But with AECOMrsquos statement in paragraph 817 of the AECOM June 2016 HRA that Natural England already have an agreement with Crest Nicholson that a ldquowhole site SANG strategy has been agreedrdquo and that an ldquoadverse effect on the integrity on the Thames Basin Heaths would not ariserdquo subject to the delivery of the agreed SANGS shows Natural England has already been compromised in the negotiations Clearly there is a conflict with the statement in paragraph 817 in the summary ldquoLocating housing more than 400m from the SPA boundaryrdquo and para 835 which states that DERA South site is only 280m from the SPA boundary What is not clear from this early HRA and subsequent updated versions by AECOM is whether housing will be developed and established at a point of only 280m or less from the SPA boundary conforming to the boundary of the DERA South site or at the 400m buffer distance Which is it

It is clear that Natural Englandrsquos role in protecting Chobham Common has been compromised already they should be sticking to their 2006 position clearly if this development goes ahead referral to European Courts of Justice is necessary Already before BREXIT is completed the UK Government cannot be trusted to ensure our richest wildlife sites are protected when the same UK Government own ldquobrownfieldrdquo sites such as DERA South adjacent to these SPA sites The HS2 in England proposals and the Gwent Levels development proposals for the M4 in Wales are already evidence of their despicable and cavalier record of

8

damage to Sites of Special Scientific Interest Such damage is not acceptable I urge Runnymede Borough Council and the UK Government to think again about a different policy for this sensitive location of DERA South

4 Natural England should be putting Englandrsquos wildlife considerations first NOT the Governmentrsquos economic development initiatives I ask here that both DEFRA and Natural England intervene in this consultation and the subsequent inspection (as a consequence this objection will be sent to both of them) because the SLAA 99 development proposals and the so-called mitigation make a travesty of nature conservation and will only further damage the Chobham Common SSSI and its wildlife species

5 Clearly AECOMrsquos conclusion with regard to disturbance of the Annex 1 birds on Chobham Common in their paragraphs 863 and 868 of the May 2017 HRA and also in paragraphs 851 to 853 of the December 2017 version is wrong and seriously flawed because it fails to take in the proximity of the DERA South development to the SPA site of Chobham Common Also when the Trumps Farm SANG is over one mile distant and the originally proposed of a 55 hectare woodland SANG mentioned in paragraph 817 of the June 2016 HRA version does not fit to the Natural Englandrsquos preferred SANG size for a large development Nor is a woodland SANG normally safe for women walking alone with a dog the original preference for a SANG was that it should replicate the open nature of the heathland sitesrsquo the public like to use for dog-walking

Runnymede Borough Councilrsquos policy for the provision of SANG is not sufficient for it to work as mitigation it must be easier to get to and access the SANG than the adjoining SPA site and the Trumps Farm site fails in this provision Clearly Natural England and the UK Government are conveniently failing to understand what must be staring them in the face if they were honest that SLAA 99 development proposals will both damage and cause disturbance to the wildlife of Chobham Common As a part of the Thames Basin Heaths SPA and with an agreed Delivery Framework for SANGS in the Thames Basin Area if SLAA 99 is accepted in this Local Plan with the existing SANG proposals this will be unacceptable to me This will then form a part of a complaint to the European Commission as currently we are still subject to the judgements of the European Court of Justice

9

6 AECOMrsquos conclusions in paragraph 865 of the June 2016 HRA 868 of the May 2017 HRA and AA and lastly in paragraphs 851 to 853 of the December 2017 HRA and AA is what you expect from AECOM a complete disregard for the issues based on just a Council policy of the provision of SANG irrespective of itsrsquo location and proximity to the proposed development Equally as the Planning Inspectorate is under the same UK Government ldquocoshrdquo as Natural England to enable the provision of more housing for the so-called housing crisis It is not a shortage of housing that is evident in England it is a clear case of overpopulation with successive governments failing to govern and do anything about excessive breeding of the native human population and uncontrolled inward migration of human numbers into the UK particularly in southern England Before the next round of housing proposals in this area post 2030 the UK Government must act to reduce the excessive human population growth in the Runnymede area and the excessive expansion of the London region I can already see the claims for the forthcoming Planning Inspection and future ones probably by the Housebuilderrsquos Federation and the agents or QCs for the private housebuilding companies (a QC was employed by one developerrsquos agent for the East Hampshire Joint Core Strategy to argue for more housing to be achieved within that area and Local Plan) that people are more important than wildlife and that we must build on the SPAs or very close to them as in the current Runnymede Local Plan This failure to properly mitigate for the development of the so-called Longcross Garden Village is the start of the destruction of one of Britainrsquos best remaining lowland heathland sites A national disgrace

The SLAA 99 proposal and the proposals to remove land from the greenbelt in this Local Plan are as clear evidence of the overpressure of people numbers on the finite land resource of England (ldquoThe UKs population is projected to reach 70 million by 2030 ndash thatrsquos nine million more people than in 2008rdquo Ref Forum for the Future in 2010 ldquoUK population grows by over 400000 in the last year the largest absolute increase of any European countryrdquo Ref Population Mattersrsquo research in August 2013 ldquoEnglandrsquos population is already twice that of Germany per square mile and four times that of France It is our quality of life that is being affectedrdquo Ref Lord Horam speaking in February 2018 in the House of Lordrsquos debate on ldquoBrexit and the labour marketrdquo As the Planning

10

Inspector stated at the commencement of the Inspection of the East Hampshire Joint Core Strategy that I was present at in 2013 ldquoI have been given a growth agendardquo With this type of pressure by the UK Government I am not sure that I or nature conservation can expect a fair and objective hearing in 2018 when I object to Runnymede Borough Councilrsquos Local Plan 2030 we will see

7 For the proximity of the DERA South development to the SPA site of Chobham Common there is one potential solution and that is to reduce the number of houses in the DERA South (Longcross Garden Village) proposal and to make a new large SANG out of the land at the western end of the DERA South site This would require the ldquoDuty of Cooperationrdquo to be observed as the extreme west end of the DERA South site as it is within the land area of Surrey Heath Borough Council but I am sure this could be achievable This area would have to be fenced with dense mesh topped with rolled razor wire or similar to prevent free roaming dogs and cats from going onto the Chobham Common site south of the M3 and B386 roads If this fence was sufficiently high and doubled up to make two fences these could be used to keep the public and their animals away from and out of the SPA of Chobham Common and also necessarily to confine the loose running dogs a requirement for SANGS from being run-over on the B386 and the other connecting roads

8 The SPD issued and adopted by Surrey Heath Borough Council states I paragraph 57 ldquoIn the period up to 2028 Surrey Heath is expected to grant planning permission for 324010 new homes and this will require the provision of over 60 hectares of SANG Major or large new developments will be expected to provide bespoke on-site SANG rather than relying on the suite of SANGs being developed by the Borough Councilrdquo SLAA 99 is a large development so it should lose some of its housing land to provide on-site SANG to separate itsrsquo housing provision from Chobham Common

Similarly for Runnymede a large amount of new homes will result from the conclusions of the Planning Inspection Almost certainly more than proposed at the moment (this was the experience in East Hampshire in 2013) In this case and similar to the proposals adopted for SLAA 97 SANG provision for SLAA 99 (which appears to be scheduled to provide

11

the largest number of homes and something like 7000 extra people in Runnymede Borough) the SANG needs to be onsite and the solution I propose in this paragraph would cater for this Hoping new residents will all get in their cars to take the dog or cat for a walk over one mile away on Trumps Farm is not sustainable practicable or likely AECOMrsquos HRA and AA of both May and December 2017 completely fail to address the roaming catrsquos issue Despite AECOMrsquos clearly different point-of-view I do not believe that Runnymede Borough Council in their role as lsquocompetent authorityrsquo can conclude that no adverse effect on the integrity of internationally important wildlife sites of the Thames Basin Heathrsquos SPA will result from their proposals in their Local Plan 2030 as a consequence of what I consider are flawed conclusions proposed by AECOM The only light at the end of the tunnel of flawed conclusions in my opinion by AECOM is their final paragraph in the Dec 2017 HRA and AA that at paragraph 93 ldquoHowever it is recommended that the potential for further bespoke or strategic SANG later in the plan period is explored by the Council in time for Examination in Publicrdquo

I suggest to the Planning Inspector and Runnymede Borough Council that an on-site large SANG at the west end of the DERA South site should be provided as greenspace which would help to alleviate the potential for disturbance by residents of the new garden village from having to go or preferring to go to Chobham Common with the dog because this SANG site would be nearer Housing development adjacent to heathland always damages it especially if local arsonists are imported nearby but my proposals would go a long way to making the proposed Local Plan sound Though it would be far better if this garden village was scrapped and the DERA South site restored to heathland or just converted to another employment site as that would do far less damage to the Chobham Common SSSI and SPA site

____________________

Stephen R Miles 21st February 2018

From Caroline CravenTo Planning PolicySubject Representation for Local PlanDate 22 February 2018 092519Attachments Representation_form_for_Regulation_19_Caroline_Cravendocx

Please find attached my representation form in response to the Runnymede 2030 Local PlanConsultation

Regards helliphellip Caroline Craven

1886

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full contact details of the agent in 2

Part B (1) ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

XParagraph PolicyPolicies Map

X

X

X

4 Do you consider the Local Plan is

x

4 (1) Legally compliant Yes No

X

4 (2) SoundYes No

x

4 (3) Complies with the Duty to co-operateYesNo

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the duty to co-operate please also use this box to set out your comments

I believe the Local Plan does not comply with the duty to co-operate with neighbouring Boroughs The previous version was not deemed to be compliant as I understand it and there does not appear to be any significant changes that allow this plan to be compliant

RBC seems to have relied on the former Statement of Community Involvement (SCI) of 2014 In a digital age 15 lines in a local (The Villager Feb 9th) on page 11 is a poor means of communication to the Runnymede Borough residents on something that will affect them so deeply

In addition the views expressed at the RBC meeting by the attending RBC councillors were essentially that they accepted it wasnrsquot as good as it should be but was lsquothe best wersquore going to get at the momentrsquo and if not submitted then a Government Inspector would be appointed and they would lose control ndash a view I can fully understand but does not give the Runnymede residents a feeling of confidence in the legality or the integrity of the plan nor that the council truly want the best for the Borough

With regard to the Longcross site improvements to the station do not address the capacity issue The impact to commuters further up the line will be significant Peak times will be heavily impacted If additional trains are being proposed on this line the impact to the residents of Egham who already have to wait some 35-40 minutes in the hour whilst gates are down would therefore have even less opportunity to transverse the line at the crossing points Longcross station has no accessible car parking or drop off points This would necessitate commuters travelling to Virginia Water Egham whose own parking capability is limited Virginia Water has lost a large number of station car park spaces due to a new development This would also cause increased congestion in already known problem junctions The additional burden to the A320 which is already operating over practical capacity at several junctions and expected to deteriorate over the coming years would be significant (A320 Corridor Study ndash Feasibility Study ndash Interim report February 2018)

(Continue on a separate sheetexpand box if necessary)

The Longcross site will also need medical facilities ndash GPrsquos and potentially NHS drop in centre to ensure the current burden on the NHS is not exacerbated

With regard to the Traveller pitches they appear to amount to 35 within the scope of the development areas However the council plan to deliver 131 net additional plotspitches ndash 96 of which are not covered in this local plan This is an extremely emotive subject and needs to be identified properly in the plan and not almost hidden to avoid confrontation with angry residents that this County is already over run with these communities Integration with new developments is not the answer ndash Allocation of Traveller sites and pitches is according to the Government guidelines ldquoinappropriate within the Green beltrdquo and trying to slide this surreptitiously into new developments is a totally inappropriate solution

The Hurst Lane development was dismissed by the Council despite the residents being on board and a sustainable and acceptable plan being put forward for c 800-1000 homes on 80 -100 acres Over time this Lane has deteriorated to the point that Planning Inspectors described it as an lsquoindustrial wastelandrsquo In addition the Council resources are being tied up with the numerous issues generated by the Lane and the inability to resolve with the resources available The primary reason given is that the land is lsquoGreen Beltrsquo although under exceptional circumstances (which I believe this would come under) the council are able to and plan to in other areas use this land It is effectively a brownfield site which could be permitted fi connected to a SANG trade off which the residents plan was

6 Please set out what modification (s) you consider necessary to make the Local Plan legally compliant or sound having regard to the Matter you have identified at 5 above where this relates to soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of modification at examination) You will need to say why this modification will make the Local Plan legally compliant or sound It will be helpful if you are able to put forward your suggested revised wording of any policy or text Please be as precise as possible

For the plan to be sound I believe that

1) Review the inclusion of the Hurst Lane site ndash SLAA 59 ndash within the plan Appendix B states the capacity of 10 for Hurst Lane and 5 for Padd Farm If this relates to additional properties the number does not reflect the plans of up to 800 houses Access and infrastructure are addressed and the reduction in headcount in the councilrsquos Customer Services (I believe there is a dedicated resource looking after Padd Farm Hurst Lane) would be an additional benefit

2) Greater publicity is required over the consultation process The council appear to work on a lsquopullrsquo basis in that residents of the borough (other than those in the Residents Associations) have to actively seek out any updates from the council Local newspapers are not a good way of disseminating information in the digital age

3) Identify the additional travellergypsy site plans and move outside of the Green Belt area

If these steps were taken the residents would all have ample opportunity to contribute to the development of the local plan

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further representations based on the original representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

7 If your representation is seeking a modification do you consider it necessary to participate at the oral part of the examination

No I do not wish to participate Yes I wish to participate

X

at the oral examinationat the oral examination

8 If you wish to participate at the oral part of the examination please outline why you consider this to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who have indicated that they wish to participate at the oral part of the examination

9 Signature Date

21st February 2018

Caroline Craven

Notes to Accompany Model Representation Form

1 Introduction

11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 2004[footnoteRef1] (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound [1 View at httpwwwlegislationgovukukpga20045contents ]

2 Legal Compliance and Duty to Co-operate

21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness

22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)[footnoteRef2] it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices [2 LDDs are defined in regulation 5 ndash see link below ]

bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications

bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)[footnoteRef3] On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified [3 View at httpwwwlegislationgovukuksi2012767contentsmade ]

bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy)

23 You should consider the following before making a representation on compliance with the duty to co-operate

bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty

bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

3 Soundness

31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy

bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development

bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence

bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities

bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF

32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations

bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included

bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan

bull If the policy is not covered elsewhere in what way is the plan unsound without the policy

bull If the plan is unsound without the policy what should the policy say

4 General advice

41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

6

image1png

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full contact details of the agent in 2

Title Mrs First Name Caroline Last Name Craven Job Title (where relevant)

Organisation (where relevant)

Address Line 1 Southover Line 2 Hurst Lane Line 3 Egham Line 4 Surrey Post Code TW20 8QJ Telephone Number Email Address (where relevant)

2

Part B (1) ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

XParagraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails to comply with the duty to co-operate Please be as precise as possible If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

X X X

x

X

x

I believe the Local Plan does not comply with the duty to co-operate with neighbouring Boroughs The previous version was not deemed to be compliant as I understand it and there does not appear to be any significant changes that allow this plan to be compliant

RBC seems to have relied on the former Statement of Community Involvement (SCI) of 2014 In a digital age 15 lines in a local (The Villager Feb 9th) on page 11 is a poor means of communication to the Runnymede Borough residents on something that will affect them so deeply

In addition the views expressed at the RBC meeting by the attending RBC councillors were essentially that they accepted it wasnrsquot as good as it should be but was lsquothe best wersquore going to get at the momentrsquo and if not submitted then a Government Inspector would be appointed and they would lose control ndash a view I can fully understand but does not give the Runnymede residents a feeling of confidence in the legality or the integrity of the plan nor that the council truly want the best for the Borough

With regard to the Longcross site improvements to the station do not address the capacity issue The impact to commuters further up the line will be significant Peak times will be heavily impacted If additional trains are being proposed on this line the impact to the residents of Egham who already have to wait some 35-40 minutes in the hour whilst gates are down would therefore have even less opportunity to transverse the line at the crossing points Longcross station has no accessible car parking or drop off points This would necessitate commuters travelling to Virginia Water Egham whose own parking capability is limited Virginia Water has lost a large number of station car park spaces due to a new development This would also cause increased congestion in already known problem junctions The additional burden to the A320 which is already operating over practical capacity at several junctions and expected to deteriorate over the coming years would be significant (A320 Corridor Study ndash Feasibility Study ndash Interim report February 2018)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally compliant or sound having regard to the Matter you have identified at 5 above where this relates to soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of modification at examination) You will need to say why this modification will make the Local Plan legally compliant or sound It will be helpful if you are able to put forward your suggested revised wording of any policy or text Please be as precise as possible

For the plan to be sound I believe that

1) Review the inclusion of the Hurst Lane site ndash SLAA 59 ndash within the plan Appendix B states the capacity of 10 for Hurst Lane and 5 for Padd Farm If this relates to additional properties the number does not reflect the plans of up to 800 houses Access and infrastructure are addressed and the reduction in headcount in the councilrsquos Customer Services (I believe there is a dedicated resource looking after Padd Farm Hurst Lane) would be an additional benefit

2) Greater publicity is required over the consultation process The council appear to work on a lsquopullrsquo basis in that residents of the borough (other than those in the Residents Associations) have to actively seek out any updates from the council Local newspapers are not a good way of disseminating information in the digital age

3) Identify the additional travellergypsy site plans and move outside of the Green Belt area

If these steps were taken the residents would all have ample opportunity to contribute to the development of the local plan

The Longcross site will also need medical facilities ndash GPrsquos and potentially NHS drop in centre to ensure the current burden on the NHS is not exacerbated

With regard to the Traveller pitches they appear to amount to 35 within the scope of the development areas However the council plan to deliver 131 net additional plotspitches ndash 96 of which are not covered in this local plan This is an extremely emotive subject and needs to be identified properly in the plan and not almost hidden to avoid confrontation with angry residents that this County is already over run with these communities Integration with new developments is not the answer ndash Allocation of Traveller sites and pitches is according to the Government guidelines ldquoinappropriate within the Green beltrdquo and trying to slide this surreptitiously into new developments is a totally inappropriate solution

The Hurst Lane development was dismissed by the Council despite the residents being on board and a sustainable and acceptable plan being put forward for c 800-1000 homes on 80 -100 acres Over time this Lane has deteriorated to the point that Planning Inspectors described it as an lsquoindustrial wastelandrsquo In addition the Council resources are being tied up with the numerous issues generated by the Lane and the inability to resolve with the resources available The primary reason given is that the land is lsquoGreen Beltrsquo although under exceptional circumstances (which I believe this would come under) the council are able to and plan to in other areas use this land It is effectively a brownfield site which could be permitted fi connected to a SANG trade off which the residents plan was

4

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further representations based on the original representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

7 If your representation is seeking a modification do you consider it necessary to participate at the oral part of the examination

No I do not wish to participate Yes I wish to participate at the oral examination at the oral examination

8 If you wish to participate at the oral part of the examination please outline why you consider this to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who have indicated that they wish to participate at the oral part of the examination

9 Signature Date

X

Caroline Craven 21st February 2018

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan 1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination 42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

FromPolicy

Subject FW New Housing Plans 2015-2030Date 21 February 2018 164919

Sent 21 February 2018 1608To PlanningSubject New Housing Plans 2015-2030

To

Policy Planning and Strategy Team

Runnymede Borough Council

Station Road

Addlestone

21022018

Dear Sirs

As an Ottershaw resident of nearly 30 years i would like you to read and take on board my objections to yourproposal to take land out of the green belt for housing and your plan to build so many houses in ourcommunity

Of course new houses have to be built right across the country now and in the future but i feel the plans youhave are for far too many houses The infrastructure of our community will just not sustain the extra amount ofpeople and cars and the general traffic that would entail

There are other possibilities available before your irreversible plans are put into action Are these possibilitiesbeing resourced

When i drive around the borough now and for a long long time i see so many empty office blocks Some ofthese have stood empty for yearsWhy has permission been given continuosly from what i can see on a huge scale for these to be built

This building of offices has to stop and the ones that have remained empty for years could be converted tohousing as in flats starter homes for young people

If Planning Practice Guidlines state that the use of Green Beltshould only occur in very special circumstances these and the Brownfield sites in Runnymede must be extensively researched

I live in Wilson Drive and for many years now when i leave my house to go into the village or elsewhere thereis often gridlock in every direction The roads in our community are so heavily used by cars and lorries headingtoward the M25 Can you imagine the impact so many more of these will bring Driving has not been a pleasurefor a long time and i do walk wherever possible Parking is a problem in the village as so many people use theone car park I believe there may be a plan in the pipeline to even get rid of that for road widening

We have a GP practice in the village that is getting harder to book an appointment for also i have been waitingmonths for an appointment at St Peters hospital and just keep getting apologetic letters

Quality of life is very important for your residents and that quality has already deteriorated lately

1888

In order to accomodate so many new residents you will be making the ones you have feel very disappointedand frustated that no one listens

There is no going back once the desicion has been made and so many houses built Please take my feelings and iam sure very many more residents comments and pleas into account before you make the irreversible decisionto go ahead with your plans

Yours Faithfully

Margaret Wensley and the Wensley family

Beechwood

Wilson Drive

Ottershaw

Surrey

KT16 0NT

----------- middotn==middot =

Planning Services

DELIVERED BY HAND

Runnymede Borough Council ~--------------=-middot ---------middot------~

Planning Dept Runnymede Borough Council Civic Offices Station Road Addlestone KT15 2AH

Dear Sirs

Catherine Brunton-Green 20The Glen Addlestone

KT151AQ

15th February 2018

Runnymede Draft local Plan 2015- 2030- Final Consultation

I have serious concerns in respect of this draft plan Runnymede Borough Council (RBC) have a duty of care to consult with listen and act upon the wishes of its residents There has been some consultation but this has not effectively reached all Runnymede residents Communication is unnecessarily legally complex and full of unexplained acronyms The basic Runnymede Voice delivered to every home has been abandoned There has been no flyer delivered to every home stating in a simplified way what is happening so that all abilities may be catered for Many people are isolated for numerous reasons and do not have internet access Neither is there evidence of full in depth cross boundary consultation with adjacent boroughs This local plan is driven primarily by a developers charter promoted by RBCS Head of Planning It is both unfair unjust and I question its soundness

The Strategic Housing Market Assessment has not taken leaving the EU into account and makes a blanket assumption on Heathrow expansion

I strongly object to the proposed loss of c 560 acres of Green Belt Our Prime Minister and government have recently stated that they are quote committed to protecting and enhancing our natural environment for successive generations therefore Green Belt land would only be lost as a last resort 11

bull Detailed evidence based research by The Council for The Protection of Rural England confirms that by fully utilising brownfield land 12 million homes could be built in London and the South East without the loss of any Green Belt

I have objection to building on the Veterinary Laboratory Green Belt Land Parcel BRow Town (Policy SL11 8283) is not justified for development This is designated for 150 additional dwellings and 2 gypsyTraveller pitches This site provides a natural demarcation between developments either side Designated SANG area is privately owned and not available The density of proposed build is unacceptable and above all an area of outstanding natural beauty would be destroyed

Our infrastructure is unable to cope at present A320 suffers perpetual gridlock now Equally gridlock is evidenced through Ottershaw Addlestone Station Road and A317 Addlestone Weybridge We already have unhealthily dangerous levels of roadside nitrogen dioxide concentrations in many areas such as Station Road RBC has made a lame submission in respect of

tackling roadside nitrogen dioxide concentrations in the South East (UK00310) Incidence of exacerbated breathing illnesses in this vicinity has increased dramatically in the past 7 years All age groups are affected

All GP surgeries across Runnymede have great difficulty in recruiting doctors Two practices in the immediate area are merging due to unprecedented numbers of doctors leaving and retiring Practice lists and capacity is stretched Patient access to services and patient safety has to be the highest priority Our schools are similarly affected

RBC infrastructure is totally reliant upon Surrey County Council who declare they are not in a financial position to fund the necessary support to develop the infrastructure for this Local Plan

I am prepared to speak at Public Enquiry

Yours faithfully

bull i I I bull bull

From Brian PickettTo Planning PolicySubject Runnymede 2030 Local Plan - submission of viewsDate 22 February 2018 090921Attachments Ottershaw development Objection letter February 2018docx

Please find attached the submission of my views on the Runnymede 2030 LocalPlan

Kind RegardsBrian Pickett

1891

planningrunnymedegovuk planningrunnymedegovuk

21022018

Re Runnymede 2030 Local Plan Ottershaw East ndash Objection to planning

Dear Sirs

We are writing to you again as we strongly object to the Runnymede Borough Councils plans to remove land behind houses along Brox Road known as lsquoOttershaw Eastrsquo from the Green Belt We are objecting for a number of reasons listed below

middot The Green Belt is precious once it is gone it is gone forever The removal of this land from the Green Belt does not comply with Planning Policy which states ldquothat Green Belt boundaries should only be altered in exceptional circumstancesrdquo there are no such circumstances that can justify the removal of this piece of land

middot The Green Belt should be an area that is preserved for future generations to enjoy and appreciate and many statements have been made by both the Government and members of Parliament on their commitment to protect the Green Belt ndash these statements now need to be converted into action in the Local Borough Plans The roll out of Green Belt to local councils in the 1950rsquos was to prevent urban sprawl and the merging of settlements thereby helping to preserve and protect the character of communities it encompassed protect the country setting and encourage development through regeneration of sites within towns and cities not villages

middot The description of Ottershaw by the council itself in the lsquoUrban Characteristicsrsquo publication on the Runnymede Borough Council website states ldquoOttershaw has its own identity and sense of place which is partly derived from the clearly identifiable heart of the urban area focused on The Otter and adjoining local shopping parade and community facilities as well as being surrounded by open greenbelt countryside Removing this green belt that is part of the identifiable heart of Ottershaw would destroy this villagersquos identity and community

middot The planning proposals and building on this part of the green belt land would lead to a considerable population increase in the village Services and facilities will struggle or fail to cope space is already limited at the doctorrsquos surgery and school places are at capacity The transport infrastructure is already stretched with limited bus services busy roads poorly maintained pavements and road surfaces Brox road is already used as a shortcut to avoid traffic congestion Given that Ottershaw does not have a train station it is reasonable to assume that the majority of houses would have at least one car the added traffic from the new development would put a severe strain on the road network and users Available information on mitigation is very vague and very open to interpretation and misguided assumptions

middot The Green Belt land is a habitat to an array of plants and animals including important pollinator species and larger animals such as birds foxes and deer There should be no assumption that animals will simply move to another area habitats are established over many years and this development will be another loss to the maintenance of biodiversity I enjoy the fauna and flora in these areas going for walks along the public footpaths Having such wonderful access to a relaxing escape so close to home is priceless and something I hold dear to myself my family and community What is now a beautiful scenic view will become a spoilt urban sprawl of modern housing

middot I moved to Ottershaw with my wife in 2016 to settle down and start a family The relaxed quiet village sense of community and safety surrounded by beautiful countryside were its appeal I are very concerned and disappointed that this planning proposal is still being considered which will undoubtedly destroy this idyllic setting

There are no ldquoexceptional or very special circumstancesrdquo that justify the removal of Ottershaw East from the Green Belt We trust that the Council will therefore not remove ldquoOttershaw Eastrdquo and ldquoThe Fieldrdquo from the Green Belt

Yours faithfully

Dr Brian Pickett

To Policy Planning and Strategy Team Runnymede Borough Council Civic Centre Station Road Addlestone Surrey KT15 2AH planningrunnymedegovuk

From Dr Brian Pickett 139 Brox Road Ottershaw Surrey KT16 0LG planningrunnymedegovuk

21022018 Re Runnymede 2030 Local Plan Ottershaw East ndash Objection to planning Dear Sirs We are writing to you again as we strongly object to the Runnymede Borough Councils plans to remove land behind houses along Brox Road known as lsquoOttershaw Eastrsquo from the Green Belt We are objecting for a number of reasons listed below bull The Green Belt is precious once it is gone it is gone forever The removal of this

land from the Green Belt does not comply with Planning Policy which states ldquothat Green Belt boundaries should only be altered in exceptional circumstancesrdquo there are no such circumstances that can justify the removal of this piece of land

bull The Green Belt should be an area that is preserved for future generations to enjoy

and appreciate and many statements have been made by both the Government and members of Parliament on their commitment to protect the Green Belt ndash these statements now need to be converted into action in the Local Borough Plans The roll out of Green Belt to local councils in the 1950rsquos was to prevent urban sprawl and the merging of settlements thereby helping to preserve and protect the character of communities it encompassed protect the country setting and encourage development through regeneration of sites within towns and cities not villages

bull The description of Ottershaw by the council itself in the lsquoUrban Characteristicsrsquo

publication on the Runnymede Borough Council website states ldquoOttershaw has its own identity and sense of place which is partly derived from the clearly identifiable heart of the urban area focused on The Otter and adjoining local shopping parade and community facilities as well as being surrounded by open greenbelt countryside Removing this green belt that is part of the identifiable heart of Ottershaw would destroy this villagersquos identity and community

bull The planning proposals and building on this part of the green belt land would lead

to a considerable population increase in the village Services and facilities will struggle or fail to cope space is already limited at the doctorrsquos surgery and school places are at capacity The transport infrastructure is already stretched with limited bus services busy roads poorly maintained pavements and road surfaces Brox road is already used as a shortcut to avoid traffic congestion Given that Ottershaw does not have a train station it is reasonable to assume that the majority of houses would have at least one car the added traffic from the new development would put a severe strain on the road network and users Available information on mitigation is very vague and very open to interpretation and misguided assumptions

bull The Green Belt land is a habitat to an array of plants and animals including important pollinator species and larger animals such as birds foxes and deer There should be no assumption that animals will simply move to another area habitats are established over many years and this development will be another loss to the maintenance of biodiversity I enjoy the fauna and flora in these areas going for walks along the public footpaths Having such wonderful access to a relaxing escape so close to home is priceless and something I hold dear to myself my family and community What is now a beautiful scenic view will become a spoilt urban sprawl of modern housing

bull I moved to Ottershaw with my wife in 2016 to settle down and start a family The

relaxed quiet village sense of community and safety surrounded by beautiful countryside were its appeal I are very concerned and disappointed that this planning proposal is still being considered which will undoubtedly destroy this idyllic setting

There are no ldquoexceptional or very special circumstancesrdquo that justify the removal of Ottershaw East from the Green Belt We trust that the Council will therefore not remove ldquoOttershaw Eastrdquo and ldquoThe Fieldrdquo from the Green Belt Yours faithfully Dr Brian Pickett

FromTo Planning PolicySubject Runnymede Local Plan 2030 - consultation responseDate 21 February 2018 163608Attachments Runnymede LP Response - EE15pdf

Please find attached a consultation response form

________________________________________Christian Leigh BSc(Hons) MPhil MRTPIDirectorLeigh amp Glennie Ltd6 All Souls RoadAscotBerkshire SL5 9EA

1893

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number 01344 297094 Email Address (where relevant)

mailchristianleighcouk

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number Email Address (where relevant)

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

From MCNAB DouglasTo Planning PolicySubject Runnymede Draft Local Plan consultation - Representation from Education and Skills Funding AgencyDate 21 February 2018 091407Attachments Runnymede Reg 19 response ESFADOC

Dear Runnymede Planning Policy Team

Please see attached a representation from the Education and Skills Funding Agency on theRunnymede Local Plan consultation

I would be grateful if you could confirm receipt

Best regardsDoug

Douglas McNab MRTPIForward Planning Manager ndash South East

Planning Team Free Schools CapitalEducation and Skills Funding AgencyDepartment for Education 5th floor Sanctuary Buildings 20 Great Smith Street London SW1P 3BT

Email douglasmcnabeducationgovukMobile 07990 082877Web wwwgovukesfa

1895

image1pngOur Ref ESFALocal PlanRunnymede 2018 21st February 2018

Dear SirMadam

Re Runnymede Local Plan

Consultation under Regulation 19 of Town and Country Planning (Local Planning) (England) Regulations 2012

Submission of the Education and Skills Funding Agency

1 The Education and Skills Funding Agency (ESFA) welcomes the opportunity to contribute to the development of planning policy at the local level

2 The ESFA launched on 1st April 2017 bringing together the existing responsibilities of the Education Funding Agency (EFA) and the Skills Funding Agency (SFA) to create a single funding agency accountable for funding education and training for children young people and adults The ESFA are accountable for pound61 billion of funding a year for the education and training sector including support for all state-provided education for 8 million children aged 3 to 16 and 16 million young people aged 16 to 19

3 Under the provisions of the Education Act 2011 and the Academies Act 2010 all new state schools are now academiesfree schools and the ESFA is the delivery body for many of these rather than local education authorities As such we aim to work closely with local authority education departments and planning authorities to meet the demand for new school places and new schools We do this through a variety of means including by supporting the adoption of sound local plan policies site allocations and guidance (all based on robust evidence) that facilitate the delivery of education infrastructure where and when it is needed and maximise developer contributions for schools In this capacity we would like to offer the following comments in response to the proposals outlined in the above consultation document

Comments on the Local Plan

4 As you will be aware the primary focus at this stage of the Local Planrsquos preparation is on the soundness of the plan with regard to it being positively prepared justified effective and consistent with national policy The following detailed comments set out the ESFArsquos view of the planrsquos soundness in respect of education provision

5 The ESFA notes that the local plan will make provision for a minimum of 7413 net additional dwellings over the plan period Development will generally complement the existing settlement pattern focusing the largest amounts of residential growth primarily in Chertsey (1950 homes) Addlestone (936 homes) and Egham (812 homes) A new ldquolocally led garden villagerdquo is also proposed at Longcross providing a further 1718 homes This level of development will put pressure on existing education infrastructure

6 The plan recognises that ldquoIt is important that infrastructure is delivered in a timely manner to ensure that the needs of the occupiers of new development can be met without placing undue burdens on existing infrastructure facilities and servicesrdquo (para 560) The ESFA supports Policy SD6 Infrastructure Provision amp Timing particularly the signposting of the Infrastructure Delivery Plan (IDP) and the need for development to deliver this either on-site or through s106 or CIL financial contributions off-site and the need for development to be phased in line with the provision of important supporting infrastructure

7 The latest version of the IDP states that there is an ongoing programme of primary school expansions this will help to meet the forecast need for 4-6FE of new capacity over the plan period The need for one new build school project is identified a 2FE primary school at the Longcross Garden Village (estimated cost pound99M to pound15M) this is referred to in the site allocation policies (see below) With respect to secondary school places it is anticipated that up to six additional FE could be required in the Borough by 2021 Additional places will be delivered through the new 6FE Runnymede Free School (which opened in temporary accommodation in 2017) development of additional FE within Salesian School (Catholic faith school) and expansion of another school in the Chertsey area (to accommodate demand from generated by the Longcross Garden Village site)

8 It would be useful if the background data informing these projections of need could be clarified particularly the pupil yield factors used and the evidence base supporting this This would help to demonstrate more clearly to the Inspector that the approach to the planning and delivery of education infrastructure has been positively prepared based on a strategy which seeks to meet objectively assessed infrastructure requirements and is justified based on proportionate evidence The ESFA notes that the Runnymede S106 SPG sets out pupil yield figures however this document dates from December 2007 so the figures may be outdated

9 The ESFA supports the Councilrsquos allocation and safeguarding of land for schools as set out in the following policies

middot Policy SD10 Longcross Garden Village - 2FE primary school with preschoolearly years settings

middot Policy SL2 to SL18 ndash series of housing allocation policies that highlight the need to make a financial contribution to early years primary and secondary school infrastructure ldquoeither through S106 or CIL (or its successor)rdquo

Developer Contributions and CIL

10 One of the tests of soundness is that a Local Plan is lsquoeffectiversquo ie the plan should be deliverable over its period In this context and with specific regard to planning for schools there is a need to ensure that education contributions made by developers are sufficient to deliver the additional school places required to meet the increase in demand generated by new developments The ESFA notes that the council has not adopted CIL and that the Planning Obligations SPG sets out how developer contributions to education provision will be secured via section 106 agreements The ESFA supports the Councilrsquos approach to ensure developer contributions address the impacts arising from growth However the ESFA recommends that the Local Plan includes a commitment to revise the Planning Obligations SPG in line with the latest evidence of the boroughrsquos infrastructure needs pupil yields and build costs (including the cost of school expansion new build and SEN provision) Any such review should be prepared in consultation with the county council as local education authority This will help to ensure appropriate rates are levied and the right infrastructure is secured across the borough

11 The ESFA would be particularly interested in responding to any update to the Infrastructure Delivery Plan or review of infrastructure requirements As such please add the ESFA to the database for future CIL consultations

Forward funding

12 In light of the proposed Longcross Garden Village emerging ESFA proposals for forward funding schools as part of large residential developments may be relevant for example if viability becomes an issue The ESFA aims to be able to clarify forward funding options for schools in 2018 We would be happy to meet to discuss this opportunity further once the options have been finalised and ifwhen relevant Any offer of forward funding would seek to maximise developer contributions to education infrastructure provision while supporting delivery of schools where and when they are needed

Conclusion

13 Finally I hope the above comments are helpful in finalising the Runnymede Local Plan with specific regard to the provision of land for new schools

14 Please notify the ESFA when the Local Plan is submitted for examination the Inspectorrsquos report is published and the Local Plan is adopted

15 Please do not hesitate to contact me if you have any queries regarding this response The ESFA looks forward to continuing to work with Runnymede Borough Council to develop a sound Local Plan that will aid in the delivery of new schools

Yours faithfully

DC McNab

Douglas McNab MRTPI

Forward Planning Manager

Tel 07990 082877

Email

douglasmcnabeducationgovuk

Web

wwwgovuk esfa

Education and Skills Funding Agency13

Department for EducationSanctuary BuildingsGreat Smith StreetLondonSW1P 3BT13

13

Tel 0207 340 700013

13

wwwgovukesfa13

13

13

To

Policy Planning and Strategy Team

Runnymede Borough Council

Civic Centre

Station Road

Addlestone

Surrey

KT15 2AH

From

Dr Brian Pickett

139 Brox Road

Ottershaw

Surrey

KT16 0LG

Title

Mrs

First Name

Caroline

Last Name

Craven

Job Title

(where relevant)

Organisation

(where relevant)

Address Line 1

Southover

Line 2

Hurst Lane

Line 3

Egham

Line 4

Surrey

Post Code

TW20 8QJ

Telephone Number

07770999572

Email Address

(where relevant)

Carolinecraven911hotmailcom

Page 9: Runnymede Borough Council, for submissions. My contact details are all in the WORD letter attached. But I will provide my telephone number here too, which …

6

housing on neighbouring land and preferred sites within 5km results in increased recreational use of this site and has potential to disturb bird feeding and breeding behaviourrdquo These pathways to damage in AECOMrsquos so-called Appropriate Assessment are then conveniently screened out just because there is a Runnymede Policy to provide SANG as related to the TBH Delivery Framework The fact that Trumps Farm is in the wrong place to provide effective green space as mitigation in paragraphs 863 to 868 of AECOMrsquos conclusions as an alternative for peoplersquos recreation with their dogs is wrong Also the effect of roaming cats is completely ignored by this organisation so that any cats present in the 1750 nearby proposed dwellings will be at liberty to kill the Annex 1 birds present on the adjoining Chobham Common as well as the reptiles and amphibians they encounter

The dictionary definition of mitigation is to alleviate diminish or moderate I cannot see how a mitigation site 15 kilometresrsquo away will provide proper mitigation when so many people are being told to forsake their cars and to get out and exercise An on-site SANG must be provided at the west end of the DERA South site where the Longcross Barracks were and the Longcross Garden Village itself must be double fenced at itsrsquo boundary with the B386 road to exclude people and their animals from walking straight out onto Chobham Common if the development of SLAA 99 goes ahead as specified in the Local Plan A large on-site SANG will help reduce lighting spread and other urbanisation effects associated with this development and identified by AECOM elsewhere in their various HRAs for this Local Plan Any visible lighting on Chobham Common SPA will damage this site from their statements I am not sure this fact has registered with AECOMrsquos HRA writers

In the latest version of the AECOM HRA for the Runnymede Local Plan dated December 2017 and taking account of the Conservation of Habitats and Species Regulations 2017 one has to ask what has AECOM and all the promoters of Longcross Garden Village got to hide when the SANG site to divert residents away from the adjacent Chobham Common site within the Thames Basin Heaths SPA is not even mentioned Are Runnymede Borough Council providing a mitigation site or not The Conservation of Habitats and Species Regulations 2017 states in paragraph 63 (5) ldquoIn the light of the conclusions of the assessment and subject to regulation 64 the competent authority may agree to the plan or project only after having ascertained that it will not adversely affect

7

the integrity of the European siterdquo If no named SANG site is to be provided than the competent authority Runnymede Borough Council cannot conclude that no damage will occur to the integrity of the Chobham Common site as a result of the approval of itsrsquo Local Plan in its current format

3 Natural England used to be a proper nature conservation organisation before 2010 before the previous coalition Government of David Cameron and particularly Owen Paterson when Secretary of State for The Environment Food and Rural Affairs from 2012 ruined it and turned into another pro-development organisation negating itsrsquo roles via the 2012 statement that it could no longer campaign to objectively protect wildlife Itsrsquo role always was to shout loudly to protect wildlife and it should in my opinion now be recording objections to stop adverse developments such as SLAA 99 But with AECOMrsquos statement in paragraph 817 of the AECOM June 2016 HRA that Natural England already have an agreement with Crest Nicholson that a ldquowhole site SANG strategy has been agreedrdquo and that an ldquoadverse effect on the integrity on the Thames Basin Heaths would not ariserdquo subject to the delivery of the agreed SANGS shows Natural England has already been compromised in the negotiations Clearly there is a conflict with the statement in paragraph 817 in the summary ldquoLocating housing more than 400m from the SPA boundaryrdquo and para 835 which states that DERA South site is only 280m from the SPA boundary What is not clear from this early HRA and subsequent updated versions by AECOM is whether housing will be developed and established at a point of only 280m or less from the SPA boundary conforming to the boundary of the DERA South site or at the 400m buffer distance Which is it

It is clear that Natural Englandrsquos role in protecting Chobham Common has been compromised already they should be sticking to their 2006 position clearly if this development goes ahead referral to European Courts of Justice is necessary Already before BREXIT is completed the UK Government cannot be trusted to ensure our richest wildlife sites are protected when the same UK Government own ldquobrownfieldrdquo sites such as DERA South adjacent to these SPA sites The HS2 in England proposals and the Gwent Levels development proposals for the M4 in Wales are already evidence of their despicable and cavalier record of

8

damage to Sites of Special Scientific Interest Such damage is not acceptable I urge Runnymede Borough Council and the UK Government to think again about a different policy for this sensitive location of DERA South

4 Natural England should be putting Englandrsquos wildlife considerations first NOT the Governmentrsquos economic development initiatives I ask here that both DEFRA and Natural England intervene in this consultation and the subsequent inspection (as a consequence this objection will be sent to both of them) because the SLAA 99 development proposals and the so-called mitigation make a travesty of nature conservation and will only further damage the Chobham Common SSSI and its wildlife species

5 Clearly AECOMrsquos conclusion with regard to disturbance of the Annex 1 birds on Chobham Common in their paragraphs 863 and 868 of the May 2017 HRA and also in paragraphs 851 to 853 of the December 2017 version is wrong and seriously flawed because it fails to take in the proximity of the DERA South development to the SPA site of Chobham Common Also when the Trumps Farm SANG is over one mile distant and the originally proposed of a 55 hectare woodland SANG mentioned in paragraph 817 of the June 2016 HRA version does not fit to the Natural Englandrsquos preferred SANG size for a large development Nor is a woodland SANG normally safe for women walking alone with a dog the original preference for a SANG was that it should replicate the open nature of the heathland sitesrsquo the public like to use for dog-walking

Runnymede Borough Councilrsquos policy for the provision of SANG is not sufficient for it to work as mitigation it must be easier to get to and access the SANG than the adjoining SPA site and the Trumps Farm site fails in this provision Clearly Natural England and the UK Government are conveniently failing to understand what must be staring them in the face if they were honest that SLAA 99 development proposals will both damage and cause disturbance to the wildlife of Chobham Common As a part of the Thames Basin Heaths SPA and with an agreed Delivery Framework for SANGS in the Thames Basin Area if SLAA 99 is accepted in this Local Plan with the existing SANG proposals this will be unacceptable to me This will then form a part of a complaint to the European Commission as currently we are still subject to the judgements of the European Court of Justice

9

6 AECOMrsquos conclusions in paragraph 865 of the June 2016 HRA 868 of the May 2017 HRA and AA and lastly in paragraphs 851 to 853 of the December 2017 HRA and AA is what you expect from AECOM a complete disregard for the issues based on just a Council policy of the provision of SANG irrespective of itsrsquo location and proximity to the proposed development Equally as the Planning Inspectorate is under the same UK Government ldquocoshrdquo as Natural England to enable the provision of more housing for the so-called housing crisis It is not a shortage of housing that is evident in England it is a clear case of overpopulation with successive governments failing to govern and do anything about excessive breeding of the native human population and uncontrolled inward migration of human numbers into the UK particularly in southern England Before the next round of housing proposals in this area post 2030 the UK Government must act to reduce the excessive human population growth in the Runnymede area and the excessive expansion of the London region I can already see the claims for the forthcoming Planning Inspection and future ones probably by the Housebuilderrsquos Federation and the agents or QCs for the private housebuilding companies (a QC was employed by one developerrsquos agent for the East Hampshire Joint Core Strategy to argue for more housing to be achieved within that area and Local Plan) that people are more important than wildlife and that we must build on the SPAs or very close to them as in the current Runnymede Local Plan This failure to properly mitigate for the development of the so-called Longcross Garden Village is the start of the destruction of one of Britainrsquos best remaining lowland heathland sites A national disgrace

The SLAA 99 proposal and the proposals to remove land from the greenbelt in this Local Plan are as clear evidence of the overpressure of people numbers on the finite land resource of England (ldquoThe UKs population is projected to reach 70 million by 2030 ndash thatrsquos nine million more people than in 2008rdquo Ref Forum for the Future in 2010 ldquoUK population grows by over 400000 in the last year the largest absolute increase of any European countryrdquo Ref Population Mattersrsquo research in August 2013 ldquoEnglandrsquos population is already twice that of Germany per square mile and four times that of France It is our quality of life that is being affectedrdquo Ref Lord Horam speaking in February 2018 in the House of Lordrsquos debate on ldquoBrexit and the labour marketrdquo As the Planning

10

Inspector stated at the commencement of the Inspection of the East Hampshire Joint Core Strategy that I was present at in 2013 ldquoI have been given a growth agendardquo With this type of pressure by the UK Government I am not sure that I or nature conservation can expect a fair and objective hearing in 2018 when I object to Runnymede Borough Councilrsquos Local Plan 2030 we will see

7 For the proximity of the DERA South development to the SPA site of Chobham Common there is one potential solution and that is to reduce the number of houses in the DERA South (Longcross Garden Village) proposal and to make a new large SANG out of the land at the western end of the DERA South site This would require the ldquoDuty of Cooperationrdquo to be observed as the extreme west end of the DERA South site as it is within the land area of Surrey Heath Borough Council but I am sure this could be achievable This area would have to be fenced with dense mesh topped with rolled razor wire or similar to prevent free roaming dogs and cats from going onto the Chobham Common site south of the M3 and B386 roads If this fence was sufficiently high and doubled up to make two fences these could be used to keep the public and their animals away from and out of the SPA of Chobham Common and also necessarily to confine the loose running dogs a requirement for SANGS from being run-over on the B386 and the other connecting roads

8 The SPD issued and adopted by Surrey Heath Borough Council states I paragraph 57 ldquoIn the period up to 2028 Surrey Heath is expected to grant planning permission for 324010 new homes and this will require the provision of over 60 hectares of SANG Major or large new developments will be expected to provide bespoke on-site SANG rather than relying on the suite of SANGs being developed by the Borough Councilrdquo SLAA 99 is a large development so it should lose some of its housing land to provide on-site SANG to separate itsrsquo housing provision from Chobham Common

Similarly for Runnymede a large amount of new homes will result from the conclusions of the Planning Inspection Almost certainly more than proposed at the moment (this was the experience in East Hampshire in 2013) In this case and similar to the proposals adopted for SLAA 97 SANG provision for SLAA 99 (which appears to be scheduled to provide

11

the largest number of homes and something like 7000 extra people in Runnymede Borough) the SANG needs to be onsite and the solution I propose in this paragraph would cater for this Hoping new residents will all get in their cars to take the dog or cat for a walk over one mile away on Trumps Farm is not sustainable practicable or likely AECOMrsquos HRA and AA of both May and December 2017 completely fail to address the roaming catrsquos issue Despite AECOMrsquos clearly different point-of-view I do not believe that Runnymede Borough Council in their role as lsquocompetent authorityrsquo can conclude that no adverse effect on the integrity of internationally important wildlife sites of the Thames Basin Heathrsquos SPA will result from their proposals in their Local Plan 2030 as a consequence of what I consider are flawed conclusions proposed by AECOM The only light at the end of the tunnel of flawed conclusions in my opinion by AECOM is their final paragraph in the Dec 2017 HRA and AA that at paragraph 93 ldquoHowever it is recommended that the potential for further bespoke or strategic SANG later in the plan period is explored by the Council in time for Examination in Publicrdquo

I suggest to the Planning Inspector and Runnymede Borough Council that an on-site large SANG at the west end of the DERA South site should be provided as greenspace which would help to alleviate the potential for disturbance by residents of the new garden village from having to go or preferring to go to Chobham Common with the dog because this SANG site would be nearer Housing development adjacent to heathland always damages it especially if local arsonists are imported nearby but my proposals would go a long way to making the proposed Local Plan sound Though it would be far better if this garden village was scrapped and the DERA South site restored to heathland or just converted to another employment site as that would do far less damage to the Chobham Common SSSI and SPA site

____________________

Stephen R Miles 21st February 2018

From Caroline CravenTo Planning PolicySubject Representation for Local PlanDate 22 February 2018 092519Attachments Representation_form_for_Regulation_19_Caroline_Cravendocx

Please find attached my representation form in response to the Runnymede 2030 Local PlanConsultation

Regards helliphellip Caroline Craven

1886

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full contact details of the agent in 2

Part B (1) ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

XParagraph PolicyPolicies Map

X

X

X

4 Do you consider the Local Plan is

x

4 (1) Legally compliant Yes No

X

4 (2) SoundYes No

x

4 (3) Complies with the Duty to co-operateYesNo

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the duty to co-operate please also use this box to set out your comments

I believe the Local Plan does not comply with the duty to co-operate with neighbouring Boroughs The previous version was not deemed to be compliant as I understand it and there does not appear to be any significant changes that allow this plan to be compliant

RBC seems to have relied on the former Statement of Community Involvement (SCI) of 2014 In a digital age 15 lines in a local (The Villager Feb 9th) on page 11 is a poor means of communication to the Runnymede Borough residents on something that will affect them so deeply

In addition the views expressed at the RBC meeting by the attending RBC councillors were essentially that they accepted it wasnrsquot as good as it should be but was lsquothe best wersquore going to get at the momentrsquo and if not submitted then a Government Inspector would be appointed and they would lose control ndash a view I can fully understand but does not give the Runnymede residents a feeling of confidence in the legality or the integrity of the plan nor that the council truly want the best for the Borough

With regard to the Longcross site improvements to the station do not address the capacity issue The impact to commuters further up the line will be significant Peak times will be heavily impacted If additional trains are being proposed on this line the impact to the residents of Egham who already have to wait some 35-40 minutes in the hour whilst gates are down would therefore have even less opportunity to transverse the line at the crossing points Longcross station has no accessible car parking or drop off points This would necessitate commuters travelling to Virginia Water Egham whose own parking capability is limited Virginia Water has lost a large number of station car park spaces due to a new development This would also cause increased congestion in already known problem junctions The additional burden to the A320 which is already operating over practical capacity at several junctions and expected to deteriorate over the coming years would be significant (A320 Corridor Study ndash Feasibility Study ndash Interim report February 2018)

(Continue on a separate sheetexpand box if necessary)

The Longcross site will also need medical facilities ndash GPrsquos and potentially NHS drop in centre to ensure the current burden on the NHS is not exacerbated

With regard to the Traveller pitches they appear to amount to 35 within the scope of the development areas However the council plan to deliver 131 net additional plotspitches ndash 96 of which are not covered in this local plan This is an extremely emotive subject and needs to be identified properly in the plan and not almost hidden to avoid confrontation with angry residents that this County is already over run with these communities Integration with new developments is not the answer ndash Allocation of Traveller sites and pitches is according to the Government guidelines ldquoinappropriate within the Green beltrdquo and trying to slide this surreptitiously into new developments is a totally inappropriate solution

The Hurst Lane development was dismissed by the Council despite the residents being on board and a sustainable and acceptable plan being put forward for c 800-1000 homes on 80 -100 acres Over time this Lane has deteriorated to the point that Planning Inspectors described it as an lsquoindustrial wastelandrsquo In addition the Council resources are being tied up with the numerous issues generated by the Lane and the inability to resolve with the resources available The primary reason given is that the land is lsquoGreen Beltrsquo although under exceptional circumstances (which I believe this would come under) the council are able to and plan to in other areas use this land It is effectively a brownfield site which could be permitted fi connected to a SANG trade off which the residents plan was

6 Please set out what modification (s) you consider necessary to make the Local Plan legally compliant or sound having regard to the Matter you have identified at 5 above where this relates to soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of modification at examination) You will need to say why this modification will make the Local Plan legally compliant or sound It will be helpful if you are able to put forward your suggested revised wording of any policy or text Please be as precise as possible

For the plan to be sound I believe that

1) Review the inclusion of the Hurst Lane site ndash SLAA 59 ndash within the plan Appendix B states the capacity of 10 for Hurst Lane and 5 for Padd Farm If this relates to additional properties the number does not reflect the plans of up to 800 houses Access and infrastructure are addressed and the reduction in headcount in the councilrsquos Customer Services (I believe there is a dedicated resource looking after Padd Farm Hurst Lane) would be an additional benefit

2) Greater publicity is required over the consultation process The council appear to work on a lsquopullrsquo basis in that residents of the borough (other than those in the Residents Associations) have to actively seek out any updates from the council Local newspapers are not a good way of disseminating information in the digital age

3) Identify the additional travellergypsy site plans and move outside of the Green Belt area

If these steps were taken the residents would all have ample opportunity to contribute to the development of the local plan

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further representations based on the original representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

7 If your representation is seeking a modification do you consider it necessary to participate at the oral part of the examination

No I do not wish to participate Yes I wish to participate

X

at the oral examinationat the oral examination

8 If you wish to participate at the oral part of the examination please outline why you consider this to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who have indicated that they wish to participate at the oral part of the examination

9 Signature Date

21st February 2018

Caroline Craven

Notes to Accompany Model Representation Form

1 Introduction

11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 2004[footnoteRef1] (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound [1 View at httpwwwlegislationgovukukpga20045contents ]

2 Legal Compliance and Duty to Co-operate

21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness

22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)[footnoteRef2] it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices [2 LDDs are defined in regulation 5 ndash see link below ]

bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications

bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)[footnoteRef3] On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified [3 View at httpwwwlegislationgovukuksi2012767contentsmade ]

bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy)

23 You should consider the following before making a representation on compliance with the duty to co-operate

bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty

bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

3 Soundness

31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy

bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development

bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence

bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities

bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF

32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations

bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included

bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan

bull If the policy is not covered elsewhere in what way is the plan unsound without the policy

bull If the plan is unsound without the policy what should the policy say

4 General advice

41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

6

image1png

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full contact details of the agent in 2

Title Mrs First Name Caroline Last Name Craven Job Title (where relevant)

Organisation (where relevant)

Address Line 1 Southover Line 2 Hurst Lane Line 3 Egham Line 4 Surrey Post Code TW20 8QJ Telephone Number Email Address (where relevant)

2

Part B (1) ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

XParagraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails to comply with the duty to co-operate Please be as precise as possible If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

X X X

x

X

x

I believe the Local Plan does not comply with the duty to co-operate with neighbouring Boroughs The previous version was not deemed to be compliant as I understand it and there does not appear to be any significant changes that allow this plan to be compliant

RBC seems to have relied on the former Statement of Community Involvement (SCI) of 2014 In a digital age 15 lines in a local (The Villager Feb 9th) on page 11 is a poor means of communication to the Runnymede Borough residents on something that will affect them so deeply

In addition the views expressed at the RBC meeting by the attending RBC councillors were essentially that they accepted it wasnrsquot as good as it should be but was lsquothe best wersquore going to get at the momentrsquo and if not submitted then a Government Inspector would be appointed and they would lose control ndash a view I can fully understand but does not give the Runnymede residents a feeling of confidence in the legality or the integrity of the plan nor that the council truly want the best for the Borough

With regard to the Longcross site improvements to the station do not address the capacity issue The impact to commuters further up the line will be significant Peak times will be heavily impacted If additional trains are being proposed on this line the impact to the residents of Egham who already have to wait some 35-40 minutes in the hour whilst gates are down would therefore have even less opportunity to transverse the line at the crossing points Longcross station has no accessible car parking or drop off points This would necessitate commuters travelling to Virginia Water Egham whose own parking capability is limited Virginia Water has lost a large number of station car park spaces due to a new development This would also cause increased congestion in already known problem junctions The additional burden to the A320 which is already operating over practical capacity at several junctions and expected to deteriorate over the coming years would be significant (A320 Corridor Study ndash Feasibility Study ndash Interim report February 2018)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally compliant or sound having regard to the Matter you have identified at 5 above where this relates to soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of modification at examination) You will need to say why this modification will make the Local Plan legally compliant or sound It will be helpful if you are able to put forward your suggested revised wording of any policy or text Please be as precise as possible

For the plan to be sound I believe that

1) Review the inclusion of the Hurst Lane site ndash SLAA 59 ndash within the plan Appendix B states the capacity of 10 for Hurst Lane and 5 for Padd Farm If this relates to additional properties the number does not reflect the plans of up to 800 houses Access and infrastructure are addressed and the reduction in headcount in the councilrsquos Customer Services (I believe there is a dedicated resource looking after Padd Farm Hurst Lane) would be an additional benefit

2) Greater publicity is required over the consultation process The council appear to work on a lsquopullrsquo basis in that residents of the borough (other than those in the Residents Associations) have to actively seek out any updates from the council Local newspapers are not a good way of disseminating information in the digital age

3) Identify the additional travellergypsy site plans and move outside of the Green Belt area

If these steps were taken the residents would all have ample opportunity to contribute to the development of the local plan

The Longcross site will also need medical facilities ndash GPrsquos and potentially NHS drop in centre to ensure the current burden on the NHS is not exacerbated

With regard to the Traveller pitches they appear to amount to 35 within the scope of the development areas However the council plan to deliver 131 net additional plotspitches ndash 96 of which are not covered in this local plan This is an extremely emotive subject and needs to be identified properly in the plan and not almost hidden to avoid confrontation with angry residents that this County is already over run with these communities Integration with new developments is not the answer ndash Allocation of Traveller sites and pitches is according to the Government guidelines ldquoinappropriate within the Green beltrdquo and trying to slide this surreptitiously into new developments is a totally inappropriate solution

The Hurst Lane development was dismissed by the Council despite the residents being on board and a sustainable and acceptable plan being put forward for c 800-1000 homes on 80 -100 acres Over time this Lane has deteriorated to the point that Planning Inspectors described it as an lsquoindustrial wastelandrsquo In addition the Council resources are being tied up with the numerous issues generated by the Lane and the inability to resolve with the resources available The primary reason given is that the land is lsquoGreen Beltrsquo although under exceptional circumstances (which I believe this would come under) the council are able to and plan to in other areas use this land It is effectively a brownfield site which could be permitted fi connected to a SANG trade off which the residents plan was

4

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further representations based on the original representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

7 If your representation is seeking a modification do you consider it necessary to participate at the oral part of the examination

No I do not wish to participate Yes I wish to participate at the oral examination at the oral examination

8 If you wish to participate at the oral part of the examination please outline why you consider this to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who have indicated that they wish to participate at the oral part of the examination

9 Signature Date

X

Caroline Craven 21st February 2018

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan 1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination 42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

FromPolicy

Subject FW New Housing Plans 2015-2030Date 21 February 2018 164919

Sent 21 February 2018 1608To PlanningSubject New Housing Plans 2015-2030

To

Policy Planning and Strategy Team

Runnymede Borough Council

Station Road

Addlestone

21022018

Dear Sirs

As an Ottershaw resident of nearly 30 years i would like you to read and take on board my objections to yourproposal to take land out of the green belt for housing and your plan to build so many houses in ourcommunity

Of course new houses have to be built right across the country now and in the future but i feel the plans youhave are for far too many houses The infrastructure of our community will just not sustain the extra amount ofpeople and cars and the general traffic that would entail

There are other possibilities available before your irreversible plans are put into action Are these possibilitiesbeing resourced

When i drive around the borough now and for a long long time i see so many empty office blocks Some ofthese have stood empty for yearsWhy has permission been given continuosly from what i can see on a huge scale for these to be built

This building of offices has to stop and the ones that have remained empty for years could be converted tohousing as in flats starter homes for young people

If Planning Practice Guidlines state that the use of Green Beltshould only occur in very special circumstances these and the Brownfield sites in Runnymede must be extensively researched

I live in Wilson Drive and for many years now when i leave my house to go into the village or elsewhere thereis often gridlock in every direction The roads in our community are so heavily used by cars and lorries headingtoward the M25 Can you imagine the impact so many more of these will bring Driving has not been a pleasurefor a long time and i do walk wherever possible Parking is a problem in the village as so many people use theone car park I believe there may be a plan in the pipeline to even get rid of that for road widening

We have a GP practice in the village that is getting harder to book an appointment for also i have been waitingmonths for an appointment at St Peters hospital and just keep getting apologetic letters

Quality of life is very important for your residents and that quality has already deteriorated lately

1888

In order to accomodate so many new residents you will be making the ones you have feel very disappointedand frustated that no one listens

There is no going back once the desicion has been made and so many houses built Please take my feelings and iam sure very many more residents comments and pleas into account before you make the irreversible decisionto go ahead with your plans

Yours Faithfully

Margaret Wensley and the Wensley family

Beechwood

Wilson Drive

Ottershaw

Surrey

KT16 0NT

----------- middotn==middot =

Planning Services

DELIVERED BY HAND

Runnymede Borough Council ~--------------=-middot ---------middot------~

Planning Dept Runnymede Borough Council Civic Offices Station Road Addlestone KT15 2AH

Dear Sirs

Catherine Brunton-Green 20The Glen Addlestone

KT151AQ

15th February 2018

Runnymede Draft local Plan 2015- 2030- Final Consultation

I have serious concerns in respect of this draft plan Runnymede Borough Council (RBC) have a duty of care to consult with listen and act upon the wishes of its residents There has been some consultation but this has not effectively reached all Runnymede residents Communication is unnecessarily legally complex and full of unexplained acronyms The basic Runnymede Voice delivered to every home has been abandoned There has been no flyer delivered to every home stating in a simplified way what is happening so that all abilities may be catered for Many people are isolated for numerous reasons and do not have internet access Neither is there evidence of full in depth cross boundary consultation with adjacent boroughs This local plan is driven primarily by a developers charter promoted by RBCS Head of Planning It is both unfair unjust and I question its soundness

The Strategic Housing Market Assessment has not taken leaving the EU into account and makes a blanket assumption on Heathrow expansion

I strongly object to the proposed loss of c 560 acres of Green Belt Our Prime Minister and government have recently stated that they are quote committed to protecting and enhancing our natural environment for successive generations therefore Green Belt land would only be lost as a last resort 11

bull Detailed evidence based research by The Council for The Protection of Rural England confirms that by fully utilising brownfield land 12 million homes could be built in London and the South East without the loss of any Green Belt

I have objection to building on the Veterinary Laboratory Green Belt Land Parcel BRow Town (Policy SL11 8283) is not justified for development This is designated for 150 additional dwellings and 2 gypsyTraveller pitches This site provides a natural demarcation between developments either side Designated SANG area is privately owned and not available The density of proposed build is unacceptable and above all an area of outstanding natural beauty would be destroyed

Our infrastructure is unable to cope at present A320 suffers perpetual gridlock now Equally gridlock is evidenced through Ottershaw Addlestone Station Road and A317 Addlestone Weybridge We already have unhealthily dangerous levels of roadside nitrogen dioxide concentrations in many areas such as Station Road RBC has made a lame submission in respect of

tackling roadside nitrogen dioxide concentrations in the South East (UK00310) Incidence of exacerbated breathing illnesses in this vicinity has increased dramatically in the past 7 years All age groups are affected

All GP surgeries across Runnymede have great difficulty in recruiting doctors Two practices in the immediate area are merging due to unprecedented numbers of doctors leaving and retiring Practice lists and capacity is stretched Patient access to services and patient safety has to be the highest priority Our schools are similarly affected

RBC infrastructure is totally reliant upon Surrey County Council who declare they are not in a financial position to fund the necessary support to develop the infrastructure for this Local Plan

I am prepared to speak at Public Enquiry

Yours faithfully

bull i I I bull bull

From Brian PickettTo Planning PolicySubject Runnymede 2030 Local Plan - submission of viewsDate 22 February 2018 090921Attachments Ottershaw development Objection letter February 2018docx

Please find attached the submission of my views on the Runnymede 2030 LocalPlan

Kind RegardsBrian Pickett

1891

planningrunnymedegovuk planningrunnymedegovuk

21022018

Re Runnymede 2030 Local Plan Ottershaw East ndash Objection to planning

Dear Sirs

We are writing to you again as we strongly object to the Runnymede Borough Councils plans to remove land behind houses along Brox Road known as lsquoOttershaw Eastrsquo from the Green Belt We are objecting for a number of reasons listed below

middot The Green Belt is precious once it is gone it is gone forever The removal of this land from the Green Belt does not comply with Planning Policy which states ldquothat Green Belt boundaries should only be altered in exceptional circumstancesrdquo there are no such circumstances that can justify the removal of this piece of land

middot The Green Belt should be an area that is preserved for future generations to enjoy and appreciate and many statements have been made by both the Government and members of Parliament on their commitment to protect the Green Belt ndash these statements now need to be converted into action in the Local Borough Plans The roll out of Green Belt to local councils in the 1950rsquos was to prevent urban sprawl and the merging of settlements thereby helping to preserve and protect the character of communities it encompassed protect the country setting and encourage development through regeneration of sites within towns and cities not villages

middot The description of Ottershaw by the council itself in the lsquoUrban Characteristicsrsquo publication on the Runnymede Borough Council website states ldquoOttershaw has its own identity and sense of place which is partly derived from the clearly identifiable heart of the urban area focused on The Otter and adjoining local shopping parade and community facilities as well as being surrounded by open greenbelt countryside Removing this green belt that is part of the identifiable heart of Ottershaw would destroy this villagersquos identity and community

middot The planning proposals and building on this part of the green belt land would lead to a considerable population increase in the village Services and facilities will struggle or fail to cope space is already limited at the doctorrsquos surgery and school places are at capacity The transport infrastructure is already stretched with limited bus services busy roads poorly maintained pavements and road surfaces Brox road is already used as a shortcut to avoid traffic congestion Given that Ottershaw does not have a train station it is reasonable to assume that the majority of houses would have at least one car the added traffic from the new development would put a severe strain on the road network and users Available information on mitigation is very vague and very open to interpretation and misguided assumptions

middot The Green Belt land is a habitat to an array of plants and animals including important pollinator species and larger animals such as birds foxes and deer There should be no assumption that animals will simply move to another area habitats are established over many years and this development will be another loss to the maintenance of biodiversity I enjoy the fauna and flora in these areas going for walks along the public footpaths Having such wonderful access to a relaxing escape so close to home is priceless and something I hold dear to myself my family and community What is now a beautiful scenic view will become a spoilt urban sprawl of modern housing

middot I moved to Ottershaw with my wife in 2016 to settle down and start a family The relaxed quiet village sense of community and safety surrounded by beautiful countryside were its appeal I are very concerned and disappointed that this planning proposal is still being considered which will undoubtedly destroy this idyllic setting

There are no ldquoexceptional or very special circumstancesrdquo that justify the removal of Ottershaw East from the Green Belt We trust that the Council will therefore not remove ldquoOttershaw Eastrdquo and ldquoThe Fieldrdquo from the Green Belt

Yours faithfully

Dr Brian Pickett

To Policy Planning and Strategy Team Runnymede Borough Council Civic Centre Station Road Addlestone Surrey KT15 2AH planningrunnymedegovuk

From Dr Brian Pickett 139 Brox Road Ottershaw Surrey KT16 0LG planningrunnymedegovuk

21022018 Re Runnymede 2030 Local Plan Ottershaw East ndash Objection to planning Dear Sirs We are writing to you again as we strongly object to the Runnymede Borough Councils plans to remove land behind houses along Brox Road known as lsquoOttershaw Eastrsquo from the Green Belt We are objecting for a number of reasons listed below bull The Green Belt is precious once it is gone it is gone forever The removal of this

land from the Green Belt does not comply with Planning Policy which states ldquothat Green Belt boundaries should only be altered in exceptional circumstancesrdquo there are no such circumstances that can justify the removal of this piece of land

bull The Green Belt should be an area that is preserved for future generations to enjoy

and appreciate and many statements have been made by both the Government and members of Parliament on their commitment to protect the Green Belt ndash these statements now need to be converted into action in the Local Borough Plans The roll out of Green Belt to local councils in the 1950rsquos was to prevent urban sprawl and the merging of settlements thereby helping to preserve and protect the character of communities it encompassed protect the country setting and encourage development through regeneration of sites within towns and cities not villages

bull The description of Ottershaw by the council itself in the lsquoUrban Characteristicsrsquo

publication on the Runnymede Borough Council website states ldquoOttershaw has its own identity and sense of place which is partly derived from the clearly identifiable heart of the urban area focused on The Otter and adjoining local shopping parade and community facilities as well as being surrounded by open greenbelt countryside Removing this green belt that is part of the identifiable heart of Ottershaw would destroy this villagersquos identity and community

bull The planning proposals and building on this part of the green belt land would lead

to a considerable population increase in the village Services and facilities will struggle or fail to cope space is already limited at the doctorrsquos surgery and school places are at capacity The transport infrastructure is already stretched with limited bus services busy roads poorly maintained pavements and road surfaces Brox road is already used as a shortcut to avoid traffic congestion Given that Ottershaw does not have a train station it is reasonable to assume that the majority of houses would have at least one car the added traffic from the new development would put a severe strain on the road network and users Available information on mitigation is very vague and very open to interpretation and misguided assumptions

bull The Green Belt land is a habitat to an array of plants and animals including important pollinator species and larger animals such as birds foxes and deer There should be no assumption that animals will simply move to another area habitats are established over many years and this development will be another loss to the maintenance of biodiversity I enjoy the fauna and flora in these areas going for walks along the public footpaths Having such wonderful access to a relaxing escape so close to home is priceless and something I hold dear to myself my family and community What is now a beautiful scenic view will become a spoilt urban sprawl of modern housing

bull I moved to Ottershaw with my wife in 2016 to settle down and start a family The

relaxed quiet village sense of community and safety surrounded by beautiful countryside were its appeal I are very concerned and disappointed that this planning proposal is still being considered which will undoubtedly destroy this idyllic setting

There are no ldquoexceptional or very special circumstancesrdquo that justify the removal of Ottershaw East from the Green Belt We trust that the Council will therefore not remove ldquoOttershaw Eastrdquo and ldquoThe Fieldrdquo from the Green Belt Yours faithfully Dr Brian Pickett

FromTo Planning PolicySubject Runnymede Local Plan 2030 - consultation responseDate 21 February 2018 163608Attachments Runnymede LP Response - EE15pdf

Please find attached a consultation response form

________________________________________Christian Leigh BSc(Hons) MPhil MRTPIDirectorLeigh amp Glennie Ltd6 All Souls RoadAscotBerkshire SL5 9EA

1893

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number 01344 297094 Email Address (where relevant)

mailchristianleighcouk

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number Email Address (where relevant)

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

From MCNAB DouglasTo Planning PolicySubject Runnymede Draft Local Plan consultation - Representation from Education and Skills Funding AgencyDate 21 February 2018 091407Attachments Runnymede Reg 19 response ESFADOC

Dear Runnymede Planning Policy Team

Please see attached a representation from the Education and Skills Funding Agency on theRunnymede Local Plan consultation

I would be grateful if you could confirm receipt

Best regardsDoug

Douglas McNab MRTPIForward Planning Manager ndash South East

Planning Team Free Schools CapitalEducation and Skills Funding AgencyDepartment for Education 5th floor Sanctuary Buildings 20 Great Smith Street London SW1P 3BT

Email douglasmcnabeducationgovukMobile 07990 082877Web wwwgovukesfa

1895

image1pngOur Ref ESFALocal PlanRunnymede 2018 21st February 2018

Dear SirMadam

Re Runnymede Local Plan

Consultation under Regulation 19 of Town and Country Planning (Local Planning) (England) Regulations 2012

Submission of the Education and Skills Funding Agency

1 The Education and Skills Funding Agency (ESFA) welcomes the opportunity to contribute to the development of planning policy at the local level

2 The ESFA launched on 1st April 2017 bringing together the existing responsibilities of the Education Funding Agency (EFA) and the Skills Funding Agency (SFA) to create a single funding agency accountable for funding education and training for children young people and adults The ESFA are accountable for pound61 billion of funding a year for the education and training sector including support for all state-provided education for 8 million children aged 3 to 16 and 16 million young people aged 16 to 19

3 Under the provisions of the Education Act 2011 and the Academies Act 2010 all new state schools are now academiesfree schools and the ESFA is the delivery body for many of these rather than local education authorities As such we aim to work closely with local authority education departments and planning authorities to meet the demand for new school places and new schools We do this through a variety of means including by supporting the adoption of sound local plan policies site allocations and guidance (all based on robust evidence) that facilitate the delivery of education infrastructure where and when it is needed and maximise developer contributions for schools In this capacity we would like to offer the following comments in response to the proposals outlined in the above consultation document

Comments on the Local Plan

4 As you will be aware the primary focus at this stage of the Local Planrsquos preparation is on the soundness of the plan with regard to it being positively prepared justified effective and consistent with national policy The following detailed comments set out the ESFArsquos view of the planrsquos soundness in respect of education provision

5 The ESFA notes that the local plan will make provision for a minimum of 7413 net additional dwellings over the plan period Development will generally complement the existing settlement pattern focusing the largest amounts of residential growth primarily in Chertsey (1950 homes) Addlestone (936 homes) and Egham (812 homes) A new ldquolocally led garden villagerdquo is also proposed at Longcross providing a further 1718 homes This level of development will put pressure on existing education infrastructure

6 The plan recognises that ldquoIt is important that infrastructure is delivered in a timely manner to ensure that the needs of the occupiers of new development can be met without placing undue burdens on existing infrastructure facilities and servicesrdquo (para 560) The ESFA supports Policy SD6 Infrastructure Provision amp Timing particularly the signposting of the Infrastructure Delivery Plan (IDP) and the need for development to deliver this either on-site or through s106 or CIL financial contributions off-site and the need for development to be phased in line with the provision of important supporting infrastructure

7 The latest version of the IDP states that there is an ongoing programme of primary school expansions this will help to meet the forecast need for 4-6FE of new capacity over the plan period The need for one new build school project is identified a 2FE primary school at the Longcross Garden Village (estimated cost pound99M to pound15M) this is referred to in the site allocation policies (see below) With respect to secondary school places it is anticipated that up to six additional FE could be required in the Borough by 2021 Additional places will be delivered through the new 6FE Runnymede Free School (which opened in temporary accommodation in 2017) development of additional FE within Salesian School (Catholic faith school) and expansion of another school in the Chertsey area (to accommodate demand from generated by the Longcross Garden Village site)

8 It would be useful if the background data informing these projections of need could be clarified particularly the pupil yield factors used and the evidence base supporting this This would help to demonstrate more clearly to the Inspector that the approach to the planning and delivery of education infrastructure has been positively prepared based on a strategy which seeks to meet objectively assessed infrastructure requirements and is justified based on proportionate evidence The ESFA notes that the Runnymede S106 SPG sets out pupil yield figures however this document dates from December 2007 so the figures may be outdated

9 The ESFA supports the Councilrsquos allocation and safeguarding of land for schools as set out in the following policies

middot Policy SD10 Longcross Garden Village - 2FE primary school with preschoolearly years settings

middot Policy SL2 to SL18 ndash series of housing allocation policies that highlight the need to make a financial contribution to early years primary and secondary school infrastructure ldquoeither through S106 or CIL (or its successor)rdquo

Developer Contributions and CIL

10 One of the tests of soundness is that a Local Plan is lsquoeffectiversquo ie the plan should be deliverable over its period In this context and with specific regard to planning for schools there is a need to ensure that education contributions made by developers are sufficient to deliver the additional school places required to meet the increase in demand generated by new developments The ESFA notes that the council has not adopted CIL and that the Planning Obligations SPG sets out how developer contributions to education provision will be secured via section 106 agreements The ESFA supports the Councilrsquos approach to ensure developer contributions address the impacts arising from growth However the ESFA recommends that the Local Plan includes a commitment to revise the Planning Obligations SPG in line with the latest evidence of the boroughrsquos infrastructure needs pupil yields and build costs (including the cost of school expansion new build and SEN provision) Any such review should be prepared in consultation with the county council as local education authority This will help to ensure appropriate rates are levied and the right infrastructure is secured across the borough

11 The ESFA would be particularly interested in responding to any update to the Infrastructure Delivery Plan or review of infrastructure requirements As such please add the ESFA to the database for future CIL consultations

Forward funding

12 In light of the proposed Longcross Garden Village emerging ESFA proposals for forward funding schools as part of large residential developments may be relevant for example if viability becomes an issue The ESFA aims to be able to clarify forward funding options for schools in 2018 We would be happy to meet to discuss this opportunity further once the options have been finalised and ifwhen relevant Any offer of forward funding would seek to maximise developer contributions to education infrastructure provision while supporting delivery of schools where and when they are needed

Conclusion

13 Finally I hope the above comments are helpful in finalising the Runnymede Local Plan with specific regard to the provision of land for new schools

14 Please notify the ESFA when the Local Plan is submitted for examination the Inspectorrsquos report is published and the Local Plan is adopted

15 Please do not hesitate to contact me if you have any queries regarding this response The ESFA looks forward to continuing to work with Runnymede Borough Council to develop a sound Local Plan that will aid in the delivery of new schools

Yours faithfully

DC McNab

Douglas McNab MRTPI

Forward Planning Manager

Tel 07990 082877

Email

douglasmcnabeducationgovuk

Web

wwwgovuk esfa

Education and Skills Funding Agency13

Department for EducationSanctuary BuildingsGreat Smith StreetLondonSW1P 3BT13

13

Tel 0207 340 700013

13

wwwgovukesfa13

13

13

To

Policy Planning and Strategy Team

Runnymede Borough Council

Civic Centre

Station Road

Addlestone

Surrey

KT15 2AH

From

Dr Brian Pickett

139 Brox Road

Ottershaw

Surrey

KT16 0LG

Title

Mrs

First Name

Caroline

Last Name

Craven

Job Title

(where relevant)

Organisation

(where relevant)

Address Line 1

Southover

Line 2

Hurst Lane

Line 3

Egham

Line 4

Surrey

Post Code

TW20 8QJ

Telephone Number

07770999572

Email Address

(where relevant)

Carolinecraven911hotmailcom

Page 10: Runnymede Borough Council, for submissions. My contact details are all in the WORD letter attached. But I will provide my telephone number here too, which …

7

the integrity of the European siterdquo If no named SANG site is to be provided than the competent authority Runnymede Borough Council cannot conclude that no damage will occur to the integrity of the Chobham Common site as a result of the approval of itsrsquo Local Plan in its current format

3 Natural England used to be a proper nature conservation organisation before 2010 before the previous coalition Government of David Cameron and particularly Owen Paterson when Secretary of State for The Environment Food and Rural Affairs from 2012 ruined it and turned into another pro-development organisation negating itsrsquo roles via the 2012 statement that it could no longer campaign to objectively protect wildlife Itsrsquo role always was to shout loudly to protect wildlife and it should in my opinion now be recording objections to stop adverse developments such as SLAA 99 But with AECOMrsquos statement in paragraph 817 of the AECOM June 2016 HRA that Natural England already have an agreement with Crest Nicholson that a ldquowhole site SANG strategy has been agreedrdquo and that an ldquoadverse effect on the integrity on the Thames Basin Heaths would not ariserdquo subject to the delivery of the agreed SANGS shows Natural England has already been compromised in the negotiations Clearly there is a conflict with the statement in paragraph 817 in the summary ldquoLocating housing more than 400m from the SPA boundaryrdquo and para 835 which states that DERA South site is only 280m from the SPA boundary What is not clear from this early HRA and subsequent updated versions by AECOM is whether housing will be developed and established at a point of only 280m or less from the SPA boundary conforming to the boundary of the DERA South site or at the 400m buffer distance Which is it

It is clear that Natural Englandrsquos role in protecting Chobham Common has been compromised already they should be sticking to their 2006 position clearly if this development goes ahead referral to European Courts of Justice is necessary Already before BREXIT is completed the UK Government cannot be trusted to ensure our richest wildlife sites are protected when the same UK Government own ldquobrownfieldrdquo sites such as DERA South adjacent to these SPA sites The HS2 in England proposals and the Gwent Levels development proposals for the M4 in Wales are already evidence of their despicable and cavalier record of

8

damage to Sites of Special Scientific Interest Such damage is not acceptable I urge Runnymede Borough Council and the UK Government to think again about a different policy for this sensitive location of DERA South

4 Natural England should be putting Englandrsquos wildlife considerations first NOT the Governmentrsquos economic development initiatives I ask here that both DEFRA and Natural England intervene in this consultation and the subsequent inspection (as a consequence this objection will be sent to both of them) because the SLAA 99 development proposals and the so-called mitigation make a travesty of nature conservation and will only further damage the Chobham Common SSSI and its wildlife species

5 Clearly AECOMrsquos conclusion with regard to disturbance of the Annex 1 birds on Chobham Common in their paragraphs 863 and 868 of the May 2017 HRA and also in paragraphs 851 to 853 of the December 2017 version is wrong and seriously flawed because it fails to take in the proximity of the DERA South development to the SPA site of Chobham Common Also when the Trumps Farm SANG is over one mile distant and the originally proposed of a 55 hectare woodland SANG mentioned in paragraph 817 of the June 2016 HRA version does not fit to the Natural Englandrsquos preferred SANG size for a large development Nor is a woodland SANG normally safe for women walking alone with a dog the original preference for a SANG was that it should replicate the open nature of the heathland sitesrsquo the public like to use for dog-walking

Runnymede Borough Councilrsquos policy for the provision of SANG is not sufficient for it to work as mitigation it must be easier to get to and access the SANG than the adjoining SPA site and the Trumps Farm site fails in this provision Clearly Natural England and the UK Government are conveniently failing to understand what must be staring them in the face if they were honest that SLAA 99 development proposals will both damage and cause disturbance to the wildlife of Chobham Common As a part of the Thames Basin Heaths SPA and with an agreed Delivery Framework for SANGS in the Thames Basin Area if SLAA 99 is accepted in this Local Plan with the existing SANG proposals this will be unacceptable to me This will then form a part of a complaint to the European Commission as currently we are still subject to the judgements of the European Court of Justice

9

6 AECOMrsquos conclusions in paragraph 865 of the June 2016 HRA 868 of the May 2017 HRA and AA and lastly in paragraphs 851 to 853 of the December 2017 HRA and AA is what you expect from AECOM a complete disregard for the issues based on just a Council policy of the provision of SANG irrespective of itsrsquo location and proximity to the proposed development Equally as the Planning Inspectorate is under the same UK Government ldquocoshrdquo as Natural England to enable the provision of more housing for the so-called housing crisis It is not a shortage of housing that is evident in England it is a clear case of overpopulation with successive governments failing to govern and do anything about excessive breeding of the native human population and uncontrolled inward migration of human numbers into the UK particularly in southern England Before the next round of housing proposals in this area post 2030 the UK Government must act to reduce the excessive human population growth in the Runnymede area and the excessive expansion of the London region I can already see the claims for the forthcoming Planning Inspection and future ones probably by the Housebuilderrsquos Federation and the agents or QCs for the private housebuilding companies (a QC was employed by one developerrsquos agent for the East Hampshire Joint Core Strategy to argue for more housing to be achieved within that area and Local Plan) that people are more important than wildlife and that we must build on the SPAs or very close to them as in the current Runnymede Local Plan This failure to properly mitigate for the development of the so-called Longcross Garden Village is the start of the destruction of one of Britainrsquos best remaining lowland heathland sites A national disgrace

The SLAA 99 proposal and the proposals to remove land from the greenbelt in this Local Plan are as clear evidence of the overpressure of people numbers on the finite land resource of England (ldquoThe UKs population is projected to reach 70 million by 2030 ndash thatrsquos nine million more people than in 2008rdquo Ref Forum for the Future in 2010 ldquoUK population grows by over 400000 in the last year the largest absolute increase of any European countryrdquo Ref Population Mattersrsquo research in August 2013 ldquoEnglandrsquos population is already twice that of Germany per square mile and four times that of France It is our quality of life that is being affectedrdquo Ref Lord Horam speaking in February 2018 in the House of Lordrsquos debate on ldquoBrexit and the labour marketrdquo As the Planning

10

Inspector stated at the commencement of the Inspection of the East Hampshire Joint Core Strategy that I was present at in 2013 ldquoI have been given a growth agendardquo With this type of pressure by the UK Government I am not sure that I or nature conservation can expect a fair and objective hearing in 2018 when I object to Runnymede Borough Councilrsquos Local Plan 2030 we will see

7 For the proximity of the DERA South development to the SPA site of Chobham Common there is one potential solution and that is to reduce the number of houses in the DERA South (Longcross Garden Village) proposal and to make a new large SANG out of the land at the western end of the DERA South site This would require the ldquoDuty of Cooperationrdquo to be observed as the extreme west end of the DERA South site as it is within the land area of Surrey Heath Borough Council but I am sure this could be achievable This area would have to be fenced with dense mesh topped with rolled razor wire or similar to prevent free roaming dogs and cats from going onto the Chobham Common site south of the M3 and B386 roads If this fence was sufficiently high and doubled up to make two fences these could be used to keep the public and their animals away from and out of the SPA of Chobham Common and also necessarily to confine the loose running dogs a requirement for SANGS from being run-over on the B386 and the other connecting roads

8 The SPD issued and adopted by Surrey Heath Borough Council states I paragraph 57 ldquoIn the period up to 2028 Surrey Heath is expected to grant planning permission for 324010 new homes and this will require the provision of over 60 hectares of SANG Major or large new developments will be expected to provide bespoke on-site SANG rather than relying on the suite of SANGs being developed by the Borough Councilrdquo SLAA 99 is a large development so it should lose some of its housing land to provide on-site SANG to separate itsrsquo housing provision from Chobham Common

Similarly for Runnymede a large amount of new homes will result from the conclusions of the Planning Inspection Almost certainly more than proposed at the moment (this was the experience in East Hampshire in 2013) In this case and similar to the proposals adopted for SLAA 97 SANG provision for SLAA 99 (which appears to be scheduled to provide

