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Posted by JamesHill on 5th October 2017

Neighbourhood Plan Update

Dear Members,

This is our view, please use these comments for your own response if you wish and also add your own views and comments as appropriate. We have only referred to the modifications that have the most significant impact on Farnham and Badshot Lea. The full Main Modifications document, 47 pages, is available on the Waverley website as `Local Plan Main Modifications`. All comments should be with Waverley by 5.00pm Friday 20th October.

You can respond to the consultation by downloading the form on the Waverley website or go to www.waverley.gov.uk/consult .

Local Plan Part 1 Main Modifications - BLCA Comments

MM1 Para 6.24

Any additional housing should be allocated by Farnham Town Council using the criteria used to identify sites for the adopted Neighbourhood Plan. This should be carried out during a review of the NP in year 5 of the plan when overall performance and housing delivery are better understood.

MM2 Policy SP2

The Green Belt Policy States five objectives:

 to check the unrestricted sprawl of large built- up areas;
 to prevent neighbouring towns merging into one another;
 to assist in safeguarding the countryside from encroachment;
 to preserve the setting and special character of historic towns; and
 to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
This policy is now failing on at least three of these objectives in Waverley.

- It is failing `to check the unrestricted urban sprawl` by simply shifting urban sprawl to areas not covered by the policy, particularly around Farnham.
- It is failing `to prevent neighbouring towns merging into one another` and forcing Farnham to become a seamless urban sprawl with Aldershot and its surrounding villages.
- It is failing to `preserve the setting and special character of historic towns`, in this case Farnham, the key historic town within the borough and gradually eroding much of the green space around the town and adding to the unacceptable traffic and air pollution problems.

The failure of the policy is clearly illustrated by the councils approach to the Strategic Gap between Aldershot and Farnham. Under the proposal within LP Part 2 this is reduced to a very thin strip of land along the Blackwater River as indicated in Plan 8. This will allow Farnham, Badshot Lea and Aldershot to become an urban sprawl, merging all three, simply because other more suitable areas are protected by the Green Belt.

This Canute like adherence to a Green Belt policy will be impossible to maintain even in the medium term. At the current anticipated rate of growth the areas not covered by Green Belt, SSSI, ANOB, Flood Zones etc will soon be exhausted. What then? No more development in Waverley? Far better to have a well considered long term plan now before it is too late and ensure that all development is plan led. 

Therefor criteria 1 should state: ` also any land within the Green Belt not seen as of high amenity and landscape value should be considered as available for development`.


Policy ALH 1.  Para 18.14

Waverley has allocated another 450 homes in Farnham to allow for Woking commuters. This approach to housing need in Farnham would appear to be totally illogical. Any `would be` Woking commuter would pass through Aldershot in Hampshire before arriving in Farnham. Should he stay on the train the next station is Bentley, also in Hampshire. Farnham is far more in the orbit of North East Hampshire than West Surrey when it is viewed as a community rather than a remote appendage on boundary of an administrative area.

Is Aldershot also tasked with finding space for Woking commuters? There is little evidence that the need to `plan strategically across local boundaries`, as outlined in NPPF paras. 178 to 181, has taken place when it comes to Woking commuters.

MM3 Pages 6-6 and 6-7.

The response to the amended housing need has rejected the opportunity to increase the housing provision at Dunsfold Airfield on the assumption that it would not be possible to deliver 3400 dwellings over the plan period. If that is their belief why was it offered as Scenario 4 in the 2014 consultation? The site is key to housing provision within the borough and the opportunity to create a new and well planned community should be taken and `planned positively` from the start as advised by the NPPF.

The opportunity to review significant growth around the villages, some of which are well placed for transport links, has not been taken. A far more robust and imaginative approach to housing allocation should be taken, particularly in view of the unwanted consequences of applying the Green Belt policy in its present form.

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