11

the largest number of homes and something like 7000 extra people in Runnymede Borough) the SANG needs to be onsite and the solution I propose in this paragraph would cater for this Hoping new residents will all get in their cars to take the dog or cat for a walk over one mile away on Trumps Farm is not sustainable practicable or likely AECOMrsquos HRA and AA of both May and December 2017 completely fail to address the roaming catrsquos issue Despite AECOMrsquos clearly different point-of-view I do not believe that Runnymede Borough Council in their role as lsquocompetent authorityrsquo can conclude that no adverse effect on the integrity of internationally important wildlife sites of the Thames Basin Heathrsquos SPA will result from their proposals in their Local Plan 2030 as a consequence of what I consider are flawed conclusions proposed by AECOM The only light at the end of the tunnel of flawed conclusions in my opinion by AECOM is their final paragraph in the Dec 2017 HRA and AA that at paragraph 93 ldquoHowever it is recommended that the potential for further bespoke or strategic SANG later in the plan period is explored by the Council in time for Examination in Publicrdquo

I suggest to the Planning Inspector and Runnymede Borough Council that an on-site large SANG at the west end of the DERA South site should be provided as greenspace which would help to alleviate the potential for disturbance by residents of the new garden village from having to go or preferring to go to Chobham Common with the dog because this SANG site would be nearer Housing development adjacent to heathland always damages it especially if local arsonists are imported nearby but my proposals would go a long way to making the proposed Local Plan sound Though it would be far better if this garden village was scrapped and the DERA South site restored to heathland or just converted to another employment site as that would do far less damage to the Chobham Common SSSI and SPA site

____________________

Stephen R Miles 21st February 2018

From Caroline CravenTo Planning PolicySubject Representation for Local PlanDate 22 February 2018 092519Attachments Representation_form_for_Regulation_19_Caroline_Cravendocx

Please find attached my representation form in response to the Runnymede 2030 Local PlanConsultation

Regards helliphellip Caroline Craven

1886

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full contact details of the agent in 2

Part B (1) ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

XParagraph PolicyPolicies Map

X

X

X

4 Do you consider the Local Plan is

x

4 (1) Legally compliant Yes No

X

4 (2) SoundYes No

x

4 (3) Complies with the Duty to co-operateYesNo

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the duty to co-operate please also use this box to set out your comments

I believe the Local Plan does not comply with the duty to co-operate with neighbouring Boroughs The previous version was not deemed to be compliant as I understand it and there does not appear to be any significant changes that allow this plan to be compliant

RBC seems to have relied on the former Statement of Community Involvement (SCI) of 2014 In a digital age 15 lines in a local (The Villager Feb 9th) on page 11 is a poor means of communication to the Runnymede Borough residents on something that will affect them so deeply

In addition the views expressed at the RBC meeting by the attending RBC councillors were essentially that they accepted it wasnrsquot as good as it should be but was lsquothe best wersquore going to get at the momentrsquo and if not submitted then a Government Inspector would be appointed and they would lose control ndash a view I can fully understand but does not give the Runnymede residents a feeling of confidence in the legality or the integrity of the plan nor that the council truly want the best for the Borough

With regard to the Longcross site improvements to the station do not address the capacity issue The impact to commuters further up the line will be significant Peak times will be heavily impacted If additional trains are being proposed on this line the impact to the residents of Egham who already have to wait some 35-40 minutes in the hour whilst gates are down would therefore have even less opportunity to transverse the line at the crossing points Longcross station has no accessible car parking or drop off points This would necessitate commuters travelling to Virginia Water Egham whose own parking capability is limited Virginia Water has lost a large number of station car park spaces due to a new development This would also cause increased congestion in already known problem junctions The additional burden to the A320 which is already operating over practical capacity at several junctions and expected to deteriorate over the coming years would be significant (A320 Corridor Study ndash Feasibility Study ndash Interim report February 2018)

(Continue on a separate sheetexpand box if necessary)

The Longcross site will also need medical facilities ndash GPrsquos and potentially NHS drop in centre to ensure the current burden on the NHS is not exacerbated

With regard to the Traveller pitches they appear to amount to 35 within the scope of the development areas However the council plan to deliver 131 net additional plotspitches ndash 96 of which are not covered in this local plan This is an extremely emotive subject and needs to be identified properly in the plan and not almost hidden to avoid confrontation with angry residents that this County is already over run with these communities Integration with new developments is not the answer ndash Allocation of Traveller sites and pitches is according to the Government guidelines ldquoinappropriate within the Green beltrdquo and trying to slide this surreptitiously into new developments is a totally inappropriate solution

The Hurst Lane development was dismissed by the Council despite the residents being on board and a sustainable and acceptable plan being put forward for c 800-1000 homes on 80 -100 acres Over time this Lane has deteriorated to the point that Planning Inspectors described it as an lsquoindustrial wastelandrsquo In addition the Council resources are being tied up with the numerous issues generated by the Lane and the inability to resolve with the resources available The primary reason given is that the land is lsquoGreen Beltrsquo although under exceptional circumstances (which I believe this would come under) the council are able to and plan to in other areas use this land It is effectively a brownfield site which could be permitted fi connected to a SANG trade off which the residents plan was

6 Please set out what modification (s) you consider necessary to make the Local Plan legally compliant or sound having regard to the Matter you have identified at 5 above where this relates to soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of modification at examination) You will need to say why this modification will make the Local Plan legally compliant or sound It will be helpful if you are able to put forward your suggested revised wording of any policy or text Please be as precise as possible

For the plan to be sound I believe that

1) Review the inclusion of the Hurst Lane site ndash SLAA 59 ndash within the plan Appendix B states the capacity of 10 for Hurst Lane and 5 for Padd Farm If this relates to additional properties the number does not reflect the plans of up to 800 houses Access and infrastructure are addressed and the reduction in headcount in the councilrsquos Customer Services (I believe there is a dedicated resource looking after Padd Farm Hurst Lane) would be an additional benefit

2) Greater publicity is required over the consultation process The council appear to work on a lsquopullrsquo basis in that residents of the borough (other than those in the Residents Associations) have to actively seek out any updates from the council Local newspapers are not a good way of disseminating information in the digital age

3) Identify the additional travellergypsy site plans and move outside of the Green Belt area

If these steps were taken the residents would all have ample opportunity to contribute to the development of the local plan

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further representations based on the original representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

7 If your representation is seeking a modification do you consider it necessary to participate at the oral part of the examination

No I do not wish to participate Yes I wish to participate

X

at the oral examinationat the oral examination

8 If you wish to participate at the oral part of the examination please outline why you consider this to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who have indicated that they wish to participate at the oral part of the examination

9 Signature Date

21st February 2018

Caroline Craven

Notes to Accompany Model Representation Form

1 Introduction

11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 2004[footnoteRef1] (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound [1 View at httpwwwlegislationgovukukpga20045contents ]

2 Legal Compliance and Duty to Co-operate

21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness

22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)[footnoteRef2] it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices [2 LDDs are defined in regulation 5 ndash see link below ]

bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications

bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)[footnoteRef3] On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified [3 View at httpwwwlegislationgovukuksi2012767contentsmade ]

bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy)

23 You should consider the following before making a representation on compliance with the duty to co-operate

bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty

bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

3 Soundness

31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy

bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development

bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence

bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities

bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF

32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations

bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included

bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan

bull If the policy is not covered elsewhere in what way is the plan unsound without the policy

bull If the plan is unsound without the policy what should the policy say

4 General advice

41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

6

image1png

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full contact details of the agent in 2

Title Mrs First Name Caroline Last Name Craven Job Title (where relevant)

Organisation (where relevant)

Address Line 1 Southover Line 2 Hurst Lane Line 3 Egham Line 4 Surrey Post Code TW20 8QJ Telephone Number Email Address (where relevant)

2

Part B (1) ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

XParagraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails to comply with the duty to co-operate Please be as precise as possible If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

X X X

x

X

x

I believe the Local Plan does not comply with the duty to co-operate with neighbouring Boroughs The previous version was not deemed to be compliant as I understand it and there does not appear to be any significant changes that allow this plan to be compliant

RBC seems to have relied on the former Statement of Community Involvement (SCI) of 2014 In a digital age 15 lines in a local (The Villager Feb 9th) on page 11 is a poor means of communication to the Runnymede Borough residents on something that will affect them so deeply

In addition the views expressed at the RBC meeting by the attending RBC councillors were essentially that they accepted it wasnrsquot as good as it should be but was lsquothe best wersquore going to get at the momentrsquo and if not submitted then a Government Inspector would be appointed and they would lose control ndash a view I can fully understand but does not give the Runnymede residents a feeling of confidence in the legality or the integrity of the plan nor that the council truly want the best for the Borough

With regard to the Longcross site improvements to the station do not address the capacity issue The impact to commuters further up the line will be significant Peak times will be heavily impacted If additional trains are being proposed on this line the impact to the residents of Egham who already have to wait some 35-40 minutes in the hour whilst gates are down would therefore have even less opportunity to transverse the line at the crossing points Longcross station has no accessible car parking or drop off points This would necessitate commuters travelling to Virginia Water Egham whose own parking capability is limited Virginia Water has lost a large number of station car park spaces due to a new development This would also cause increased congestion in already known problem junctions The additional burden to the A320 which is already operating over practical capacity at several junctions and expected to deteriorate over the coming years would be significant (A320 Corridor Study ndash Feasibility Study ndash Interim report February 2018)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally compliant or sound having regard to the Matter you have identified at 5 above where this relates to soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of modification at examination) You will need to say why this modification will make the Local Plan legally compliant or sound It will be helpful if you are able to put forward your suggested revised wording of any policy or text Please be as precise as possible

For the plan to be sound I believe that

1) Review the inclusion of the Hurst Lane site ndash SLAA 59 ndash within the plan Appendix B states the capacity of 10 for Hurst Lane and 5 for Padd Farm If this relates to additional properties the number does not reflect the plans of up to 800 houses Access and infrastructure are addressed and the reduction in headcount in the councilrsquos Customer Services (I believe there is a dedicated resource looking after Padd Farm Hurst Lane) would be an additional benefit

2) Greater publicity is required over the consultation process The council appear to work on a lsquopullrsquo basis in that residents of the borough (other than those in the Residents Associations) have to actively seek out any updates from the council Local newspapers are not a good way of disseminating information in the digital age

3) Identify the additional travellergypsy site plans and move outside of the Green Belt area

If these steps were taken the residents would all have ample opportunity to contribute to the development of the local plan

The Longcross site will also need medical facilities ndash GPrsquos and potentially NHS drop in centre to ensure the current burden on the NHS is not exacerbated

With regard to the Traveller pitches they appear to amount to 35 within the scope of the development areas However the council plan to deliver 131 net additional plotspitches ndash 96 of which are not covered in this local plan This is an extremely emotive subject and needs to be identified properly in the plan and not almost hidden to avoid confrontation with angry residents that this County is already over run with these communities Integration with new developments is not the answer ndash Allocation of Traveller sites and pitches is according to the Government guidelines ldquoinappropriate within the Green beltrdquo and trying to slide this surreptitiously into new developments is a totally inappropriate solution

The Hurst Lane development was dismissed by the Council despite the residents being on board and a sustainable and acceptable plan being put forward for c 800-1000 homes on 80 -100 acres Over time this Lane has deteriorated to the point that Planning Inspectors described it as an lsquoindustrial wastelandrsquo In addition the Council resources are being tied up with the numerous issues generated by the Lane and the inability to resolve with the resources available The primary reason given is that the land is lsquoGreen Beltrsquo although under exceptional circumstances (which I believe this would come under) the council are able to and plan to in other areas use this land It is effectively a brownfield site which could be permitted fi connected to a SANG trade off which the residents plan was

4

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further representations based on the original representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

7 If your representation is seeking a modification do you consider it necessary to participate at the oral part of the examination

No I do not wish to participate Yes I wish to participate at the oral examination at the oral examination

8 If you wish to participate at the oral part of the examination please outline why you consider this to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who have indicated that they wish to participate at the oral part of the examination

9 Signature Date

X

Caroline Craven 21st February 2018

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan 1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination 42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

FromPolicy

Subject FW New Housing Plans 2015-2030Date 21 February 2018 164919

Sent 21 February 2018 1608To PlanningSubject New Housing Plans 2015-2030

To

Policy Planning and Strategy Team

Runnymede Borough Council

Station Road

Addlestone

21022018

Dear Sirs

As an Ottershaw resident of nearly 30 years i would like you to read and take on board my objections to yourproposal to take land out of the green belt for housing and your plan to build so many houses in ourcommunity

Of course new houses have to be built right across the country now and in the future but i feel the plans youhave are for far too many houses The infrastructure of our community will just not sustain the extra amount ofpeople and cars and the general traffic that would entail

There are other possibilities available before your irreversible plans are put into action Are these possibilitiesbeing resourced

When i drive around the borough now and for a long long time i see so many empty office blocks Some ofthese have stood empty for yearsWhy has permission been given continuosly from what i can see on a huge scale for these to be built

This building of offices has to stop and the ones that have remained empty for years could be converted tohousing as in flats starter homes for young people

If Planning Practice Guidlines state that the use of Green Beltshould only occur in very special circumstances these and the Brownfield sites in Runnymede must be extensively researched

I live in Wilson Drive and for many years now when i leave my house to go into the village or elsewhere thereis often gridlock in every direction The roads in our community are so heavily used by cars and lorries headingtoward the M25 Can you imagine the impact so many more of these will bring Driving has not been a pleasurefor a long time and i do walk wherever possible Parking is a problem in the village as so many people use theone car park I believe there may be a plan in the pipeline to even get rid of that for road widening

We have a GP practice in the village that is getting harder to book an appointment for also i have been waitingmonths for an appointment at St Peters hospital and just keep getting apologetic letters

Quality of life is very important for your residents and that quality has already deteriorated lately

1888

In order to accomodate so many new residents you will be making the ones you have feel very disappointedand frustated that no one listens

There is no going back once the desicion has been made and so many houses built Please take my feelings and iam sure very many more residents comments and pleas into account before you make the irreversible decisionto go ahead with your plans

Yours Faithfully

Margaret Wensley and the Wensley family

Beechwood

Wilson Drive

Ottershaw

Surrey

KT16 0NT

----------- middotn==middot =

Planning Services

DELIVERED BY HAND

Runnymede Borough Council ~--------------=-middot ---------middot------~

Planning Dept Runnymede Borough Council Civic Offices Station Road Addlestone KT15 2AH

Dear Sirs

Catherine Brunton-Green 20The Glen Addlestone

KT151AQ

15th February 2018

Runnymede Draft local Plan 2015- 2030- Final Consultation

I have serious concerns in respect of this draft plan Runnymede Borough Council (RBC) have a duty of care to consult with listen and act upon the wishes of its residents There has been some consultation but this has not effectively reached all Runnymede residents Communication is unnecessarily legally complex and full of unexplained acronyms The basic Runnymede Voice delivered to every home has been abandoned There has been no flyer delivered to every home stating in a simplified way what is happening so that all abilities may be catered for Many people are isolated for numerous reasons and do not have internet access Neither is there evidence of full in depth cross boundary consultation with adjacent boroughs This local plan is driven primarily by a developers charter promoted by RBCS Head of Planning It is both unfair unjust and I question its soundness

The Strategic Housing Market Assessment has not taken leaving the EU into account and makes a blanket assumption on Heathrow expansion

I strongly object to the proposed loss of c 560 acres of Green Belt Our Prime Minister and government have recently stated that they are quote committed to protecting and enhancing our natural environment for successive generations therefore Green Belt land would only be lost as a last resort 11

bull Detailed evidence based research by The Council for The Protection of Rural England confirms that by fully utilising brownfield land 12 million homes could be built in London and the South East without the loss of any Green Belt

I have objection to building on the Veterinary Laboratory Green Belt Land Parcel BRow Town (Policy SL11 8283) is not justified for development This is designated for 150 additional dwellings and 2 gypsyTraveller pitches This site provides a natural demarcation between developments either side Designated SANG area is privately owned and not available The density of proposed build is unacceptable and above all an area of outstanding natural beauty would be destroyed

Our infrastructure is unable to cope at present A320 suffers perpetual gridlock now Equally gridlock is evidenced through Ottershaw Addlestone Station Road and A317 Addlestone Weybridge We already have unhealthily dangerous levels of roadside nitrogen dioxide concentrations in many areas such as Station Road RBC has made a lame submission in respect of

tackling roadside nitrogen dioxide concentrations in the South East (UK00310) Incidence of exacerbated breathing illnesses in this vicinity has increased dramatically in the past 7 years All age groups are affected

All GP surgeries across Runnymede have great difficulty in recruiting doctors Two practices in the immediate area are merging due to unprecedented numbers of doctors leaving and retiring Practice lists and capacity is stretched Patient access to services and patient safety has to be the highest priority Our schools are similarly affected

RBC infrastructure is totally reliant upon Surrey County Council who declare they are not in a financial position to fund the necessary support to develop the infrastructure for this Local Plan

I am prepared to speak at Public Enquiry

Yours faithfully

bull i I I bull bull

From Brian PickettTo Planning PolicySubject Runnymede 2030 Local Plan - submission of viewsDate 22 February 2018 090921Attachments Ottershaw development Objection letter February 2018docx

Please find attached the submission of my views on the Runnymede 2030 LocalPlan

Kind RegardsBrian Pickett

1891

planningrunnymedegovuk planningrunnymedegovuk

21022018

Re Runnymede 2030 Local Plan Ottershaw East ndash Objection to planning

Dear Sirs

We are writing to you again as we strongly object to the Runnymede Borough Councils plans to remove land behind houses along Brox Road known as lsquoOttershaw Eastrsquo from the Green Belt We are objecting for a number of reasons listed below

middot The Green Belt is precious once it is gone it is gone forever The removal of this land from the Green Belt does not comply with Planning Policy which states ldquothat Green Belt boundaries should only be altered in exceptional circumstancesrdquo there are no such circumstances that can justify the removal of this piece of land

middot The Green Belt should be an area that is preserved for future generations to enjoy and appreciate and many statements have been made by both the Government and members of Parliament on their commitment to protect the Green Belt ndash these statements now need to be converted into action in the Local Borough Plans The roll out of Green Belt to local councils in the 1950rsquos was to prevent urban sprawl and the merging of settlements thereby helping to preserve and protect the character of communities it encompassed protect the country setting and encourage development through regeneration of sites within towns and cities not villages

middot The description of Ottershaw by the council itself in the lsquoUrban Characteristicsrsquo publication on the Runnymede Borough Council website states ldquoOttershaw has its own identity and sense of place which is partly derived from the clearly identifiable heart of the urban area focused on The Otter and adjoining local shopping parade and community facilities as well as being surrounded by open greenbelt countryside Removing this green belt that is part of the identifiable heart of Ottershaw would destroy this villagersquos identity and community

middot The planning proposals and building on this part of the green belt land would lead to a considerable population increase in the village Services and facilities will struggle or fail to cope space is already limited at the doctorrsquos surgery and school places are at capacity The transport infrastructure is already stretched with limited bus services busy roads poorly maintained pavements and road surfaces Brox road is already used as a shortcut to avoid traffic congestion Given that Ottershaw does not have a train station it is reasonable to assume that the majority of houses would have at least one car the added traffic from the new development would put a severe strain on the road network and users Available information on mitigation is very vague and very open to interpretation and misguided assumptions

middot The Green Belt land is a habitat to an array of plants and animals including important pollinator species and larger animals such as birds foxes and deer There should be no assumption that animals will simply move to another area habitats are established over many years and this development will be another loss to the maintenance of biodiversity I enjoy the fauna and flora in these areas going for walks along the public footpaths Having such wonderful access to a relaxing escape so close to home is priceless and something I hold dear to myself my family and community What is now a beautiful scenic view will become a spoilt urban sprawl of modern housing

middot I moved to Ottershaw with my wife in 2016 to settle down and start a family The relaxed quiet village sense of community and safety surrounded by beautiful countryside were its appeal I are very concerned and disappointed that this planning proposal is still being considered which will undoubtedly destroy this idyllic setting

There are no ldquoexceptional or very special circumstancesrdquo that justify the removal of Ottershaw East from the Green Belt We trust that the Council will therefore not remove ldquoOttershaw Eastrdquo and ldquoThe Fieldrdquo from the Green Belt

Yours faithfully

Dr Brian Pickett

To Policy Planning and Strategy Team Runnymede Borough Council Civic Centre Station Road Addlestone Surrey KT15 2AH planningrunnymedegovuk

From Dr Brian Pickett 139 Brox Road Ottershaw Surrey KT16 0LG planningrunnymedegovuk

21022018 Re Runnymede 2030 Local Plan Ottershaw East ndash Objection to planning Dear Sirs We are writing to you again as we strongly object to the Runnymede Borough Councils plans to remove land behind houses along Brox Road known as lsquoOttershaw Eastrsquo from the Green Belt We are objecting for a number of reasons listed below bull The Green Belt is precious once it is gone it is gone forever The removal of this

land from the Green Belt does not comply with Planning Policy which states ldquothat Green Belt boundaries should only be altered in exceptional circumstancesrdquo there are no such circumstances that can justify the removal of this piece of land

bull The Green Belt should be an area that is preserved for future generations to enjoy

and appreciate and many statements have been made by both the Government and members of Parliament on their commitment to protect the Green Belt ndash these statements now need to be converted into action in the Local Borough Plans The roll out of Green Belt to local councils in the 1950rsquos was to prevent urban sprawl and the merging of settlements thereby helping to preserve and protect the character of communities it encompassed protect the country setting and encourage development through regeneration of sites within towns and cities not villages

bull The description of Ottershaw by the council itself in the lsquoUrban Characteristicsrsquo

publication on the Runnymede Borough Council website states ldquoOttershaw has its own identity and sense of place which is partly derived from the clearly identifiable heart of the urban area focused on The Otter and adjoining local shopping parade and community facilities as well as being surrounded by open greenbelt countryside Removing this green belt that is part of the identifiable heart of Ottershaw would destroy this villagersquos identity and community

bull The planning proposals and building on this part of the green belt land would lead

to a considerable population increase in the village Services and facilities will struggle or fail to cope space is already limited at the doctorrsquos surgery and school places are at capacity The transport infrastructure is already stretched with limited bus services busy roads poorly maintained pavements and road surfaces Brox road is already used as a shortcut to avoid traffic congestion Given that Ottershaw does not have a train station it is reasonable to assume that the majority of houses would have at least one car the added traffic from the new development would put a severe strain on the road network and users Available information on mitigation is very vague and very open to interpretation and misguided assumptions

bull The Green Belt land is a habitat to an array of plants and animals including important pollinator species and larger animals such as birds foxes and deer There should be no assumption that animals will simply move to another area habitats are established over many years and this development will be another loss to the maintenance of biodiversity I enjoy the fauna and flora in these areas going for walks along the public footpaths Having such wonderful access to a relaxing escape so close to home is priceless and something I hold dear to myself my family and community What is now a beautiful scenic view will become a spoilt urban sprawl of modern housing

bull I moved to Ottershaw with my wife in 2016 to settle down and start a family The

relaxed quiet village sense of community and safety surrounded by beautiful countryside were its appeal I are very concerned and disappointed that this planning proposal is still being considered which will undoubtedly destroy this idyllic setting

There are no ldquoexceptional or very special circumstancesrdquo that justify the removal of Ottershaw East from the Green Belt We trust that the Council will therefore not remove ldquoOttershaw Eastrdquo and ldquoThe Fieldrdquo from the Green Belt Yours faithfully Dr Brian Pickett

FromTo Planning PolicySubject Runnymede Local Plan 2030 - consultation responseDate 21 February 2018 163608Attachments Runnymede LP Response - EE15pdf

Please find attached a consultation response form

________________________________________Christian Leigh BSc(Hons) MPhil MRTPIDirectorLeigh amp Glennie Ltd6 All Souls RoadAscotBerkshire SL5 9EA

1893

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number 01344 297094 Email Address (where relevant)

mailchristianleighcouk

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number Email Address (where relevant)

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

From MCNAB DouglasTo Planning PolicySubject Runnymede Draft Local Plan consultation - Representation from Education and Skills Funding AgencyDate 21 February 2018 091407Attachments Runnymede Reg 19 response ESFADOC

Dear Runnymede Planning Policy Team

Please see attached a representation from the Education and Skills Funding Agency on theRunnymede Local Plan consultation

I would be grateful if you could confirm receipt

Best regardsDoug

Douglas McNab MRTPIForward Planning Manager ndash South East

Planning Team Free Schools CapitalEducation and Skills Funding AgencyDepartment for Education 5th floor Sanctuary Buildings 20 Great Smith Street London SW1P 3BT

Email douglasmcnabeducationgovukMobile 07990 082877Web wwwgovukesfa

1895

image1pngOur Ref ESFALocal PlanRunnymede 2018 21st February 2018

Dear SirMadam

Re Runnymede Local Plan

Consultation under Regulation 19 of Town and Country Planning (Local Planning) (England) Regulations 2012

Submission of the Education and Skills Funding Agency

1 The Education and Skills Funding Agency (ESFA) welcomes the opportunity to contribute to the development of planning policy at the local level

2 The ESFA launched on 1st April 2017 bringing together the existing responsibilities of the Education Funding Agency (EFA) and the Skills Funding Agency (SFA) to create a single funding agency accountable for funding education and training for children young people and adults The ESFA are accountable for pound61 billion of funding a year for the education and training sector including support for all state-provided education for 8 million children aged 3 to 16 and 16 million young people aged 16 to 19

3 Under the provisions of the Education Act 2011 and the Academies Act 2010 all new state schools are now academiesfree schools and the ESFA is the delivery body for many of these rather than local education authorities As such we aim to work closely with local authority education departments and planning authorities to meet the demand for new school places and new schools We do this through a variety of means including by supporting the adoption of sound local plan policies site allocations and guidance (all based on robust evidence) that facilitate the delivery of education infrastructure where and when it is needed and maximise developer contributions for schools In this capacity we would like to offer the following comments in response to the proposals outlined in the above consultation document

Comments on the Local Plan

4 As you will be aware the primary focus at this stage of the Local Planrsquos preparation is on the soundness of the plan with regard to it being positively prepared justified effective and consistent with national policy The following detailed comments set out the ESFArsquos view of the planrsquos soundness in respect of education provision

5 The ESFA notes that the local plan will make provision for a minimum of 7413 net additional dwellings over the plan period Development will generally complement the existing settlement pattern focusing the largest amounts of residential growth primarily in Chertsey (1950 homes) Addlestone (936 homes) and Egham (812 homes) A new ldquolocally led garden villagerdquo is also proposed at Longcross providing a further 1718 homes This level of development will put pressure on existing education infrastructure

6 The plan recognises that ldquoIt is important that infrastructure is delivered in a timely manner to ensure that the needs of the occupiers of new development can be met without placing undue burdens on existing infrastructure facilities and servicesrdquo (para 560) The ESFA supports Policy SD6 Infrastructure Provision amp Timing particularly the signposting of the Infrastructure Delivery Plan (IDP) and the need for development to deliver this either on-site or through s106 or CIL financial contributions off-site and the need for development to be phased in line with the provision of important supporting infrastructure

7 The latest version of the IDP states that there is an ongoing programme of primary school expansions this will help to meet the forecast need for 4-6FE of new capacity over the plan period The need for one new build school project is identified a 2FE primary school at the Longcross Garden Village (estimated cost pound99M to pound15M) this is referred to in the site allocation policies (see below) With respect to secondary school places it is anticipated that up to six additional FE could be required in the Borough by 2021 Additional places will be delivered through the new 6FE Runnymede Free School (which opened in temporary accommodation in 2017) development of additional FE within Salesian School (Catholic faith school) and expansion of another school in the Chertsey area (to accommodate demand from generated by the Longcross Garden Village site)

8 It would be useful if the background data informing these projections of need could be clarified particularly the pupil yield factors used and the evidence base supporting this This would help to demonstrate more clearly to the Inspector that the approach to the planning and delivery of education infrastructure has been positively prepared based on a strategy which seeks to meet objectively assessed infrastructure requirements and is justified based on proportionate evidence The ESFA notes that the Runnymede S106 SPG sets out pupil yield figures however this document dates from December 2007 so the figures may be outdated

9 The ESFA supports the Councilrsquos allocation and safeguarding of land for schools as set out in the following policies

middot Policy SD10 Longcross Garden Village - 2FE primary school with preschoolearly years settings

middot Policy SL2 to SL18 ndash series of housing allocation policies that highlight the need to make a financial contribution to early years primary and secondary school infrastructure ldquoeither through S106 or CIL (or its successor)rdquo

Developer Contributions and CIL

10 One of the tests of soundness is that a Local Plan is lsquoeffectiversquo ie the plan should be deliverable over its period In this context and with specific regard to planning for schools there is a need to ensure that education contributions made by developers are sufficient to deliver the additional school places required to meet the increase in demand generated by new developments The ESFA notes that the council has not adopted CIL and that the Planning Obligations SPG sets out how developer contributions to education provision will be secured via section 106 agreements The ESFA supports the Councilrsquos approach to ensure developer contributions address the impacts arising from growth However the ESFA recommends that the Local Plan includes a commitment to revise the Planning Obligations SPG in line with the latest evidence of the boroughrsquos infrastructure needs pupil yields and build costs (including the cost of school expansion new build and SEN provision) Any such review should be prepared in consultation with the county council as local education authority This will help to ensure appropriate rates are levied and the right infrastructure is secured across the borough

11 The ESFA would be particularly interested in responding to any update to the Infrastructure Delivery Plan or review of infrastructure requirements As such please add the ESFA to the database for future CIL consultations

Forward funding

12 In light of the proposed Longcross Garden Village emerging ESFA proposals for forward funding schools as part of large residential developments may be relevant for example if viability becomes an issue The ESFA aims to be able to clarify forward funding options for schools in 2018 We would be happy to meet to discuss this opportunity further once the options have been finalised and ifwhen relevant Any offer of forward funding would seek to maximise developer contributions to education infrastructure provision while supporting delivery of schools where and when they are needed

Conclusion

13 Finally I hope the above comments are helpful in finalising the Runnymede Local Plan with specific regard to the provision of land for new schools

14 Please notify the ESFA when the Local Plan is submitted for examination the Inspectorrsquos report is published and the Local Plan is adopted

15 Please do not hesitate to contact me if you have any queries regarding this response The ESFA looks forward to continuing to work with Runnymede Borough Council to develop a sound Local Plan that will aid in the delivery of new schools

Yours faithfully

DC McNab

Douglas McNab MRTPI

Forward Planning Manager

Tel 07990 082877

Email

douglasmcnabeducationgovuk

Web

wwwgovuk esfa

Education and Skills Funding Agency13

Department for EducationSanctuary BuildingsGreat Smith StreetLondonSW1P 3BT13

13

Tel 0207 340 700013

13

wwwgovukesfa13

13

13

To

Policy Planning and Strategy Team

Runnymede Borough Council

Civic Centre

Station Road

Addlestone

Surrey

KT15 2AH

From

Dr Brian Pickett

139 Brox Road

Ottershaw

Surrey

KT16 0LG

Title

Mrs

First Name

Caroline

Last Name

Craven

Job Title

(where relevant)

Organisation

(where relevant)

Address Line 1

Southover

Line 2

Hurst Lane

Line 3

Egham

Line 4

Surrey

Post Code

TW20 8QJ

Telephone Number

07770999572

Email Address

(where relevant)

Carolinecraven911hotmailcom

Page 11: Runnymede Borough Council, for submissions. My contact details are all in the WORD letter attached. But I will provide my telephone number here too, which …

8

damage to Sites of Special Scientific Interest Such damage is not acceptable I urge Runnymede Borough Council and the UK Government to think again about a different policy for this sensitive location of DERA South

4 Natural England should be putting Englandrsquos wildlife considerations first NOT the Governmentrsquos economic development initiatives I ask here that both DEFRA and Natural England intervene in this consultation and the subsequent inspection (as a consequence this objection will be sent to both of them) because the SLAA 99 development proposals and the so-called mitigation make a travesty of nature conservation and will only further damage the Chobham Common SSSI and its wildlife species

5 Clearly AECOMrsquos conclusion with regard to disturbance of the Annex 1 birds on Chobham Common in their paragraphs 863 and 868 of the May 2017 HRA and also in paragraphs 851 to 853 of the December 2017 version is wrong and seriously flawed because it fails to take in the proximity of the DERA South development to the SPA site of Chobham Common Also when the Trumps Farm SANG is over one mile distant and the originally proposed of a 55 hectare woodland SANG mentioned in paragraph 817 of the June 2016 HRA version does not fit to the Natural Englandrsquos preferred SANG size for a large development Nor is a woodland SANG normally safe for women walking alone with a dog the original preference for a SANG was that it should replicate the open nature of the heathland sitesrsquo the public like to use for dog-walking

Runnymede Borough Councilrsquos policy for the provision of SANG is not sufficient for it to work as mitigation it must be easier to get to and access the SANG than the adjoining SPA site and the Trumps Farm site fails in this provision Clearly Natural England and the UK Government are conveniently failing to understand what must be staring them in the face if they were honest that SLAA 99 development proposals will both damage and cause disturbance to the wildlife of Chobham Common As a part of the Thames Basin Heaths SPA and with an agreed Delivery Framework for SANGS in the Thames Basin Area if SLAA 99 is accepted in this Local Plan with the existing SANG proposals this will be unacceptable to me This will then form a part of a complaint to the European Commission as currently we are still subject to the judgements of the European Court of Justice

9

6 AECOMrsquos conclusions in paragraph 865 of the June 2016 HRA 868 of the May 2017 HRA and AA and lastly in paragraphs 851 to 853 of the December 2017 HRA and AA is what you expect from AECOM a complete disregard for the issues based on just a Council policy of the provision of SANG irrespective of itsrsquo location and proximity to the proposed development Equally as the Planning Inspectorate is under the same UK Government ldquocoshrdquo as Natural England to enable the provision of more housing for the so-called housing crisis It is not a shortage of housing that is evident in England it is a clear case of overpopulation with successive governments failing to govern and do anything about excessive breeding of the native human population and uncontrolled inward migration of human numbers into the UK particularly in southern England Before the next round of housing proposals in this area post 2030 the UK Government must act to reduce the excessive human population growth in the Runnymede area and the excessive expansion of the London region I can already see the claims for the forthcoming Planning Inspection and future ones probably by the Housebuilderrsquos Federation and the agents or QCs for the private housebuilding companies (a QC was employed by one developerrsquos agent for the East Hampshire Joint Core Strategy to argue for more housing to be achieved within that area and Local Plan) that people are more important than wildlife and that we must build on the SPAs or very close to them as in the current Runnymede Local Plan This failure to properly mitigate for the development of the so-called Longcross Garden Village is the start of the destruction of one of Britainrsquos best remaining lowland heathland sites A national disgrace

The SLAA 99 proposal and the proposals to remove land from the greenbelt in this Local Plan are as clear evidence of the overpressure of people numbers on the finite land resource of England (ldquoThe UKs population is projected to reach 70 million by 2030 ndash thatrsquos nine million more people than in 2008rdquo Ref Forum for the Future in 2010 ldquoUK population grows by over 400000 in the last year the largest absolute increase of any European countryrdquo Ref Population Mattersrsquo research in August 2013 ldquoEnglandrsquos population is already twice that of Germany per square mile and four times that of France It is our quality of life that is being affectedrdquo Ref Lord Horam speaking in February 2018 in the House of Lordrsquos debate on ldquoBrexit and the labour marketrdquo As the Planning

10

Inspector stated at the commencement of the Inspection of the East Hampshire Joint Core Strategy that I was present at in 2013 ldquoI have been given a growth agendardquo With this type of pressure by the UK Government I am not sure that I or nature conservation can expect a fair and objective hearing in 2018 when I object to Runnymede Borough Councilrsquos Local Plan 2030 we will see

7 For the proximity of the DERA South development to the SPA site of Chobham Common there is one potential solution and that is to reduce the number of houses in the DERA South (Longcross Garden Village) proposal and to make a new large SANG out of the land at the western end of the DERA South site This would require the ldquoDuty of Cooperationrdquo to be observed as the extreme west end of the DERA South site as it is within the land area of Surrey Heath Borough Council but I am sure this could be achievable This area would have to be fenced with dense mesh topped with rolled razor wire or similar to prevent free roaming dogs and cats from going onto the Chobham Common site south of the M3 and B386 roads If this fence was sufficiently high and doubled up to make two fences these could be used to keep the public and their animals away from and out of the SPA of Chobham Common and also necessarily to confine the loose running dogs a requirement for SANGS from being run-over on the B386 and the other connecting roads

8 The SPD issued and adopted by Surrey Heath Borough Council states I paragraph 57 ldquoIn the period up to 2028 Surrey Heath is expected to grant planning permission for 324010 new homes and this will require the provision of over 60 hectares of SANG Major or large new developments will be expected to provide bespoke on-site SANG rather than relying on the suite of SANGs being developed by the Borough Councilrdquo SLAA 99 is a large development so it should lose some of its housing land to provide on-site SANG to separate itsrsquo housing provision from Chobham Common

Similarly for Runnymede a large amount of new homes will result from the conclusions of the Planning Inspection Almost certainly more than proposed at the moment (this was the experience in East Hampshire in 2013) In this case and similar to the proposals adopted for SLAA 97 SANG provision for SLAA 99 (which appears to be scheduled to provide

11

the largest number of homes and something like 7000 extra people in Runnymede Borough) the SANG needs to be onsite and the solution I propose in this paragraph would cater for this Hoping new residents will all get in their cars to take the dog or cat for a walk over one mile away on Trumps Farm is not sustainable practicable or likely AECOMrsquos HRA and AA of both May and December 2017 completely fail to address the roaming catrsquos issue Despite AECOMrsquos clearly different point-of-view I do not believe that Runnymede Borough Council in their role as lsquocompetent authorityrsquo can conclude that no adverse effect on the integrity of internationally important wildlife sites of the Thames Basin Heathrsquos SPA will result from their proposals in their Local Plan 2030 as a consequence of what I consider are flawed conclusions proposed by AECOM The only light at the end of the tunnel of flawed conclusions in my opinion by AECOM is their final paragraph in the Dec 2017 HRA and AA that at paragraph 93 ldquoHowever it is recommended that the potential for further bespoke or strategic SANG later in the plan period is explored by the Council in time for Examination in Publicrdquo

I suggest to the Planning Inspector and Runnymede Borough Council that an on-site large SANG at the west end of the DERA South site should be provided as greenspace which would help to alleviate the potential for disturbance by residents of the new garden village from having to go or preferring to go to Chobham Common with the dog because this SANG site would be nearer Housing development adjacent to heathland always damages it especially if local arsonists are imported nearby but my proposals would go a long way to making the proposed Local Plan sound Though it would be far better if this garden village was scrapped and the DERA South site restored to heathland or just converted to another employment site as that would do far less damage to the Chobham Common SSSI and SPA site

____________________

Stephen R Miles 21st February 2018

From Caroline CravenTo Planning PolicySubject Representation for Local PlanDate 22 February 2018 092519Attachments Representation_form_for_Regulation_19_Caroline_Cravendocx

Please find attached my representation form in response to the Runnymede 2030 Local PlanConsultation

Regards helliphellip Caroline Craven

1886

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full contact details of the agent in 2

Part B (1) ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

XParagraph PolicyPolicies Map

X

X

X

4 Do you consider the Local Plan is

x

4 (1) Legally compliant Yes No

X

4 (2) SoundYes No

x

4 (3) Complies with the Duty to co-operateYesNo

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the duty to co-operate please also use this box to set out your comments

I believe the Local Plan does not comply with the duty to co-operate with neighbouring Boroughs The previous version was not deemed to be compliant as I understand it and there does not appear to be any significant changes that allow this plan to be compliant

RBC seems to have relied on the former Statement of Community Involvement (SCI) of 2014 In a digital age 15 lines in a local (The Villager Feb 9th) on page 11 is a poor means of communication to the Runnymede Borough residents on something that will affect them so deeply

In addition the views expressed at the RBC meeting by the attending RBC councillors were essentially that they accepted it wasnrsquot as good as it should be but was lsquothe best wersquore going to get at the momentrsquo and if not submitted then a Government Inspector would be appointed and they would lose control ndash a view I can fully understand but does not give the Runnymede residents a feeling of confidence in the legality or the integrity of the plan nor that the council truly want the best for the Borough

With regard to the Longcross site improvements to the station do not address the capacity issue The impact to commuters further up the line will be significant Peak times will be heavily impacted If additional trains are being proposed on this line the impact to the residents of Egham who already have to wait some 35-40 minutes in the hour whilst gates are down would therefore have even less opportunity to transverse the line at the crossing points Longcross station has no accessible car parking or drop off points This would necessitate commuters travelling to Virginia Water Egham whose own parking capability is limited Virginia Water has lost a large number of station car park spaces due to a new development This would also cause increased congestion in already known problem junctions The additional burden to the A320 which is already operating over practical capacity at several junctions and expected to deteriorate over the coming years would be significant (A320 Corridor Study ndash Feasibility Study ndash Interim report February 2018)

(Continue on a separate sheetexpand box if necessary)

The Longcross site will also need medical facilities ndash GPrsquos and potentially NHS drop in centre to ensure the current burden on the NHS is not exacerbated

With regard to the Traveller pitches they appear to amount to 35 within the scope of the development areas However the council plan to deliver 131 net additional plotspitches ndash 96 of which are not covered in this local plan This is an extremely emotive subject and needs to be identified properly in the plan and not almost hidden to avoid confrontation with angry residents that this County is already over run with these communities Integration with new developments is not the answer ndash Allocation of Traveller sites and pitches is according to the Government guidelines ldquoinappropriate within the Green beltrdquo and trying to slide this surreptitiously into new developments is a totally inappropriate solution

The Hurst Lane development was dismissed by the Council despite the residents being on board and a sustainable and acceptable plan being put forward for c 800-1000 homes on 80 -100 acres Over time this Lane has deteriorated to the point that Planning Inspectors described it as an lsquoindustrial wastelandrsquo In addition the Council resources are being tied up with the numerous issues generated by the Lane and the inability to resolve with the resources available The primary reason given is that the land is lsquoGreen Beltrsquo although under exceptional circumstances (which I believe this would come under) the council are able to and plan to in other areas use this land It is effectively a brownfield site which could be permitted fi connected to a SANG trade off which the residents plan was

6 Please set out what modification (s) you consider necessary to make the Local Plan legally compliant or sound having regard to the Matter you have identified at 5 above where this relates to soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of modification at examination) You will need to say why this modification will make the Local Plan legally compliant or sound It will be helpful if you are able to put forward your suggested revised wording of any policy or text Please be as precise as possible

For the plan to be sound I believe that

1) Review the inclusion of the Hurst Lane site ndash SLAA 59 ndash within the plan Appendix B states the capacity of 10 for Hurst Lane and 5 for Padd Farm If this relates to additional properties the number does not reflect the plans of up to 800 houses Access and infrastructure are addressed and the reduction in headcount in the councilrsquos Customer Services (I believe there is a dedicated resource looking after Padd Farm Hurst Lane) would be an additional benefit

2) Greater publicity is required over the consultation process The council appear to work on a lsquopullrsquo basis in that residents of the borough (other than those in the Residents Associations) have to actively seek out any updates from the council Local newspapers are not a good way of disseminating information in the digital age

3) Identify the additional travellergypsy site plans and move outside of the Green Belt area

If these steps were taken the residents would all have ample opportunity to contribute to the development of the local plan

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further representations based on the original representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

7 If your representation is seeking a modification do you consider it necessary to participate at the oral part of the examination

No I do not wish to participate Yes I wish to participate

X

at the oral examinationat the oral examination

8 If you wish to participate at the oral part of the examination please outline why you consider this to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who have indicated that they wish to participate at the oral part of the examination

9 Signature Date

21st February 2018

Caroline Craven

Notes to Accompany Model Representation Form

1 Introduction

11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 2004[footnoteRef1] (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound [1 View at httpwwwlegislationgovukukpga20045contents ]

2 Legal Compliance and Duty to Co-operate

21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness

22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)[footnoteRef2] it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices [2 LDDs are defined in regulation 5 ndash see link below ]

bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications

bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)[footnoteRef3] On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified [3 View at httpwwwlegislationgovukuksi2012767contentsmade ]

bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy)

23 You should consider the following before making a representation on compliance with the duty to co-operate

bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty

bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

3 Soundness

31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy

bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development

bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence

bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities

bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF

32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations

bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included

bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan

bull If the policy is not covered elsewhere in what way is the plan unsound without the policy

bull If the plan is unsound without the policy what should the policy say

4 General advice

41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

6

image1png

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full contact details of the agent in 2

Title Mrs First Name Caroline Last Name Craven Job Title (where relevant)

Organisation (where relevant)

Address Line 1 Southover Line 2 Hurst Lane Line 3 Egham Line 4 Surrey Post Code TW20 8QJ Telephone Number Email Address (where relevant)

2

Part B (1) ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

XParagraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails to comply with the duty to co-operate Please be as precise as possible If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

X X X

x

X

x

I believe the Local Plan does not comply with the duty to co-operate with neighbouring Boroughs The previous version was not deemed to be compliant as I understand it and there does not appear to be any significant changes that allow this plan to be compliant

RBC seems to have relied on the former Statement of Community Involvement (SCI) of 2014 In a digital age 15 lines in a local (The Villager Feb 9th) on page 11 is a poor means of communication to the Runnymede Borough residents on something that will affect them so deeply

In addition the views expressed at the RBC meeting by the attending RBC councillors were essentially that they accepted it wasnrsquot as good as it should be but was lsquothe best wersquore going to get at the momentrsquo and if not submitted then a Government Inspector would be appointed and they would lose control ndash a view I can fully understand but does not give the Runnymede residents a feeling of confidence in the legality or the integrity of the plan nor that the council truly want the best for the Borough

With regard to the Longcross site improvements to the station do not address the capacity issue The impact to commuters further up the line will be significant Peak times will be heavily impacted If additional trains are being proposed on this line the impact to the residents of Egham who already have to wait some 35-40 minutes in the hour whilst gates are down would therefore have even less opportunity to transverse the line at the crossing points Longcross station has no accessible car parking or drop off points This would necessitate commuters travelling to Virginia Water Egham whose own parking capability is limited Virginia Water has lost a large number of station car park spaces due to a new development This would also cause increased congestion in already known problem junctions The additional burden to the A320 which is already operating over practical capacity at several junctions and expected to deteriorate over the coming years would be significant (A320 Corridor Study ndash Feasibility Study ndash Interim report February 2018)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally compliant or sound having regard to the Matter you have identified at 5 above where this relates to soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of modification at examination) You will need to say why this modification will make the Local Plan legally compliant or sound It will be helpful if you are able to put forward your suggested revised wording of any policy or text Please be as precise as possible

For the plan to be sound I believe that

1) Review the inclusion of the Hurst Lane site ndash SLAA 59 ndash within the plan Appendix B states the capacity of 10 for Hurst Lane and 5 for Padd Farm If this relates to additional properties the number does not reflect the plans of up to 800 houses Access and infrastructure are addressed and the reduction in headcount in the councilrsquos Customer Services (I believe there is a dedicated resource looking after Padd Farm Hurst Lane) would be an additional benefit

2) Greater publicity is required over the consultation process The council appear to work on a lsquopullrsquo basis in that residents of the borough (other than those in the Residents Associations) have to actively seek out any updates from the council Local newspapers are not a good way of disseminating information in the digital age

3) Identify the additional travellergypsy site plans and move outside of the Green Belt area

If these steps were taken the residents would all have ample opportunity to contribute to the development of the local plan

The Longcross site will also need medical facilities ndash GPrsquos and potentially NHS drop in centre to ensure the current burden on the NHS is not exacerbated

With regard to the Traveller pitches they appear to amount to 35 within the scope of the development areas However the council plan to deliver 131 net additional plotspitches ndash 96 of which are not covered in this local plan This is an extremely emotive subject and needs to be identified properly in the plan and not almost hidden to avoid confrontation with angry residents that this County is already over run with these communities Integration with new developments is not the answer ndash Allocation of Traveller sites and pitches is according to the Government guidelines ldquoinappropriate within the Green beltrdquo and trying to slide this surreptitiously into new developments is a totally inappropriate solution

The Hurst Lane development was dismissed by the Council despite the residents being on board and a sustainable and acceptable plan being put forward for c 800-1000 homes on 80 -100 acres Over time this Lane has deteriorated to the point that Planning Inspectors described it as an lsquoindustrial wastelandrsquo In addition the Council resources are being tied up with the numerous issues generated by the Lane and the inability to resolve with the resources available The primary reason given is that the land is lsquoGreen Beltrsquo although under exceptional circumstances (which I believe this would come under) the council are able to and plan to in other areas use this land It is effectively a brownfield site which could be permitted fi connected to a SANG trade off which the residents plan was

4

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further representations based on the original representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

7 If your representation is seeking a modification do you consider it necessary to participate at the oral part of the examination

No I do not wish to participate Yes I wish to participate at the oral examination at the oral examination

8 If you wish to participate at the oral part of the examination please outline why you consider this to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who have indicated that they wish to participate at the oral part of the examination

9 Signature Date

X

Caroline Craven 21st February 2018

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan 1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination 42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

FromPolicy

Subject FW New Housing Plans 2015-2030Date 21 February 2018 164919

Sent 21 February 2018 1608To PlanningSubject New Housing Plans 2015-2030

To

Policy Planning and Strategy Team

Runnymede Borough Council

Station Road

Addlestone

21022018

Dear Sirs

As an Ottershaw resident of nearly 30 years i would like you to read and take on board my objections to yourproposal to take land out of the green belt for housing and your plan to build so many houses in ourcommunity

Of course new houses have to be built right across the country now and in the future but i feel the plans youhave are for far too many houses The infrastructure of our community will just not sustain the extra amount ofpeople and cars and the general traffic that would entail

There are other possibilities available before your irreversible plans are put into action Are these possibilitiesbeing resourced

When i drive around the borough now and for a long long time i see so many empty office blocks Some ofthese have stood empty for yearsWhy has permission been given continuosly from what i can see on a huge scale for these to be built

This building of offices has to stop and the ones that have remained empty for years could be converted tohousing as in flats starter homes for young people

If Planning Practice Guidlines state that the use of Green Beltshould only occur in very special circumstances these and the Brownfield sites in Runnymede must be extensively researched

I live in Wilson Drive and for many years now when i leave my house to go into the village or elsewhere thereis often gridlock in every direction The roads in our community are so heavily used by cars and lorries headingtoward the M25 Can you imagine the impact so many more of these will bring Driving has not been a pleasurefor a long time and i do walk wherever possible Parking is a problem in the village as so many people use theone car park I believe there may be a plan in the pipeline to even get rid of that for road widening

We have a GP practice in the village that is getting harder to book an appointment for also i have been waitingmonths for an appointment at St Peters hospital and just keep getting apologetic letters

Quality of life is very important for your residents and that quality has already deteriorated lately

1888

In order to accomodate so many new residents you will be making the ones you have feel very disappointedand frustated that no one listens

There is no going back once the desicion has been made and so many houses built Please take my feelings and iam sure very many more residents comments and pleas into account before you make the irreversible decisionto go ahead with your plans

Yours Faithfully

Margaret Wensley and the Wensley family

Beechwood

Wilson Drive

Ottershaw

Surrey

KT16 0NT

----------- middotn==middot =

Planning Services

DELIVERED BY HAND

Runnymede Borough Council ~--------------=-middot ---------middot------~

Planning Dept Runnymede Borough Council Civic Offices Station Road Addlestone KT15 2AH

Dear Sirs

Catherine Brunton-Green 20The Glen Addlestone

KT151AQ

15th February 2018

Runnymede Draft local Plan 2015- 2030- Final Consultation

I have serious concerns in respect of this draft plan Runnymede Borough Council (RBC) have a duty of care to consult with listen and act upon the wishes of its residents There has been some consultation but this has not effectively reached all Runnymede residents Communication is unnecessarily legally complex and full of unexplained acronyms The basic Runnymede Voice delivered to every home has been abandoned There has been no flyer delivered to every home stating in a simplified way what is happening so that all abilities may be catered for Many people are isolated for numerous reasons and do not have internet access Neither is there evidence of full in depth cross boundary consultation with adjacent boroughs This local plan is driven primarily by a developers charter promoted by RBCS Head of Planning It is both unfair unjust and I question its soundness

The Strategic Housing Market Assessment has not taken leaving the EU into account and makes a blanket assumption on Heathrow expansion

I strongly object to the proposed loss of c 560 acres of Green Belt Our Prime Minister and government have recently stated that they are quote committed to protecting and enhancing our natural environment for successive generations therefore Green Belt land would only be lost as a last resort 11

bull Detailed evidence based research by The Council for The Protection of Rural England confirms that by fully utilising brownfield land 12 million homes could be built in London and the South East without the loss of any Green Belt

I have objection to building on the Veterinary Laboratory Green Belt Land Parcel BRow Town (Policy SL11 8283) is not justified for development This is designated for 150 additional dwellings and 2 gypsyTraveller pitches This site provides a natural demarcation between developments either side Designated SANG area is privately owned and not available The density of proposed build is unacceptable and above all an area of outstanding natural beauty would be destroyed

Our infrastructure is unable to cope at present A320 suffers perpetual gridlock now Equally gridlock is evidenced through Ottershaw Addlestone Station Road and A317 Addlestone Weybridge We already have unhealthily dangerous levels of roadside nitrogen dioxide concentrations in many areas such as Station Road RBC has made a lame submission in respect of

tackling roadside nitrogen dioxide concentrations in the South East (UK00310) Incidence of exacerbated breathing illnesses in this vicinity has increased dramatically in the past 7 years All age groups are affected

All GP surgeries across Runnymede have great difficulty in recruiting doctors Two practices in the immediate area are merging due to unprecedented numbers of doctors leaving and retiring Practice lists and capacity is stretched Patient access to services and patient safety has to be the highest priority Our schools are similarly affected

RBC infrastructure is totally reliant upon Surrey County Council who declare they are not in a financial position to fund the necessary support to develop the infrastructure for this Local Plan

I am prepared to speak at Public Enquiry

Yours faithfully

bull i I I bull bull

From Brian PickettTo Planning PolicySubject Runnymede 2030 Local Plan - submission of viewsDate 22 February 2018 090921Attachments Ottershaw development Objection letter February 2018docx

Please find attached the submission of my views on the Runnymede 2030 LocalPlan

Kind RegardsBrian Pickett

1891

planningrunnymedegovuk planningrunnymedegovuk

21022018

Re Runnymede 2030 Local Plan Ottershaw East ndash Objection to planning

Dear Sirs

We are writing to you again as we strongly object to the Runnymede Borough Councils plans to remove land behind houses along Brox Road known as lsquoOttershaw Eastrsquo from the Green Belt We are objecting for a number of reasons listed below

middot The Green Belt is precious once it is gone it is gone forever The removal of this land from the Green Belt does not comply with Planning Policy which states ldquothat Green Belt boundaries should only be altered in exceptional circumstancesrdquo there are no such circumstances that can justify the removal of this piece of land

middot The Green Belt should be an area that is preserved for future generations to enjoy and appreciate and many statements have been made by both the Government and members of Parliament on their commitment to protect the Green Belt ndash these statements now need to be converted into action in the Local Borough Plans The roll out of Green Belt to local councils in the 1950rsquos was to prevent urban sprawl and the merging of settlements thereby helping to preserve and protect the character of communities it encompassed protect the country setting and encourage development through regeneration of sites within towns and cities not villages

middot The description of Ottershaw by the council itself in the lsquoUrban Characteristicsrsquo publication on the Runnymede Borough Council website states ldquoOttershaw has its own identity and sense of place which is partly derived from the clearly identifiable heart of the urban area focused on The Otter and adjoining local shopping parade and community facilities as well as being surrounded by open greenbelt countryside Removing this green belt that is part of the identifiable heart of Ottershaw would destroy this villagersquos identity and community

middot The planning proposals and building on this part of the green belt land would lead to a considerable population increase in the village Services and facilities will struggle or fail to cope space is already limited at the doctorrsquos surgery and school places are at capacity The transport infrastructure is already stretched with limited bus services busy roads poorly maintained pavements and road surfaces Brox road is already used as a shortcut to avoid traffic congestion Given that Ottershaw does not have a train station it is reasonable to assume that the majority of houses would have at least one car the added traffic from the new development would put a severe strain on the road network and users Available information on mitigation is very vague and very open to interpretation and misguided assumptions

middot The Green Belt land is a habitat to an array of plants and animals including important pollinator species and larger animals such as birds foxes and deer There should be no assumption that animals will simply move to another area habitats are established over many years and this development will be another loss to the maintenance of biodiversity I enjoy the fauna and flora in these areas going for walks along the public footpaths Having such wonderful access to a relaxing escape so close to home is priceless and something I hold dear to myself my family and community What is now a beautiful scenic view will become a spoilt urban sprawl of modern housing

middot I moved to Ottershaw with my wife in 2016 to settle down and start a family The relaxed quiet village sense of community and safety surrounded by beautiful countryside were its appeal I are very concerned and disappointed that this planning proposal is still being considered which will undoubtedly destroy this idyllic setting

There are no ldquoexceptional or very special circumstancesrdquo that justify the removal of Ottershaw East from the Green Belt We trust that the Council will therefore not remove ldquoOttershaw Eastrdquo and ldquoThe Fieldrdquo from the Green Belt

Yours faithfully

Dr Brian Pickett

To Policy Planning and Strategy Team Runnymede Borough Council Civic Centre Station Road Addlestone Surrey KT15 2AH planningrunnymedegovuk

From Dr Brian Pickett 139 Brox Road Ottershaw Surrey KT16 0LG planningrunnymedegovuk

21022018 Re Runnymede 2030 Local Plan Ottershaw East ndash Objection to planning Dear Sirs We are writing to you again as we strongly object to the Runnymede Borough Councils plans to remove land behind houses along Brox Road known as lsquoOttershaw Eastrsquo from the Green Belt We are objecting for a number of reasons listed below bull The Green Belt is precious once it is gone it is gone forever The removal of this

land from the Green Belt does not comply with Planning Policy which states ldquothat Green Belt boundaries should only be altered in exceptional circumstancesrdquo there are no such circumstances that can justify the removal of this piece of land

bull The Green Belt should be an area that is preserved for future generations to enjoy

and appreciate and many statements have been made by both the Government and members of Parliament on their commitment to protect the Green Belt ndash these statements now need to be converted into action in the Local Borough Plans The roll out of Green Belt to local councils in the 1950rsquos was to prevent urban sprawl and the merging of settlements thereby helping to preserve and protect the character of communities it encompassed protect the country setting and encourage development through regeneration of sites within towns and cities not villages

bull The description of Ottershaw by the council itself in the lsquoUrban Characteristicsrsquo

publication on the Runnymede Borough Council website states ldquoOttershaw has its own identity and sense of place which is partly derived from the clearly identifiable heart of the urban area focused on The Otter and adjoining local shopping parade and community facilities as well as being surrounded by open greenbelt countryside Removing this green belt that is part of the identifiable heart of Ottershaw would destroy this villagersquos identity and community

bull The planning proposals and building on this part of the green belt land would lead

to a considerable population increase in the village Services and facilities will struggle or fail to cope space is already limited at the doctorrsquos surgery and school places are at capacity The transport infrastructure is already stretched with limited bus services busy roads poorly maintained pavements and road surfaces Brox road is already used as a shortcut to avoid traffic congestion Given that Ottershaw does not have a train station it is reasonable to assume that the majority of houses would have at least one car the added traffic from the new development would put a severe strain on the road network and users Available information on mitigation is very vague and very open to interpretation and misguided assumptions

bull The Green Belt land is a habitat to an array of plants and animals including important pollinator species and larger animals such as birds foxes and deer There should be no assumption that animals will simply move to another area habitats are established over many years and this development will be another loss to the maintenance of biodiversity I enjoy the fauna and flora in these areas going for walks along the public footpaths Having such wonderful access to a relaxing escape so close to home is priceless and something I hold dear to myself my family and community What is now a beautiful scenic view will become a spoilt urban sprawl of modern housing

bull I moved to Ottershaw with my wife in 2016 to settle down and start a family The

relaxed quiet village sense of community and safety surrounded by beautiful countryside were its appeal I are very concerned and disappointed that this planning proposal is still being considered which will undoubtedly destroy this idyllic setting

There are no ldquoexceptional or very special circumstancesrdquo that justify the removal of Ottershaw East from the Green Belt We trust that the Council will therefore not remove ldquoOttershaw Eastrdquo and ldquoThe Fieldrdquo from the Green Belt Yours faithfully Dr Brian Pickett

FromTo Planning PolicySubject Runnymede Local Plan 2030 - consultation responseDate 21 February 2018 163608Attachments Runnymede LP Response - EE15pdf

Please find attached a consultation response form

________________________________________Christian Leigh BSc(Hons) MPhil MRTPIDirectorLeigh amp Glennie Ltd6 All Souls RoadAscotBerkshire SL5 9EA

1893

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number 01344 297094 Email Address (where relevant)

mailchristianleighcouk

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number Email Address (where relevant)

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

From MCNAB DouglasTo Planning PolicySubject Runnymede Draft Local Plan consultation - Representation from Education and Skills Funding AgencyDate 21 February 2018 091407Attachments Runnymede Reg 19 response ESFADOC

Dear Runnymede Planning Policy Team

Please see attached a representation from the Education and Skills Funding Agency on theRunnymede Local Plan consultation

I would be grateful if you could confirm receipt

Best regardsDoug

Douglas McNab MRTPIForward Planning Manager ndash South East

Planning Team Free Schools CapitalEducation and Skills Funding AgencyDepartment for Education 5th floor Sanctuary Buildings 20 Great Smith Street London SW1P 3BT

Email douglasmcnabeducationgovukMobile 07990 082877Web wwwgovukesfa

1895

image1pngOur Ref ESFALocal PlanRunnymede 2018 21st February 2018

Dear SirMadam

Re Runnymede Local Plan

Consultation under Regulation 19 of Town and Country Planning (Local Planning) (England) Regulations 2012

Submission of the Education and Skills Funding Agency

1 The Education and Skills Funding Agency (ESFA) welcomes the opportunity to contribute to the development of planning policy at the local level

2 The ESFA launched on 1st April 2017 bringing together the existing responsibilities of the Education Funding Agency (EFA) and the Skills Funding Agency (SFA) to create a single funding agency accountable for funding education and training for children young people and adults The ESFA are accountable for pound61 billion of funding a year for the education and training sector including support for all state-provided education for 8 million children aged 3 to 16 and 16 million young people aged 16 to 19

3 Under the provisions of the Education Act 2011 and the Academies Act 2010 all new state schools are now academiesfree schools and the ESFA is the delivery body for many of these rather than local education authorities As such we aim to work closely with local authority education departments and planning authorities to meet the demand for new school places and new schools We do this through a variety of means including by supporting the adoption of sound local plan policies site allocations and guidance (all based on robust evidence) that facilitate the delivery of education infrastructure where and when it is needed and maximise developer contributions for schools In this capacity we would like to offer the following comments in response to the proposals outlined in the above consultation document

Comments on the Local Plan

4 As you will be aware the primary focus at this stage of the Local Planrsquos preparation is on the soundness of the plan with regard to it being positively prepared justified effective and consistent with national policy The following detailed comments set out the ESFArsquos view of the planrsquos soundness in respect of education provision

5 The ESFA notes that the local plan will make provision for a minimum of 7413 net additional dwellings over the plan period Development will generally complement the existing settlement pattern focusing the largest amounts of residential growth primarily in Chertsey (1950 homes) Addlestone (936 homes) and Egham (812 homes) A new ldquolocally led garden villagerdquo is also proposed at Longcross providing a further 1718 homes This level of development will put pressure on existing education infrastructure

6 The plan recognises that ldquoIt is important that infrastructure is delivered in a timely manner to ensure that the needs of the occupiers of new development can be met without placing undue burdens on existing infrastructure facilities and servicesrdquo (para 560) The ESFA supports Policy SD6 Infrastructure Provision amp Timing particularly the signposting of the Infrastructure Delivery Plan (IDP) and the need for development to deliver this either on-site or through s106 or CIL financial contributions off-site and the need for development to be phased in line with the provision of important supporting infrastructure

7 The latest version of the IDP states that there is an ongoing programme of primary school expansions this will help to meet the forecast need for 4-6FE of new capacity over the plan period The need for one new build school project is identified a 2FE primary school at the Longcross Garden Village (estimated cost pound99M to pound15M) this is referred to in the site allocation policies (see below) With respect to secondary school places it is anticipated that up to six additional FE could be required in the Borough by 2021 Additional places will be delivered through the new 6FE Runnymede Free School (which opened in temporary accommodation in 2017) development of additional FE within Salesian School (Catholic faith school) and expansion of another school in the Chertsey area (to accommodate demand from generated by the Longcross Garden Village site)

8 It would be useful if the background data informing these projections of need could be clarified particularly the pupil yield factors used and the evidence base supporting this This would help to demonstrate more clearly to the Inspector that the approach to the planning and delivery of education infrastructure has been positively prepared based on a strategy which seeks to meet objectively assessed infrastructure requirements and is justified based on proportionate evidence The ESFA notes that the Runnymede S106 SPG sets out pupil yield figures however this document dates from December 2007 so the figures may be outdated

9 The ESFA supports the Councilrsquos allocation and safeguarding of land for schools as set out in the following policies

middot Policy SD10 Longcross Garden Village - 2FE primary school with preschoolearly years settings

middot Policy SL2 to SL18 ndash series of housing allocation policies that highlight the need to make a financial contribution to early years primary and secondary school infrastructure ldquoeither through S106 or CIL (or its successor)rdquo

Developer Contributions and CIL

10 One of the tests of soundness is that a Local Plan is lsquoeffectiversquo ie the plan should be deliverable over its period In this context and with specific regard to planning for schools there is a need to ensure that education contributions made by developers are sufficient to deliver the additional school places required to meet the increase in demand generated by new developments The ESFA notes that the council has not adopted CIL and that the Planning Obligations SPG sets out how developer contributions to education provision will be secured via section 106 agreements The ESFA supports the Councilrsquos approach to ensure developer contributions address the impacts arising from growth However the ESFA recommends that the Local Plan includes a commitment to revise the Planning Obligations SPG in line with the latest evidence of the boroughrsquos infrastructure needs pupil yields and build costs (including the cost of school expansion new build and SEN provision) Any such review should be prepared in consultation with the county council as local education authority This will help to ensure appropriate rates are levied and the right infrastructure is secured across the borough

11 The ESFA would be particularly interested in responding to any update to the Infrastructure Delivery Plan or review of infrastructure requirements As such please add the ESFA to the database for future CIL consultations

Forward funding

12 In light of the proposed Longcross Garden Village emerging ESFA proposals for forward funding schools as part of large residential developments may be relevant for example if viability becomes an issue The ESFA aims to be able to clarify forward funding options for schools in 2018 We would be happy to meet to discuss this opportunity further once the options have been finalised and ifwhen relevant Any offer of forward funding would seek to maximise developer contributions to education infrastructure provision while supporting delivery of schools where and when they are needed

Conclusion

13 Finally I hope the above comments are helpful in finalising the Runnymede Local Plan with specific regard to the provision of land for new schools

14 Please notify the ESFA when the Local Plan is submitted for examination the Inspectorrsquos report is published and the Local Plan is adopted

15 Please do not hesitate to contact me if you have any queries regarding this response The ESFA looks forward to continuing to work with Runnymede Borough Council to develop a sound Local Plan that will aid in the delivery of new schools

Yours faithfully

DC McNab

Douglas McNab MRTPI

Forward Planning Manager

Tel 07990 082877

Email

douglasmcnabeducationgovuk

Web

wwwgovuk esfa

Education and Skills Funding Agency13

Department for EducationSanctuary BuildingsGreat Smith StreetLondonSW1P 3BT13

13

Tel 0207 340 700013

13

wwwgovukesfa13

13

13

To

Policy Planning and Strategy Team

Runnymede Borough Council

Civic Centre

Station Road

Addlestone

Surrey

KT15 2AH

From

Dr Brian Pickett

139 Brox Road

Ottershaw

Surrey

KT16 0LG

Title

Mrs

First Name

Caroline

Last Name

Craven

Job Title

(where relevant)

Organisation

(where relevant)

Address Line 1

Southover

Line 2

Hurst Lane

Line 3

Egham

Line 4

Surrey

Post Code

TW20 8QJ

Telephone Number

07770999572

Email Address

(where relevant)

Carolinecraven911hotmailcom

Page 12: Runnymede Borough Council, for submissions. My contact details are all in the WORD letter attached. But I will provide my telephone number here too, which …

9

6 AECOMrsquos conclusions in paragraph 865 of the June 2016 HRA 868 of the May 2017 HRA and AA and lastly in paragraphs 851 to 853 of the December 2017 HRA and AA is what you expect from AECOM a complete disregard for the issues based on just a Council policy of the provision of SANG irrespective of itsrsquo location and proximity to the proposed development Equally as the Planning Inspectorate is under the same UK Government ldquocoshrdquo as Natural England to enable the provision of more housing for the so-called housing crisis It is not a shortage of housing that is evident in England it is a clear case of overpopulation with successive governments failing to govern and do anything about excessive breeding of the native human population and uncontrolled inward migration of human numbers into the UK particularly in southern England Before the next round of housing proposals in this area post 2030 the UK Government must act to reduce the excessive human population growth in the Runnymede area and the excessive expansion of the London region I can already see the claims for the forthcoming Planning Inspection and future ones probably by the Housebuilderrsquos Federation and the agents or QCs for the private housebuilding companies (a QC was employed by one developerrsquos agent for the East Hampshire Joint Core Strategy to argue for more housing to be achieved within that area and Local Plan) that people are more important than wildlife and that we must build on the SPAs or very close to them as in the current Runnymede Local Plan This failure to properly mitigate for the development of the so-called Longcross Garden Village is the start of the destruction of one of Britainrsquos best remaining lowland heathland sites A national disgrace

The SLAA 99 proposal and the proposals to remove land from the greenbelt in this Local Plan are as clear evidence of the overpressure of people numbers on the finite land resource of England (ldquoThe UKs population is projected to reach 70 million by 2030 ndash thatrsquos nine million more people than in 2008rdquo Ref Forum for the Future in 2010 ldquoUK population grows by over 400000 in the last year the largest absolute increase of any European countryrdquo Ref Population Mattersrsquo research in August 2013 ldquoEnglandrsquos population is already twice that of Germany per square mile and four times that of France It is our quality of life that is being affectedrdquo Ref Lord Horam speaking in February 2018 in the House of Lordrsquos debate on ldquoBrexit and the labour marketrdquo As the Planning

10

Inspector stated at the commencement of the Inspection of the East Hampshire Joint Core Strategy that I was present at in 2013 ldquoI have been given a growth agendardquo With this type of pressure by the UK Government I am not sure that I or nature conservation can expect a fair and objective hearing in 2018 when I object to Runnymede Borough Councilrsquos Local Plan 2030 we will see

7 For the proximity of the DERA South development to the SPA site of Chobham Common there is one potential solution and that is to reduce the number of houses in the DERA South (Longcross Garden Village) proposal and to make a new large SANG out of the land at the western end of the DERA South site This would require the ldquoDuty of Cooperationrdquo to be observed as the extreme west end of the DERA South site as it is within the land area of Surrey Heath Borough Council but I am sure this could be achievable This area would have to be fenced with dense mesh topped with rolled razor wire or similar to prevent free roaming dogs and cats from going onto the Chobham Common site south of the M3 and B386 roads If this fence was sufficiently high and doubled up to make two fences these could be used to keep the public and their animals away from and out of the SPA of Chobham Common and also necessarily to confine the loose running dogs a requirement for SANGS from being run-over on the B386 and the other connecting roads

8 The SPD issued and adopted by Surrey Heath Borough Council states I paragraph 57 ldquoIn the period up to 2028 Surrey Heath is expected to grant planning permission for 324010 new homes and this will require the provision of over 60 hectares of SANG Major or large new developments will be expected to provide bespoke on-site SANG rather than relying on the suite of SANGs being developed by the Borough Councilrdquo SLAA 99 is a large development so it should lose some of its housing land to provide on-site SANG to separate itsrsquo housing provision from Chobham Common

Similarly for Runnymede a large amount of new homes will result from the conclusions of the Planning Inspection Almost certainly more than proposed at the moment (this was the experience in East Hampshire in 2013) In this case and similar to the proposals adopted for SLAA 97 SANG provision for SLAA 99 (which appears to be scheduled to provide

11

the largest number of homes and something like 7000 extra people in Runnymede Borough) the SANG needs to be onsite and the solution I propose in this paragraph would cater for this Hoping new residents will all get in their cars to take the dog or cat for a walk over one mile away on Trumps Farm is not sustainable practicable or likely AECOMrsquos HRA and AA of both May and December 2017 completely fail to address the roaming catrsquos issue Despite AECOMrsquos clearly different point-of-view I do not believe that Runnymede Borough Council in their role as lsquocompetent authorityrsquo can conclude that no adverse effect on the integrity of internationally important wildlife sites of the Thames Basin Heathrsquos SPA will result from their proposals in their Local Plan 2030 as a consequence of what I consider are flawed conclusions proposed by AECOM The only light at the end of the tunnel of flawed conclusions in my opinion by AECOM is their final paragraph in the Dec 2017 HRA and AA that at paragraph 93 ldquoHowever it is recommended that the potential for further bespoke or strategic SANG later in the plan period is explored by the Council in time for Examination in Publicrdquo

I suggest to the Planning Inspector and Runnymede Borough Council that an on-site large SANG at the west end of the DERA South site should be provided as greenspace which would help to alleviate the potential for disturbance by residents of the new garden village from having to go or preferring to go to Chobham Common with the dog because this SANG site would be nearer Housing development adjacent to heathland always damages it especially if local arsonists are imported nearby but my proposals would go a long way to making the proposed Local Plan sound Though it would be far better if this garden village was scrapped and the DERA South site restored to heathland or just converted to another employment site as that would do far less damage to the Chobham Common SSSI and SPA site

____________________

Stephen R Miles 21st February 2018

From Caroline CravenTo Planning PolicySubject Representation for Local PlanDate 22 February 2018 092519Attachments Representation_form_for_Regulation_19_Caroline_Cravendocx

Please find attached my representation form in response to the Runnymede 2030 Local PlanConsultation

Regards helliphellip Caroline Craven

1886

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full contact details of the agent in 2

Part B (1) ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

XParagraph PolicyPolicies Map

X

X

X

4 Do you consider the Local Plan is

x

4 (1) Legally compliant Yes No

X

4 (2) SoundYes No

x

4 (3) Complies with the Duty to co-operateYesNo

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the duty to co-operate please also use this box to set out your comments

I believe the Local Plan does not comply with the duty to co-operate with neighbouring Boroughs The previous version was not deemed to be compliant as I understand it and there does not appear to be any significant changes that allow this plan to be compliant

RBC seems to have relied on the former Statement of Community Involvement (SCI) of 2014 In a digital age 15 lines in a local (The Villager Feb 9th) on page 11 is a poor means of communication to the Runnymede Borough residents on something that will affect them so deeply

In addition the views expressed at the RBC meeting by the attending RBC councillors were essentially that they accepted it wasnrsquot as good as it should be but was lsquothe best wersquore going to get at the momentrsquo and if not submitted then a Government Inspector would be appointed and they would lose control ndash a view I can fully understand but does not give the Runnymede residents a feeling of confidence in the legality or the integrity of the plan nor that the council truly want the best for the Borough

With regard to the Longcross site improvements to the station do not address the capacity issue The impact to commuters further up the line will be significant Peak times will be heavily impacted If additional trains are being proposed on this line the impact to the residents of Egham who already have to wait some 35-40 minutes in the hour whilst gates are down would therefore have even less opportunity to transverse the line at the crossing points Longcross station has no accessible car parking or drop off points This would necessitate commuters travelling to Virginia Water Egham whose own parking capability is limited Virginia Water has lost a large number of station car park spaces due to a new development This would also cause increased congestion in already known problem junctions The additional burden to the A320 which is already operating over practical capacity at several junctions and expected to deteriorate over the coming years would be significant (A320 Corridor Study ndash Feasibility Study ndash Interim report February 2018)

(Continue on a separate sheetexpand box if necessary)

The Longcross site will also need medical facilities ndash GPrsquos and potentially NHS drop in centre to ensure the current burden on the NHS is not exacerbated

With regard to the Traveller pitches they appear to amount to 35 within the scope of the development areas However the council plan to deliver 131 net additional plotspitches ndash 96 of which are not covered in this local plan This is an extremely emotive subject and needs to be identified properly in the plan and not almost hidden to avoid confrontation with angry residents that this County is already over run with these communities Integration with new developments is not the answer ndash Allocation of Traveller sites and pitches is according to the Government guidelines ldquoinappropriate within the Green beltrdquo and trying to slide this surreptitiously into new developments is a totally inappropriate solution

The Hurst Lane development was dismissed by the Council despite the residents being on board and a sustainable and acceptable plan being put forward for c 800-1000 homes on 80 -100 acres Over time this Lane has deteriorated to the point that Planning Inspectors described it as an lsquoindustrial wastelandrsquo In addition the Council resources are being tied up with the numerous issues generated by the Lane and the inability to resolve with the resources available The primary reason given is that the land is lsquoGreen Beltrsquo although under exceptional circumstances (which I believe this would come under) the council are able to and plan to in other areas use this land It is effectively a brownfield site which could be permitted fi connected to a SANG trade off which the residents plan was

6 Please set out what modification (s) you consider necessary to make the Local Plan legally compliant or sound having regard to the Matter you have identified at 5 above where this relates to soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of modification at examination) You will need to say why this modification will make the Local Plan legally compliant or sound It will be helpful if you are able to put forward your suggested revised wording of any policy or text Please be as precise as possible

For the plan to be sound I believe that

1) Review the inclusion of the Hurst Lane site ndash SLAA 59 ndash within the plan Appendix B states the capacity of 10 for Hurst Lane and 5 for Padd Farm If this relates to additional properties the number does not reflect the plans of up to 800 houses Access and infrastructure are addressed and the reduction in headcount in the councilrsquos Customer Services (I believe there is a dedicated resource looking after Padd Farm Hurst Lane) would be an additional benefit

2) Greater publicity is required over the consultation process The council appear to work on a lsquopullrsquo basis in that residents of the borough (other than those in the Residents Associations) have to actively seek out any updates from the council Local newspapers are not a good way of disseminating information in the digital age

3) Identify the additional travellergypsy site plans and move outside of the Green Belt area

If these steps were taken the residents would all have ample opportunity to contribute to the development of the local plan

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further representations based on the original representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

7 If your representation is seeking a modification do you consider it necessary to participate at the oral part of the examination

No I do not wish to participate Yes I wish to participate

X

at the oral examinationat the oral examination

8 If you wish to participate at the oral part of the examination please outline why you consider this to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who have indicated that they wish to participate at the oral part of the examination

9 Signature Date

21st February 2018

Caroline Craven

Notes to Accompany Model Representation Form

1 Introduction

11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 2004[footnoteRef1] (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound [1 View at httpwwwlegislationgovukukpga20045contents ]

2 Legal Compliance and Duty to Co-operate

21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness

22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)[footnoteRef2] it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices [2 LDDs are defined in regulation 5 ndash see link below ]

bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications

bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)[footnoteRef3] On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified [3 View at httpwwwlegislationgovukuksi2012767contentsmade ]

bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy)

23 You should consider the following before making a representation on compliance with the duty to co-operate

bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty

bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

3 Soundness

31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy

bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development

bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence

bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities

bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF

32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations

bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included

bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan

bull If the policy is not covered elsewhere in what way is the plan unsound without the policy

bull If the plan is unsound without the policy what should the policy say

4 General advice

41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

6

image1png

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full contact details of the agent in 2

Title Mrs First Name Caroline Last Name Craven Job Title (where relevant)

Organisation (where relevant)

Address Line 1 Southover Line 2 Hurst Lane Line 3 Egham Line 4 Surrey Post Code TW20 8QJ Telephone Number Email Address (where relevant)

2

Part B (1) ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

XParagraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails to comply with the duty to co-operate Please be as precise as possible If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

X X X

x

X

x

I believe the Local Plan does not comply with the duty to co-operate with neighbouring Boroughs The previous version was not deemed to be compliant as I understand it and there does not appear to be any significant changes that allow this plan to be compliant

RBC seems to have relied on the former Statement of Community Involvement (SCI) of 2014 In a digital age 15 lines in a local (The Villager Feb 9th) on page 11 is a poor means of communication to the Runnymede Borough residents on something that will affect them so deeply

In addition the views expressed at the RBC meeting by the attending RBC councillors were essentially that they accepted it wasnrsquot as good as it should be but was lsquothe best wersquore going to get at the momentrsquo and if not submitted then a Government Inspector would be appointed and they would lose control ndash a view I can fully understand but does not give the Runnymede residents a feeling of confidence in the legality or the integrity of the plan nor that the council truly want the best for the Borough

With regard to the Longcross site improvements to the station do not address the capacity issue The impact to commuters further up the line will be significant Peak times will be heavily impacted If additional trains are being proposed on this line the impact to the residents of Egham who already have to wait some 35-40 minutes in the hour whilst gates are down would therefore have even less opportunity to transverse the line at the crossing points Longcross station has no accessible car parking or drop off points This would necessitate commuters travelling to Virginia Water Egham whose own parking capability is limited Virginia Water has lost a large number of station car park spaces due to a new development This would also cause increased congestion in already known problem junctions The additional burden to the A320 which is already operating over practical capacity at several junctions and expected to deteriorate over the coming years would be significant (A320 Corridor Study ndash Feasibility Study ndash Interim report February 2018)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally compliant or sound having regard to the Matter you have identified at 5 above where this relates to soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of modification at examination) You will need to say why this modification will make the Local Plan legally compliant or sound It will be helpful if you are able to put forward your suggested revised wording of any policy or text Please be as precise as possible

For the plan to be sound I believe that

1) Review the inclusion of the Hurst Lane site ndash SLAA 59 ndash within the plan Appendix B states the capacity of 10 for Hurst Lane and 5 for Padd Farm If this relates to additional properties the number does not reflect the plans of up to 800 houses Access and infrastructure are addressed and the reduction in headcount in the councilrsquos Customer Services (I believe there is a dedicated resource looking after Padd Farm Hurst Lane) would be an additional benefit

2) Greater publicity is required over the consultation process The council appear to work on a lsquopullrsquo basis in that residents of the borough (other than those in the Residents Associations) have to actively seek out any updates from the council Local newspapers are not a good way of disseminating information in the digital age

3) Identify the additional travellergypsy site plans and move outside of the Green Belt area

If these steps were taken the residents would all have ample opportunity to contribute to the development of the local plan

The Longcross site will also need medical facilities ndash GPrsquos and potentially NHS drop in centre to ensure the current burden on the NHS is not exacerbated

With regard to the Traveller pitches they appear to amount to 35 within the scope of the development areas However the council plan to deliver 131 net additional plotspitches ndash 96 of which are not covered in this local plan This is an extremely emotive subject and needs to be identified properly in the plan and not almost hidden to avoid confrontation with angry residents that this County is already over run with these communities Integration with new developments is not the answer ndash Allocation of Traveller sites and pitches is according to the Government guidelines ldquoinappropriate within the Green beltrdquo and trying to slide this surreptitiously into new developments is a totally inappropriate solution

The Hurst Lane development was dismissed by the Council despite the residents being on board and a sustainable and acceptable plan being put forward for c 800-1000 homes on 80 -100 acres Over time this Lane has deteriorated to the point that Planning Inspectors described it as an lsquoindustrial wastelandrsquo In addition the Council resources are being tied up with the numerous issues generated by the Lane and the inability to resolve with the resources available The primary reason given is that the land is lsquoGreen Beltrsquo although under exceptional circumstances (which I believe this would come under) the council are able to and plan to in other areas use this land It is effectively a brownfield site which could be permitted fi connected to a SANG trade off which the residents plan was

4

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further representations based on the original representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

7 If your representation is seeking a modification do you consider it necessary to participate at the oral part of the examination

No I do not wish to participate Yes I wish to participate at the oral examination at the oral examination

8 If you wish to participate at the oral part of the examination please outline why you consider this to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who have indicated that they wish to participate at the oral part of the examination

9 Signature Date

X

Caroline Craven 21st February 2018

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan 1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination 42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

FromPolicy

Subject FW New Housing Plans 2015-2030Date 21 February 2018 164919

Sent 21 February 2018 1608To PlanningSubject New Housing Plans 2015-2030

To

Policy Planning and Strategy Team

Runnymede Borough Council

Station Road

Addlestone

21022018

Dear Sirs

As an Ottershaw resident of nearly 30 years i would like you to read and take on board my objections to yourproposal to take land out of the green belt for housing and your plan to build so many houses in ourcommunity

Of course new houses have to be built right across the country now and in the future but i feel the plans youhave are for far too many houses The infrastructure of our community will just not sustain the extra amount ofpeople and cars and the general traffic that would entail

There are other possibilities available before your irreversible plans are put into action Are these possibilitiesbeing resourced

When i drive around the borough now and for a long long time i see so many empty office blocks Some ofthese have stood empty for yearsWhy has permission been given continuosly from what i can see on a huge scale for these to be built

This building of offices has to stop and the ones that have remained empty for years could be converted tohousing as in flats starter homes for young people

If Planning Practice Guidlines state that the use of Green Beltshould only occur in very special circumstances these and the Brownfield sites in Runnymede must be extensively researched

I live in Wilson Drive and for many years now when i leave my house to go into the village or elsewhere thereis often gridlock in every direction The roads in our community are so heavily used by cars and lorries headingtoward the M25 Can you imagine the impact so many more of these will bring Driving has not been a pleasurefor a long time and i do walk wherever possible Parking is a problem in the village as so many people use theone car park I believe there may be a plan in the pipeline to even get rid of that for road widening

We have a GP practice in the village that is getting harder to book an appointment for also i have been waitingmonths for an appointment at St Peters hospital and just keep getting apologetic letters

Quality of life is very important for your residents and that quality has already deteriorated lately

1888

In order to accomodate so many new residents you will be making the ones you have feel very disappointedand frustated that no one listens

There is no going back once the desicion has been made and so many houses built Please take my feelings and iam sure very many more residents comments and pleas into account before you make the irreversible decisionto go ahead with your plans

Yours Faithfully

Margaret Wensley and the Wensley family

Beechwood

Wilson Drive

Ottershaw

Surrey

KT16 0NT

----------- middotn==middot =

Planning Services

DELIVERED BY HAND

Runnymede Borough Council ~--------------=-middot ---------middot------~

Planning Dept Runnymede Borough Council Civic Offices Station Road Addlestone KT15 2AH

Dear Sirs

Catherine Brunton-Green 20The Glen Addlestone

KT151AQ

15th February 2018

Runnymede Draft local Plan 2015- 2030- Final Consultation

I have serious concerns in respect of this draft plan Runnymede Borough Council (RBC) have a duty of care to consult with listen and act upon the wishes of its residents There has been some consultation but this has not effectively reached all Runnymede residents Communication is unnecessarily legally complex and full of unexplained acronyms The basic Runnymede Voice delivered to every home has been abandoned There has been no flyer delivered to every home stating in a simplified way what is happening so that all abilities may be catered for Many people are isolated for numerous reasons and do not have internet access Neither is there evidence of full in depth cross boundary consultation with adjacent boroughs This local plan is driven primarily by a developers charter promoted by RBCS Head of Planning It is both unfair unjust and I question its soundness

The Strategic Housing Market Assessment has not taken leaving the EU into account and makes a blanket assumption on Heathrow expansion

I strongly object to the proposed loss of c 560 acres of Green Belt Our Prime Minister and government have recently stated that they are quote committed to protecting and enhancing our natural environment for successive generations therefore Green Belt land would only be lost as a last resort 11

bull Detailed evidence based research by The Council for The Protection of Rural England confirms that by fully utilising brownfield land 12 million homes could be built in London and the South East without the loss of any Green Belt

I have objection to building on the Veterinary Laboratory Green Belt Land Parcel BRow Town (Policy SL11 8283) is not justified for development This is designated for 150 additional dwellings and 2 gypsyTraveller pitches This site provides a natural demarcation between developments either side Designated SANG area is privately owned and not available The density of proposed build is unacceptable and above all an area of outstanding natural beauty would be destroyed

Our infrastructure is unable to cope at present A320 suffers perpetual gridlock now Equally gridlock is evidenced through Ottershaw Addlestone Station Road and A317 Addlestone Weybridge We already have unhealthily dangerous levels of roadside nitrogen dioxide concentrations in many areas such as Station Road RBC has made a lame submission in respect of

tackling roadside nitrogen dioxide concentrations in the South East (UK00310) Incidence of exacerbated breathing illnesses in this vicinity has increased dramatically in the past 7 years All age groups are affected

All GP surgeries across Runnymede have great difficulty in recruiting doctors Two practices in the immediate area are merging due to unprecedented numbers of doctors leaving and retiring Practice lists and capacity is stretched Patient access to services and patient safety has to be the highest priority Our schools are similarly affected

RBC infrastructure is totally reliant upon Surrey County Council who declare they are not in a financial position to fund the necessary support to develop the infrastructure for this Local Plan

I am prepared to speak at Public Enquiry

Yours faithfully

bull i I I bull bull

From Brian PickettTo Planning PolicySubject Runnymede 2030 Local Plan - submission of viewsDate 22 February 2018 090921Attachments Ottershaw development Objection letter February 2018docx

Please find attached the submission of my views on the Runnymede 2030 LocalPlan

Kind RegardsBrian Pickett

1891

planningrunnymedegovuk planningrunnymedegovuk

21022018

Re Runnymede 2030 Local Plan Ottershaw East ndash Objection to planning

Dear Sirs

We are writing to you again as we strongly object to the Runnymede Borough Councils plans to remove land behind houses along Brox Road known as lsquoOttershaw Eastrsquo from the Green Belt We are objecting for a number of reasons listed below

middot The Green Belt is precious once it is gone it is gone forever The removal of this land from the Green Belt does not comply with Planning Policy which states ldquothat Green Belt boundaries should only be altered in exceptional circumstancesrdquo there are no such circumstances that can justify the removal of this piece of land

middot The Green Belt should be an area that is preserved for future generations to enjoy and appreciate and many statements have been made by both the Government and members of Parliament on their commitment to protect the Green Belt ndash these statements now need to be converted into action in the Local Borough Plans The roll out of Green Belt to local councils in the 1950rsquos was to prevent urban sprawl and the merging of settlements thereby helping to preserve and protect the character of communities it encompassed protect the country setting and encourage development through regeneration of sites within towns and cities not villages

middot The description of Ottershaw by the council itself in the lsquoUrban Characteristicsrsquo publication on the Runnymede Borough Council website states ldquoOttershaw has its own identity and sense of place which is partly derived from the clearly identifiable heart of the urban area focused on The Otter and adjoining local shopping parade and community facilities as well as being surrounded by open greenbelt countryside Removing this green belt that is part of the identifiable heart of Ottershaw would destroy this villagersquos identity and community

middot The planning proposals and building on this part of the green belt land would lead to a considerable population increase in the village Services and facilities will struggle or fail to cope space is already limited at the doctorrsquos surgery and school places are at capacity The transport infrastructure is already stretched with limited bus services busy roads poorly maintained pavements and road surfaces Brox road is already used as a shortcut to avoid traffic congestion Given that Ottershaw does not have a train station it is reasonable to assume that the majority of houses would have at least one car the added traffic from the new development would put a severe strain on the road network and users Available information on mitigation is very vague and very open to interpretation and misguided assumptions

middot The Green Belt land is a habitat to an array of plants and animals including important pollinator species and larger animals such as birds foxes and deer There should be no assumption that animals will simply move to another area habitats are established over many years and this development will be another loss to the maintenance of biodiversity I enjoy the fauna and flora in these areas going for walks along the public footpaths Having such wonderful access to a relaxing escape so close to home is priceless and something I hold dear to myself my family and community What is now a beautiful scenic view will become a spoilt urban sprawl of modern housing

middot I moved to Ottershaw with my wife in 2016 to settle down and start a family The relaxed quiet village sense of community and safety surrounded by beautiful countryside were its appeal I are very concerned and disappointed that this planning proposal is still being considered which will undoubtedly destroy this idyllic setting

There are no ldquoexceptional or very special circumstancesrdquo that justify the removal of Ottershaw East from the Green Belt We trust that the Council will therefore not remove ldquoOttershaw Eastrdquo and ldquoThe Fieldrdquo from the Green Belt

Yours faithfully

Dr Brian Pickett

To Policy Planning and Strategy Team Runnymede Borough Council Civic Centre Station Road Addlestone Surrey KT15 2AH planningrunnymedegovuk

From Dr Brian Pickett 139 Brox Road Ottershaw Surrey KT16 0LG planningrunnymedegovuk

21022018 Re Runnymede 2030 Local Plan Ottershaw East ndash Objection to planning Dear Sirs We are writing to you again as we strongly object to the Runnymede Borough Councils plans to remove land behind houses along Brox Road known as lsquoOttershaw Eastrsquo from the Green Belt We are objecting for a number of reasons listed below bull The Green Belt is precious once it is gone it is gone forever The removal of this

land from the Green Belt does not comply with Planning Policy which states ldquothat Green Belt boundaries should only be altered in exceptional circumstancesrdquo there are no such circumstances that can justify the removal of this piece of land

bull The Green Belt should be an area that is preserved for future generations to enjoy

and appreciate and many statements have been made by both the Government and members of Parliament on their commitment to protect the Green Belt ndash these statements now need to be converted into action in the Local Borough Plans The roll out of Green Belt to local councils in the 1950rsquos was to prevent urban sprawl and the merging of settlements thereby helping to preserve and protect the character of communities it encompassed protect the country setting and encourage development through regeneration of sites within towns and cities not villages

bull The description of Ottershaw by the council itself in the lsquoUrban Characteristicsrsquo

publication on the Runnymede Borough Council website states ldquoOttershaw has its own identity and sense of place which is partly derived from the clearly identifiable heart of the urban area focused on The Otter and adjoining local shopping parade and community facilities as well as being surrounded by open greenbelt countryside Removing this green belt that is part of the identifiable heart of Ottershaw would destroy this villagersquos identity and community

bull The planning proposals and building on this part of the green belt land would lead

to a considerable population increase in the village Services and facilities will struggle or fail to cope space is already limited at the doctorrsquos surgery and school places are at capacity The transport infrastructure is already stretched with limited bus services busy roads poorly maintained pavements and road surfaces Brox road is already used as a shortcut to avoid traffic congestion Given that Ottershaw does not have a train station it is reasonable to assume that the majority of houses would have at least one car the added traffic from the new development would put a severe strain on the road network and users Available information on mitigation is very vague and very open to interpretation and misguided assumptions

bull The Green Belt land is a habitat to an array of plants and animals including important pollinator species and larger animals such as birds foxes and deer There should be no assumption that animals will simply move to another area habitats are established over many years and this development will be another loss to the maintenance of biodiversity I enjoy the fauna and flora in these areas going for walks along the public footpaths Having such wonderful access to a relaxing escape so close to home is priceless and something I hold dear to myself my family and community What is now a beautiful scenic view will become a spoilt urban sprawl of modern housing

bull I moved to Ottershaw with my wife in 2016 to settle down and start a family The

relaxed quiet village sense of community and safety surrounded by beautiful countryside were its appeal I are very concerned and disappointed that this planning proposal is still being considered which will undoubtedly destroy this idyllic setting

There are no ldquoexceptional or very special circumstancesrdquo that justify the removal of Ottershaw East from the Green Belt We trust that the Council will therefore not remove ldquoOttershaw Eastrdquo and ldquoThe Fieldrdquo from the Green Belt Yours faithfully Dr Brian Pickett

FromTo Planning PolicySubject Runnymede Local Plan 2030 - consultation responseDate 21 February 2018 163608Attachments Runnymede LP Response - EE15pdf

Please find attached a consultation response form

________________________________________Christian Leigh BSc(Hons) MPhil MRTPIDirectorLeigh amp Glennie Ltd6 All Souls RoadAscotBerkshire SL5 9EA

1893

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number 01344 297094 Email Address (where relevant)

mailchristianleighcouk

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number Email Address (where relevant)

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

From MCNAB DouglasTo Planning PolicySubject Runnymede Draft Local Plan consultation - Representation from Education and Skills Funding AgencyDate 21 February 2018 091407Attachments Runnymede Reg 19 response ESFADOC

Dear Runnymede Planning Policy Team

Please see attached a representation from the Education and Skills Funding Agency on theRunnymede Local Plan consultation

I would be grateful if you could confirm receipt

Best regardsDoug

Douglas McNab MRTPIForward Planning Manager ndash South East

Planning Team Free Schools CapitalEducation and Skills Funding AgencyDepartment for Education 5th floor Sanctuary Buildings 20 Great Smith Street London SW1P 3BT

Email douglasmcnabeducationgovukMobile 07990 082877Web wwwgovukesfa

1895

image1pngOur Ref ESFALocal PlanRunnymede 2018 21st February 2018

Dear SirMadam

Re Runnymede Local Plan

Consultation under Regulation 19 of Town and Country Planning (Local Planning) (England) Regulations 2012

Submission of the Education and Skills Funding Agency

1 The Education and Skills Funding Agency (ESFA) welcomes the opportunity to contribute to the development of planning policy at the local level

2 The ESFA launched on 1st April 2017 bringing together the existing responsibilities of the Education Funding Agency (EFA) and the Skills Funding Agency (SFA) to create a single funding agency accountable for funding education and training for children young people and adults The ESFA are accountable for pound61 billion of funding a year for the education and training sector including support for all state-provided education for 8 million children aged 3 to 16 and 16 million young people aged 16 to 19

3 Under the provisions of the Education Act 2011 and the Academies Act 2010 all new state schools are now academiesfree schools and the ESFA is the delivery body for many of these rather than local education authorities As such we aim to work closely with local authority education departments and planning authorities to meet the demand for new school places and new schools We do this through a variety of means including by supporting the adoption of sound local plan policies site allocations and guidance (all based on robust evidence) that facilitate the delivery of education infrastructure where and when it is needed and maximise developer contributions for schools In this capacity we would like to offer the following comments in response to the proposals outlined in the above consultation document

Comments on the Local Plan

4 As you will be aware the primary focus at this stage of the Local Planrsquos preparation is on the soundness of the plan with regard to it being positively prepared justified effective and consistent with national policy The following detailed comments set out the ESFArsquos view of the planrsquos soundness in respect of education provision

5 The ESFA notes that the local plan will make provision for a minimum of 7413 net additional dwellings over the plan period Development will generally complement the existing settlement pattern focusing the largest amounts of residential growth primarily in Chertsey (1950 homes) Addlestone (936 homes) and Egham (812 homes) A new ldquolocally led garden villagerdquo is also proposed at Longcross providing a further 1718 homes This level of development will put pressure on existing education infrastructure

6 The plan recognises that ldquoIt is important that infrastructure is delivered in a timely manner to ensure that the needs of the occupiers of new development can be met without placing undue burdens on existing infrastructure facilities and servicesrdquo (para 560) The ESFA supports Policy SD6 Infrastructure Provision amp Timing particularly the signposting of the Infrastructure Delivery Plan (IDP) and the need for development to deliver this either on-site or through s106 or CIL financial contributions off-site and the need for development to be phased in line with the provision of important supporting infrastructure

7 The latest version of the IDP states that there is an ongoing programme of primary school expansions this will help to meet the forecast need for 4-6FE of new capacity over the plan period The need for one new build school project is identified a 2FE primary school at the Longcross Garden Village (estimated cost pound99M to pound15M) this is referred to in the site allocation policies (see below) With respect to secondary school places it is anticipated that up to six additional FE could be required in the Borough by 2021 Additional places will be delivered through the new 6FE Runnymede Free School (which opened in temporary accommodation in 2017) development of additional FE within Salesian School (Catholic faith school) and expansion of another school in the Chertsey area (to accommodate demand from generated by the Longcross Garden Village site)

8 It would be useful if the background data informing these projections of need could be clarified particularly the pupil yield factors used and the evidence base supporting this This would help to demonstrate more clearly to the Inspector that the approach to the planning and delivery of education infrastructure has been positively prepared based on a strategy which seeks to meet objectively assessed infrastructure requirements and is justified based on proportionate evidence The ESFA notes that the Runnymede S106 SPG sets out pupil yield figures however this document dates from December 2007 so the figures may be outdated

9 The ESFA supports the Councilrsquos allocation and safeguarding of land for schools as set out in the following policies

middot Policy SD10 Longcross Garden Village - 2FE primary school with preschoolearly years settings

middot Policy SL2 to SL18 ndash series of housing allocation policies that highlight the need to make a financial contribution to early years primary and secondary school infrastructure ldquoeither through S106 or CIL (or its successor)rdquo

Developer Contributions and CIL

10 One of the tests of soundness is that a Local Plan is lsquoeffectiversquo ie the plan should be deliverable over its period In this context and with specific regard to planning for schools there is a need to ensure that education contributions made by developers are sufficient to deliver the additional school places required to meet the increase in demand generated by new developments The ESFA notes that the council has not adopted CIL and that the Planning Obligations SPG sets out how developer contributions to education provision will be secured via section 106 agreements The ESFA supports the Councilrsquos approach to ensure developer contributions address the impacts arising from growth However the ESFA recommends that the Local Plan includes a commitment to revise the Planning Obligations SPG in line with the latest evidence of the boroughrsquos infrastructure needs pupil yields and build costs (including the cost of school expansion new build and SEN provision) Any such review should be prepared in consultation with the county council as local education authority This will help to ensure appropriate rates are levied and the right infrastructure is secured across the borough

11 The ESFA would be particularly interested in responding to any update to the Infrastructure Delivery Plan or review of infrastructure requirements As such please add the ESFA to the database for future CIL consultations

Forward funding

12 In light of the proposed Longcross Garden Village emerging ESFA proposals for forward funding schools as part of large residential developments may be relevant for example if viability becomes an issue The ESFA aims to be able to clarify forward funding options for schools in 2018 We would be happy to meet to discuss this opportunity further once the options have been finalised and ifwhen relevant Any offer of forward funding would seek to maximise developer contributions to education infrastructure provision while supporting delivery of schools where and when they are needed

Conclusion

13 Finally I hope the above comments are helpful in finalising the Runnymede Local Plan with specific regard to the provision of land for new schools

14 Please notify the ESFA when the Local Plan is submitted for examination the Inspectorrsquos report is published and the Local Plan is adopted

15 Please do not hesitate to contact me if you have any queries regarding this response The ESFA looks forward to continuing to work with Runnymede Borough Council to develop a sound Local Plan that will aid in the delivery of new schools

Yours faithfully

DC McNab

Douglas McNab MRTPI

Forward Planning Manager

Tel 07990 082877

Email

douglasmcnabeducationgovuk

Web

wwwgovuk esfa

Education and Skills Funding Agency13

Department for EducationSanctuary BuildingsGreat Smith StreetLondonSW1P 3BT13

13

Tel 0207 340 700013

13

wwwgovukesfa13

13

13

To

Policy Planning and Strategy Team

Runnymede Borough Council

Civic Centre

Station Road

Addlestone

Surrey

KT15 2AH

From

Dr Brian Pickett

139 Brox Road

Ottershaw

Surrey

KT16 0LG

Title

Mrs

First Name

Caroline

Last Name

Craven

Job Title

(where relevant)

Organisation

(where relevant)

Address Line 1

Southover

Line 2

Hurst Lane

Line 3

Egham

Line 4

Surrey

Post Code

TW20 8QJ

Telephone Number

07770999572

Email Address

(where relevant)

Carolinecraven911hotmailcom

Page 13: Runnymede Borough Council, for submissions. My contact details are all in the WORD letter attached. But I will provide my telephone number here too, which …

10

Inspector stated at the commencement of the Inspection of the East Hampshire Joint Core Strategy that I was present at in 2013 ldquoI have been given a growth agendardquo With this type of pressure by the UK Government I am not sure that I or nature conservation can expect a fair and objective hearing in 2018 when I object to Runnymede Borough Councilrsquos Local Plan 2030 we will see

7 For the proximity of the DERA South development to the SPA site of Chobham Common there is one potential solution and that is to reduce the number of houses in the DERA South (Longcross Garden Village) proposal and to make a new large SANG out of the land at the western end of the DERA South site This would require the ldquoDuty of Cooperationrdquo to be observed as the extreme west end of the DERA South site as it is within the land area of Surrey Heath Borough Council but I am sure this could be achievable This area would have to be fenced with dense mesh topped with rolled razor wire or similar to prevent free roaming dogs and cats from going onto the Chobham Common site south of the M3 and B386 roads If this fence was sufficiently high and doubled up to make two fences these could be used to keep the public and their animals away from and out of the SPA of Chobham Common and also necessarily to confine the loose running dogs a requirement for SANGS from being run-over on the B386 and the other connecting roads

8 The SPD issued and adopted by Surrey Heath Borough Council states I paragraph 57 ldquoIn the period up to 2028 Surrey Heath is expected to grant planning permission for 324010 new homes and this will require the provision of over 60 hectares of SANG Major or large new developments will be expected to provide bespoke on-site SANG rather than relying on the suite of SANGs being developed by the Borough Councilrdquo SLAA 99 is a large development so it should lose some of its housing land to provide on-site SANG to separate itsrsquo housing provision from Chobham Common

Similarly for Runnymede a large amount of new homes will result from the conclusions of the Planning Inspection Almost certainly more than proposed at the moment (this was the experience in East Hampshire in 2013) In this case and similar to the proposals adopted for SLAA 97 SANG provision for SLAA 99 (which appears to be scheduled to provide

11

the largest number of homes and something like 7000 extra people in Runnymede Borough) the SANG needs to be onsite and the solution I propose in this paragraph would cater for this Hoping new residents will all get in their cars to take the dog or cat for a walk over one mile away on Trumps Farm is not sustainable practicable or likely AECOMrsquos HRA and AA of both May and December 2017 completely fail to address the roaming catrsquos issue Despite AECOMrsquos clearly different point-of-view I do not believe that Runnymede Borough Council in their role as lsquocompetent authorityrsquo can conclude that no adverse effect on the integrity of internationally important wildlife sites of the Thames Basin Heathrsquos SPA will result from their proposals in their Local Plan 2030 as a consequence of what I consider are flawed conclusions proposed by AECOM The only light at the end of the tunnel of flawed conclusions in my opinion by AECOM is their final paragraph in the Dec 2017 HRA and AA that at paragraph 93 ldquoHowever it is recommended that the potential for further bespoke or strategic SANG later in the plan period is explored by the Council in time for Examination in Publicrdquo

I suggest to the Planning Inspector and Runnymede Borough Council that an on-site large SANG at the west end of the DERA South site should be provided as greenspace which would help to alleviate the potential for disturbance by residents of the new garden village from having to go or preferring to go to Chobham Common with the dog because this SANG site would be nearer Housing development adjacent to heathland always damages it especially if local arsonists are imported nearby but my proposals would go a long way to making the proposed Local Plan sound Though it would be far better if this garden village was scrapped and the DERA South site restored to heathland or just converted to another employment site as that would do far less damage to the Chobham Common SSSI and SPA site

____________________

Stephen R Miles 21st February 2018

From Caroline CravenTo Planning PolicySubject Representation for Local PlanDate 22 February 2018 092519Attachments Representation_form_for_Regulation_19_Caroline_Cravendocx

Please find attached my representation form in response to the Runnymede 2030 Local PlanConsultation

Regards helliphellip Caroline Craven

1886

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full contact details of the agent in 2

Part B (1) ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

XParagraph PolicyPolicies Map

X

X

X

4 Do you consider the Local Plan is

x

4 (1) Legally compliant Yes No

X

4 (2) SoundYes No

x

4 (3) Complies with the Duty to co-operateYesNo

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the duty to co-operate please also use this box to set out your comments

I believe the Local Plan does not comply with the duty to co-operate with neighbouring Boroughs The previous version was not deemed to be compliant as I understand it and there does not appear to be any significant changes that allow this plan to be compliant

RBC seems to have relied on the former Statement of Community Involvement (SCI) of 2014 In a digital age 15 lines in a local (The Villager Feb 9th) on page 11 is a poor means of communication to the Runnymede Borough residents on something that will affect them so deeply

In addition the views expressed at the RBC meeting by the attending RBC councillors were essentially that they accepted it wasnrsquot as good as it should be but was lsquothe best wersquore going to get at the momentrsquo and if not submitted then a Government Inspector would be appointed and they would lose control ndash a view I can fully understand but does not give the Runnymede residents a feeling of confidence in the legality or the integrity of the plan nor that the council truly want the best for the Borough

With regard to the Longcross site improvements to the station do not address the capacity issue The impact to commuters further up the line will be significant Peak times will be heavily impacted If additional trains are being proposed on this line the impact to the residents of Egham who already have to wait some 35-40 minutes in the hour whilst gates are down would therefore have even less opportunity to transverse the line at the crossing points Longcross station has no accessible car parking or drop off points This would necessitate commuters travelling to Virginia Water Egham whose own parking capability is limited Virginia Water has lost a large number of station car park spaces due to a new development This would also cause increased congestion in already known problem junctions The additional burden to the A320 which is already operating over practical capacity at several junctions and expected to deteriorate over the coming years would be significant (A320 Corridor Study ndash Feasibility Study ndash Interim report February 2018)

(Continue on a separate sheetexpand box if necessary)

The Longcross site will also need medical facilities ndash GPrsquos and potentially NHS drop in centre to ensure the current burden on the NHS is not exacerbated

With regard to the Traveller pitches they appear to amount to 35 within the scope of the development areas However the council plan to deliver 131 net additional plotspitches ndash 96 of which are not covered in this local plan This is an extremely emotive subject and needs to be identified properly in the plan and not almost hidden to avoid confrontation with angry residents that this County is already over run with these communities Integration with new developments is not the answer ndash Allocation of Traveller sites and pitches is according to the Government guidelines ldquoinappropriate within the Green beltrdquo and trying to slide this surreptitiously into new developments is a totally inappropriate solution

The Hurst Lane development was dismissed by the Council despite the residents being on board and a sustainable and acceptable plan being put forward for c 800-1000 homes on 80 -100 acres Over time this Lane has deteriorated to the point that Planning Inspectors described it as an lsquoindustrial wastelandrsquo In addition the Council resources are being tied up with the numerous issues generated by the Lane and the inability to resolve with the resources available The primary reason given is that the land is lsquoGreen Beltrsquo although under exceptional circumstances (which I believe this would come under) the council are able to and plan to in other areas use this land It is effectively a brownfield site which could be permitted fi connected to a SANG trade off which the residents plan was

6 Please set out what modification (s) you consider necessary to make the Local Plan legally compliant or sound having regard to the Matter you have identified at 5 above where this relates to soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of modification at examination) You will need to say why this modification will make the Local Plan legally compliant or sound It will be helpful if you are able to put forward your suggested revised wording of any policy or text Please be as precise as possible

For the plan to be sound I believe that

1) Review the inclusion of the Hurst Lane site ndash SLAA 59 ndash within the plan Appendix B states the capacity of 10 for Hurst Lane and 5 for Padd Farm If this relates to additional properties the number does not reflect the plans of up to 800 houses Access and infrastructure are addressed and the reduction in headcount in the councilrsquos Customer Services (I believe there is a dedicated resource looking after Padd Farm Hurst Lane) would be an additional benefit

2) Greater publicity is required over the consultation process The council appear to work on a lsquopullrsquo basis in that residents of the borough (other than those in the Residents Associations) have to actively seek out any updates from the council Local newspapers are not a good way of disseminating information in the digital age

3) Identify the additional travellergypsy site plans and move outside of the Green Belt area

If these steps were taken the residents would all have ample opportunity to contribute to the development of the local plan

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further representations based on the original representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

7 If your representation is seeking a modification do you consider it necessary to participate at the oral part of the examination

No I do not wish to participate Yes I wish to participate

X

at the oral examinationat the oral examination

8 If you wish to participate at the oral part of the examination please outline why you consider this to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who have indicated that they wish to participate at the oral part of the examination

9 Signature Date

21st February 2018

Caroline Craven

Notes to Accompany Model Representation Form

1 Introduction

11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 2004[footnoteRef1] (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound [1 View at httpwwwlegislationgovukukpga20045contents ]

2 Legal Compliance and Duty to Co-operate

21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness

22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)[footnoteRef2] it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices [2 LDDs are defined in regulation 5 ndash see link below ]

bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications

bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)[footnoteRef3] On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified [3 View at httpwwwlegislationgovukuksi2012767contentsmade ]

bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy)

23 You should consider the following before making a representation on compliance with the duty to co-operate

bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty

bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

3 Soundness

31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy

bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development

bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence

bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities

bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF

32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations

bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included

bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan

bull If the policy is not covered elsewhere in what way is the plan unsound without the policy

bull If the plan is unsound without the policy what should the policy say

4 General advice

41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

6

image1png

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full contact details of the agent in 2

Title Mrs First Name Caroline Last Name Craven Job Title (where relevant)

Organisation (where relevant)

Address Line 1 Southover Line 2 Hurst Lane Line 3 Egham Line 4 Surrey Post Code TW20 8QJ Telephone Number Email Address (where relevant)

2

Part B (1) ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

XParagraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails to comply with the duty to co-operate Please be as precise as possible If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

X X X

x

X

x

I believe the Local Plan does not comply with the duty to co-operate with neighbouring Boroughs The previous version was not deemed to be compliant as I understand it and there does not appear to be any significant changes that allow this plan to be compliant

RBC seems to have relied on the former Statement of Community Involvement (SCI) of 2014 In a digital age 15 lines in a local (The Villager Feb 9th) on page 11 is a poor means of communication to the Runnymede Borough residents on something that will affect them so deeply

In addition the views expressed at the RBC meeting by the attending RBC councillors were essentially that they accepted it wasnrsquot as good as it should be but was lsquothe best wersquore going to get at the momentrsquo and if not submitted then a Government Inspector would be appointed and they would lose control ndash a view I can fully understand but does not give the Runnymede residents a feeling of confidence in the legality or the integrity of the plan nor that the council truly want the best for the Borough

With regard to the Longcross site improvements to the station do not address the capacity issue The impact to commuters further up the line will be significant Peak times will be heavily impacted If additional trains are being proposed on this line the impact to the residents of Egham who already have to wait some 35-40 minutes in the hour whilst gates are down would therefore have even less opportunity to transverse the line at the crossing points Longcross station has no accessible car parking or drop off points This would necessitate commuters travelling to Virginia Water Egham whose own parking capability is limited Virginia Water has lost a large number of station car park spaces due to a new development This would also cause increased congestion in already known problem junctions The additional burden to the A320 which is already operating over practical capacity at several junctions and expected to deteriorate over the coming years would be significant (A320 Corridor Study ndash Feasibility Study ndash Interim report February 2018)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally compliant or sound having regard to the Matter you have identified at 5 above where this relates to soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of modification at examination) You will need to say why this modification will make the Local Plan legally compliant or sound It will be helpful if you are able to put forward your suggested revised wording of any policy or text Please be as precise as possible

For the plan to be sound I believe that

1) Review the inclusion of the Hurst Lane site ndash SLAA 59 ndash within the plan Appendix B states the capacity of 10 for Hurst Lane and 5 for Padd Farm If this relates to additional properties the number does not reflect the plans of up to 800 houses Access and infrastructure are addressed and the reduction in headcount in the councilrsquos Customer Services (I believe there is a dedicated resource looking after Padd Farm Hurst Lane) would be an additional benefit

2) Greater publicity is required over the consultation process The council appear to work on a lsquopullrsquo basis in that residents of the borough (other than those in the Residents Associations) have to actively seek out any updates from the council Local newspapers are not a good way of disseminating information in the digital age

3) Identify the additional travellergypsy site plans and move outside of the Green Belt area

If these steps were taken the residents would all have ample opportunity to contribute to the development of the local plan

The Longcross site will also need medical facilities ndash GPrsquos and potentially NHS drop in centre to ensure the current burden on the NHS is not exacerbated

With regard to the Traveller pitches they appear to amount to 35 within the scope of the development areas However the council plan to deliver 131 net additional plotspitches ndash 96 of which are not covered in this local plan This is an extremely emotive subject and needs to be identified properly in the plan and not almost hidden to avoid confrontation with angry residents that this County is already over run with these communities Integration with new developments is not the answer ndash Allocation of Traveller sites and pitches is according to the Government guidelines ldquoinappropriate within the Green beltrdquo and trying to slide this surreptitiously into new developments is a totally inappropriate solution

The Hurst Lane development was dismissed by the Council despite the residents being on board and a sustainable and acceptable plan being put forward for c 800-1000 homes on 80 -100 acres Over time this Lane has deteriorated to the point that Planning Inspectors described it as an lsquoindustrial wastelandrsquo In addition the Council resources are being tied up with the numerous issues generated by the Lane and the inability to resolve with the resources available The primary reason given is that the land is lsquoGreen Beltrsquo although under exceptional circumstances (which I believe this would come under) the council are able to and plan to in other areas use this land It is effectively a brownfield site which could be permitted fi connected to a SANG trade off which the residents plan was

4

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further representations based on the original representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

7 If your representation is seeking a modification do you consider it necessary to participate at the oral part of the examination

No I do not wish to participate Yes I wish to participate at the oral examination at the oral examination

8 If you wish to participate at the oral part of the examination please outline why you consider this to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who have indicated that they wish to participate at the oral part of the examination

9 Signature Date

X

Caroline Craven 21st February 2018

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan 1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination 42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

FromPolicy

Subject FW New Housing Plans 2015-2030Date 21 February 2018 164919

Sent 21 February 2018 1608To PlanningSubject New Housing Plans 2015-2030

To

Policy Planning and Strategy Team

Runnymede Borough Council

Station Road

Addlestone

21022018

Dear Sirs

As an Ottershaw resident of nearly 30 years i would like you to read and take on board my objections to yourproposal to take land out of the green belt for housing and your plan to build so many houses in ourcommunity

Of course new houses have to be built right across the country now and in the future but i feel the plans youhave are for far too many houses The infrastructure of our community will just not sustain the extra amount ofpeople and cars and the general traffic that would entail

There are other possibilities available before your irreversible plans are put into action Are these possibilitiesbeing resourced

When i drive around the borough now and for a long long time i see so many empty office blocks Some ofthese have stood empty for yearsWhy has permission been given continuosly from what i can see on a huge scale for these to be built

This building of offices has to stop and the ones that have remained empty for years could be converted tohousing as in flats starter homes for young people

If Planning Practice Guidlines state that the use of Green Beltshould only occur in very special circumstances these and the Brownfield sites in Runnymede must be extensively researched

I live in Wilson Drive and for many years now when i leave my house to go into the village or elsewhere thereis often gridlock in every direction The roads in our community are so heavily used by cars and lorries headingtoward the M25 Can you imagine the impact so many more of these will bring Driving has not been a pleasurefor a long time and i do walk wherever possible Parking is a problem in the village as so many people use theone car park I believe there may be a plan in the pipeline to even get rid of that for road widening

We have a GP practice in the village that is getting harder to book an appointment for also i have been waitingmonths for an appointment at St Peters hospital and just keep getting apologetic letters

Quality of life is very important for your residents and that quality has already deteriorated lately

1888

In order to accomodate so many new residents you will be making the ones you have feel very disappointedand frustated that no one listens

There is no going back once the desicion has been made and so many houses built Please take my feelings and iam sure very many more residents comments and pleas into account before you make the irreversible decisionto go ahead with your plans

Yours Faithfully

Margaret Wensley and the Wensley family

Beechwood

Wilson Drive

Ottershaw

Surrey

KT16 0NT

----------- middotn==middot =

Planning Services

DELIVERED BY HAND

Runnymede Borough Council ~--------------=-middot ---------middot------~

Planning Dept Runnymede Borough Council Civic Offices Station Road Addlestone KT15 2AH

Dear Sirs

Catherine Brunton-Green 20The Glen Addlestone

KT151AQ

15th February 2018

Runnymede Draft local Plan 2015- 2030- Final Consultation

I have serious concerns in respect of this draft plan Runnymede Borough Council (RBC) have a duty of care to consult with listen and act upon the wishes of its residents There has been some consultation but this has not effectively reached all Runnymede residents Communication is unnecessarily legally complex and full of unexplained acronyms The basic Runnymede Voice delivered to every home has been abandoned There has been no flyer delivered to every home stating in a simplified way what is happening so that all abilities may be catered for Many people are isolated for numerous reasons and do not have internet access Neither is there evidence of full in depth cross boundary consultation with adjacent boroughs This local plan is driven primarily by a developers charter promoted by RBCS Head of Planning It is both unfair unjust and I question its soundness

The Strategic Housing Market Assessment has not taken leaving the EU into account and makes a blanket assumption on Heathrow expansion

I strongly object to the proposed loss of c 560 acres of Green Belt Our Prime Minister and government have recently stated that they are quote committed to protecting and enhancing our natural environment for successive generations therefore Green Belt land would only be lost as a last resort 11

bull Detailed evidence based research by The Council for The Protection of Rural England confirms that by fully utilising brownfield land 12 million homes could be built in London and the South East without the loss of any Green Belt

I have objection to building on the Veterinary Laboratory Green Belt Land Parcel BRow Town (Policy SL11 8283) is not justified for development This is designated for 150 additional dwellings and 2 gypsyTraveller pitches This site provides a natural demarcation between developments either side Designated SANG area is privately owned and not available The density of proposed build is unacceptable and above all an area of outstanding natural beauty would be destroyed

Our infrastructure is unable to cope at present A320 suffers perpetual gridlock now Equally gridlock is evidenced through Ottershaw Addlestone Station Road and A317 Addlestone Weybridge We already have unhealthily dangerous levels of roadside nitrogen dioxide concentrations in many areas such as Station Road RBC has made a lame submission in respect of

tackling roadside nitrogen dioxide concentrations in the South East (UK00310) Incidence of exacerbated breathing illnesses in this vicinity has increased dramatically in the past 7 years All age groups are affected

All GP surgeries across Runnymede have great difficulty in recruiting doctors Two practices in the immediate area are merging due to unprecedented numbers of doctors leaving and retiring Practice lists and capacity is stretched Patient access to services and patient safety has to be the highest priority Our schools are similarly affected

RBC infrastructure is totally reliant upon Surrey County Council who declare they are not in a financial position to fund the necessary support to develop the infrastructure for this Local Plan

I am prepared to speak at Public Enquiry

Yours faithfully

bull i I I bull bull

From Brian PickettTo Planning PolicySubject Runnymede 2030 Local Plan - submission of viewsDate 22 February 2018 090921Attachments Ottershaw development Objection letter February 2018docx

Please find attached the submission of my views on the Runnymede 2030 LocalPlan

Kind RegardsBrian Pickett

1891

planningrunnymedegovuk planningrunnymedegovuk

21022018

Re Runnymede 2030 Local Plan Ottershaw East ndash Objection to planning

Dear Sirs

We are writing to you again as we strongly object to the Runnymede Borough Councils plans to remove land behind houses along Brox Road known as lsquoOttershaw Eastrsquo from the Green Belt We are objecting for a number of reasons listed below

middot The Green Belt is precious once it is gone it is gone forever The removal of this land from the Green Belt does not comply with Planning Policy which states ldquothat Green Belt boundaries should only be altered in exceptional circumstancesrdquo there are no such circumstances that can justify the removal of this piece of land

middot The Green Belt should be an area that is preserved for future generations to enjoy and appreciate and many statements have been made by both the Government and members of Parliament on their commitment to protect the Green Belt ndash these statements now need to be converted into action in the Local Borough Plans The roll out of Green Belt to local councils in the 1950rsquos was to prevent urban sprawl and the merging of settlements thereby helping to preserve and protect the character of communities it encompassed protect the country setting and encourage development through regeneration of sites within towns and cities not villages

middot The description of Ottershaw by the council itself in the lsquoUrban Characteristicsrsquo publication on the Runnymede Borough Council website states ldquoOttershaw has its own identity and sense of place which is partly derived from the clearly identifiable heart of the urban area focused on The Otter and adjoining local shopping parade and community facilities as well as being surrounded by open greenbelt countryside Removing this green belt that is part of the identifiable heart of Ottershaw would destroy this villagersquos identity and community

middot The planning proposals and building on this part of the green belt land would lead to a considerable population increase in the village Services and facilities will struggle or fail to cope space is already limited at the doctorrsquos surgery and school places are at capacity The transport infrastructure is already stretched with limited bus services busy roads poorly maintained pavements and road surfaces Brox road is already used as a shortcut to avoid traffic congestion Given that Ottershaw does not have a train station it is reasonable to assume that the majority of houses would have at least one car the added traffic from the new development would put a severe strain on the road network and users Available information on mitigation is very vague and very open to interpretation and misguided assumptions

middot The Green Belt land is a habitat to an array of plants and animals including important pollinator species and larger animals such as birds foxes and deer There should be no assumption that animals will simply move to another area habitats are established over many years and this development will be another loss to the maintenance of biodiversity I enjoy the fauna and flora in these areas going for walks along the public footpaths Having such wonderful access to a relaxing escape so close to home is priceless and something I hold dear to myself my family and community What is now a beautiful scenic view will become a spoilt urban sprawl of modern housing

middot I moved to Ottershaw with my wife in 2016 to settle down and start a family The relaxed quiet village sense of community and safety surrounded by beautiful countryside were its appeal I are very concerned and disappointed that this planning proposal is still being considered which will undoubtedly destroy this idyllic setting

There are no ldquoexceptional or very special circumstancesrdquo that justify the removal of Ottershaw East from the Green Belt We trust that the Council will therefore not remove ldquoOttershaw Eastrdquo and ldquoThe Fieldrdquo from the Green Belt

Yours faithfully

Dr Brian Pickett

To Policy Planning and Strategy Team Runnymede Borough Council Civic Centre Station Road Addlestone Surrey KT15 2AH planningrunnymedegovuk

From Dr Brian Pickett 139 Brox Road Ottershaw Surrey KT16 0LG planningrunnymedegovuk

21022018 Re Runnymede 2030 Local Plan Ottershaw East ndash Objection to planning Dear Sirs We are writing to you again as we strongly object to the Runnymede Borough Councils plans to remove land behind houses along Brox Road known as lsquoOttershaw Eastrsquo from the Green Belt We are objecting for a number of reasons listed below bull The Green Belt is precious once it is gone it is gone forever The removal of this

land from the Green Belt does not comply with Planning Policy which states ldquothat Green Belt boundaries should only be altered in exceptional circumstancesrdquo there are no such circumstances that can justify the removal of this piece of land

bull The Green Belt should be an area that is preserved for future generations to enjoy

and appreciate and many statements have been made by both the Government and members of Parliament on their commitment to protect the Green Belt ndash these statements now need to be converted into action in the Local Borough Plans The roll out of Green Belt to local councils in the 1950rsquos was to prevent urban sprawl and the merging of settlements thereby helping to preserve and protect the character of communities it encompassed protect the country setting and encourage development through regeneration of sites within towns and cities not villages

bull The description of Ottershaw by the council itself in the lsquoUrban Characteristicsrsquo

publication on the Runnymede Borough Council website states ldquoOttershaw has its own identity and sense of place which is partly derived from the clearly identifiable heart of the urban area focused on The Otter and adjoining local shopping parade and community facilities as well as being surrounded by open greenbelt countryside Removing this green belt that is part of the identifiable heart of Ottershaw would destroy this villagersquos identity and community

bull The planning proposals and building on this part of the green belt land would lead

to a considerable population increase in the village Services and facilities will struggle or fail to cope space is already limited at the doctorrsquos surgery and school places are at capacity The transport infrastructure is already stretched with limited bus services busy roads poorly maintained pavements and road surfaces Brox road is already used as a shortcut to avoid traffic congestion Given that Ottershaw does not have a train station it is reasonable to assume that the majority of houses would have at least one car the added traffic from the new development would put a severe strain on the road network and users Available information on mitigation is very vague and very open to interpretation and misguided assumptions

bull The Green Belt land is a habitat to an array of plants and animals including important pollinator species and larger animals such as birds foxes and deer There should be no assumption that animals will simply move to another area habitats are established over many years and this development will be another loss to the maintenance of biodiversity I enjoy the fauna and flora in these areas going for walks along the public footpaths Having such wonderful access to a relaxing escape so close to home is priceless and something I hold dear to myself my family and community What is now a beautiful scenic view will become a spoilt urban sprawl of modern housing

bull I moved to Ottershaw with my wife in 2016 to settle down and start a family The

relaxed quiet village sense of community and safety surrounded by beautiful countryside were its appeal I are very concerned and disappointed that this planning proposal is still being considered which will undoubtedly destroy this idyllic setting

There are no ldquoexceptional or very special circumstancesrdquo that justify the removal of Ottershaw East from the Green Belt We trust that the Council will therefore not remove ldquoOttershaw Eastrdquo and ldquoThe Fieldrdquo from the Green Belt Yours faithfully Dr Brian Pickett

FromTo Planning PolicySubject Runnymede Local Plan 2030 - consultation responseDate 21 February 2018 163608Attachments Runnymede LP Response - EE15pdf

Please find attached a consultation response form

________________________________________Christian Leigh BSc(Hons) MPhil MRTPIDirectorLeigh amp Glennie Ltd6 All Souls RoadAscotBerkshire SL5 9EA

1893

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number 01344 297094 Email Address (where relevant)

mailchristianleighcouk

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number Email Address (where relevant)

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

From MCNAB DouglasTo Planning PolicySubject Runnymede Draft Local Plan consultation - Representation from Education and Skills Funding AgencyDate 21 February 2018 091407Attachments Runnymede Reg 19 response ESFADOC

Dear Runnymede Planning Policy Team

Please see attached a representation from the Education and Skills Funding Agency on theRunnymede Local Plan consultation

I would be grateful if you could confirm receipt

Best regardsDoug

Douglas McNab MRTPIForward Planning Manager ndash South East

Planning Team Free Schools CapitalEducation and Skills Funding AgencyDepartment for Education 5th floor Sanctuary Buildings 20 Great Smith Street London SW1P 3BT

Email douglasmcnabeducationgovukMobile 07990 082877Web wwwgovukesfa

1895

image1pngOur Ref ESFALocal PlanRunnymede 2018 21st February 2018

Dear SirMadam

Re Runnymede Local Plan

Consultation under Regulation 19 of Town and Country Planning (Local Planning) (England) Regulations 2012

Submission of the Education and Skills Funding Agency

1 The Education and Skills Funding Agency (ESFA) welcomes the opportunity to contribute to the development of planning policy at the local level

2 The ESFA launched on 1st April 2017 bringing together the existing responsibilities of the Education Funding Agency (EFA) and the Skills Funding Agency (SFA) to create a single funding agency accountable for funding education and training for children young people and adults The ESFA are accountable for pound61 billion of funding a year for the education and training sector including support for all state-provided education for 8 million children aged 3 to 16 and 16 million young people aged 16 to 19

3 Under the provisions of the Education Act 2011 and the Academies Act 2010 all new state schools are now academiesfree schools and the ESFA is the delivery body for many of these rather than local education authorities As such we aim to work closely with local authority education departments and planning authorities to meet the demand for new school places and new schools We do this through a variety of means including by supporting the adoption of sound local plan policies site allocations and guidance (all based on robust evidence) that facilitate the delivery of education infrastructure where and when it is needed and maximise developer contributions for schools In this capacity we would like to offer the following comments in response to the proposals outlined in the above consultation document

Comments on the Local Plan

4 As you will be aware the primary focus at this stage of the Local Planrsquos preparation is on the soundness of the plan with regard to it being positively prepared justified effective and consistent with national policy The following detailed comments set out the ESFArsquos view of the planrsquos soundness in respect of education provision

5 The ESFA notes that the local plan will make provision for a minimum of 7413 net additional dwellings over the plan period Development will generally complement the existing settlement pattern focusing the largest amounts of residential growth primarily in Chertsey (1950 homes) Addlestone (936 homes) and Egham (812 homes) A new ldquolocally led garden villagerdquo is also proposed at Longcross providing a further 1718 homes This level of development will put pressure on existing education infrastructure

6 The plan recognises that ldquoIt is important that infrastructure is delivered in a timely manner to ensure that the needs of the occupiers of new development can be met without placing undue burdens on existing infrastructure facilities and servicesrdquo (para 560) The ESFA supports Policy SD6 Infrastructure Provision amp Timing particularly the signposting of the Infrastructure Delivery Plan (IDP) and the need for development to deliver this either on-site or through s106 or CIL financial contributions off-site and the need for development to be phased in line with the provision of important supporting infrastructure

7 The latest version of the IDP states that there is an ongoing programme of primary school expansions this will help to meet the forecast need for 4-6FE of new capacity over the plan period The need for one new build school project is identified a 2FE primary school at the Longcross Garden Village (estimated cost pound99M to pound15M) this is referred to in the site allocation policies (see below) With respect to secondary school places it is anticipated that up to six additional FE could be required in the Borough by 2021 Additional places will be delivered through the new 6FE Runnymede Free School (which opened in temporary accommodation in 2017) development of additional FE within Salesian School (Catholic faith school) and expansion of another school in the Chertsey area (to accommodate demand from generated by the Longcross Garden Village site)

8 It would be useful if the background data informing these projections of need could be clarified particularly the pupil yield factors used and the evidence base supporting this This would help to demonstrate more clearly to the Inspector that the approach to the planning and delivery of education infrastructure has been positively prepared based on a strategy which seeks to meet objectively assessed infrastructure requirements and is justified based on proportionate evidence The ESFA notes that the Runnymede S106 SPG sets out pupil yield figures however this document dates from December 2007 so the figures may be outdated

9 The ESFA supports the Councilrsquos allocation and safeguarding of land for schools as set out in the following policies

middot Policy SD10 Longcross Garden Village - 2FE primary school with preschoolearly years settings

middot Policy SL2 to SL18 ndash series of housing allocation policies that highlight the need to make a financial contribution to early years primary and secondary school infrastructure ldquoeither through S106 or CIL (or its successor)rdquo

Developer Contributions and CIL

10 One of the tests of soundness is that a Local Plan is lsquoeffectiversquo ie the plan should be deliverable over its period In this context and with specific regard to planning for schools there is a need to ensure that education contributions made by developers are sufficient to deliver the additional school places required to meet the increase in demand generated by new developments The ESFA notes that the council has not adopted CIL and that the Planning Obligations SPG sets out how developer contributions to education provision will be secured via section 106 agreements The ESFA supports the Councilrsquos approach to ensure developer contributions address the impacts arising from growth However the ESFA recommends that the Local Plan includes a commitment to revise the Planning Obligations SPG in line with the latest evidence of the boroughrsquos infrastructure needs pupil yields and build costs (including the cost of school expansion new build and SEN provision) Any such review should be prepared in consultation with the county council as local education authority This will help to ensure appropriate rates are levied and the right infrastructure is secured across the borough

11 The ESFA would be particularly interested in responding to any update to the Infrastructure Delivery Plan or review of infrastructure requirements As such please add the ESFA to the database for future CIL consultations

Forward funding

12 In light of the proposed Longcross Garden Village emerging ESFA proposals for forward funding schools as part of large residential developments may be relevant for example if viability becomes an issue The ESFA aims to be able to clarify forward funding options for schools in 2018 We would be happy to meet to discuss this opportunity further once the options have been finalised and ifwhen relevant Any offer of forward funding would seek to maximise developer contributions to education infrastructure provision while supporting delivery of schools where and when they are needed

Conclusion

13 Finally I hope the above comments are helpful in finalising the Runnymede Local Plan with specific regard to the provision of land for new schools

14 Please notify the ESFA when the Local Plan is submitted for examination the Inspectorrsquos report is published and the Local Plan is adopted

15 Please do not hesitate to contact me if you have any queries regarding this response The ESFA looks forward to continuing to work with Runnymede Borough Council to develop a sound Local Plan that will aid in the delivery of new schools

Yours faithfully

DC McNab

Douglas McNab MRTPI

Forward Planning Manager

Tel 07990 082877

Email

douglasmcnabeducationgovuk

Web

wwwgovuk esfa

Education and Skills Funding Agency13

Department for EducationSanctuary BuildingsGreat Smith StreetLondonSW1P 3BT13

13

Tel 0207 340 700013

13

wwwgovukesfa13

13

13

To

Policy Planning and Strategy Team

Runnymede Borough Council

Civic Centre

Station Road

Addlestone

Surrey

KT15 2AH

From

Dr Brian Pickett

139 Brox Road

Ottershaw

Surrey

KT16 0LG

Title

Mrs

First Name

Caroline

Last Name

Craven

Job Title

(where relevant)

Organisation

(where relevant)

Address Line 1

Southover

Line 2

Hurst Lane

Line 3

Egham

Line 4

Surrey

Post Code

TW20 8QJ

Telephone Number

07770999572

Email Address

(where relevant)

Carolinecraven911hotmailcom

Page 14: Runnymede Borough Council, for submissions. My contact details are all in the WORD letter attached. But I will provide my telephone number here too, which …

11

the largest number of homes and something like 7000 extra people in Runnymede Borough) the SANG needs to be onsite and the solution I propose in this paragraph would cater for this Hoping new residents will all get in their cars to take the dog or cat for a walk over one mile away on Trumps Farm is not sustainable practicable or likely AECOMrsquos HRA and AA of both May and December 2017 completely fail to address the roaming catrsquos issue Despite AECOMrsquos clearly different point-of-view I do not believe that Runnymede Borough Council in their role as lsquocompetent authorityrsquo can conclude that no adverse effect on the integrity of internationally important wildlife sites of the Thames Basin Heathrsquos SPA will result from their proposals in their Local Plan 2030 as a consequence of what I consider are flawed conclusions proposed by AECOM The only light at the end of the tunnel of flawed conclusions in my opinion by AECOM is their final paragraph in the Dec 2017 HRA and AA that at paragraph 93 ldquoHowever it is recommended that the potential for further bespoke or strategic SANG later in the plan period is explored by the Council in time for Examination in Publicrdquo

I suggest to the Planning Inspector and Runnymede Borough Council that an on-site large SANG at the west end of the DERA South site should be provided as greenspace which would help to alleviate the potential for disturbance by residents of the new garden village from having to go or preferring to go to Chobham Common with the dog because this SANG site would be nearer Housing development adjacent to heathland always damages it especially if local arsonists are imported nearby but my proposals would go a long way to making the proposed Local Plan sound Though it would be far better if this garden village was scrapped and the DERA South site restored to heathland or just converted to another employment site as that would do far less damage to the Chobham Common SSSI and SPA site

____________________

Stephen R Miles 21st February 2018

From Caroline CravenTo Planning PolicySubject Representation for Local PlanDate 22 February 2018 092519Attachments Representation_form_for_Regulation_19_Caroline_Cravendocx

Please find attached my representation form in response to the Runnymede 2030 Local PlanConsultation

Regards helliphellip Caroline Craven

1886

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full contact details of the agent in 2

Part B (1) ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

XParagraph PolicyPolicies Map

X

X

X

4 Do you consider the Local Plan is

x

4 (1) Legally compliant Yes No

X

4 (2) SoundYes No

x

4 (3) Complies with the Duty to co-operateYesNo

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the duty to co-operate please also use this box to set out your comments

I believe the Local Plan does not comply with the duty to co-operate with neighbouring Boroughs The previous version was not deemed to be compliant as I understand it and there does not appear to be any significant changes that allow this plan to be compliant

RBC seems to have relied on the former Statement of Community Involvement (SCI) of 2014 In a digital age 15 lines in a local (The Villager Feb 9th) on page 11 is a poor means of communication to the Runnymede Borough residents on something that will affect them so deeply

In addition the views expressed at the RBC meeting by the attending RBC councillors were essentially that they accepted it wasnrsquot as good as it should be but was lsquothe best wersquore going to get at the momentrsquo and if not submitted then a Government Inspector would be appointed and they would lose control ndash a view I can fully understand but does not give the Runnymede residents a feeling of confidence in the legality or the integrity of the plan nor that the council truly want the best for the Borough

With regard to the Longcross site improvements to the station do not address the capacity issue The impact to commuters further up the line will be significant Peak times will be heavily impacted If additional trains are being proposed on this line the impact to the residents of Egham who already have to wait some 35-40 minutes in the hour whilst gates are down would therefore have even less opportunity to transverse the line at the crossing points Longcross station has no accessible car parking or drop off points This would necessitate commuters travelling to Virginia Water Egham whose own parking capability is limited Virginia Water has lost a large number of station car park spaces due to a new development This would also cause increased congestion in already known problem junctions The additional burden to the A320 which is already operating over practical capacity at several junctions and expected to deteriorate over the coming years would be significant (A320 Corridor Study ndash Feasibility Study ndash Interim report February 2018)

(Continue on a separate sheetexpand box if necessary)

The Longcross site will also need medical facilities ndash GPrsquos and potentially NHS drop in centre to ensure the current burden on the NHS is not exacerbated

With regard to the Traveller pitches they appear to amount to 35 within the scope of the development areas However the council plan to deliver 131 net additional plotspitches ndash 96 of which are not covered in this local plan This is an extremely emotive subject and needs to be identified properly in the plan and not almost hidden to avoid confrontation with angry residents that this County is already over run with these communities Integration with new developments is not the answer ndash Allocation of Traveller sites and pitches is according to the Government guidelines ldquoinappropriate within the Green beltrdquo and trying to slide this surreptitiously into new developments is a totally inappropriate solution

The Hurst Lane development was dismissed by the Council despite the residents being on board and a sustainable and acceptable plan being put forward for c 800-1000 homes on 80 -100 acres Over time this Lane has deteriorated to the point that Planning Inspectors described it as an lsquoindustrial wastelandrsquo In addition the Council resources are being tied up with the numerous issues generated by the Lane and the inability to resolve with the resources available The primary reason given is that the land is lsquoGreen Beltrsquo although under exceptional circumstances (which I believe this would come under) the council are able to and plan to in other areas use this land It is effectively a brownfield site which could be permitted fi connected to a SANG trade off which the residents plan was

6 Please set out what modification (s) you consider necessary to make the Local Plan legally compliant or sound having regard to the Matter you have identified at 5 above where this relates to soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of modification at examination) You will need to say why this modification will make the Local Plan legally compliant or sound It will be helpful if you are able to put forward your suggested revised wording of any policy or text Please be as precise as possible

For the plan to be sound I believe that

1) Review the inclusion of the Hurst Lane site ndash SLAA 59 ndash within the plan Appendix B states the capacity of 10 for Hurst Lane and 5 for Padd Farm If this relates to additional properties the number does not reflect the plans of up to 800 houses Access and infrastructure are addressed and the reduction in headcount in the councilrsquos Customer Services (I believe there is a dedicated resource looking after Padd Farm Hurst Lane) would be an additional benefit

2) Greater publicity is required over the consultation process The council appear to work on a lsquopullrsquo basis in that residents of the borough (other than those in the Residents Associations) have to actively seek out any updates from the council Local newspapers are not a good way of disseminating information in the digital age

3) Identify the additional travellergypsy site plans and move outside of the Green Belt area

If these steps were taken the residents would all have ample opportunity to contribute to the development of the local plan

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further representations based on the original representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

7 If your representation is seeking a modification do you consider it necessary to participate at the oral part of the examination

No I do not wish to participate Yes I wish to participate

X

at the oral examinationat the oral examination

8 If you wish to participate at the oral part of the examination please outline why you consider this to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who have indicated that they wish to participate at the oral part of the examination

9 Signature Date

21st February 2018

Caroline Craven

Notes to Accompany Model Representation Form

1 Introduction

11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 2004[footnoteRef1] (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound [1 View at httpwwwlegislationgovukukpga20045contents ]

2 Legal Compliance and Duty to Co-operate

21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness

22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)[footnoteRef2] it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices [2 LDDs are defined in regulation 5 ndash see link below ]

bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications

bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)[footnoteRef3] On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified [3 View at httpwwwlegislationgovukuksi2012767contentsmade ]

bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy)

23 You should consider the following before making a representation on compliance with the duty to co-operate

bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty

bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

3 Soundness

31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy

bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development

bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence

bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities

bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF

32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations

bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included

bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan

bull If the policy is not covered elsewhere in what way is the plan unsound without the policy

bull If the plan is unsound without the policy what should the policy say

4 General advice

41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

6

image1png

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full contact details of the agent in 2

Title Mrs First Name Caroline Last Name Craven Job Title (where relevant)

Organisation (where relevant)

Address Line 1 Southover Line 2 Hurst Lane Line 3 Egham Line 4 Surrey Post Code TW20 8QJ Telephone Number Email Address (where relevant)

2

Part B (1) ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

XParagraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails to comply with the duty to co-operate Please be as precise as possible If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

X X X

x

X

x

I believe the Local Plan does not comply with the duty to co-operate with neighbouring Boroughs The previous version was not deemed to be compliant as I understand it and there does not appear to be any significant changes that allow this plan to be compliant

RBC seems to have relied on the former Statement of Community Involvement (SCI) of 2014 In a digital age 15 lines in a local (The Villager Feb 9th) on page 11 is a poor means of communication to the Runnymede Borough residents on something that will affect them so deeply

In addition the views expressed at the RBC meeting by the attending RBC councillors were essentially that they accepted it wasnrsquot as good as it should be but was lsquothe best wersquore going to get at the momentrsquo and if not submitted then a Government Inspector would be appointed and they would lose control ndash a view I can fully understand but does not give the Runnymede residents a feeling of confidence in the legality or the integrity of the plan nor that the council truly want the best for the Borough

With regard to the Longcross site improvements to the station do not address the capacity issue The impact to commuters further up the line will be significant Peak times will be heavily impacted If additional trains are being proposed on this line the impact to the residents of Egham who already have to wait some 35-40 minutes in the hour whilst gates are down would therefore have even less opportunity to transverse the line at the crossing points Longcross station has no accessible car parking or drop off points This would necessitate commuters travelling to Virginia Water Egham whose own parking capability is limited Virginia Water has lost a large number of station car park spaces due to a new development This would also cause increased congestion in already known problem junctions The additional burden to the A320 which is already operating over practical capacity at several junctions and expected to deteriorate over the coming years would be significant (A320 Corridor Study ndash Feasibility Study ndash Interim report February 2018)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally compliant or sound having regard to the Matter you have identified at 5 above where this relates to soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of modification at examination) You will need to say why this modification will make the Local Plan legally compliant or sound It will be helpful if you are able to put forward your suggested revised wording of any policy or text Please be as precise as possible

For the plan to be sound I believe that

1) Review the inclusion of the Hurst Lane site ndash SLAA 59 ndash within the plan Appendix B states the capacity of 10 for Hurst Lane and 5 for Padd Farm If this relates to additional properties the number does not reflect the plans of up to 800 houses Access and infrastructure are addressed and the reduction in headcount in the councilrsquos Customer Services (I believe there is a dedicated resource looking after Padd Farm Hurst Lane) would be an additional benefit

2) Greater publicity is required over the consultation process The council appear to work on a lsquopullrsquo basis in that residents of the borough (other than those in the Residents Associations) have to actively seek out any updates from the council Local newspapers are not a good way of disseminating information in the digital age

3) Identify the additional travellergypsy site plans and move outside of the Green Belt area

If these steps were taken the residents would all have ample opportunity to contribute to the development of the local plan

The Longcross site will also need medical facilities ndash GPrsquos and potentially NHS drop in centre to ensure the current burden on the NHS is not exacerbated

With regard to the Traveller pitches they appear to amount to 35 within the scope of the development areas However the council plan to deliver 131 net additional plotspitches ndash 96 of which are not covered in this local plan This is an extremely emotive subject and needs to be identified properly in the plan and not almost hidden to avoid confrontation with angry residents that this County is already over run with these communities Integration with new developments is not the answer ndash Allocation of Traveller sites and pitches is according to the Government guidelines ldquoinappropriate within the Green beltrdquo and trying to slide this surreptitiously into new developments is a totally inappropriate solution

The Hurst Lane development was dismissed by the Council despite the residents being on board and a sustainable and acceptable plan being put forward for c 800-1000 homes on 80 -100 acres Over time this Lane has deteriorated to the point that Planning Inspectors described it as an lsquoindustrial wastelandrsquo In addition the Council resources are being tied up with the numerous issues generated by the Lane and the inability to resolve with the resources available The primary reason given is that the land is lsquoGreen Beltrsquo although under exceptional circumstances (which I believe this would come under) the council are able to and plan to in other areas use this land It is effectively a brownfield site which could be permitted fi connected to a SANG trade off which the residents plan was

4

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further representations based on the original representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

7 If your representation is seeking a modification do you consider it necessary to participate at the oral part of the examination

No I do not wish to participate Yes I wish to participate at the oral examination at the oral examination

8 If you wish to participate at the oral part of the examination please outline why you consider this to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who have indicated that they wish to participate at the oral part of the examination

9 Signature Date

X

Caroline Craven 21st February 2018

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan 1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination 42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

FromPolicy

Subject FW New Housing Plans 2015-2030Date 21 February 2018 164919

Sent 21 February 2018 1608To PlanningSubject New Housing Plans 2015-2030

To

Policy Planning and Strategy Team

Runnymede Borough Council

Station Road

Addlestone

21022018

Dear Sirs

As an Ottershaw resident of nearly 30 years i would like you to read and take on board my objections to yourproposal to take land out of the green belt for housing and your plan to build so many houses in ourcommunity

Of course new houses have to be built right across the country now and in the future but i feel the plans youhave are for far too many houses The infrastructure of our community will just not sustain the extra amount ofpeople and cars and the general traffic that would entail

There are other possibilities available before your irreversible plans are put into action Are these possibilitiesbeing resourced

When i drive around the borough now and for a long long time i see so many empty office blocks Some ofthese have stood empty for yearsWhy has permission been given continuosly from what i can see on a huge scale for these to be built

This building of offices has to stop and the ones that have remained empty for years could be converted tohousing as in flats starter homes for young people

If Planning Practice Guidlines state that the use of Green Beltshould only occur in very special circumstances these and the Brownfield sites in Runnymede must be extensively researched

I live in Wilson Drive and for many years now when i leave my house to go into the village or elsewhere thereis often gridlock in every direction The roads in our community are so heavily used by cars and lorries headingtoward the M25 Can you imagine the impact so many more of these will bring Driving has not been a pleasurefor a long time and i do walk wherever possible Parking is a problem in the village as so many people use theone car park I believe there may be a plan in the pipeline to even get rid of that for road widening

We have a GP practice in the village that is getting harder to book an appointment for also i have been waitingmonths for an appointment at St Peters hospital and just keep getting apologetic letters

Quality of life is very important for your residents and that quality has already deteriorated lately

1888

In order to accomodate so many new residents you will be making the ones you have feel very disappointedand frustated that no one listens

There is no going back once the desicion has been made and so many houses built Please take my feelings and iam sure very many more residents comments and pleas into account before you make the irreversible decisionto go ahead with your plans

Yours Faithfully

Margaret Wensley and the Wensley family

Beechwood

Wilson Drive

Ottershaw

Surrey

KT16 0NT

----------- middotn==middot =

Planning Services

DELIVERED BY HAND

Runnymede Borough Council ~--------------=-middot ---------middot------~

Planning Dept Runnymede Borough Council Civic Offices Station Road Addlestone KT15 2AH

Dear Sirs

Catherine Brunton-Green 20The Glen Addlestone

KT151AQ

15th February 2018

Runnymede Draft local Plan 2015- 2030- Final Consultation

I have serious concerns in respect of this draft plan Runnymede Borough Council (RBC) have a duty of care to consult with listen and act upon the wishes of its residents There has been some consultation but this has not effectively reached all Runnymede residents Communication is unnecessarily legally complex and full of unexplained acronyms The basic Runnymede Voice delivered to every home has been abandoned There has been no flyer delivered to every home stating in a simplified way what is happening so that all abilities may be catered for Many people are isolated for numerous reasons and do not have internet access Neither is there evidence of full in depth cross boundary consultation with adjacent boroughs This local plan is driven primarily by a developers charter promoted by RBCS Head of Planning It is both unfair unjust and I question its soundness

The Strategic Housing Market Assessment has not taken leaving the EU into account and makes a blanket assumption on Heathrow expansion

I strongly object to the proposed loss of c 560 acres of Green Belt Our Prime Minister and government have recently stated that they are quote committed to protecting and enhancing our natural environment for successive generations therefore Green Belt land would only be lost as a last resort 11

bull Detailed evidence based research by The Council for The Protection of Rural England confirms that by fully utilising brownfield land 12 million homes could be built in London and the South East without the loss of any Green Belt

I have objection to building on the Veterinary Laboratory Green Belt Land Parcel BRow Town (Policy SL11 8283) is not justified for development This is designated for 150 additional dwellings and 2 gypsyTraveller pitches This site provides a natural demarcation between developments either side Designated SANG area is privately owned and not available The density of proposed build is unacceptable and above all an area of outstanding natural beauty would be destroyed

Our infrastructure is unable to cope at present A320 suffers perpetual gridlock now Equally gridlock is evidenced through Ottershaw Addlestone Station Road and A317 Addlestone Weybridge We already have unhealthily dangerous levels of roadside nitrogen dioxide concentrations in many areas such as Station Road RBC has made a lame submission in respect of

tackling roadside nitrogen dioxide concentrations in the South East (UK00310) Incidence of exacerbated breathing illnesses in this vicinity has increased dramatically in the past 7 years All age groups are affected

All GP surgeries across Runnymede have great difficulty in recruiting doctors Two practices in the immediate area are merging due to unprecedented numbers of doctors leaving and retiring Practice lists and capacity is stretched Patient access to services and patient safety has to be the highest priority Our schools are similarly affected

RBC infrastructure is totally reliant upon Surrey County Council who declare they are not in a financial position to fund the necessary support to develop the infrastructure for this Local Plan

I am prepared to speak at Public Enquiry

Yours faithfully

bull i I I bull bull

From Brian PickettTo Planning PolicySubject Runnymede 2030 Local Plan - submission of viewsDate 22 February 2018 090921Attachments Ottershaw development Objection letter February 2018docx

Please find attached the submission of my views on the Runnymede 2030 LocalPlan

Kind RegardsBrian Pickett

1891

planningrunnymedegovuk planningrunnymedegovuk

21022018

Re Runnymede 2030 Local Plan Ottershaw East ndash Objection to planning

Dear Sirs

We are writing to you again as we strongly object to the Runnymede Borough Councils plans to remove land behind houses along Brox Road known as lsquoOttershaw Eastrsquo from the Green Belt We are objecting for a number of reasons listed below

middot The Green Belt is precious once it is gone it is gone forever The removal of this land from the Green Belt does not comply with Planning Policy which states ldquothat Green Belt boundaries should only be altered in exceptional circumstancesrdquo there are no such circumstances that can justify the removal of this piece of land

middot The Green Belt should be an area that is preserved for future generations to enjoy and appreciate and many statements have been made by both the Government and members of Parliament on their commitment to protect the Green Belt ndash these statements now need to be converted into action in the Local Borough Plans The roll out of Green Belt to local councils in the 1950rsquos was to prevent urban sprawl and the merging of settlements thereby helping to preserve and protect the character of communities it encompassed protect the country setting and encourage development through regeneration of sites within towns and cities not villages

middot The description of Ottershaw by the council itself in the lsquoUrban Characteristicsrsquo publication on the Runnymede Borough Council website states ldquoOttershaw has its own identity and sense of place which is partly derived from the clearly identifiable heart of the urban area focused on The Otter and adjoining local shopping parade and community facilities as well as being surrounded by open greenbelt countryside Removing this green belt that is part of the identifiable heart of Ottershaw would destroy this villagersquos identity and community

middot The planning proposals and building on this part of the green belt land would lead to a considerable population increase in the village Services and facilities will struggle or fail to cope space is already limited at the doctorrsquos surgery and school places are at capacity The transport infrastructure is already stretched with limited bus services busy roads poorly maintained pavements and road surfaces Brox road is already used as a shortcut to avoid traffic congestion Given that Ottershaw does not have a train station it is reasonable to assume that the majority of houses would have at least one car the added traffic from the new development would put a severe strain on the road network and users Available information on mitigation is very vague and very open to interpretation and misguided assumptions

middot The Green Belt land is a habitat to an array of plants and animals including important pollinator species and larger animals such as birds foxes and deer There should be no assumption that animals will simply move to another area habitats are established over many years and this development will be another loss to the maintenance of biodiversity I enjoy the fauna and flora in these areas going for walks along the public footpaths Having such wonderful access to a relaxing escape so close to home is priceless and something I hold dear to myself my family and community What is now a beautiful scenic view will become a spoilt urban sprawl of modern housing

middot I moved to Ottershaw with my wife in 2016 to settle down and start a family The relaxed quiet village sense of community and safety surrounded by beautiful countryside were its appeal I are very concerned and disappointed that this planning proposal is still being considered which will undoubtedly destroy this idyllic setting

There are no ldquoexceptional or very special circumstancesrdquo that justify the removal of Ottershaw East from the Green Belt We trust that the Council will therefore not remove ldquoOttershaw Eastrdquo and ldquoThe Fieldrdquo from the Green Belt

Yours faithfully

Dr Brian Pickett

To Policy Planning and Strategy Team Runnymede Borough Council Civic Centre Station Road Addlestone Surrey KT15 2AH planningrunnymedegovuk

From Dr Brian Pickett 139 Brox Road Ottershaw Surrey KT16 0LG planningrunnymedegovuk

21022018 Re Runnymede 2030 Local Plan Ottershaw East ndash Objection to planning Dear Sirs We are writing to you again as we strongly object to the Runnymede Borough Councils plans to remove land behind houses along Brox Road known as lsquoOttershaw Eastrsquo from the Green Belt We are objecting for a number of reasons listed below bull The Green Belt is precious once it is gone it is gone forever The removal of this

land from the Green Belt does not comply with Planning Policy which states ldquothat Green Belt boundaries should only be altered in exceptional circumstancesrdquo there are no such circumstances that can justify the removal of this piece of land

bull The Green Belt should be an area that is preserved for future generations to enjoy

and appreciate and many statements have been made by both the Government and members of Parliament on their commitment to protect the Green Belt ndash these statements now need to be converted into action in the Local Borough Plans The roll out of Green Belt to local councils in the 1950rsquos was to prevent urban sprawl and the merging of settlements thereby helping to preserve and protect the character of communities it encompassed protect the country setting and encourage development through regeneration of sites within towns and cities not villages

bull The description of Ottershaw by the council itself in the lsquoUrban Characteristicsrsquo

publication on the Runnymede Borough Council website states ldquoOttershaw has its own identity and sense of place which is partly derived from the clearly identifiable heart of the urban area focused on The Otter and adjoining local shopping parade and community facilities as well as being surrounded by open greenbelt countryside Removing this green belt that is part of the identifiable heart of Ottershaw would destroy this villagersquos identity and community

bull The planning proposals and building on this part of the green belt land would lead

to a considerable population increase in the village Services and facilities will struggle or fail to cope space is already limited at the doctorrsquos surgery and school places are at capacity The transport infrastructure is already stretched with limited bus services busy roads poorly maintained pavements and road surfaces Brox road is already used as a shortcut to avoid traffic congestion Given that Ottershaw does not have a train station it is reasonable to assume that the majority of houses would have at least one car the added traffic from the new development would put a severe strain on the road network and users Available information on mitigation is very vague and very open to interpretation and misguided assumptions

bull The Green Belt land is a habitat to an array of plants and animals including important pollinator species and larger animals such as birds foxes and deer There should be no assumption that animals will simply move to another area habitats are established over many years and this development will be another loss to the maintenance of biodiversity I enjoy the fauna and flora in these areas going for walks along the public footpaths Having such wonderful access to a relaxing escape so close to home is priceless and something I hold dear to myself my family and community What is now a beautiful scenic view will become a spoilt urban sprawl of modern housing

bull I moved to Ottershaw with my wife in 2016 to settle down and start a family The

relaxed quiet village sense of community and safety surrounded by beautiful countryside were its appeal I are very concerned and disappointed that this planning proposal is still being considered which will undoubtedly destroy this idyllic setting

There are no ldquoexceptional or very special circumstancesrdquo that justify the removal of Ottershaw East from the Green Belt We trust that the Council will therefore not remove ldquoOttershaw Eastrdquo and ldquoThe Fieldrdquo from the Green Belt Yours faithfully Dr Brian Pickett

FromTo Planning PolicySubject Runnymede Local Plan 2030 - consultation responseDate 21 February 2018 163608Attachments Runnymede LP Response - EE15pdf

Please find attached a consultation response form

________________________________________Christian Leigh BSc(Hons) MPhil MRTPIDirectorLeigh amp Glennie Ltd6 All Souls RoadAscotBerkshire SL5 9EA

1893

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number 01344 297094 Email Address (where relevant)

mailchristianleighcouk

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number Email Address (where relevant)

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

From MCNAB DouglasTo Planning PolicySubject Runnymede Draft Local Plan consultation - Representation from Education and Skills Funding AgencyDate 21 February 2018 091407Attachments Runnymede Reg 19 response ESFADOC

Dear Runnymede Planning Policy Team

Please see attached a representation from the Education and Skills Funding Agency on theRunnymede Local Plan consultation

I would be grateful if you could confirm receipt

Best regardsDoug

Douglas McNab MRTPIForward Planning Manager ndash South East

Planning Team Free Schools CapitalEducation and Skills Funding AgencyDepartment for Education 5th floor Sanctuary Buildings 20 Great Smith Street London SW1P 3BT

Email douglasmcnabeducationgovukMobile 07990 082877Web wwwgovukesfa

1895

image1pngOur Ref ESFALocal PlanRunnymede 2018 21st February 2018

Dear SirMadam

Re Runnymede Local Plan

Consultation under Regulation 19 of Town and Country Planning (Local Planning) (England) Regulations 2012

Submission of the Education and Skills Funding Agency

1 The Education and Skills Funding Agency (ESFA) welcomes the opportunity to contribute to the development of planning policy at the local level

2 The ESFA launched on 1st April 2017 bringing together the existing responsibilities of the Education Funding Agency (EFA) and the Skills Funding Agency (SFA) to create a single funding agency accountable for funding education and training for children young people and adults The ESFA are accountable for pound61 billion of funding a year for the education and training sector including support for all state-provided education for 8 million children aged 3 to 16 and 16 million young people aged 16 to 19

3 Under the provisions of the Education Act 2011 and the Academies Act 2010 all new state schools are now academiesfree schools and the ESFA is the delivery body for many of these rather than local education authorities As such we aim to work closely with local authority education departments and planning authorities to meet the demand for new school places and new schools We do this through a variety of means including by supporting the adoption of sound local plan policies site allocations and guidance (all based on robust evidence) that facilitate the delivery of education infrastructure where and when it is needed and maximise developer contributions for schools In this capacity we would like to offer the following comments in response to the proposals outlined in the above consultation document

Comments on the Local Plan

4 As you will be aware the primary focus at this stage of the Local Planrsquos preparation is on the soundness of the plan with regard to it being positively prepared justified effective and consistent with national policy The following detailed comments set out the ESFArsquos view of the planrsquos soundness in respect of education provision

5 The ESFA notes that the local plan will make provision for a minimum of 7413 net additional dwellings over the plan period Development will generally complement the existing settlement pattern focusing the largest amounts of residential growth primarily in Chertsey (1950 homes) Addlestone (936 homes) and Egham (812 homes) A new ldquolocally led garden villagerdquo is also proposed at Longcross providing a further 1718 homes This level of development will put pressure on existing education infrastructure

6 The plan recognises that ldquoIt is important that infrastructure is delivered in a timely manner to ensure that the needs of the occupiers of new development can be met without placing undue burdens on existing infrastructure facilities and servicesrdquo (para 560) The ESFA supports Policy SD6 Infrastructure Provision amp Timing particularly the signposting of the Infrastructure Delivery Plan (IDP) and the need for development to deliver this either on-site or through s106 or CIL financial contributions off-site and the need for development to be phased in line with the provision of important supporting infrastructure

7 The latest version of the IDP states that there is an ongoing programme of primary school expansions this will help to meet the forecast need for 4-6FE of new capacity over the plan period The need for one new build school project is identified a 2FE primary school at the Longcross Garden Village (estimated cost pound99M to pound15M) this is referred to in the site allocation policies (see below) With respect to secondary school places it is anticipated that up to six additional FE could be required in the Borough by 2021 Additional places will be delivered through the new 6FE Runnymede Free School (which opened in temporary accommodation in 2017) development of additional FE within Salesian School (Catholic faith school) and expansion of another school in the Chertsey area (to accommodate demand from generated by the Longcross Garden Village site)

8 It would be useful if the background data informing these projections of need could be clarified particularly the pupil yield factors used and the evidence base supporting this This would help to demonstrate more clearly to the Inspector that the approach to the planning and delivery of education infrastructure has been positively prepared based on a strategy which seeks to meet objectively assessed infrastructure requirements and is justified based on proportionate evidence The ESFA notes that the Runnymede S106 SPG sets out pupil yield figures however this document dates from December 2007 so the figures may be outdated

9 The ESFA supports the Councilrsquos allocation and safeguarding of land for schools as set out in the following policies

middot Policy SD10 Longcross Garden Village - 2FE primary school with preschoolearly years settings

middot Policy SL2 to SL18 ndash series of housing allocation policies that highlight the need to make a financial contribution to early years primary and secondary school infrastructure ldquoeither through S106 or CIL (or its successor)rdquo

Developer Contributions and CIL

10 One of the tests of soundness is that a Local Plan is lsquoeffectiversquo ie the plan should be deliverable over its period In this context and with specific regard to planning for schools there is a need to ensure that education contributions made by developers are sufficient to deliver the additional school places required to meet the increase in demand generated by new developments The ESFA notes that the council has not adopted CIL and that the Planning Obligations SPG sets out how developer contributions to education provision will be secured via section 106 agreements The ESFA supports the Councilrsquos approach to ensure developer contributions address the impacts arising from growth However the ESFA recommends that the Local Plan includes a commitment to revise the Planning Obligations SPG in line with the latest evidence of the boroughrsquos infrastructure needs pupil yields and build costs (including the cost of school expansion new build and SEN provision) Any such review should be prepared in consultation with the county council as local education authority This will help to ensure appropriate rates are levied and the right infrastructure is secured across the borough

11 The ESFA would be particularly interested in responding to any update to the Infrastructure Delivery Plan or review of infrastructure requirements As such please add the ESFA to the database for future CIL consultations

Forward funding

12 In light of the proposed Longcross Garden Village emerging ESFA proposals for forward funding schools as part of large residential developments may be relevant for example if viability becomes an issue The ESFA aims to be able to clarify forward funding options for schools in 2018 We would be happy to meet to discuss this opportunity further once the options have been finalised and ifwhen relevant Any offer of forward funding would seek to maximise developer contributions to education infrastructure provision while supporting delivery of schools where and when they are needed

Conclusion

13 Finally I hope the above comments are helpful in finalising the Runnymede Local Plan with specific regard to the provision of land for new schools

14 Please notify the ESFA when the Local Plan is submitted for examination the Inspectorrsquos report is published and the Local Plan is adopted

15 Please do not hesitate to contact me if you have any queries regarding this response The ESFA looks forward to continuing to work with Runnymede Borough Council to develop a sound Local Plan that will aid in the delivery of new schools

Yours faithfully

DC McNab

Douglas McNab MRTPI

Forward Planning Manager

Tel 07990 082877

Email

douglasmcnabeducationgovuk

Web

wwwgovuk esfa

Education and Skills Funding Agency13

Department for EducationSanctuary BuildingsGreat Smith StreetLondonSW1P 3BT13

13

Tel 0207 340 700013

13

wwwgovukesfa13

13

13

To

Policy Planning and Strategy Team

Runnymede Borough Council

Civic Centre

Station Road

Addlestone

Surrey

KT15 2AH

From

Dr Brian Pickett

139 Brox Road

Ottershaw

Surrey

KT16 0LG

Title

Mrs

First Name

Caroline

Last Name

Craven

Job Title

(where relevant)

Organisation

(where relevant)

Address Line 1

Southover

Line 2

Hurst Lane

Line 3

Egham

Line 4

Surrey

Post Code

TW20 8QJ

Telephone Number

07770999572

Email Address

(where relevant)

Carolinecraven911hotmailcom

Page 15: Runnymede Borough Council, for submissions. My contact details are all in the WORD letter attached. But I will provide my telephone number here too, which …

From Caroline CravenTo Planning PolicySubject Representation for Local PlanDate 22 February 2018 092519Attachments Representation_form_for_Regulation_19_Caroline_Cravendocx

Please find attached my representation form in response to the Runnymede 2030 Local PlanConsultation

Regards helliphellip Caroline Craven

1886

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full contact details of the agent in 2

Part B (1) ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

XParagraph PolicyPolicies Map

X

X

X

4 Do you consider the Local Plan is

x

4 (1) Legally compliant Yes No

X

4 (2) SoundYes No

x

4 (3) Complies with the Duty to co-operateYesNo

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the duty to co-operate please also use this box to set out your comments

I believe the Local Plan does not comply with the duty to co-operate with neighbouring Boroughs The previous version was not deemed to be compliant as I understand it and there does not appear to be any significant changes that allow this plan to be compliant

RBC seems to have relied on the former Statement of Community Involvement (SCI) of 2014 In a digital age 15 lines in a local (The Villager Feb 9th) on page 11 is a poor means of communication to the Runnymede Borough residents on something that will affect them so deeply

In addition the views expressed at the RBC meeting by the attending RBC councillors were essentially that they accepted it wasnrsquot as good as it should be but was lsquothe best wersquore going to get at the momentrsquo and if not submitted then a Government Inspector would be appointed and they would lose control ndash a view I can fully understand but does not give the Runnymede residents a feeling of confidence in the legality or the integrity of the plan nor that the council truly want the best for the Borough

With regard to the Longcross site improvements to the station do not address the capacity issue The impact to commuters further up the line will be significant Peak times will be heavily impacted If additional trains are being proposed on this line the impact to the residents of Egham who already have to wait some 35-40 minutes in the hour whilst gates are down would therefore have even less opportunity to transverse the line at the crossing points Longcross station has no accessible car parking or drop off points This would necessitate commuters travelling to Virginia Water Egham whose own parking capability is limited Virginia Water has lost a large number of station car park spaces due to a new development This would also cause increased congestion in already known problem junctions The additional burden to the A320 which is already operating over practical capacity at several junctions and expected to deteriorate over the coming years would be significant (A320 Corridor Study ndash Feasibility Study ndash Interim report February 2018)

(Continue on a separate sheetexpand box if necessary)

The Longcross site will also need medical facilities ndash GPrsquos and potentially NHS drop in centre to ensure the current burden on the NHS is not exacerbated

With regard to the Traveller pitches they appear to amount to 35 within the scope of the development areas However the council plan to deliver 131 net additional plotspitches ndash 96 of which are not covered in this local plan This is an extremely emotive subject and needs to be identified properly in the plan and not almost hidden to avoid confrontation with angry residents that this County is already over run with these communities Integration with new developments is not the answer ndash Allocation of Traveller sites and pitches is according to the Government guidelines ldquoinappropriate within the Green beltrdquo and trying to slide this surreptitiously into new developments is a totally inappropriate solution

The Hurst Lane development was dismissed by the Council despite the residents being on board and a sustainable and acceptable plan being put forward for c 800-1000 homes on 80 -100 acres Over time this Lane has deteriorated to the point that Planning Inspectors described it as an lsquoindustrial wastelandrsquo In addition the Council resources are being tied up with the numerous issues generated by the Lane and the inability to resolve with the resources available The primary reason given is that the land is lsquoGreen Beltrsquo although under exceptional circumstances (which I believe this would come under) the council are able to and plan to in other areas use this land It is effectively a brownfield site which could be permitted fi connected to a SANG trade off which the residents plan was

6 Please set out what modification (s) you consider necessary to make the Local Plan legally compliant or sound having regard to the Matter you have identified at 5 above where this relates to soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of modification at examination) You will need to say why this modification will make the Local Plan legally compliant or sound It will be helpful if you are able to put forward your suggested revised wording of any policy or text Please be as precise as possible

For the plan to be sound I believe that

1) Review the inclusion of the Hurst Lane site ndash SLAA 59 ndash within the plan Appendix B states the capacity of 10 for Hurst Lane and 5 for Padd Farm If this relates to additional properties the number does not reflect the plans of up to 800 houses Access and infrastructure are addressed and the reduction in headcount in the councilrsquos Customer Services (I believe there is a dedicated resource looking after Padd Farm Hurst Lane) would be an additional benefit

2) Greater publicity is required over the consultation process The council appear to work on a lsquopullrsquo basis in that residents of the borough (other than those in the Residents Associations) have to actively seek out any updates from the council Local newspapers are not a good way of disseminating information in the digital age

3) Identify the additional travellergypsy site plans and move outside of the Green Belt area

If these steps were taken the residents would all have ample opportunity to contribute to the development of the local plan

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further representations based on the original representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

7 If your representation is seeking a modification do you consider it necessary to participate at the oral part of the examination

No I do not wish to participate Yes I wish to participate

X

at the oral examinationat the oral examination

8 If you wish to participate at the oral part of the examination please outline why you consider this to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who have indicated that they wish to participate at the oral part of the examination

9 Signature Date

21st February 2018

Caroline Craven

Notes to Accompany Model Representation Form

1 Introduction

11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 2004[footnoteRef1] (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound [1 View at httpwwwlegislationgovukukpga20045contents ]

2 Legal Compliance and Duty to Co-operate

21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness

22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)[footnoteRef2] it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices [2 LDDs are defined in regulation 5 ndash see link below ]

bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications

bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)[footnoteRef3] On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified [3 View at httpwwwlegislationgovukuksi2012767contentsmade ]

bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy)

23 You should consider the following before making a representation on compliance with the duty to co-operate

bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty

bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

3 Soundness

31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy

bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development

bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence

bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities

bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF

32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations

bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included

bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan

bull If the policy is not covered elsewhere in what way is the plan unsound without the policy

bull If the plan is unsound without the policy what should the policy say

4 General advice

41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

6

image1png

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full contact details of the agent in 2

Title Mrs First Name Caroline Last Name Craven Job Title (where relevant)

Organisation (where relevant)

Address Line 1 Southover Line 2 Hurst Lane Line 3 Egham Line 4 Surrey Post Code TW20 8QJ Telephone Number Email Address (where relevant)

2

Part B (1) ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

XParagraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails to comply with the duty to co-operate Please be as precise as possible If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

X X X

x

X

x

I believe the Local Plan does not comply with the duty to co-operate with neighbouring Boroughs The previous version was not deemed to be compliant as I understand it and there does not appear to be any significant changes that allow this plan to be compliant

RBC seems to have relied on the former Statement of Community Involvement (SCI) of 2014 In a digital age 15 lines in a local (The Villager Feb 9th) on page 11 is a poor means of communication to the Runnymede Borough residents on something that will affect them so deeply

In addition the views expressed at the RBC meeting by the attending RBC councillors were essentially that they accepted it wasnrsquot as good as it should be but was lsquothe best wersquore going to get at the momentrsquo and if not submitted then a Government Inspector would be appointed and they would lose control ndash a view I can fully understand but does not give the Runnymede residents a feeling of confidence in the legality or the integrity of the plan nor that the council truly want the best for the Borough

With regard to the Longcross site improvements to the station do not address the capacity issue The impact to commuters further up the line will be significant Peak times will be heavily impacted If additional trains are being proposed on this line the impact to the residents of Egham who already have to wait some 35-40 minutes in the hour whilst gates are down would therefore have even less opportunity to transverse the line at the crossing points Longcross station has no accessible car parking or drop off points This would necessitate commuters travelling to Virginia Water Egham whose own parking capability is limited Virginia Water has lost a large number of station car park spaces due to a new development This would also cause increased congestion in already known problem junctions The additional burden to the A320 which is already operating over practical capacity at several junctions and expected to deteriorate over the coming years would be significant (A320 Corridor Study ndash Feasibility Study ndash Interim report February 2018)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally compliant or sound having regard to the Matter you have identified at 5 above where this relates to soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of modification at examination) You will need to say why this modification will make the Local Plan legally compliant or sound It will be helpful if you are able to put forward your suggested revised wording of any policy or text Please be as precise as possible

For the plan to be sound I believe that

1) Review the inclusion of the Hurst Lane site ndash SLAA 59 ndash within the plan Appendix B states the capacity of 10 for Hurst Lane and 5 for Padd Farm If this relates to additional properties the number does not reflect the plans of up to 800 houses Access and infrastructure are addressed and the reduction in headcount in the councilrsquos Customer Services (I believe there is a dedicated resource looking after Padd Farm Hurst Lane) would be an additional benefit

2) Greater publicity is required over the consultation process The council appear to work on a lsquopullrsquo basis in that residents of the borough (other than those in the Residents Associations) have to actively seek out any updates from the council Local newspapers are not a good way of disseminating information in the digital age

3) Identify the additional travellergypsy site plans and move outside of the Green Belt area

If these steps were taken the residents would all have ample opportunity to contribute to the development of the local plan

The Longcross site will also need medical facilities ndash GPrsquos and potentially NHS drop in centre to ensure the current burden on the NHS is not exacerbated

With regard to the Traveller pitches they appear to amount to 35 within the scope of the development areas However the council plan to deliver 131 net additional plotspitches ndash 96 of which are not covered in this local plan This is an extremely emotive subject and needs to be identified properly in the plan and not almost hidden to avoid confrontation with angry residents that this County is already over run with these communities Integration with new developments is not the answer ndash Allocation of Traveller sites and pitches is according to the Government guidelines ldquoinappropriate within the Green beltrdquo and trying to slide this surreptitiously into new developments is a totally inappropriate solution

The Hurst Lane development was dismissed by the Council despite the residents being on board and a sustainable and acceptable plan being put forward for c 800-1000 homes on 80 -100 acres Over time this Lane has deteriorated to the point that Planning Inspectors described it as an lsquoindustrial wastelandrsquo In addition the Council resources are being tied up with the numerous issues generated by the Lane and the inability to resolve with the resources available The primary reason given is that the land is lsquoGreen Beltrsquo although under exceptional circumstances (which I believe this would come under) the council are able to and plan to in other areas use this land It is effectively a brownfield site which could be permitted fi connected to a SANG trade off which the residents plan was

4

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further representations based on the original representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

7 If your representation is seeking a modification do you consider it necessary to participate at the oral part of the examination

No I do not wish to participate Yes I wish to participate at the oral examination at the oral examination

8 If you wish to participate at the oral part of the examination please outline why you consider this to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who have indicated that they wish to participate at the oral part of the examination

9 Signature Date

X

Caroline Craven 21st February 2018

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan 1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination 42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

FromPolicy

Subject FW New Housing Plans 2015-2030Date 21 February 2018 164919

Sent 21 February 2018 1608To PlanningSubject New Housing Plans 2015-2030

To

Policy Planning and Strategy Team

Runnymede Borough Council

Station Road

Addlestone

21022018

Dear Sirs

As an Ottershaw resident of nearly 30 years i would like you to read and take on board my objections to yourproposal to take land out of the green belt for housing and your plan to build so many houses in ourcommunity

Of course new houses have to be built right across the country now and in the future but i feel the plans youhave are for far too many houses The infrastructure of our community will just not sustain the extra amount ofpeople and cars and the general traffic that would entail

There are other possibilities available before your irreversible plans are put into action Are these possibilitiesbeing resourced

When i drive around the borough now and for a long long time i see so many empty office blocks Some ofthese have stood empty for yearsWhy has permission been given continuosly from what i can see on a huge scale for these to be built

This building of offices has to stop and the ones that have remained empty for years could be converted tohousing as in flats starter homes for young people

If Planning Practice Guidlines state that the use of Green Beltshould only occur in very special circumstances these and the Brownfield sites in Runnymede must be extensively researched

I live in Wilson Drive and for many years now when i leave my house to go into the village or elsewhere thereis often gridlock in every direction The roads in our community are so heavily used by cars and lorries headingtoward the M25 Can you imagine the impact so many more of these will bring Driving has not been a pleasurefor a long time and i do walk wherever possible Parking is a problem in the village as so many people use theone car park I believe there may be a plan in the pipeline to even get rid of that for road widening

We have a GP practice in the village that is getting harder to book an appointment for also i have been waitingmonths for an appointment at St Peters hospital and just keep getting apologetic letters

Quality of life is very important for your residents and that quality has already deteriorated lately

1888

In order to accomodate so many new residents you will be making the ones you have feel very disappointedand frustated that no one listens

There is no going back once the desicion has been made and so many houses built Please take my feelings and iam sure very many more residents comments and pleas into account before you make the irreversible decisionto go ahead with your plans

Yours Faithfully

Margaret Wensley and the Wensley family

Beechwood

Wilson Drive

Ottershaw

Surrey

KT16 0NT

----------- middotn==middot =

Planning Services

DELIVERED BY HAND

Runnymede Borough Council ~--------------=-middot ---------middot------~

Planning Dept Runnymede Borough Council Civic Offices Station Road Addlestone KT15 2AH

Dear Sirs

Catherine Brunton-Green 20The Glen Addlestone

KT151AQ

15th February 2018

Runnymede Draft local Plan 2015- 2030- Final Consultation

I have serious concerns in respect of this draft plan Runnymede Borough Council (RBC) have a duty of care to consult with listen and act upon the wishes of its residents There has been some consultation but this has not effectively reached all Runnymede residents Communication is unnecessarily legally complex and full of unexplained acronyms The basic Runnymede Voice delivered to every home has been abandoned There has been no flyer delivered to every home stating in a simplified way what is happening so that all abilities may be catered for Many people are isolated for numerous reasons and do not have internet access Neither is there evidence of full in depth cross boundary consultation with adjacent boroughs This local plan is driven primarily by a developers charter promoted by RBCS Head of Planning It is both unfair unjust and I question its soundness

The Strategic Housing Market Assessment has not taken leaving the EU into account and makes a blanket assumption on Heathrow expansion

I strongly object to the proposed loss of c 560 acres of Green Belt Our Prime Minister and government have recently stated that they are quote committed to protecting and enhancing our natural environment for successive generations therefore Green Belt land would only be lost as a last resort 11

bull Detailed evidence based research by The Council for The Protection of Rural England confirms that by fully utilising brownfield land 12 million homes could be built in London and the South East without the loss of any Green Belt

I have objection to building on the Veterinary Laboratory Green Belt Land Parcel BRow Town (Policy SL11 8283) is not justified for development This is designated for 150 additional dwellings and 2 gypsyTraveller pitches This site provides a natural demarcation between developments either side Designated SANG area is privately owned and not available The density of proposed build is unacceptable and above all an area of outstanding natural beauty would be destroyed

Our infrastructure is unable to cope at present A320 suffers perpetual gridlock now Equally gridlock is evidenced through Ottershaw Addlestone Station Road and A317 Addlestone Weybridge We already have unhealthily dangerous levels of roadside nitrogen dioxide concentrations in many areas such as Station Road RBC has made a lame submission in respect of

tackling roadside nitrogen dioxide concentrations in the South East (UK00310) Incidence of exacerbated breathing illnesses in this vicinity has increased dramatically in the past 7 years All age groups are affected

All GP surgeries across Runnymede have great difficulty in recruiting doctors Two practices in the immediate area are merging due to unprecedented numbers of doctors leaving and retiring Practice lists and capacity is stretched Patient access to services and patient safety has to be the highest priority Our schools are similarly affected

RBC infrastructure is totally reliant upon Surrey County Council who declare they are not in a financial position to fund the necessary support to develop the infrastructure for this Local Plan

I am prepared to speak at Public Enquiry

Yours faithfully

bull i I I bull bull

From Brian PickettTo Planning PolicySubject Runnymede 2030 Local Plan - submission of viewsDate 22 February 2018 090921Attachments Ottershaw development Objection letter February 2018docx

Please find attached the submission of my views on the Runnymede 2030 LocalPlan

Kind RegardsBrian Pickett

1891

planningrunnymedegovuk planningrunnymedegovuk

21022018

Re Runnymede 2030 Local Plan Ottershaw East ndash Objection to planning

Dear Sirs

We are writing to you again as we strongly object to the Runnymede Borough Councils plans to remove land behind houses along Brox Road known as lsquoOttershaw Eastrsquo from the Green Belt We are objecting for a number of reasons listed below

middot The Green Belt is precious once it is gone it is gone forever The removal of this land from the Green Belt does not comply with Planning Policy which states ldquothat Green Belt boundaries should only be altered in exceptional circumstancesrdquo there are no such circumstances that can justify the removal of this piece of land

middot The Green Belt should be an area that is preserved for future generations to enjoy and appreciate and many statements have been made by both the Government and members of Parliament on their commitment to protect the Green Belt ndash these statements now need to be converted into action in the Local Borough Plans The roll out of Green Belt to local councils in the 1950rsquos was to prevent urban sprawl and the merging of settlements thereby helping to preserve and protect the character of communities it encompassed protect the country setting and encourage development through regeneration of sites within towns and cities not villages

middot The description of Ottershaw by the council itself in the lsquoUrban Characteristicsrsquo publication on the Runnymede Borough Council website states ldquoOttershaw has its own identity and sense of place which is partly derived from the clearly identifiable heart of the urban area focused on The Otter and adjoining local shopping parade and community facilities as well as being surrounded by open greenbelt countryside Removing this green belt that is part of the identifiable heart of Ottershaw would destroy this villagersquos identity and community

middot The planning proposals and building on this part of the green belt land would lead to a considerable population increase in the village Services and facilities will struggle or fail to cope space is already limited at the doctorrsquos surgery and school places are at capacity The transport infrastructure is already stretched with limited bus services busy roads poorly maintained pavements and road surfaces Brox road is already used as a shortcut to avoid traffic congestion Given that Ottershaw does not have a train station it is reasonable to assume that the majority of houses would have at least one car the added traffic from the new development would put a severe strain on the road network and users Available information on mitigation is very vague and very open to interpretation and misguided assumptions

middot The Green Belt land is a habitat to an array of plants and animals including important pollinator species and larger animals such as birds foxes and deer There should be no assumption that animals will simply move to another area habitats are established over many years and this development will be another loss to the maintenance of biodiversity I enjoy the fauna and flora in these areas going for walks along the public footpaths Having such wonderful access to a relaxing escape so close to home is priceless and something I hold dear to myself my family and community What is now a beautiful scenic view will become a spoilt urban sprawl of modern housing

middot I moved to Ottershaw with my wife in 2016 to settle down and start a family The relaxed quiet village sense of community and safety surrounded by beautiful countryside were its appeal I are very concerned and disappointed that this planning proposal is still being considered which will undoubtedly destroy this idyllic setting

There are no ldquoexceptional or very special circumstancesrdquo that justify the removal of Ottershaw East from the Green Belt We trust that the Council will therefore not remove ldquoOttershaw Eastrdquo and ldquoThe Fieldrdquo from the Green Belt

Yours faithfully

Dr Brian Pickett

To Policy Planning and Strategy Team Runnymede Borough Council Civic Centre Station Road Addlestone Surrey KT15 2AH planningrunnymedegovuk

From Dr Brian Pickett 139 Brox Road Ottershaw Surrey KT16 0LG planningrunnymedegovuk

21022018 Re Runnymede 2030 Local Plan Ottershaw East ndash Objection to planning Dear Sirs We are writing to you again as we strongly object to the Runnymede Borough Councils plans to remove land behind houses along Brox Road known as lsquoOttershaw Eastrsquo from the Green Belt We are objecting for a number of reasons listed below bull The Green Belt is precious once it is gone it is gone forever The removal of this

land from the Green Belt does not comply with Planning Policy which states ldquothat Green Belt boundaries should only be altered in exceptional circumstancesrdquo there are no such circumstances that can justify the removal of this piece of land

bull The Green Belt should be an area that is preserved for future generations to enjoy

and appreciate and many statements have been made by both the Government and members of Parliament on their commitment to protect the Green Belt ndash these statements now need to be converted into action in the Local Borough Plans The roll out of Green Belt to local councils in the 1950rsquos was to prevent urban sprawl and the merging of settlements thereby helping to preserve and protect the character of communities it encompassed protect the country setting and encourage development through regeneration of sites within towns and cities not villages

bull The description of Ottershaw by the council itself in the lsquoUrban Characteristicsrsquo

publication on the Runnymede Borough Council website states ldquoOttershaw has its own identity and sense of place which is partly derived from the clearly identifiable heart of the urban area focused on The Otter and adjoining local shopping parade and community facilities as well as being surrounded by open greenbelt countryside Removing this green belt that is part of the identifiable heart of Ottershaw would destroy this villagersquos identity and community

bull The planning proposals and building on this part of the green belt land would lead

to a considerable population increase in the village Services and facilities will struggle or fail to cope space is already limited at the doctorrsquos surgery and school places are at capacity The transport infrastructure is already stretched with limited bus services busy roads poorly maintained pavements and road surfaces Brox road is already used as a shortcut to avoid traffic congestion Given that Ottershaw does not have a train station it is reasonable to assume that the majority of houses would have at least one car the added traffic from the new development would put a severe strain on the road network and users Available information on mitigation is very vague and very open to interpretation and misguided assumptions

bull The Green Belt land is a habitat to an array of plants and animals including important pollinator species and larger animals such as birds foxes and deer There should be no assumption that animals will simply move to another area habitats are established over many years and this development will be another loss to the maintenance of biodiversity I enjoy the fauna and flora in these areas going for walks along the public footpaths Having such wonderful access to a relaxing escape so close to home is priceless and something I hold dear to myself my family and community What is now a beautiful scenic view will become a spoilt urban sprawl of modern housing

bull I moved to Ottershaw with my wife in 2016 to settle down and start a family The

relaxed quiet village sense of community and safety surrounded by beautiful countryside were its appeal I are very concerned and disappointed that this planning proposal is still being considered which will undoubtedly destroy this idyllic setting

There are no ldquoexceptional or very special circumstancesrdquo that justify the removal of Ottershaw East from the Green Belt We trust that the Council will therefore not remove ldquoOttershaw Eastrdquo and ldquoThe Fieldrdquo from the Green Belt Yours faithfully Dr Brian Pickett

FromTo Planning PolicySubject Runnymede Local Plan 2030 - consultation responseDate 21 February 2018 163608Attachments Runnymede LP Response - EE15pdf

Please find attached a consultation response form

________________________________________Christian Leigh BSc(Hons) MPhil MRTPIDirectorLeigh amp Glennie Ltd6 All Souls RoadAscotBerkshire SL5 9EA

1893

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number 01344 297094 Email Address (where relevant)

mailchristianleighcouk

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number Email Address (where relevant)

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

From MCNAB DouglasTo Planning PolicySubject Runnymede Draft Local Plan consultation - Representation from Education and Skills Funding AgencyDate 21 February 2018 091407Attachments Runnymede Reg 19 response ESFADOC

Dear Runnymede Planning Policy Team

Please see attached a representation from the Education and Skills Funding Agency on theRunnymede Local Plan consultation

I would be grateful if you could confirm receipt

Best regardsDoug

Douglas McNab MRTPIForward Planning Manager ndash South East

Planning Team Free Schools CapitalEducation and Skills Funding AgencyDepartment for Education 5th floor Sanctuary Buildings 20 Great Smith Street London SW1P 3BT

Email douglasmcnabeducationgovukMobile 07990 082877Web wwwgovukesfa

1895

image1pngOur Ref ESFALocal PlanRunnymede 2018 21st February 2018

Dear SirMadam

Re Runnymede Local Plan

Consultation under Regulation 19 of Town and Country Planning (Local Planning) (England) Regulations 2012

Submission of the Education and Skills Funding Agency

1 The Education and Skills Funding Agency (ESFA) welcomes the opportunity to contribute to the development of planning policy at the local level

2 The ESFA launched on 1st April 2017 bringing together the existing responsibilities of the Education Funding Agency (EFA) and the Skills Funding Agency (SFA) to create a single funding agency accountable for funding education and training for children young people and adults The ESFA are accountable for pound61 billion of funding a year for the education and training sector including support for all state-provided education for 8 million children aged 3 to 16 and 16 million young people aged 16 to 19

3 Under the provisions of the Education Act 2011 and the Academies Act 2010 all new state schools are now academiesfree schools and the ESFA is the delivery body for many of these rather than local education authorities As such we aim to work closely with local authority education departments and planning authorities to meet the demand for new school places and new schools We do this through a variety of means including by supporting the adoption of sound local plan policies site allocations and guidance (all based on robust evidence) that facilitate the delivery of education infrastructure where and when it is needed and maximise developer contributions for schools In this capacity we would like to offer the following comments in response to the proposals outlined in the above consultation document

Comments on the Local Plan

4 As you will be aware the primary focus at this stage of the Local Planrsquos preparation is on the soundness of the plan with regard to it being positively prepared justified effective and consistent with national policy The following detailed comments set out the ESFArsquos view of the planrsquos soundness in respect of education provision

5 The ESFA notes that the local plan will make provision for a minimum of 7413 net additional dwellings over the plan period Development will generally complement the existing settlement pattern focusing the largest amounts of residential growth primarily in Chertsey (1950 homes) Addlestone (936 homes) and Egham (812 homes) A new ldquolocally led garden villagerdquo is also proposed at Longcross providing a further 1718 homes This level of development will put pressure on existing education infrastructure

6 The plan recognises that ldquoIt is important that infrastructure is delivered in a timely manner to ensure that the needs of the occupiers of new development can be met without placing undue burdens on existing infrastructure facilities and servicesrdquo (para 560) The ESFA supports Policy SD6 Infrastructure Provision amp Timing particularly the signposting of the Infrastructure Delivery Plan (IDP) and the need for development to deliver this either on-site or through s106 or CIL financial contributions off-site and the need for development to be phased in line with the provision of important supporting infrastructure

7 The latest version of the IDP states that there is an ongoing programme of primary school expansions this will help to meet the forecast need for 4-6FE of new capacity over the plan period The need for one new build school project is identified a 2FE primary school at the Longcross Garden Village (estimated cost pound99M to pound15M) this is referred to in the site allocation policies (see below) With respect to secondary school places it is anticipated that up to six additional FE could be required in the Borough by 2021 Additional places will be delivered through the new 6FE Runnymede Free School (which opened in temporary accommodation in 2017) development of additional FE within Salesian School (Catholic faith school) and expansion of another school in the Chertsey area (to accommodate demand from generated by the Longcross Garden Village site)

8 It would be useful if the background data informing these projections of need could be clarified particularly the pupil yield factors used and the evidence base supporting this This would help to demonstrate more clearly to the Inspector that the approach to the planning and delivery of education infrastructure has been positively prepared based on a strategy which seeks to meet objectively assessed infrastructure requirements and is justified based on proportionate evidence The ESFA notes that the Runnymede S106 SPG sets out pupil yield figures however this document dates from December 2007 so the figures may be outdated

9 The ESFA supports the Councilrsquos allocation and safeguarding of land for schools as set out in the following policies

middot Policy SD10 Longcross Garden Village - 2FE primary school with preschoolearly years settings

middot Policy SL2 to SL18 ndash series of housing allocation policies that highlight the need to make a financial contribution to early years primary and secondary school infrastructure ldquoeither through S106 or CIL (or its successor)rdquo

Developer Contributions and CIL

10 One of the tests of soundness is that a Local Plan is lsquoeffectiversquo ie the plan should be deliverable over its period In this context and with specific regard to planning for schools there is a need to ensure that education contributions made by developers are sufficient to deliver the additional school places required to meet the increase in demand generated by new developments The ESFA notes that the council has not adopted CIL and that the Planning Obligations SPG sets out how developer contributions to education provision will be secured via section 106 agreements The ESFA supports the Councilrsquos approach to ensure developer contributions address the impacts arising from growth However the ESFA recommends that the Local Plan includes a commitment to revise the Planning Obligations SPG in line with the latest evidence of the boroughrsquos infrastructure needs pupil yields and build costs (including the cost of school expansion new build and SEN provision) Any such review should be prepared in consultation with the county council as local education authority This will help to ensure appropriate rates are levied and the right infrastructure is secured across the borough

11 The ESFA would be particularly interested in responding to any update to the Infrastructure Delivery Plan or review of infrastructure requirements As such please add the ESFA to the database for future CIL consultations

Forward funding

12 In light of the proposed Longcross Garden Village emerging ESFA proposals for forward funding schools as part of large residential developments may be relevant for example if viability becomes an issue The ESFA aims to be able to clarify forward funding options for schools in 2018 We would be happy to meet to discuss this opportunity further once the options have been finalised and ifwhen relevant Any offer of forward funding would seek to maximise developer contributions to education infrastructure provision while supporting delivery of schools where and when they are needed

Conclusion

13 Finally I hope the above comments are helpful in finalising the Runnymede Local Plan with specific regard to the provision of land for new schools

14 Please notify the ESFA when the Local Plan is submitted for examination the Inspectorrsquos report is published and the Local Plan is adopted

15 Please do not hesitate to contact me if you have any queries regarding this response The ESFA looks forward to continuing to work with Runnymede Borough Council to develop a sound Local Plan that will aid in the delivery of new schools

Yours faithfully

DC McNab

Douglas McNab MRTPI

Forward Planning Manager

Tel 07990 082877

Email

douglasmcnabeducationgovuk

Web

wwwgovuk esfa

Education and Skills Funding Agency13

Department for EducationSanctuary BuildingsGreat Smith StreetLondonSW1P 3BT13

13

Tel 0207 340 700013

13

wwwgovukesfa13

13

13

To

Policy Planning and Strategy Team

Runnymede Borough Council

Civic Centre

Station Road

Addlestone

Surrey

KT15 2AH

From

Dr Brian Pickett

139 Brox Road

Ottershaw

Surrey

KT16 0LG

Title

Mrs

First Name

Caroline

Last Name

Craven

Job Title

(where relevant)

Organisation

(where relevant)

Address Line 1

Southover

Line 2

Hurst Lane

Line 3

Egham

Line 4

Surrey

Post Code

TW20 8QJ

Telephone Number

07770999572

Email Address

(where relevant)

Carolinecraven911hotmailcom

Page 16: Runnymede Borough Council, for submissions. My contact details are all in the WORD letter attached. But I will provide my telephone number here too, which …

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full contact details of the agent in 2

Title Mrs First Name Caroline Last Name Craven Job Title (where relevant)

Organisation (where relevant)

Address Line 1 Southover Line 2 Hurst Lane Line 3 Egham Line 4 Surrey Post Code TW20 8QJ Telephone Number Email Address (where relevant)

2

Part B (1) ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

XParagraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails to comply with the duty to co-operate Please be as precise as possible If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

X X X

x

X

x

I believe the Local Plan does not comply with the duty to co-operate with neighbouring Boroughs The previous version was not deemed to be compliant as I understand it and there does not appear to be any significant changes that allow this plan to be compliant

RBC seems to have relied on the former Statement of Community Involvement (SCI) of 2014 In a digital age 15 lines in a local (The Villager Feb 9th) on page 11 is a poor means of communication to the Runnymede Borough residents on something that will affect them so deeply

In addition the views expressed at the RBC meeting by the attending RBC councillors were essentially that they accepted it wasnrsquot as good as it should be but was lsquothe best wersquore going to get at the momentrsquo and if not submitted then a Government Inspector would be appointed and they would lose control ndash a view I can fully understand but does not give the Runnymede residents a feeling of confidence in the legality or the integrity of the plan nor that the council truly want the best for the Borough

With regard to the Longcross site improvements to the station do not address the capacity issue The impact to commuters further up the line will be significant Peak times will be heavily impacted If additional trains are being proposed on this line the impact to the residents of Egham who already have to wait some 35-40 minutes in the hour whilst gates are down would therefore have even less opportunity to transverse the line at the crossing points Longcross station has no accessible car parking or drop off points This would necessitate commuters travelling to Virginia Water Egham whose own parking capability is limited Virginia Water has lost a large number of station car park spaces due to a new development This would also cause increased congestion in already known problem junctions The additional burden to the A320 which is already operating over practical capacity at several junctions and expected to deteriorate over the coming years would be significant (A320 Corridor Study ndash Feasibility Study ndash Interim report February 2018)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally compliant or sound having regard to the Matter you have identified at 5 above where this relates to soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of modification at examination) You will need to say why this modification will make the Local Plan legally compliant or sound It will be helpful if you are able to put forward your suggested revised wording of any policy or text Please be as precise as possible

For the plan to be sound I believe that

1) Review the inclusion of the Hurst Lane site ndash SLAA 59 ndash within the plan Appendix B states the capacity of 10 for Hurst Lane and 5 for Padd Farm If this relates to additional properties the number does not reflect the plans of up to 800 houses Access and infrastructure are addressed and the reduction in headcount in the councilrsquos Customer Services (I believe there is a dedicated resource looking after Padd Farm Hurst Lane) would be an additional benefit

2) Greater publicity is required over the consultation process The council appear to work on a lsquopullrsquo basis in that residents of the borough (other than those in the Residents Associations) have to actively seek out any updates from the council Local newspapers are not a good way of disseminating information in the digital age

3) Identify the additional travellergypsy site plans and move outside of the Green Belt area

If these steps were taken the residents would all have ample opportunity to contribute to the development of the local plan

The Longcross site will also need medical facilities ndash GPrsquos and potentially NHS drop in centre to ensure the current burden on the NHS is not exacerbated

With regard to the Traveller pitches they appear to amount to 35 within the scope of the development areas However the council plan to deliver 131 net additional plotspitches ndash 96 of which are not covered in this local plan This is an extremely emotive subject and needs to be identified properly in the plan and not almost hidden to avoid confrontation with angry residents that this County is already over run with these communities Integration with new developments is not the answer ndash Allocation of Traveller sites and pitches is according to the Government guidelines ldquoinappropriate within the Green beltrdquo and trying to slide this surreptitiously into new developments is a totally inappropriate solution

The Hurst Lane development was dismissed by the Council despite the residents being on board and a sustainable and acceptable plan being put forward for c 800-1000 homes on 80 -100 acres Over time this Lane has deteriorated to the point that Planning Inspectors described it as an lsquoindustrial wastelandrsquo In addition the Council resources are being tied up with the numerous issues generated by the Lane and the inability to resolve with the resources available The primary reason given is that the land is lsquoGreen Beltrsquo although under exceptional circumstances (which I believe this would come under) the council are able to and plan to in other areas use this land It is effectively a brownfield site which could be permitted fi connected to a SANG trade off which the residents plan was

4

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further representations based on the original representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

7 If your representation is seeking a modification do you consider it necessary to participate at the oral part of the examination

No I do not wish to participate Yes I wish to participate at the oral examination at the oral examination

8 If you wish to participate at the oral part of the examination please outline why you consider this to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who have indicated that they wish to participate at the oral part of the examination

9 Signature Date

X

Caroline Craven 21st February 2018

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan 1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination 42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

FromPolicy

Subject FW New Housing Plans 2015-2030Date 21 February 2018 164919

Sent 21 February 2018 1608To PlanningSubject New Housing Plans 2015-2030

To

Policy Planning and Strategy Team

Runnymede Borough Council

Station Road

Addlestone

21022018

Dear Sirs

As an Ottershaw resident of nearly 30 years i would like you to read and take on board my objections to yourproposal to take land out of the green belt for housing and your plan to build so many houses in ourcommunity

Of course new houses have to be built right across the country now and in the future but i feel the plans youhave are for far too many houses The infrastructure of our community will just not sustain the extra amount ofpeople and cars and the general traffic that would entail

There are other possibilities available before your irreversible plans are put into action Are these possibilitiesbeing resourced

When i drive around the borough now and for a long long time i see so many empty office blocks Some ofthese have stood empty for yearsWhy has permission been given continuosly from what i can see on a huge scale for these to be built

This building of offices has to stop and the ones that have remained empty for years could be converted tohousing as in flats starter homes for young people

If Planning Practice Guidlines state that the use of Green Beltshould only occur in very special circumstances these and the Brownfield sites in Runnymede must be extensively researched

I live in Wilson Drive and for many years now when i leave my house to go into the village or elsewhere thereis often gridlock in every direction The roads in our community are so heavily used by cars and lorries headingtoward the M25 Can you imagine the impact so many more of these will bring Driving has not been a pleasurefor a long time and i do walk wherever possible Parking is a problem in the village as so many people use theone car park I believe there may be a plan in the pipeline to even get rid of that for road widening

We have a GP practice in the village that is getting harder to book an appointment for also i have been waitingmonths for an appointment at St Peters hospital and just keep getting apologetic letters

Quality of life is very important for your residents and that quality has already deteriorated lately

1888

In order to accomodate so many new residents you will be making the ones you have feel very disappointedand frustated that no one listens

There is no going back once the desicion has been made and so many houses built Please take my feelings and iam sure very many more residents comments and pleas into account before you make the irreversible decisionto go ahead with your plans

Yours Faithfully

Margaret Wensley and the Wensley family

Beechwood

Wilson Drive

Ottershaw

Surrey

KT16 0NT

----------- middotn==middot =

Planning Services

DELIVERED BY HAND

Runnymede Borough Council ~--------------=-middot ---------middot------~

Planning Dept Runnymede Borough Council Civic Offices Station Road Addlestone KT15 2AH

Dear Sirs

Catherine Brunton-Green 20The Glen Addlestone

KT151AQ

15th February 2018

Runnymede Draft local Plan 2015- 2030- Final Consultation

I have serious concerns in respect of this draft plan Runnymede Borough Council (RBC) have a duty of care to consult with listen and act upon the wishes of its residents There has been some consultation but this has not effectively reached all Runnymede residents Communication is unnecessarily legally complex and full of unexplained acronyms The basic Runnymede Voice delivered to every home has been abandoned There has been no flyer delivered to every home stating in a simplified way what is happening so that all abilities may be catered for Many people are isolated for numerous reasons and do not have internet access Neither is there evidence of full in depth cross boundary consultation with adjacent boroughs This local plan is driven primarily by a developers charter promoted by RBCS Head of Planning It is both unfair unjust and I question its soundness

The Strategic Housing Market Assessment has not taken leaving the EU into account and makes a blanket assumption on Heathrow expansion

I strongly object to the proposed loss of c 560 acres of Green Belt Our Prime Minister and government have recently stated that they are quote committed to protecting and enhancing our natural environment for successive generations therefore Green Belt land would only be lost as a last resort 11

bull Detailed evidence based research by The Council for The Protection of Rural England confirms that by fully utilising brownfield land 12 million homes could be built in London and the South East without the loss of any Green Belt

I have objection to building on the Veterinary Laboratory Green Belt Land Parcel BRow Town (Policy SL11 8283) is not justified for development This is designated for 150 additional dwellings and 2 gypsyTraveller pitches This site provides a natural demarcation between developments either side Designated SANG area is privately owned and not available The density of proposed build is unacceptable and above all an area of outstanding natural beauty would be destroyed

Our infrastructure is unable to cope at present A320 suffers perpetual gridlock now Equally gridlock is evidenced through Ottershaw Addlestone Station Road and A317 Addlestone Weybridge We already have unhealthily dangerous levels of roadside nitrogen dioxide concentrations in many areas such as Station Road RBC has made a lame submission in respect of

tackling roadside nitrogen dioxide concentrations in the South East (UK00310) Incidence of exacerbated breathing illnesses in this vicinity has increased dramatically in the past 7 years All age groups are affected

All GP surgeries across Runnymede have great difficulty in recruiting doctors Two practices in the immediate area are merging due to unprecedented numbers of doctors leaving and retiring Practice lists and capacity is stretched Patient access to services and patient safety has to be the highest priority Our schools are similarly affected

RBC infrastructure is totally reliant upon Surrey County Council who declare they are not in a financial position to fund the necessary support to develop the infrastructure for this Local Plan

I am prepared to speak at Public Enquiry

Yours faithfully

bull i I I bull bull

From Brian PickettTo Planning PolicySubject Runnymede 2030 Local Plan - submission of viewsDate 22 February 2018 090921Attachments Ottershaw development Objection letter February 2018docx

Please find attached the submission of my views on the Runnymede 2030 LocalPlan

Kind RegardsBrian Pickett

1891

planningrunnymedegovuk planningrunnymedegovuk

21022018

Re Runnymede 2030 Local Plan Ottershaw East ndash Objection to planning

Dear Sirs

We are writing to you again as we strongly object to the Runnymede Borough Councils plans to remove land behind houses along Brox Road known as lsquoOttershaw Eastrsquo from the Green Belt We are objecting for a number of reasons listed below

middot The Green Belt is precious once it is gone it is gone forever The removal of this land from the Green Belt does not comply with Planning Policy which states ldquothat Green Belt boundaries should only be altered in exceptional circumstancesrdquo there are no such circumstances that can justify the removal of this piece of land

middot The Green Belt should be an area that is preserved for future generations to enjoy and appreciate and many statements have been made by both the Government and members of Parliament on their commitment to protect the Green Belt ndash these statements now need to be converted into action in the Local Borough Plans The roll out of Green Belt to local councils in the 1950rsquos was to prevent urban sprawl and the merging of settlements thereby helping to preserve and protect the character of communities it encompassed protect the country setting and encourage development through regeneration of sites within towns and cities not villages

middot The description of Ottershaw by the council itself in the lsquoUrban Characteristicsrsquo publication on the Runnymede Borough Council website states ldquoOttershaw has its own identity and sense of place which is partly derived from the clearly identifiable heart of the urban area focused on The Otter and adjoining local shopping parade and community facilities as well as being surrounded by open greenbelt countryside Removing this green belt that is part of the identifiable heart of Ottershaw would destroy this villagersquos identity and community

middot The planning proposals and building on this part of the green belt land would lead to a considerable population increase in the village Services and facilities will struggle or fail to cope space is already limited at the doctorrsquos surgery and school places are at capacity The transport infrastructure is already stretched with limited bus services busy roads poorly maintained pavements and road surfaces Brox road is already used as a shortcut to avoid traffic congestion Given that Ottershaw does not have a train station it is reasonable to assume that the majority of houses would have at least one car the added traffic from the new development would put a severe strain on the road network and users Available information on mitigation is very vague and very open to interpretation and misguided assumptions

middot The Green Belt land is a habitat to an array of plants and animals including important pollinator species and larger animals such as birds foxes and deer There should be no assumption that animals will simply move to another area habitats are established over many years and this development will be another loss to the maintenance of biodiversity I enjoy the fauna and flora in these areas going for walks along the public footpaths Having such wonderful access to a relaxing escape so close to home is priceless and something I hold dear to myself my family and community What is now a beautiful scenic view will become a spoilt urban sprawl of modern housing

middot I moved to Ottershaw with my wife in 2016 to settle down and start a family The relaxed quiet village sense of community and safety surrounded by beautiful countryside were its appeal I are very concerned and disappointed that this planning proposal is still being considered which will undoubtedly destroy this idyllic setting

There are no ldquoexceptional or very special circumstancesrdquo that justify the removal of Ottershaw East from the Green Belt We trust that the Council will therefore not remove ldquoOttershaw Eastrdquo and ldquoThe Fieldrdquo from the Green Belt

Yours faithfully

Dr Brian Pickett

To Policy Planning and Strategy Team Runnymede Borough Council Civic Centre Station Road Addlestone Surrey KT15 2AH planningrunnymedegovuk

From Dr Brian Pickett 139 Brox Road Ottershaw Surrey KT16 0LG planningrunnymedegovuk

21022018 Re Runnymede 2030 Local Plan Ottershaw East ndash Objection to planning Dear Sirs We are writing to you again as we strongly object to the Runnymede Borough Councils plans to remove land behind houses along Brox Road known as lsquoOttershaw Eastrsquo from the Green Belt We are objecting for a number of reasons listed below bull The Green Belt is precious once it is gone it is gone forever The removal of this

land from the Green Belt does not comply with Planning Policy which states ldquothat Green Belt boundaries should only be altered in exceptional circumstancesrdquo there are no such circumstances that can justify the removal of this piece of land

bull The Green Belt should be an area that is preserved for future generations to enjoy

and appreciate and many statements have been made by both the Government and members of Parliament on their commitment to protect the Green Belt ndash these statements now need to be converted into action in the Local Borough Plans The roll out of Green Belt to local councils in the 1950rsquos was to prevent urban sprawl and the merging of settlements thereby helping to preserve and protect the character of communities it encompassed protect the country setting and encourage development through regeneration of sites within towns and cities not villages

bull The description of Ottershaw by the council itself in the lsquoUrban Characteristicsrsquo

publication on the Runnymede Borough Council website states ldquoOttershaw has its own identity and sense of place which is partly derived from the clearly identifiable heart of the urban area focused on The Otter and adjoining local shopping parade and community facilities as well as being surrounded by open greenbelt countryside Removing this green belt that is part of the identifiable heart of Ottershaw would destroy this villagersquos identity and community

bull The planning proposals and building on this part of the green belt land would lead

to a considerable population increase in the village Services and facilities will struggle or fail to cope space is already limited at the doctorrsquos surgery and school places are at capacity The transport infrastructure is already stretched with limited bus services busy roads poorly maintained pavements and road surfaces Brox road is already used as a shortcut to avoid traffic congestion Given that Ottershaw does not have a train station it is reasonable to assume that the majority of houses would have at least one car the added traffic from the new development would put a severe strain on the road network and users Available information on mitigation is very vague and very open to interpretation and misguided assumptions

bull The Green Belt land is a habitat to an array of plants and animals including important pollinator species and larger animals such as birds foxes and deer There should be no assumption that animals will simply move to another area habitats are established over many years and this development will be another loss to the maintenance of biodiversity I enjoy the fauna and flora in these areas going for walks along the public footpaths Having such wonderful access to a relaxing escape so close to home is priceless and something I hold dear to myself my family and community What is now a beautiful scenic view will become a spoilt urban sprawl of modern housing

bull I moved to Ottershaw with my wife in 2016 to settle down and start a family The

relaxed quiet village sense of community and safety surrounded by beautiful countryside were its appeal I are very concerned and disappointed that this planning proposal is still being considered which will undoubtedly destroy this idyllic setting

There are no ldquoexceptional or very special circumstancesrdquo that justify the removal of Ottershaw East from the Green Belt We trust that the Council will therefore not remove ldquoOttershaw Eastrdquo and ldquoThe Fieldrdquo from the Green Belt Yours faithfully Dr Brian Pickett

FromTo Planning PolicySubject Runnymede Local Plan 2030 - consultation responseDate 21 February 2018 163608Attachments Runnymede LP Response - EE15pdf

Please find attached a consultation response form

________________________________________Christian Leigh BSc(Hons) MPhil MRTPIDirectorLeigh amp Glennie Ltd6 All Souls RoadAscotBerkshire SL5 9EA

1893

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number 01344 297094 Email Address (where relevant)

mailchristianleighcouk

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number Email Address (where relevant)

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

From MCNAB DouglasTo Planning PolicySubject Runnymede Draft Local Plan consultation - Representation from Education and Skills Funding AgencyDate 21 February 2018 091407Attachments Runnymede Reg 19 response ESFADOC

Dear Runnymede Planning Policy Team

Please see attached a representation from the Education and Skills Funding Agency on theRunnymede Local Plan consultation

I would be grateful if you could confirm receipt

Best regardsDoug

Douglas McNab MRTPIForward Planning Manager ndash South East

Planning Team Free Schools CapitalEducation and Skills Funding AgencyDepartment for Education 5th floor Sanctuary Buildings 20 Great Smith Street London SW1P 3BT

Email douglasmcnabeducationgovukMobile 07990 082877Web wwwgovukesfa

1895

image1pngOur Ref ESFALocal PlanRunnymede 2018 21st February 2018

Dear SirMadam

Re Runnymede Local Plan

Consultation under Regulation 19 of Town and Country Planning (Local Planning) (England) Regulations 2012

Submission of the Education and Skills Funding Agency

1 The Education and Skills Funding Agency (ESFA) welcomes the opportunity to contribute to the development of planning policy at the local level

2 The ESFA launched on 1st April 2017 bringing together the existing responsibilities of the Education Funding Agency (EFA) and the Skills Funding Agency (SFA) to create a single funding agency accountable for funding education and training for children young people and adults The ESFA are accountable for pound61 billion of funding a year for the education and training sector including support for all state-provided education for 8 million children aged 3 to 16 and 16 million young people aged 16 to 19

3 Under the provisions of the Education Act 2011 and the Academies Act 2010 all new state schools are now academiesfree schools and the ESFA is the delivery body for many of these rather than local education authorities As such we aim to work closely with local authority education departments and planning authorities to meet the demand for new school places and new schools We do this through a variety of means including by supporting the adoption of sound local plan policies site allocations and guidance (all based on robust evidence) that facilitate the delivery of education infrastructure where and when it is needed and maximise developer contributions for schools In this capacity we would like to offer the following comments in response to the proposals outlined in the above consultation document

Comments on the Local Plan

4 As you will be aware the primary focus at this stage of the Local Planrsquos preparation is on the soundness of the plan with regard to it being positively prepared justified effective and consistent with national policy The following detailed comments set out the ESFArsquos view of the planrsquos soundness in respect of education provision

5 The ESFA notes that the local plan will make provision for a minimum of 7413 net additional dwellings over the plan period Development will generally complement the existing settlement pattern focusing the largest amounts of residential growth primarily in Chertsey (1950 homes) Addlestone (936 homes) and Egham (812 homes) A new ldquolocally led garden villagerdquo is also proposed at Longcross providing a further 1718 homes This level of development will put pressure on existing education infrastructure

6 The plan recognises that ldquoIt is important that infrastructure is delivered in a timely manner to ensure that the needs of the occupiers of new development can be met without placing undue burdens on existing infrastructure facilities and servicesrdquo (para 560) The ESFA supports Policy SD6 Infrastructure Provision amp Timing particularly the signposting of the Infrastructure Delivery Plan (IDP) and the need for development to deliver this either on-site or through s106 or CIL financial contributions off-site and the need for development to be phased in line with the provision of important supporting infrastructure

7 The latest version of the IDP states that there is an ongoing programme of primary school expansions this will help to meet the forecast need for 4-6FE of new capacity over the plan period The need for one new build school project is identified a 2FE primary school at the Longcross Garden Village (estimated cost pound99M to pound15M) this is referred to in the site allocation policies (see below) With respect to secondary school places it is anticipated that up to six additional FE could be required in the Borough by 2021 Additional places will be delivered through the new 6FE Runnymede Free School (which opened in temporary accommodation in 2017) development of additional FE within Salesian School (Catholic faith school) and expansion of another school in the Chertsey area (to accommodate demand from generated by the Longcross Garden Village site)

8 It would be useful if the background data informing these projections of need could be clarified particularly the pupil yield factors used and the evidence base supporting this This would help to demonstrate more clearly to the Inspector that the approach to the planning and delivery of education infrastructure has been positively prepared based on a strategy which seeks to meet objectively assessed infrastructure requirements and is justified based on proportionate evidence The ESFA notes that the Runnymede S106 SPG sets out pupil yield figures however this document dates from December 2007 so the figures may be outdated

9 The ESFA supports the Councilrsquos allocation and safeguarding of land for schools as set out in the following policies

middot Policy SD10 Longcross Garden Village - 2FE primary school with preschoolearly years settings

middot Policy SL2 to SL18 ndash series of housing allocation policies that highlight the need to make a financial contribution to early years primary and secondary school infrastructure ldquoeither through S106 or CIL (or its successor)rdquo

Developer Contributions and CIL

10 One of the tests of soundness is that a Local Plan is lsquoeffectiversquo ie the plan should be deliverable over its period In this context and with specific regard to planning for schools there is a need to ensure that education contributions made by developers are sufficient to deliver the additional school places required to meet the increase in demand generated by new developments The ESFA notes that the council has not adopted CIL and that the Planning Obligations SPG sets out how developer contributions to education provision will be secured via section 106 agreements The ESFA supports the Councilrsquos approach to ensure developer contributions address the impacts arising from growth However the ESFA recommends that the Local Plan includes a commitment to revise the Planning Obligations SPG in line with the latest evidence of the boroughrsquos infrastructure needs pupil yields and build costs (including the cost of school expansion new build and SEN provision) Any such review should be prepared in consultation with the county council as local education authority This will help to ensure appropriate rates are levied and the right infrastructure is secured across the borough

11 The ESFA would be particularly interested in responding to any update to the Infrastructure Delivery Plan or review of infrastructure requirements As such please add the ESFA to the database for future CIL consultations

Forward funding

12 In light of the proposed Longcross Garden Village emerging ESFA proposals for forward funding schools as part of large residential developments may be relevant for example if viability becomes an issue The ESFA aims to be able to clarify forward funding options for schools in 2018 We would be happy to meet to discuss this opportunity further once the options have been finalised and ifwhen relevant Any offer of forward funding would seek to maximise developer contributions to education infrastructure provision while supporting delivery of schools where and when they are needed

Conclusion

13 Finally I hope the above comments are helpful in finalising the Runnymede Local Plan with specific regard to the provision of land for new schools

14 Please notify the ESFA when the Local Plan is submitted for examination the Inspectorrsquos report is published and the Local Plan is adopted

15 Please do not hesitate to contact me if you have any queries regarding this response The ESFA looks forward to continuing to work with Runnymede Borough Council to develop a sound Local Plan that will aid in the delivery of new schools

Yours faithfully

DC McNab

Douglas McNab MRTPI

Forward Planning Manager

Tel 07990 082877

Email

douglasmcnabeducationgovuk

Web

wwwgovuk esfa

Education and Skills Funding Agency13

Department for EducationSanctuary BuildingsGreat Smith StreetLondonSW1P 3BT13

13

Tel 0207 340 700013

13

wwwgovukesfa13

13

13

To

Policy Planning and Strategy Team

Runnymede Borough Council

Civic Centre

Station Road

Addlestone

Surrey

KT15 2AH

From

Dr Brian Pickett

139 Brox Road

Ottershaw

Surrey

KT16 0LG

Page 17: Runnymede Borough Council, for submissions. My contact details are all in the WORD letter attached. But I will provide my telephone number here too, which …

2

Part B (1) ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

XParagraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails to comply with the duty to co-operate Please be as precise as possible If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

X X X

x

X

x

I believe the Local Plan does not comply with the duty to co-operate with neighbouring Boroughs The previous version was not deemed to be compliant as I understand it and there does not appear to be any significant changes that allow this plan to be compliant

RBC seems to have relied on the former Statement of Community Involvement (SCI) of 2014 In a digital age 15 lines in a local (The Villager Feb 9th) on page 11 is a poor means of communication to the Runnymede Borough residents on something that will affect them so deeply

In addition the views expressed at the RBC meeting by the attending RBC councillors were essentially that they accepted it wasnrsquot as good as it should be but was lsquothe best wersquore going to get at the momentrsquo and if not submitted then a Government Inspector would be appointed and they would lose control ndash a view I can fully understand but does not give the Runnymede residents a feeling of confidence in the legality or the integrity of the plan nor that the council truly want the best for the Borough

With regard to the Longcross site improvements to the station do not address the capacity issue The impact to commuters further up the line will be significant Peak times will be heavily impacted If additional trains are being proposed on this line the impact to the residents of Egham who already have to wait some 35-40 minutes in the hour whilst gates are down would therefore have even less opportunity to transverse the line at the crossing points Longcross station has no accessible car parking or drop off points This would necessitate commuters travelling to Virginia Water Egham whose own parking capability is limited Virginia Water has lost a large number of station car park spaces due to a new development This would also cause increased congestion in already known problem junctions The additional burden to the A320 which is already operating over practical capacity at several junctions and expected to deteriorate over the coming years would be significant (A320 Corridor Study ndash Feasibility Study ndash Interim report February 2018)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally compliant or sound having regard to the Matter you have identified at 5 above where this relates to soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of modification at examination) You will need to say why this modification will make the Local Plan legally compliant or sound It will be helpful if you are able to put forward your suggested revised wording of any policy or text Please be as precise as possible

For the plan to be sound I believe that

1) Review the inclusion of the Hurst Lane site ndash SLAA 59 ndash within the plan Appendix B states the capacity of 10 for Hurst Lane and 5 for Padd Farm If this relates to additional properties the number does not reflect the plans of up to 800 houses Access and infrastructure are addressed and the reduction in headcount in the councilrsquos Customer Services (I believe there is a dedicated resource looking after Padd Farm Hurst Lane) would be an additional benefit

2) Greater publicity is required over the consultation process The council appear to work on a lsquopullrsquo basis in that residents of the borough (other than those in the Residents Associations) have to actively seek out any updates from the council Local newspapers are not a good way of disseminating information in the digital age

3) Identify the additional travellergypsy site plans and move outside of the Green Belt area

If these steps were taken the residents would all have ample opportunity to contribute to the development of the local plan

The Longcross site will also need medical facilities ndash GPrsquos and potentially NHS drop in centre to ensure the current burden on the NHS is not exacerbated

With regard to the Traveller pitches they appear to amount to 35 within the scope of the development areas However the council plan to deliver 131 net additional plotspitches ndash 96 of which are not covered in this local plan This is an extremely emotive subject and needs to be identified properly in the plan and not almost hidden to avoid confrontation with angry residents that this County is already over run with these communities Integration with new developments is not the answer ndash Allocation of Traveller sites and pitches is according to the Government guidelines ldquoinappropriate within the Green beltrdquo and trying to slide this surreptitiously into new developments is a totally inappropriate solution

The Hurst Lane development was dismissed by the Council despite the residents being on board and a sustainable and acceptable plan being put forward for c 800-1000 homes on 80 -100 acres Over time this Lane has deteriorated to the point that Planning Inspectors described it as an lsquoindustrial wastelandrsquo In addition the Council resources are being tied up with the numerous issues generated by the Lane and the inability to resolve with the resources available The primary reason given is that the land is lsquoGreen Beltrsquo although under exceptional circumstances (which I believe this would come under) the council are able to and plan to in other areas use this land It is effectively a brownfield site which could be permitted fi connected to a SANG trade off which the residents plan was

4

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further representations based on the original representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

7 If your representation is seeking a modification do you consider it necessary to participate at the oral part of the examination

No I do not wish to participate Yes I wish to participate at the oral examination at the oral examination

8 If you wish to participate at the oral part of the examination please outline why you consider this to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who have indicated that they wish to participate at the oral part of the examination

9 Signature Date

X

Caroline Craven 21st February 2018

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan 1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination 42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

FromPolicy

Subject FW New Housing Plans 2015-2030Date 21 February 2018 164919

Sent 21 February 2018 1608To PlanningSubject New Housing Plans 2015-2030

To

Policy Planning and Strategy Team

Runnymede Borough Council

Station Road

Addlestone

21022018

Dear Sirs

As an Ottershaw resident of nearly 30 years i would like you to read and take on board my objections to yourproposal to take land out of the green belt for housing and your plan to build so many houses in ourcommunity

Of course new houses have to be built right across the country now and in the future but i feel the plans youhave are for far too many houses The infrastructure of our community will just not sustain the extra amount ofpeople and cars and the general traffic that would entail

There are other possibilities available before your irreversible plans are put into action Are these possibilitiesbeing resourced

When i drive around the borough now and for a long long time i see so many empty office blocks Some ofthese have stood empty for yearsWhy has permission been given continuosly from what i can see on a huge scale for these to be built

This building of offices has to stop and the ones that have remained empty for years could be converted tohousing as in flats starter homes for young people

If Planning Practice Guidlines state that the use of Green Beltshould only occur in very special circumstances these and the Brownfield sites in Runnymede must be extensively researched

I live in Wilson Drive and for many years now when i leave my house to go into the village or elsewhere thereis often gridlock in every direction The roads in our community are so heavily used by cars and lorries headingtoward the M25 Can you imagine the impact so many more of these will bring Driving has not been a pleasurefor a long time and i do walk wherever possible Parking is a problem in the village as so many people use theone car park I believe there may be a plan in the pipeline to even get rid of that for road widening

We have a GP practice in the village that is getting harder to book an appointment for also i have been waitingmonths for an appointment at St Peters hospital and just keep getting apologetic letters

Quality of life is very important for your residents and that quality has already deteriorated lately

1888

In order to accomodate so many new residents you will be making the ones you have feel very disappointedand frustated that no one listens

There is no going back once the desicion has been made and so many houses built Please take my feelings and iam sure very many more residents comments and pleas into account before you make the irreversible decisionto go ahead with your plans

Yours Faithfully

Margaret Wensley and the Wensley family

Beechwood

Wilson Drive

Ottershaw

Surrey

KT16 0NT

----------- middotn==middot =

Planning Services

DELIVERED BY HAND

Runnymede Borough Council ~--------------=-middot ---------middot------~

Planning Dept Runnymede Borough Council Civic Offices Station Road Addlestone KT15 2AH

Dear Sirs

Catherine Brunton-Green 20The Glen Addlestone

KT151AQ

15th February 2018

Runnymede Draft local Plan 2015- 2030- Final Consultation

I have serious concerns in respect of this draft plan Runnymede Borough Council (RBC) have a duty of care to consult with listen and act upon the wishes of its residents There has been some consultation but this has not effectively reached all Runnymede residents Communication is unnecessarily legally complex and full of unexplained acronyms The basic Runnymede Voice delivered to every home has been abandoned There has been no flyer delivered to every home stating in a simplified way what is happening so that all abilities may be catered for Many people are isolated for numerous reasons and do not have internet access Neither is there evidence of full in depth cross boundary consultation with adjacent boroughs This local plan is driven primarily by a developers charter promoted by RBCS Head of Planning It is both unfair unjust and I question its soundness

The Strategic Housing Market Assessment has not taken leaving the EU into account and makes a blanket assumption on Heathrow expansion

I strongly object to the proposed loss of c 560 acres of Green Belt Our Prime Minister and government have recently stated that they are quote committed to protecting and enhancing our natural environment for successive generations therefore Green Belt land would only be lost as a last resort 11

bull Detailed evidence based research by The Council for The Protection of Rural England confirms that by fully utilising brownfield land 12 million homes could be built in London and the South East without the loss of any Green Belt

I have objection to building on the Veterinary Laboratory Green Belt Land Parcel BRow Town (Policy SL11 8283) is not justified for development This is designated for 150 additional dwellings and 2 gypsyTraveller pitches This site provides a natural demarcation between developments either side Designated SANG area is privately owned and not available The density of proposed build is unacceptable and above all an area of outstanding natural beauty would be destroyed

Our infrastructure is unable to cope at present A320 suffers perpetual gridlock now Equally gridlock is evidenced through Ottershaw Addlestone Station Road and A317 Addlestone Weybridge We already have unhealthily dangerous levels of roadside nitrogen dioxide concentrations in many areas such as Station Road RBC has made a lame submission in respect of

tackling roadside nitrogen dioxide concentrations in the South East (UK00310) Incidence of exacerbated breathing illnesses in this vicinity has increased dramatically in the past 7 years All age groups are affected

All GP surgeries across Runnymede have great difficulty in recruiting doctors Two practices in the immediate area are merging due to unprecedented numbers of doctors leaving and retiring Practice lists and capacity is stretched Patient access to services and patient safety has to be the highest priority Our schools are similarly affected

RBC infrastructure is totally reliant upon Surrey County Council who declare they are not in a financial position to fund the necessary support to develop the infrastructure for this Local Plan

I am prepared to speak at Public Enquiry

Yours faithfully

bull i I I bull bull

From Brian PickettTo Planning PolicySubject Runnymede 2030 Local Plan - submission of viewsDate 22 February 2018 090921Attachments Ottershaw development Objection letter February 2018docx

Please find attached the submission of my views on the Runnymede 2030 LocalPlan

Kind RegardsBrian Pickett

1891

planningrunnymedegovuk planningrunnymedegovuk

21022018

Re Runnymede 2030 Local Plan Ottershaw East ndash Objection to planning

Dear Sirs

We are writing to you again as we strongly object to the Runnymede Borough Councils plans to remove land behind houses along Brox Road known as lsquoOttershaw Eastrsquo from the Green Belt We are objecting for a number of reasons listed below

middot The Green Belt is precious once it is gone it is gone forever The removal of this land from the Green Belt does not comply with Planning Policy which states ldquothat Green Belt boundaries should only be altered in exceptional circumstancesrdquo there are no such circumstances that can justify the removal of this piece of land

middot The Green Belt should be an area that is preserved for future generations to enjoy and appreciate and many statements have been made by both the Government and members of Parliament on their commitment to protect the Green Belt ndash these statements now need to be converted into action in the Local Borough Plans The roll out of Green Belt to local councils in the 1950rsquos was to prevent urban sprawl and the merging of settlements thereby helping to preserve and protect the character of communities it encompassed protect the country setting and encourage development through regeneration of sites within towns and cities not villages

middot The description of Ottershaw by the council itself in the lsquoUrban Characteristicsrsquo publication on the Runnymede Borough Council website states ldquoOttershaw has its own identity and sense of place which is partly derived from the clearly identifiable heart of the urban area focused on The Otter and adjoining local shopping parade and community facilities as well as being surrounded by open greenbelt countryside Removing this green belt that is part of the identifiable heart of Ottershaw would destroy this villagersquos identity and community

middot The planning proposals and building on this part of the green belt land would lead to a considerable population increase in the village Services and facilities will struggle or fail to cope space is already limited at the doctorrsquos surgery and school places are at capacity The transport infrastructure is already stretched with limited bus services busy roads poorly maintained pavements and road surfaces Brox road is already used as a shortcut to avoid traffic congestion Given that Ottershaw does not have a train station it is reasonable to assume that the majority of houses would have at least one car the added traffic from the new development would put a severe strain on the road network and users Available information on mitigation is very vague and very open to interpretation and misguided assumptions

middot The Green Belt land is a habitat to an array of plants and animals including important pollinator species and larger animals such as birds foxes and deer There should be no assumption that animals will simply move to another area habitats are established over many years and this development will be another loss to the maintenance of biodiversity I enjoy the fauna and flora in these areas going for walks along the public footpaths Having such wonderful access to a relaxing escape so close to home is priceless and something I hold dear to myself my family and community What is now a beautiful scenic view will become a spoilt urban sprawl of modern housing

middot I moved to Ottershaw with my wife in 2016 to settle down and start a family The relaxed quiet village sense of community and safety surrounded by beautiful countryside were its appeal I are very concerned and disappointed that this planning proposal is still being considered which will undoubtedly destroy this idyllic setting

There are no ldquoexceptional or very special circumstancesrdquo that justify the removal of Ottershaw East from the Green Belt We trust that the Council will therefore not remove ldquoOttershaw Eastrdquo and ldquoThe Fieldrdquo from the Green Belt

Yours faithfully

Dr Brian Pickett

To Policy Planning and Strategy Team Runnymede Borough Council Civic Centre Station Road Addlestone Surrey KT15 2AH planningrunnymedegovuk

From Dr Brian Pickett 139 Brox Road Ottershaw Surrey KT16 0LG planningrunnymedegovuk

21022018 Re Runnymede 2030 Local Plan Ottershaw East ndash Objection to planning Dear Sirs We are writing to you again as we strongly object to the Runnymede Borough Councils plans to remove land behind houses along Brox Road known as lsquoOttershaw Eastrsquo from the Green Belt We are objecting for a number of reasons listed below bull The Green Belt is precious once it is gone it is gone forever The removal of this

land from the Green Belt does not comply with Planning Policy which states ldquothat Green Belt boundaries should only be altered in exceptional circumstancesrdquo there are no such circumstances that can justify the removal of this piece of land

bull The Green Belt should be an area that is preserved for future generations to enjoy

and appreciate and many statements have been made by both the Government and members of Parliament on their commitment to protect the Green Belt ndash these statements now need to be converted into action in the Local Borough Plans The roll out of Green Belt to local councils in the 1950rsquos was to prevent urban sprawl and the merging of settlements thereby helping to preserve and protect the character of communities it encompassed protect the country setting and encourage development through regeneration of sites within towns and cities not villages

bull The description of Ottershaw by the council itself in the lsquoUrban Characteristicsrsquo

publication on the Runnymede Borough Council website states ldquoOttershaw has its own identity and sense of place which is partly derived from the clearly identifiable heart of the urban area focused on The Otter and adjoining local shopping parade and community facilities as well as being surrounded by open greenbelt countryside Removing this green belt that is part of the identifiable heart of Ottershaw would destroy this villagersquos identity and community

bull The planning proposals and building on this part of the green belt land would lead

to a considerable population increase in the village Services and facilities will struggle or fail to cope space is already limited at the doctorrsquos surgery and school places are at capacity The transport infrastructure is already stretched with limited bus services busy roads poorly maintained pavements and road surfaces Brox road is already used as a shortcut to avoid traffic congestion Given that Ottershaw does not have a train station it is reasonable to assume that the majority of houses would have at least one car the added traffic from the new development would put a severe strain on the road network and users Available information on mitigation is very vague and very open to interpretation and misguided assumptions

bull The Green Belt land is a habitat to an array of plants and animals including important pollinator species and larger animals such as birds foxes and deer There should be no assumption that animals will simply move to another area habitats are established over many years and this development will be another loss to the maintenance of biodiversity I enjoy the fauna and flora in these areas going for walks along the public footpaths Having such wonderful access to a relaxing escape so close to home is priceless and something I hold dear to myself my family and community What is now a beautiful scenic view will become a spoilt urban sprawl of modern housing

bull I moved to Ottershaw with my wife in 2016 to settle down and start a family The

relaxed quiet village sense of community and safety surrounded by beautiful countryside were its appeal I are very concerned and disappointed that this planning proposal is still being considered which will undoubtedly destroy this idyllic setting

There are no ldquoexceptional or very special circumstancesrdquo that justify the removal of Ottershaw East from the Green Belt We trust that the Council will therefore not remove ldquoOttershaw Eastrdquo and ldquoThe Fieldrdquo from the Green Belt Yours faithfully Dr Brian Pickett

FromTo Planning PolicySubject Runnymede Local Plan 2030 - consultation responseDate 21 February 2018 163608Attachments Runnymede LP Response - EE15pdf

Please find attached a consultation response form

________________________________________Christian Leigh BSc(Hons) MPhil MRTPIDirectorLeigh amp Glennie Ltd6 All Souls RoadAscotBerkshire SL5 9EA

1893

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number 01344 297094 Email Address (where relevant)

mailchristianleighcouk

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number Email Address (where relevant)

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

From MCNAB DouglasTo Planning PolicySubject Runnymede Draft Local Plan consultation - Representation from Education and Skills Funding AgencyDate 21 February 2018 091407Attachments Runnymede Reg 19 response ESFADOC

Dear Runnymede Planning Policy Team

Please see attached a representation from the Education and Skills Funding Agency on theRunnymede Local Plan consultation

I would be grateful if you could confirm receipt

Best regardsDoug

Douglas McNab MRTPIForward Planning Manager ndash South East

Planning Team Free Schools CapitalEducation and Skills Funding AgencyDepartment for Education 5th floor Sanctuary Buildings 20 Great Smith Street London SW1P 3BT

Email douglasmcnabeducationgovukMobile 07990 082877Web wwwgovukesfa

1895

image1pngOur Ref ESFALocal PlanRunnymede 2018 21st February 2018

Dear SirMadam

Re Runnymede Local Plan

Consultation under Regulation 19 of Town and Country Planning (Local Planning) (England) Regulations 2012

Submission of the Education and Skills Funding Agency

1 The Education and Skills Funding Agency (ESFA) welcomes the opportunity to contribute to the development of planning policy at the local level

2 The ESFA launched on 1st April 2017 bringing together the existing responsibilities of the Education Funding Agency (EFA) and the Skills Funding Agency (SFA) to create a single funding agency accountable for funding education and training for children young people and adults The ESFA are accountable for pound61 billion of funding a year for the education and training sector including support for all state-provided education for 8 million children aged 3 to 16 and 16 million young people aged 16 to 19

3 Under the provisions of the Education Act 2011 and the Academies Act 2010 all new state schools are now academiesfree schools and the ESFA is the delivery body for many of these rather than local education authorities As such we aim to work closely with local authority education departments and planning authorities to meet the demand for new school places and new schools We do this through a variety of means including by supporting the adoption of sound local plan policies site allocations and guidance (all based on robust evidence) that facilitate the delivery of education infrastructure where and when it is needed and maximise developer contributions for schools In this capacity we would like to offer the following comments in response to the proposals outlined in the above consultation document

Comments on the Local Plan

4 As you will be aware the primary focus at this stage of the Local Planrsquos preparation is on the soundness of the plan with regard to it being positively prepared justified effective and consistent with national policy The following detailed comments set out the ESFArsquos view of the planrsquos soundness in respect of education provision

5 The ESFA notes that the local plan will make provision for a minimum of 7413 net additional dwellings over the plan period Development will generally complement the existing settlement pattern focusing the largest amounts of residential growth primarily in Chertsey (1950 homes) Addlestone (936 homes) and Egham (812 homes) A new ldquolocally led garden villagerdquo is also proposed at Longcross providing a further 1718 homes This level of development will put pressure on existing education infrastructure

6 The plan recognises that ldquoIt is important that infrastructure is delivered in a timely manner to ensure that the needs of the occupiers of new development can be met without placing undue burdens on existing infrastructure facilities and servicesrdquo (para 560) The ESFA supports Policy SD6 Infrastructure Provision amp Timing particularly the signposting of the Infrastructure Delivery Plan (IDP) and the need for development to deliver this either on-site or through s106 or CIL financial contributions off-site and the need for development to be phased in line with the provision of important supporting infrastructure

7 The latest version of the IDP states that there is an ongoing programme of primary school expansions this will help to meet the forecast need for 4-6FE of new capacity over the plan period The need for one new build school project is identified a 2FE primary school at the Longcross Garden Village (estimated cost pound99M to pound15M) this is referred to in the site allocation policies (see below) With respect to secondary school places it is anticipated that up to six additional FE could be required in the Borough by 2021 Additional places will be delivered through the new 6FE Runnymede Free School (which opened in temporary accommodation in 2017) development of additional FE within Salesian School (Catholic faith school) and expansion of another school in the Chertsey area (to accommodate demand from generated by the Longcross Garden Village site)

8 It would be useful if the background data informing these projections of need could be clarified particularly the pupil yield factors used and the evidence base supporting this This would help to demonstrate more clearly to the Inspector that the approach to the planning and delivery of education infrastructure has been positively prepared based on a strategy which seeks to meet objectively assessed infrastructure requirements and is justified based on proportionate evidence The ESFA notes that the Runnymede S106 SPG sets out pupil yield figures however this document dates from December 2007 so the figures may be outdated

9 The ESFA supports the Councilrsquos allocation and safeguarding of land for schools as set out in the following policies

middot Policy SD10 Longcross Garden Village - 2FE primary school with preschoolearly years settings

middot Policy SL2 to SL18 ndash series of housing allocation policies that highlight the need to make a financial contribution to early years primary and secondary school infrastructure ldquoeither through S106 or CIL (or its successor)rdquo

Developer Contributions and CIL

10 One of the tests of soundness is that a Local Plan is lsquoeffectiversquo ie the plan should be deliverable over its period In this context and with specific regard to planning for schools there is a need to ensure that education contributions made by developers are sufficient to deliver the additional school places required to meet the increase in demand generated by new developments The ESFA notes that the council has not adopted CIL and that the Planning Obligations SPG sets out how developer contributions to education provision will be secured via section 106 agreements The ESFA supports the Councilrsquos approach to ensure developer contributions address the impacts arising from growth However the ESFA recommends that the Local Plan includes a commitment to revise the Planning Obligations SPG in line with the latest evidence of the boroughrsquos infrastructure needs pupil yields and build costs (including the cost of school expansion new build and SEN provision) Any such review should be prepared in consultation with the county council as local education authority This will help to ensure appropriate rates are levied and the right infrastructure is secured across the borough

11 The ESFA would be particularly interested in responding to any update to the Infrastructure Delivery Plan or review of infrastructure requirements As such please add the ESFA to the database for future CIL consultations

Forward funding

12 In light of the proposed Longcross Garden Village emerging ESFA proposals for forward funding schools as part of large residential developments may be relevant for example if viability becomes an issue The ESFA aims to be able to clarify forward funding options for schools in 2018 We would be happy to meet to discuss this opportunity further once the options have been finalised and ifwhen relevant Any offer of forward funding would seek to maximise developer contributions to education infrastructure provision while supporting delivery of schools where and when they are needed

Conclusion

13 Finally I hope the above comments are helpful in finalising the Runnymede Local Plan with specific regard to the provision of land for new schools

14 Please notify the ESFA when the Local Plan is submitted for examination the Inspectorrsquos report is published and the Local Plan is adopted

15 Please do not hesitate to contact me if you have any queries regarding this response The ESFA looks forward to continuing to work with Runnymede Borough Council to develop a sound Local Plan that will aid in the delivery of new schools

Yours faithfully

DC McNab

Douglas McNab MRTPI

Forward Planning Manager

Tel 07990 082877

Email

douglasmcnabeducationgovuk

Web

wwwgovuk esfa

Education and Skills Funding Agency13

Department for EducationSanctuary BuildingsGreat Smith StreetLondonSW1P 3BT13

13

Tel 0207 340 700013

13

wwwgovukesfa13

13

13

To

Policy Planning and Strategy Team

Runnymede Borough Council

Civic Centre

Station Road

Addlestone

Surrey

KT15 2AH

From

Dr Brian Pickett

139 Brox Road

Ottershaw

Surrey

KT16 0LG

Page 18: Runnymede Borough Council, for submissions. My contact details are all in the WORD letter attached. But I will provide my telephone number here too, which …

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally compliant or sound having regard to the Matter you have identified at 5 above where this relates to soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of modification at examination) You will need to say why this modification will make the Local Plan legally compliant or sound It will be helpful if you are able to put forward your suggested revised wording of any policy or text Please be as precise as possible

For the plan to be sound I believe that

1) Review the inclusion of the Hurst Lane site ndash SLAA 59 ndash within the plan Appendix B states the capacity of 10 for Hurst Lane and 5 for Padd Farm If this relates to additional properties the number does not reflect the plans of up to 800 houses Access and infrastructure are addressed and the reduction in headcount in the councilrsquos Customer Services (I believe there is a dedicated resource looking after Padd Farm Hurst Lane) would be an additional benefit

2) Greater publicity is required over the consultation process The council appear to work on a lsquopullrsquo basis in that residents of the borough (other than those in the Residents Associations) have to actively seek out any updates from the council Local newspapers are not a good way of disseminating information in the digital age

3) Identify the additional travellergypsy site plans and move outside of the Green Belt area

If these steps were taken the residents would all have ample opportunity to contribute to the development of the local plan

The Longcross site will also need medical facilities ndash GPrsquos and potentially NHS drop in centre to ensure the current burden on the NHS is not exacerbated

With regard to the Traveller pitches they appear to amount to 35 within the scope of the development areas However the council plan to deliver 131 net additional plotspitches ndash 96 of which are not covered in this local plan This is an extremely emotive subject and needs to be identified properly in the plan and not almost hidden to avoid confrontation with angry residents that this County is already over run with these communities Integration with new developments is not the answer ndash Allocation of Traveller sites and pitches is according to the Government guidelines ldquoinappropriate within the Green beltrdquo and trying to slide this surreptitiously into new developments is a totally inappropriate solution

The Hurst Lane development was dismissed by the Council despite the residents being on board and a sustainable and acceptable plan being put forward for c 800-1000 homes on 80 -100 acres Over time this Lane has deteriorated to the point that Planning Inspectors described it as an lsquoindustrial wastelandrsquo In addition the Council resources are being tied up with the numerous issues generated by the Lane and the inability to resolve with the resources available The primary reason given is that the land is lsquoGreen Beltrsquo although under exceptional circumstances (which I believe this would come under) the council are able to and plan to in other areas use this land It is effectively a brownfield site which could be permitted fi connected to a SANG trade off which the residents plan was

4

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further representations based on the original representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

7 If your representation is seeking a modification do you consider it necessary to participate at the oral part of the examination

No I do not wish to participate Yes I wish to participate at the oral examination at the oral examination

8 If you wish to participate at the oral part of the examination please outline why you consider this to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who have indicated that they wish to participate at the oral part of the examination

9 Signature Date

X

Caroline Craven 21st February 2018

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan 1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination 42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

FromPolicy

Subject FW New Housing Plans 2015-2030Date 21 February 2018 164919

Sent 21 February 2018 1608To PlanningSubject New Housing Plans 2015-2030

To

Policy Planning and Strategy Team

Runnymede Borough Council

Station Road

Addlestone

21022018

Dear Sirs

As an Ottershaw resident of nearly 30 years i would like you to read and take on board my objections to yourproposal to take land out of the green belt for housing and your plan to build so many houses in ourcommunity

Of course new houses have to be built right across the country now and in the future but i feel the plans youhave are for far too many houses The infrastructure of our community will just not sustain the extra amount ofpeople and cars and the general traffic that would entail

There are other possibilities available before your irreversible plans are put into action Are these possibilitiesbeing resourced

When i drive around the borough now and for a long long time i see so many empty office blocks Some ofthese have stood empty for yearsWhy has permission been given continuosly from what i can see on a huge scale for these to be built

This building of offices has to stop and the ones that have remained empty for years could be converted tohousing as in flats starter homes for young people

If Planning Practice Guidlines state that the use of Green Beltshould only occur in very special circumstances these and the Brownfield sites in Runnymede must be extensively researched

I live in Wilson Drive and for many years now when i leave my house to go into the village or elsewhere thereis often gridlock in every direction The roads in our community are so heavily used by cars and lorries headingtoward the M25 Can you imagine the impact so many more of these will bring Driving has not been a pleasurefor a long time and i do walk wherever possible Parking is a problem in the village as so many people use theone car park I believe there may be a plan in the pipeline to even get rid of that for road widening

We have a GP practice in the village that is getting harder to book an appointment for also i have been waitingmonths for an appointment at St Peters hospital and just keep getting apologetic letters

Quality of life is very important for your residents and that quality has already deteriorated lately

1888

In order to accomodate so many new residents you will be making the ones you have feel very disappointedand frustated that no one listens

There is no going back once the desicion has been made and so many houses built Please take my feelings and iam sure very many more residents comments and pleas into account before you make the irreversible decisionto go ahead with your plans

Yours Faithfully

Margaret Wensley and the Wensley family

Beechwood

Wilson Drive

Ottershaw

Surrey

KT16 0NT

----------- middotn==middot =

Planning Services

DELIVERED BY HAND

Runnymede Borough Council ~--------------=-middot ---------middot------~

Planning Dept Runnymede Borough Council Civic Offices Station Road Addlestone KT15 2AH

Dear Sirs

Catherine Brunton-Green 20The Glen Addlestone

KT151AQ

15th February 2018

Runnymede Draft local Plan 2015- 2030- Final Consultation

I have serious concerns in respect of this draft plan Runnymede Borough Council (RBC) have a duty of care to consult with listen and act upon the wishes of its residents There has been some consultation but this has not effectively reached all Runnymede residents Communication is unnecessarily legally complex and full of unexplained acronyms The basic Runnymede Voice delivered to every home has been abandoned There has been no flyer delivered to every home stating in a simplified way what is happening so that all abilities may be catered for Many people are isolated for numerous reasons and do not have internet access Neither is there evidence of full in depth cross boundary consultation with adjacent boroughs This local plan is driven primarily by a developers charter promoted by RBCS Head of Planning It is both unfair unjust and I question its soundness

The Strategic Housing Market Assessment has not taken leaving the EU into account and makes a blanket assumption on Heathrow expansion

I strongly object to the proposed loss of c 560 acres of Green Belt Our Prime Minister and government have recently stated that they are quote committed to protecting and enhancing our natural environment for successive generations therefore Green Belt land would only be lost as a last resort 11

bull Detailed evidence based research by The Council for The Protection of Rural England confirms that by fully utilising brownfield land 12 million homes could be built in London and the South East without the loss of any Green Belt

I have objection to building on the Veterinary Laboratory Green Belt Land Parcel BRow Town (Policy SL11 8283) is not justified for development This is designated for 150 additional dwellings and 2 gypsyTraveller pitches This site provides a natural demarcation between developments either side Designated SANG area is privately owned and not available The density of proposed build is unacceptable and above all an area of outstanding natural beauty would be destroyed

Our infrastructure is unable to cope at present A320 suffers perpetual gridlock now Equally gridlock is evidenced through Ottershaw Addlestone Station Road and A317 Addlestone Weybridge We already have unhealthily dangerous levels of roadside nitrogen dioxide concentrations in many areas such as Station Road RBC has made a lame submission in respect of

tackling roadside nitrogen dioxide concentrations in the South East (UK00310) Incidence of exacerbated breathing illnesses in this vicinity has increased dramatically in the past 7 years All age groups are affected

All GP surgeries across Runnymede have great difficulty in recruiting doctors Two practices in the immediate area are merging due to unprecedented numbers of doctors leaving and retiring Practice lists and capacity is stretched Patient access to services and patient safety has to be the highest priority Our schools are similarly affected

RBC infrastructure is totally reliant upon Surrey County Council who declare they are not in a financial position to fund the necessary support to develop the infrastructure for this Local Plan

I am prepared to speak at Public Enquiry

Yours faithfully

bull i I I bull bull

From Brian PickettTo Planning PolicySubject Runnymede 2030 Local Plan - submission of viewsDate 22 February 2018 090921Attachments Ottershaw development Objection letter February 2018docx

Please find attached the submission of my views on the Runnymede 2030 LocalPlan

Kind RegardsBrian Pickett

1891

planningrunnymedegovuk planningrunnymedegovuk

21022018

Re Runnymede 2030 Local Plan Ottershaw East ndash Objection to planning

Dear Sirs

We are writing to you again as we strongly object to the Runnymede Borough Councils plans to remove land behind houses along Brox Road known as lsquoOttershaw Eastrsquo from the Green Belt We are objecting for a number of reasons listed below

middot The Green Belt is precious once it is gone it is gone forever The removal of this land from the Green Belt does not comply with Planning Policy which states ldquothat Green Belt boundaries should only be altered in exceptional circumstancesrdquo there are no such circumstances that can justify the removal of this piece of land

middot The Green Belt should be an area that is preserved for future generations to enjoy and appreciate and many statements have been made by both the Government and members of Parliament on their commitment to protect the Green Belt ndash these statements now need to be converted into action in the Local Borough Plans The roll out of Green Belt to local councils in the 1950rsquos was to prevent urban sprawl and the merging of settlements thereby helping to preserve and protect the character of communities it encompassed protect the country setting and encourage development through regeneration of sites within towns and cities not villages

middot The description of Ottershaw by the council itself in the lsquoUrban Characteristicsrsquo publication on the Runnymede Borough Council website states ldquoOttershaw has its own identity and sense of place which is partly derived from the clearly identifiable heart of the urban area focused on The Otter and adjoining local shopping parade and community facilities as well as being surrounded by open greenbelt countryside Removing this green belt that is part of the identifiable heart of Ottershaw would destroy this villagersquos identity and community

middot The planning proposals and building on this part of the green belt land would lead to a considerable population increase in the village Services and facilities will struggle or fail to cope space is already limited at the doctorrsquos surgery and school places are at capacity The transport infrastructure is already stretched with limited bus services busy roads poorly maintained pavements and road surfaces Brox road is already used as a shortcut to avoid traffic congestion Given that Ottershaw does not have a train station it is reasonable to assume that the majority of houses would have at least one car the added traffic from the new development would put a severe strain on the road network and users Available information on mitigation is very vague and very open to interpretation and misguided assumptions

middot The Green Belt land is a habitat to an array of plants and animals including important pollinator species and larger animals such as birds foxes and deer There should be no assumption that animals will simply move to another area habitats are established over many years and this development will be another loss to the maintenance of biodiversity I enjoy the fauna and flora in these areas going for walks along the public footpaths Having such wonderful access to a relaxing escape so close to home is priceless and something I hold dear to myself my family and community What is now a beautiful scenic view will become a spoilt urban sprawl of modern housing

middot I moved to Ottershaw with my wife in 2016 to settle down and start a family The relaxed quiet village sense of community and safety surrounded by beautiful countryside were its appeal I are very concerned and disappointed that this planning proposal is still being considered which will undoubtedly destroy this idyllic setting

There are no ldquoexceptional or very special circumstancesrdquo that justify the removal of Ottershaw East from the Green Belt We trust that the Council will therefore not remove ldquoOttershaw Eastrdquo and ldquoThe Fieldrdquo from the Green Belt

Yours faithfully

Dr Brian Pickett

To Policy Planning and Strategy Team Runnymede Borough Council Civic Centre Station Road Addlestone Surrey KT15 2AH planningrunnymedegovuk

From Dr Brian Pickett 139 Brox Road Ottershaw Surrey KT16 0LG planningrunnymedegovuk

21022018 Re Runnymede 2030 Local Plan Ottershaw East ndash Objection to planning Dear Sirs We are writing to you again as we strongly object to the Runnymede Borough Councils plans to remove land behind houses along Brox Road known as lsquoOttershaw Eastrsquo from the Green Belt We are objecting for a number of reasons listed below bull The Green Belt is precious once it is gone it is gone forever The removal of this

land from the Green Belt does not comply with Planning Policy which states ldquothat Green Belt boundaries should only be altered in exceptional circumstancesrdquo there are no such circumstances that can justify the removal of this piece of land

bull The Green Belt should be an area that is preserved for future generations to enjoy

and appreciate and many statements have been made by both the Government and members of Parliament on their commitment to protect the Green Belt ndash these statements now need to be converted into action in the Local Borough Plans The roll out of Green Belt to local councils in the 1950rsquos was to prevent urban sprawl and the merging of settlements thereby helping to preserve and protect the character of communities it encompassed protect the country setting and encourage development through regeneration of sites within towns and cities not villages

bull The description of Ottershaw by the council itself in the lsquoUrban Characteristicsrsquo

publication on the Runnymede Borough Council website states ldquoOttershaw has its own identity and sense of place which is partly derived from the clearly identifiable heart of the urban area focused on The Otter and adjoining local shopping parade and community facilities as well as being surrounded by open greenbelt countryside Removing this green belt that is part of the identifiable heart of Ottershaw would destroy this villagersquos identity and community

bull The planning proposals and building on this part of the green belt land would lead

to a considerable population increase in the village Services and facilities will struggle or fail to cope space is already limited at the doctorrsquos surgery and school places are at capacity The transport infrastructure is already stretched with limited bus services busy roads poorly maintained pavements and road surfaces Brox road is already used as a shortcut to avoid traffic congestion Given that Ottershaw does not have a train station it is reasonable to assume that the majority of houses would have at least one car the added traffic from the new development would put a severe strain on the road network and users Available information on mitigation is very vague and very open to interpretation and misguided assumptions

bull The Green Belt land is a habitat to an array of plants and animals including important pollinator species and larger animals such as birds foxes and deer There should be no assumption that animals will simply move to another area habitats are established over many years and this development will be another loss to the maintenance of biodiversity I enjoy the fauna and flora in these areas going for walks along the public footpaths Having such wonderful access to a relaxing escape so close to home is priceless and something I hold dear to myself my family and community What is now a beautiful scenic view will become a spoilt urban sprawl of modern housing

bull I moved to Ottershaw with my wife in 2016 to settle down and start a family The

relaxed quiet village sense of community and safety surrounded by beautiful countryside were its appeal I are very concerned and disappointed that this planning proposal is still being considered which will undoubtedly destroy this idyllic setting

There are no ldquoexceptional or very special circumstancesrdquo that justify the removal of Ottershaw East from the Green Belt We trust that the Council will therefore not remove ldquoOttershaw Eastrdquo and ldquoThe Fieldrdquo from the Green Belt Yours faithfully Dr Brian Pickett

FromTo Planning PolicySubject Runnymede Local Plan 2030 - consultation responseDate 21 February 2018 163608Attachments Runnymede LP Response - EE15pdf

Please find attached a consultation response form

________________________________________Christian Leigh BSc(Hons) MPhil MRTPIDirectorLeigh amp Glennie Ltd6 All Souls RoadAscotBerkshire SL5 9EA

1893

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number 01344 297094 Email Address (where relevant)

mailchristianleighcouk

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number Email Address (where relevant)

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

From MCNAB DouglasTo Planning PolicySubject Runnymede Draft Local Plan consultation - Representation from Education and Skills Funding AgencyDate 21 February 2018 091407Attachments Runnymede Reg 19 response ESFADOC

Dear Runnymede Planning Policy Team

Please see attached a representation from the Education and Skills Funding Agency on theRunnymede Local Plan consultation

I would be grateful if you could confirm receipt

Best regardsDoug

Douglas McNab MRTPIForward Planning Manager ndash South East

Planning Team Free Schools CapitalEducation and Skills Funding AgencyDepartment for Education 5th floor Sanctuary Buildings 20 Great Smith Street London SW1P 3BT

Email douglasmcnabeducationgovukMobile 07990 082877Web wwwgovukesfa

1895

image1pngOur Ref ESFALocal PlanRunnymede 2018 21st February 2018

Dear SirMadam

Re Runnymede Local Plan

Consultation under Regulation 19 of Town and Country Planning (Local Planning) (England) Regulations 2012

Submission of the Education and Skills Funding Agency

1 The Education and Skills Funding Agency (ESFA) welcomes the opportunity to contribute to the development of planning policy at the local level

2 The ESFA launched on 1st April 2017 bringing together the existing responsibilities of the Education Funding Agency (EFA) and the Skills Funding Agency (SFA) to create a single funding agency accountable for funding education and training for children young people and adults The ESFA are accountable for pound61 billion of funding a year for the education and training sector including support for all state-provided education for 8 million children aged 3 to 16 and 16 million young people aged 16 to 19

3 Under the provisions of the Education Act 2011 and the Academies Act 2010 all new state schools are now academiesfree schools and the ESFA is the delivery body for many of these rather than local education authorities As such we aim to work closely with local authority education departments and planning authorities to meet the demand for new school places and new schools We do this through a variety of means including by supporting the adoption of sound local plan policies site allocations and guidance (all based on robust evidence) that facilitate the delivery of education infrastructure where and when it is needed and maximise developer contributions for schools In this capacity we would like to offer the following comments in response to the proposals outlined in the above consultation document

Comments on the Local Plan

4 As you will be aware the primary focus at this stage of the Local Planrsquos preparation is on the soundness of the plan with regard to it being positively prepared justified effective and consistent with national policy The following detailed comments set out the ESFArsquos view of the planrsquos soundness in respect of education provision

5 The ESFA notes that the local plan will make provision for a minimum of 7413 net additional dwellings over the plan period Development will generally complement the existing settlement pattern focusing the largest amounts of residential growth primarily in Chertsey (1950 homes) Addlestone (936 homes) and Egham (812 homes) A new ldquolocally led garden villagerdquo is also proposed at Longcross providing a further 1718 homes This level of development will put pressure on existing education infrastructure

6 The plan recognises that ldquoIt is important that infrastructure is delivered in a timely manner to ensure that the needs of the occupiers of new development can be met without placing undue burdens on existing infrastructure facilities and servicesrdquo (para 560) The ESFA supports Policy SD6 Infrastructure Provision amp Timing particularly the signposting of the Infrastructure Delivery Plan (IDP) and the need for development to deliver this either on-site or through s106 or CIL financial contributions off-site and the need for development to be phased in line with the provision of important supporting infrastructure

7 The latest version of the IDP states that there is an ongoing programme of primary school expansions this will help to meet the forecast need for 4-6FE of new capacity over the plan period The need for one new build school project is identified a 2FE primary school at the Longcross Garden Village (estimated cost pound99M to pound15M) this is referred to in the site allocation policies (see below) With respect to secondary school places it is anticipated that up to six additional FE could be required in the Borough by 2021 Additional places will be delivered through the new 6FE Runnymede Free School (which opened in temporary accommodation in 2017) development of additional FE within Salesian School (Catholic faith school) and expansion of another school in the Chertsey area (to accommodate demand from generated by the Longcross Garden Village site)

8 It would be useful if the background data informing these projections of need could be clarified particularly the pupil yield factors used and the evidence base supporting this This would help to demonstrate more clearly to the Inspector that the approach to the planning and delivery of education infrastructure has been positively prepared based on a strategy which seeks to meet objectively assessed infrastructure requirements and is justified based on proportionate evidence The ESFA notes that the Runnymede S106 SPG sets out pupil yield figures however this document dates from December 2007 so the figures may be outdated

9 The ESFA supports the Councilrsquos allocation and safeguarding of land for schools as set out in the following policies

middot Policy SD10 Longcross Garden Village - 2FE primary school with preschoolearly years settings

middot Policy SL2 to SL18 ndash series of housing allocation policies that highlight the need to make a financial contribution to early years primary and secondary school infrastructure ldquoeither through S106 or CIL (or its successor)rdquo

Developer Contributions and CIL

10 One of the tests of soundness is that a Local Plan is lsquoeffectiversquo ie the plan should be deliverable over its period In this context and with specific regard to planning for schools there is a need to ensure that education contributions made by developers are sufficient to deliver the additional school places required to meet the increase in demand generated by new developments The ESFA notes that the council has not adopted CIL and that the Planning Obligations SPG sets out how developer contributions to education provision will be secured via section 106 agreements The ESFA supports the Councilrsquos approach to ensure developer contributions address the impacts arising from growth However the ESFA recommends that the Local Plan includes a commitment to revise the Planning Obligations SPG in line with the latest evidence of the boroughrsquos infrastructure needs pupil yields and build costs (including the cost of school expansion new build and SEN provision) Any such review should be prepared in consultation with the county council as local education authority This will help to ensure appropriate rates are levied and the right infrastructure is secured across the borough

11 The ESFA would be particularly interested in responding to any update to the Infrastructure Delivery Plan or review of infrastructure requirements As such please add the ESFA to the database for future CIL consultations

Forward funding

12 In light of the proposed Longcross Garden Village emerging ESFA proposals for forward funding schools as part of large residential developments may be relevant for example if viability becomes an issue The ESFA aims to be able to clarify forward funding options for schools in 2018 We would be happy to meet to discuss this opportunity further once the options have been finalised and ifwhen relevant Any offer of forward funding would seek to maximise developer contributions to education infrastructure provision while supporting delivery of schools where and when they are needed

Conclusion

13 Finally I hope the above comments are helpful in finalising the Runnymede Local Plan with specific regard to the provision of land for new schools

14 Please notify the ESFA when the Local Plan is submitted for examination the Inspectorrsquos report is published and the Local Plan is adopted

15 Please do not hesitate to contact me if you have any queries regarding this response The ESFA looks forward to continuing to work with Runnymede Borough Council to develop a sound Local Plan that will aid in the delivery of new schools

Yours faithfully

DC McNab

Douglas McNab MRTPI

Forward Planning Manager

Tel 07990 082877

Email

douglasmcnabeducationgovuk

Web

wwwgovuk esfa

Education and Skills Funding Agency13

Department for EducationSanctuary BuildingsGreat Smith StreetLondonSW1P 3BT13

13

Tel 0207 340 700013

13

wwwgovukesfa13

13

13

To

Policy Planning and Strategy Team

Runnymede Borough Council

Civic Centre

Station Road

Addlestone

Surrey

KT15 2AH

From

Dr Brian Pickett

139 Brox Road

Ottershaw

Surrey

KT16 0LG

Page 19: Runnymede Borough Council, for submissions. My contact details are all in the WORD letter attached. But I will provide my telephone number here too, which …

4

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further representations based on the original representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

7 If your representation is seeking a modification do you consider it necessary to participate at the oral part of the examination

No I do not wish to participate Yes I wish to participate at the oral examination at the oral examination

8 If you wish to participate at the oral part of the examination please outline why you consider this to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who have indicated that they wish to participate at the oral part of the examination

9 Signature Date

X

Caroline Craven 21st February 2018

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan 1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination 42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

FromPolicy

Subject FW New Housing Plans 2015-2030Date 21 February 2018 164919

Sent 21 February 2018 1608To PlanningSubject New Housing Plans 2015-2030

To

Policy Planning and Strategy Team

Runnymede Borough Council

Station Road

Addlestone

21022018

Dear Sirs

As an Ottershaw resident of nearly 30 years i would like you to read and take on board my objections to yourproposal to take land out of the green belt for housing and your plan to build so many houses in ourcommunity

Of course new houses have to be built right across the country now and in the future but i feel the plans youhave are for far too many houses The infrastructure of our community will just not sustain the extra amount ofpeople and cars and the general traffic that would entail

There are other possibilities available before your irreversible plans are put into action Are these possibilitiesbeing resourced

When i drive around the borough now and for a long long time i see so many empty office blocks Some ofthese have stood empty for yearsWhy has permission been given continuosly from what i can see on a huge scale for these to be built

This building of offices has to stop and the ones that have remained empty for years could be converted tohousing as in flats starter homes for young people

If Planning Practice Guidlines state that the use of Green Beltshould only occur in very special circumstances these and the Brownfield sites in Runnymede must be extensively researched

I live in Wilson Drive and for many years now when i leave my house to go into the village or elsewhere thereis often gridlock in every direction The roads in our community are so heavily used by cars and lorries headingtoward the M25 Can you imagine the impact so many more of these will bring Driving has not been a pleasurefor a long time and i do walk wherever possible Parking is a problem in the village as so many people use theone car park I believe there may be a plan in the pipeline to even get rid of that for road widening

We have a GP practice in the village that is getting harder to book an appointment for also i have been waitingmonths for an appointment at St Peters hospital and just keep getting apologetic letters

Quality of life is very important for your residents and that quality has already deteriorated lately

1888

In order to accomodate so many new residents you will be making the ones you have feel very disappointedand frustated that no one listens

There is no going back once the desicion has been made and so many houses built Please take my feelings and iam sure very many more residents comments and pleas into account before you make the irreversible decisionto go ahead with your plans

Yours Faithfully

Margaret Wensley and the Wensley family

Beechwood

Wilson Drive

Ottershaw

Surrey

KT16 0NT

----------- middotn==middot =

Planning Services

DELIVERED BY HAND

Runnymede Borough Council ~--------------=-middot ---------middot------~

Planning Dept Runnymede Borough Council Civic Offices Station Road Addlestone KT15 2AH

Dear Sirs

Catherine Brunton-Green 20The Glen Addlestone

KT151AQ

15th February 2018

Runnymede Draft local Plan 2015- 2030- Final Consultation

I have serious concerns in respect of this draft plan Runnymede Borough Council (RBC) have a duty of care to consult with listen and act upon the wishes of its residents There has been some consultation but this has not effectively reached all Runnymede residents Communication is unnecessarily legally complex and full of unexplained acronyms The basic Runnymede Voice delivered to every home has been abandoned There has been no flyer delivered to every home stating in a simplified way what is happening so that all abilities may be catered for Many people are isolated for numerous reasons and do not have internet access Neither is there evidence of full in depth cross boundary consultation with adjacent boroughs This local plan is driven primarily by a developers charter promoted by RBCS Head of Planning It is both unfair unjust and I question its soundness

The Strategic Housing Market Assessment has not taken leaving the EU into account and makes a blanket assumption on Heathrow expansion

I strongly object to the proposed loss of c 560 acres of Green Belt Our Prime Minister and government have recently stated that they are quote committed to protecting and enhancing our natural environment for successive generations therefore Green Belt land would only be lost as a last resort 11

bull Detailed evidence based research by The Council for The Protection of Rural England confirms that by fully utilising brownfield land 12 million homes could be built in London and the South East without the loss of any Green Belt

I have objection to building on the Veterinary Laboratory Green Belt Land Parcel BRow Town (Policy SL11 8283) is not justified for development This is designated for 150 additional dwellings and 2 gypsyTraveller pitches This site provides a natural demarcation between developments either side Designated SANG area is privately owned and not available The density of proposed build is unacceptable and above all an area of outstanding natural beauty would be destroyed

Our infrastructure is unable to cope at present A320 suffers perpetual gridlock now Equally gridlock is evidenced through Ottershaw Addlestone Station Road and A317 Addlestone Weybridge We already have unhealthily dangerous levels of roadside nitrogen dioxide concentrations in many areas such as Station Road RBC has made a lame submission in respect of

tackling roadside nitrogen dioxide concentrations in the South East (UK00310) Incidence of exacerbated breathing illnesses in this vicinity has increased dramatically in the past 7 years All age groups are affected

All GP surgeries across Runnymede have great difficulty in recruiting doctors Two practices in the immediate area are merging due to unprecedented numbers of doctors leaving and retiring Practice lists and capacity is stretched Patient access to services and patient safety has to be the highest priority Our schools are similarly affected

RBC infrastructure is totally reliant upon Surrey County Council who declare they are not in a financial position to fund the necessary support to develop the infrastructure for this Local Plan

I am prepared to speak at Public Enquiry

Yours faithfully

bull i I I bull bull

From Brian PickettTo Planning PolicySubject Runnymede 2030 Local Plan - submission of viewsDate 22 February 2018 090921Attachments Ottershaw development Objection letter February 2018docx

Please find attached the submission of my views on the Runnymede 2030 LocalPlan

Kind RegardsBrian Pickett

1891

planningrunnymedegovuk planningrunnymedegovuk

21022018

Re Runnymede 2030 Local Plan Ottershaw East ndash Objection to planning

Dear Sirs

We are writing to you again as we strongly object to the Runnymede Borough Councils plans to remove land behind houses along Brox Road known as lsquoOttershaw Eastrsquo from the Green Belt We are objecting for a number of reasons listed below

middot The Green Belt is precious once it is gone it is gone forever The removal of this land from the Green Belt does not comply with Planning Policy which states ldquothat Green Belt boundaries should only be altered in exceptional circumstancesrdquo there are no such circumstances that can justify the removal of this piece of land

middot The Green Belt should be an area that is preserved for future generations to enjoy and appreciate and many statements have been made by both the Government and members of Parliament on their commitment to protect the Green Belt ndash these statements now need to be converted into action in the Local Borough Plans The roll out of Green Belt to local councils in the 1950rsquos was to prevent urban sprawl and the merging of settlements thereby helping to preserve and protect the character of communities it encompassed protect the country setting and encourage development through regeneration of sites within towns and cities not villages

middot The description of Ottershaw by the council itself in the lsquoUrban Characteristicsrsquo publication on the Runnymede Borough Council website states ldquoOttershaw has its own identity and sense of place which is partly derived from the clearly identifiable heart of the urban area focused on The Otter and adjoining local shopping parade and community facilities as well as being surrounded by open greenbelt countryside Removing this green belt that is part of the identifiable heart of Ottershaw would destroy this villagersquos identity and community

middot The planning proposals and building on this part of the green belt land would lead to a considerable population increase in the village Services and facilities will struggle or fail to cope space is already limited at the doctorrsquos surgery and school places are at capacity The transport infrastructure is already stretched with limited bus services busy roads poorly maintained pavements and road surfaces Brox road is already used as a shortcut to avoid traffic congestion Given that Ottershaw does not have a train station it is reasonable to assume that the majority of houses would have at least one car the added traffic from the new development would put a severe strain on the road network and users Available information on mitigation is very vague and very open to interpretation and misguided assumptions

middot The Green Belt land is a habitat to an array of plants and animals including important pollinator species and larger animals such as birds foxes and deer There should be no assumption that animals will simply move to another area habitats are established over many years and this development will be another loss to the maintenance of biodiversity I enjoy the fauna and flora in these areas going for walks along the public footpaths Having such wonderful access to a relaxing escape so close to home is priceless and something I hold dear to myself my family and community What is now a beautiful scenic view will become a spoilt urban sprawl of modern housing

middot I moved to Ottershaw with my wife in 2016 to settle down and start a family The relaxed quiet village sense of community and safety surrounded by beautiful countryside were its appeal I are very concerned and disappointed that this planning proposal is still being considered which will undoubtedly destroy this idyllic setting

There are no ldquoexceptional or very special circumstancesrdquo that justify the removal of Ottershaw East from the Green Belt We trust that the Council will therefore not remove ldquoOttershaw Eastrdquo and ldquoThe Fieldrdquo from the Green Belt

Yours faithfully

Dr Brian Pickett

To Policy Planning and Strategy Team Runnymede Borough Council Civic Centre Station Road Addlestone Surrey KT15 2AH planningrunnymedegovuk

From Dr Brian Pickett 139 Brox Road Ottershaw Surrey KT16 0LG planningrunnymedegovuk

21022018 Re Runnymede 2030 Local Plan Ottershaw East ndash Objection to planning Dear Sirs We are writing to you again as we strongly object to the Runnymede Borough Councils plans to remove land behind houses along Brox Road known as lsquoOttershaw Eastrsquo from the Green Belt We are objecting for a number of reasons listed below bull The Green Belt is precious once it is gone it is gone forever The removal of this

land from the Green Belt does not comply with Planning Policy which states ldquothat Green Belt boundaries should only be altered in exceptional circumstancesrdquo there are no such circumstances that can justify the removal of this piece of land

bull The Green Belt should be an area that is preserved for future generations to enjoy

and appreciate and many statements have been made by both the Government and members of Parliament on their commitment to protect the Green Belt ndash these statements now need to be converted into action in the Local Borough Plans The roll out of Green Belt to local councils in the 1950rsquos was to prevent urban sprawl and the merging of settlements thereby helping to preserve and protect the character of communities it encompassed protect the country setting and encourage development through regeneration of sites within towns and cities not villages

bull The description of Ottershaw by the council itself in the lsquoUrban Characteristicsrsquo

publication on the Runnymede Borough Council website states ldquoOttershaw has its own identity and sense of place which is partly derived from the clearly identifiable heart of the urban area focused on The Otter and adjoining local shopping parade and community facilities as well as being surrounded by open greenbelt countryside Removing this green belt that is part of the identifiable heart of Ottershaw would destroy this villagersquos identity and community

bull The planning proposals and building on this part of the green belt land would lead

to a considerable population increase in the village Services and facilities will struggle or fail to cope space is already limited at the doctorrsquos surgery and school places are at capacity The transport infrastructure is already stretched with limited bus services busy roads poorly maintained pavements and road surfaces Brox road is already used as a shortcut to avoid traffic congestion Given that Ottershaw does not have a train station it is reasonable to assume that the majority of houses would have at least one car the added traffic from the new development would put a severe strain on the road network and users Available information on mitigation is very vague and very open to interpretation and misguided assumptions

bull The Green Belt land is a habitat to an array of plants and animals including important pollinator species and larger animals such as birds foxes and deer There should be no assumption that animals will simply move to another area habitats are established over many years and this development will be another loss to the maintenance of biodiversity I enjoy the fauna and flora in these areas going for walks along the public footpaths Having such wonderful access to a relaxing escape so close to home is priceless and something I hold dear to myself my family and community What is now a beautiful scenic view will become a spoilt urban sprawl of modern housing

bull I moved to Ottershaw with my wife in 2016 to settle down and start a family The

relaxed quiet village sense of community and safety surrounded by beautiful countryside were its appeal I are very concerned and disappointed that this planning proposal is still being considered which will undoubtedly destroy this idyllic setting

There are no ldquoexceptional or very special circumstancesrdquo that justify the removal of Ottershaw East from the Green Belt We trust that the Council will therefore not remove ldquoOttershaw Eastrdquo and ldquoThe Fieldrdquo from the Green Belt Yours faithfully Dr Brian Pickett

FromTo Planning PolicySubject Runnymede Local Plan 2030 - consultation responseDate 21 February 2018 163608Attachments Runnymede LP Response - EE15pdf

Please find attached a consultation response form

________________________________________Christian Leigh BSc(Hons) MPhil MRTPIDirectorLeigh amp Glennie Ltd6 All Souls RoadAscotBerkshire SL5 9EA

1893

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number 01344 297094 Email Address (where relevant)

mailchristianleighcouk

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number Email Address (where relevant)

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

From MCNAB DouglasTo Planning PolicySubject Runnymede Draft Local Plan consultation - Representation from Education and Skills Funding AgencyDate 21 February 2018 091407Attachments Runnymede Reg 19 response ESFADOC

Dear Runnymede Planning Policy Team

Please see attached a representation from the Education and Skills Funding Agency on theRunnymede Local Plan consultation

I would be grateful if you could confirm receipt

Best regardsDoug

Douglas McNab MRTPIForward Planning Manager ndash South East

Planning Team Free Schools CapitalEducation and Skills Funding AgencyDepartment for Education 5th floor Sanctuary Buildings 20 Great Smith Street London SW1P 3BT

Email douglasmcnabeducationgovukMobile 07990 082877Web wwwgovukesfa

1895

image1pngOur Ref ESFALocal PlanRunnymede 2018 21st February 2018

Dear SirMadam

Re Runnymede Local Plan

Consultation under Regulation 19 of Town and Country Planning (Local Planning) (England) Regulations 2012

Submission of the Education and Skills Funding Agency

1 The Education and Skills Funding Agency (ESFA) welcomes the opportunity to contribute to the development of planning policy at the local level

2 The ESFA launched on 1st April 2017 bringing together the existing responsibilities of the Education Funding Agency (EFA) and the Skills Funding Agency (SFA) to create a single funding agency accountable for funding education and training for children young people and adults The ESFA are accountable for pound61 billion of funding a year for the education and training sector including support for all state-provided education for 8 million children aged 3 to 16 and 16 million young people aged 16 to 19

3 Under the provisions of the Education Act 2011 and the Academies Act 2010 all new state schools are now academiesfree schools and the ESFA is the delivery body for many of these rather than local education authorities As such we aim to work closely with local authority education departments and planning authorities to meet the demand for new school places and new schools We do this through a variety of means including by supporting the adoption of sound local plan policies site allocations and guidance (all based on robust evidence) that facilitate the delivery of education infrastructure where and when it is needed and maximise developer contributions for schools In this capacity we would like to offer the following comments in response to the proposals outlined in the above consultation document

Comments on the Local Plan

4 As you will be aware the primary focus at this stage of the Local Planrsquos preparation is on the soundness of the plan with regard to it being positively prepared justified effective and consistent with national policy The following detailed comments set out the ESFArsquos view of the planrsquos soundness in respect of education provision

5 The ESFA notes that the local plan will make provision for a minimum of 7413 net additional dwellings over the plan period Development will generally complement the existing settlement pattern focusing the largest amounts of residential growth primarily in Chertsey (1950 homes) Addlestone (936 homes) and Egham (812 homes) A new ldquolocally led garden villagerdquo is also proposed at Longcross providing a further 1718 homes This level of development will put pressure on existing education infrastructure

6 The plan recognises that ldquoIt is important that infrastructure is delivered in a timely manner to ensure that the needs of the occupiers of new development can be met without placing undue burdens on existing infrastructure facilities and servicesrdquo (para 560) The ESFA supports Policy SD6 Infrastructure Provision amp Timing particularly the signposting of the Infrastructure Delivery Plan (IDP) and the need for development to deliver this either on-site or through s106 or CIL financial contributions off-site and the need for development to be phased in line with the provision of important supporting infrastructure

7 The latest version of the IDP states that there is an ongoing programme of primary school expansions this will help to meet the forecast need for 4-6FE of new capacity over the plan period The need for one new build school project is identified a 2FE primary school at the Longcross Garden Village (estimated cost pound99M to pound15M) this is referred to in the site allocation policies (see below) With respect to secondary school places it is anticipated that up to six additional FE could be required in the Borough by 2021 Additional places will be delivered through the new 6FE Runnymede Free School (which opened in temporary accommodation in 2017) development of additional FE within Salesian School (Catholic faith school) and expansion of another school in the Chertsey area (to accommodate demand from generated by the Longcross Garden Village site)

8 It would be useful if the background data informing these projections of need could be clarified particularly the pupil yield factors used and the evidence base supporting this This would help to demonstrate more clearly to the Inspector that the approach to the planning and delivery of education infrastructure has been positively prepared based on a strategy which seeks to meet objectively assessed infrastructure requirements and is justified based on proportionate evidence The ESFA notes that the Runnymede S106 SPG sets out pupil yield figures however this document dates from December 2007 so the figures may be outdated

9 The ESFA supports the Councilrsquos allocation and safeguarding of land for schools as set out in the following policies

middot Policy SD10 Longcross Garden Village - 2FE primary school with preschoolearly years settings

middot Policy SL2 to SL18 ndash series of housing allocation policies that highlight the need to make a financial contribution to early years primary and secondary school infrastructure ldquoeither through S106 or CIL (or its successor)rdquo

Developer Contributions and CIL

10 One of the tests of soundness is that a Local Plan is lsquoeffectiversquo ie the plan should be deliverable over its period In this context and with specific regard to planning for schools there is a need to ensure that education contributions made by developers are sufficient to deliver the additional school places required to meet the increase in demand generated by new developments The ESFA notes that the council has not adopted CIL and that the Planning Obligations SPG sets out how developer contributions to education provision will be secured via section 106 agreements The ESFA supports the Councilrsquos approach to ensure developer contributions address the impacts arising from growth However the ESFA recommends that the Local Plan includes a commitment to revise the Planning Obligations SPG in line with the latest evidence of the boroughrsquos infrastructure needs pupil yields and build costs (including the cost of school expansion new build and SEN provision) Any such review should be prepared in consultation with the county council as local education authority This will help to ensure appropriate rates are levied and the right infrastructure is secured across the borough

11 The ESFA would be particularly interested in responding to any update to the Infrastructure Delivery Plan or review of infrastructure requirements As such please add the ESFA to the database for future CIL consultations

Forward funding

12 In light of the proposed Longcross Garden Village emerging ESFA proposals for forward funding schools as part of large residential developments may be relevant for example if viability becomes an issue The ESFA aims to be able to clarify forward funding options for schools in 2018 We would be happy to meet to discuss this opportunity further once the options have been finalised and ifwhen relevant Any offer of forward funding would seek to maximise developer contributions to education infrastructure provision while supporting delivery of schools where and when they are needed

Conclusion

13 Finally I hope the above comments are helpful in finalising the Runnymede Local Plan with specific regard to the provision of land for new schools

14 Please notify the ESFA when the Local Plan is submitted for examination the Inspectorrsquos report is published and the Local Plan is adopted

15 Please do not hesitate to contact me if you have any queries regarding this response The ESFA looks forward to continuing to work with Runnymede Borough Council to develop a sound Local Plan that will aid in the delivery of new schools

Yours faithfully

DC McNab

Douglas McNab MRTPI

Forward Planning Manager

Tel 07990 082877

Email

douglasmcnabeducationgovuk

Web

wwwgovuk esfa

Education and Skills Funding Agency13

Department for EducationSanctuary BuildingsGreat Smith StreetLondonSW1P 3BT13

13

Tel 0207 340 700013

13

wwwgovukesfa13

13

13

To

Policy Planning and Strategy Team

Runnymede Borough Council

Civic Centre

Station Road

Addlestone

Surrey

KT15 2AH

From

Dr Brian Pickett

139 Brox Road

Ottershaw

Surrey

KT16 0LG

Page 20: Runnymede Borough Council, for submissions. My contact details are all in the WORD letter attached. But I will provide my telephone number here too, which …

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan 1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination 42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

FromPolicy

Subject FW New Housing Plans 2015-2030Date 21 February 2018 164919

Sent 21 February 2018 1608To PlanningSubject New Housing Plans 2015-2030

To

Policy Planning and Strategy Team

Runnymede Borough Council

Station Road

Addlestone

21022018

Dear Sirs

As an Ottershaw resident of nearly 30 years i would like you to read and take on board my objections to yourproposal to take land out of the green belt for housing and your plan to build so many houses in ourcommunity

Of course new houses have to be built right across the country now and in the future but i feel the plans youhave are for far too many houses The infrastructure of our community will just not sustain the extra amount ofpeople and cars and the general traffic that would entail

There are other possibilities available before your irreversible plans are put into action Are these possibilitiesbeing resourced

When i drive around the borough now and for a long long time i see so many empty office blocks Some ofthese have stood empty for yearsWhy has permission been given continuosly from what i can see on a huge scale for these to be built

This building of offices has to stop and the ones that have remained empty for years could be converted tohousing as in flats starter homes for young people

If Planning Practice Guidlines state that the use of Green Beltshould only occur in very special circumstances these and the Brownfield sites in Runnymede must be extensively researched

I live in Wilson Drive and for many years now when i leave my house to go into the village or elsewhere thereis often gridlock in every direction The roads in our community are so heavily used by cars and lorries headingtoward the M25 Can you imagine the impact so many more of these will bring Driving has not been a pleasurefor a long time and i do walk wherever possible Parking is a problem in the village as so many people use theone car park I believe there may be a plan in the pipeline to even get rid of that for road widening

We have a GP practice in the village that is getting harder to book an appointment for also i have been waitingmonths for an appointment at St Peters hospital and just keep getting apologetic letters

Quality of life is very important for your residents and that quality has already deteriorated lately

1888

In order to accomodate so many new residents you will be making the ones you have feel very disappointedand frustated that no one listens

There is no going back once the desicion has been made and so many houses built Please take my feelings and iam sure very many more residents comments and pleas into account before you make the irreversible decisionto go ahead with your plans

Yours Faithfully

Margaret Wensley and the Wensley family

Beechwood

Wilson Drive

Ottershaw

Surrey

KT16 0NT

----------- middotn==middot =

Planning Services

DELIVERED BY HAND

Runnymede Borough Council ~--------------=-middot ---------middot------~

Planning Dept Runnymede Borough Council Civic Offices Station Road Addlestone KT15 2AH

Dear Sirs

Catherine Brunton-Green 20The Glen Addlestone

KT151AQ

15th February 2018

Runnymede Draft local Plan 2015- 2030- Final Consultation

I have serious concerns in respect of this draft plan Runnymede Borough Council (RBC) have a duty of care to consult with listen and act upon the wishes of its residents There has been some consultation but this has not effectively reached all Runnymede residents Communication is unnecessarily legally complex and full of unexplained acronyms The basic Runnymede Voice delivered to every home has been abandoned There has been no flyer delivered to every home stating in a simplified way what is happening so that all abilities may be catered for Many people are isolated for numerous reasons and do not have internet access Neither is there evidence of full in depth cross boundary consultation with adjacent boroughs This local plan is driven primarily by a developers charter promoted by RBCS Head of Planning It is both unfair unjust and I question its soundness

The Strategic Housing Market Assessment has not taken leaving the EU into account and makes a blanket assumption on Heathrow expansion

I strongly object to the proposed loss of c 560 acres of Green Belt Our Prime Minister and government have recently stated that they are quote committed to protecting and enhancing our natural environment for successive generations therefore Green Belt land would only be lost as a last resort 11

bull Detailed evidence based research by The Council for The Protection of Rural England confirms that by fully utilising brownfield land 12 million homes could be built in London and the South East without the loss of any Green Belt

I have objection to building on the Veterinary Laboratory Green Belt Land Parcel BRow Town (Policy SL11 8283) is not justified for development This is designated for 150 additional dwellings and 2 gypsyTraveller pitches This site provides a natural demarcation between developments either side Designated SANG area is privately owned and not available The density of proposed build is unacceptable and above all an area of outstanding natural beauty would be destroyed

Our infrastructure is unable to cope at present A320 suffers perpetual gridlock now Equally gridlock is evidenced through Ottershaw Addlestone Station Road and A317 Addlestone Weybridge We already have unhealthily dangerous levels of roadside nitrogen dioxide concentrations in many areas such as Station Road RBC has made a lame submission in respect of

tackling roadside nitrogen dioxide concentrations in the South East (UK00310) Incidence of exacerbated breathing illnesses in this vicinity has increased dramatically in the past 7 years All age groups are affected

All GP surgeries across Runnymede have great difficulty in recruiting doctors Two practices in the immediate area are merging due to unprecedented numbers of doctors leaving and retiring Practice lists and capacity is stretched Patient access to services and patient safety has to be the highest priority Our schools are similarly affected

RBC infrastructure is totally reliant upon Surrey County Council who declare they are not in a financial position to fund the necessary support to develop the infrastructure for this Local Plan

I am prepared to speak at Public Enquiry

Yours faithfully

bull i I I bull bull

From Brian PickettTo Planning PolicySubject Runnymede 2030 Local Plan - submission of viewsDate 22 February 2018 090921Attachments Ottershaw development Objection letter February 2018docx

Please find attached the submission of my views on the Runnymede 2030 LocalPlan

Kind RegardsBrian Pickett

1891

planningrunnymedegovuk planningrunnymedegovuk

21022018

Re Runnymede 2030 Local Plan Ottershaw East ndash Objection to planning

Dear Sirs

We are writing to you again as we strongly object to the Runnymede Borough Councils plans to remove land behind houses along Brox Road known as lsquoOttershaw Eastrsquo from the Green Belt We are objecting for a number of reasons listed below

middot The Green Belt is precious once it is gone it is gone forever The removal of this land from the Green Belt does not comply with Planning Policy which states ldquothat Green Belt boundaries should only be altered in exceptional circumstancesrdquo there are no such circumstances that can justify the removal of this piece of land

middot The Green Belt should be an area that is preserved for future generations to enjoy and appreciate and many statements have been made by both the Government and members of Parliament on their commitment to protect the Green Belt ndash these statements now need to be converted into action in the Local Borough Plans The roll out of Green Belt to local councils in the 1950rsquos was to prevent urban sprawl and the merging of settlements thereby helping to preserve and protect the character of communities it encompassed protect the country setting and encourage development through regeneration of sites within towns and cities not villages

middot The description of Ottershaw by the council itself in the lsquoUrban Characteristicsrsquo publication on the Runnymede Borough Council website states ldquoOttershaw has its own identity and sense of place which is partly derived from the clearly identifiable heart of the urban area focused on The Otter and adjoining local shopping parade and community facilities as well as being surrounded by open greenbelt countryside Removing this green belt that is part of the identifiable heart of Ottershaw would destroy this villagersquos identity and community

middot The planning proposals and building on this part of the green belt land would lead to a considerable population increase in the village Services and facilities will struggle or fail to cope space is already limited at the doctorrsquos surgery and school places are at capacity The transport infrastructure is already stretched with limited bus services busy roads poorly maintained pavements and road surfaces Brox road is already used as a shortcut to avoid traffic congestion Given that Ottershaw does not have a train station it is reasonable to assume that the majority of houses would have at least one car the added traffic from the new development would put a severe strain on the road network and users Available information on mitigation is very vague and very open to interpretation and misguided assumptions

middot The Green Belt land is a habitat to an array of plants and animals including important pollinator species and larger animals such as birds foxes and deer There should be no assumption that animals will simply move to another area habitats are established over many years and this development will be another loss to the maintenance of biodiversity I enjoy the fauna and flora in these areas going for walks along the public footpaths Having such wonderful access to a relaxing escape so close to home is priceless and something I hold dear to myself my family and community What is now a beautiful scenic view will become a spoilt urban sprawl of modern housing

middot I moved to Ottershaw with my wife in 2016 to settle down and start a family The relaxed quiet village sense of community and safety surrounded by beautiful countryside were its appeal I are very concerned and disappointed that this planning proposal is still being considered which will undoubtedly destroy this idyllic setting

There are no ldquoexceptional or very special circumstancesrdquo that justify the removal of Ottershaw East from the Green Belt We trust that the Council will therefore not remove ldquoOttershaw Eastrdquo and ldquoThe Fieldrdquo from the Green Belt

Yours faithfully

Dr Brian Pickett

To Policy Planning and Strategy Team Runnymede Borough Council Civic Centre Station Road Addlestone Surrey KT15 2AH planningrunnymedegovuk

From Dr Brian Pickett 139 Brox Road Ottershaw Surrey KT16 0LG planningrunnymedegovuk

21022018 Re Runnymede 2030 Local Plan Ottershaw East ndash Objection to planning Dear Sirs We are writing to you again as we strongly object to the Runnymede Borough Councils plans to remove land behind houses along Brox Road known as lsquoOttershaw Eastrsquo from the Green Belt We are objecting for a number of reasons listed below bull The Green Belt is precious once it is gone it is gone forever The removal of this

land from the Green Belt does not comply with Planning Policy which states ldquothat Green Belt boundaries should only be altered in exceptional circumstancesrdquo there are no such circumstances that can justify the removal of this piece of land

bull The Green Belt should be an area that is preserved for future generations to enjoy

and appreciate and many statements have been made by both the Government and members of Parliament on their commitment to protect the Green Belt ndash these statements now need to be converted into action in the Local Borough Plans The roll out of Green Belt to local councils in the 1950rsquos was to prevent urban sprawl and the merging of settlements thereby helping to preserve and protect the character of communities it encompassed protect the country setting and encourage development through regeneration of sites within towns and cities not villages

bull The description of Ottershaw by the council itself in the lsquoUrban Characteristicsrsquo

publication on the Runnymede Borough Council website states ldquoOttershaw has its own identity and sense of place which is partly derived from the clearly identifiable heart of the urban area focused on The Otter and adjoining local shopping parade and community facilities as well as being surrounded by open greenbelt countryside Removing this green belt that is part of the identifiable heart of Ottershaw would destroy this villagersquos identity and community

bull The planning proposals and building on this part of the green belt land would lead

to a considerable population increase in the village Services and facilities will struggle or fail to cope space is already limited at the doctorrsquos surgery and school places are at capacity The transport infrastructure is already stretched with limited bus services busy roads poorly maintained pavements and road surfaces Brox road is already used as a shortcut to avoid traffic congestion Given that Ottershaw does not have a train station it is reasonable to assume that the majority of houses would have at least one car the added traffic from the new development would put a severe strain on the road network and users Available information on mitigation is very vague and very open to interpretation and misguided assumptions

bull The Green Belt land is a habitat to an array of plants and animals including important pollinator species and larger animals such as birds foxes and deer There should be no assumption that animals will simply move to another area habitats are established over many years and this development will be another loss to the maintenance of biodiversity I enjoy the fauna and flora in these areas going for walks along the public footpaths Having such wonderful access to a relaxing escape so close to home is priceless and something I hold dear to myself my family and community What is now a beautiful scenic view will become a spoilt urban sprawl of modern housing

bull I moved to Ottershaw with my wife in 2016 to settle down and start a family The

relaxed quiet village sense of community and safety surrounded by beautiful countryside were its appeal I are very concerned and disappointed that this planning proposal is still being considered which will undoubtedly destroy this idyllic setting

There are no ldquoexceptional or very special circumstancesrdquo that justify the removal of Ottershaw East from the Green Belt We trust that the Council will therefore not remove ldquoOttershaw Eastrdquo and ldquoThe Fieldrdquo from the Green Belt Yours faithfully Dr Brian Pickett

FromTo Planning PolicySubject Runnymede Local Plan 2030 - consultation responseDate 21 February 2018 163608Attachments Runnymede LP Response - EE15pdf

Please find attached a consultation response form

________________________________________Christian Leigh BSc(Hons) MPhil MRTPIDirectorLeigh amp Glennie Ltd6 All Souls RoadAscotBerkshire SL5 9EA

1893

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number 01344 297094 Email Address (where relevant)

mailchristianleighcouk

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number Email Address (where relevant)

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

From MCNAB DouglasTo Planning PolicySubject Runnymede Draft Local Plan consultation - Representation from Education and Skills Funding AgencyDate 21 February 2018 091407Attachments Runnymede Reg 19 response ESFADOC

Dear Runnymede Planning Policy Team

Please see attached a representation from the Education and Skills Funding Agency on theRunnymede Local Plan consultation

I would be grateful if you could confirm receipt

Best regardsDoug

Douglas McNab MRTPIForward Planning Manager ndash South East

Planning Team Free Schools CapitalEducation and Skills Funding AgencyDepartment for Education 5th floor Sanctuary Buildings 20 Great Smith Street London SW1P 3BT

Email douglasmcnabeducationgovukMobile 07990 082877Web wwwgovukesfa

1895

image1pngOur Ref ESFALocal PlanRunnymede 2018 21st February 2018

Dear SirMadam

Re Runnymede Local Plan

Consultation under Regulation 19 of Town and Country Planning (Local Planning) (England) Regulations 2012

Submission of the Education and Skills Funding Agency

1 The Education and Skills Funding Agency (ESFA) welcomes the opportunity to contribute to the development of planning policy at the local level

2 The ESFA launched on 1st April 2017 bringing together the existing responsibilities of the Education Funding Agency (EFA) and the Skills Funding Agency (SFA) to create a single funding agency accountable for funding education and training for children young people and adults The ESFA are accountable for pound61 billion of funding a year for the education and training sector including support for all state-provided education for 8 million children aged 3 to 16 and 16 million young people aged 16 to 19

3 Under the provisions of the Education Act 2011 and the Academies Act 2010 all new state schools are now academiesfree schools and the ESFA is the delivery body for many of these rather than local education authorities As such we aim to work closely with local authority education departments and planning authorities to meet the demand for new school places and new schools We do this through a variety of means including by supporting the adoption of sound local plan policies site allocations and guidance (all based on robust evidence) that facilitate the delivery of education infrastructure where and when it is needed and maximise developer contributions for schools In this capacity we would like to offer the following comments in response to the proposals outlined in the above consultation document

Comments on the Local Plan

4 As you will be aware the primary focus at this stage of the Local Planrsquos preparation is on the soundness of the plan with regard to it being positively prepared justified effective and consistent with national policy The following detailed comments set out the ESFArsquos view of the planrsquos soundness in respect of education provision

5 The ESFA notes that the local plan will make provision for a minimum of 7413 net additional dwellings over the plan period Development will generally complement the existing settlement pattern focusing the largest amounts of residential growth primarily in Chertsey (1950 homes) Addlestone (936 homes) and Egham (812 homes) A new ldquolocally led garden villagerdquo is also proposed at Longcross providing a further 1718 homes This level of development will put pressure on existing education infrastructure

6 The plan recognises that ldquoIt is important that infrastructure is delivered in a timely manner to ensure that the needs of the occupiers of new development can be met without placing undue burdens on existing infrastructure facilities and servicesrdquo (para 560) The ESFA supports Policy SD6 Infrastructure Provision amp Timing particularly the signposting of the Infrastructure Delivery Plan (IDP) and the need for development to deliver this either on-site or through s106 or CIL financial contributions off-site and the need for development to be phased in line with the provision of important supporting infrastructure

7 The latest version of the IDP states that there is an ongoing programme of primary school expansions this will help to meet the forecast need for 4-6FE of new capacity over the plan period The need for one new build school project is identified a 2FE primary school at the Longcross Garden Village (estimated cost pound99M to pound15M) this is referred to in the site allocation policies (see below) With respect to secondary school places it is anticipated that up to six additional FE could be required in the Borough by 2021 Additional places will be delivered through the new 6FE Runnymede Free School (which opened in temporary accommodation in 2017) development of additional FE within Salesian School (Catholic faith school) and expansion of another school in the Chertsey area (to accommodate demand from generated by the Longcross Garden Village site)

8 It would be useful if the background data informing these projections of need could be clarified particularly the pupil yield factors used and the evidence base supporting this This would help to demonstrate more clearly to the Inspector that the approach to the planning and delivery of education infrastructure has been positively prepared based on a strategy which seeks to meet objectively assessed infrastructure requirements and is justified based on proportionate evidence The ESFA notes that the Runnymede S106 SPG sets out pupil yield figures however this document dates from December 2007 so the figures may be outdated

9 The ESFA supports the Councilrsquos allocation and safeguarding of land for schools as set out in the following policies

middot Policy SD10 Longcross Garden Village - 2FE primary school with preschoolearly years settings

middot Policy SL2 to SL18 ndash series of housing allocation policies that highlight the need to make a financial contribution to early years primary and secondary school infrastructure ldquoeither through S106 or CIL (or its successor)rdquo

Developer Contributions and CIL

10 One of the tests of soundness is that a Local Plan is lsquoeffectiversquo ie the plan should be deliverable over its period In this context and with specific regard to planning for schools there is a need to ensure that education contributions made by developers are sufficient to deliver the additional school places required to meet the increase in demand generated by new developments The ESFA notes that the council has not adopted CIL and that the Planning Obligations SPG sets out how developer contributions to education provision will be secured via section 106 agreements The ESFA supports the Councilrsquos approach to ensure developer contributions address the impacts arising from growth However the ESFA recommends that the Local Plan includes a commitment to revise the Planning Obligations SPG in line with the latest evidence of the boroughrsquos infrastructure needs pupil yields and build costs (including the cost of school expansion new build and SEN provision) Any such review should be prepared in consultation with the county council as local education authority This will help to ensure appropriate rates are levied and the right infrastructure is secured across the borough

11 The ESFA would be particularly interested in responding to any update to the Infrastructure Delivery Plan or review of infrastructure requirements As such please add the ESFA to the database for future CIL consultations

Forward funding

12 In light of the proposed Longcross Garden Village emerging ESFA proposals for forward funding schools as part of large residential developments may be relevant for example if viability becomes an issue The ESFA aims to be able to clarify forward funding options for schools in 2018 We would be happy to meet to discuss this opportunity further once the options have been finalised and ifwhen relevant Any offer of forward funding would seek to maximise developer contributions to education infrastructure provision while supporting delivery of schools where and when they are needed

Conclusion

13 Finally I hope the above comments are helpful in finalising the Runnymede Local Plan with specific regard to the provision of land for new schools

14 Please notify the ESFA when the Local Plan is submitted for examination the Inspectorrsquos report is published and the Local Plan is adopted

15 Please do not hesitate to contact me if you have any queries regarding this response The ESFA looks forward to continuing to work with Runnymede Borough Council to develop a sound Local Plan that will aid in the delivery of new schools

Yours faithfully

DC McNab

Douglas McNab MRTPI

Forward Planning Manager

Tel 07990 082877

Email

douglasmcnabeducationgovuk

Web

wwwgovuk esfa

Education and Skills Funding Agency13

Department for EducationSanctuary BuildingsGreat Smith StreetLondonSW1P 3BT13

13

Tel 0207 340 700013

13

wwwgovukesfa13

13

13

To

Policy Planning and Strategy Team

Runnymede Borough Council

Civic Centre

Station Road

Addlestone

Surrey

KT15 2AH

From

Dr Brian Pickett

139 Brox Road

Ottershaw

Surrey

KT16 0LG

Page 21: Runnymede Borough Council, for submissions. My contact details are all in the WORD letter attached. But I will provide my telephone number here too, which …

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination 42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

FromPolicy

Subject FW New Housing Plans 2015-2030Date 21 February 2018 164919

Sent 21 February 2018 1608To PlanningSubject New Housing Plans 2015-2030

To

Policy Planning and Strategy Team

Runnymede Borough Council

Station Road

Addlestone

21022018

Dear Sirs

As an Ottershaw resident of nearly 30 years i would like you to read and take on board my objections to yourproposal to take land out of the green belt for housing and your plan to build so many houses in ourcommunity

Of course new houses have to be built right across the country now and in the future but i feel the plans youhave are for far too many houses The infrastructure of our community will just not sustain the extra amount ofpeople and cars and the general traffic that would entail

There are other possibilities available before your irreversible plans are put into action Are these possibilitiesbeing resourced

When i drive around the borough now and for a long long time i see so many empty office blocks Some ofthese have stood empty for yearsWhy has permission been given continuosly from what i can see on a huge scale for these to be built

This building of offices has to stop and the ones that have remained empty for years could be converted tohousing as in flats starter homes for young people

If Planning Practice Guidlines state that the use of Green Beltshould only occur in very special circumstances these and the Brownfield sites in Runnymede must be extensively researched

I live in Wilson Drive and for many years now when i leave my house to go into the village or elsewhere thereis often gridlock in every direction The roads in our community are so heavily used by cars and lorries headingtoward the M25 Can you imagine the impact so many more of these will bring Driving has not been a pleasurefor a long time and i do walk wherever possible Parking is a problem in the village as so many people use theone car park I believe there may be a plan in the pipeline to even get rid of that for road widening

We have a GP practice in the village that is getting harder to book an appointment for also i have been waitingmonths for an appointment at St Peters hospital and just keep getting apologetic letters

Quality of life is very important for your residents and that quality has already deteriorated lately

1888

In order to accomodate so many new residents you will be making the ones you have feel very disappointedand frustated that no one listens

There is no going back once the desicion has been made and so many houses built Please take my feelings and iam sure very many more residents comments and pleas into account before you make the irreversible decisionto go ahead with your plans

Yours Faithfully

Margaret Wensley and the Wensley family

Beechwood

Wilson Drive

Ottershaw

Surrey

KT16 0NT

----------- middotn==middot =

Planning Services

DELIVERED BY HAND

Runnymede Borough Council ~--------------=-middot ---------middot------~

Planning Dept Runnymede Borough Council Civic Offices Station Road Addlestone KT15 2AH

Dear Sirs

Catherine Brunton-Green 20The Glen Addlestone

KT151AQ

15th February 2018

Runnymede Draft local Plan 2015- 2030- Final Consultation

I have serious concerns in respect of this draft plan Runnymede Borough Council (RBC) have a duty of care to consult with listen and act upon the wishes of its residents There has been some consultation but this has not effectively reached all Runnymede residents Communication is unnecessarily legally complex and full of unexplained acronyms The basic Runnymede Voice delivered to every home has been abandoned There has been no flyer delivered to every home stating in a simplified way what is happening so that all abilities may be catered for Many people are isolated for numerous reasons and do not have internet access Neither is there evidence of full in depth cross boundary consultation with adjacent boroughs This local plan is driven primarily by a developers charter promoted by RBCS Head of Planning It is both unfair unjust and I question its soundness

The Strategic Housing Market Assessment has not taken leaving the EU into account and makes a blanket assumption on Heathrow expansion

I strongly object to the proposed loss of c 560 acres of Green Belt Our Prime Minister and government have recently stated that they are quote committed to protecting and enhancing our natural environment for successive generations therefore Green Belt land would only be lost as a last resort 11

bull Detailed evidence based research by The Council for The Protection of Rural England confirms that by fully utilising brownfield land 12 million homes could be built in London and the South East without the loss of any Green Belt

I have objection to building on the Veterinary Laboratory Green Belt Land Parcel BRow Town (Policy SL11 8283) is not justified for development This is designated for 150 additional dwellings and 2 gypsyTraveller pitches This site provides a natural demarcation between developments either side Designated SANG area is privately owned and not available The density of proposed build is unacceptable and above all an area of outstanding natural beauty would be destroyed

Our infrastructure is unable to cope at present A320 suffers perpetual gridlock now Equally gridlock is evidenced through Ottershaw Addlestone Station Road and A317 Addlestone Weybridge We already have unhealthily dangerous levels of roadside nitrogen dioxide concentrations in many areas such as Station Road RBC has made a lame submission in respect of

tackling roadside nitrogen dioxide concentrations in the South East (UK00310) Incidence of exacerbated breathing illnesses in this vicinity has increased dramatically in the past 7 years All age groups are affected

All GP surgeries across Runnymede have great difficulty in recruiting doctors Two practices in the immediate area are merging due to unprecedented numbers of doctors leaving and retiring Practice lists and capacity is stretched Patient access to services and patient safety has to be the highest priority Our schools are similarly affected

RBC infrastructure is totally reliant upon Surrey County Council who declare they are not in a financial position to fund the necessary support to develop the infrastructure for this Local Plan

I am prepared to speak at Public Enquiry

Yours faithfully

bull i I I bull bull

From Brian PickettTo Planning PolicySubject Runnymede 2030 Local Plan - submission of viewsDate 22 February 2018 090921Attachments Ottershaw development Objection letter February 2018docx

Please find attached the submission of my views on the Runnymede 2030 LocalPlan

Kind RegardsBrian Pickett

1891

planningrunnymedegovuk planningrunnymedegovuk

21022018

Re Runnymede 2030 Local Plan Ottershaw East ndash Objection to planning

Dear Sirs

We are writing to you again as we strongly object to the Runnymede Borough Councils plans to remove land behind houses along Brox Road known as lsquoOttershaw Eastrsquo from the Green Belt We are objecting for a number of reasons listed below

middot The Green Belt is precious once it is gone it is gone forever The removal of this land from the Green Belt does not comply with Planning Policy which states ldquothat Green Belt boundaries should only be altered in exceptional circumstancesrdquo there are no such circumstances that can justify the removal of this piece of land

middot The Green Belt should be an area that is preserved for future generations to enjoy and appreciate and many statements have been made by both the Government and members of Parliament on their commitment to protect the Green Belt ndash these statements now need to be converted into action in the Local Borough Plans The roll out of Green Belt to local councils in the 1950rsquos was to prevent urban sprawl and the merging of settlements thereby helping to preserve and protect the character of communities it encompassed protect the country setting and encourage development through regeneration of sites within towns and cities not villages

middot The description of Ottershaw by the council itself in the lsquoUrban Characteristicsrsquo publication on the Runnymede Borough Council website states ldquoOttershaw has its own identity and sense of place which is partly derived from the clearly identifiable heart of the urban area focused on The Otter and adjoining local shopping parade and community facilities as well as being surrounded by open greenbelt countryside Removing this green belt that is part of the identifiable heart of Ottershaw would destroy this villagersquos identity and community

middot The planning proposals and building on this part of the green belt land would lead to a considerable population increase in the village Services and facilities will struggle or fail to cope space is already limited at the doctorrsquos surgery and school places are at capacity The transport infrastructure is already stretched with limited bus services busy roads poorly maintained pavements and road surfaces Brox road is already used as a shortcut to avoid traffic congestion Given that Ottershaw does not have a train station it is reasonable to assume that the majority of houses would have at least one car the added traffic from the new development would put a severe strain on the road network and users Available information on mitigation is very vague and very open to interpretation and misguided assumptions

middot The Green Belt land is a habitat to an array of plants and animals including important pollinator species and larger animals such as birds foxes and deer There should be no assumption that animals will simply move to another area habitats are established over many years and this development will be another loss to the maintenance of biodiversity I enjoy the fauna and flora in these areas going for walks along the public footpaths Having such wonderful access to a relaxing escape so close to home is priceless and something I hold dear to myself my family and community What is now a beautiful scenic view will become a spoilt urban sprawl of modern housing

middot I moved to Ottershaw with my wife in 2016 to settle down and start a family The relaxed quiet village sense of community and safety surrounded by beautiful countryside were its appeal I are very concerned and disappointed that this planning proposal is still being considered which will undoubtedly destroy this idyllic setting

There are no ldquoexceptional or very special circumstancesrdquo that justify the removal of Ottershaw East from the Green Belt We trust that the Council will therefore not remove ldquoOttershaw Eastrdquo and ldquoThe Fieldrdquo from the Green Belt

Yours faithfully

Dr Brian Pickett

To Policy Planning and Strategy Team Runnymede Borough Council Civic Centre Station Road Addlestone Surrey KT15 2AH planningrunnymedegovuk

From Dr Brian Pickett 139 Brox Road Ottershaw Surrey KT16 0LG planningrunnymedegovuk

21022018 Re Runnymede 2030 Local Plan Ottershaw East ndash Objection to planning Dear Sirs We are writing to you again as we strongly object to the Runnymede Borough Councils plans to remove land behind houses along Brox Road known as lsquoOttershaw Eastrsquo from the Green Belt We are objecting for a number of reasons listed below bull The Green Belt is precious once it is gone it is gone forever The removal of this

land from the Green Belt does not comply with Planning Policy which states ldquothat Green Belt boundaries should only be altered in exceptional circumstancesrdquo there are no such circumstances that can justify the removal of this piece of land

bull The Green Belt should be an area that is preserved for future generations to enjoy

and appreciate and many statements have been made by both the Government and members of Parliament on their commitment to protect the Green Belt ndash these statements now need to be converted into action in the Local Borough Plans The roll out of Green Belt to local councils in the 1950rsquos was to prevent urban sprawl and the merging of settlements thereby helping to preserve and protect the character of communities it encompassed protect the country setting and encourage development through regeneration of sites within towns and cities not villages

bull The description of Ottershaw by the council itself in the lsquoUrban Characteristicsrsquo

publication on the Runnymede Borough Council website states ldquoOttershaw has its own identity and sense of place which is partly derived from the clearly identifiable heart of the urban area focused on The Otter and adjoining local shopping parade and community facilities as well as being surrounded by open greenbelt countryside Removing this green belt that is part of the identifiable heart of Ottershaw would destroy this villagersquos identity and community

bull The planning proposals and building on this part of the green belt land would lead

to a considerable population increase in the village Services and facilities will struggle or fail to cope space is already limited at the doctorrsquos surgery and school places are at capacity The transport infrastructure is already stretched with limited bus services busy roads poorly maintained pavements and road surfaces Brox road is already used as a shortcut to avoid traffic congestion Given that Ottershaw does not have a train station it is reasonable to assume that the majority of houses would have at least one car the added traffic from the new development would put a severe strain on the road network and users Available information on mitigation is very vague and very open to interpretation and misguided assumptions

bull The Green Belt land is a habitat to an array of plants and animals including important pollinator species and larger animals such as birds foxes and deer There should be no assumption that animals will simply move to another area habitats are established over many years and this development will be another loss to the maintenance of biodiversity I enjoy the fauna and flora in these areas going for walks along the public footpaths Having such wonderful access to a relaxing escape so close to home is priceless and something I hold dear to myself my family and community What is now a beautiful scenic view will become a spoilt urban sprawl of modern housing

bull I moved to Ottershaw with my wife in 2016 to settle down and start a family The

relaxed quiet village sense of community and safety surrounded by beautiful countryside were its appeal I are very concerned and disappointed that this planning proposal is still being considered which will undoubtedly destroy this idyllic setting

There are no ldquoexceptional or very special circumstancesrdquo that justify the removal of Ottershaw East from the Green Belt We trust that the Council will therefore not remove ldquoOttershaw Eastrdquo and ldquoThe Fieldrdquo from the Green Belt Yours faithfully Dr Brian Pickett

FromTo Planning PolicySubject Runnymede Local Plan 2030 - consultation responseDate 21 February 2018 163608Attachments Runnymede LP Response - EE15pdf

Please find attached a consultation response form

________________________________________Christian Leigh BSc(Hons) MPhil MRTPIDirectorLeigh amp Glennie Ltd6 All Souls RoadAscotBerkshire SL5 9EA

1893

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number 01344 297094 Email Address (where relevant)

mailchristianleighcouk

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number Email Address (where relevant)

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

From MCNAB DouglasTo Planning PolicySubject Runnymede Draft Local Plan consultation - Representation from Education and Skills Funding AgencyDate 21 February 2018 091407Attachments Runnymede Reg 19 response ESFADOC

Dear Runnymede Planning Policy Team

Please see attached a representation from the Education and Skills Funding Agency on theRunnymede Local Plan consultation

I would be grateful if you could confirm receipt

Best regardsDoug

Douglas McNab MRTPIForward Planning Manager ndash South East

Planning Team Free Schools CapitalEducation and Skills Funding AgencyDepartment for Education 5th floor Sanctuary Buildings 20 Great Smith Street London SW1P 3BT

Email douglasmcnabeducationgovukMobile 07990 082877Web wwwgovukesfa

1895

image1pngOur Ref ESFALocal PlanRunnymede 2018 21st February 2018

Dear SirMadam

Re Runnymede Local Plan

Consultation under Regulation 19 of Town and Country Planning (Local Planning) (England) Regulations 2012

Submission of the Education and Skills Funding Agency

1 The Education and Skills Funding Agency (ESFA) welcomes the opportunity to contribute to the development of planning policy at the local level

2 The ESFA launched on 1st April 2017 bringing together the existing responsibilities of the Education Funding Agency (EFA) and the Skills Funding Agency (SFA) to create a single funding agency accountable for funding education and training for children young people and adults The ESFA are accountable for pound61 billion of funding a year for the education and training sector including support for all state-provided education for 8 million children aged 3 to 16 and 16 million young people aged 16 to 19

3 Under the provisions of the Education Act 2011 and the Academies Act 2010 all new state schools are now academiesfree schools and the ESFA is the delivery body for many of these rather than local education authorities As such we aim to work closely with local authority education departments and planning authorities to meet the demand for new school places and new schools We do this through a variety of means including by supporting the adoption of sound local plan policies site allocations and guidance (all based on robust evidence) that facilitate the delivery of education infrastructure where and when it is needed and maximise developer contributions for schools In this capacity we would like to offer the following comments in response to the proposals outlined in the above consultation document

Comments on the Local Plan

4 As you will be aware the primary focus at this stage of the Local Planrsquos preparation is on the soundness of the plan with regard to it being positively prepared justified effective and consistent with national policy The following detailed comments set out the ESFArsquos view of the planrsquos soundness in respect of education provision

5 The ESFA notes that the local plan will make provision for a minimum of 7413 net additional dwellings over the plan period Development will generally complement the existing settlement pattern focusing the largest amounts of residential growth primarily in Chertsey (1950 homes) Addlestone (936 homes) and Egham (812 homes) A new ldquolocally led garden villagerdquo is also proposed at Longcross providing a further 1718 homes This level of development will put pressure on existing education infrastructure

6 The plan recognises that ldquoIt is important that infrastructure is delivered in a timely manner to ensure that the needs of the occupiers of new development can be met without placing undue burdens on existing infrastructure facilities and servicesrdquo (para 560) The ESFA supports Policy SD6 Infrastructure Provision amp Timing particularly the signposting of the Infrastructure Delivery Plan (IDP) and the need for development to deliver this either on-site or through s106 or CIL financial contributions off-site and the need for development to be phased in line with the provision of important supporting infrastructure

7 The latest version of the IDP states that there is an ongoing programme of primary school expansions this will help to meet the forecast need for 4-6FE of new capacity over the plan period The need for one new build school project is identified a 2FE primary school at the Longcross Garden Village (estimated cost pound99M to pound15M) this is referred to in the site allocation policies (see below) With respect to secondary school places it is anticipated that up to six additional FE could be required in the Borough by 2021 Additional places will be delivered through the new 6FE Runnymede Free School (which opened in temporary accommodation in 2017) development of additional FE within Salesian School (Catholic faith school) and expansion of another school in the Chertsey area (to accommodate demand from generated by the Longcross Garden Village site)

8 It would be useful if the background data informing these projections of need could be clarified particularly the pupil yield factors used and the evidence base supporting this This would help to demonstrate more clearly to the Inspector that the approach to the planning and delivery of education infrastructure has been positively prepared based on a strategy which seeks to meet objectively assessed infrastructure requirements and is justified based on proportionate evidence The ESFA notes that the Runnymede S106 SPG sets out pupil yield figures however this document dates from December 2007 so the figures may be outdated

9 The ESFA supports the Councilrsquos allocation and safeguarding of land for schools as set out in the following policies

middot Policy SD10 Longcross Garden Village - 2FE primary school with preschoolearly years settings

middot Policy SL2 to SL18 ndash series of housing allocation policies that highlight the need to make a financial contribution to early years primary and secondary school infrastructure ldquoeither through S106 or CIL (or its successor)rdquo

Developer Contributions and CIL

10 One of the tests of soundness is that a Local Plan is lsquoeffectiversquo ie the plan should be deliverable over its period In this context and with specific regard to planning for schools there is a need to ensure that education contributions made by developers are sufficient to deliver the additional school places required to meet the increase in demand generated by new developments The ESFA notes that the council has not adopted CIL and that the Planning Obligations SPG sets out how developer contributions to education provision will be secured via section 106 agreements The ESFA supports the Councilrsquos approach to ensure developer contributions address the impacts arising from growth However the ESFA recommends that the Local Plan includes a commitment to revise the Planning Obligations SPG in line with the latest evidence of the boroughrsquos infrastructure needs pupil yields and build costs (including the cost of school expansion new build and SEN provision) Any such review should be prepared in consultation with the county council as local education authority This will help to ensure appropriate rates are levied and the right infrastructure is secured across the borough

11 The ESFA would be particularly interested in responding to any update to the Infrastructure Delivery Plan or review of infrastructure requirements As such please add the ESFA to the database for future CIL consultations

Forward funding

12 In light of the proposed Longcross Garden Village emerging ESFA proposals for forward funding schools as part of large residential developments may be relevant for example if viability becomes an issue The ESFA aims to be able to clarify forward funding options for schools in 2018 We would be happy to meet to discuss this opportunity further once the options have been finalised and ifwhen relevant Any offer of forward funding would seek to maximise developer contributions to education infrastructure provision while supporting delivery of schools where and when they are needed

Conclusion

13 Finally I hope the above comments are helpful in finalising the Runnymede Local Plan with specific regard to the provision of land for new schools

14 Please notify the ESFA when the Local Plan is submitted for examination the Inspectorrsquos report is published and the Local Plan is adopted

15 Please do not hesitate to contact me if you have any queries regarding this response The ESFA looks forward to continuing to work with Runnymede Borough Council to develop a sound Local Plan that will aid in the delivery of new schools

Yours faithfully

DC McNab

Douglas McNab MRTPI

Forward Planning Manager

Tel 07990 082877

Email

douglasmcnabeducationgovuk

Web

wwwgovuk esfa

Education and Skills Funding Agency13

Department for EducationSanctuary BuildingsGreat Smith StreetLondonSW1P 3BT13

13

Tel 0207 340 700013

13

wwwgovukesfa13

13

13

To

Policy Planning and Strategy Team

Runnymede Borough Council

Civic Centre

Station Road

Addlestone

Surrey

KT15 2AH

From

Dr Brian Pickett

139 Brox Road

Ottershaw

Surrey

KT16 0LG

Page 22: Runnymede Borough Council, for submissions. My contact details are all in the WORD letter attached. But I will provide my telephone number here too, which …

FromPolicy

Subject FW New Housing Plans 2015-2030Date 21 February 2018 164919

Sent 21 February 2018 1608To PlanningSubject New Housing Plans 2015-2030

To

Policy Planning and Strategy Team

Runnymede Borough Council

Station Road

Addlestone

21022018

Dear Sirs

As an Ottershaw resident of nearly 30 years i would like you to read and take on board my objections to yourproposal to take land out of the green belt for housing and your plan to build so many houses in ourcommunity

Of course new houses have to be built right across the country now and in the future but i feel the plans youhave are for far too many houses The infrastructure of our community will just not sustain the extra amount ofpeople and cars and the general traffic that would entail

There are other possibilities available before your irreversible plans are put into action Are these possibilitiesbeing resourced

When i drive around the borough now and for a long long time i see so many empty office blocks Some ofthese have stood empty for yearsWhy has permission been given continuosly from what i can see on a huge scale for these to be built

This building of offices has to stop and the ones that have remained empty for years could be converted tohousing as in flats starter homes for young people

If Planning Practice Guidlines state that the use of Green Beltshould only occur in very special circumstances these and the Brownfield sites in Runnymede must be extensively researched

I live in Wilson Drive and for many years now when i leave my house to go into the village or elsewhere thereis often gridlock in every direction The roads in our community are so heavily used by cars and lorries headingtoward the M25 Can you imagine the impact so many more of these will bring Driving has not been a pleasurefor a long time and i do walk wherever possible Parking is a problem in the village as so many people use theone car park I believe there may be a plan in the pipeline to even get rid of that for road widening

We have a GP practice in the village that is getting harder to book an appointment for also i have been waitingmonths for an appointment at St Peters hospital and just keep getting apologetic letters

Quality of life is very important for your residents and that quality has already deteriorated lately

1888

In order to accomodate so many new residents you will be making the ones you have feel very disappointedand frustated that no one listens

There is no going back once the desicion has been made and so many houses built Please take my feelings and iam sure very many more residents comments and pleas into account before you make the irreversible decisionto go ahead with your plans

Yours Faithfully

Margaret Wensley and the Wensley family

Beechwood

Wilson Drive

Ottershaw

Surrey

KT16 0NT

----------- middotn==middot =

Planning Services

DELIVERED BY HAND

Runnymede Borough Council ~--------------=-middot ---------middot------~

Planning Dept Runnymede Borough Council Civic Offices Station Road Addlestone KT15 2AH

Dear Sirs

Catherine Brunton-Green 20The Glen Addlestone

KT151AQ

15th February 2018

Runnymede Draft local Plan 2015- 2030- Final Consultation

I have serious concerns in respect of this draft plan Runnymede Borough Council (RBC) have a duty of care to consult with listen and act upon the wishes of its residents There has been some consultation but this has not effectively reached all Runnymede residents Communication is unnecessarily legally complex and full of unexplained acronyms The basic Runnymede Voice delivered to every home has been abandoned There has been no flyer delivered to every home stating in a simplified way what is happening so that all abilities may be catered for Many people are isolated for numerous reasons and do not have internet access Neither is there evidence of full in depth cross boundary consultation with adjacent boroughs This local plan is driven primarily by a developers charter promoted by RBCS Head of Planning It is both unfair unjust and I question its soundness

The Strategic Housing Market Assessment has not taken leaving the EU into account and makes a blanket assumption on Heathrow expansion

I strongly object to the proposed loss of c 560 acres of Green Belt Our Prime Minister and government have recently stated that they are quote committed to protecting and enhancing our natural environment for successive generations therefore Green Belt land would only be lost as a last resort 11

bull Detailed evidence based research by The Council for The Protection of Rural England confirms that by fully utilising brownfield land 12 million homes could be built in London and the South East without the loss of any Green Belt

I have objection to building on the Veterinary Laboratory Green Belt Land Parcel BRow Town (Policy SL11 8283) is not justified for development This is designated for 150 additional dwellings and 2 gypsyTraveller pitches This site provides a natural demarcation between developments either side Designated SANG area is privately owned and not available The density of proposed build is unacceptable and above all an area of outstanding natural beauty would be destroyed

Our infrastructure is unable to cope at present A320 suffers perpetual gridlock now Equally gridlock is evidenced through Ottershaw Addlestone Station Road and A317 Addlestone Weybridge We already have unhealthily dangerous levels of roadside nitrogen dioxide concentrations in many areas such as Station Road RBC has made a lame submission in respect of

tackling roadside nitrogen dioxide concentrations in the South East (UK00310) Incidence of exacerbated breathing illnesses in this vicinity has increased dramatically in the past 7 years All age groups are affected

All GP surgeries across Runnymede have great difficulty in recruiting doctors Two practices in the immediate area are merging due to unprecedented numbers of doctors leaving and retiring Practice lists and capacity is stretched Patient access to services and patient safety has to be the highest priority Our schools are similarly affected

RBC infrastructure is totally reliant upon Surrey County Council who declare they are not in a financial position to fund the necessary support to develop the infrastructure for this Local Plan

I am prepared to speak at Public Enquiry

Yours faithfully

bull i I I bull bull

From Brian PickettTo Planning PolicySubject Runnymede 2030 Local Plan - submission of viewsDate 22 February 2018 090921Attachments Ottershaw development Objection letter February 2018docx

Please find attached the submission of my views on the Runnymede 2030 LocalPlan

Kind RegardsBrian Pickett

1891

planningrunnymedegovuk planningrunnymedegovuk

21022018

Re Runnymede 2030 Local Plan Ottershaw East ndash Objection to planning

Dear Sirs

We are writing to you again as we strongly object to the Runnymede Borough Councils plans to remove land behind houses along Brox Road known as lsquoOttershaw Eastrsquo from the Green Belt We are objecting for a number of reasons listed below

middot The Green Belt is precious once it is gone it is gone forever The removal of this land from the Green Belt does not comply with Planning Policy which states ldquothat Green Belt boundaries should only be altered in exceptional circumstancesrdquo there are no such circumstances that can justify the removal of this piece of land

middot The Green Belt should be an area that is preserved for future generations to enjoy and appreciate and many statements have been made by both the Government and members of Parliament on their commitment to protect the Green Belt ndash these statements now need to be converted into action in the Local Borough Plans The roll out of Green Belt to local councils in the 1950rsquos was to prevent urban sprawl and the merging of settlements thereby helping to preserve and protect the character of communities it encompassed protect the country setting and encourage development through regeneration of sites within towns and cities not villages

middot The description of Ottershaw by the council itself in the lsquoUrban Characteristicsrsquo publication on the Runnymede Borough Council website states ldquoOttershaw has its own identity and sense of place which is partly derived from the clearly identifiable heart of the urban area focused on The Otter and adjoining local shopping parade and community facilities as well as being surrounded by open greenbelt countryside Removing this green belt that is part of the identifiable heart of Ottershaw would destroy this villagersquos identity and community

middot The planning proposals and building on this part of the green belt land would lead to a considerable population increase in the village Services and facilities will struggle or fail to cope space is already limited at the doctorrsquos surgery and school places are at capacity The transport infrastructure is already stretched with limited bus services busy roads poorly maintained pavements and road surfaces Brox road is already used as a shortcut to avoid traffic congestion Given that Ottershaw does not have a train station it is reasonable to assume that the majority of houses would have at least one car the added traffic from the new development would put a severe strain on the road network and users Available information on mitigation is very vague and very open to interpretation and misguided assumptions

middot The Green Belt land is a habitat to an array of plants and animals including important pollinator species and larger animals such as birds foxes and deer There should be no assumption that animals will simply move to another area habitats are established over many years and this development will be another loss to the maintenance of biodiversity I enjoy the fauna and flora in these areas going for walks along the public footpaths Having such wonderful access to a relaxing escape so close to home is priceless and something I hold dear to myself my family and community What is now a beautiful scenic view will become a spoilt urban sprawl of modern housing

middot I moved to Ottershaw with my wife in 2016 to settle down and start a family The relaxed quiet village sense of community and safety surrounded by beautiful countryside were its appeal I are very concerned and disappointed that this planning proposal is still being considered which will undoubtedly destroy this idyllic setting

There are no ldquoexceptional or very special circumstancesrdquo that justify the removal of Ottershaw East from the Green Belt We trust that the Council will therefore not remove ldquoOttershaw Eastrdquo and ldquoThe Fieldrdquo from the Green Belt

Yours faithfully

Dr Brian Pickett

To Policy Planning and Strategy Team Runnymede Borough Council Civic Centre Station Road Addlestone Surrey KT15 2AH planningrunnymedegovuk

From Dr Brian Pickett 139 Brox Road Ottershaw Surrey KT16 0LG planningrunnymedegovuk

21022018 Re Runnymede 2030 Local Plan Ottershaw East ndash Objection to planning Dear Sirs We are writing to you again as we strongly object to the Runnymede Borough Councils plans to remove land behind houses along Brox Road known as lsquoOttershaw Eastrsquo from the Green Belt We are objecting for a number of reasons listed below bull The Green Belt is precious once it is gone it is gone forever The removal of this

land from the Green Belt does not comply with Planning Policy which states ldquothat Green Belt boundaries should only be altered in exceptional circumstancesrdquo there are no such circumstances that can justify the removal of this piece of land

bull The Green Belt should be an area that is preserved for future generations to enjoy

and appreciate and many statements have been made by both the Government and members of Parliament on their commitment to protect the Green Belt ndash these statements now need to be converted into action in the Local Borough Plans The roll out of Green Belt to local councils in the 1950rsquos was to prevent urban sprawl and the merging of settlements thereby helping to preserve and protect the character of communities it encompassed protect the country setting and encourage development through regeneration of sites within towns and cities not villages

bull The description of Ottershaw by the council itself in the lsquoUrban Characteristicsrsquo

publication on the Runnymede Borough Council website states ldquoOttershaw has its own identity and sense of place which is partly derived from the clearly identifiable heart of the urban area focused on The Otter and adjoining local shopping parade and community facilities as well as being surrounded by open greenbelt countryside Removing this green belt that is part of the identifiable heart of Ottershaw would destroy this villagersquos identity and community

bull The planning proposals and building on this part of the green belt land would lead

to a considerable population increase in the village Services and facilities will struggle or fail to cope space is already limited at the doctorrsquos surgery and school places are at capacity The transport infrastructure is already stretched with limited bus services busy roads poorly maintained pavements and road surfaces Brox road is already used as a shortcut to avoid traffic congestion Given that Ottershaw does not have a train station it is reasonable to assume that the majority of houses would have at least one car the added traffic from the new development would put a severe strain on the road network and users Available information on mitigation is very vague and very open to interpretation and misguided assumptions

bull The Green Belt land is a habitat to an array of plants and animals including important pollinator species and larger animals such as birds foxes and deer There should be no assumption that animals will simply move to another area habitats are established over many years and this development will be another loss to the maintenance of biodiversity I enjoy the fauna and flora in these areas going for walks along the public footpaths Having such wonderful access to a relaxing escape so close to home is priceless and something I hold dear to myself my family and community What is now a beautiful scenic view will become a spoilt urban sprawl of modern housing

bull I moved to Ottershaw with my wife in 2016 to settle down and start a family The

relaxed quiet village sense of community and safety surrounded by beautiful countryside were its appeal I are very concerned and disappointed that this planning proposal is still being considered which will undoubtedly destroy this idyllic setting

There are no ldquoexceptional or very special circumstancesrdquo that justify the removal of Ottershaw East from the Green Belt We trust that the Council will therefore not remove ldquoOttershaw Eastrdquo and ldquoThe Fieldrdquo from the Green Belt Yours faithfully Dr Brian Pickett

FromTo Planning PolicySubject Runnymede Local Plan 2030 - consultation responseDate 21 February 2018 163608Attachments Runnymede LP Response - EE15pdf

Please find attached a consultation response form

________________________________________Christian Leigh BSc(Hons) MPhil MRTPIDirectorLeigh amp Glennie Ltd6 All Souls RoadAscotBerkshire SL5 9EA

1893

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number 01344 297094 Email Address (where relevant)

mailchristianleighcouk

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number Email Address (where relevant)

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

From MCNAB DouglasTo Planning PolicySubject Runnymede Draft Local Plan consultation - Representation from Education and Skills Funding AgencyDate 21 February 2018 091407Attachments Runnymede Reg 19 response ESFADOC

Dear Runnymede Planning Policy Team

Please see attached a representation from the Education and Skills Funding Agency on theRunnymede Local Plan consultation

I would be grateful if you could confirm receipt

Best regardsDoug

Douglas McNab MRTPIForward Planning Manager ndash South East

Planning Team Free Schools CapitalEducation and Skills Funding AgencyDepartment for Education 5th floor Sanctuary Buildings 20 Great Smith Street London SW1P 3BT

Email douglasmcnabeducationgovukMobile 07990 082877Web wwwgovukesfa

1895

image1pngOur Ref ESFALocal PlanRunnymede 2018 21st February 2018

Dear SirMadam

Re Runnymede Local Plan

Consultation under Regulation 19 of Town and Country Planning (Local Planning) (England) Regulations 2012

Submission of the Education and Skills Funding Agency

1 The Education and Skills Funding Agency (ESFA) welcomes the opportunity to contribute to the development of planning policy at the local level

2 The ESFA launched on 1st April 2017 bringing together the existing responsibilities of the Education Funding Agency (EFA) and the Skills Funding Agency (SFA) to create a single funding agency accountable for funding education and training for children young people and adults The ESFA are accountable for pound61 billion of funding a year for the education and training sector including support for all state-provided education for 8 million children aged 3 to 16 and 16 million young people aged 16 to 19

3 Under the provisions of the Education Act 2011 and the Academies Act 2010 all new state schools are now academiesfree schools and the ESFA is the delivery body for many of these rather than local education authorities As such we aim to work closely with local authority education departments and planning authorities to meet the demand for new school places and new schools We do this through a variety of means including by supporting the adoption of sound local plan policies site allocations and guidance (all based on robust evidence) that facilitate the delivery of education infrastructure where and when it is needed and maximise developer contributions for schools In this capacity we would like to offer the following comments in response to the proposals outlined in the above consultation document

Comments on the Local Plan

4 As you will be aware the primary focus at this stage of the Local Planrsquos preparation is on the soundness of the plan with regard to it being positively prepared justified effective and consistent with national policy The following detailed comments set out the ESFArsquos view of the planrsquos soundness in respect of education provision

5 The ESFA notes that the local plan will make provision for a minimum of 7413 net additional dwellings over the plan period Development will generally complement the existing settlement pattern focusing the largest amounts of residential growth primarily in Chertsey (1950 homes) Addlestone (936 homes) and Egham (812 homes) A new ldquolocally led garden villagerdquo is also proposed at Longcross providing a further 1718 homes This level of development will put pressure on existing education infrastructure

6 The plan recognises that ldquoIt is important that infrastructure is delivered in a timely manner to ensure that the needs of the occupiers of new development can be met without placing undue burdens on existing infrastructure facilities and servicesrdquo (para 560) The ESFA supports Policy SD6 Infrastructure Provision amp Timing particularly the signposting of the Infrastructure Delivery Plan (IDP) and the need for development to deliver this either on-site or through s106 or CIL financial contributions off-site and the need for development to be phased in line with the provision of important supporting infrastructure

7 The latest version of the IDP states that there is an ongoing programme of primary school expansions this will help to meet the forecast need for 4-6FE of new capacity over the plan period The need for one new build school project is identified a 2FE primary school at the Longcross Garden Village (estimated cost pound99M to pound15M) this is referred to in the site allocation policies (see below) With respect to secondary school places it is anticipated that up to six additional FE could be required in the Borough by 2021 Additional places will be delivered through the new 6FE Runnymede Free School (which opened in temporary accommodation in 2017) development of additional FE within Salesian School (Catholic faith school) and expansion of another school in the Chertsey area (to accommodate demand from generated by the Longcross Garden Village site)

8 It would be useful if the background data informing these projections of need could be clarified particularly the pupil yield factors used and the evidence base supporting this This would help to demonstrate more clearly to the Inspector that the approach to the planning and delivery of education infrastructure has been positively prepared based on a strategy which seeks to meet objectively assessed infrastructure requirements and is justified based on proportionate evidence The ESFA notes that the Runnymede S106 SPG sets out pupil yield figures however this document dates from December 2007 so the figures may be outdated

9 The ESFA supports the Councilrsquos allocation and safeguarding of land for schools as set out in the following policies

middot Policy SD10 Longcross Garden Village - 2FE primary school with preschoolearly years settings

middot Policy SL2 to SL18 ndash series of housing allocation policies that highlight the need to make a financial contribution to early years primary and secondary school infrastructure ldquoeither through S106 or CIL (or its successor)rdquo

Developer Contributions and CIL

10 One of the tests of soundness is that a Local Plan is lsquoeffectiversquo ie the plan should be deliverable over its period In this context and with specific regard to planning for schools there is a need to ensure that education contributions made by developers are sufficient to deliver the additional school places required to meet the increase in demand generated by new developments The ESFA notes that the council has not adopted CIL and that the Planning Obligations SPG sets out how developer contributions to education provision will be secured via section 106 agreements The ESFA supports the Councilrsquos approach to ensure developer contributions address the impacts arising from growth However the ESFA recommends that the Local Plan includes a commitment to revise the Planning Obligations SPG in line with the latest evidence of the boroughrsquos infrastructure needs pupil yields and build costs (including the cost of school expansion new build and SEN provision) Any such review should be prepared in consultation with the county council as local education authority This will help to ensure appropriate rates are levied and the right infrastructure is secured across the borough

11 The ESFA would be particularly interested in responding to any update to the Infrastructure Delivery Plan or review of infrastructure requirements As such please add the ESFA to the database for future CIL consultations

Forward funding

12 In light of the proposed Longcross Garden Village emerging ESFA proposals for forward funding schools as part of large residential developments may be relevant for example if viability becomes an issue The ESFA aims to be able to clarify forward funding options for schools in 2018 We would be happy to meet to discuss this opportunity further once the options have been finalised and ifwhen relevant Any offer of forward funding would seek to maximise developer contributions to education infrastructure provision while supporting delivery of schools where and when they are needed

Conclusion

13 Finally I hope the above comments are helpful in finalising the Runnymede Local Plan with specific regard to the provision of land for new schools

14 Please notify the ESFA when the Local Plan is submitted for examination the Inspectorrsquos report is published and the Local Plan is adopted

15 Please do not hesitate to contact me if you have any queries regarding this response The ESFA looks forward to continuing to work with Runnymede Borough Council to develop a sound Local Plan that will aid in the delivery of new schools

Yours faithfully

DC McNab

Douglas McNab MRTPI

Forward Planning Manager

Tel 07990 082877

Email

douglasmcnabeducationgovuk

Web

wwwgovuk esfa

Education and Skills Funding Agency13

Department for EducationSanctuary BuildingsGreat Smith StreetLondonSW1P 3BT13

13

Tel 0207 340 700013

13

wwwgovukesfa13

13

13

To

Policy Planning and Strategy Team

Runnymede Borough Council

Civic Centre

Station Road

Addlestone

Surrey

KT15 2AH

From

Dr Brian Pickett

139 Brox Road

Ottershaw

Surrey

KT16 0LG

Page 23: Runnymede Borough Council, for submissions. My contact details are all in the WORD letter attached. But I will provide my telephone number here too, which …

In order to accomodate so many new residents you will be making the ones you have feel very disappointedand frustated that no one listens

There is no going back once the desicion has been made and so many houses built Please take my feelings and iam sure very many more residents comments and pleas into account before you make the irreversible decisionto go ahead with your plans

Yours Faithfully

Margaret Wensley and the Wensley family

Beechwood

Wilson Drive

Ottershaw

Surrey

KT16 0NT

----------- middotn==middot =

Planning Services

DELIVERED BY HAND

Runnymede Borough Council ~--------------=-middot ---------middot------~

Planning Dept Runnymede Borough Council Civic Offices Station Road Addlestone KT15 2AH

Dear Sirs

Catherine Brunton-Green 20The Glen Addlestone

KT151AQ

15th February 2018

Runnymede Draft local Plan 2015- 2030- Final Consultation

I have serious concerns in respect of this draft plan Runnymede Borough Council (RBC) have a duty of care to consult with listen and act upon the wishes of its residents There has been some consultation but this has not effectively reached all Runnymede residents Communication is unnecessarily legally complex and full of unexplained acronyms The basic Runnymede Voice delivered to every home has been abandoned There has been no flyer delivered to every home stating in a simplified way what is happening so that all abilities may be catered for Many people are isolated for numerous reasons and do not have internet access Neither is there evidence of full in depth cross boundary consultation with adjacent boroughs This local plan is driven primarily by a developers charter promoted by RBCS Head of Planning It is both unfair unjust and I question its soundness

The Strategic Housing Market Assessment has not taken leaving the EU into account and makes a blanket assumption on Heathrow expansion

I strongly object to the proposed loss of c 560 acres of Green Belt Our Prime Minister and government have recently stated that they are quote committed to protecting and enhancing our natural environment for successive generations therefore Green Belt land would only be lost as a last resort 11

bull Detailed evidence based research by The Council for The Protection of Rural England confirms that by fully utilising brownfield land 12 million homes could be built in London and the South East without the loss of any Green Belt

I have objection to building on the Veterinary Laboratory Green Belt Land Parcel BRow Town (Policy SL11 8283) is not justified for development This is designated for 150 additional dwellings and 2 gypsyTraveller pitches This site provides a natural demarcation between developments either side Designated SANG area is privately owned and not available The density of proposed build is unacceptable and above all an area of outstanding natural beauty would be destroyed

Our infrastructure is unable to cope at present A320 suffers perpetual gridlock now Equally gridlock is evidenced through Ottershaw Addlestone Station Road and A317 Addlestone Weybridge We already have unhealthily dangerous levels of roadside nitrogen dioxide concentrations in many areas such as Station Road RBC has made a lame submission in respect of

tackling roadside nitrogen dioxide concentrations in the South East (UK00310) Incidence of exacerbated breathing illnesses in this vicinity has increased dramatically in the past 7 years All age groups are affected

All GP surgeries across Runnymede have great difficulty in recruiting doctors Two practices in the immediate area are merging due to unprecedented numbers of doctors leaving and retiring Practice lists and capacity is stretched Patient access to services and patient safety has to be the highest priority Our schools are similarly affected

RBC infrastructure is totally reliant upon Surrey County Council who declare they are not in a financial position to fund the necessary support to develop the infrastructure for this Local Plan

I am prepared to speak at Public Enquiry

Yours faithfully

bull i I I bull bull

From Brian PickettTo Planning PolicySubject Runnymede 2030 Local Plan - submission of viewsDate 22 February 2018 090921Attachments Ottershaw development Objection letter February 2018docx

Please find attached the submission of my views on the Runnymede 2030 LocalPlan

Kind RegardsBrian Pickett

1891

planningrunnymedegovuk planningrunnymedegovuk

21022018

Re Runnymede 2030 Local Plan Ottershaw East ndash Objection to planning

Dear Sirs

We are writing to you again as we strongly object to the Runnymede Borough Councils plans to remove land behind houses along Brox Road known as lsquoOttershaw Eastrsquo from the Green Belt We are objecting for a number of reasons listed below

middot The Green Belt is precious once it is gone it is gone forever The removal of this land from the Green Belt does not comply with Planning Policy which states ldquothat Green Belt boundaries should only be altered in exceptional circumstancesrdquo there are no such circumstances that can justify the removal of this piece of land

middot The Green Belt should be an area that is preserved for future generations to enjoy and appreciate and many statements have been made by both the Government and members of Parliament on their commitment to protect the Green Belt ndash these statements now need to be converted into action in the Local Borough Plans The roll out of Green Belt to local councils in the 1950rsquos was to prevent urban sprawl and the merging of settlements thereby helping to preserve and protect the character of communities it encompassed protect the country setting and encourage development through regeneration of sites within towns and cities not villages

middot The description of Ottershaw by the council itself in the lsquoUrban Characteristicsrsquo publication on the Runnymede Borough Council website states ldquoOttershaw has its own identity and sense of place which is partly derived from the clearly identifiable heart of the urban area focused on The Otter and adjoining local shopping parade and community facilities as well as being surrounded by open greenbelt countryside Removing this green belt that is part of the identifiable heart of Ottershaw would destroy this villagersquos identity and community

middot The planning proposals and building on this part of the green belt land would lead to a considerable population increase in the village Services and facilities will struggle or fail to cope space is already limited at the doctorrsquos surgery and school places are at capacity The transport infrastructure is already stretched with limited bus services busy roads poorly maintained pavements and road surfaces Brox road is already used as a shortcut to avoid traffic congestion Given that Ottershaw does not have a train station it is reasonable to assume that the majority of houses would have at least one car the added traffic from the new development would put a severe strain on the road network and users Available information on mitigation is very vague and very open to interpretation and misguided assumptions

middot The Green Belt land is a habitat to an array of plants and animals including important pollinator species and larger animals such as birds foxes and deer There should be no assumption that animals will simply move to another area habitats are established over many years and this development will be another loss to the maintenance of biodiversity I enjoy the fauna and flora in these areas going for walks along the public footpaths Having such wonderful access to a relaxing escape so close to home is priceless and something I hold dear to myself my family and community What is now a beautiful scenic view will become a spoilt urban sprawl of modern housing

middot I moved to Ottershaw with my wife in 2016 to settle down and start a family The relaxed quiet village sense of community and safety surrounded by beautiful countryside were its appeal I are very concerned and disappointed that this planning proposal is still being considered which will undoubtedly destroy this idyllic setting

There are no ldquoexceptional or very special circumstancesrdquo that justify the removal of Ottershaw East from the Green Belt We trust that the Council will therefore not remove ldquoOttershaw Eastrdquo and ldquoThe Fieldrdquo from the Green Belt

Yours faithfully

Dr Brian Pickett

To Policy Planning and Strategy Team Runnymede Borough Council Civic Centre Station Road Addlestone Surrey KT15 2AH planningrunnymedegovuk

From Dr Brian Pickett 139 Brox Road Ottershaw Surrey KT16 0LG planningrunnymedegovuk

21022018 Re Runnymede 2030 Local Plan Ottershaw East ndash Objection to planning Dear Sirs We are writing to you again as we strongly object to the Runnymede Borough Councils plans to remove land behind houses along Brox Road known as lsquoOttershaw Eastrsquo from the Green Belt We are objecting for a number of reasons listed below bull The Green Belt is precious once it is gone it is gone forever The removal of this

land from the Green Belt does not comply with Planning Policy which states ldquothat Green Belt boundaries should only be altered in exceptional circumstancesrdquo there are no such circumstances that can justify the removal of this piece of land

bull The Green Belt should be an area that is preserved for future generations to enjoy

and appreciate and many statements have been made by both the Government and members of Parliament on their commitment to protect the Green Belt ndash these statements now need to be converted into action in the Local Borough Plans The roll out of Green Belt to local councils in the 1950rsquos was to prevent urban sprawl and the merging of settlements thereby helping to preserve and protect the character of communities it encompassed protect the country setting and encourage development through regeneration of sites within towns and cities not villages

bull The description of Ottershaw by the council itself in the lsquoUrban Characteristicsrsquo

publication on the Runnymede Borough Council website states ldquoOttershaw has its own identity and sense of place which is partly derived from the clearly identifiable heart of the urban area focused on The Otter and adjoining local shopping parade and community facilities as well as being surrounded by open greenbelt countryside Removing this green belt that is part of the identifiable heart of Ottershaw would destroy this villagersquos identity and community

bull The planning proposals and building on this part of the green belt land would lead

to a considerable population increase in the village Services and facilities will struggle or fail to cope space is already limited at the doctorrsquos surgery and school places are at capacity The transport infrastructure is already stretched with limited bus services busy roads poorly maintained pavements and road surfaces Brox road is already used as a shortcut to avoid traffic congestion Given that Ottershaw does not have a train station it is reasonable to assume that the majority of houses would have at least one car the added traffic from the new development would put a severe strain on the road network and users Available information on mitigation is very vague and very open to interpretation and misguided assumptions

bull The Green Belt land is a habitat to an array of plants and animals including important pollinator species and larger animals such as birds foxes and deer There should be no assumption that animals will simply move to another area habitats are established over many years and this development will be another loss to the maintenance of biodiversity I enjoy the fauna and flora in these areas going for walks along the public footpaths Having such wonderful access to a relaxing escape so close to home is priceless and something I hold dear to myself my family and community What is now a beautiful scenic view will become a spoilt urban sprawl of modern housing

bull I moved to Ottershaw with my wife in 2016 to settle down and start a family The

relaxed quiet village sense of community and safety surrounded by beautiful countryside were its appeal I are very concerned and disappointed that this planning proposal is still being considered which will undoubtedly destroy this idyllic setting

There are no ldquoexceptional or very special circumstancesrdquo that justify the removal of Ottershaw East from the Green Belt We trust that the Council will therefore not remove ldquoOttershaw Eastrdquo and ldquoThe Fieldrdquo from the Green Belt Yours faithfully Dr Brian Pickett

FromTo Planning PolicySubject Runnymede Local Plan 2030 - consultation responseDate 21 February 2018 163608Attachments Runnymede LP Response - EE15pdf

Please find attached a consultation response form

________________________________________Christian Leigh BSc(Hons) MPhil MRTPIDirectorLeigh amp Glennie Ltd6 All Souls RoadAscotBerkshire SL5 9EA

1893

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number 01344 297094 Email Address (where relevant)

mailchristianleighcouk

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number Email Address (where relevant)

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

From MCNAB DouglasTo Planning PolicySubject Runnymede Draft Local Plan consultation - Representation from Education and Skills Funding AgencyDate 21 February 2018 091407Attachments Runnymede Reg 19 response ESFADOC

Dear Runnymede Planning Policy Team

Please see attached a representation from the Education and Skills Funding Agency on theRunnymede Local Plan consultation

I would be grateful if you could confirm receipt

Best regardsDoug

Douglas McNab MRTPIForward Planning Manager ndash South East

Planning Team Free Schools CapitalEducation and Skills Funding AgencyDepartment for Education 5th floor Sanctuary Buildings 20 Great Smith Street London SW1P 3BT

Email douglasmcnabeducationgovukMobile 07990 082877Web wwwgovukesfa

1895

image1pngOur Ref ESFALocal PlanRunnymede 2018 21st February 2018

Dear SirMadam

Re Runnymede Local Plan

Consultation under Regulation 19 of Town and Country Planning (Local Planning) (England) Regulations 2012

Submission of the Education and Skills Funding Agency

1 The Education and Skills Funding Agency (ESFA) welcomes the opportunity to contribute to the development of planning policy at the local level

2 The ESFA launched on 1st April 2017 bringing together the existing responsibilities of the Education Funding Agency (EFA) and the Skills Funding Agency (SFA) to create a single funding agency accountable for funding education and training for children young people and adults The ESFA are accountable for pound61 billion of funding a year for the education and training sector including support for all state-provided education for 8 million children aged 3 to 16 and 16 million young people aged 16 to 19

3 Under the provisions of the Education Act 2011 and the Academies Act 2010 all new state schools are now academiesfree schools and the ESFA is the delivery body for many of these rather than local education authorities As such we aim to work closely with local authority education departments and planning authorities to meet the demand for new school places and new schools We do this through a variety of means including by supporting the adoption of sound local plan policies site allocations and guidance (all based on robust evidence) that facilitate the delivery of education infrastructure where and when it is needed and maximise developer contributions for schools In this capacity we would like to offer the following comments in response to the proposals outlined in the above consultation document

Comments on the Local Plan

4 As you will be aware the primary focus at this stage of the Local Planrsquos preparation is on the soundness of the plan with regard to it being positively prepared justified effective and consistent with national policy The following detailed comments set out the ESFArsquos view of the planrsquos soundness in respect of education provision

5 The ESFA notes that the local plan will make provision for a minimum of 7413 net additional dwellings over the plan period Development will generally complement the existing settlement pattern focusing the largest amounts of residential growth primarily in Chertsey (1950 homes) Addlestone (936 homes) and Egham (812 homes) A new ldquolocally led garden villagerdquo is also proposed at Longcross providing a further 1718 homes This level of development will put pressure on existing education infrastructure

6 The plan recognises that ldquoIt is important that infrastructure is delivered in a timely manner to ensure that the needs of the occupiers of new development can be met without placing undue burdens on existing infrastructure facilities and servicesrdquo (para 560) The ESFA supports Policy SD6 Infrastructure Provision amp Timing particularly the signposting of the Infrastructure Delivery Plan (IDP) and the need for development to deliver this either on-site or through s106 or CIL financial contributions off-site and the need for development to be phased in line with the provision of important supporting infrastructure

7 The latest version of the IDP states that there is an ongoing programme of primary school expansions this will help to meet the forecast need for 4-6FE of new capacity over the plan period The need for one new build school project is identified a 2FE primary school at the Longcross Garden Village (estimated cost pound99M to pound15M) this is referred to in the site allocation policies (see below) With respect to secondary school places it is anticipated that up to six additional FE could be required in the Borough by 2021 Additional places will be delivered through the new 6FE Runnymede Free School (which opened in temporary accommodation in 2017) development of additional FE within Salesian School (Catholic faith school) and expansion of another school in the Chertsey area (to accommodate demand from generated by the Longcross Garden Village site)

8 It would be useful if the background data informing these projections of need could be clarified particularly the pupil yield factors used and the evidence base supporting this This would help to demonstrate more clearly to the Inspector that the approach to the planning and delivery of education infrastructure has been positively prepared based on a strategy which seeks to meet objectively assessed infrastructure requirements and is justified based on proportionate evidence The ESFA notes that the Runnymede S106 SPG sets out pupil yield figures however this document dates from December 2007 so the figures may be outdated

9 The ESFA supports the Councilrsquos allocation and safeguarding of land for schools as set out in the following policies

middot Policy SD10 Longcross Garden Village - 2FE primary school with preschoolearly years settings

middot Policy SL2 to SL18 ndash series of housing allocation policies that highlight the need to make a financial contribution to early years primary and secondary school infrastructure ldquoeither through S106 or CIL (or its successor)rdquo

Developer Contributions and CIL

10 One of the tests of soundness is that a Local Plan is lsquoeffectiversquo ie the plan should be deliverable over its period In this context and with specific regard to planning for schools there is a need to ensure that education contributions made by developers are sufficient to deliver the additional school places required to meet the increase in demand generated by new developments The ESFA notes that the council has not adopted CIL and that the Planning Obligations SPG sets out how developer contributions to education provision will be secured via section 106 agreements The ESFA supports the Councilrsquos approach to ensure developer contributions address the impacts arising from growth However the ESFA recommends that the Local Plan includes a commitment to revise the Planning Obligations SPG in line with the latest evidence of the boroughrsquos infrastructure needs pupil yields and build costs (including the cost of school expansion new build and SEN provision) Any such review should be prepared in consultation with the county council as local education authority This will help to ensure appropriate rates are levied and the right infrastructure is secured across the borough

11 The ESFA would be particularly interested in responding to any update to the Infrastructure Delivery Plan or review of infrastructure requirements As such please add the ESFA to the database for future CIL consultations

Forward funding

12 In light of the proposed Longcross Garden Village emerging ESFA proposals for forward funding schools as part of large residential developments may be relevant for example if viability becomes an issue The ESFA aims to be able to clarify forward funding options for schools in 2018 We would be happy to meet to discuss this opportunity further once the options have been finalised and ifwhen relevant Any offer of forward funding would seek to maximise developer contributions to education infrastructure provision while supporting delivery of schools where and when they are needed

Conclusion

13 Finally I hope the above comments are helpful in finalising the Runnymede Local Plan with specific regard to the provision of land for new schools

14 Please notify the ESFA when the Local Plan is submitted for examination the Inspectorrsquos report is published and the Local Plan is adopted

15 Please do not hesitate to contact me if you have any queries regarding this response The ESFA looks forward to continuing to work with Runnymede Borough Council to develop a sound Local Plan that will aid in the delivery of new schools

Yours faithfully

DC McNab

Douglas McNab MRTPI

Forward Planning Manager

Tel 07990 082877

Email

douglasmcnabeducationgovuk

Web

wwwgovuk esfa

Education and Skills Funding Agency13

Department for EducationSanctuary BuildingsGreat Smith StreetLondonSW1P 3BT13

13

Tel 0207 340 700013

13

wwwgovukesfa13

13

13

To

Policy Planning and Strategy Team

Runnymede Borough Council

Civic Centre

Station Road

Addlestone

Surrey

KT15 2AH

From

Dr Brian Pickett

139 Brox Road

Ottershaw

Surrey

KT16 0LG

Page 24: Runnymede Borough Council, for submissions. My contact details are all in the WORD letter attached. But I will provide my telephone number here too, which …

----------- middotn==middot =

Planning Services

DELIVERED BY HAND

Runnymede Borough Council ~--------------=-middot ---------middot------~

Planning Dept Runnymede Borough Council Civic Offices Station Road Addlestone KT15 2AH

Dear Sirs

Catherine Brunton-Green 20The Glen Addlestone

KT151AQ

15th February 2018

Runnymede Draft local Plan 2015- 2030- Final Consultation

I have serious concerns in respect of this draft plan Runnymede Borough Council (RBC) have a duty of care to consult with listen and act upon the wishes of its residents There has been some consultation but this has not effectively reached all Runnymede residents Communication is unnecessarily legally complex and full of unexplained acronyms The basic Runnymede Voice delivered to every home has been abandoned There has been no flyer delivered to every home stating in a simplified way what is happening so that all abilities may be catered for Many people are isolated for numerous reasons and do not have internet access Neither is there evidence of full in depth cross boundary consultation with adjacent boroughs This local plan is driven primarily by a developers charter promoted by RBCS Head of Planning It is both unfair unjust and I question its soundness

The Strategic Housing Market Assessment has not taken leaving the EU into account and makes a blanket assumption on Heathrow expansion

I strongly object to the proposed loss of c 560 acres of Green Belt Our Prime Minister and government have recently stated that they are quote committed to protecting and enhancing our natural environment for successive generations therefore Green Belt land would only be lost as a last resort 11

bull Detailed evidence based research by The Council for The Protection of Rural England confirms that by fully utilising brownfield land 12 million homes could be built in London and the South East without the loss of any Green Belt

I have objection to building on the Veterinary Laboratory Green Belt Land Parcel BRow Town (Policy SL11 8283) is not justified for development This is designated for 150 additional dwellings and 2 gypsyTraveller pitches This site provides a natural demarcation between developments either side Designated SANG area is privately owned and not available The density of proposed build is unacceptable and above all an area of outstanding natural beauty would be destroyed

Our infrastructure is unable to cope at present A320 suffers perpetual gridlock now Equally gridlock is evidenced through Ottershaw Addlestone Station Road and A317 Addlestone Weybridge We already have unhealthily dangerous levels of roadside nitrogen dioxide concentrations in many areas such as Station Road RBC has made a lame submission in respect of

tackling roadside nitrogen dioxide concentrations in the South East (UK00310) Incidence of exacerbated breathing illnesses in this vicinity has increased dramatically in the past 7 years All age groups are affected

All GP surgeries across Runnymede have great difficulty in recruiting doctors Two practices in the immediate area are merging due to unprecedented numbers of doctors leaving and retiring Practice lists and capacity is stretched Patient access to services and patient safety has to be the highest priority Our schools are similarly affected

RBC infrastructure is totally reliant upon Surrey County Council who declare they are not in a financial position to fund the necessary support to develop the infrastructure for this Local Plan

I am prepared to speak at Public Enquiry

Yours faithfully

bull i I I bull bull

From Brian PickettTo Planning PolicySubject Runnymede 2030 Local Plan - submission of viewsDate 22 February 2018 090921Attachments Ottershaw development Objection letter February 2018docx

Please find attached the submission of my views on the Runnymede 2030 LocalPlan

Kind RegardsBrian Pickett

1891

planningrunnymedegovuk planningrunnymedegovuk

21022018

Re Runnymede 2030 Local Plan Ottershaw East ndash Objection to planning

Dear Sirs

We are writing to you again as we strongly object to the Runnymede Borough Councils plans to remove land behind houses along Brox Road known as lsquoOttershaw Eastrsquo from the Green Belt We are objecting for a number of reasons listed below

middot The Green Belt is precious once it is gone it is gone forever The removal of this land from the Green Belt does not comply with Planning Policy which states ldquothat Green Belt boundaries should only be altered in exceptional circumstancesrdquo there are no such circumstances that can justify the removal of this piece of land

middot The Green Belt should be an area that is preserved for future generations to enjoy and appreciate and many statements have been made by both the Government and members of Parliament on their commitment to protect the Green Belt ndash these statements now need to be converted into action in the Local Borough Plans The roll out of Green Belt to local councils in the 1950rsquos was to prevent urban sprawl and the merging of settlements thereby helping to preserve and protect the character of communities it encompassed protect the country setting and encourage development through regeneration of sites within towns and cities not villages

middot The description of Ottershaw by the council itself in the lsquoUrban Characteristicsrsquo publication on the Runnymede Borough Council website states ldquoOttershaw has its own identity and sense of place which is partly derived from the clearly identifiable heart of the urban area focused on The Otter and adjoining local shopping parade and community facilities as well as being surrounded by open greenbelt countryside Removing this green belt that is part of the identifiable heart of Ottershaw would destroy this villagersquos identity and community

middot The planning proposals and building on this part of the green belt land would lead to a considerable population increase in the village Services and facilities will struggle or fail to cope space is already limited at the doctorrsquos surgery and school places are at capacity The transport infrastructure is already stretched with limited bus services busy roads poorly maintained pavements and road surfaces Brox road is already used as a shortcut to avoid traffic congestion Given that Ottershaw does not have a train station it is reasonable to assume that the majority of houses would have at least one car the added traffic from the new development would put a severe strain on the road network and users Available information on mitigation is very vague and very open to interpretation and misguided assumptions

middot The Green Belt land is a habitat to an array of plants and animals including important pollinator species and larger animals such as birds foxes and deer There should be no assumption that animals will simply move to another area habitats are established over many years and this development will be another loss to the maintenance of biodiversity I enjoy the fauna and flora in these areas going for walks along the public footpaths Having such wonderful access to a relaxing escape so close to home is priceless and something I hold dear to myself my family and community What is now a beautiful scenic view will become a spoilt urban sprawl of modern housing

middot I moved to Ottershaw with my wife in 2016 to settle down and start a family The relaxed quiet village sense of community and safety surrounded by beautiful countryside were its appeal I are very concerned and disappointed that this planning proposal is still being considered which will undoubtedly destroy this idyllic setting

There are no ldquoexceptional or very special circumstancesrdquo that justify the removal of Ottershaw East from the Green Belt We trust that the Council will therefore not remove ldquoOttershaw Eastrdquo and ldquoThe Fieldrdquo from the Green Belt

Yours faithfully

Dr Brian Pickett

To Policy Planning and Strategy Team Runnymede Borough Council Civic Centre Station Road Addlestone Surrey KT15 2AH planningrunnymedegovuk

From Dr Brian Pickett 139 Brox Road Ottershaw Surrey KT16 0LG planningrunnymedegovuk

21022018 Re Runnymede 2030 Local Plan Ottershaw East ndash Objection to planning Dear Sirs We are writing to you again as we strongly object to the Runnymede Borough Councils plans to remove land behind houses along Brox Road known as lsquoOttershaw Eastrsquo from the Green Belt We are objecting for a number of reasons listed below bull The Green Belt is precious once it is gone it is gone forever The removal of this

land from the Green Belt does not comply with Planning Policy which states ldquothat Green Belt boundaries should only be altered in exceptional circumstancesrdquo there are no such circumstances that can justify the removal of this piece of land

bull The Green Belt should be an area that is preserved for future generations to enjoy

and appreciate and many statements have been made by both the Government and members of Parliament on their commitment to protect the Green Belt ndash these statements now need to be converted into action in the Local Borough Plans The roll out of Green Belt to local councils in the 1950rsquos was to prevent urban sprawl and the merging of settlements thereby helping to preserve and protect the character of communities it encompassed protect the country setting and encourage development through regeneration of sites within towns and cities not villages

bull The description of Ottershaw by the council itself in the lsquoUrban Characteristicsrsquo

publication on the Runnymede Borough Council website states ldquoOttershaw has its own identity and sense of place which is partly derived from the clearly identifiable heart of the urban area focused on The Otter and adjoining local shopping parade and community facilities as well as being surrounded by open greenbelt countryside Removing this green belt that is part of the identifiable heart of Ottershaw would destroy this villagersquos identity and community

bull The planning proposals and building on this part of the green belt land would lead

to a considerable population increase in the village Services and facilities will struggle or fail to cope space is already limited at the doctorrsquos surgery and school places are at capacity The transport infrastructure is already stretched with limited bus services busy roads poorly maintained pavements and road surfaces Brox road is already used as a shortcut to avoid traffic congestion Given that Ottershaw does not have a train station it is reasonable to assume that the majority of houses would have at least one car the added traffic from the new development would put a severe strain on the road network and users Available information on mitigation is very vague and very open to interpretation and misguided assumptions

bull The Green Belt land is a habitat to an array of plants and animals including important pollinator species and larger animals such as birds foxes and deer There should be no assumption that animals will simply move to another area habitats are established over many years and this development will be another loss to the maintenance of biodiversity I enjoy the fauna and flora in these areas going for walks along the public footpaths Having such wonderful access to a relaxing escape so close to home is priceless and something I hold dear to myself my family and community What is now a beautiful scenic view will become a spoilt urban sprawl of modern housing

bull I moved to Ottershaw with my wife in 2016 to settle down and start a family The

relaxed quiet village sense of community and safety surrounded by beautiful countryside were its appeal I are very concerned and disappointed that this planning proposal is still being considered which will undoubtedly destroy this idyllic setting

There are no ldquoexceptional or very special circumstancesrdquo that justify the removal of Ottershaw East from the Green Belt We trust that the Council will therefore not remove ldquoOttershaw Eastrdquo and ldquoThe Fieldrdquo from the Green Belt Yours faithfully Dr Brian Pickett

FromTo Planning PolicySubject Runnymede Local Plan 2030 - consultation responseDate 21 February 2018 163608Attachments Runnymede LP Response - EE15pdf

Please find attached a consultation response form

________________________________________Christian Leigh BSc(Hons) MPhil MRTPIDirectorLeigh amp Glennie Ltd6 All Souls RoadAscotBerkshire SL5 9EA

1893

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number 01344 297094 Email Address (where relevant)

mailchristianleighcouk

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number Email Address (where relevant)

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

From MCNAB DouglasTo Planning PolicySubject Runnymede Draft Local Plan consultation - Representation from Education and Skills Funding AgencyDate 21 February 2018 091407Attachments Runnymede Reg 19 response ESFADOC

Dear Runnymede Planning Policy Team

Please see attached a representation from the Education and Skills Funding Agency on theRunnymede Local Plan consultation

I would be grateful if you could confirm receipt

Best regardsDoug

Douglas McNab MRTPIForward Planning Manager ndash South East

Planning Team Free Schools CapitalEducation and Skills Funding AgencyDepartment for Education 5th floor Sanctuary Buildings 20 Great Smith Street London SW1P 3BT

Email douglasmcnabeducationgovukMobile 07990 082877Web wwwgovukesfa

1895

image1pngOur Ref ESFALocal PlanRunnymede 2018 21st February 2018

Dear SirMadam

Re Runnymede Local Plan

Consultation under Regulation 19 of Town and Country Planning (Local Planning) (England) Regulations 2012

Submission of the Education and Skills Funding Agency

1 The Education and Skills Funding Agency (ESFA) welcomes the opportunity to contribute to the development of planning policy at the local level

2 The ESFA launched on 1st April 2017 bringing together the existing responsibilities of the Education Funding Agency (EFA) and the Skills Funding Agency (SFA) to create a single funding agency accountable for funding education and training for children young people and adults The ESFA are accountable for pound61 billion of funding a year for the education and training sector including support for all state-provided education for 8 million children aged 3 to 16 and 16 million young people aged 16 to 19

3 Under the provisions of the Education Act 2011 and the Academies Act 2010 all new state schools are now academiesfree schools and the ESFA is the delivery body for many of these rather than local education authorities As such we aim to work closely with local authority education departments and planning authorities to meet the demand for new school places and new schools We do this through a variety of means including by supporting the adoption of sound local plan policies site allocations and guidance (all based on robust evidence) that facilitate the delivery of education infrastructure where and when it is needed and maximise developer contributions for schools In this capacity we would like to offer the following comments in response to the proposals outlined in the above consultation document

Comments on the Local Plan

4 As you will be aware the primary focus at this stage of the Local Planrsquos preparation is on the soundness of the plan with regard to it being positively prepared justified effective and consistent with national policy The following detailed comments set out the ESFArsquos view of the planrsquos soundness in respect of education provision

5 The ESFA notes that the local plan will make provision for a minimum of 7413 net additional dwellings over the plan period Development will generally complement the existing settlement pattern focusing the largest amounts of residential growth primarily in Chertsey (1950 homes) Addlestone (936 homes) and Egham (812 homes) A new ldquolocally led garden villagerdquo is also proposed at Longcross providing a further 1718 homes This level of development will put pressure on existing education infrastructure

6 The plan recognises that ldquoIt is important that infrastructure is delivered in a timely manner to ensure that the needs of the occupiers of new development can be met without placing undue burdens on existing infrastructure facilities and servicesrdquo (para 560) The ESFA supports Policy SD6 Infrastructure Provision amp Timing particularly the signposting of the Infrastructure Delivery Plan (IDP) and the need for development to deliver this either on-site or through s106 or CIL financial contributions off-site and the need for development to be phased in line with the provision of important supporting infrastructure

7 The latest version of the IDP states that there is an ongoing programme of primary school expansions this will help to meet the forecast need for 4-6FE of new capacity over the plan period The need for one new build school project is identified a 2FE primary school at the Longcross Garden Village (estimated cost pound99M to pound15M) this is referred to in the site allocation policies (see below) With respect to secondary school places it is anticipated that up to six additional FE could be required in the Borough by 2021 Additional places will be delivered through the new 6FE Runnymede Free School (which opened in temporary accommodation in 2017) development of additional FE within Salesian School (Catholic faith school) and expansion of another school in the Chertsey area (to accommodate demand from generated by the Longcross Garden Village site)

8 It would be useful if the background data informing these projections of need could be clarified particularly the pupil yield factors used and the evidence base supporting this This would help to demonstrate more clearly to the Inspector that the approach to the planning and delivery of education infrastructure has been positively prepared based on a strategy which seeks to meet objectively assessed infrastructure requirements and is justified based on proportionate evidence The ESFA notes that the Runnymede S106 SPG sets out pupil yield figures however this document dates from December 2007 so the figures may be outdated

9 The ESFA supports the Councilrsquos allocation and safeguarding of land for schools as set out in the following policies

middot Policy SD10 Longcross Garden Village - 2FE primary school with preschoolearly years settings

middot Policy SL2 to SL18 ndash series of housing allocation policies that highlight the need to make a financial contribution to early years primary and secondary school infrastructure ldquoeither through S106 or CIL (or its successor)rdquo

Developer Contributions and CIL

10 One of the tests of soundness is that a Local Plan is lsquoeffectiversquo ie the plan should be deliverable over its period In this context and with specific regard to planning for schools there is a need to ensure that education contributions made by developers are sufficient to deliver the additional school places required to meet the increase in demand generated by new developments The ESFA notes that the council has not adopted CIL and that the Planning Obligations SPG sets out how developer contributions to education provision will be secured via section 106 agreements The ESFA supports the Councilrsquos approach to ensure developer contributions address the impacts arising from growth However the ESFA recommends that the Local Plan includes a commitment to revise the Planning Obligations SPG in line with the latest evidence of the boroughrsquos infrastructure needs pupil yields and build costs (including the cost of school expansion new build and SEN provision) Any such review should be prepared in consultation with the county council as local education authority This will help to ensure appropriate rates are levied and the right infrastructure is secured across the borough

11 The ESFA would be particularly interested in responding to any update to the Infrastructure Delivery Plan or review of infrastructure requirements As such please add the ESFA to the database for future CIL consultations

Forward funding

12 In light of the proposed Longcross Garden Village emerging ESFA proposals for forward funding schools as part of large residential developments may be relevant for example if viability becomes an issue The ESFA aims to be able to clarify forward funding options for schools in 2018 We would be happy to meet to discuss this opportunity further once the options have been finalised and ifwhen relevant Any offer of forward funding would seek to maximise developer contributions to education infrastructure provision while supporting delivery of schools where and when they are needed

Conclusion

13 Finally I hope the above comments are helpful in finalising the Runnymede Local Plan with specific regard to the provision of land for new schools

14 Please notify the ESFA when the Local Plan is submitted for examination the Inspectorrsquos report is published and the Local Plan is adopted

15 Please do not hesitate to contact me if you have any queries regarding this response The ESFA looks forward to continuing to work with Runnymede Borough Council to develop a sound Local Plan that will aid in the delivery of new schools

Yours faithfully

DC McNab

Douglas McNab MRTPI

Forward Planning Manager

Tel 07990 082877

Email

douglasmcnabeducationgovuk

Web

wwwgovuk esfa

Education and Skills Funding Agency13

Department for EducationSanctuary BuildingsGreat Smith StreetLondonSW1P 3BT13

13

Tel 0207 340 700013

13

wwwgovukesfa13

13

13

To

Policy Planning and Strategy Team

Runnymede Borough Council

Civic Centre

Station Road

Addlestone

Surrey

KT15 2AH

From

Dr Brian Pickett

139 Brox Road

Ottershaw

Surrey

KT16 0LG

Page 25: Runnymede Borough Council, for submissions. My contact details are all in the WORD letter attached. But I will provide my telephone number here too, which …

tackling roadside nitrogen dioxide concentrations in the South East (UK00310) Incidence of exacerbated breathing illnesses in this vicinity has increased dramatically in the past 7 years All age groups are affected

All GP surgeries across Runnymede have great difficulty in recruiting doctors Two practices in the immediate area are merging due to unprecedented numbers of doctors leaving and retiring Practice lists and capacity is stretched Patient access to services and patient safety has to be the highest priority Our schools are similarly affected

RBC infrastructure is totally reliant upon Surrey County Council who declare they are not in a financial position to fund the necessary support to develop the infrastructure for this Local Plan

I am prepared to speak at Public Enquiry

Yours faithfully

bull i I I bull bull

From Brian PickettTo Planning PolicySubject Runnymede 2030 Local Plan - submission of viewsDate 22 February 2018 090921Attachments Ottershaw development Objection letter February 2018docx

Please find attached the submission of my views on the Runnymede 2030 LocalPlan

Kind RegardsBrian Pickett

1891

planningrunnymedegovuk planningrunnymedegovuk

21022018

Re Runnymede 2030 Local Plan Ottershaw East ndash Objection to planning

Dear Sirs

We are writing to you again as we strongly object to the Runnymede Borough Councils plans to remove land behind houses along Brox Road known as lsquoOttershaw Eastrsquo from the Green Belt We are objecting for a number of reasons listed below

middot The Green Belt is precious once it is gone it is gone forever The removal of this land from the Green Belt does not comply with Planning Policy which states ldquothat Green Belt boundaries should only be altered in exceptional circumstancesrdquo there are no such circumstances that can justify the removal of this piece of land

middot The Green Belt should be an area that is preserved for future generations to enjoy and appreciate and many statements have been made by both the Government and members of Parliament on their commitment to protect the Green Belt ndash these statements now need to be converted into action in the Local Borough Plans The roll out of Green Belt to local councils in the 1950rsquos was to prevent urban sprawl and the merging of settlements thereby helping to preserve and protect the character of communities it encompassed protect the country setting and encourage development through regeneration of sites within towns and cities not villages

middot The description of Ottershaw by the council itself in the lsquoUrban Characteristicsrsquo publication on the Runnymede Borough Council website states ldquoOttershaw has its own identity and sense of place which is partly derived from the clearly identifiable heart of the urban area focused on The Otter and adjoining local shopping parade and community facilities as well as being surrounded by open greenbelt countryside Removing this green belt that is part of the identifiable heart of Ottershaw would destroy this villagersquos identity and community

middot The planning proposals and building on this part of the green belt land would lead to a considerable population increase in the village Services and facilities will struggle or fail to cope space is already limited at the doctorrsquos surgery and school places are at capacity The transport infrastructure is already stretched with limited bus services busy roads poorly maintained pavements and road surfaces Brox road is already used as a shortcut to avoid traffic congestion Given that Ottershaw does not have a train station it is reasonable to assume that the majority of houses would have at least one car the added traffic from the new development would put a severe strain on the road network and users Available information on mitigation is very vague and very open to interpretation and misguided assumptions

middot The Green Belt land is a habitat to an array of plants and animals including important pollinator species and larger animals such as birds foxes and deer There should be no assumption that animals will simply move to another area habitats are established over many years and this development will be another loss to the maintenance of biodiversity I enjoy the fauna and flora in these areas going for walks along the public footpaths Having such wonderful access to a relaxing escape so close to home is priceless and something I hold dear to myself my family and community What is now a beautiful scenic view will become a spoilt urban sprawl of modern housing

middot I moved to Ottershaw with my wife in 2016 to settle down and start a family The relaxed quiet village sense of community and safety surrounded by beautiful countryside were its appeal I are very concerned and disappointed that this planning proposal is still being considered which will undoubtedly destroy this idyllic setting

There are no ldquoexceptional or very special circumstancesrdquo that justify the removal of Ottershaw East from the Green Belt We trust that the Council will therefore not remove ldquoOttershaw Eastrdquo and ldquoThe Fieldrdquo from the Green Belt

Yours faithfully

Dr Brian Pickett

To Policy Planning and Strategy Team Runnymede Borough Council Civic Centre Station Road Addlestone Surrey KT15 2AH planningrunnymedegovuk

From Dr Brian Pickett 139 Brox Road Ottershaw Surrey KT16 0LG planningrunnymedegovuk

21022018 Re Runnymede 2030 Local Plan Ottershaw East ndash Objection to planning Dear Sirs We are writing to you again as we strongly object to the Runnymede Borough Councils plans to remove land behind houses along Brox Road known as lsquoOttershaw Eastrsquo from the Green Belt We are objecting for a number of reasons listed below bull The Green Belt is precious once it is gone it is gone forever The removal of this

land from the Green Belt does not comply with Planning Policy which states ldquothat Green Belt boundaries should only be altered in exceptional circumstancesrdquo there are no such circumstances that can justify the removal of this piece of land

bull The Green Belt should be an area that is preserved for future generations to enjoy

and appreciate and many statements have been made by both the Government and members of Parliament on their commitment to protect the Green Belt ndash these statements now need to be converted into action in the Local Borough Plans The roll out of Green Belt to local councils in the 1950rsquos was to prevent urban sprawl and the merging of settlements thereby helping to preserve and protect the character of communities it encompassed protect the country setting and encourage development through regeneration of sites within towns and cities not villages

bull The description of Ottershaw by the council itself in the lsquoUrban Characteristicsrsquo

publication on the Runnymede Borough Council website states ldquoOttershaw has its own identity and sense of place which is partly derived from the clearly identifiable heart of the urban area focused on The Otter and adjoining local shopping parade and community facilities as well as being surrounded by open greenbelt countryside Removing this green belt that is part of the identifiable heart of Ottershaw would destroy this villagersquos identity and community

bull The planning proposals and building on this part of the green belt land would lead

to a considerable population increase in the village Services and facilities will struggle or fail to cope space is already limited at the doctorrsquos surgery and school places are at capacity The transport infrastructure is already stretched with limited bus services busy roads poorly maintained pavements and road surfaces Brox road is already used as a shortcut to avoid traffic congestion Given that Ottershaw does not have a train station it is reasonable to assume that the majority of houses would have at least one car the added traffic from the new development would put a severe strain on the road network and users Available information on mitigation is very vague and very open to interpretation and misguided assumptions

bull The Green Belt land is a habitat to an array of plants and animals including important pollinator species and larger animals such as birds foxes and deer There should be no assumption that animals will simply move to another area habitats are established over many years and this development will be another loss to the maintenance of biodiversity I enjoy the fauna and flora in these areas going for walks along the public footpaths Having such wonderful access to a relaxing escape so close to home is priceless and something I hold dear to myself my family and community What is now a beautiful scenic view will become a spoilt urban sprawl of modern housing

bull I moved to Ottershaw with my wife in 2016 to settle down and start a family The

relaxed quiet village sense of community and safety surrounded by beautiful countryside were its appeal I are very concerned and disappointed that this planning proposal is still being considered which will undoubtedly destroy this idyllic setting

There are no ldquoexceptional or very special circumstancesrdquo that justify the removal of Ottershaw East from the Green Belt We trust that the Council will therefore not remove ldquoOttershaw Eastrdquo and ldquoThe Fieldrdquo from the Green Belt Yours faithfully Dr Brian Pickett

FromTo Planning PolicySubject Runnymede Local Plan 2030 - consultation responseDate 21 February 2018 163608Attachments Runnymede LP Response - EE15pdf

Please find attached a consultation response form

________________________________________Christian Leigh BSc(Hons) MPhil MRTPIDirectorLeigh amp Glennie Ltd6 All Souls RoadAscotBerkshire SL5 9EA

1893

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number 01344 297094 Email Address (where relevant)

mailchristianleighcouk

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number Email Address (where relevant)

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

From MCNAB DouglasTo Planning PolicySubject Runnymede Draft Local Plan consultation - Representation from Education and Skills Funding AgencyDate 21 February 2018 091407Attachments Runnymede Reg 19 response ESFADOC

Dear Runnymede Planning Policy Team

Please see attached a representation from the Education and Skills Funding Agency on theRunnymede Local Plan consultation

I would be grateful if you could confirm receipt

Best regardsDoug

Douglas McNab MRTPIForward Planning Manager ndash South East

Planning Team Free Schools CapitalEducation and Skills Funding AgencyDepartment for Education 5th floor Sanctuary Buildings 20 Great Smith Street London SW1P 3BT

Email douglasmcnabeducationgovukMobile 07990 082877Web wwwgovukesfa

1895

image1pngOur Ref ESFALocal PlanRunnymede 2018 21st February 2018

Dear SirMadam

Re Runnymede Local Plan

Consultation under Regulation 19 of Town and Country Planning (Local Planning) (England) Regulations 2012

Submission of the Education and Skills Funding Agency

1 The Education and Skills Funding Agency (ESFA) welcomes the opportunity to contribute to the development of planning policy at the local level

2 The ESFA launched on 1st April 2017 bringing together the existing responsibilities of the Education Funding Agency (EFA) and the Skills Funding Agency (SFA) to create a single funding agency accountable for funding education and training for children young people and adults The ESFA are accountable for pound61 billion of funding a year for the education and training sector including support for all state-provided education for 8 million children aged 3 to 16 and 16 million young people aged 16 to 19

3 Under the provisions of the Education Act 2011 and the Academies Act 2010 all new state schools are now academiesfree schools and the ESFA is the delivery body for many of these rather than local education authorities As such we aim to work closely with local authority education departments and planning authorities to meet the demand for new school places and new schools We do this through a variety of means including by supporting the adoption of sound local plan policies site allocations and guidance (all based on robust evidence) that facilitate the delivery of education infrastructure where and when it is needed and maximise developer contributions for schools In this capacity we would like to offer the following comments in response to the proposals outlined in the above consultation document

Comments on the Local Plan

4 As you will be aware the primary focus at this stage of the Local Planrsquos preparation is on the soundness of the plan with regard to it being positively prepared justified effective and consistent with national policy The following detailed comments set out the ESFArsquos view of the planrsquos soundness in respect of education provision

5 The ESFA notes that the local plan will make provision for a minimum of 7413 net additional dwellings over the plan period Development will generally complement the existing settlement pattern focusing the largest amounts of residential growth primarily in Chertsey (1950 homes) Addlestone (936 homes) and Egham (812 homes) A new ldquolocally led garden villagerdquo is also proposed at Longcross providing a further 1718 homes This level of development will put pressure on existing education infrastructure

6 The plan recognises that ldquoIt is important that infrastructure is delivered in a timely manner to ensure that the needs of the occupiers of new development can be met without placing undue burdens on existing infrastructure facilities and servicesrdquo (para 560) The ESFA supports Policy SD6 Infrastructure Provision amp Timing particularly the signposting of the Infrastructure Delivery Plan (IDP) and the need for development to deliver this either on-site or through s106 or CIL financial contributions off-site and the need for development to be phased in line with the provision of important supporting infrastructure

7 The latest version of the IDP states that there is an ongoing programme of primary school expansions this will help to meet the forecast need for 4-6FE of new capacity over the plan period The need for one new build school project is identified a 2FE primary school at the Longcross Garden Village (estimated cost pound99M to pound15M) this is referred to in the site allocation policies (see below) With respect to secondary school places it is anticipated that up to six additional FE could be required in the Borough by 2021 Additional places will be delivered through the new 6FE Runnymede Free School (which opened in temporary accommodation in 2017) development of additional FE within Salesian School (Catholic faith school) and expansion of another school in the Chertsey area (to accommodate demand from generated by the Longcross Garden Village site)

8 It would be useful if the background data informing these projections of need could be clarified particularly the pupil yield factors used and the evidence base supporting this This would help to demonstrate more clearly to the Inspector that the approach to the planning and delivery of education infrastructure has been positively prepared based on a strategy which seeks to meet objectively assessed infrastructure requirements and is justified based on proportionate evidence The ESFA notes that the Runnymede S106 SPG sets out pupil yield figures however this document dates from December 2007 so the figures may be outdated

9 The ESFA supports the Councilrsquos allocation and safeguarding of land for schools as set out in the following policies

middot Policy SD10 Longcross Garden Village - 2FE primary school with preschoolearly years settings

middot Policy SL2 to SL18 ndash series of housing allocation policies that highlight the need to make a financial contribution to early years primary and secondary school infrastructure ldquoeither through S106 or CIL (or its successor)rdquo

Developer Contributions and CIL

10 One of the tests of soundness is that a Local Plan is lsquoeffectiversquo ie the plan should be deliverable over its period In this context and with specific regard to planning for schools there is a need to ensure that education contributions made by developers are sufficient to deliver the additional school places required to meet the increase in demand generated by new developments The ESFA notes that the council has not adopted CIL and that the Planning Obligations SPG sets out how developer contributions to education provision will be secured via section 106 agreements The ESFA supports the Councilrsquos approach to ensure developer contributions address the impacts arising from growth However the ESFA recommends that the Local Plan includes a commitment to revise the Planning Obligations SPG in line with the latest evidence of the boroughrsquos infrastructure needs pupil yields and build costs (including the cost of school expansion new build and SEN provision) Any such review should be prepared in consultation with the county council as local education authority This will help to ensure appropriate rates are levied and the right infrastructure is secured across the borough

11 The ESFA would be particularly interested in responding to any update to the Infrastructure Delivery Plan or review of infrastructure requirements As such please add the ESFA to the database for future CIL consultations

Forward funding

12 In light of the proposed Longcross Garden Village emerging ESFA proposals for forward funding schools as part of large residential developments may be relevant for example if viability becomes an issue The ESFA aims to be able to clarify forward funding options for schools in 2018 We would be happy to meet to discuss this opportunity further once the options have been finalised and ifwhen relevant Any offer of forward funding would seek to maximise developer contributions to education infrastructure provision while supporting delivery of schools where and when they are needed

Conclusion

13 Finally I hope the above comments are helpful in finalising the Runnymede Local Plan with specific regard to the provision of land for new schools

14 Please notify the ESFA when the Local Plan is submitted for examination the Inspectorrsquos report is published and the Local Plan is adopted

15 Please do not hesitate to contact me if you have any queries regarding this response The ESFA looks forward to continuing to work with Runnymede Borough Council to develop a sound Local Plan that will aid in the delivery of new schools

Yours faithfully

DC McNab

Douglas McNab MRTPI

Forward Planning Manager

Tel 07990 082877

Email

douglasmcnabeducationgovuk

Web

wwwgovuk esfa

Education and Skills Funding Agency13

Department for EducationSanctuary BuildingsGreat Smith StreetLondonSW1P 3BT13

13

Tel 0207 340 700013

13

wwwgovukesfa13

13

13

To

Policy Planning and Strategy Team

Runnymede Borough Council

Civic Centre

Station Road

Addlestone

Surrey

KT15 2AH

From

Dr Brian Pickett

139 Brox Road

Ottershaw

Surrey

KT16 0LG

Page 26: Runnymede Borough Council, for submissions. My contact details are all in the WORD letter attached. But I will provide my telephone number here too, which …

From Brian PickettTo Planning PolicySubject Runnymede 2030 Local Plan - submission of viewsDate 22 February 2018 090921Attachments Ottershaw development Objection letter February 2018docx

Please find attached the submission of my views on the Runnymede 2030 LocalPlan

Kind RegardsBrian Pickett

1891

planningrunnymedegovuk planningrunnymedegovuk

21022018

Re Runnymede 2030 Local Plan Ottershaw East ndash Objection to planning

Dear Sirs

We are writing to you again as we strongly object to the Runnymede Borough Councils plans to remove land behind houses along Brox Road known as lsquoOttershaw Eastrsquo from the Green Belt We are objecting for a number of reasons listed below

middot The Green Belt is precious once it is gone it is gone forever The removal of this land from the Green Belt does not comply with Planning Policy which states ldquothat Green Belt boundaries should only be altered in exceptional circumstancesrdquo there are no such circumstances that can justify the removal of this piece of land

middot The Green Belt should be an area that is preserved for future generations to enjoy and appreciate and many statements have been made by both the Government and members of Parliament on their commitment to protect the Green Belt ndash these statements now need to be converted into action in the Local Borough Plans The roll out of Green Belt to local councils in the 1950rsquos was to prevent urban sprawl and the merging of settlements thereby helping to preserve and protect the character of communities it encompassed protect the country setting and encourage development through regeneration of sites within towns and cities not villages

middot The description of Ottershaw by the council itself in the lsquoUrban Characteristicsrsquo publication on the Runnymede Borough Council website states ldquoOttershaw has its own identity and sense of place which is partly derived from the clearly identifiable heart of the urban area focused on The Otter and adjoining local shopping parade and community facilities as well as being surrounded by open greenbelt countryside Removing this green belt that is part of the identifiable heart of Ottershaw would destroy this villagersquos identity and community

middot The planning proposals and building on this part of the green belt land would lead to a considerable population increase in the village Services and facilities will struggle or fail to cope space is already limited at the doctorrsquos surgery and school places are at capacity The transport infrastructure is already stretched with limited bus services busy roads poorly maintained pavements and road surfaces Brox road is already used as a shortcut to avoid traffic congestion Given that Ottershaw does not have a train station it is reasonable to assume that the majority of houses would have at least one car the added traffic from the new development would put a severe strain on the road network and users Available information on mitigation is very vague and very open to interpretation and misguided assumptions

middot The Green Belt land is a habitat to an array of plants and animals including important pollinator species and larger animals such as birds foxes and deer There should be no assumption that animals will simply move to another area habitats are established over many years and this development will be another loss to the maintenance of biodiversity I enjoy the fauna and flora in these areas going for walks along the public footpaths Having such wonderful access to a relaxing escape so close to home is priceless and something I hold dear to myself my family and community What is now a beautiful scenic view will become a spoilt urban sprawl of modern housing

middot I moved to Ottershaw with my wife in 2016 to settle down and start a family The relaxed quiet village sense of community and safety surrounded by beautiful countryside were its appeal I are very concerned and disappointed that this planning proposal is still being considered which will undoubtedly destroy this idyllic setting

There are no ldquoexceptional or very special circumstancesrdquo that justify the removal of Ottershaw East from the Green Belt We trust that the Council will therefore not remove ldquoOttershaw Eastrdquo and ldquoThe Fieldrdquo from the Green Belt

Yours faithfully

Dr Brian Pickett

To Policy Planning and Strategy Team Runnymede Borough Council Civic Centre Station Road Addlestone Surrey KT15 2AH planningrunnymedegovuk

From Dr Brian Pickett 139 Brox Road Ottershaw Surrey KT16 0LG planningrunnymedegovuk

21022018 Re Runnymede 2030 Local Plan Ottershaw East ndash Objection to planning Dear Sirs We are writing to you again as we strongly object to the Runnymede Borough Councils plans to remove land behind houses along Brox Road known as lsquoOttershaw Eastrsquo from the Green Belt We are objecting for a number of reasons listed below bull The Green Belt is precious once it is gone it is gone forever The removal of this

land from the Green Belt does not comply with Planning Policy which states ldquothat Green Belt boundaries should only be altered in exceptional circumstancesrdquo there are no such circumstances that can justify the removal of this piece of land

bull The Green Belt should be an area that is preserved for future generations to enjoy

and appreciate and many statements have been made by both the Government and members of Parliament on their commitment to protect the Green Belt ndash these statements now need to be converted into action in the Local Borough Plans The roll out of Green Belt to local councils in the 1950rsquos was to prevent urban sprawl and the merging of settlements thereby helping to preserve and protect the character of communities it encompassed protect the country setting and encourage development through regeneration of sites within towns and cities not villages

bull The description of Ottershaw by the council itself in the lsquoUrban Characteristicsrsquo

publication on the Runnymede Borough Council website states ldquoOttershaw has its own identity and sense of place which is partly derived from the clearly identifiable heart of the urban area focused on The Otter and adjoining local shopping parade and community facilities as well as being surrounded by open greenbelt countryside Removing this green belt that is part of the identifiable heart of Ottershaw would destroy this villagersquos identity and community

bull The planning proposals and building on this part of the green belt land would lead

to a considerable population increase in the village Services and facilities will struggle or fail to cope space is already limited at the doctorrsquos surgery and school places are at capacity The transport infrastructure is already stretched with limited bus services busy roads poorly maintained pavements and road surfaces Brox road is already used as a shortcut to avoid traffic congestion Given that Ottershaw does not have a train station it is reasonable to assume that the majority of houses would have at least one car the added traffic from the new development would put a severe strain on the road network and users Available information on mitigation is very vague and very open to interpretation and misguided assumptions

bull The Green Belt land is a habitat to an array of plants and animals including important pollinator species and larger animals such as birds foxes and deer There should be no assumption that animals will simply move to another area habitats are established over many years and this development will be another loss to the maintenance of biodiversity I enjoy the fauna and flora in these areas going for walks along the public footpaths Having such wonderful access to a relaxing escape so close to home is priceless and something I hold dear to myself my family and community What is now a beautiful scenic view will become a spoilt urban sprawl of modern housing

bull I moved to Ottershaw with my wife in 2016 to settle down and start a family The

relaxed quiet village sense of community and safety surrounded by beautiful countryside were its appeal I are very concerned and disappointed that this planning proposal is still being considered which will undoubtedly destroy this idyllic setting

There are no ldquoexceptional or very special circumstancesrdquo that justify the removal of Ottershaw East from the Green Belt We trust that the Council will therefore not remove ldquoOttershaw Eastrdquo and ldquoThe Fieldrdquo from the Green Belt Yours faithfully Dr Brian Pickett

FromTo Planning PolicySubject Runnymede Local Plan 2030 - consultation responseDate 21 February 2018 163608Attachments Runnymede LP Response - EE15pdf

Please find attached a consultation response form

________________________________________Christian Leigh BSc(Hons) MPhil MRTPIDirectorLeigh amp Glennie Ltd6 All Souls RoadAscotBerkshire SL5 9EA

1893

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number 01344 297094 Email Address (where relevant)

mailchristianleighcouk

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number Email Address (where relevant)

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

From MCNAB DouglasTo Planning PolicySubject Runnymede Draft Local Plan consultation - Representation from Education and Skills Funding AgencyDate 21 February 2018 091407Attachments Runnymede Reg 19 response ESFADOC

Dear Runnymede Planning Policy Team

Please see attached a representation from the Education and Skills Funding Agency on theRunnymede Local Plan consultation

I would be grateful if you could confirm receipt

Best regardsDoug

Douglas McNab MRTPIForward Planning Manager ndash South East

Planning Team Free Schools CapitalEducation and Skills Funding AgencyDepartment for Education 5th floor Sanctuary Buildings 20 Great Smith Street London SW1P 3BT

Email douglasmcnabeducationgovukMobile 07990 082877Web wwwgovukesfa

1895

image1pngOur Ref ESFALocal PlanRunnymede 2018 21st February 2018

Dear SirMadam

Re Runnymede Local Plan

Consultation under Regulation 19 of Town and Country Planning (Local Planning) (England) Regulations 2012

Submission of the Education and Skills Funding Agency

1 The Education and Skills Funding Agency (ESFA) welcomes the opportunity to contribute to the development of planning policy at the local level

2 The ESFA launched on 1st April 2017 bringing together the existing responsibilities of the Education Funding Agency (EFA) and the Skills Funding Agency (SFA) to create a single funding agency accountable for funding education and training for children young people and adults The ESFA are accountable for pound61 billion of funding a year for the education and training sector including support for all state-provided education for 8 million children aged 3 to 16 and 16 million young people aged 16 to 19

3 Under the provisions of the Education Act 2011 and the Academies Act 2010 all new state schools are now academiesfree schools and the ESFA is the delivery body for many of these rather than local education authorities As such we aim to work closely with local authority education departments and planning authorities to meet the demand for new school places and new schools We do this through a variety of means including by supporting the adoption of sound local plan policies site allocations and guidance (all based on robust evidence) that facilitate the delivery of education infrastructure where and when it is needed and maximise developer contributions for schools In this capacity we would like to offer the following comments in response to the proposals outlined in the above consultation document

Comments on the Local Plan

4 As you will be aware the primary focus at this stage of the Local Planrsquos preparation is on the soundness of the plan with regard to it being positively prepared justified effective and consistent with national policy The following detailed comments set out the ESFArsquos view of the planrsquos soundness in respect of education provision

5 The ESFA notes that the local plan will make provision for a minimum of 7413 net additional dwellings over the plan period Development will generally complement the existing settlement pattern focusing the largest amounts of residential growth primarily in Chertsey (1950 homes) Addlestone (936 homes) and Egham (812 homes) A new ldquolocally led garden villagerdquo is also proposed at Longcross providing a further 1718 homes This level of development will put pressure on existing education infrastructure

6 The plan recognises that ldquoIt is important that infrastructure is delivered in a timely manner to ensure that the needs of the occupiers of new development can be met without placing undue burdens on existing infrastructure facilities and servicesrdquo (para 560) The ESFA supports Policy SD6 Infrastructure Provision amp Timing particularly the signposting of the Infrastructure Delivery Plan (IDP) and the need for development to deliver this either on-site or through s106 or CIL financial contributions off-site and the need for development to be phased in line with the provision of important supporting infrastructure

7 The latest version of the IDP states that there is an ongoing programme of primary school expansions this will help to meet the forecast need for 4-6FE of new capacity over the plan period The need for one new build school project is identified a 2FE primary school at the Longcross Garden Village (estimated cost pound99M to pound15M) this is referred to in the site allocation policies (see below) With respect to secondary school places it is anticipated that up to six additional FE could be required in the Borough by 2021 Additional places will be delivered through the new 6FE Runnymede Free School (which opened in temporary accommodation in 2017) development of additional FE within Salesian School (Catholic faith school) and expansion of another school in the Chertsey area (to accommodate demand from generated by the Longcross Garden Village site)

8 It would be useful if the background data informing these projections of need could be clarified particularly the pupil yield factors used and the evidence base supporting this This would help to demonstrate more clearly to the Inspector that the approach to the planning and delivery of education infrastructure has been positively prepared based on a strategy which seeks to meet objectively assessed infrastructure requirements and is justified based on proportionate evidence The ESFA notes that the Runnymede S106 SPG sets out pupil yield figures however this document dates from December 2007 so the figures may be outdated

9 The ESFA supports the Councilrsquos allocation and safeguarding of land for schools as set out in the following policies

middot Policy SD10 Longcross Garden Village - 2FE primary school with preschoolearly years settings

middot Policy SL2 to SL18 ndash series of housing allocation policies that highlight the need to make a financial contribution to early years primary and secondary school infrastructure ldquoeither through S106 or CIL (or its successor)rdquo

Developer Contributions and CIL

10 One of the tests of soundness is that a Local Plan is lsquoeffectiversquo ie the plan should be deliverable over its period In this context and with specific regard to planning for schools there is a need to ensure that education contributions made by developers are sufficient to deliver the additional school places required to meet the increase in demand generated by new developments The ESFA notes that the council has not adopted CIL and that the Planning Obligations SPG sets out how developer contributions to education provision will be secured via section 106 agreements The ESFA supports the Councilrsquos approach to ensure developer contributions address the impacts arising from growth However the ESFA recommends that the Local Plan includes a commitment to revise the Planning Obligations SPG in line with the latest evidence of the boroughrsquos infrastructure needs pupil yields and build costs (including the cost of school expansion new build and SEN provision) Any such review should be prepared in consultation with the county council as local education authority This will help to ensure appropriate rates are levied and the right infrastructure is secured across the borough

11 The ESFA would be particularly interested in responding to any update to the Infrastructure Delivery Plan or review of infrastructure requirements As such please add the ESFA to the database for future CIL consultations

Forward funding

12 In light of the proposed Longcross Garden Village emerging ESFA proposals for forward funding schools as part of large residential developments may be relevant for example if viability becomes an issue The ESFA aims to be able to clarify forward funding options for schools in 2018 We would be happy to meet to discuss this opportunity further once the options have been finalised and ifwhen relevant Any offer of forward funding would seek to maximise developer contributions to education infrastructure provision while supporting delivery of schools where and when they are needed

Conclusion

13 Finally I hope the above comments are helpful in finalising the Runnymede Local Plan with specific regard to the provision of land for new schools

14 Please notify the ESFA when the Local Plan is submitted for examination the Inspectorrsquos report is published and the Local Plan is adopted

15 Please do not hesitate to contact me if you have any queries regarding this response The ESFA looks forward to continuing to work with Runnymede Borough Council to develop a sound Local Plan that will aid in the delivery of new schools

Yours faithfully

DC McNab

Douglas McNab MRTPI

Forward Planning Manager

Tel 07990 082877

Email

douglasmcnabeducationgovuk

Web

wwwgovuk esfa

Education and Skills Funding Agency13

Department for EducationSanctuary BuildingsGreat Smith StreetLondonSW1P 3BT13

13

Tel 0207 340 700013

13

wwwgovukesfa13

13

13

To

Policy Planning and Strategy Team

Runnymede Borough Council

Civic Centre

Station Road

Addlestone

Surrey

KT15 2AH

From

Dr Brian Pickett

139 Brox Road

Ottershaw

Surrey

KT16 0LG

Page 27: Runnymede Borough Council, for submissions. My contact details are all in the WORD letter attached. But I will provide my telephone number here too, which …

To Policy Planning and Strategy Team Runnymede Borough Council Civic Centre Station Road Addlestone Surrey KT15 2AH planningrunnymedegovuk

From Dr Brian Pickett 139 Brox Road Ottershaw Surrey KT16 0LG planningrunnymedegovuk

21022018 Re Runnymede 2030 Local Plan Ottershaw East ndash Objection to planning Dear Sirs We are writing to you again as we strongly object to the Runnymede Borough Councils plans to remove land behind houses along Brox Road known as lsquoOttershaw Eastrsquo from the Green Belt We are objecting for a number of reasons listed below bull The Green Belt is precious once it is gone it is gone forever The removal of this

land from the Green Belt does not comply with Planning Policy which states ldquothat Green Belt boundaries should only be altered in exceptional circumstancesrdquo there are no such circumstances that can justify the removal of this piece of land

bull The Green Belt should be an area that is preserved for future generations to enjoy

and appreciate and many statements have been made by both the Government and members of Parliament on their commitment to protect the Green Belt ndash these statements now need to be converted into action in the Local Borough Plans The roll out of Green Belt to local councils in the 1950rsquos was to prevent urban sprawl and the merging of settlements thereby helping to preserve and protect the character of communities it encompassed protect the country setting and encourage development through regeneration of sites within towns and cities not villages

bull The description of Ottershaw by the council itself in the lsquoUrban Characteristicsrsquo

publication on the Runnymede Borough Council website states ldquoOttershaw has its own identity and sense of place which is partly derived from the clearly identifiable heart of the urban area focused on The Otter and adjoining local shopping parade and community facilities as well as being surrounded by open greenbelt countryside Removing this green belt that is part of the identifiable heart of Ottershaw would destroy this villagersquos identity and community

bull The planning proposals and building on this part of the green belt land would lead

to a considerable population increase in the village Services and facilities will struggle or fail to cope space is already limited at the doctorrsquos surgery and school places are at capacity The transport infrastructure is already stretched with limited bus services busy roads poorly maintained pavements and road surfaces Brox road is already used as a shortcut to avoid traffic congestion Given that Ottershaw does not have a train station it is reasonable to assume that the majority of houses would have at least one car the added traffic from the new development would put a severe strain on the road network and users Available information on mitigation is very vague and very open to interpretation and misguided assumptions

bull The Green Belt land is a habitat to an array of plants and animals including important pollinator species and larger animals such as birds foxes and deer There should be no assumption that animals will simply move to another area habitats are established over many years and this development will be another loss to the maintenance of biodiversity I enjoy the fauna and flora in these areas going for walks along the public footpaths Having such wonderful access to a relaxing escape so close to home is priceless and something I hold dear to myself my family and community What is now a beautiful scenic view will become a spoilt urban sprawl of modern housing

bull I moved to Ottershaw with my wife in 2016 to settle down and start a family The

relaxed quiet village sense of community and safety surrounded by beautiful countryside were its appeal I are very concerned and disappointed that this planning proposal is still being considered which will undoubtedly destroy this idyllic setting

There are no ldquoexceptional or very special circumstancesrdquo that justify the removal of Ottershaw East from the Green Belt We trust that the Council will therefore not remove ldquoOttershaw Eastrdquo and ldquoThe Fieldrdquo from the Green Belt Yours faithfully Dr Brian Pickett

FromTo Planning PolicySubject Runnymede Local Plan 2030 - consultation responseDate 21 February 2018 163608Attachments Runnymede LP Response - EE15pdf

Please find attached a consultation response form

________________________________________Christian Leigh BSc(Hons) MPhil MRTPIDirectorLeigh amp Glennie Ltd6 All Souls RoadAscotBerkshire SL5 9EA

1893

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number 01344 297094 Email Address (where relevant)

mailchristianleighcouk

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number Email Address (where relevant)

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

From MCNAB DouglasTo Planning PolicySubject Runnymede Draft Local Plan consultation - Representation from Education and Skills Funding AgencyDate 21 February 2018 091407Attachments Runnymede Reg 19 response ESFADOC

Dear Runnymede Planning Policy Team

Please see attached a representation from the Education and Skills Funding Agency on theRunnymede Local Plan consultation

I would be grateful if you could confirm receipt

Best regardsDoug

Douglas McNab MRTPIForward Planning Manager ndash South East

Planning Team Free Schools CapitalEducation and Skills Funding AgencyDepartment for Education 5th floor Sanctuary Buildings 20 Great Smith Street London SW1P 3BT

Email douglasmcnabeducationgovukMobile 07990 082877Web wwwgovukesfa

1895

image1pngOur Ref ESFALocal PlanRunnymede 2018 21st February 2018

Dear SirMadam

Re Runnymede Local Plan

Consultation under Regulation 19 of Town and Country Planning (Local Planning) (England) Regulations 2012

Submission of the Education and Skills Funding Agency

1 The Education and Skills Funding Agency (ESFA) welcomes the opportunity to contribute to the development of planning policy at the local level

2 The ESFA launched on 1st April 2017 bringing together the existing responsibilities of the Education Funding Agency (EFA) and the Skills Funding Agency (SFA) to create a single funding agency accountable for funding education and training for children young people and adults The ESFA are accountable for pound61 billion of funding a year for the education and training sector including support for all state-provided education for 8 million children aged 3 to 16 and 16 million young people aged 16 to 19

3 Under the provisions of the Education Act 2011 and the Academies Act 2010 all new state schools are now academiesfree schools and the ESFA is the delivery body for many of these rather than local education authorities As such we aim to work closely with local authority education departments and planning authorities to meet the demand for new school places and new schools We do this through a variety of means including by supporting the adoption of sound local plan policies site allocations and guidance (all based on robust evidence) that facilitate the delivery of education infrastructure where and when it is needed and maximise developer contributions for schools In this capacity we would like to offer the following comments in response to the proposals outlined in the above consultation document

Comments on the Local Plan

4 As you will be aware the primary focus at this stage of the Local Planrsquos preparation is on the soundness of the plan with regard to it being positively prepared justified effective and consistent with national policy The following detailed comments set out the ESFArsquos view of the planrsquos soundness in respect of education provision

5 The ESFA notes that the local plan will make provision for a minimum of 7413 net additional dwellings over the plan period Development will generally complement the existing settlement pattern focusing the largest amounts of residential growth primarily in Chertsey (1950 homes) Addlestone (936 homes) and Egham (812 homes) A new ldquolocally led garden villagerdquo is also proposed at Longcross providing a further 1718 homes This level of development will put pressure on existing education infrastructure

6 The plan recognises that ldquoIt is important that infrastructure is delivered in a timely manner to ensure that the needs of the occupiers of new development can be met without placing undue burdens on existing infrastructure facilities and servicesrdquo (para 560) The ESFA supports Policy SD6 Infrastructure Provision amp Timing particularly the signposting of the Infrastructure Delivery Plan (IDP) and the need for development to deliver this either on-site or through s106 or CIL financial contributions off-site and the need for development to be phased in line with the provision of important supporting infrastructure

7 The latest version of the IDP states that there is an ongoing programme of primary school expansions this will help to meet the forecast need for 4-6FE of new capacity over the plan period The need for one new build school project is identified a 2FE primary school at the Longcross Garden Village (estimated cost pound99M to pound15M) this is referred to in the site allocation policies (see below) With respect to secondary school places it is anticipated that up to six additional FE could be required in the Borough by 2021 Additional places will be delivered through the new 6FE Runnymede Free School (which opened in temporary accommodation in 2017) development of additional FE within Salesian School (Catholic faith school) and expansion of another school in the Chertsey area (to accommodate demand from generated by the Longcross Garden Village site)

8 It would be useful if the background data informing these projections of need could be clarified particularly the pupil yield factors used and the evidence base supporting this This would help to demonstrate more clearly to the Inspector that the approach to the planning and delivery of education infrastructure has been positively prepared based on a strategy which seeks to meet objectively assessed infrastructure requirements and is justified based on proportionate evidence The ESFA notes that the Runnymede S106 SPG sets out pupil yield figures however this document dates from December 2007 so the figures may be outdated

9 The ESFA supports the Councilrsquos allocation and safeguarding of land for schools as set out in the following policies

middot Policy SD10 Longcross Garden Village - 2FE primary school with preschoolearly years settings

middot Policy SL2 to SL18 ndash series of housing allocation policies that highlight the need to make a financial contribution to early years primary and secondary school infrastructure ldquoeither through S106 or CIL (or its successor)rdquo

Developer Contributions and CIL

10 One of the tests of soundness is that a Local Plan is lsquoeffectiversquo ie the plan should be deliverable over its period In this context and with specific regard to planning for schools there is a need to ensure that education contributions made by developers are sufficient to deliver the additional school places required to meet the increase in demand generated by new developments The ESFA notes that the council has not adopted CIL and that the Planning Obligations SPG sets out how developer contributions to education provision will be secured via section 106 agreements The ESFA supports the Councilrsquos approach to ensure developer contributions address the impacts arising from growth However the ESFA recommends that the Local Plan includes a commitment to revise the Planning Obligations SPG in line with the latest evidence of the boroughrsquos infrastructure needs pupil yields and build costs (including the cost of school expansion new build and SEN provision) Any such review should be prepared in consultation with the county council as local education authority This will help to ensure appropriate rates are levied and the right infrastructure is secured across the borough

11 The ESFA would be particularly interested in responding to any update to the Infrastructure Delivery Plan or review of infrastructure requirements As such please add the ESFA to the database for future CIL consultations

Forward funding

12 In light of the proposed Longcross Garden Village emerging ESFA proposals for forward funding schools as part of large residential developments may be relevant for example if viability becomes an issue The ESFA aims to be able to clarify forward funding options for schools in 2018 We would be happy to meet to discuss this opportunity further once the options have been finalised and ifwhen relevant Any offer of forward funding would seek to maximise developer contributions to education infrastructure provision while supporting delivery of schools where and when they are needed

Conclusion

13 Finally I hope the above comments are helpful in finalising the Runnymede Local Plan with specific regard to the provision of land for new schools

14 Please notify the ESFA when the Local Plan is submitted for examination the Inspectorrsquos report is published and the Local Plan is adopted

15 Please do not hesitate to contact me if you have any queries regarding this response The ESFA looks forward to continuing to work with Runnymede Borough Council to develop a sound Local Plan that will aid in the delivery of new schools

Yours faithfully

DC McNab

Douglas McNab MRTPI

Forward Planning Manager

Tel 07990 082877

Email

douglasmcnabeducationgovuk
Page 28: Runnymede Borough Council, for submissions. My contact details are all in the WORD letter attached. But I will provide my telephone number here too, which …

bull The planning proposals and building on this part of the green belt land would lead

to a considerable population increase in the village Services and facilities will struggle or fail to cope space is already limited at the doctorrsquos surgery and school places are at capacity The transport infrastructure is already stretched with limited bus services busy roads poorly maintained pavements and road surfaces Brox road is already used as a shortcut to avoid traffic congestion Given that Ottershaw does not have a train station it is reasonable to assume that the majority of houses would have at least one car the added traffic from the new development would put a severe strain on the road network and users Available information on mitigation is very vague and very open to interpretation and misguided assumptions

bull The Green Belt land is a habitat to an array of plants and animals including important pollinator species and larger animals such as birds foxes and deer There should be no assumption that animals will simply move to another area habitats are established over many years and this development will be another loss to the maintenance of biodiversity I enjoy the fauna and flora in these areas going for walks along the public footpaths Having such wonderful access to a relaxing escape so close to home is priceless and something I hold dear to myself my family and community What is now a beautiful scenic view will become a spoilt urban sprawl of modern housing

bull I moved to Ottershaw with my wife in 2016 to settle down and start a family The

relaxed quiet village sense of community and safety surrounded by beautiful countryside were its appeal I are very concerned and disappointed that this planning proposal is still being considered which will undoubtedly destroy this idyllic setting

There are no ldquoexceptional or very special circumstancesrdquo that justify the removal of Ottershaw East from the Green Belt We trust that the Council will therefore not remove ldquoOttershaw Eastrdquo and ldquoThe Fieldrdquo from the Green Belt Yours faithfully Dr Brian Pickett

FromTo Planning PolicySubject Runnymede Local Plan 2030 - consultation responseDate 21 February 2018 163608Attachments Runnymede LP Response - EE15pdf

Please find attached a consultation response form

________________________________________Christian Leigh BSc(Hons) MPhil MRTPIDirectorLeigh amp Glennie Ltd6 All Souls RoadAscotBerkshire SL5 9EA

1893

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number 01344 297094 Email Address (where relevant)

mailchristianleighcouk

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number Email Address (where relevant)

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

From MCNAB DouglasTo Planning PolicySubject Runnymede Draft Local Plan consultation - Representation from Education and Skills Funding AgencyDate 21 February 2018 091407Attachments Runnymede Reg 19 response ESFADOC

Dear Runnymede Planning Policy Team

Please see attached a representation from the Education and Skills Funding Agency on theRunnymede Local Plan consultation

I would be grateful if you could confirm receipt

Best regardsDoug

Douglas McNab MRTPIForward Planning Manager ndash South East

Planning Team Free Schools CapitalEducation and Skills Funding AgencyDepartment for Education 5th floor Sanctuary Buildings 20 Great Smith Street London SW1P 3BT

Email douglasmcnabeducationgovukMobile 07990 082877Web wwwgovukesfa

1895

image1pngOur Ref ESFALocal PlanRunnymede 2018 21st February 2018

Dear SirMadam

Re Runnymede Local Plan

Consultation under Regulation 19 of Town and Country Planning (Local Planning) (England) Regulations 2012

Submission of the Education and Skills Funding Agency

1 The Education and Skills Funding Agency (ESFA) welcomes the opportunity to contribute to the development of planning policy at the local level

2 The ESFA launched on 1st April 2017 bringing together the existing responsibilities of the Education Funding Agency (EFA) and the Skills Funding Agency (SFA) to create a single funding agency accountable for funding education and training for children young people and adults The ESFA are accountable for pound61 billion of funding a year for the education and training sector including support for all state-provided education for 8 million children aged 3 to 16 and 16 million young people aged 16 to 19

3 Under the provisions of the Education Act 2011 and the Academies Act 2010 all new state schools are now academiesfree schools and the ESFA is the delivery body for many of these rather than local education authorities As such we aim to work closely with local authority education departments and planning authorities to meet the demand for new school places and new schools We do this through a variety of means including by supporting the adoption of sound local plan policies site allocations and guidance (all based on robust evidence) that facilitate the delivery of education infrastructure where and when it is needed and maximise developer contributions for schools In this capacity we would like to offer the following comments in response to the proposals outlined in the above consultation document

Comments on the Local Plan

4 As you will be aware the primary focus at this stage of the Local Planrsquos preparation is on the soundness of the plan with regard to it being positively prepared justified effective and consistent with national policy The following detailed comments set out the ESFArsquos view of the planrsquos soundness in respect of education provision

5 The ESFA notes that the local plan will make provision for a minimum of 7413 net additional dwellings over the plan period Development will generally complement the existing settlement pattern focusing the largest amounts of residential growth primarily in Chertsey (1950 homes) Addlestone (936 homes) and Egham (812 homes) A new ldquolocally led garden villagerdquo is also proposed at Longcross providing a further 1718 homes This level of development will put pressure on existing education infrastructure

6 The plan recognises that ldquoIt is important that infrastructure is delivered in a timely manner to ensure that the needs of the occupiers of new development can be met without placing undue burdens on existing infrastructure facilities and servicesrdquo (para 560) The ESFA supports Policy SD6 Infrastructure Provision amp Timing particularly the signposting of the Infrastructure Delivery Plan (IDP) and the need for development to deliver this either on-site or through s106 or CIL financial contributions off-site and the need for development to be phased in line with the provision of important supporting infrastructure

7 The latest version of the IDP states that there is an ongoing programme of primary school expansions this will help to meet the forecast need for 4-6FE of new capacity over the plan period The need for one new build school project is identified a 2FE primary school at the Longcross Garden Village (estimated cost pound99M to pound15M) this is referred to in the site allocation policies (see below) With respect to secondary school places it is anticipated that up to six additional FE could be required in the Borough by 2021 Additional places will be delivered through the new 6FE Runnymede Free School (which opened in temporary accommodation in 2017) development of additional FE within Salesian School (Catholic faith school) and expansion of another school in the Chertsey area (to accommodate demand from generated by the Longcross Garden Village site)

8 It would be useful if the background data informing these projections of need could be clarified particularly the pupil yield factors used and the evidence base supporting this This would help to demonstrate more clearly to the Inspector that the approach to the planning and delivery of education infrastructure has been positively prepared based on a strategy which seeks to meet objectively assessed infrastructure requirements and is justified based on proportionate evidence The ESFA notes that the Runnymede S106 SPG sets out pupil yield figures however this document dates from December 2007 so the figures may be outdated

9 The ESFA supports the Councilrsquos allocation and safeguarding of land for schools as set out in the following policies

middot Policy SD10 Longcross Garden Village - 2FE primary school with preschoolearly years settings

middot Policy SL2 to SL18 ndash series of housing allocation policies that highlight the need to make a financial contribution to early years primary and secondary school infrastructure ldquoeither through S106 or CIL (or its successor)rdquo

Developer Contributions and CIL

10 One of the tests of soundness is that a Local Plan is lsquoeffectiversquo ie the plan should be deliverable over its period In this context and with specific regard to planning for schools there is a need to ensure that education contributions made by developers are sufficient to deliver the additional school places required to meet the increase in demand generated by new developments The ESFA notes that the council has not adopted CIL and that the Planning Obligations SPG sets out how developer contributions to education provision will be secured via section 106 agreements The ESFA supports the Councilrsquos approach to ensure developer contributions address the impacts arising from growth However the ESFA recommends that the Local Plan includes a commitment to revise the Planning Obligations SPG in line with the latest evidence of the boroughrsquos infrastructure needs pupil yields and build costs (including the cost of school expansion new build and SEN provision) Any such review should be prepared in consultation with the county council as local education authority This will help to ensure appropriate rates are levied and the right infrastructure is secured across the borough

11 The ESFA would be particularly interested in responding to any update to the Infrastructure Delivery Plan or review of infrastructure requirements As such please add the ESFA to the database for future CIL consultations

Forward funding

12 In light of the proposed Longcross Garden Village emerging ESFA proposals for forward funding schools as part of large residential developments may be relevant for example if viability becomes an issue The ESFA aims to be able to clarify forward funding options for schools in 2018 We would be happy to meet to discuss this opportunity further once the options have been finalised and ifwhen relevant Any offer of forward funding would seek to maximise developer contributions to education infrastructure provision while supporting delivery of schools where and when they are needed

Conclusion

13 Finally I hope the above comments are helpful in finalising the Runnymede Local Plan with specific regard to the provision of land for new schools

14 Please notify the ESFA when the Local Plan is submitted for examination the Inspectorrsquos report is published and the Local Plan is adopted

15 Please do not hesitate to contact me if you have any queries regarding this response The ESFA looks forward to continuing to work with Runnymede Borough Council to develop a sound Local Plan that will aid in the delivery of new schools

Yours faithfully

DC McNab

Douglas McNab MRTPI

Forward Planning Manager

Tel 07990 082877

Email

douglasmcnabeducationgovuk
Page 29: Runnymede Borough Council, for submissions. My contact details are all in the WORD letter attached. But I will provide my telephone number here too, which …

FromTo Planning PolicySubject Runnymede Local Plan 2030 - consultation responseDate 21 February 2018 163608Attachments Runnymede LP Response - EE15pdf

Please find attached a consultation response form

________________________________________Christian Leigh BSc(Hons) MPhil MRTPIDirectorLeigh amp Glennie Ltd6 All Souls RoadAscotBerkshire SL5 9EA

1893

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number 01344 297094 Email Address (where relevant)

mailchristianleighcouk

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number Email Address (where relevant)

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

From MCNAB DouglasTo Planning PolicySubject Runnymede Draft Local Plan consultation - Representation from Education and Skills Funding AgencyDate 21 February 2018 091407Attachments Runnymede Reg 19 response ESFADOC

Dear Runnymede Planning Policy Team

Please see attached a representation from the Education and Skills Funding Agency on theRunnymede Local Plan consultation

I would be grateful if you could confirm receipt

Best regardsDoug

Douglas McNab MRTPIForward Planning Manager ndash South East

Planning Team Free Schools CapitalEducation and Skills Funding AgencyDepartment for Education 5th floor Sanctuary Buildings 20 Great Smith Street London SW1P 3BT

Email douglasmcnabeducationgovukMobile 07990 082877Web wwwgovukesfa

1895

image1pngOur Ref ESFALocal PlanRunnymede 2018 21st February 2018

Dear SirMadam

Re Runnymede Local Plan

Consultation under Regulation 19 of Town and Country Planning (Local Planning) (England) Regulations 2012

Submission of the Education and Skills Funding Agency

1 The Education and Skills Funding Agency (ESFA) welcomes the opportunity to contribute to the development of planning policy at the local level

2 The ESFA launched on 1st April 2017 bringing together the existing responsibilities of the Education Funding Agency (EFA) and the Skills Funding Agency (SFA) to create a single funding agency accountable for funding education and training for children young people and adults The ESFA are accountable for pound61 billion of funding a year for the education and training sector including support for all state-provided education for 8 million children aged 3 to 16 and 16 million young people aged 16 to 19

3 Under the provisions of the Education Act 2011 and the Academies Act 2010 all new state schools are now academiesfree schools and the ESFA is the delivery body for many of these rather than local education authorities As such we aim to work closely with local authority education departments and planning authorities to meet the demand for new school places and new schools We do this through a variety of means including by supporting the adoption of sound local plan policies site allocations and guidance (all based on robust evidence) that facilitate the delivery of education infrastructure where and when it is needed and maximise developer contributions for schools In this capacity we would like to offer the following comments in response to the proposals outlined in the above consultation document

Comments on the Local Plan

4 As you will be aware the primary focus at this stage of the Local Planrsquos preparation is on the soundness of the plan with regard to it being positively prepared justified effective and consistent with national policy The following detailed comments set out the ESFArsquos view of the planrsquos soundness in respect of education provision

5 The ESFA notes that the local plan will make provision for a minimum of 7413 net additional dwellings over the plan period Development will generally complement the existing settlement pattern focusing the largest amounts of residential growth primarily in Chertsey (1950 homes) Addlestone (936 homes) and Egham (812 homes) A new ldquolocally led garden villagerdquo is also proposed at Longcross providing a further 1718 homes This level of development will put pressure on existing education infrastructure

6 The plan recognises that ldquoIt is important that infrastructure is delivered in a timely manner to ensure that the needs of the occupiers of new development can be met without placing undue burdens on existing infrastructure facilities and servicesrdquo (para 560) The ESFA supports Policy SD6 Infrastructure Provision amp Timing particularly the signposting of the Infrastructure Delivery Plan (IDP) and the need for development to deliver this either on-site or through s106 or CIL financial contributions off-site and the need for development to be phased in line with the provision of important supporting infrastructure

7 The latest version of the IDP states that there is an ongoing programme of primary school expansions this will help to meet the forecast need for 4-6FE of new capacity over the plan period The need for one new build school project is identified a 2FE primary school at the Longcross Garden Village (estimated cost pound99M to pound15M) this is referred to in the site allocation policies (see below) With respect to secondary school places it is anticipated that up to six additional FE could be required in the Borough by 2021 Additional places will be delivered through the new 6FE Runnymede Free School (which opened in temporary accommodation in 2017) development of additional FE within Salesian School (Catholic faith school) and expansion of another school in the Chertsey area (to accommodate demand from generated by the Longcross Garden Village site)

8 It would be useful if the background data informing these projections of need could be clarified particularly the pupil yield factors used and the evidence base supporting this This would help to demonstrate more clearly to the Inspector that the approach to the planning and delivery of education infrastructure has been positively prepared based on a strategy which seeks to meet objectively assessed infrastructure requirements and is justified based on proportionate evidence The ESFA notes that the Runnymede S106 SPG sets out pupil yield figures however this document dates from December 2007 so the figures may be outdated

9 The ESFA supports the Councilrsquos allocation and safeguarding of land for schools as set out in the following policies

middot Policy SD10 Longcross Garden Village - 2FE primary school with preschoolearly years settings

middot Policy SL2 to SL18 ndash series of housing allocation policies that highlight the need to make a financial contribution to early years primary and secondary school infrastructure ldquoeither through S106 or CIL (or its successor)rdquo

Developer Contributions and CIL

10 One of the tests of soundness is that a Local Plan is lsquoeffectiversquo ie the plan should be deliverable over its period In this context and with specific regard to planning for schools there is a need to ensure that education contributions made by developers are sufficient to deliver the additional school places required to meet the increase in demand generated by new developments The ESFA notes that the council has not adopted CIL and that the Planning Obligations SPG sets out how developer contributions to education provision will be secured via section 106 agreements The ESFA supports the Councilrsquos approach to ensure developer contributions address the impacts arising from growth However the ESFA recommends that the Local Plan includes a commitment to revise the Planning Obligations SPG in line with the latest evidence of the boroughrsquos infrastructure needs pupil yields and build costs (including the cost of school expansion new build and SEN provision) Any such review should be prepared in consultation with the county council as local education authority This will help to ensure appropriate rates are levied and the right infrastructure is secured across the borough

11 The ESFA would be particularly interested in responding to any update to the Infrastructure Delivery Plan or review of infrastructure requirements As such please add the ESFA to the database for future CIL consultations

Forward funding

12 In light of the proposed Longcross Garden Village emerging ESFA proposals for forward funding schools as part of large residential developments may be relevant for example if viability becomes an issue The ESFA aims to be able to clarify forward funding options for schools in 2018 We would be happy to meet to discuss this opportunity further once the options have been finalised and ifwhen relevant Any offer of forward funding would seek to maximise developer contributions to education infrastructure provision while supporting delivery of schools where and when they are needed

Conclusion

13 Finally I hope the above comments are helpful in finalising the Runnymede Local Plan with specific regard to the provision of land for new schools

14 Please notify the ESFA when the Local Plan is submitted for examination the Inspectorrsquos report is published and the Local Plan is adopted

15 Please do not hesitate to contact me if you have any queries regarding this response The ESFA looks forward to continuing to work with Runnymede Borough Council to develop a sound Local Plan that will aid in the delivery of new schools

Yours faithfully

DC McNab

Douglas McNab MRTPI

Forward Planning Manager

Tel 07990 082877

Email

douglasmcnabeducationgovuk
Page 30: Runnymede Borough Council, for submissions. My contact details are all in the WORD letter attached. But I will provide my telephone number here too, which …

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number 01344 297094 Email Address (where relevant)

mailchristianleighcouk

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number Email Address (where relevant)

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

From MCNAB DouglasTo Planning PolicySubject Runnymede Draft Local Plan consultation - Representation from Education and Skills Funding AgencyDate 21 February 2018 091407Attachments Runnymede Reg 19 response ESFADOC

Dear Runnymede Planning Policy Team

Please see attached a representation from the Education and Skills Funding Agency on theRunnymede Local Plan consultation

I would be grateful if you could confirm receipt

Best regardsDoug

Douglas McNab MRTPIForward Planning Manager ndash South East

Planning Team Free Schools CapitalEducation and Skills Funding AgencyDepartment for Education 5th floor Sanctuary Buildings 20 Great Smith Street London SW1P 3BT

Email douglasmcnabeducationgovukMobile 07990 082877Web wwwgovukesfa

1895

image1pngOur Ref ESFALocal PlanRunnymede 2018 21st February 2018

Dear SirMadam

Re Runnymede Local Plan

Consultation under Regulation 19 of Town and Country Planning (Local Planning) (England) Regulations 2012

Submission of the Education and Skills Funding Agency

1 The Education and Skills Funding Agency (ESFA) welcomes the opportunity to contribute to the development of planning policy at the local level

2 The ESFA launched on 1st April 2017 bringing together the existing responsibilities of the Education Funding Agency (EFA) and the Skills Funding Agency (SFA) to create a single funding agency accountable for funding education and training for children young people and adults The ESFA are accountable for pound61 billion of funding a year for the education and training sector including support for all state-provided education for 8 million children aged 3 to 16 and 16 million young people aged 16 to 19

3 Under the provisions of the Education Act 2011 and the Academies Act 2010 all new state schools are now academiesfree schools and the ESFA is the delivery body for many of these rather than local education authorities As such we aim to work closely with local authority education departments and planning authorities to meet the demand for new school places and new schools We do this through a variety of means including by supporting the adoption of sound local plan policies site allocations and guidance (all based on robust evidence) that facilitate the delivery of education infrastructure where and when it is needed and maximise developer contributions for schools In this capacity we would like to offer the following comments in response to the proposals outlined in the above consultation document

Comments on the Local Plan

4 As you will be aware the primary focus at this stage of the Local Planrsquos preparation is on the soundness of the plan with regard to it being positively prepared justified effective and consistent with national policy The following detailed comments set out the ESFArsquos view of the planrsquos soundness in respect of education provision

5 The ESFA notes that the local plan will make provision for a minimum of 7413 net additional dwellings over the plan period Development will generally complement the existing settlement pattern focusing the largest amounts of residential growth primarily in Chertsey (1950 homes) Addlestone (936 homes) and Egham (812 homes) A new ldquolocally led garden villagerdquo is also proposed at Longcross providing a further 1718 homes This level of development will put pressure on existing education infrastructure

6 The plan recognises that ldquoIt is important that infrastructure is delivered in a timely manner to ensure that the needs of the occupiers of new development can be met without placing undue burdens on existing infrastructure facilities and servicesrdquo (para 560) The ESFA supports Policy SD6 Infrastructure Provision amp Timing particularly the signposting of the Infrastructure Delivery Plan (IDP) and the need for development to deliver this either on-site or through s106 or CIL financial contributions off-site and the need for development to be phased in line with the provision of important supporting infrastructure

7 The latest version of the IDP states that there is an ongoing programme of primary school expansions this will help to meet the forecast need for 4-6FE of new capacity over the plan period The need for one new build school project is identified a 2FE primary school at the Longcross Garden Village (estimated cost pound99M to pound15M) this is referred to in the site allocation policies (see below) With respect to secondary school places it is anticipated that up to six additional FE could be required in the Borough by 2021 Additional places will be delivered through the new 6FE Runnymede Free School (which opened in temporary accommodation in 2017) development of additional FE within Salesian School (Catholic faith school) and expansion of another school in the Chertsey area (to accommodate demand from generated by the Longcross Garden Village site)

8 It would be useful if the background data informing these projections of need could be clarified particularly the pupil yield factors used and the evidence base supporting this This would help to demonstrate more clearly to the Inspector that the approach to the planning and delivery of education infrastructure has been positively prepared based on a strategy which seeks to meet objectively assessed infrastructure requirements and is justified based on proportionate evidence The ESFA notes that the Runnymede S106 SPG sets out pupil yield figures however this document dates from December 2007 so the figures may be outdated

9 The ESFA supports the Councilrsquos allocation and safeguarding of land for schools as set out in the following policies

middot Policy SD10 Longcross Garden Village - 2FE primary school with preschoolearly years settings

middot Policy SL2 to SL18 ndash series of housing allocation policies that highlight the need to make a financial contribution to early years primary and secondary school infrastructure ldquoeither through S106 or CIL (or its successor)rdquo

Developer Contributions and CIL

10 One of the tests of soundness is that a Local Plan is lsquoeffectiversquo ie the plan should be deliverable over its period In this context and with specific regard to planning for schools there is a need to ensure that education contributions made by developers are sufficient to deliver the additional school places required to meet the increase in demand generated by new developments The ESFA notes that the council has not adopted CIL and that the Planning Obligations SPG sets out how developer contributions to education provision will be secured via section 106 agreements The ESFA supports the Councilrsquos approach to ensure developer contributions address the impacts arising from growth However the ESFA recommends that the Local Plan includes a commitment to revise the Planning Obligations SPG in line with the latest evidence of the boroughrsquos infrastructure needs pupil yields and build costs (including the cost of school expansion new build and SEN provision) Any such review should be prepared in consultation with the county council as local education authority This will help to ensure appropriate rates are levied and the right infrastructure is secured across the borough

11 The ESFA would be particularly interested in responding to any update to the Infrastructure Delivery Plan or review of infrastructure requirements As such please add the ESFA to the database for future CIL consultations

Forward funding

12 In light of the proposed Longcross Garden Village emerging ESFA proposals for forward funding schools as part of large residential developments may be relevant for example if viability becomes an issue The ESFA aims to be able to clarify forward funding options for schools in 2018 We would be happy to meet to discuss this opportunity further once the options have been finalised and ifwhen relevant Any offer of forward funding would seek to maximise developer contributions to education infrastructure provision while supporting delivery of schools where and when they are needed

Conclusion

13 Finally I hope the above comments are helpful in finalising the Runnymede Local Plan with specific regard to the provision of land for new schools

14 Please notify the ESFA when the Local Plan is submitted for examination the Inspectorrsquos report is published and the Local Plan is adopted

15 Please do not hesitate to contact me if you have any queries regarding this response The ESFA looks forward to continuing to work with Runnymede Borough Council to develop a sound Local Plan that will aid in the delivery of new schools

Yours faithfully

DC McNab

Douglas McNab MRTPI

Forward Planning Manager

Tel 07990 082877

Email

douglasmcnabeducationgovuk
Page 31: Runnymede Borough Council, for submissions. My contact details are all in the WORD letter attached. But I will provide my telephone number here too, which …

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number Email Address (where relevant)

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

From MCNAB DouglasTo Planning PolicySubject Runnymede Draft Local Plan consultation - Representation from Education and Skills Funding AgencyDate 21 February 2018 091407Attachments Runnymede Reg 19 response ESFADOC

Dear Runnymede Planning Policy Team

Please see attached a representation from the Education and Skills Funding Agency on theRunnymede Local Plan consultation

I would be grateful if you could confirm receipt

Best regardsDoug

Douglas McNab MRTPIForward Planning Manager ndash South East

Planning Team Free Schools CapitalEducation and Skills Funding AgencyDepartment for Education 5th floor Sanctuary Buildings 20 Great Smith Street London SW1P 3BT

Email douglasmcnabeducationgovukMobile 07990 082877Web wwwgovukesfa

1895

image1pngOur Ref ESFALocal PlanRunnymede 2018 21st February 2018

Dear SirMadam

Re Runnymede Local Plan

Consultation under Regulation 19 of Town and Country Planning (Local Planning) (England) Regulations 2012

Submission of the Education and Skills Funding Agency

1 The Education and Skills Funding Agency (ESFA) welcomes the opportunity to contribute to the development of planning policy at the local level

2 The ESFA launched on 1st April 2017 bringing together the existing responsibilities of the Education Funding Agency (EFA) and the Skills Funding Agency (SFA) to create a single funding agency accountable for funding education and training for children young people and adults The ESFA are accountable for pound61 billion of funding a year for the education and training sector including support for all state-provided education for 8 million children aged 3 to 16 and 16 million young people aged 16 to 19

3 Under the provisions of the Education Act 2011 and the Academies Act 2010 all new state schools are now academiesfree schools and the ESFA is the delivery body for many of these rather than local education authorities As such we aim to work closely with local authority education departments and planning authorities to meet the demand for new school places and new schools We do this through a variety of means including by supporting the adoption of sound local plan policies site allocations and guidance (all based on robust evidence) that facilitate the delivery of education infrastructure where and when it is needed and maximise developer contributions for schools In this capacity we would like to offer the following comments in response to the proposals outlined in the above consultation document

Comments on the Local Plan

4 As you will be aware the primary focus at this stage of the Local Planrsquos preparation is on the soundness of the plan with regard to it being positively prepared justified effective and consistent with national policy The following detailed comments set out the ESFArsquos view of the planrsquos soundness in respect of education provision

5 The ESFA notes that the local plan will make provision for a minimum of 7413 net additional dwellings over the plan period Development will generally complement the existing settlement pattern focusing the largest amounts of residential growth primarily in Chertsey (1950 homes) Addlestone (936 homes) and Egham (812 homes) A new ldquolocally led garden villagerdquo is also proposed at Longcross providing a further 1718 homes This level of development will put pressure on existing education infrastructure

6 The plan recognises that ldquoIt is important that infrastructure is delivered in a timely manner to ensure that the needs of the occupiers of new development can be met without placing undue burdens on existing infrastructure facilities and servicesrdquo (para 560) The ESFA supports Policy SD6 Infrastructure Provision amp Timing particularly the signposting of the Infrastructure Delivery Plan (IDP) and the need for development to deliver this either on-site or through s106 or CIL financial contributions off-site and the need for development to be phased in line with the provision of important supporting infrastructure

7 The latest version of the IDP states that there is an ongoing programme of primary school expansions this will help to meet the forecast need for 4-6FE of new capacity over the plan period The need for one new build school project is identified a 2FE primary school at the Longcross Garden Village (estimated cost pound99M to pound15M) this is referred to in the site allocation policies (see below) With respect to secondary school places it is anticipated that up to six additional FE could be required in the Borough by 2021 Additional places will be delivered through the new 6FE Runnymede Free School (which opened in temporary accommodation in 2017) development of additional FE within Salesian School (Catholic faith school) and expansion of another school in the Chertsey area (to accommodate demand from generated by the Longcross Garden Village site)

8 It would be useful if the background data informing these projections of need could be clarified particularly the pupil yield factors used and the evidence base supporting this This would help to demonstrate more clearly to the Inspector that the approach to the planning and delivery of education infrastructure has been positively prepared based on a strategy which seeks to meet objectively assessed infrastructure requirements and is justified based on proportionate evidence The ESFA notes that the Runnymede S106 SPG sets out pupil yield figures however this document dates from December 2007 so the figures may be outdated

9 The ESFA supports the Councilrsquos allocation and safeguarding of land for schools as set out in the following policies

middot Policy SD10 Longcross Garden Village - 2FE primary school with preschoolearly years settings

middot Policy SL2 to SL18 ndash series of housing allocation policies that highlight the need to make a financial contribution to early years primary and secondary school infrastructure ldquoeither through S106 or CIL (or its successor)rdquo

Developer Contributions and CIL

10 One of the tests of soundness is that a Local Plan is lsquoeffectiversquo ie the plan should be deliverable over its period In this context and with specific regard to planning for schools there is a need to ensure that education contributions made by developers are sufficient to deliver the additional school places required to meet the increase in demand generated by new developments The ESFA notes that the council has not adopted CIL and that the Planning Obligations SPG sets out how developer contributions to education provision will be secured via section 106 agreements The ESFA supports the Councilrsquos approach to ensure developer contributions address the impacts arising from growth However the ESFA recommends that the Local Plan includes a commitment to revise the Planning Obligations SPG in line with the latest evidence of the boroughrsquos infrastructure needs pupil yields and build costs (including the cost of school expansion new build and SEN provision) Any such review should be prepared in consultation with the county council as local education authority This will help to ensure appropriate rates are levied and the right infrastructure is secured across the borough

11 The ESFA would be particularly interested in responding to any update to the Infrastructure Delivery Plan or review of infrastructure requirements As such please add the ESFA to the database for future CIL consultations

Forward funding

12 In light of the proposed Longcross Garden Village emerging ESFA proposals for forward funding schools as part of large residential developments may be relevant for example if viability becomes an issue The ESFA aims to be able to clarify forward funding options for schools in 2018 We would be happy to meet to discuss this opportunity further once the options have been finalised and ifwhen relevant Any offer of forward funding would seek to maximise developer contributions to education infrastructure provision while supporting delivery of schools where and when they are needed

Conclusion

13 Finally I hope the above comments are helpful in finalising the Runnymede Local Plan with specific regard to the provision of land for new schools

14 Please notify the ESFA when the Local Plan is submitted for examination the Inspectorrsquos report is published and the Local Plan is adopted

15 Please do not hesitate to contact me if you have any queries regarding this response The ESFA looks forward to continuing to work with Runnymede Borough Council to develop a sound Local Plan that will aid in the delivery of new schools

Yours faithfully

DC McNab

Douglas McNab MRTPI

Forward Planning Manager

Tel 07990 082877

Email

douglasmcnabeducationgovuk
Page 32: Runnymede Borough Council, for submissions. My contact details are all in the WORD letter attached. But I will provide my telephone number here too, which …

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number Email Address (where relevant)

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

From MCNAB DouglasTo Planning PolicySubject Runnymede Draft Local Plan consultation - Representation from Education and Skills Funding AgencyDate 21 February 2018 091407Attachments Runnymede Reg 19 response ESFADOC

Dear Runnymede Planning Policy Team

Please see attached a representation from the Education and Skills Funding Agency on theRunnymede Local Plan consultation

I would be grateful if you could confirm receipt

Best regardsDoug

Douglas McNab MRTPIForward Planning Manager ndash South East

Planning Team Free Schools CapitalEducation and Skills Funding AgencyDepartment for Education 5th floor Sanctuary Buildings 20 Great Smith Street London SW1P 3BT

Email douglasmcnabeducationgovukMobile 07990 082877Web wwwgovukesfa

1895

image1pngOur Ref ESFALocal PlanRunnymede 2018 21st February 2018

Dear SirMadam

Re Runnymede Local Plan

Consultation under Regulation 19 of Town and Country Planning (Local Planning) (England) Regulations 2012

Submission of the Education and Skills Funding Agency

1 The Education and Skills Funding Agency (ESFA) welcomes the opportunity to contribute to the development of planning policy at the local level

2 The ESFA launched on 1st April 2017 bringing together the existing responsibilities of the Education Funding Agency (EFA) and the Skills Funding Agency (SFA) to create a single funding agency accountable for funding education and training for children young people and adults The ESFA are accountable for pound61 billion of funding a year for the education and training sector including support for all state-provided education for 8 million children aged 3 to 16 and 16 million young people aged 16 to 19

3 Under the provisions of the Education Act 2011 and the Academies Act 2010 all new state schools are now academiesfree schools and the ESFA is the delivery body for many of these rather than local education authorities As such we aim to work closely with local authority education departments and planning authorities to meet the demand for new school places and new schools We do this through a variety of means including by supporting the adoption of sound local plan policies site allocations and guidance (all based on robust evidence) that facilitate the delivery of education infrastructure where and when it is needed and maximise developer contributions for schools In this capacity we would like to offer the following comments in response to the proposals outlined in the above consultation document

Comments on the Local Plan

4 As you will be aware the primary focus at this stage of the Local Planrsquos preparation is on the soundness of the plan with regard to it being positively prepared justified effective and consistent with national policy The following detailed comments set out the ESFArsquos view of the planrsquos soundness in respect of education provision

5 The ESFA notes that the local plan will make provision for a minimum of 7413 net additional dwellings over the plan period Development will generally complement the existing settlement pattern focusing the largest amounts of residential growth primarily in Chertsey (1950 homes) Addlestone (936 homes) and Egham (812 homes) A new ldquolocally led garden villagerdquo is also proposed at Longcross providing a further 1718 homes This level of development will put pressure on existing education infrastructure

6 The plan recognises that ldquoIt is important that infrastructure is delivered in a timely manner to ensure that the needs of the occupiers of new development can be met without placing undue burdens on existing infrastructure facilities and servicesrdquo (para 560) The ESFA supports Policy SD6 Infrastructure Provision amp Timing particularly the signposting of the Infrastructure Delivery Plan (IDP) and the need for development to deliver this either on-site or through s106 or CIL financial contributions off-site and the need for development to be phased in line with the provision of important supporting infrastructure

7 The latest version of the IDP states that there is an ongoing programme of primary school expansions this will help to meet the forecast need for 4-6FE of new capacity over the plan period The need for one new build school project is identified a 2FE primary school at the Longcross Garden Village (estimated cost pound99M to pound15M) this is referred to in the site allocation policies (see below) With respect to secondary school places it is anticipated that up to six additional FE could be required in the Borough by 2021 Additional places will be delivered through the new 6FE Runnymede Free School (which opened in temporary accommodation in 2017) development of additional FE within Salesian School (Catholic faith school) and expansion of another school in the Chertsey area (to accommodate demand from generated by the Longcross Garden Village site)

8 It would be useful if the background data informing these projections of need could be clarified particularly the pupil yield factors used and the evidence base supporting this This would help to demonstrate more clearly to the Inspector that the approach to the planning and delivery of education infrastructure has been positively prepared based on a strategy which seeks to meet objectively assessed infrastructure requirements and is justified based on proportionate evidence The ESFA notes that the Runnymede S106 SPG sets out pupil yield figures however this document dates from December 2007 so the figures may be outdated

9 The ESFA supports the Councilrsquos allocation and safeguarding of land for schools as set out in the following policies

middot Policy SD10 Longcross Garden Village - 2FE primary school with preschoolearly years settings

middot Policy SL2 to SL18 ndash series of housing allocation policies that highlight the need to make a financial contribution to early years primary and secondary school infrastructure ldquoeither through S106 or CIL (or its successor)rdquo

Developer Contributions and CIL

10 One of the tests of soundness is that a Local Plan is lsquoeffectiversquo ie the plan should be deliverable over its period In this context and with specific regard to planning for schools there is a need to ensure that education contributions made by developers are sufficient to deliver the additional school places required to meet the increase in demand generated by new developments The ESFA notes that the council has not adopted CIL and that the Planning Obligations SPG sets out how developer contributions to education provision will be secured via section 106 agreements The ESFA supports the Councilrsquos approach to ensure developer contributions address the impacts arising from growth However the ESFA recommends that the Local Plan includes a commitment to revise the Planning Obligations SPG in line with the latest evidence of the boroughrsquos infrastructure needs pupil yields and build costs (including the cost of school expansion new build and SEN provision) Any such review should be prepared in consultation with the county council as local education authority This will help to ensure appropriate rates are levied and the right infrastructure is secured across the borough

11 The ESFA would be particularly interested in responding to any update to the Infrastructure Delivery Plan or review of infrastructure requirements As such please add the ESFA to the database for future CIL consultations

Forward funding

12 In light of the proposed Longcross Garden Village emerging ESFA proposals for forward funding schools as part of large residential developments may be relevant for example if viability becomes an issue The ESFA aims to be able to clarify forward funding options for schools in 2018 We would be happy to meet to discuss this opportunity further once the options have been finalised and ifwhen relevant Any offer of forward funding would seek to maximise developer contributions to education infrastructure provision while supporting delivery of schools where and when they are needed

Conclusion

13 Finally I hope the above comments are helpful in finalising the Runnymede Local Plan with specific regard to the provision of land for new schools

14 Please notify the ESFA when the Local Plan is submitted for examination the Inspectorrsquos report is published and the Local Plan is adopted

15 Please do not hesitate to contact me if you have any queries regarding this response The ESFA looks forward to continuing to work with Runnymede Borough Council to develop a sound Local Plan that will aid in the delivery of new schools

Yours faithfully

DC McNab

Douglas McNab MRTPI

Forward Planning Manager

Tel 07990 082877

Email

douglasmcnabeducationgovuk
Page 33: Runnymede Borough Council, for submissions. My contact details are all in the WORD letter attached. But I will provide my telephone number here too, which …

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number Email Address (where relevant)

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

From MCNAB DouglasTo Planning PolicySubject Runnymede Draft Local Plan consultation - Representation from Education and Skills Funding AgencyDate 21 February 2018 091407Attachments Runnymede Reg 19 response ESFADOC

Dear Runnymede Planning Policy Team

Please see attached a representation from the Education and Skills Funding Agency on theRunnymede Local Plan consultation

I would be grateful if you could confirm receipt

Best regardsDoug

Douglas McNab MRTPIForward Planning Manager ndash South East

Planning Team Free Schools CapitalEducation and Skills Funding AgencyDepartment for Education 5th floor Sanctuary Buildings 20 Great Smith Street London SW1P 3BT

Email douglasmcnabeducationgovukMobile 07990 082877Web wwwgovukesfa

1895

image1pngOur Ref ESFALocal PlanRunnymede 2018 21st February 2018

Dear SirMadam

Re Runnymede Local Plan

Consultation under Regulation 19 of Town and Country Planning (Local Planning) (England) Regulations 2012

Submission of the Education and Skills Funding Agency

1 The Education and Skills Funding Agency (ESFA) welcomes the opportunity to contribute to the development of planning policy at the local level

2 The ESFA launched on 1st April 2017 bringing together the existing responsibilities of the Education Funding Agency (EFA) and the Skills Funding Agency (SFA) to create a single funding agency accountable for funding education and training for children young people and adults The ESFA are accountable for pound61 billion of funding a year for the education and training sector including support for all state-provided education for 8 million children aged 3 to 16 and 16 million young people aged 16 to 19

3 Under the provisions of the Education Act 2011 and the Academies Act 2010 all new state schools are now academiesfree schools and the ESFA is the delivery body for many of these rather than local education authorities As such we aim to work closely with local authority education departments and planning authorities to meet the demand for new school places and new schools We do this through a variety of means including by supporting the adoption of sound local plan policies site allocations and guidance (all based on robust evidence) that facilitate the delivery of education infrastructure where and when it is needed and maximise developer contributions for schools In this capacity we would like to offer the following comments in response to the proposals outlined in the above consultation document

Comments on the Local Plan

4 As you will be aware the primary focus at this stage of the Local Planrsquos preparation is on the soundness of the plan with regard to it being positively prepared justified effective and consistent with national policy The following detailed comments set out the ESFArsquos view of the planrsquos soundness in respect of education provision

5 The ESFA notes that the local plan will make provision for a minimum of 7413 net additional dwellings over the plan period Development will generally complement the existing settlement pattern focusing the largest amounts of residential growth primarily in Chertsey (1950 homes) Addlestone (936 homes) and Egham (812 homes) A new ldquolocally led garden villagerdquo is also proposed at Longcross providing a further 1718 homes This level of development will put pressure on existing education infrastructure

6 The plan recognises that ldquoIt is important that infrastructure is delivered in a timely manner to ensure that the needs of the occupiers of new development can be met without placing undue burdens on existing infrastructure facilities and servicesrdquo (para 560) The ESFA supports Policy SD6 Infrastructure Provision amp Timing particularly the signposting of the Infrastructure Delivery Plan (IDP) and the need for development to deliver this either on-site or through s106 or CIL financial contributions off-site and the need for development to be phased in line with the provision of important supporting infrastructure

7 The latest version of the IDP states that there is an ongoing programme of primary school expansions this will help to meet the forecast need for 4-6FE of new capacity over the plan period The need for one new build school project is identified a 2FE primary school at the Longcross Garden Village (estimated cost pound99M to pound15M) this is referred to in the site allocation policies (see below) With respect to secondary school places it is anticipated that up to six additional FE could be required in the Borough by 2021 Additional places will be delivered through the new 6FE Runnymede Free School (which opened in temporary accommodation in 2017) development of additional FE within Salesian School (Catholic faith school) and expansion of another school in the Chertsey area (to accommodate demand from generated by the Longcross Garden Village site)

8 It would be useful if the background data informing these projections of need could be clarified particularly the pupil yield factors used and the evidence base supporting this This would help to demonstrate more clearly to the Inspector that the approach to the planning and delivery of education infrastructure has been positively prepared based on a strategy which seeks to meet objectively assessed infrastructure requirements and is justified based on proportionate evidence The ESFA notes that the Runnymede S106 SPG sets out pupil yield figures however this document dates from December 2007 so the figures may be outdated

9 The ESFA supports the Councilrsquos allocation and safeguarding of land for schools as set out in the following policies

middot Policy SD10 Longcross Garden Village - 2FE primary school with preschoolearly years settings

middot Policy SL2 to SL18 ndash series of housing allocation policies that highlight the need to make a financial contribution to early years primary and secondary school infrastructure ldquoeither through S106 or CIL (or its successor)rdquo

Developer Contributions and CIL

10 One of the tests of soundness is that a Local Plan is lsquoeffectiversquo ie the plan should be deliverable over its period In this context and with specific regard to planning for schools there is a need to ensure that education contributions made by developers are sufficient to deliver the additional school places required to meet the increase in demand generated by new developments The ESFA notes that the council has not adopted CIL and that the Planning Obligations SPG sets out how developer contributions to education provision will be secured via section 106 agreements The ESFA supports the Councilrsquos approach to ensure developer contributions address the impacts arising from growth However the ESFA recommends that the Local Plan includes a commitment to revise the Planning Obligations SPG in line with the latest evidence of the boroughrsquos infrastructure needs pupil yields and build costs (including the cost of school expansion new build and SEN provision) Any such review should be prepared in consultation with the county council as local education authority This will help to ensure appropriate rates are levied and the right infrastructure is secured across the borough

11 The ESFA would be particularly interested in responding to any update to the Infrastructure Delivery Plan or review of infrastructure requirements As such please add the ESFA to the database for future CIL consultations

Forward funding

12 In light of the proposed Longcross Garden Village emerging ESFA proposals for forward funding schools as part of large residential developments may be relevant for example if viability becomes an issue The ESFA aims to be able to clarify forward funding options for schools in 2018 We would be happy to meet to discuss this opportunity further once the options have been finalised and ifwhen relevant Any offer of forward funding would seek to maximise developer contributions to education infrastructure provision while supporting delivery of schools where and when they are needed

Conclusion

13 Finally I hope the above comments are helpful in finalising the Runnymede Local Plan with specific regard to the provision of land for new schools

14 Please notify the ESFA when the Local Plan is submitted for examination the Inspectorrsquos report is published and the Local Plan is adopted

15 Please do not hesitate to contact me if you have any queries regarding this response The ESFA looks forward to continuing to work with Runnymede Borough Council to develop a sound Local Plan that will aid in the delivery of new schools

Yours faithfully

DC McNab

Douglas McNab MRTPI

Forward Planning Manager

Tel 07990 082877

Email

douglasmcnabeducationgovuk
Page 34: Runnymede Borough Council, for submissions. My contact details are all in the WORD letter attached. But I will provide my telephone number here too, which …

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number Email Address (where relevant)

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

From MCNAB DouglasTo Planning PolicySubject Runnymede Draft Local Plan consultation - Representation from Education and Skills Funding AgencyDate 21 February 2018 091407Attachments Runnymede Reg 19 response ESFADOC

Dear Runnymede Planning Policy Team

Please see attached a representation from the Education and Skills Funding Agency on theRunnymede Local Plan consultation

I would be grateful if you could confirm receipt

Best regardsDoug

Douglas McNab MRTPIForward Planning Manager ndash South East

Planning Team Free Schools CapitalEducation and Skills Funding AgencyDepartment for Education 5th floor Sanctuary Buildings 20 Great Smith Street London SW1P 3BT

Email douglasmcnabeducationgovukMobile 07990 082877Web wwwgovukesfa

1895

image1pngOur Ref ESFALocal PlanRunnymede 2018 21st February 2018

Dear SirMadam

Re Runnymede Local Plan

Consultation under Regulation 19 of Town and Country Planning (Local Planning) (England) Regulations 2012

Submission of the Education and Skills Funding Agency

1 The Education and Skills Funding Agency (ESFA) welcomes the opportunity to contribute to the development of planning policy at the local level

2 The ESFA launched on 1st April 2017 bringing together the existing responsibilities of the Education Funding Agency (EFA) and the Skills Funding Agency (SFA) to create a single funding agency accountable for funding education and training for children young people and adults The ESFA are accountable for pound61 billion of funding a year for the education and training sector including support for all state-provided education for 8 million children aged 3 to 16 and 16 million young people aged 16 to 19

3 Under the provisions of the Education Act 2011 and the Academies Act 2010 all new state schools are now academiesfree schools and the ESFA is the delivery body for many of these rather than local education authorities As such we aim to work closely with local authority education departments and planning authorities to meet the demand for new school places and new schools We do this through a variety of means including by supporting the adoption of sound local plan policies site allocations and guidance (all based on robust evidence) that facilitate the delivery of education infrastructure where and when it is needed and maximise developer contributions for schools In this capacity we would like to offer the following comments in response to the proposals outlined in the above consultation document

Comments on the Local Plan

4 As you will be aware the primary focus at this stage of the Local Planrsquos preparation is on the soundness of the plan with regard to it being positively prepared justified effective and consistent with national policy The following detailed comments set out the ESFArsquos view of the planrsquos soundness in respect of education provision

5 The ESFA notes that the local plan will make provision for a minimum of 7413 net additional dwellings over the plan period Development will generally complement the existing settlement pattern focusing the largest amounts of residential growth primarily in Chertsey (1950 homes) Addlestone (936 homes) and Egham (812 homes) A new ldquolocally led garden villagerdquo is also proposed at Longcross providing a further 1718 homes This level of development will put pressure on existing education infrastructure

6 The plan recognises that ldquoIt is important that infrastructure is delivered in a timely manner to ensure that the needs of the occupiers of new development can be met without placing undue burdens on existing infrastructure facilities and servicesrdquo (para 560) The ESFA supports Policy SD6 Infrastructure Provision amp Timing particularly the signposting of the Infrastructure Delivery Plan (IDP) and the need for development to deliver this either on-site or through s106 or CIL financial contributions off-site and the need for development to be phased in line with the provision of important supporting infrastructure

7 The latest version of the IDP states that there is an ongoing programme of primary school expansions this will help to meet the forecast need for 4-6FE of new capacity over the plan period The need for one new build school project is identified a 2FE primary school at the Longcross Garden Village (estimated cost pound99M to pound15M) this is referred to in the site allocation policies (see below) With respect to secondary school places it is anticipated that up to six additional FE could be required in the Borough by 2021 Additional places will be delivered through the new 6FE Runnymede Free School (which opened in temporary accommodation in 2017) development of additional FE within Salesian School (Catholic faith school) and expansion of another school in the Chertsey area (to accommodate demand from generated by the Longcross Garden Village site)

8 It would be useful if the background data informing these projections of need could be clarified particularly the pupil yield factors used and the evidence base supporting this This would help to demonstrate more clearly to the Inspector that the approach to the planning and delivery of education infrastructure has been positively prepared based on a strategy which seeks to meet objectively assessed infrastructure requirements and is justified based on proportionate evidence The ESFA notes that the Runnymede S106 SPG sets out pupil yield figures however this document dates from December 2007 so the figures may be outdated

9 The ESFA supports the Councilrsquos allocation and safeguarding of land for schools as set out in the following policies

middot Policy SD10 Longcross Garden Village - 2FE primary school with preschoolearly years settings

middot Policy SL2 to SL18 ndash series of housing allocation policies that highlight the need to make a financial contribution to early years primary and secondary school infrastructure ldquoeither through S106 or CIL (or its successor)rdquo

Developer Contributions and CIL

10 One of the tests of soundness is that a Local Plan is lsquoeffectiversquo ie the plan should be deliverable over its period In this context and with specific regard to planning for schools there is a need to ensure that education contributions made by developers are sufficient to deliver the additional school places required to meet the increase in demand generated by new developments The ESFA notes that the council has not adopted CIL and that the Planning Obligations SPG sets out how developer contributions to education provision will be secured via section 106 agreements The ESFA supports the Councilrsquos approach to ensure developer contributions address the impacts arising from growth However the ESFA recommends that the Local Plan includes a commitment to revise the Planning Obligations SPG in line with the latest evidence of the boroughrsquos infrastructure needs pupil yields and build costs (including the cost of school expansion new build and SEN provision) Any such review should be prepared in consultation with the county council as local education authority This will help to ensure appropriate rates are levied and the right infrastructure is secured across the borough

11 The ESFA would be particularly interested in responding to any update to the Infrastructure Delivery Plan or review of infrastructure requirements As such please add the ESFA to the database for future CIL consultations

Forward funding

12 In light of the proposed Longcross Garden Village emerging ESFA proposals for forward funding schools as part of large residential developments may be relevant for example if viability becomes an issue The ESFA aims to be able to clarify forward funding options for schools in 2018 We would be happy to meet to discuss this opportunity further once the options have been finalised and ifwhen relevant Any offer of forward funding would seek to maximise developer contributions to education infrastructure provision while supporting delivery of schools where and when they are needed

Conclusion

13 Finally I hope the above comments are helpful in finalising the Runnymede Local Plan with specific regard to the provision of land for new schools

14 Please notify the ESFA when the Local Plan is submitted for examination the Inspectorrsquos report is published and the Local Plan is adopted

15 Please do not hesitate to contact me if you have any queries regarding this response The ESFA looks forward to continuing to work with Runnymede Borough Council to develop a sound Local Plan that will aid in the delivery of new schools

Yours faithfully

DC McNab

Douglas McNab MRTPI

Forward Planning Manager

Tel 07990 082877

Email

douglasmcnabeducationgovuk
Page 35: Runnymede Borough Council, for submissions. My contact details are all in the WORD letter attached. But I will provide my telephone number here too, which …

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number Email Address (where relevant)

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

From MCNAB DouglasTo Planning PolicySubject Runnymede Draft Local Plan consultation - Representation from Education and Skills Funding AgencyDate 21 February 2018 091407Attachments Runnymede Reg 19 response ESFADOC

Dear Runnymede Planning Policy Team

Please see attached a representation from the Education and Skills Funding Agency on theRunnymede Local Plan consultation

I would be grateful if you could confirm receipt

Best regardsDoug

Douglas McNab MRTPIForward Planning Manager ndash South East

Planning Team Free Schools CapitalEducation and Skills Funding AgencyDepartment for Education 5th floor Sanctuary Buildings 20 Great Smith Street London SW1P 3BT

Email douglasmcnabeducationgovukMobile 07990 082877Web wwwgovukesfa

1895

image1pngOur Ref ESFALocal PlanRunnymede 2018 21st February 2018

Dear SirMadam

Re Runnymede Local Plan

Consultation under Regulation 19 of Town and Country Planning (Local Planning) (England) Regulations 2012

Submission of the Education and Skills Funding Agency

1 The Education and Skills Funding Agency (ESFA) welcomes the opportunity to contribute to the development of planning policy at the local level

2 The ESFA launched on 1st April 2017 bringing together the existing responsibilities of the Education Funding Agency (EFA) and the Skills Funding Agency (SFA) to create a single funding agency accountable for funding education and training for children young people and adults The ESFA are accountable for pound61 billion of funding a year for the education and training sector including support for all state-provided education for 8 million children aged 3 to 16 and 16 million young people aged 16 to 19

3 Under the provisions of the Education Act 2011 and the Academies Act 2010 all new state schools are now academiesfree schools and the ESFA is the delivery body for many of these rather than local education authorities As such we aim to work closely with local authority education departments and planning authorities to meet the demand for new school places and new schools We do this through a variety of means including by supporting the adoption of sound local plan policies site allocations and guidance (all based on robust evidence) that facilitate the delivery of education infrastructure where and when it is needed and maximise developer contributions for schools In this capacity we would like to offer the following comments in response to the proposals outlined in the above consultation document

Comments on the Local Plan

4 As you will be aware the primary focus at this stage of the Local Planrsquos preparation is on the soundness of the plan with regard to it being positively prepared justified effective and consistent with national policy The following detailed comments set out the ESFArsquos view of the planrsquos soundness in respect of education provision

5 The ESFA notes that the local plan will make provision for a minimum of 7413 net additional dwellings over the plan period Development will generally complement the existing settlement pattern focusing the largest amounts of residential growth primarily in Chertsey (1950 homes) Addlestone (936 homes) and Egham (812 homes) A new ldquolocally led garden villagerdquo is also proposed at Longcross providing a further 1718 homes This level of development will put pressure on existing education infrastructure

6 The plan recognises that ldquoIt is important that infrastructure is delivered in a timely manner to ensure that the needs of the occupiers of new development can be met without placing undue burdens on existing infrastructure facilities and servicesrdquo (para 560) The ESFA supports Policy SD6 Infrastructure Provision amp Timing particularly the signposting of the Infrastructure Delivery Plan (IDP) and the need for development to deliver this either on-site or through s106 or CIL financial contributions off-site and the need for development to be phased in line with the provision of important supporting infrastructure

7 The latest version of the IDP states that there is an ongoing programme of primary school expansions this will help to meet the forecast need for 4-6FE of new capacity over the plan period The need for one new build school project is identified a 2FE primary school at the Longcross Garden Village (estimated cost pound99M to pound15M) this is referred to in the site allocation policies (see below) With respect to secondary school places it is anticipated that up to six additional FE could be required in the Borough by 2021 Additional places will be delivered through the new 6FE Runnymede Free School (which opened in temporary accommodation in 2017) development of additional FE within Salesian School (Catholic faith school) and expansion of another school in the Chertsey area (to accommodate demand from generated by the Longcross Garden Village site)

8 It would be useful if the background data informing these projections of need could be clarified particularly the pupil yield factors used and the evidence base supporting this This would help to demonstrate more clearly to the Inspector that the approach to the planning and delivery of education infrastructure has been positively prepared based on a strategy which seeks to meet objectively assessed infrastructure requirements and is justified based on proportionate evidence The ESFA notes that the Runnymede S106 SPG sets out pupil yield figures however this document dates from December 2007 so the figures may be outdated

9 The ESFA supports the Councilrsquos allocation and safeguarding of land for schools as set out in the following policies

middot Policy SD10 Longcross Garden Village - 2FE primary school with preschoolearly years settings

middot Policy SL2 to SL18 ndash series of housing allocation policies that highlight the need to make a financial contribution to early years primary and secondary school infrastructure ldquoeither through S106 or CIL (or its successor)rdquo

Developer Contributions and CIL

10 One of the tests of soundness is that a Local Plan is lsquoeffectiversquo ie the plan should be deliverable over its period In this context and with specific regard to planning for schools there is a need to ensure that education contributions made by developers are sufficient to deliver the additional school places required to meet the increase in demand generated by new developments The ESFA notes that the council has not adopted CIL and that the Planning Obligations SPG sets out how developer contributions to education provision will be secured via section 106 agreements The ESFA supports the Councilrsquos approach to ensure developer contributions address the impacts arising from growth However the ESFA recommends that the Local Plan includes a commitment to revise the Planning Obligations SPG in line with the latest evidence of the boroughrsquos infrastructure needs pupil yields and build costs (including the cost of school expansion new build and SEN provision) Any such review should be prepared in consultation with the county council as local education authority This will help to ensure appropriate rates are levied and the right infrastructure is secured across the borough

11 The ESFA would be particularly interested in responding to any update to the Infrastructure Delivery Plan or review of infrastructure requirements As such please add the ESFA to the database for future CIL consultations

Forward funding

12 In light of the proposed Longcross Garden Village emerging ESFA proposals for forward funding schools as part of large residential developments may be relevant for example if viability becomes an issue The ESFA aims to be able to clarify forward funding options for schools in 2018 We would be happy to meet to discuss this opportunity further once the options have been finalised and ifwhen relevant Any offer of forward funding would seek to maximise developer contributions to education infrastructure provision while supporting delivery of schools where and when they are needed

Conclusion

13 Finally I hope the above comments are helpful in finalising the Runnymede Local Plan with specific regard to the provision of land for new schools

14 Please notify the ESFA when the Local Plan is submitted for examination the Inspectorrsquos report is published and the Local Plan is adopted

15 Please do not hesitate to contact me if you have any queries regarding this response The ESFA looks forward to continuing to work with Runnymede Borough Council to develop a sound Local Plan that will aid in the delivery of new schools

Yours faithfully

DC McNab

Douglas McNab MRTPI

Forward Planning Manager

Tel 07990 082877

Email

douglasmcnabeducationgovuk
Page 36: Runnymede Borough Council, for submissions. My contact details are all in the WORD letter attached. But I will provide my telephone number here too, which …

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number Email Address (where relevant)

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

From MCNAB DouglasTo Planning PolicySubject Runnymede Draft Local Plan consultation - Representation from Education and Skills Funding AgencyDate 21 February 2018 091407Attachments Runnymede Reg 19 response ESFADOC

Dear Runnymede Planning Policy Team

Please see attached a representation from the Education and Skills Funding Agency on theRunnymede Local Plan consultation

I would be grateful if you could confirm receipt

Best regardsDoug

Douglas McNab MRTPIForward Planning Manager ndash South East

Planning Team Free Schools CapitalEducation and Skills Funding AgencyDepartment for Education 5th floor Sanctuary Buildings 20 Great Smith Street London SW1P 3BT

Email douglasmcnabeducationgovukMobile 07990 082877Web wwwgovukesfa

1895

image1pngOur Ref ESFALocal PlanRunnymede 2018 21st February 2018

Dear SirMadam

Re Runnymede Local Plan

Consultation under Regulation 19 of Town and Country Planning (Local Planning) (England) Regulations 2012

Submission of the Education and Skills Funding Agency

1 The Education and Skills Funding Agency (ESFA) welcomes the opportunity to contribute to the development of planning policy at the local level

2 The ESFA launched on 1st April 2017 bringing together the existing responsibilities of the Education Funding Agency (EFA) and the Skills Funding Agency (SFA) to create a single funding agency accountable for funding education and training for children young people and adults The ESFA are accountable for pound61 billion of funding a year for the education and training sector including support for all state-provided education for 8 million children aged 3 to 16 and 16 million young people aged 16 to 19

3 Under the provisions of the Education Act 2011 and the Academies Act 2010 all new state schools are now academiesfree schools and the ESFA is the delivery body for many of these rather than local education authorities As such we aim to work closely with local authority education departments and planning authorities to meet the demand for new school places and new schools We do this through a variety of means including by supporting the adoption of sound local plan policies site allocations and guidance (all based on robust evidence) that facilitate the delivery of education infrastructure where and when it is needed and maximise developer contributions for schools In this capacity we would like to offer the following comments in response to the proposals outlined in the above consultation document

Comments on the Local Plan

4 As you will be aware the primary focus at this stage of the Local Planrsquos preparation is on the soundness of the plan with regard to it being positively prepared justified effective and consistent with national policy The following detailed comments set out the ESFArsquos view of the planrsquos soundness in respect of education provision

5 The ESFA notes that the local plan will make provision for a minimum of 7413 net additional dwellings over the plan period Development will generally complement the existing settlement pattern focusing the largest amounts of residential growth primarily in Chertsey (1950 homes) Addlestone (936 homes) and Egham (812 homes) A new ldquolocally led garden villagerdquo is also proposed at Longcross providing a further 1718 homes This level of development will put pressure on existing education infrastructure

6 The plan recognises that ldquoIt is important that infrastructure is delivered in a timely manner to ensure that the needs of the occupiers of new development can be met without placing undue burdens on existing infrastructure facilities and servicesrdquo (para 560) The ESFA supports Policy SD6 Infrastructure Provision amp Timing particularly the signposting of the Infrastructure Delivery Plan (IDP) and the need for development to deliver this either on-site or through s106 or CIL financial contributions off-site and the need for development to be phased in line with the provision of important supporting infrastructure

7 The latest version of the IDP states that there is an ongoing programme of primary school expansions this will help to meet the forecast need for 4-6FE of new capacity over the plan period The need for one new build school project is identified a 2FE primary school at the Longcross Garden Village (estimated cost pound99M to pound15M) this is referred to in the site allocation policies (see below) With respect to secondary school places it is anticipated that up to six additional FE could be required in the Borough by 2021 Additional places will be delivered through the new 6FE Runnymede Free School (which opened in temporary accommodation in 2017) development of additional FE within Salesian School (Catholic faith school) and expansion of another school in the Chertsey area (to accommodate demand from generated by the Longcross Garden Village site)

8 It would be useful if the background data informing these projections of need could be clarified particularly the pupil yield factors used and the evidence base supporting this This would help to demonstrate more clearly to the Inspector that the approach to the planning and delivery of education infrastructure has been positively prepared based on a strategy which seeks to meet objectively assessed infrastructure requirements and is justified based on proportionate evidence The ESFA notes that the Runnymede S106 SPG sets out pupil yield figures however this document dates from December 2007 so the figures may be outdated

9 The ESFA supports the Councilrsquos allocation and safeguarding of land for schools as set out in the following policies

middot Policy SD10 Longcross Garden Village - 2FE primary school with preschoolearly years settings

middot Policy SL2 to SL18 ndash series of housing allocation policies that highlight the need to make a financial contribution to early years primary and secondary school infrastructure ldquoeither through S106 or CIL (or its successor)rdquo

Developer Contributions and CIL

10 One of the tests of soundness is that a Local Plan is lsquoeffectiversquo ie the plan should be deliverable over its period In this context and with specific regard to planning for schools there is a need to ensure that education contributions made by developers are sufficient to deliver the additional school places required to meet the increase in demand generated by new developments The ESFA notes that the council has not adopted CIL and that the Planning Obligations SPG sets out how developer contributions to education provision will be secured via section 106 agreements The ESFA supports the Councilrsquos approach to ensure developer contributions address the impacts arising from growth However the ESFA recommends that the Local Plan includes a commitment to revise the Planning Obligations SPG in line with the latest evidence of the boroughrsquos infrastructure needs pupil yields and build costs (including the cost of school expansion new build and SEN provision) Any such review should be prepared in consultation with the county council as local education authority This will help to ensure appropriate rates are levied and the right infrastructure is secured across the borough

11 The ESFA would be particularly interested in responding to any update to the Infrastructure Delivery Plan or review of infrastructure requirements As such please add the ESFA to the database for future CIL consultations

Forward funding

12 In light of the proposed Longcross Garden Village emerging ESFA proposals for forward funding schools as part of large residential developments may be relevant for example if viability becomes an issue The ESFA aims to be able to clarify forward funding options for schools in 2018 We would be happy to meet to discuss this opportunity further once the options have been finalised and ifwhen relevant Any offer of forward funding would seek to maximise developer contributions to education infrastructure provision while supporting delivery of schools where and when they are needed

Conclusion

13 Finally I hope the above comments are helpful in finalising the Runnymede Local Plan with specific regard to the provision of land for new schools

14 Please notify the ESFA when the Local Plan is submitted for examination the Inspectorrsquos report is published and the Local Plan is adopted

15 Please do not hesitate to contact me if you have any queries regarding this response The ESFA looks forward to continuing to work with Runnymede Borough Council to develop a sound Local Plan that will aid in the delivery of new schools

Yours faithfully

DC McNab

Douglas McNab MRTPI

Forward Planning Manager

Tel 07990 082877

Email

douglasmcnabeducationgovuk
Page 37: Runnymede Borough Council, for submissions. My contact details are all in the WORD letter attached. But I will provide my telephone number here too, which …

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number Email Address (where relevant)

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

From MCNAB DouglasTo Planning PolicySubject Runnymede Draft Local Plan consultation - Representation from Education and Skills Funding AgencyDate 21 February 2018 091407Attachments Runnymede Reg 19 response ESFADOC

Dear Runnymede Planning Policy Team

Please see attached a representation from the Education and Skills Funding Agency on theRunnymede Local Plan consultation

I would be grateful if you could confirm receipt

Best regardsDoug

Douglas McNab MRTPIForward Planning Manager ndash South East

Planning Team Free Schools CapitalEducation and Skills Funding AgencyDepartment for Education 5th floor Sanctuary Buildings 20 Great Smith Street London SW1P 3BT

Email douglasmcnabeducationgovukMobile 07990 082877Web wwwgovukesfa

1895

image1pngOur Ref ESFALocal PlanRunnymede 2018 21st February 2018

Dear SirMadam

Re Runnymede Local Plan

Consultation under Regulation 19 of Town and Country Planning (Local Planning) (England) Regulations 2012

Submission of the Education and Skills Funding Agency

1 The Education and Skills Funding Agency (ESFA) welcomes the opportunity to contribute to the development of planning policy at the local level

2 The ESFA launched on 1st April 2017 bringing together the existing responsibilities of the Education Funding Agency (EFA) and the Skills Funding Agency (SFA) to create a single funding agency accountable for funding education and training for children young people and adults The ESFA are accountable for pound61 billion of funding a year for the education and training sector including support for all state-provided education for 8 million children aged 3 to 16 and 16 million young people aged 16 to 19

3 Under the provisions of the Education Act 2011 and the Academies Act 2010 all new state schools are now academiesfree schools and the ESFA is the delivery body for many of these rather than local education authorities As such we aim to work closely with local authority education departments and planning authorities to meet the demand for new school places and new schools We do this through a variety of means including by supporting the adoption of sound local plan policies site allocations and guidance (all based on robust evidence) that facilitate the delivery of education infrastructure where and when it is needed and maximise developer contributions for schools In this capacity we would like to offer the following comments in response to the proposals outlined in the above consultation document

Comments on the Local Plan

4 As you will be aware the primary focus at this stage of the Local Planrsquos preparation is on the soundness of the plan with regard to it being positively prepared justified effective and consistent with national policy The following detailed comments set out the ESFArsquos view of the planrsquos soundness in respect of education provision

5 The ESFA notes that the local plan will make provision for a minimum of 7413 net additional dwellings over the plan period Development will generally complement the existing settlement pattern focusing the largest amounts of residential growth primarily in Chertsey (1950 homes) Addlestone (936 homes) and Egham (812 homes) A new ldquolocally led garden villagerdquo is also proposed at Longcross providing a further 1718 homes This level of development will put pressure on existing education infrastructure

6 The plan recognises that ldquoIt is important that infrastructure is delivered in a timely manner to ensure that the needs of the occupiers of new development can be met without placing undue burdens on existing infrastructure facilities and servicesrdquo (para 560) The ESFA supports Policy SD6 Infrastructure Provision amp Timing particularly the signposting of the Infrastructure Delivery Plan (IDP) and the need for development to deliver this either on-site or through s106 or CIL financial contributions off-site and the need for development to be phased in line with the provision of important supporting infrastructure

7 The latest version of the IDP states that there is an ongoing programme of primary school expansions this will help to meet the forecast need for 4-6FE of new capacity over the plan period The need for one new build school project is identified a 2FE primary school at the Longcross Garden Village (estimated cost pound99M to pound15M) this is referred to in the site allocation policies (see below) With respect to secondary school places it is anticipated that up to six additional FE could be required in the Borough by 2021 Additional places will be delivered through the new 6FE Runnymede Free School (which opened in temporary accommodation in 2017) development of additional FE within Salesian School (Catholic faith school) and expansion of another school in the Chertsey area (to accommodate demand from generated by the Longcross Garden Village site)

8 It would be useful if the background data informing these projections of need could be clarified particularly the pupil yield factors used and the evidence base supporting this This would help to demonstrate more clearly to the Inspector that the approach to the planning and delivery of education infrastructure has been positively prepared based on a strategy which seeks to meet objectively assessed infrastructure requirements and is justified based on proportionate evidence The ESFA notes that the Runnymede S106 SPG sets out pupil yield figures however this document dates from December 2007 so the figures may be outdated

9 The ESFA supports the Councilrsquos allocation and safeguarding of land for schools as set out in the following policies

middot Policy SD10 Longcross Garden Village - 2FE primary school with preschoolearly years settings

middot Policy SL2 to SL18 ndash series of housing allocation policies that highlight the need to make a financial contribution to early years primary and secondary school infrastructure ldquoeither through S106 or CIL (or its successor)rdquo

Developer Contributions and CIL

10 One of the tests of soundness is that a Local Plan is lsquoeffectiversquo ie the plan should be deliverable over its period In this context and with specific regard to planning for schools there is a need to ensure that education contributions made by developers are sufficient to deliver the additional school places required to meet the increase in demand generated by new developments The ESFA notes that the council has not adopted CIL and that the Planning Obligations SPG sets out how developer contributions to education provision will be secured via section 106 agreements The ESFA supports the Councilrsquos approach to ensure developer contributions address the impacts arising from growth However the ESFA recommends that the Local Plan includes a commitment to revise the Planning Obligations SPG in line with the latest evidence of the boroughrsquos infrastructure needs pupil yields and build costs (including the cost of school expansion new build and SEN provision) Any such review should be prepared in consultation with the county council as local education authority This will help to ensure appropriate rates are levied and the right infrastructure is secured across the borough

11 The ESFA would be particularly interested in responding to any update to the Infrastructure Delivery Plan or review of infrastructure requirements As such please add the ESFA to the database for future CIL consultations

Forward funding

12 In light of the proposed Longcross Garden Village emerging ESFA proposals for forward funding schools as part of large residential developments may be relevant for example if viability becomes an issue The ESFA aims to be able to clarify forward funding options for schools in 2018 We would be happy to meet to discuss this opportunity further once the options have been finalised and ifwhen relevant Any offer of forward funding would seek to maximise developer contributions to education infrastructure provision while supporting delivery of schools where and when they are needed

Conclusion

13 Finally I hope the above comments are helpful in finalising the Runnymede Local Plan with specific regard to the provision of land for new schools

14 Please notify the ESFA when the Local Plan is submitted for examination the Inspectorrsquos report is published and the Local Plan is adopted

15 Please do not hesitate to contact me if you have any queries regarding this response The ESFA looks forward to continuing to work with Runnymede Borough Council to develop a sound Local Plan that will aid in the delivery of new schools

Yours faithfully

DC McNab

Douglas McNab MRTPI

Forward Planning Manager

Tel 07990 082877

Email

douglasmcnabeducationgovuk
Page 38: Runnymede Borough Council, for submissions. My contact details are all in the WORD letter attached. But I will provide my telephone number here too, which …

1

Representation Form for the Runnymede 2030 Draft Local Plan

Please return to Runnymede Borough Council by Thursday 22nd February 2018

This form has two parts-

Part A ndash Personal Details

Part B ndash Your representation (s) Please fill in a separate sheet for each representation you wish to

make

Part A

1 Personal Details 2 Agentrsquos Details (if applicable)

If an agent is appointed please complete only the Title Name and Organisation boxes below but complete the full

contact details of the agent in 2

Title Mr Mr First Name Gary Christian Last Name Humphries Leigh Job Title (where relevant)

Director

Organisation (where relevant)

Leigh amp Glennie Ltd

Address Line 1 1 Vicarage Mews 6 All Souls Road Line 2 Longcross Road Ascot Line 3 Longcross Line 4 Post Code KT16 0DU SL5 9EA Telephone Number Email Address (where relevant)

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

From MCNAB DouglasTo Planning PolicySubject Runnymede Draft Local Plan consultation - Representation from Education and Skills Funding AgencyDate 21 February 2018 091407Attachments Runnymede Reg 19 response ESFADOC

Dear Runnymede Planning Policy Team

Please see attached a representation from the Education and Skills Funding Agency on theRunnymede Local Plan consultation

I would be grateful if you could confirm receipt

Best regardsDoug

Douglas McNab MRTPIForward Planning Manager ndash South East

Planning Team Free Schools CapitalEducation and Skills Funding AgencyDepartment for Education 5th floor Sanctuary Buildings 20 Great Smith Street London SW1P 3BT

Email douglasmcnabeducationgovukMobile 07990 082877Web wwwgovukesfa

1895

image1pngOur Ref ESFALocal PlanRunnymede 2018 21st February 2018

Dear SirMadam

Re Runnymede Local Plan

Consultation under Regulation 19 of Town and Country Planning (Local Planning) (England) Regulations 2012

Submission of the Education and Skills Funding Agency

1 The Education and Skills Funding Agency (ESFA) welcomes the opportunity to contribute to the development of planning policy at the local level

2 The ESFA launched on 1st April 2017 bringing together the existing responsibilities of the Education Funding Agency (EFA) and the Skills Funding Agency (SFA) to create a single funding agency accountable for funding education and training for children young people and adults The ESFA are accountable for pound61 billion of funding a year for the education and training sector including support for all state-provided education for 8 million children aged 3 to 16 and 16 million young people aged 16 to 19

3 Under the provisions of the Education Act 2011 and the Academies Act 2010 all new state schools are now academiesfree schools and the ESFA is the delivery body for many of these rather than local education authorities As such we aim to work closely with local authority education departments and planning authorities to meet the demand for new school places and new schools We do this through a variety of means including by supporting the adoption of sound local plan policies site allocations and guidance (all based on robust evidence) that facilitate the delivery of education infrastructure where and when it is needed and maximise developer contributions for schools In this capacity we would like to offer the following comments in response to the proposals outlined in the above consultation document

Comments on the Local Plan

4 As you will be aware the primary focus at this stage of the Local Planrsquos preparation is on the soundness of the plan with regard to it being positively prepared justified effective and consistent with national policy The following detailed comments set out the ESFArsquos view of the planrsquos soundness in respect of education provision

5 The ESFA notes that the local plan will make provision for a minimum of 7413 net additional dwellings over the plan period Development will generally complement the existing settlement pattern focusing the largest amounts of residential growth primarily in Chertsey (1950 homes) Addlestone (936 homes) and Egham (812 homes) A new ldquolocally led garden villagerdquo is also proposed at Longcross providing a further 1718 homes This level of development will put pressure on existing education infrastructure

6 The plan recognises that ldquoIt is important that infrastructure is delivered in a timely manner to ensure that the needs of the occupiers of new development can be met without placing undue burdens on existing infrastructure facilities and servicesrdquo (para 560) The ESFA supports Policy SD6 Infrastructure Provision amp Timing particularly the signposting of the Infrastructure Delivery Plan (IDP) and the need for development to deliver this either on-site or through s106 or CIL financial contributions off-site and the need for development to be phased in line with the provision of important supporting infrastructure

7 The latest version of the IDP states that there is an ongoing programme of primary school expansions this will help to meet the forecast need for 4-6FE of new capacity over the plan period The need for one new build school project is identified a 2FE primary school at the Longcross Garden Village (estimated cost pound99M to pound15M) this is referred to in the site allocation policies (see below) With respect to secondary school places it is anticipated that up to six additional FE could be required in the Borough by 2021 Additional places will be delivered through the new 6FE Runnymede Free School (which opened in temporary accommodation in 2017) development of additional FE within Salesian School (Catholic faith school) and expansion of another school in the Chertsey area (to accommodate demand from generated by the Longcross Garden Village site)

8 It would be useful if the background data informing these projections of need could be clarified particularly the pupil yield factors used and the evidence base supporting this This would help to demonstrate more clearly to the Inspector that the approach to the planning and delivery of education infrastructure has been positively prepared based on a strategy which seeks to meet objectively assessed infrastructure requirements and is justified based on proportionate evidence The ESFA notes that the Runnymede S106 SPG sets out pupil yield figures however this document dates from December 2007 so the figures may be outdated

9 The ESFA supports the Councilrsquos allocation and safeguarding of land for schools as set out in the following policies

middot Policy SD10 Longcross Garden Village - 2FE primary school with preschoolearly years settings

middot Policy SL2 to SL18 ndash series of housing allocation policies that highlight the need to make a financial contribution to early years primary and secondary school infrastructure ldquoeither through S106 or CIL (or its successor)rdquo

Developer Contributions and CIL

10 One of the tests of soundness is that a Local Plan is lsquoeffectiversquo ie the plan should be deliverable over its period In this context and with specific regard to planning for schools there is a need to ensure that education contributions made by developers are sufficient to deliver the additional school places required to meet the increase in demand generated by new developments The ESFA notes that the council has not adopted CIL and that the Planning Obligations SPG sets out how developer contributions to education provision will be secured via section 106 agreements The ESFA supports the Councilrsquos approach to ensure developer contributions address the impacts arising from growth However the ESFA recommends that the Local Plan includes a commitment to revise the Planning Obligations SPG in line with the latest evidence of the boroughrsquos infrastructure needs pupil yields and build costs (including the cost of school expansion new build and SEN provision) Any such review should be prepared in consultation with the county council as local education authority This will help to ensure appropriate rates are levied and the right infrastructure is secured across the borough

11 The ESFA would be particularly interested in responding to any update to the Infrastructure Delivery Plan or review of infrastructure requirements As such please add the ESFA to the database for future CIL consultations

Forward funding

12 In light of the proposed Longcross Garden Village emerging ESFA proposals for forward funding schools as part of large residential developments may be relevant for example if viability becomes an issue The ESFA aims to be able to clarify forward funding options for schools in 2018 We would be happy to meet to discuss this opportunity further once the options have been finalised and ifwhen relevant Any offer of forward funding would seek to maximise developer contributions to education infrastructure provision while supporting delivery of schools where and when they are needed

Conclusion

13 Finally I hope the above comments are helpful in finalising the Runnymede Local Plan with specific regard to the provision of land for new schools

14 Please notify the ESFA when the Local Plan is submitted for examination the Inspectorrsquos report is published and the Local Plan is adopted

15 Please do not hesitate to contact me if you have any queries regarding this response The ESFA looks forward to continuing to work with Runnymede Borough Council to develop a sound Local Plan that will aid in the delivery of new schools

Yours faithfully

DC McNab

Douglas McNab MRTPI

Forward Planning Manager

Tel 07990 082877

Email

douglasmcnabeducationgovuk
Page 39: Runnymede Borough Council, for submissions. My contact details are all in the WORD letter attached. But I will provide my telephone number here too, which …

2

Part B ndash Please use a separate sheet for each representation

Name or Organisation

3 To which part of the Local Plan does this representation relate

Paragraph Policy Policies Map

4 Do you consider the Local Plan is

4 (1) Legally compliant Yes No

4 (2) Sound Yes No

4 (3) Complies with the Duty to co-operate Yes No

Please tick as appropriate

5 Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails

to comply with the duty to co-operate Please be as precise as possible

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the

duty to co-operate please also use this box to set out your comments

(Continue on a separate sheetexpand box if necessary)

EE15

x

x

x

Please see attached (pages 7-8)

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

From MCNAB DouglasTo Planning PolicySubject Runnymede Draft Local Plan consultation - Representation from Education and Skills Funding AgencyDate 21 February 2018 091407Attachments Runnymede Reg 19 response ESFADOC

Dear Runnymede Planning Policy Team

Please see attached a representation from the Education and Skills Funding Agency on theRunnymede Local Plan consultation

I would be grateful if you could confirm receipt

Best regardsDoug

Douglas McNab MRTPIForward Planning Manager ndash South East

Planning Team Free Schools CapitalEducation and Skills Funding AgencyDepartment for Education 5th floor Sanctuary Buildings 20 Great Smith Street London SW1P 3BT

Email douglasmcnabeducationgovukMobile 07990 082877Web wwwgovukesfa

1895

image1pngOur Ref ESFALocal PlanRunnymede 2018 21st February 2018

Dear SirMadam

Re Runnymede Local Plan

Consultation under Regulation 19 of Town and Country Planning (Local Planning) (England) Regulations 2012

Submission of the Education and Skills Funding Agency

1 The Education and Skills Funding Agency (ESFA) welcomes the opportunity to contribute to the development of planning policy at the local level

2 The ESFA launched on 1st April 2017 bringing together the existing responsibilities of the Education Funding Agency (EFA) and the Skills Funding Agency (SFA) to create a single funding agency accountable for funding education and training for children young people and adults The ESFA are accountable for pound61 billion of funding a year for the education and training sector including support for all state-provided education for 8 million children aged 3 to 16 and 16 million young people aged 16 to 19

3 Under the provisions of the Education Act 2011 and the Academies Act 2010 all new state schools are now academiesfree schools and the ESFA is the delivery body for many of these rather than local education authorities As such we aim to work closely with local authority education departments and planning authorities to meet the demand for new school places and new schools We do this through a variety of means including by supporting the adoption of sound local plan policies site allocations and guidance (all based on robust evidence) that facilitate the delivery of education infrastructure where and when it is needed and maximise developer contributions for schools In this capacity we would like to offer the following comments in response to the proposals outlined in the above consultation document

Comments on the Local Plan

4 As you will be aware the primary focus at this stage of the Local Planrsquos preparation is on the soundness of the plan with regard to it being positively prepared justified effective and consistent with national policy The following detailed comments set out the ESFArsquos view of the planrsquos soundness in respect of education provision

5 The ESFA notes that the local plan will make provision for a minimum of 7413 net additional dwellings over the plan period Development will generally complement the existing settlement pattern focusing the largest amounts of residential growth primarily in Chertsey (1950 homes) Addlestone (936 homes) and Egham (812 homes) A new ldquolocally led garden villagerdquo is also proposed at Longcross providing a further 1718 homes This level of development will put pressure on existing education infrastructure

6 The plan recognises that ldquoIt is important that infrastructure is delivered in a timely manner to ensure that the needs of the occupiers of new development can be met without placing undue burdens on existing infrastructure facilities and servicesrdquo (para 560) The ESFA supports Policy SD6 Infrastructure Provision amp Timing particularly the signposting of the Infrastructure Delivery Plan (IDP) and the need for development to deliver this either on-site or through s106 or CIL financial contributions off-site and the need for development to be phased in line with the provision of important supporting infrastructure

7 The latest version of the IDP states that there is an ongoing programme of primary school expansions this will help to meet the forecast need for 4-6FE of new capacity over the plan period The need for one new build school project is identified a 2FE primary school at the Longcross Garden Village (estimated cost pound99M to pound15M) this is referred to in the site allocation policies (see below) With respect to secondary school places it is anticipated that up to six additional FE could be required in the Borough by 2021 Additional places will be delivered through the new 6FE Runnymede Free School (which opened in temporary accommodation in 2017) development of additional FE within Salesian School (Catholic faith school) and expansion of another school in the Chertsey area (to accommodate demand from generated by the Longcross Garden Village site)

8 It would be useful if the background data informing these projections of need could be clarified particularly the pupil yield factors used and the evidence base supporting this This would help to demonstrate more clearly to the Inspector that the approach to the planning and delivery of education infrastructure has been positively prepared based on a strategy which seeks to meet objectively assessed infrastructure requirements and is justified based on proportionate evidence The ESFA notes that the Runnymede S106 SPG sets out pupil yield figures however this document dates from December 2007 so the figures may be outdated

9 The ESFA supports the Councilrsquos allocation and safeguarding of land for schools as set out in the following policies

middot Policy SD10 Longcross Garden Village - 2FE primary school with preschoolearly years settings

middot Policy SL2 to SL18 ndash series of housing allocation policies that highlight the need to make a financial contribution to early years primary and secondary school infrastructure ldquoeither through S106 or CIL (or its successor)rdquo

Developer Contributions and CIL

10 One of the tests of soundness is that a Local Plan is lsquoeffectiversquo ie the plan should be deliverable over its period In this context and with specific regard to planning for schools there is a need to ensure that education contributions made by developers are sufficient to deliver the additional school places required to meet the increase in demand generated by new developments The ESFA notes that the council has not adopted CIL and that the Planning Obligations SPG sets out how developer contributions to education provision will be secured via section 106 agreements The ESFA supports the Councilrsquos approach to ensure developer contributions address the impacts arising from growth However the ESFA recommends that the Local Plan includes a commitment to revise the Planning Obligations SPG in line with the latest evidence of the boroughrsquos infrastructure needs pupil yields and build costs (including the cost of school expansion new build and SEN provision) Any such review should be prepared in consultation with the county council as local education authority This will help to ensure appropriate rates are levied and the right infrastructure is secured across the borough

11 The ESFA would be particularly interested in responding to any update to the Infrastructure Delivery Plan or review of infrastructure requirements As such please add the ESFA to the database for future CIL consultations

Forward funding

12 In light of the proposed Longcross Garden Village emerging ESFA proposals for forward funding schools as part of large residential developments may be relevant for example if viability becomes an issue The ESFA aims to be able to clarify forward funding options for schools in 2018 We would be happy to meet to discuss this opportunity further once the options have been finalised and ifwhen relevant Any offer of forward funding would seek to maximise developer contributions to education infrastructure provision while supporting delivery of schools where and when they are needed

Conclusion

13 Finally I hope the above comments are helpful in finalising the Runnymede Local Plan with specific regard to the provision of land for new schools

14 Please notify the ESFA when the Local Plan is submitted for examination the Inspectorrsquos report is published and the Local Plan is adopted

15 Please do not hesitate to contact me if you have any queries regarding this response The ESFA looks forward to continuing to work with Runnymede Borough Council to develop a sound Local Plan that will aid in the delivery of new schools

Yours faithfully

DC McNab

Douglas McNab MRTPI

Forward Planning Manager

Tel 07990 082877

Email

douglasmcnabeducationgovuk
Page 40: Runnymede Borough Council, for submissions. My contact details are all in the WORD letter attached. But I will provide my telephone number here too, which …

3

6 Please set out what modification (s) you consider necessary to make the Local Plan legally

compliant or sound having regard to the Matter you have identified at 5 above where this relates to

soundness (NB Please note that any non-compliance with the duty to co-operate is incapable of

modification at examination) You will need to say why this modification will make the Local Plan

legally compliant or sound It will be helpful if you are able to put forward your suggested revised

wording of any policy or text Please be as precise as possible

(Continue on a separate sheetexpand box if necessary)

Please note your representation should cover succinctly all the information evidence and supporting

information necessary to supportjustify the representation and the suggested modification as there

will not normally be a subsequent opportunity to make further representations based on the original

representation at publication stage

After this stage further submissions will be only at the request of the Inspector based on the

matters and issues heshe identifies for examination

7 If you representation is seeking a modification do you consider it necessary to participate at the

oral part of the examination

No I do not wish to participate Yes I wish to participate

at the oral examination at the oral examination

Change of wording of lsquoThe re-use of buildings in the Green Belt may not be

inappropriate providedhelliprsquo to lsquoThe re-use of buildings in the Green Belt will not be

inappropriate providedhelliprsquo

Deletion of the last sentence of Policy EE15 and the bullet points

x

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

From MCNAB DouglasTo Planning PolicySubject Runnymede Draft Local Plan consultation - Representation from Education and Skills Funding AgencyDate 21 February 2018 091407Attachments Runnymede Reg 19 response ESFADOC

Dear Runnymede Planning Policy Team

Please see attached a representation from the Education and Skills Funding Agency on theRunnymede Local Plan consultation

I would be grateful if you could confirm receipt

Best regardsDoug

Douglas McNab MRTPIForward Planning Manager ndash South East

Planning Team Free Schools CapitalEducation and Skills Funding AgencyDepartment for Education 5th floor Sanctuary Buildings 20 Great Smith Street London SW1P 3BT

Email douglasmcnabeducationgovukMobile 07990 082877Web wwwgovukesfa

1895

image1pngOur Ref ESFALocal PlanRunnymede 2018 21st February 2018

Dear SirMadam

Re Runnymede Local Plan

Consultation under Regulation 19 of Town and Country Planning (Local Planning) (England) Regulations 2012

Submission of the Education and Skills Funding Agency

1 The Education and Skills Funding Agency (ESFA) welcomes the opportunity to contribute to the development of planning policy at the local level

2 The ESFA launched on 1st April 2017 bringing together the existing responsibilities of the Education Funding Agency (EFA) and the Skills Funding Agency (SFA) to create a single funding agency accountable for funding education and training for children young people and adults The ESFA are accountable for pound61 billion of funding a year for the education and training sector including support for all state-provided education for 8 million children aged 3 to 16 and 16 million young people aged 16 to 19

3 Under the provisions of the Education Act 2011 and the Academies Act 2010 all new state schools are now academiesfree schools and the ESFA is the delivery body for many of these rather than local education authorities As such we aim to work closely with local authority education departments and planning authorities to meet the demand for new school places and new schools We do this through a variety of means including by supporting the adoption of sound local plan policies site allocations and guidance (all based on robust evidence) that facilitate the delivery of education infrastructure where and when it is needed and maximise developer contributions for schools In this capacity we would like to offer the following comments in response to the proposals outlined in the above consultation document

Comments on the Local Plan

4 As you will be aware the primary focus at this stage of the Local Planrsquos preparation is on the soundness of the plan with regard to it being positively prepared justified effective and consistent with national policy The following detailed comments set out the ESFArsquos view of the planrsquos soundness in respect of education provision

5 The ESFA notes that the local plan will make provision for a minimum of 7413 net additional dwellings over the plan period Development will generally complement the existing settlement pattern focusing the largest amounts of residential growth primarily in Chertsey (1950 homes) Addlestone (936 homes) and Egham (812 homes) A new ldquolocally led garden villagerdquo is also proposed at Longcross providing a further 1718 homes This level of development will put pressure on existing education infrastructure

6 The plan recognises that ldquoIt is important that infrastructure is delivered in a timely manner to ensure that the needs of the occupiers of new development can be met without placing undue burdens on existing infrastructure facilities and servicesrdquo (para 560) The ESFA supports Policy SD6 Infrastructure Provision amp Timing particularly the signposting of the Infrastructure Delivery Plan (IDP) and the need for development to deliver this either on-site or through s106 or CIL financial contributions off-site and the need for development to be phased in line with the provision of important supporting infrastructure

7 The latest version of the IDP states that there is an ongoing programme of primary school expansions this will help to meet the forecast need for 4-6FE of new capacity over the plan period The need for one new build school project is identified a 2FE primary school at the Longcross Garden Village (estimated cost pound99M to pound15M) this is referred to in the site allocation policies (see below) With respect to secondary school places it is anticipated that up to six additional FE could be required in the Borough by 2021 Additional places will be delivered through the new 6FE Runnymede Free School (which opened in temporary accommodation in 2017) development of additional FE within Salesian School (Catholic faith school) and expansion of another school in the Chertsey area (to accommodate demand from generated by the Longcross Garden Village site)

8 It would be useful if the background data informing these projections of need could be clarified particularly the pupil yield factors used and the evidence base supporting this This would help to demonstrate more clearly to the Inspector that the approach to the planning and delivery of education infrastructure has been positively prepared based on a strategy which seeks to meet objectively assessed infrastructure requirements and is justified based on proportionate evidence The ESFA notes that the Runnymede S106 SPG sets out pupil yield figures however this document dates from December 2007 so the figures may be outdated

9 The ESFA supports the Councilrsquos allocation and safeguarding of land for schools as set out in the following policies

middot Policy SD10 Longcross Garden Village - 2FE primary school with preschoolearly years settings

middot Policy SL2 to SL18 ndash series of housing allocation policies that highlight the need to make a financial contribution to early years primary and secondary school infrastructure ldquoeither through S106 or CIL (or its successor)rdquo

Developer Contributions and CIL

10 One of the tests of soundness is that a Local Plan is lsquoeffectiversquo ie the plan should be deliverable over its period In this context and with specific regard to planning for schools there is a need to ensure that education contributions made by developers are sufficient to deliver the additional school places required to meet the increase in demand generated by new developments The ESFA notes that the council has not adopted CIL and that the Planning Obligations SPG sets out how developer contributions to education provision will be secured via section 106 agreements The ESFA supports the Councilrsquos approach to ensure developer contributions address the impacts arising from growth However the ESFA recommends that the Local Plan includes a commitment to revise the Planning Obligations SPG in line with the latest evidence of the boroughrsquos infrastructure needs pupil yields and build costs (including the cost of school expansion new build and SEN provision) Any such review should be prepared in consultation with the county council as local education authority This will help to ensure appropriate rates are levied and the right infrastructure is secured across the borough

11 The ESFA would be particularly interested in responding to any update to the Infrastructure Delivery Plan or review of infrastructure requirements As such please add the ESFA to the database for future CIL consultations

Forward funding

12 In light of the proposed Longcross Garden Village emerging ESFA proposals for forward funding schools as part of large residential developments may be relevant for example if viability becomes an issue The ESFA aims to be able to clarify forward funding options for schools in 2018 We would be happy to meet to discuss this opportunity further once the options have been finalised and ifwhen relevant Any offer of forward funding would seek to maximise developer contributions to education infrastructure provision while supporting delivery of schools where and when they are needed

Conclusion

13 Finally I hope the above comments are helpful in finalising the Runnymede Local Plan with specific regard to the provision of land for new schools

14 Please notify the ESFA when the Local Plan is submitted for examination the Inspectorrsquos report is published and the Local Plan is adopted

15 Please do not hesitate to contact me if you have any queries regarding this response The ESFA looks forward to continuing to work with Runnymede Borough Council to develop a sound Local Plan that will aid in the delivery of new schools

Yours faithfully

DC McNab

Douglas McNab MRTPI

Forward Planning Manager

Tel 07990 082877

Email

douglasmcnabeducationgovuk
Page 41: Runnymede Borough Council, for submissions. My contact details are all in the WORD letter attached. But I will provide my telephone number here too, which …

4

8 If you wish to participate at the oral part of the examination please outline why you consider this

to be necessary

Please note the Inspector will determine the most appropriate procedure to adopt to hear those who

have indicated that they wish to participate at the oral part of the examination

9 Signature Date

C J Leigh 21218

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

From MCNAB DouglasTo Planning PolicySubject Runnymede Draft Local Plan consultation - Representation from Education and Skills Funding AgencyDate 21 February 2018 091407Attachments Runnymede Reg 19 response ESFADOC

Dear Runnymede Planning Policy Team

Please see attached a representation from the Education and Skills Funding Agency on theRunnymede Local Plan consultation

I would be grateful if you could confirm receipt

Best regardsDoug

Douglas McNab MRTPIForward Planning Manager ndash South East

Planning Team Free Schools CapitalEducation and Skills Funding AgencyDepartment for Education 5th floor Sanctuary Buildings 20 Great Smith Street London SW1P 3BT

Email douglasmcnabeducationgovukMobile 07990 082877Web wwwgovukesfa

1895

image1pngOur Ref ESFALocal PlanRunnymede 2018 21st February 2018

Dear SirMadam

Re Runnymede Local Plan

Consultation under Regulation 19 of Town and Country Planning (Local Planning) (England) Regulations 2012

Submission of the Education and Skills Funding Agency

1 The Education and Skills Funding Agency (ESFA) welcomes the opportunity to contribute to the development of planning policy at the local level

2 The ESFA launched on 1st April 2017 bringing together the existing responsibilities of the Education Funding Agency (EFA) and the Skills Funding Agency (SFA) to create a single funding agency accountable for funding education and training for children young people and adults The ESFA are accountable for pound61 billion of funding a year for the education and training sector including support for all state-provided education for 8 million children aged 3 to 16 and 16 million young people aged 16 to 19

3 Under the provisions of the Education Act 2011 and the Academies Act 2010 all new state schools are now academiesfree schools and the ESFA is the delivery body for many of these rather than local education authorities As such we aim to work closely with local authority education departments and planning authorities to meet the demand for new school places and new schools We do this through a variety of means including by supporting the adoption of sound local plan policies site allocations and guidance (all based on robust evidence) that facilitate the delivery of education infrastructure where and when it is needed and maximise developer contributions for schools In this capacity we would like to offer the following comments in response to the proposals outlined in the above consultation document

Comments on the Local Plan

4 As you will be aware the primary focus at this stage of the Local Planrsquos preparation is on the soundness of the plan with regard to it being positively prepared justified effective and consistent with national policy The following detailed comments set out the ESFArsquos view of the planrsquos soundness in respect of education provision

5 The ESFA notes that the local plan will make provision for a minimum of 7413 net additional dwellings over the plan period Development will generally complement the existing settlement pattern focusing the largest amounts of residential growth primarily in Chertsey (1950 homes) Addlestone (936 homes) and Egham (812 homes) A new ldquolocally led garden villagerdquo is also proposed at Longcross providing a further 1718 homes This level of development will put pressure on existing education infrastructure

6 The plan recognises that ldquoIt is important that infrastructure is delivered in a timely manner to ensure that the needs of the occupiers of new development can be met without placing undue burdens on existing infrastructure facilities and servicesrdquo (para 560) The ESFA supports Policy SD6 Infrastructure Provision amp Timing particularly the signposting of the Infrastructure Delivery Plan (IDP) and the need for development to deliver this either on-site or through s106 or CIL financial contributions off-site and the need for development to be phased in line with the provision of important supporting infrastructure

7 The latest version of the IDP states that there is an ongoing programme of primary school expansions this will help to meet the forecast need for 4-6FE of new capacity over the plan period The need for one new build school project is identified a 2FE primary school at the Longcross Garden Village (estimated cost pound99M to pound15M) this is referred to in the site allocation policies (see below) With respect to secondary school places it is anticipated that up to six additional FE could be required in the Borough by 2021 Additional places will be delivered through the new 6FE Runnymede Free School (which opened in temporary accommodation in 2017) development of additional FE within Salesian School (Catholic faith school) and expansion of another school in the Chertsey area (to accommodate demand from generated by the Longcross Garden Village site)

8 It would be useful if the background data informing these projections of need could be clarified particularly the pupil yield factors used and the evidence base supporting this This would help to demonstrate more clearly to the Inspector that the approach to the planning and delivery of education infrastructure has been positively prepared based on a strategy which seeks to meet objectively assessed infrastructure requirements and is justified based on proportionate evidence The ESFA notes that the Runnymede S106 SPG sets out pupil yield figures however this document dates from December 2007 so the figures may be outdated

9 The ESFA supports the Councilrsquos allocation and safeguarding of land for schools as set out in the following policies

middot Policy SD10 Longcross Garden Village - 2FE primary school with preschoolearly years settings

middot Policy SL2 to SL18 ndash series of housing allocation policies that highlight the need to make a financial contribution to early years primary and secondary school infrastructure ldquoeither through S106 or CIL (or its successor)rdquo

Developer Contributions and CIL

10 One of the tests of soundness is that a Local Plan is lsquoeffectiversquo ie the plan should be deliverable over its period In this context and with specific regard to planning for schools there is a need to ensure that education contributions made by developers are sufficient to deliver the additional school places required to meet the increase in demand generated by new developments The ESFA notes that the council has not adopted CIL and that the Planning Obligations SPG sets out how developer contributions to education provision will be secured via section 106 agreements The ESFA supports the Councilrsquos approach to ensure developer contributions address the impacts arising from growth However the ESFA recommends that the Local Plan includes a commitment to revise the Planning Obligations SPG in line with the latest evidence of the boroughrsquos infrastructure needs pupil yields and build costs (including the cost of school expansion new build and SEN provision) Any such review should be prepared in consultation with the county council as local education authority This will help to ensure appropriate rates are levied and the right infrastructure is secured across the borough

11 The ESFA would be particularly interested in responding to any update to the Infrastructure Delivery Plan or review of infrastructure requirements As such please add the ESFA to the database for future CIL consultations

Forward funding

12 In light of the proposed Longcross Garden Village emerging ESFA proposals for forward funding schools as part of large residential developments may be relevant for example if viability becomes an issue The ESFA aims to be able to clarify forward funding options for schools in 2018 We would be happy to meet to discuss this opportunity further once the options have been finalised and ifwhen relevant Any offer of forward funding would seek to maximise developer contributions to education infrastructure provision while supporting delivery of schools where and when they are needed

Conclusion

13 Finally I hope the above comments are helpful in finalising the Runnymede Local Plan with specific regard to the provision of land for new schools

14 Please notify the ESFA when the Local Plan is submitted for examination the Inspectorrsquos report is published and the Local Plan is adopted

15 Please do not hesitate to contact me if you have any queries regarding this response The ESFA looks forward to continuing to work with Runnymede Borough Council to develop a sound Local Plan that will aid in the delivery of new schools

Yours faithfully

DC McNab

Douglas McNab MRTPI

Forward Planning Manager

Tel 07990 082877

Email

douglasmcnabeducationgovuk
Page 42: Runnymede Borough Council, for submissions. My contact details are all in the WORD letter attached. But I will provide my telephone number here too, which …

5

Notes to Accompany Model Representation Form 1 Introduction 11 The plan is published in order for representations to be made prior to submission The representations will be considered alongside the published plan when submitted which will be examined by a Planning Inspector The Planning and Compulsory Purchase Act 20041 (as amended) (PCPA) states that the purpose of the examination is to consider whether the plan complies with the legal requirements the duty to co-operate and is sound 2 Legal Compliance and Duty to Co-operate 21 The Inspector will first check that the plan meets the legal requirements under s20(5)(a) and the duty to co-operate under s20(5)(c) of the PCPA before moving on to test for soundness 22 You should consider the following before making a representation on legal compliance

bull The plan in question should be included in the current Local Development Scheme (LDS) and the key stages should have been followed The LDS is effectively a programme of work prepared by the LPA setting out the Local Development Documents (LDDs)2 it proposes to produce It will set out the key stages in the production of any plans which the LPA proposes to bring forward for independent examination If the plan is not in the current LDS it should not have been published for representations The LDS should be on the LPArsquos website and available at its main offices bull The process of community involvement for the plan in question should be in general accordance with the LPArsquos Statement of Community Involvement (SCI) (where one exists) The SCI sets out the LPArsquos strategy for involving the community in the preparation and revision of LDDs (including plans) and the consideration of planning applications bullThe plan should comply with the Town and County Planning (Local Planning) (England) Regulations 2012 (the Regulations)3 On publication the LPA must publish the documents prescribed in the Regulations and make them available at its principal offices and on its website The LPA must also notify the various persons and organisations set out in the Regulations and any persons who have requested to be notified bull The LPA is required to provide a Sustainability Appraisal Report when it publishes a plan This should identify the process by which the Sustainability Appraisal has been carried out and the baseline information used to inform the process and the outcomes of that process Sustainability Appraisal is a tool for appraising policies to ensure they reflect social environmental and economic factors

bull In London the plan should be in general conformity with the London Plan (the Spatial Development Strategy) 23 You should consider the following before making a representation on compliance with the duty to co-operate bull The duty to co-operate came into force on 15 November 2011 and any plan submitted for examination on or after this date will be examined for compliance LPAs will be expected to provide evidence of how they have complied with any requirements arising from the duty bull The PCPA establishes that non-compliance with the duty to co-operate cannot be rectified after the submission of the plan Therefore the Inspector has no power to recommend modifications in this regard Where the duty has not been complied with the Inspector has no choice but to recommend non-adoption of the plan

1 View at httpwwwlegislationgovukukpga20045contents 2 LDDs are defined in regulation 5 ndash see link below 3 View at httpwwwlegislationgovukuksi2012767contentsmade

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

From MCNAB DouglasTo Planning PolicySubject Runnymede Draft Local Plan consultation - Representation from Education and Skills Funding AgencyDate 21 February 2018 091407Attachments Runnymede Reg 19 response ESFADOC

Dear Runnymede Planning Policy Team

Please see attached a representation from the Education and Skills Funding Agency on theRunnymede Local Plan consultation

I would be grateful if you could confirm receipt

Best regardsDoug

Douglas McNab MRTPIForward Planning Manager ndash South East

Planning Team Free Schools CapitalEducation and Skills Funding AgencyDepartment for Education 5th floor Sanctuary Buildings 20 Great Smith Street London SW1P 3BT

Email douglasmcnabeducationgovukMobile 07990 082877Web wwwgovukesfa

1895

image1pngOur Ref ESFALocal PlanRunnymede 2018 21st February 2018

Dear SirMadam

Re Runnymede Local Plan

Consultation under Regulation 19 of Town and Country Planning (Local Planning) (England) Regulations 2012

Submission of the Education and Skills Funding Agency

1 The Education and Skills Funding Agency (ESFA) welcomes the opportunity to contribute to the development of planning policy at the local level

2 The ESFA launched on 1st April 2017 bringing together the existing responsibilities of the Education Funding Agency (EFA) and the Skills Funding Agency (SFA) to create a single funding agency accountable for funding education and training for children young people and adults The ESFA are accountable for pound61 billion of funding a year for the education and training sector including support for all state-provided education for 8 million children aged 3 to 16 and 16 million young people aged 16 to 19

3 Under the provisions of the Education Act 2011 and the Academies Act 2010 all new state schools are now academiesfree schools and the ESFA is the delivery body for many of these rather than local education authorities As such we aim to work closely with local authority education departments and planning authorities to meet the demand for new school places and new schools We do this through a variety of means including by supporting the adoption of sound local plan policies site allocations and guidance (all based on robust evidence) that facilitate the delivery of education infrastructure where and when it is needed and maximise developer contributions for schools In this capacity we would like to offer the following comments in response to the proposals outlined in the above consultation document

Comments on the Local Plan

4 As you will be aware the primary focus at this stage of the Local Planrsquos preparation is on the soundness of the plan with regard to it being positively prepared justified effective and consistent with national policy The following detailed comments set out the ESFArsquos view of the planrsquos soundness in respect of education provision

5 The ESFA notes that the local plan will make provision for a minimum of 7413 net additional dwellings over the plan period Development will generally complement the existing settlement pattern focusing the largest amounts of residential growth primarily in Chertsey (1950 homes) Addlestone (936 homes) and Egham (812 homes) A new ldquolocally led garden villagerdquo is also proposed at Longcross providing a further 1718 homes This level of development will put pressure on existing education infrastructure

6 The plan recognises that ldquoIt is important that infrastructure is delivered in a timely manner to ensure that the needs of the occupiers of new development can be met without placing undue burdens on existing infrastructure facilities and servicesrdquo (para 560) The ESFA supports Policy SD6 Infrastructure Provision amp Timing particularly the signposting of the Infrastructure Delivery Plan (IDP) and the need for development to deliver this either on-site or through s106 or CIL financial contributions off-site and the need for development to be phased in line with the provision of important supporting infrastructure

7 The latest version of the IDP states that there is an ongoing programme of primary school expansions this will help to meet the forecast need for 4-6FE of new capacity over the plan period The need for one new build school project is identified a 2FE primary school at the Longcross Garden Village (estimated cost pound99M to pound15M) this is referred to in the site allocation policies (see below) With respect to secondary school places it is anticipated that up to six additional FE could be required in the Borough by 2021 Additional places will be delivered through the new 6FE Runnymede Free School (which opened in temporary accommodation in 2017) development of additional FE within Salesian School (Catholic faith school) and expansion of another school in the Chertsey area (to accommodate demand from generated by the Longcross Garden Village site)

8 It would be useful if the background data informing these projections of need could be clarified particularly the pupil yield factors used and the evidence base supporting this This would help to demonstrate more clearly to the Inspector that the approach to the planning and delivery of education infrastructure has been positively prepared based on a strategy which seeks to meet objectively assessed infrastructure requirements and is justified based on proportionate evidence The ESFA notes that the Runnymede S106 SPG sets out pupil yield figures however this document dates from December 2007 so the figures may be outdated

9 The ESFA supports the Councilrsquos allocation and safeguarding of land for schools as set out in the following policies

middot Policy SD10 Longcross Garden Village - 2FE primary school with preschoolearly years settings

middot Policy SL2 to SL18 ndash series of housing allocation policies that highlight the need to make a financial contribution to early years primary and secondary school infrastructure ldquoeither through S106 or CIL (or its successor)rdquo

Developer Contributions and CIL

10 One of the tests of soundness is that a Local Plan is lsquoeffectiversquo ie the plan should be deliverable over its period In this context and with specific regard to planning for schools there is a need to ensure that education contributions made by developers are sufficient to deliver the additional school places required to meet the increase in demand generated by new developments The ESFA notes that the council has not adopted CIL and that the Planning Obligations SPG sets out how developer contributions to education provision will be secured via section 106 agreements The ESFA supports the Councilrsquos approach to ensure developer contributions address the impacts arising from growth However the ESFA recommends that the Local Plan includes a commitment to revise the Planning Obligations SPG in line with the latest evidence of the boroughrsquos infrastructure needs pupil yields and build costs (including the cost of school expansion new build and SEN provision) Any such review should be prepared in consultation with the county council as local education authority This will help to ensure appropriate rates are levied and the right infrastructure is secured across the borough

11 The ESFA would be particularly interested in responding to any update to the Infrastructure Delivery Plan or review of infrastructure requirements As such please add the ESFA to the database for future CIL consultations

Forward funding

12 In light of the proposed Longcross Garden Village emerging ESFA proposals for forward funding schools as part of large residential developments may be relevant for example if viability becomes an issue The ESFA aims to be able to clarify forward funding options for schools in 2018 We would be happy to meet to discuss this opportunity further once the options have been finalised and ifwhen relevant Any offer of forward funding would seek to maximise developer contributions to education infrastructure provision while supporting delivery of schools where and when they are needed

Conclusion

13 Finally I hope the above comments are helpful in finalising the Runnymede Local Plan with specific regard to the provision of land for new schools

14 Please notify the ESFA when the Local Plan is submitted for examination the Inspectorrsquos report is published and the Local Plan is adopted

15 Please do not hesitate to contact me if you have any queries regarding this response The ESFA looks forward to continuing to work with Runnymede Borough Council to develop a sound Local Plan that will aid in the delivery of new schools

Yours faithfully

DC McNab

Douglas McNab MRTPI

Forward Planning Manager

Tel 07990 082877

Email

douglasmcnabeducationgovuk
Page 43: Runnymede Borough Council, for submissions. My contact details are all in the WORD letter attached. But I will provide my telephone number here too, which …

6

3 Soundness 31 Soundness is explained in paragraph 182 of the National Planning Policy Framework (NPPF) The Inspector has to be satisfied that the plan is positively prepared justified effective and consistent with national policy bull Positively prepared This means that the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development bull Justified The plan should be the most appropriate strategy when considered against reasonable alternatives based on proportionate evidence bull Effective The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities bull Consistent with national policy The plan should enable the delivery of sustainable development in accordance with the policies in the NPPF 32 If you think the content of the plan is not sound because it does not include a policy where it should do you should go through the following steps before making representations bull Is the issue with which you are concerned already covered specifically by national planning policy (or the London Plan) If so it does not need to be included bull Is what you are concerned with covered by any other policies in the plan on which you are seeking to make representations or in any other plan bull If the policy is not covered elsewhere in what way is the plan unsound without the policy bull If the plan is unsound without the policy what should the policy say

4 General advice 41 If you wish to make a representation seeking a modification to a plan or part of a plan you should make clear in what way the plan or part of the plan is inadequate having regard to legal compliance the duty to cooperate and the four requirements of soundness set out above You should try to support your representation by evidence showing why the plan should be modified It will be helpful if you also say precisely how you think the plan should be modified Representations should cover succinctly all the information evidence and supporting information necessary to supportjustify the representation and the suggested modification as there will not normally be a subsequent opportunity to make further submissions based on the original representation made at publication After this stage further submissions will be only at the request of the Inspector based on the matters and issues heshe identifies for examination

42 Where there are groups who share a common view on how they wish to see a plan modified it would be very helpful for that group to send a single representation which represents the view rather than for a large number of individuals to send in separate representations which repeat the same points In such cases the group should indicate how many people it is representing and how the representation has been authorised

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

From MCNAB DouglasTo Planning PolicySubject Runnymede Draft Local Plan consultation - Representation from Education and Skills Funding AgencyDate 21 February 2018 091407Attachments Runnymede Reg 19 response ESFADOC

Dear Runnymede Planning Policy Team

Please see attached a representation from the Education and Skills Funding Agency on theRunnymede Local Plan consultation

I would be grateful if you could confirm receipt

Best regardsDoug

Douglas McNab MRTPIForward Planning Manager ndash South East

Planning Team Free Schools CapitalEducation and Skills Funding AgencyDepartment for Education 5th floor Sanctuary Buildings 20 Great Smith Street London SW1P 3BT

Email douglasmcnabeducationgovukMobile 07990 082877Web wwwgovukesfa

1895

image1pngOur Ref ESFALocal PlanRunnymede 2018 21st February 2018

Dear SirMadam

Re Runnymede Local Plan

Consultation under Regulation 19 of Town and Country Planning (Local Planning) (England) Regulations 2012

Submission of the Education and Skills Funding Agency

1 The Education and Skills Funding Agency (ESFA) welcomes the opportunity to contribute to the development of planning policy at the local level

2 The ESFA launched on 1st April 2017 bringing together the existing responsibilities of the Education Funding Agency (EFA) and the Skills Funding Agency (SFA) to create a single funding agency accountable for funding education and training for children young people and adults The ESFA are accountable for pound61 billion of funding a year for the education and training sector including support for all state-provided education for 8 million children aged 3 to 16 and 16 million young people aged 16 to 19

3 Under the provisions of the Education Act 2011 and the Academies Act 2010 all new state schools are now academiesfree schools and the ESFA is the delivery body for many of these rather than local education authorities As such we aim to work closely with local authority education departments and planning authorities to meet the demand for new school places and new schools We do this through a variety of means including by supporting the adoption of sound local plan policies site allocations and guidance (all based on robust evidence) that facilitate the delivery of education infrastructure where and when it is needed and maximise developer contributions for schools In this capacity we would like to offer the following comments in response to the proposals outlined in the above consultation document

Comments on the Local Plan

4 As you will be aware the primary focus at this stage of the Local Planrsquos preparation is on the soundness of the plan with regard to it being positively prepared justified effective and consistent with national policy The following detailed comments set out the ESFArsquos view of the planrsquos soundness in respect of education provision

5 The ESFA notes that the local plan will make provision for a minimum of 7413 net additional dwellings over the plan period Development will generally complement the existing settlement pattern focusing the largest amounts of residential growth primarily in Chertsey (1950 homes) Addlestone (936 homes) and Egham (812 homes) A new ldquolocally led garden villagerdquo is also proposed at Longcross providing a further 1718 homes This level of development will put pressure on existing education infrastructure

6 The plan recognises that ldquoIt is important that infrastructure is delivered in a timely manner to ensure that the needs of the occupiers of new development can be met without placing undue burdens on existing infrastructure facilities and servicesrdquo (para 560) The ESFA supports Policy SD6 Infrastructure Provision amp Timing particularly the signposting of the Infrastructure Delivery Plan (IDP) and the need for development to deliver this either on-site or through s106 or CIL financial contributions off-site and the need for development to be phased in line with the provision of important supporting infrastructure

7 The latest version of the IDP states that there is an ongoing programme of primary school expansions this will help to meet the forecast need for 4-6FE of new capacity over the plan period The need for one new build school project is identified a 2FE primary school at the Longcross Garden Village (estimated cost pound99M to pound15M) this is referred to in the site allocation policies (see below) With respect to secondary school places it is anticipated that up to six additional FE could be required in the Borough by 2021 Additional places will be delivered through the new 6FE Runnymede Free School (which opened in temporary accommodation in 2017) development of additional FE within Salesian School (Catholic faith school) and expansion of another school in the Chertsey area (to accommodate demand from generated by the Longcross Garden Village site)

8 It would be useful if the background data informing these projections of need could be clarified particularly the pupil yield factors used and the evidence base supporting this This would help to demonstrate more clearly to the Inspector that the approach to the planning and delivery of education infrastructure has been positively prepared based on a strategy which seeks to meet objectively assessed infrastructure requirements and is justified based on proportionate evidence The ESFA notes that the Runnymede S106 SPG sets out pupil yield figures however this document dates from December 2007 so the figures may be outdated

9 The ESFA supports the Councilrsquos allocation and safeguarding of land for schools as set out in the following policies

middot Policy SD10 Longcross Garden Village - 2FE primary school with preschoolearly years settings

middot Policy SL2 to SL18 ndash series of housing allocation policies that highlight the need to make a financial contribution to early years primary and secondary school infrastructure ldquoeither through S106 or CIL (or its successor)rdquo

Developer Contributions and CIL

10 One of the tests of soundness is that a Local Plan is lsquoeffectiversquo ie the plan should be deliverable over its period In this context and with specific regard to planning for schools there is a need to ensure that education contributions made by developers are sufficient to deliver the additional school places required to meet the increase in demand generated by new developments The ESFA notes that the council has not adopted CIL and that the Planning Obligations SPG sets out how developer contributions to education provision will be secured via section 106 agreements The ESFA supports the Councilrsquos approach to ensure developer contributions address the impacts arising from growth However the ESFA recommends that the Local Plan includes a commitment to revise the Planning Obligations SPG in line with the latest evidence of the boroughrsquos infrastructure needs pupil yields and build costs (including the cost of school expansion new build and SEN provision) Any such review should be prepared in consultation with the county council as local education authority This will help to ensure appropriate rates are levied and the right infrastructure is secured across the borough

11 The ESFA would be particularly interested in responding to any update to the Infrastructure Delivery Plan or review of infrastructure requirements As such please add the ESFA to the database for future CIL consultations

Forward funding

12 In light of the proposed Longcross Garden Village emerging ESFA proposals for forward funding schools as part of large residential developments may be relevant for example if viability becomes an issue The ESFA aims to be able to clarify forward funding options for schools in 2018 We would be happy to meet to discuss this opportunity further once the options have been finalised and ifwhen relevant Any offer of forward funding would seek to maximise developer contributions to education infrastructure provision while supporting delivery of schools where and when they are needed

Conclusion

13 Finally I hope the above comments are helpful in finalising the Runnymede Local Plan with specific regard to the provision of land for new schools

14 Please notify the ESFA when the Local Plan is submitted for examination the Inspectorrsquos report is published and the Local Plan is adopted

15 Please do not hesitate to contact me if you have any queries regarding this response The ESFA looks forward to continuing to work with Runnymede Borough Council to develop a sound Local Plan that will aid in the delivery of new schools

Yours faithfully

DC McNab

Douglas McNab MRTPI

Forward Planning Manager

Tel 07990 082877

Email

douglasmcnabeducationgovuk
Page 44: Runnymede Borough Council, for submissions. My contact details are all in the WORD letter attached. But I will provide my telephone number here too, which …

7

Answer to Q5

Policy EE15 is not consistent with policy in the NPPF Paragraph 90 of the NPPF says that the

re-use of buildings within the Green Belt is a form of development that lsquoare also not

inappropriate in Green Belt provided they preserve the openness of the Green Belt and do

not conflict with the purposes of including land in Green Beltrsquo (emphasis added) The draft

Policy says the re-use of buildings lsquomay not be inappropriatersquo (emphasis added) The use of

the word lsquomayrsquo introduces the opportunity for flexibility by the Council in interpretation of

whether the re-use of a building will be lsquonot inappropriatersquo and such flexibilityambiguity is

not included in the NPPF

Policy EE15 also attempts to bring in further tests that are not set out in the NPPF The

reference to the requirement that lsquoprovided the buildings are of permanent and substantial

construction the proposal preserves the openness of the Green Belt and does not conflict

with the Green Belt purposesrsquo is suitable But other tests are not suitable as discussed

below

The permanence and condition of the building It must be capable of conversion

without major or complete reconstruction Comment reasonable but not necessary

ndash the wording of the NPPF and the main paragraph of Policy EE15 contains this

requirement

The relationship with surrounding land uses and implications for future uses

Comment not reasonable There is nothing in the NPPF that says such a test of some

unclear lsquorelationshiprsquo with other uses or possible lsquofuture usesrsquo should be taken into

account This is a vague and unreasonable test to include in a policy If the intention

is to have regard to the effect of the re-use on the openness of the Green Belt or the

purposes of including land within the Green Belt then the NPPF provides that (as

does the first paragraph of Policy EE15)

The loss of an existing use should not give rise to a need for another building to fulfil

the function of the building being re-used Comment unreasonable There is no such

test in the NPPF This is another vague and imprecise policy test how would such a

matter be regarded It is just speculation on future uses of the land In any event

any future application for a new building would be tested against Green Belt policy

and permitted or refused on its merits in relation to policy (and the fact that if a

previous building had been converted then that could be a material consideration at

the time) There is no justification for this criterion

Extent of ancillary works or features such as external storage hardstanding car

parking boundary walling or fencing Comment unnecessary As noted the wording

of the NPPF and the main paragraph of Policy EE15 already has the tests of

preserving the openness of the Green Belt and not conflicting with the purposes of

including land within the Green Belt

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

From MCNAB DouglasTo Planning PolicySubject Runnymede Draft Local Plan consultation - Representation from Education and Skills Funding AgencyDate 21 February 2018 091407Attachments Runnymede Reg 19 response ESFADOC

Dear Runnymede Planning Policy Team

Please see attached a representation from the Education and Skills Funding Agency on theRunnymede Local Plan consultation

I would be grateful if you could confirm receipt

Best regardsDoug

Douglas McNab MRTPIForward Planning Manager ndash South East

Planning Team Free Schools CapitalEducation and Skills Funding AgencyDepartment for Education 5th floor Sanctuary Buildings 20 Great Smith Street London SW1P 3BT

Email douglasmcnabeducationgovukMobile 07990 082877Web wwwgovukesfa

1895

image1pngOur Ref ESFALocal PlanRunnymede 2018 21st February 2018

Dear SirMadam

Re Runnymede Local Plan

Consultation under Regulation 19 of Town and Country Planning (Local Planning) (England) Regulations 2012

Submission of the Education and Skills Funding Agency

1 The Education and Skills Funding Agency (ESFA) welcomes the opportunity to contribute to the development of planning policy at the local level

2 The ESFA launched on 1st April 2017 bringing together the existing responsibilities of the Education Funding Agency (EFA) and the Skills Funding Agency (SFA) to create a single funding agency accountable for funding education and training for children young people and adults The ESFA are accountable for pound61 billion of funding a year for the education and training sector including support for all state-provided education for 8 million children aged 3 to 16 and 16 million young people aged 16 to 19

3 Under the provisions of the Education Act 2011 and the Academies Act 2010 all new state schools are now academiesfree schools and the ESFA is the delivery body for many of these rather than local education authorities As such we aim to work closely with local authority education departments and planning authorities to meet the demand for new school places and new schools We do this through a variety of means including by supporting the adoption of sound local plan policies site allocations and guidance (all based on robust evidence) that facilitate the delivery of education infrastructure where and when it is needed and maximise developer contributions for schools In this capacity we would like to offer the following comments in response to the proposals outlined in the above consultation document

Comments on the Local Plan

4 As you will be aware the primary focus at this stage of the Local Planrsquos preparation is on the soundness of the plan with regard to it being positively prepared justified effective and consistent with national policy The following detailed comments set out the ESFArsquos view of the planrsquos soundness in respect of education provision

5 The ESFA notes that the local plan will make provision for a minimum of 7413 net additional dwellings over the plan period Development will generally complement the existing settlement pattern focusing the largest amounts of residential growth primarily in Chertsey (1950 homes) Addlestone (936 homes) and Egham (812 homes) A new ldquolocally led garden villagerdquo is also proposed at Longcross providing a further 1718 homes This level of development will put pressure on existing education infrastructure

6 The plan recognises that ldquoIt is important that infrastructure is delivered in a timely manner to ensure that the needs of the occupiers of new development can be met without placing undue burdens on existing infrastructure facilities and servicesrdquo (para 560) The ESFA supports Policy SD6 Infrastructure Provision amp Timing particularly the signposting of the Infrastructure Delivery Plan (IDP) and the need for development to deliver this either on-site or through s106 or CIL financial contributions off-site and the need for development to be phased in line with the provision of important supporting infrastructure

7 The latest version of the IDP states that there is an ongoing programme of primary school expansions this will help to meet the forecast need for 4-6FE of new capacity over the plan period The need for one new build school project is identified a 2FE primary school at the Longcross Garden Village (estimated cost pound99M to pound15M) this is referred to in the site allocation policies (see below) With respect to secondary school places it is anticipated that up to six additional FE could be required in the Borough by 2021 Additional places will be delivered through the new 6FE Runnymede Free School (which opened in temporary accommodation in 2017) development of additional FE within Salesian School (Catholic faith school) and expansion of another school in the Chertsey area (to accommodate demand from generated by the Longcross Garden Village site)

8 It would be useful if the background data informing these projections of need could be clarified particularly the pupil yield factors used and the evidence base supporting this This would help to demonstrate more clearly to the Inspector that the approach to the planning and delivery of education infrastructure has been positively prepared based on a strategy which seeks to meet objectively assessed infrastructure requirements and is justified based on proportionate evidence The ESFA notes that the Runnymede S106 SPG sets out pupil yield figures however this document dates from December 2007 so the figures may be outdated

9 The ESFA supports the Councilrsquos allocation and safeguarding of land for schools as set out in the following policies

middot Policy SD10 Longcross Garden Village - 2FE primary school with preschoolearly years settings

middot Policy SL2 to SL18 ndash series of housing allocation policies that highlight the need to make a financial contribution to early years primary and secondary school infrastructure ldquoeither through S106 or CIL (or its successor)rdquo

Developer Contributions and CIL

10 One of the tests of soundness is that a Local Plan is lsquoeffectiversquo ie the plan should be deliverable over its period In this context and with specific regard to planning for schools there is a need to ensure that education contributions made by developers are sufficient to deliver the additional school places required to meet the increase in demand generated by new developments The ESFA notes that the council has not adopted CIL and that the Planning Obligations SPG sets out how developer contributions to education provision will be secured via section 106 agreements The ESFA supports the Councilrsquos approach to ensure developer contributions address the impacts arising from growth However the ESFA recommends that the Local Plan includes a commitment to revise the Planning Obligations SPG in line with the latest evidence of the boroughrsquos infrastructure needs pupil yields and build costs (including the cost of school expansion new build and SEN provision) Any such review should be prepared in consultation with the county council as local education authority This will help to ensure appropriate rates are levied and the right infrastructure is secured across the borough

11 The ESFA would be particularly interested in responding to any update to the Infrastructure Delivery Plan or review of infrastructure requirements As such please add the ESFA to the database for future CIL consultations

Forward funding

12 In light of the proposed Longcross Garden Village emerging ESFA proposals for forward funding schools as part of large residential developments may be relevant for example if viability becomes an issue The ESFA aims to be able to clarify forward funding options for schools in 2018 We would be happy to meet to discuss this opportunity further once the options have been finalised and ifwhen relevant Any offer of forward funding would seek to maximise developer contributions to education infrastructure provision while supporting delivery of schools where and when they are needed

Conclusion

13 Finally I hope the above comments are helpful in finalising the Runnymede Local Plan with specific regard to the provision of land for new schools

14 Please notify the ESFA when the Local Plan is submitted for examination the Inspectorrsquos report is published and the Local Plan is adopted

15 Please do not hesitate to contact me if you have any queries regarding this response The ESFA looks forward to continuing to work with Runnymede Borough Council to develop a sound Local Plan that will aid in the delivery of new schools

Yours faithfully

DC McNab

Douglas McNab MRTPI

Forward Planning Manager

Tel 07990 082877

Email

douglasmcnabeducationgovuk
Page 45: Runnymede Borough Council, for submissions. My contact details are all in the WORD letter attached. But I will provide my telephone number here too, which …

8

Whether the proposal would restoreretain a building of architectural or historic

interest Comment unreasonable There is nothing in the NPPF that says this should

be a consideration as to whether the principle of the re-use of a building within the

Green Belt should be considered not inappropriate development

The location of the building Re-use may require associated works in relation to the

public highway network and utility services such as sewerage water and electricity

which may impact upon the Green Belt Comment unreasonable and unnecessary

There is nothing in the NPPF that relates to the location of the building being

relevant to the test of whether the re-use of a building should be considered not

inappropriate development Any impacts upon the Green Belt arising from highways

works or utility works would be considered by the NPPF and Policy EE15 tests

relating to preserving the openness of the Green Belt and not conflicting with the

purposes of including land in the Green Belt

All the lsquotestsrsquo set out in the bullet points of the Policy are therefore not consistent with the

NPPF as they attempt to bring in matters not set out in national policy The Policy EE15 is

therefore not sound

From MCNAB DouglasTo Planning PolicySubject Runnymede Draft Local Plan consultation - Representation from Education and Skills Funding AgencyDate 21 February 2018 091407Attachments Runnymede Reg 19 response ESFADOC

Dear Runnymede Planning Policy Team

Please see attached a representation from the Education and Skills Funding Agency on theRunnymede Local Plan consultation

I would be grateful if you could confirm receipt

Best regardsDoug

Douglas McNab MRTPIForward Planning Manager ndash South East

Planning Team Free Schools CapitalEducation and Skills Funding AgencyDepartment for Education 5th floor Sanctuary Buildings 20 Great Smith Street London SW1P 3BT

Email douglasmcnabeducationgovukMobile 07990 082877Web wwwgovukesfa

1895

image1pngOur Ref ESFALocal PlanRunnymede 2018 21st February 2018

Dear SirMadam

Re Runnymede Local Plan

Consultation under Regulation 19 of Town and Country Planning (Local Planning) (England) Regulations 2012

Submission of the Education and Skills Funding Agency

1 The Education and Skills Funding Agency (ESFA) welcomes the opportunity to contribute to the development of planning policy at the local level

2 The ESFA launched on 1st April 2017 bringing together the existing responsibilities of the Education Funding Agency (EFA) and the Skills Funding Agency (SFA) to create a single funding agency accountable for funding education and training for children young people and adults The ESFA are accountable for pound61 billion of funding a year for the education and training sector including support for all state-provided education for 8 million children aged 3 to 16 and 16 million young people aged 16 to 19

3 Under the provisions of the Education Act 2011 and the Academies Act 2010 all new state schools are now academiesfree schools and the ESFA is the delivery body for many of these rather than local education authorities As such we aim to work closely with local authority education departments and planning authorities to meet the demand for new school places and new schools We do this through a variety of means including by supporting the adoption of sound local plan policies site allocations and guidance (all based on robust evidence) that facilitate the delivery of education infrastructure where and when it is needed and maximise developer contributions for schools In this capacity we would like to offer the following comments in response to the proposals outlined in the above consultation document

Comments on the Local Plan

4 As you will be aware the primary focus at this stage of the Local Planrsquos preparation is on the soundness of the plan with regard to it being positively prepared justified effective and consistent with national policy The following detailed comments set out the ESFArsquos view of the planrsquos soundness in respect of education provision

5 The ESFA notes that the local plan will make provision for a minimum of 7413 net additional dwellings over the plan period Development will generally complement the existing settlement pattern focusing the largest amounts of residential growth primarily in Chertsey (1950 homes) Addlestone (936 homes) and Egham (812 homes) A new ldquolocally led garden villagerdquo is also proposed at Longcross providing a further 1718 homes This level of development will put pressure on existing education infrastructure

6 The plan recognises that ldquoIt is important that infrastructure is delivered in a timely manner to ensure that the needs of the occupiers of new development can be met without placing undue burdens on existing infrastructure facilities and servicesrdquo (para 560) The ESFA supports Policy SD6 Infrastructure Provision amp Timing particularly the signposting of the Infrastructure Delivery Plan (IDP) and the need for development to deliver this either on-site or through s106 or CIL financial contributions off-site and the need for development to be phased in line with the provision of important supporting infrastructure

7 The latest version of the IDP states that there is an ongoing programme of primary school expansions this will help to meet the forecast need for 4-6FE of new capacity over the plan period The need for one new build school project is identified a 2FE primary school at the Longcross Garden Village (estimated cost pound99M to pound15M) this is referred to in the site allocation policies (see below) With respect to secondary school places it is anticipated that up to six additional FE could be required in the Borough by 2021 Additional places will be delivered through the new 6FE Runnymede Free School (which opened in temporary accommodation in 2017) development of additional FE within Salesian School (Catholic faith school) and expansion of another school in the Chertsey area (to accommodate demand from generated by the Longcross Garden Village site)

8 It would be useful if the background data informing these projections of need could be clarified particularly the pupil yield factors used and the evidence base supporting this This would help to demonstrate more clearly to the Inspector that the approach to the planning and delivery of education infrastructure has been positively prepared based on a strategy which seeks to meet objectively assessed infrastructure requirements and is justified based on proportionate evidence The ESFA notes that the Runnymede S106 SPG sets out pupil yield figures however this document dates from December 2007 so the figures may be outdated

9 The ESFA supports the Councilrsquos allocation and safeguarding of land for schools as set out in the following policies

middot Policy SD10 Longcross Garden Village - 2FE primary school with preschoolearly years settings

middot Policy SL2 to SL18 ndash series of housing allocation policies that highlight the need to make a financial contribution to early years primary and secondary school infrastructure ldquoeither through S106 or CIL (or its successor)rdquo

Developer Contributions and CIL

10 One of the tests of soundness is that a Local Plan is lsquoeffectiversquo ie the plan should be deliverable over its period In this context and with specific regard to planning for schools there is a need to ensure that education contributions made by developers are sufficient to deliver the additional school places required to meet the increase in demand generated by new developments The ESFA notes that the council has not adopted CIL and that the Planning Obligations SPG sets out how developer contributions to education provision will be secured via section 106 agreements The ESFA supports the Councilrsquos approach to ensure developer contributions address the impacts arising from growth However the ESFA recommends that the Local Plan includes a commitment to revise the Planning Obligations SPG in line with the latest evidence of the boroughrsquos infrastructure needs pupil yields and build costs (including the cost of school expansion new build and SEN provision) Any such review should be prepared in consultation with the county council as local education authority This will help to ensure appropriate rates are levied and the right infrastructure is secured across the borough

11 The ESFA would be particularly interested in responding to any update to the Infrastructure Delivery Plan or review of infrastructure requirements As such please add the ESFA to the database for future CIL consultations

Forward funding

12 In light of the proposed Longcross Garden Village emerging ESFA proposals for forward funding schools as part of large residential developments may be relevant for example if viability becomes an issue The ESFA aims to be able to clarify forward funding options for schools in 2018 We would be happy to meet to discuss this opportunity further once the options have been finalised and ifwhen relevant Any offer of forward funding would seek to maximise developer contributions to education infrastructure provision while supporting delivery of schools where and when they are needed

Conclusion

13 Finally I hope the above comments are helpful in finalising the Runnymede Local Plan with specific regard to the provision of land for new schools

14 Please notify the ESFA when the Local Plan is submitted for examination the Inspectorrsquos report is published and the Local Plan is adopted

15 Please do not hesitate to contact me if you have any queries regarding this response The ESFA looks forward to continuing to work with Runnymede Borough Council to develop a sound Local Plan that will aid in the delivery of new schools

Yours faithfully

DC McNab

Douglas McNab MRTPI

Forward Planning Manager

Tel 07990 082877

Email

douglasmcnabeducationgovuk
Page 46: Runnymede Borough Council, for submissions. My contact details are all in the WORD letter attached. But I will provide my telephone number here too, which …

From MCNAB DouglasTo Planning PolicySubject Runnymede Draft Local Plan consultation - Representation from Education and Skills Funding AgencyDate 21 February 2018 091407Attachments Runnymede Reg 19 response ESFADOC

Dear Runnymede Planning Policy Team

Please see attached a representation from the Education and Skills Funding Agency on theRunnymede Local Plan consultation

I would be grateful if you could confirm receipt

Best regardsDoug

Douglas McNab MRTPIForward Planning Manager ndash South East

Planning Team Free Schools CapitalEducation and Skills Funding AgencyDepartment for Education 5th floor Sanctuary Buildings 20 Great Smith Street London SW1P 3BT

Email douglasmcnabeducationgovukMobile 07990 082877Web wwwgovukesfa

1895

image1pngOur Ref ESFALocal PlanRunnymede 2018 21st February 2018

Dear SirMadam

Re Runnymede Local Plan

Consultation under Regulation 19 of Town and Country Planning (Local Planning) (England) Regulations 2012

Submission of the Education and Skills Funding Agency

1 The Education and Skills Funding Agency (ESFA) welcomes the opportunity to contribute to the development of planning policy at the local level

2 The ESFA launched on 1st April 2017 bringing together the existing responsibilities of the Education Funding Agency (EFA) and the Skills Funding Agency (SFA) to create a single funding agency accountable for funding education and training for children young people and adults The ESFA are accountable for pound61 billion of funding a year for the education and training sector including support for all state-provided education for 8 million children aged 3 to 16 and 16 million young people aged 16 to 19

3 Under the provisions of the Education Act 2011 and the Academies Act 2010 all new state schools are now academiesfree schools and the ESFA is the delivery body for many of these rather than local education authorities As such we aim to work closely with local authority education departments and planning authorities to meet the demand for new school places and new schools We do this through a variety of means including by supporting the adoption of sound local plan policies site allocations and guidance (all based on robust evidence) that facilitate the delivery of education infrastructure where and when it is needed and maximise developer contributions for schools In this capacity we would like to offer the following comments in response to the proposals outlined in the above consultation document

Comments on the Local Plan

4 As you will be aware the primary focus at this stage of the Local Planrsquos preparation is on the soundness of the plan with regard to it being positively prepared justified effective and consistent with national policy The following detailed comments set out the ESFArsquos view of the planrsquos soundness in respect of education provision

5 The ESFA notes that the local plan will make provision for a minimum of 7413 net additional dwellings over the plan period Development will generally complement the existing settlement pattern focusing the largest amounts of residential growth primarily in Chertsey (1950 homes) Addlestone (936 homes) and Egham (812 homes) A new ldquolocally led garden villagerdquo is also proposed at Longcross providing a further 1718 homes This level of development will put pressure on existing education infrastructure

6 The plan recognises that ldquoIt is important that infrastructure is delivered in a timely manner to ensure that the needs of the occupiers of new development can be met without placing undue burdens on existing infrastructure facilities and servicesrdquo (para 560) The ESFA supports Policy SD6 Infrastructure Provision amp Timing particularly the signposting of the Infrastructure Delivery Plan (IDP) and the need for development to deliver this either on-site or through s106 or CIL financial contributions off-site and the need for development to be phased in line with the provision of important supporting infrastructure

7 The latest version of the IDP states that there is an ongoing programme of primary school expansions this will help to meet the forecast need for 4-6FE of new capacity over the plan period The need for one new build school project is identified a 2FE primary school at the Longcross Garden Village (estimated cost pound99M to pound15M) this is referred to in the site allocation policies (see below) With respect to secondary school places it is anticipated that up to six additional FE could be required in the Borough by 2021 Additional places will be delivered through the new 6FE Runnymede Free School (which opened in temporary accommodation in 2017) development of additional FE within Salesian School (Catholic faith school) and expansion of another school in the Chertsey area (to accommodate demand from generated by the Longcross Garden Village site)

8 It would be useful if the background data informing these projections of need could be clarified particularly the pupil yield factors used and the evidence base supporting this This would help to demonstrate more clearly to the Inspector that the approach to the planning and delivery of education infrastructure has been positively prepared based on a strategy which seeks to meet objectively assessed infrastructure requirements and is justified based on proportionate evidence The ESFA notes that the Runnymede S106 SPG sets out pupil yield figures however this document dates from December 2007 so the figures may be outdated

9 The ESFA supports the Councilrsquos allocation and safeguarding of land for schools as set out in the following policies

middot Policy SD10 Longcross Garden Village - 2FE primary school with preschoolearly years settings

middot Policy SL2 to SL18 ndash series of housing allocation policies that highlight the need to make a financial contribution to early years primary and secondary school infrastructure ldquoeither through S106 or CIL (or its successor)rdquo

Developer Contributions and CIL

10 One of the tests of soundness is that a Local Plan is lsquoeffectiversquo ie the plan should be deliverable over its period In this context and with specific regard to planning for schools there is a need to ensure that education contributions made by developers are sufficient to deliver the additional school places required to meet the increase in demand generated by new developments The ESFA notes that the council has not adopted CIL and that the Planning Obligations SPG sets out how developer contributions to education provision will be secured via section 106 agreements The ESFA supports the Councilrsquos approach to ensure developer contributions address the impacts arising from growth However the ESFA recommends that the Local Plan includes a commitment to revise the Planning Obligations SPG in line with the latest evidence of the boroughrsquos infrastructure needs pupil yields and build costs (including the cost of school expansion new build and SEN provision) Any such review should be prepared in consultation with the county council as local education authority This will help to ensure appropriate rates are levied and the right infrastructure is secured across the borough

11 The ESFA would be particularly interested in responding to any update to the Infrastructure Delivery Plan or review of infrastructure requirements As such please add the ESFA to the database for future CIL consultations

Forward funding

12 In light of the proposed Longcross Garden Village emerging ESFA proposals for forward funding schools as part of large residential developments may be relevant for example if viability becomes an issue The ESFA aims to be able to clarify forward funding options for schools in 2018 We would be happy to meet to discuss this opportunity further once the options have been finalised and ifwhen relevant Any offer of forward funding would seek to maximise developer contributions to education infrastructure provision while supporting delivery of schools where and when they are needed

Conclusion

13 Finally I hope the above comments are helpful in finalising the Runnymede Local Plan with specific regard to the provision of land for new schools

14 Please notify the ESFA when the Local Plan is submitted for examination the Inspectorrsquos report is published and the Local Plan is adopted

15 Please do not hesitate to contact me if you have any queries regarding this response The ESFA looks forward to continuing to work with Runnymede Borough Council to develop a sound Local Plan that will aid in the delivery of new schools

Yours faithfully

DC McNab

Douglas McNab MRTPI

Forward Planning Manager

Tel 07990 082877

Email

douglasmcnabeducationgovuk
Page 47: Runnymede Borough Council, for submissions. My contact details are all in the WORD letter attached. But I will provide my telephone number here too, which …

1

Our Ref ESFALocal PlanRunnymede 2018 21st February 2018

Dear SirMadam

Re Runnymede Local Plan

Consultation under Regulation 19 of Town and Country Planning (Local Planning) (England) Regulations 2012

Submission of the Education and Skills Funding Agency

1 The Education and Skills Funding Agency (ESFA) welcomes the opportunity to contribute to the development of planning policy at the local level

2 The ESFA launched on 1st April 2017 bringing together the existing responsibilities of the Education Funding Agency (EFA) and the Skills Funding Agency (SFA) to create a single funding agency accountable for funding education and training for children young people and adults The ESFA are accountable for pound61 billion of funding a year for the education and training sector including support for all state-provided education for 8 million children aged 3 to 16 and 16 million young people aged 16 to 19

3 Under the provisions of the Education Act 2011 and the Academies Act 2010 all new state schools are now academiesfree schools and the ESFA is the delivery body for many of these rather than local education authorities As such we aim to work closely with local authority education departments and planning authorities to meet the demand for new school places and new schools We do this through a variety of means including by supporting the adoption of sound local plan policies site allocations and guidance (all based on robust evidence) that facilitate the delivery of education infrastructure where and when it is needed and maximise developer contributions for schools In this capacity we would like to offer the following comments in response to the proposals outlined in the above consultation document

Comments on the Local Plan

4 As you will be aware the primary focus at this stage of the Local Planrsquos preparation is on the soundness of the plan with regard to it being positively prepared justified effective and consistent with national policy The following detailed comments set out the ESFArsquos view of the planrsquos soundness in respect of education provision

5 The ESFA notes that the local plan will make provision for a minimum of 7413 net additional dwellings over the plan period Development will generally complement the existing settlement pattern focusing the largest amounts of residential growth primarily in Chertsey (1950 homes) Addlestone (936 homes)

Education and Skills Funding Agency Department for Education Sanctuary Buildings Great Smith Street London SW1P 3BT Tel 0207 340 7000 wwwgovukesfa

2

and Egham (812 homes) A new ldquolocally led garden villagerdquo is also proposed at Longcross providing a further 1718 homes This level of development will put pressure on existing education infrastructure

6 The plan recognises that ldquoIt is important that infrastructure is delivered in a timely manner to ensure that the needs of the occupiers of new development can be met without placing undue burdens on existing infrastructure facilities and servicesrdquo (para 560) The ESFA supports Policy SD6 Infrastructure Provision amp Timing particularly the signposting of the Infrastructure Delivery Plan (IDP) and the need for development to deliver this either on-site or through s106 or CIL financial contributions off-site and the need for development to be phased in line with the provision of important supporting infrastructure

7 The latest version of the IDP states that there is an ongoing programme of primary school expansions this will help to meet the forecast need for 4-6FE of new capacity over the plan period The need for one new build school project is identified a 2FE primary school at the Longcross Garden Village (estimated cost pound99M to pound15M) this is referred to in the site allocation policies (see below) With respect to secondary school places it is anticipated that up to six additional FE could be required in the Borough by 2021 Additional places will be delivered through the new 6FE Runnymede Free School (which opened in temporary accommodation in 2017) development of additional FE within Salesian School (Catholic faith school) and expansion of another school in the Chertsey area (to accommodate demand from generated by the Longcross Garden Village site)

8 It would be useful if the background data informing these projections of need could be clarified particularly the pupil yield factors used and the evidence base supporting this This would help to demonstrate more clearly to the Inspector that the approach to the planning and delivery of education infrastructure has been positively prepared based on a strategy which seeks to meet objectively assessed infrastructure requirements and is justified based on proportionate evidence The ESFA notes that the Runnymede S106 SPG sets out pupil yield figures however this document dates from December 2007 so the figures may be outdated

9 The ESFA supports the Councilrsquos allocation and safeguarding of land for schools as set out in the following policies

bull Policy SD10 Longcross Garden Village - 2FE primary school with preschoolearly years settings

bull Policy SL2 to SL18 ndash series of housing allocation policies that highlight the need to make a financial contribution to early years primary and secondary school infrastructure ldquoeither through S106 or CIL (or its successor)rdquo

Developer Contributions and CIL

10 One of the tests of soundness is that a Local Plan is lsquoeffectiversquo ie the plan should be deliverable over its period In this context and with specific regard to planning for schools there is a need to ensure that education contributions made by developers are sufficient to deliver the additional school places required to meet the increase in demand generated by new developments The ESFA notes that the council has not adopted CIL and that the Planning Obligations SPG sets out how developer contributions to education provision will be secured via section 106 agreements The ESFA supports the Councilrsquos approach to

3

ensure developer contributions address the impacts arising from growth However the ESFA recommends that the Local Plan includes a commitment to revise the Planning Obligations SPG in line with the latest evidence of the boroughrsquos infrastructure needs pupil yields and build costs (including the cost of school expansion new build and SEN provision) Any such review should be prepared in consultation with the county council as local education authority This will help to ensure appropriate rates are levied and the right infrastructure is secured across the borough

11 The ESFA would be particularly interested in responding to any update to the Infrastructure Delivery Plan or review of infrastructure requirements As such please add the ESFA to the database for future CIL consultations

Forward funding

12 In light of the proposed Longcross Garden Village emerging ESFA proposals for forward funding schools as part of large residential developments may be relevant for example if viability becomes an issue The ESFA aims to be able to clarify forward funding options for schools in 2018 We would be happy to meet to discuss this opportunity further once the options have been finalised and ifwhen relevant Any offer of forward funding would seek to maximise developer contributions to education infrastructure provision while supporting delivery of schools where and when they are needed

Conclusion

13 Finally I hope the above comments are helpful in finalising the Runnymede Local Plan with specific regard to the provision of land for new schools

14 Please notify the ESFA when the Local Plan is submitted for examination the Inspectorrsquos report is published and the Local Plan is adopted

15 Please do not hesitate to contact me if you have any queries regarding this response The ESFA looks forward to continuing to work with Runnymede Borough Council to develop a sound Local Plan that will aid in the delivery of new schools

Yours faithfully

DC McNab

Douglas McNab MRTPI Forward Planning Manager Tel 07990 082877 Email douglasmcnabeducationgovuk Web wwwgovukesfa

FromTo Planning PolicySubject Runnymede Local Plan 2030 Letter of RepresentationDate 22 February 2018 085538

Dear Sir

I wish to raise my concerns in reference to the above plan-

Virginia Water Ward Knowle Hill and Callow Hill

I read with interest that you have ear marked two sites in the above area for housingdevelopment on Green Belt land Both sites would be harmful by definition by being builton Green Belt and I see no special circumstances for these sites to developed for housingwhen other sites in Virginia Water and the borough exist for instance Hurst Lane This siteis already a troubled site with many enforcement issues and unlawful development byexisting land owners (Contrary to Saved Policy GB1 of the Runnymede Borough LocalPlan Section Alteration 2001 and the guidance in the NPPF)

I can see no mention of any infrastructure or highways comments that the current roadscan actually cope with all these additional housing developments or the additional servicesfor the substantial increase in population In particular Stroude Road and TrumpsgreenRoad are already very busy with difficult junctions and single track under the railwaybridge both roads already have significant heavy traffic flow and speed limits not adheredto which is well documented under various previous rejected planning applications on theRBC planning portal for the Virginia Water ward

There appears to be no provision for the mitigation of the impact of the proposedresidential developments on the Thames basin Heaths Special Protection Area This iscontrary to the conservation of habitats and species regulations 2010 and EuropeanDirectives 9243 EEC and 79409EEC and in addition the councils own adoptedSupplementary Planning Guidance on the Thames Basin Heaths Special Protection AreaNovember 2009

In addition it is very unlikely that in reality any affordable housing will be created so thesedevelopments would not in any way contribute to the UK housing crisis

In conclusion I deem this plan unsafe and other opportunities should be sought withcollaboration with other local councils in the Surrey area

Yours faithfully

1898

Linda Barron

345 Stroude Road

Virginia Water

Surrey

GU25 4DB

FromTo Planning PolicySubject Draft Local Plan ConsultationDate 21 February 2018 114703

FromMark Darlow18 The GroveAddlestoneSurreyKT15 1RB

As a resident of Addlestone for over 30 years and Surrey for almost 60 I feel I am well placed to comment onyour current local plan consultation As such I object in the strongest possible terms to your current proposalsto concrete over large areas of green belt land

Living as close as we do the the M25 and Heathrow it could and SHOULD be argued that we need MOREgreen belt land not less to counteract the high levels of local pollution Urbanising the few remaining greenareas in the Addlestone area is NOT the answer to the housing crisis Spreading the load around the countryrather than cram housing into the South-East is Pollution in the area is already too high and its impact is feltfrom children to the elderly with asthma at an all time high putting an ever increasing burden on ouroverstretched health service

Your proposals to build almost 9000 new housing units in this area are in truth ridiculous Addlestone hasalready contributed large numbers of dwellings in Franklands Drive Aviator Park and in the new precinct areain addition to the significant infill in the area Infrastructure is at breaking point Local doctors are impossibleto book appointments for in under two weeks I have now suffered irreversible nerve damage because havingbeen recommended to see the doctor immediately by my chiropractor and the local pharmacist I was offered anappointment in March a wait of over two weeks Where will the 9000 to potential 30000 new residents find adoctor a dentist school places or hospital bed A service already in crisis The area also has more than its fairshare of gypsy sites notably Lyne Shepperton and Chertsey Fly tipping at an all time high and not all butmuch of which can be laid at their door

The local road network is stretched to breaking point My journey to work has doubled in time over the last 30years a fact highlighted by the recent A320 traffic study which found traffic congestion is at serious levels andthats before 9000 new housing units The Ottershaw area all entries to Addlestone and Weybridge arestationary every rush hour and if there is an accident on the M25 you might as well set up camp Ive parked asclose to home as I could get and walked on three occasions in recent years Addlestone is regularly at astandstill which will only get worse with the current developments let alone 9000 new properties Theadditional school places required will put even more pressure on the education system plus the increased trafficwill add further to the congestion

So to summarise

1 Destroying green belt land and sites is both short sighted and goes against the principals of good planning Itis greed for the sake of greed political dogma from short sighted politicians The green belt is Londons lungsand decimating our remaining green spaces affects the health and wellbeing of all

2 The increased traffic burden will turn Addlestone and the surrounding areas into a no go zone in peak hoursI assume most in planning drive cars and MUST see that any increase will be intolerable The additionalincrease in noise and pollution is unacceptable for the health and wellbeing of existing residents We alreadyhave unacceptable levels of noise with Heathrow and a concrete M25 which can be heard from miles around anadditional 9000 dwellings and gypsy camps will only dramatically increase this burden

3 The affect on other infrastructure is obvious to all Addlestone Health Centre barely manages now with a 2 -4 week wait for an appointment quite normal A amp E waiting times at St Peters already breach governmenttargets so what will 9000 more dwellings do And thats not to mention dentists where finding a NHS servicealmost impossible school places in already overstretched schools social services and accommodation for theelderly and public parking Pressure on water and electricity supply will severely impact on what is already a

1899

poor service Power cuts are not unusual and water pressure is dire already so 9000 new units will only worsenthe situation

4 Bulldozing Fairoaks Airport removes a valuable resource as its the only small airport in the area Fairoaksalso supports a significant number of jobs which are important to the local economy Runnymede should becreating permanent jobs such as those at Fairoaks rather than destroying them Yes the building works willcreate jobs in the short term but they are not permanent and once those that are here are gone there is nowhereleft to support them Short term gain will lead to long term pain Stupid and shortsighted

5 Finally the impact on the environment We dont have many green places and this area isnt the mostbeautiful but it does have areas where you can walk and breath in relatively clean air that supports a goodvariety of wildlife and its important to protect whats left not to turn it into a concrete jungle More concretewill lead to more water run-off and increase the flooding weve seen in recent years The impact on theenvironment and those that live here CANNOT be underestimated

As representatives of the area you in RBC have a duty of your care to its residents This plan abuses that dutyof care and the trust placed in you by significantly worsening the health and wellbeing of existing residents Iam not against building but with recent major developments we have more than done our part Its time to stopand see reason before its too late and you decimate the local area forever

Regards

Mark Darlow

  • 1895 Douglas McNab - Education and Skills Funding Agency_Redactedpdf
    • ADPB347tmp
      • Our Ref ESFALocal PlanRunnymede 2018 21st February 2018
          • 1893 Mr Christian Leigh on behalf of Mr Gary Humphries_Redactedpdf
            • Runnymede Local Plan 2030 - consultation response
            • Runnymede LP Response - EE15
              • 1891 Dr Brian Pickett_Redactedpdf
                • Runnymede 2030 Local Plan - submission of views
                • Ottershaw development Objection letter February 2018
                  • 1886 Mrs Caroline Craven_Redactedpdf
                    • Representation for Local Plan
                    • Representation_form_for_Regulation_19_Caroline_Craven
                      • 1885 Stephen R Miles_Redactedpdf
                        • FW_ Objection to Runnymede Local Plan 2030
                        • Stephen R Miles Objection to Runnymede Local Plan 2030 at Feb 2018 Version 2
Page 48: Runnymede Borough Council, for submissions. My contact details are all in the WORD letter attached. But I will provide my telephone number here too, which …

2

and Egham (812 homes) A new ldquolocally led garden villagerdquo is also proposed at Longcross providing a further 1718 homes This level of development will put pressure on existing education infrastructure

6 The plan recognises that ldquoIt is important that infrastructure is delivered in a timely manner to ensure that the needs of the occupiers of new development can be met without placing undue burdens on existing infrastructure facilities and servicesrdquo (para 560) The ESFA supports Policy SD6 Infrastructure Provision amp Timing particularly the signposting of the Infrastructure Delivery Plan (IDP) and the need for development to deliver this either on-site or through s106 or CIL financial contributions off-site and the need for development to be phased in line with the provision of important supporting infrastructure

7 The latest version of the IDP states that there is an ongoing programme of primary school expansions this will help to meet the forecast need for 4-6FE of new capacity over the plan period The need for one new build school project is identified a 2FE primary school at the Longcross Garden Village (estimated cost pound99M to pound15M) this is referred to in the site allocation policies (see below) With respect to secondary school places it is anticipated that up to six additional FE could be required in the Borough by 2021 Additional places will be delivered through the new 6FE Runnymede Free School (which opened in temporary accommodation in 2017) development of additional FE within Salesian School (Catholic faith school) and expansion of another school in the Chertsey area (to accommodate demand from generated by the Longcross Garden Village site)

8 It would be useful if the background data informing these projections of need could be clarified particularly the pupil yield factors used and the evidence base supporting this This would help to demonstrate more clearly to the Inspector that the approach to the planning and delivery of education infrastructure has been positively prepared based on a strategy which seeks to meet objectively assessed infrastructure requirements and is justified based on proportionate evidence The ESFA notes that the Runnymede S106 SPG sets out pupil yield figures however this document dates from December 2007 so the figures may be outdated

9 The ESFA supports the Councilrsquos allocation and safeguarding of land for schools as set out in the following policies

bull Policy SD10 Longcross Garden Village - 2FE primary school with preschoolearly years settings

bull Policy SL2 to SL18 ndash series of housing allocation policies that highlight the need to make a financial contribution to early years primary and secondary school infrastructure ldquoeither through S106 or CIL (or its successor)rdquo

Developer Contributions and CIL

10 One of the tests of soundness is that a Local Plan is lsquoeffectiversquo ie the plan should be deliverable over its period In this context and with specific regard to planning for schools there is a need to ensure that education contributions made by developers are sufficient to deliver the additional school places required to meet the increase in demand generated by new developments The ESFA notes that the council has not adopted CIL and that the Planning Obligations SPG sets out how developer contributions to education provision will be secured via section 106 agreements The ESFA supports the Councilrsquos approach to

3

ensure developer contributions address the impacts arising from growth However the ESFA recommends that the Local Plan includes a commitment to revise the Planning Obligations SPG in line with the latest evidence of the boroughrsquos infrastructure needs pupil yields and build costs (including the cost of school expansion new build and SEN provision) Any such review should be prepared in consultation with the county council as local education authority This will help to ensure appropriate rates are levied and the right infrastructure is secured across the borough

11 The ESFA would be particularly interested in responding to any update to the Infrastructure Delivery Plan or review of infrastructure requirements As such please add the ESFA to the database for future CIL consultations

Forward funding

12 In light of the proposed Longcross Garden Village emerging ESFA proposals for forward funding schools as part of large residential developments may be relevant for example if viability becomes an issue The ESFA aims to be able to clarify forward funding options for schools in 2018 We would be happy to meet to discuss this opportunity further once the options have been finalised and ifwhen relevant Any offer of forward funding would seek to maximise developer contributions to education infrastructure provision while supporting delivery of schools where and when they are needed

Conclusion

13 Finally I hope the above comments are helpful in finalising the Runnymede Local Plan with specific regard to the provision of land for new schools

14 Please notify the ESFA when the Local Plan is submitted for examination the Inspectorrsquos report is published and the Local Plan is adopted

15 Please do not hesitate to contact me if you have any queries regarding this response The ESFA looks forward to continuing to work with Runnymede Borough Council to develop a sound Local Plan that will aid in the delivery of new schools

Yours faithfully

DC McNab

Douglas McNab MRTPI Forward Planning Manager Tel 07990 082877 Email douglasmcnabeducationgovuk Web wwwgovukesfa

FromTo Planning PolicySubject Runnymede Local Plan 2030 Letter of RepresentationDate 22 February 2018 085538

Dear Sir

I wish to raise my concerns in reference to the above plan-

Virginia Water Ward Knowle Hill and Callow Hill

I read with interest that you have ear marked two sites in the above area for housingdevelopment on Green Belt land Both sites would be harmful by definition by being builton Green Belt and I see no special circumstances for these sites to developed for housingwhen other sites in Virginia Water and the borough exist for instance Hurst Lane This siteis already a troubled site with many enforcement issues and unlawful development byexisting land owners (Contrary to Saved Policy GB1 of the Runnymede Borough LocalPlan Section Alteration 2001 and the guidance in the NPPF)

I can see no mention of any infrastructure or highways comments that the current roadscan actually cope with all these additional housing developments or the additional servicesfor the substantial increase in population In particular Stroude Road and TrumpsgreenRoad are already very busy with difficult junctions and single track under the railwaybridge both roads already have significant heavy traffic flow and speed limits not adheredto which is well documented under various previous rejected planning applications on theRBC planning portal for the Virginia Water ward

There appears to be no provision for the mitigation of the impact of the proposedresidential developments on the Thames basin Heaths Special Protection Area This iscontrary to the conservation of habitats and species regulations 2010 and EuropeanDirectives 9243 EEC and 79409EEC and in addition the councils own adoptedSupplementary Planning Guidance on the Thames Basin Heaths Special Protection AreaNovember 2009

In addition it is very unlikely that in reality any affordable housing will be created so thesedevelopments would not in any way contribute to the UK housing crisis

In conclusion I deem this plan unsafe and other opportunities should be sought withcollaboration with other local councils in the Surrey area

Yours faithfully

1898

Linda Barron

345 Stroude Road

Virginia Water

Surrey

GU25 4DB

FromTo Planning PolicySubject Draft Local Plan ConsultationDate 21 February 2018 114703

FromMark Darlow18 The GroveAddlestoneSurreyKT15 1RB

As a resident of Addlestone for over 30 years and Surrey for almost 60 I feel I am well placed to comment onyour current local plan consultation As such I object in the strongest possible terms to your current proposalsto concrete over large areas of green belt land

Living as close as we do the the M25 and Heathrow it could and SHOULD be argued that we need MOREgreen belt land not less to counteract the high levels of local pollution Urbanising the few remaining greenareas in the Addlestone area is NOT the answer to the housing crisis Spreading the load around the countryrather than cram housing into the South-East is Pollution in the area is already too high and its impact is feltfrom children to the elderly with asthma at an all time high putting an ever increasing burden on ouroverstretched health service

Your proposals to build almost 9000 new housing units in this area are in truth ridiculous Addlestone hasalready contributed large numbers of dwellings in Franklands Drive Aviator Park and in the new precinct areain addition to the significant infill in the area Infrastructure is at breaking point Local doctors are impossibleto book appointments for in under two weeks I have now suffered irreversible nerve damage because havingbeen recommended to see the doctor immediately by my chiropractor and the local pharmacist I was offered anappointment in March a wait of over two weeks Where will the 9000 to potential 30000 new residents find adoctor a dentist school places or hospital bed A service already in crisis The area also has more than its fairshare of gypsy sites notably Lyne Shepperton and Chertsey Fly tipping at an all time high and not all butmuch of which can be laid at their door

The local road network is stretched to breaking point My journey to work has doubled in time over the last 30years a fact highlighted by the recent A320 traffic study which found traffic congestion is at serious levels andthats before 9000 new housing units The Ottershaw area all entries to Addlestone and Weybridge arestationary every rush hour and if there is an accident on the M25 you might as well set up camp Ive parked asclose to home as I could get and walked on three occasions in recent years Addlestone is regularly at astandstill which will only get worse with the current developments let alone 9000 new properties Theadditional school places required will put even more pressure on the education system plus the increased trafficwill add further to the congestion

So to summarise

1 Destroying green belt land and sites is both short sighted and goes against the principals of good planning Itis greed for the sake of greed political dogma from short sighted politicians The green belt is Londons lungsand decimating our remaining green spaces affects the health and wellbeing of all

2 The increased traffic burden will turn Addlestone and the surrounding areas into a no go zone in peak hoursI assume most in planning drive cars and MUST see that any increase will be intolerable The additionalincrease in noise and pollution is unacceptable for the health and wellbeing of existing residents We alreadyhave unacceptable levels of noise with Heathrow and a concrete M25 which can be heard from miles around anadditional 9000 dwellings and gypsy camps will only dramatically increase this burden

3 The affect on other infrastructure is obvious to all Addlestone Health Centre barely manages now with a 2 -4 week wait for an appointment quite normal A amp E waiting times at St Peters already breach governmenttargets so what will 9000 more dwellings do And thats not to mention dentists where finding a NHS servicealmost impossible school places in already overstretched schools social services and accommodation for theelderly and public parking Pressure on water and electricity supply will severely impact on what is already a

1899

poor service Power cuts are not unusual and water pressure is dire already so 9000 new units will only worsenthe situation

4 Bulldozing Fairoaks Airport removes a valuable resource as its the only small airport in the area Fairoaksalso supports a significant number of jobs which are important to the local economy Runnymede should becreating permanent jobs such as those at Fairoaks rather than destroying them Yes the building works willcreate jobs in the short term but they are not permanent and once those that are here are gone there is nowhereleft to support them Short term gain will lead to long term pain Stupid and shortsighted

5 Finally the impact on the environment We dont have many green places and this area isnt the mostbeautiful but it does have areas where you can walk and breath in relatively clean air that supports a goodvariety of wildlife and its important to protect whats left not to turn it into a concrete jungle More concretewill lead to more water run-off and increase the flooding weve seen in recent years The impact on theenvironment and those that live here CANNOT be underestimated

As representatives of the area you in RBC have a duty of your care to its residents This plan abuses that dutyof care and the trust placed in you by significantly worsening the health and wellbeing of existing residents Iam not against building but with recent major developments we have more than done our part Its time to stopand see reason before its too late and you decimate the local area forever

Regards

Mark Darlow

  • 1895 Douglas McNab - Education and Skills Funding Agency_Redactedpdf
    • ADPB347tmp
      • Our Ref ESFALocal PlanRunnymede 2018 21st February 2018
          • 1893 Mr Christian Leigh on behalf of Mr Gary Humphries_Redactedpdf
            • Runnymede Local Plan 2030 - consultation response
            • Runnymede LP Response - EE15
              • 1891 Dr Brian Pickett_Redactedpdf
                • Runnymede 2030 Local Plan - submission of views
                • Ottershaw development Objection letter February 2018
                  • 1886 Mrs Caroline Craven_Redactedpdf
                    • Representation for Local Plan
                    • Representation_form_for_Regulation_19_Caroline_Craven
                      • 1885 Stephen R Miles_Redactedpdf
                        • FW_ Objection to Runnymede Local Plan 2030
                        • Stephen R Miles Objection to Runnymede Local Plan 2030 at Feb 2018 Version 2
Page 49: Runnymede Borough Council, for submissions. My contact details are all in the WORD letter attached. But I will provide my telephone number here too, which …

3

ensure developer contributions address the impacts arising from growth However the ESFA recommends that the Local Plan includes a commitment to revise the Planning Obligations SPG in line with the latest evidence of the boroughrsquos infrastructure needs pupil yields and build costs (including the cost of school expansion new build and SEN provision) Any such review should be prepared in consultation with the county council as local education authority This will help to ensure appropriate rates are levied and the right infrastructure is secured across the borough

11 The ESFA would be particularly interested in responding to any update to the Infrastructure Delivery Plan or review of infrastructure requirements As such please add the ESFA to the database for future CIL consultations

Forward funding

12 In light of the proposed Longcross Garden Village emerging ESFA proposals for forward funding schools as part of large residential developments may be relevant for example if viability becomes an issue The ESFA aims to be able to clarify forward funding options for schools in 2018 We would be happy to meet to discuss this opportunity further once the options have been finalised and ifwhen relevant Any offer of forward funding would seek to maximise developer contributions to education infrastructure provision while supporting delivery of schools where and when they are needed

Conclusion

13 Finally I hope the above comments are helpful in finalising the Runnymede Local Plan with specific regard to the provision of land for new schools

14 Please notify the ESFA when the Local Plan is submitted for examination the Inspectorrsquos report is published and the Local Plan is adopted

15 Please do not hesitate to contact me if you have any queries regarding this response The ESFA looks forward to continuing to work with Runnymede Borough Council to develop a sound Local Plan that will aid in the delivery of new schools

Yours faithfully

DC McNab

Douglas McNab MRTPI Forward Planning Manager Tel 07990 082877 Email douglasmcnabeducationgovuk Web wwwgovukesfa

FromTo Planning PolicySubject Runnymede Local Plan 2030 Letter of RepresentationDate 22 February 2018 085538

Dear Sir

I wish to raise my concerns in reference to the above plan-

Virginia Water Ward Knowle Hill and Callow Hill

I read with interest that you have ear marked two sites in the above area for housingdevelopment on Green Belt land Both sites would be harmful by definition by being builton Green Belt and I see no special circumstances for these sites to developed for housingwhen other sites in Virginia Water and the borough exist for instance Hurst Lane This siteis already a troubled site with many enforcement issues and unlawful development byexisting land owners (Contrary to Saved Policy GB1 of the Runnymede Borough LocalPlan Section Alteration 2001 and the guidance in the NPPF)

I can see no mention of any infrastructure or highways comments that the current roadscan actually cope with all these additional housing developments or the additional servicesfor the substantial increase in population In particular Stroude Road and TrumpsgreenRoad are already very busy with difficult junctions and single track under the railwaybridge both roads already have significant heavy traffic flow and speed limits not adheredto which is well documented under various previous rejected planning applications on theRBC planning portal for the Virginia Water ward

There appears to be no provision for the mitigation of the impact of the proposedresidential developments on the Thames basin Heaths Special Protection Area This iscontrary to the conservation of habitats and species regulations 2010 and EuropeanDirectives 9243 EEC and 79409EEC and in addition the councils own adoptedSupplementary Planning Guidance on the Thames Basin Heaths Special Protection AreaNovember 2009

In addition it is very unlikely that in reality any affordable housing will be created so thesedevelopments would not in any way contribute to the UK housing crisis

In conclusion I deem this plan unsafe and other opportunities should be sought withcollaboration with other local councils in the Surrey area

Yours faithfully

1898

Linda Barron

345 Stroude Road

Virginia Water

Surrey

GU25 4DB

FromTo Planning PolicySubject Draft Local Plan ConsultationDate 21 February 2018 114703

FromMark Darlow18 The GroveAddlestoneSurreyKT15 1RB

As a resident of Addlestone for over 30 years and Surrey for almost 60 I feel I am well placed to comment onyour current local plan consultation As such I object in the strongest possible terms to your current proposalsto concrete over large areas of green belt land

Living as close as we do the the M25 and Heathrow it could and SHOULD be argued that we need MOREgreen belt land not less to counteract the high levels of local pollution Urbanising the few remaining greenareas in the Addlestone area is NOT the answer to the housing crisis Spreading the load around the countryrather than cram housing into the South-East is Pollution in the area is already too high and its impact is feltfrom children to the elderly with asthma at an all time high putting an ever increasing burden on ouroverstretched health service

Your proposals to build almost 9000 new housing units in this area are in truth ridiculous Addlestone hasalready contributed large numbers of dwellings in Franklands Drive Aviator Park and in the new precinct areain addition to the significant infill in the area Infrastructure is at breaking point Local doctors are impossibleto book appointments for in under two weeks I have now suffered irreversible nerve damage because havingbeen recommended to see the doctor immediately by my chiropractor and the local pharmacist I was offered anappointment in March a wait of over two weeks Where will the 9000 to potential 30000 new residents find adoctor a dentist school places or hospital bed A service already in crisis The area also has more than its fairshare of gypsy sites notably Lyne Shepperton and Chertsey Fly tipping at an all time high and not all butmuch of which can be laid at their door

The local road network is stretched to breaking point My journey to work has doubled in time over the last 30years a fact highlighted by the recent A320 traffic study which found traffic congestion is at serious levels andthats before 9000 new housing units The Ottershaw area all entries to Addlestone and Weybridge arestationary every rush hour and if there is an accident on the M25 you might as well set up camp Ive parked asclose to home as I could get and walked on three occasions in recent years Addlestone is regularly at astandstill which will only get worse with the current developments let alone 9000 new properties Theadditional school places required will put even more pressure on the education system plus the increased trafficwill add further to the congestion

So to summarise

1 Destroying green belt land and sites is both short sighted and goes against the principals of good planning Itis greed for the sake of greed political dogma from short sighted politicians The green belt is Londons lungsand decimating our remaining green spaces affects the health and wellbeing of all

2 The increased traffic burden will turn Addlestone and the surrounding areas into a no go zone in peak hoursI assume most in planning drive cars and MUST see that any increase will be intolerable The additionalincrease in noise and pollution is unacceptable for the health and wellbeing of existing residents We alreadyhave unacceptable levels of noise with Heathrow and a concrete M25 which can be heard from miles around anadditional 9000 dwellings and gypsy camps will only dramatically increase this burden

3 The affect on other infrastructure is obvious to all Addlestone Health Centre barely manages now with a 2 -4 week wait for an appointment quite normal A amp E waiting times at St Peters already breach governmenttargets so what will 9000 more dwellings do And thats not to mention dentists where finding a NHS servicealmost impossible school places in already overstretched schools social services and accommodation for theelderly and public parking Pressure on water and electricity supply will severely impact on what is already a

1899

poor service Power cuts are not unusual and water pressure is dire already so 9000 new units will only worsenthe situation

4 Bulldozing Fairoaks Airport removes a valuable resource as its the only small airport in the area Fairoaksalso supports a significant number of jobs which are important to the local economy Runnymede should becreating permanent jobs such as those at Fairoaks rather than destroying them Yes the building works willcreate jobs in the short term but they are not permanent and once those that are here are gone there is nowhereleft to support them Short term gain will lead to long term pain Stupid and shortsighted

5 Finally the impact on the environment We dont have many green places and this area isnt the mostbeautiful but it does have areas where you can walk and breath in relatively clean air that supports a goodvariety of wildlife and its important to protect whats left not to turn it into a concrete jungle More concretewill lead to more water run-off and increase the flooding weve seen in recent years The impact on theenvironment and those that live here CANNOT be underestimated

As representatives of the area you in RBC have a duty of your care to its residents This plan abuses that dutyof care and the trust placed in you by significantly worsening the health and wellbeing of existing residents Iam not against building but with recent major developments we have more than done our part Its time to stopand see reason before its too late and you decimate the local area forever

Regards

Mark Darlow

  • 1895 Douglas McNab - Education and Skills Funding Agency_Redactedpdf
    • ADPB347tmp
      • Our Ref ESFALocal PlanRunnymede 2018 21st February 2018
          • 1893 Mr Christian Leigh on behalf of Mr Gary Humphries_Redactedpdf
            • Runnymede Local Plan 2030 - consultation response
            • Runnymede LP Response - EE15
              • 1891 Dr Brian Pickett_Redactedpdf
                • Runnymede 2030 Local Plan - submission of views
                • Ottershaw development Objection letter February 2018
                  • 1886 Mrs Caroline Craven_Redactedpdf
                    • Representation for Local Plan
                    • Representation_form_for_Regulation_19_Caroline_Craven
                      • 1885 Stephen R Miles_Redactedpdf
                        • FW_ Objection to Runnymede Local Plan 2030
                        • Stephen R Miles Objection to Runnymede Local Plan 2030 at Feb 2018 Version 2
Page 50: Runnymede Borough Council, for submissions. My contact details are all in the WORD letter attached. But I will provide my telephone number here too, which …

FromTo Planning PolicySubject Runnymede Local Plan 2030 Letter of RepresentationDate 22 February 2018 085538

Dear Sir

I wish to raise my concerns in reference to the above plan-

Virginia Water Ward Knowle Hill and Callow Hill

I read with interest that you have ear marked two sites in the above area for housingdevelopment on Green Belt land Both sites would be harmful by definition by being builton Green Belt and I see no special circumstances for these sites to developed for housingwhen other sites in Virginia Water and the borough exist for instance Hurst Lane This siteis already a troubled site with many enforcement issues and unlawful development byexisting land owners (Contrary to Saved Policy GB1 of the Runnymede Borough LocalPlan Section Alteration 2001 and the guidance in the NPPF)

I can see no mention of any infrastructure or highways comments that the current roadscan actually cope with all these additional housing developments or the additional servicesfor the substantial increase in population In particular Stroude Road and TrumpsgreenRoad are already very busy with difficult junctions and single track under the railwaybridge both roads already have significant heavy traffic flow and speed limits not adheredto which is well documented under various previous rejected planning applications on theRBC planning portal for the Virginia Water ward

There appears to be no provision for the mitigation of the impact of the proposedresidential developments on the Thames basin Heaths Special Protection Area This iscontrary to the conservation of habitats and species regulations 2010 and EuropeanDirectives 9243 EEC and 79409EEC and in addition the councils own adoptedSupplementary Planning Guidance on the Thames Basin Heaths Special Protection AreaNovember 2009

In addition it is very unlikely that in reality any affordable housing will be created so thesedevelopments would not in any way contribute to the UK housing crisis

In conclusion I deem this plan unsafe and other opportunities should be sought withcollaboration with other local councils in the Surrey area

Yours faithfully

1898

Linda Barron

345 Stroude Road

Virginia Water

Surrey

GU25 4DB

FromTo Planning PolicySubject Draft Local Plan ConsultationDate 21 February 2018 114703

FromMark Darlow18 The GroveAddlestoneSurreyKT15 1RB

As a resident of Addlestone for over 30 years and Surrey for almost 60 I feel I am well placed to comment onyour current local plan consultation As such I object in the strongest possible terms to your current proposalsto concrete over large areas of green belt land

Living as close as we do the the M25 and Heathrow it could and SHOULD be argued that we need MOREgreen belt land not less to counteract the high levels of local pollution Urbanising the few remaining greenareas in the Addlestone area is NOT the answer to the housing crisis Spreading the load around the countryrather than cram housing into the South-East is Pollution in the area is already too high and its impact is feltfrom children to the elderly with asthma at an all time high putting an ever increasing burden on ouroverstretched health service

Your proposals to build almost 9000 new housing units in this area are in truth ridiculous Addlestone hasalready contributed large numbers of dwellings in Franklands Drive Aviator Park and in the new precinct areain addition to the significant infill in the area Infrastructure is at breaking point Local doctors are impossibleto book appointments for in under two weeks I have now suffered irreversible nerve damage because havingbeen recommended to see the doctor immediately by my chiropractor and the local pharmacist I was offered anappointment in March a wait of over two weeks Where will the 9000 to potential 30000 new residents find adoctor a dentist school places or hospital bed A service already in crisis The area also has more than its fairshare of gypsy sites notably Lyne Shepperton and Chertsey Fly tipping at an all time high and not all butmuch of which can be laid at their door

The local road network is stretched to breaking point My journey to work has doubled in time over the last 30years a fact highlighted by the recent A320 traffic study which found traffic congestion is at serious levels andthats before 9000 new housing units The Ottershaw area all entries to Addlestone and Weybridge arestationary every rush hour and if there is an accident on the M25 you might as well set up camp Ive parked asclose to home as I could get and walked on three occasions in recent years Addlestone is regularly at astandstill which will only get worse with the current developments let alone 9000 new properties Theadditional school places required will put even more pressure on the education system plus the increased trafficwill add further to the congestion

So to summarise

1 Destroying green belt land and sites is both short sighted and goes against the principals of good planning Itis greed for the sake of greed political dogma from short sighted politicians The green belt is Londons lungsand decimating our remaining green spaces affects the health and wellbeing of all

2 The increased traffic burden will turn Addlestone and the surrounding areas into a no go zone in peak hoursI assume most in planning drive cars and MUST see that any increase will be intolerable The additionalincrease in noise and pollution is unacceptable for the health and wellbeing of existing residents We alreadyhave unacceptable levels of noise with Heathrow and a concrete M25 which can be heard from miles around anadditional 9000 dwellings and gypsy camps will only dramatically increase this burden

3 The affect on other infrastructure is obvious to all Addlestone Health Centre barely manages now with a 2 -4 week wait for an appointment quite normal A amp E waiting times at St Peters already breach governmenttargets so what will 9000 more dwellings do And thats not to mention dentists where finding a NHS servicealmost impossible school places in already overstretched schools social services and accommodation for theelderly and public parking Pressure on water and electricity supply will severely impact on what is already a

1899

poor service Power cuts are not unusual and water pressure is dire already so 9000 new units will only worsenthe situation

4 Bulldozing Fairoaks Airport removes a valuable resource as its the only small airport in the area Fairoaksalso supports a significant number of jobs which are important to the local economy Runnymede should becreating permanent jobs such as those at Fairoaks rather than destroying them Yes the building works willcreate jobs in the short term but they are not permanent and once those that are here are gone there is nowhereleft to support them Short term gain will lead to long term pain Stupid and shortsighted

5 Finally the impact on the environment We dont have many green places and this area isnt the mostbeautiful but it does have areas where you can walk and breath in relatively clean air that supports a goodvariety of wildlife and its important to protect whats left not to turn it into a concrete jungle More concretewill lead to more water run-off and increase the flooding weve seen in recent years The impact on theenvironment and those that live here CANNOT be underestimated

As representatives of the area you in RBC have a duty of your care to its residents This plan abuses that dutyof care and the trust placed in you by significantly worsening the health and wellbeing of existing residents Iam not against building but with recent major developments we have more than done our part Its time to stopand see reason before its too late and you decimate the local area forever

Regards

Mark Darlow

  • 1895 Douglas McNab - Education and Skills Funding Agency_Redactedpdf
    • ADPB347tmp
      • Our Ref ESFALocal PlanRunnymede 2018 21st February 2018
          • 1893 Mr Christian Leigh on behalf of Mr Gary Humphries_Redactedpdf
            • Runnymede Local Plan 2030 - consultation response
            • Runnymede LP Response - EE15
              • 1891 Dr Brian Pickett_Redactedpdf
                • Runnymede 2030 Local Plan - submission of views
                • Ottershaw development Objection letter February 2018
                  • 1886 Mrs Caroline Craven_Redactedpdf
                    • Representation for Local Plan
                    • Representation_form_for_Regulation_19_Caroline_Craven
                      • 1885 Stephen R Miles_Redactedpdf
                        • FW_ Objection to Runnymede Local Plan 2030
                        • Stephen R Miles Objection to Runnymede Local Plan 2030 at Feb 2018 Version 2
Page 51: Runnymede Borough Council, for submissions. My contact details are all in the WORD letter attached. But I will provide my telephone number here too, which …

Linda Barron

345 Stroude Road

Virginia Water

Surrey

GU25 4DB

FromTo Planning PolicySubject Draft Local Plan ConsultationDate 21 February 2018 114703

FromMark Darlow18 The GroveAddlestoneSurreyKT15 1RB

As a resident of Addlestone for over 30 years and Surrey for almost 60 I feel I am well placed to comment onyour current local plan consultation As such I object in the strongest possible terms to your current proposalsto concrete over large areas of green belt land

Living as close as we do the the M25 and Heathrow it could and SHOULD be argued that we need MOREgreen belt land not less to counteract the high levels of local pollution Urbanising the few remaining greenareas in the Addlestone area is NOT the answer to the housing crisis Spreading the load around the countryrather than cram housing into the South-East is Pollution in the area is already too high and its impact is feltfrom children to the elderly with asthma at an all time high putting an ever increasing burden on ouroverstretched health service

Your proposals to build almost 9000 new housing units in this area are in truth ridiculous Addlestone hasalready contributed large numbers of dwellings in Franklands Drive Aviator Park and in the new precinct areain addition to the significant infill in the area Infrastructure is at breaking point Local doctors are impossibleto book appointments for in under two weeks I have now suffered irreversible nerve damage because havingbeen recommended to see the doctor immediately by my chiropractor and the local pharmacist I was offered anappointment in March a wait of over two weeks Where will the 9000 to potential 30000 new residents find adoctor a dentist school places or hospital bed A service already in crisis The area also has more than its fairshare of gypsy sites notably Lyne Shepperton and Chertsey Fly tipping at an all time high and not all butmuch of which can be laid at their door

The local road network is stretched to breaking point My journey to work has doubled in time over the last 30years a fact highlighted by the recent A320 traffic study which found traffic congestion is at serious levels andthats before 9000 new housing units The Ottershaw area all entries to Addlestone and Weybridge arestationary every rush hour and if there is an accident on the M25 you might as well set up camp Ive parked asclose to home as I could get and walked on three occasions in recent years Addlestone is regularly at astandstill which will only get worse with the current developments let alone 9000 new properties Theadditional school places required will put even more pressure on the education system plus the increased trafficwill add further to the congestion

So to summarise

1 Destroying green belt land and sites is both short sighted and goes against the principals of good planning Itis greed for the sake of greed political dogma from short sighted politicians The green belt is Londons lungsand decimating our remaining green spaces affects the health and wellbeing of all

2 The increased traffic burden will turn Addlestone and the surrounding areas into a no go zone in peak hoursI assume most in planning drive cars and MUST see that any increase will be intolerable The additionalincrease in noise and pollution is unacceptable for the health and wellbeing of existing residents We alreadyhave unacceptable levels of noise with Heathrow and a concrete M25 which can be heard from miles around anadditional 9000 dwellings and gypsy camps will only dramatically increase this burden

3 The affect on other infrastructure is obvious to all Addlestone Health Centre barely manages now with a 2 -4 week wait for an appointment quite normal A amp E waiting times at St Peters already breach governmenttargets so what will 9000 more dwellings do And thats not to mention dentists where finding a NHS servicealmost impossible school places in already overstretched schools social services and accommodation for theelderly and public parking Pressure on water and electricity supply will severely impact on what is already a

1899

poor service Power cuts are not unusual and water pressure is dire already so 9000 new units will only worsenthe situation

4 Bulldozing Fairoaks Airport removes a valuable resource as its the only small airport in the area Fairoaksalso supports a significant number of jobs which are important to the local economy Runnymede should becreating permanent jobs such as those at Fairoaks rather than destroying them Yes the building works willcreate jobs in the short term but they are not permanent and once those that are here are gone there is nowhereleft to support them Short term gain will lead to long term pain Stupid and shortsighted

5 Finally the impact on the environment We dont have many green places and this area isnt the mostbeautiful but it does have areas where you can walk and breath in relatively clean air that supports a goodvariety of wildlife and its important to protect whats left not to turn it into a concrete jungle More concretewill lead to more water run-off and increase the flooding weve seen in recent years The impact on theenvironment and those that live here CANNOT be underestimated

As representatives of the area you in RBC have a duty of your care to its residents This plan abuses that dutyof care and the trust placed in you by significantly worsening the health and wellbeing of existing residents Iam not against building but with recent major developments we have more than done our part Its time to stopand see reason before its too late and you decimate the local area forever

Regards

Mark Darlow

  • 1895 Douglas McNab - Education and Skills Funding Agency_Redactedpdf
    • ADPB347tmp
      • Our Ref ESFALocal PlanRunnymede 2018 21st February 2018
          • 1893 Mr Christian Leigh on behalf of Mr Gary Humphries_Redactedpdf
            • Runnymede Local Plan 2030 - consultation response
            • Runnymede LP Response - EE15
              • 1891 Dr Brian Pickett_Redactedpdf
                • Runnymede 2030 Local Plan - submission of views
                • Ottershaw development Objection letter February 2018
                  • 1886 Mrs Caroline Craven_Redactedpdf
                    • Representation for Local Plan
                    • Representation_form_for_Regulation_19_Caroline_Craven
                      • 1885 Stephen R Miles_Redactedpdf
                        • FW_ Objection to Runnymede Local Plan 2030
                        • Stephen R Miles Objection to Runnymede Local Plan 2030 at Feb 2018 Version 2
Page 52: Runnymede Borough Council, for submissions. My contact details are all in the WORD letter attached. But I will provide my telephone number here too, which …

FromTo Planning PolicySubject Draft Local Plan ConsultationDate 21 February 2018 114703

FromMark Darlow18 The GroveAddlestoneSurreyKT15 1RB

As a resident of Addlestone for over 30 years and Surrey for almost 60 I feel I am well placed to comment onyour current local plan consultation As such I object in the strongest possible terms to your current proposalsto concrete over large areas of green belt land

Living as close as we do the the M25 and Heathrow it could and SHOULD be argued that we need MOREgreen belt land not less to counteract the high levels of local pollution Urbanising the few remaining greenareas in the Addlestone area is NOT the answer to the housing crisis Spreading the load around the countryrather than cram housing into the South-East is Pollution in the area is already too high and its impact is feltfrom children to the elderly with asthma at an all time high putting an ever increasing burden on ouroverstretched health service

Your proposals to build almost 9000 new housing units in this area are in truth ridiculous Addlestone hasalready contributed large numbers of dwellings in Franklands Drive Aviator Park and in the new precinct areain addition to the significant infill in the area Infrastructure is at breaking point Local doctors are impossibleto book appointments for in under two weeks I have now suffered irreversible nerve damage because havingbeen recommended to see the doctor immediately by my chiropractor and the local pharmacist I was offered anappointment in March a wait of over two weeks Where will the 9000 to potential 30000 new residents find adoctor a dentist school places or hospital bed A service already in crisis The area also has more than its fairshare of gypsy sites notably Lyne Shepperton and Chertsey Fly tipping at an all time high and not all butmuch of which can be laid at their door

The local road network is stretched to breaking point My journey to work has doubled in time over the last 30years a fact highlighted by the recent A320 traffic study which found traffic congestion is at serious levels andthats before 9000 new housing units The Ottershaw area all entries to Addlestone and Weybridge arestationary every rush hour and if there is an accident on the M25 you might as well set up camp Ive parked asclose to home as I could get and walked on three occasions in recent years Addlestone is regularly at astandstill which will only get worse with the current developments let alone 9000 new properties Theadditional school places required will put even more pressure on the education system plus the increased trafficwill add further to the congestion

So to summarise

1 Destroying green belt land and sites is both short sighted and goes against the principals of good planning Itis greed for the sake of greed political dogma from short sighted politicians The green belt is Londons lungsand decimating our remaining green spaces affects the health and wellbeing of all

2 The increased traffic burden will turn Addlestone and the surrounding areas into a no go zone in peak hoursI assume most in planning drive cars and MUST see that any increase will be intolerable The additionalincrease in noise and pollution is unacceptable for the health and wellbeing of existing residents We alreadyhave unacceptable levels of noise with Heathrow and a concrete M25 which can be heard from miles around anadditional 9000 dwellings and gypsy camps will only dramatically increase this burden

3 The affect on other infrastructure is obvious to all Addlestone Health Centre barely manages now with a 2 -4 week wait for an appointment quite normal A amp E waiting times at St Peters already breach governmenttargets so what will 9000 more dwellings do And thats not to mention dentists where finding a NHS servicealmost impossible school places in already overstretched schools social services and accommodation for theelderly and public parking Pressure on water and electricity supply will severely impact on what is already a

1899

poor service Power cuts are not unusual and water pressure is dire already so 9000 new units will only worsenthe situation

4 Bulldozing Fairoaks Airport removes a valuable resource as its the only small airport in the area Fairoaksalso supports a significant number of jobs which are important to the local economy Runnymede should becreating permanent jobs such as those at Fairoaks rather than destroying them Yes the building works willcreate jobs in the short term but they are not permanent and once those that are here are gone there is nowhereleft to support them Short term gain will lead to long term pain Stupid and shortsighted

5 Finally the impact on the environment We dont have many green places and this area isnt the mostbeautiful but it does have areas where you can walk and breath in relatively clean air that supports a goodvariety of wildlife and its important to protect whats left not to turn it into a concrete jungle More concretewill lead to more water run-off and increase the flooding weve seen in recent years The impact on theenvironment and those that live here CANNOT be underestimated

As representatives of the area you in RBC have a duty of your care to its residents This plan abuses that dutyof care and the trust placed in you by significantly worsening the health and wellbeing of existing residents Iam not against building but with recent major developments we have more than done our part Its time to stopand see reason before its too late and you decimate the local area forever

Regards

Mark Darlow

  • 1895 Douglas McNab - Education and Skills Funding Agency_Redactedpdf
    • ADPB347tmp
      • Our Ref ESFALocal PlanRunnymede 2018 21st February 2018
          • 1893 Mr Christian Leigh on behalf of Mr Gary Humphries_Redactedpdf
            • Runnymede Local Plan 2030 - consultation response
            • Runnymede LP Response - EE15
              • 1891 Dr Brian Pickett_Redactedpdf
                • Runnymede 2030 Local Plan - submission of views
                • Ottershaw development Objection letter February 2018
                  • 1886 Mrs Caroline Craven_Redactedpdf
                    • Representation for Local Plan
                    • Representation_form_for_Regulation_19_Caroline_Craven
                      • 1885 Stephen R Miles_Redactedpdf
                        • FW_ Objection to Runnymede Local Plan 2030
                        • Stephen R Miles Objection to Runnymede Local Plan 2030 at Feb 2018 Version 2
Page 53: Runnymede Borough Council, for submissions. My contact details are all in the WORD letter attached. But I will provide my telephone number here too, which …

poor service Power cuts are not unusual and water pressure is dire already so 9000 new units will only worsenthe situation

4 Bulldozing Fairoaks Airport removes a valuable resource as its the only small airport in the area Fairoaksalso supports a significant number of jobs which are important to the local economy Runnymede should becreating permanent jobs such as those at Fairoaks rather than destroying them Yes the building works willcreate jobs in the short term but they are not permanent and once those that are here are gone there is nowhereleft to support them Short term gain will lead to long term pain Stupid and shortsighted

5 Finally the impact on the environment We dont have many green places and this area isnt the mostbeautiful but it does have areas where you can walk and breath in relatively clean air that supports a goodvariety of wildlife and its important to protect whats left not to turn it into a concrete jungle More concretewill lead to more water run-off and increase the flooding weve seen in recent years The impact on theenvironment and those that live here CANNOT be underestimated

As representatives of the area you in RBC have a duty of your care to its residents This plan abuses that dutyof care and the trust placed in you by significantly worsening the health and wellbeing of existing residents Iam not against building but with recent major developments we have more than done our part Its time to stopand see reason before its too late and you decimate the local area forever

Regards

Mark Darlow

  • 1895 Douglas McNab - Education and Skills Funding Agency_Redactedpdf
    • ADPB347tmp
      • Our Ref ESFALocal PlanRunnymede 2018 21st February 2018
          • 1893 Mr Christian Leigh on behalf of Mr Gary Humphries_Redactedpdf
            • Runnymede Local Plan 2030 - consultation response
            • Runnymede LP Response - EE15
              • 1891 Dr Brian Pickett_Redactedpdf
                • Runnymede 2030 Local Plan - submission of views
                • Ottershaw development Objection letter February 2018
                  • 1886 Mrs Caroline Craven_Redactedpdf
                    • Representation for Local Plan
                    • Representation_form_for_Regulation_19_Caroline_Craven
                      • 1885 Stephen R Miles_Redactedpdf
                        • FW_ Objection to Runnymede Local Plan 2030
                        • Stephen R Miles Objection to Runnymede Local Plan 2030 at Feb 2018 Version 2

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