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Waverley Borough Council Committee System - Committee Document

Meeting of the Central Area Development Control Sub Committee held on 18/07/2001
SCHEDULE 'A' TO THE AGENDA



Central 12
SCHEDULE 'A' TO THE AGENDA FOR THE
CENTRAL AREA DEVELOPMENT CONTROL SUB-COMMITTEE
18TH JULY 2001

Major applications or those giving rise to substantial local controversy.

Background Papers (DoPD)

Background papers (as defined by Section 100D(5) of the Local Government Act 1972) relating to this report are listed under the "Representations" heading for each planning application presented, or may be individually identified under a heading "Background Papers".

A.1WA01/0621
Barratt Southern Counties
02.04.01
Erection of 29 dwellings, including nine affordable housing units, and a detached garage to serve retained dwelling following demolition of all existing buildings except May Croft on land at Croft Nurseries, Hookley Lane, Elstead (as amended by letter dated 06.07.01 and plans received 05.07.01)
A.2WA01/0622
Barratt Southern Counties
02.04.01
Erection of 29 dwellings, including nine affordable housing units, and a detached garage to serve retained dwelling following demolition of all existing buildings except May Croft on land at Croft Nurseries, Hookley Lane, Elstead (as amended by letter dated 06.07.01 and plan received 05.07.01)
Grid Reference:E: 491199 N: 143371
Parish:Elstead
Ward:Elstead, Peperharow, Thursley
Development Plan:MGB, AONB, AGLV part within settlement/part outside settlement (Replacement Local Plan)
Highway Authority:Recommends conditions.
Drainage Authority:Environment Agency – No objection subject to inclusion of conditions and informatives.
Parish Council:WA01/0621 and WA01/0622 – “The Council objects to the proposals, it was noted that the settlement area has not yet been approved by Waverley and, as such, the Council cannot approve that which is not yet approved, in addition the area is in the Metropolitan Green Belt Area of Great Landscape Value (AGLV) within the Area of Outstanding Natural Beauty (AONB).”
Consultations:Surrey County Council Strategic Consultation – Object (see report).
Representations:38 letters have been received objecting on the following grounds:
      1. previously stated objections apply;
      2. number of dwellings increase with every proposal;
      3. overdensity;
      4. excessive traffic generation;
      5. inconvenience and noise to adjoining properties;

      6. out of keeping;
      7. within Green Belt, outside settlement;
      8. increased congestion;
      9. loss of privacy;
      10. loss of rural tranquillity;
      11. detrimental effect on walkers/riders;
      12. conflict with heavy traffic from egg farm;
      13. effect on wildlife habitat;
14. undesirable precedent;
15. number of dwellings excessive;
16. loss of property value;
17. contrary to Local Plan Modification;
18. loss of hedge at access;
19. drainage/flooding problems;
      20. not a good site for haulage so no argument for alternative development;
      21. impact upon AONB and AGLV;
      22. disregards previous appeal dismissal;
      23. developer does not have control of land within sight lines;
      24. query compliance with Enforcement Notice;
      25. not a Brownfield site;
      26. preference for access off Spring Hill;
      27. threat to badger setts;
      28. contrary to Rural Protection Zone;
      29. “public open space” will be subsequently developed for housing;
      30. overdevelopment and intensive.

History

WA76/0657Outline application for erection of one two-bedroomed bungalow
Permitted
15.07.76
WA76/1630Details pursuant to WA76/0657 for erection of one two-bedroomed bungalow
Permitted
19.01.77
WA91/0330Siting of storage units for agricultural purposes
Permitted
12.06.91
WA99/0520Use of land as nursery and haulage with associated storage and scrap-yard
Withdrawn
WA99/0815Application for a Certificate of Lawfulness under Section 191 for the continued use of Area A as a horticultural nursery, Area B haulage and associated activities and Area C for outside storage/scrap associated with haulage and nursery
Appeal against
non-determination
allowed in respect
of Areas A and B
Refused in respect
of Area C
21.02.00

WA99/1139Erection of 22 new dwellings following demolition of existing buildings with the retention of one dwelling, together with the erection of a detached garage
Withdrawn
WA99/1140Erection of 22 new dwellings following demolition of existing buildings with the retention of one dwelling, together with the erection of a detached garage
Withdrawn
WA99/1383Application for a Certificate of Lawfulness under Section 191 for the continued use of Area A as a horticultural nursery, Area B haulage and associated activities and Area C for outside storage/scrap associated with haulage and nursery (resubmission of WA99/0815)
Certificate of
Lawfulness granted
for Areas A and B
with amplification
Certificate of
Lawfulness refused
for Area C
22.12.99
1/95/0060Application for a Certificate of Lawfulness for outside storage/scrap associated with haulage and nursery
Not determined by
Local Planning
Authority
Appeal Dismissed
23.08.00
High Court – Withdrawn
P43/8/16Enforcement action in respect of unauthorised storage use
Notice served
30.12.99
Appeal Dismissed
Enforcement Notice
upheld
23.08.00
WA00/0423Erection of 28 dwellings
Refused
30.06.00
Appeal Dismissed
30.01.01
WA00/0424Erection of 28 dwellings (duplicate of WA00/0423)
Refused
30.06.00
P43/8/16Enforcement action in respect of:
      (a) the unauthorised erection of a timber building;
      (b) the extension in the size of the hardstanding area serving the haulage use;
      (c) the increase in the number of lorries operating from the site.
Authorised
21.06.00

WA00/0937Retention of storage building
Refused
17.08.00
WA01/0217Retention of and use of building for storage/sorting facility by the Charity “Aid to Children Everywhere”
Refused
05.04.01

Site Description

These “twin tracking” applications relate to 0.95 hectares of land at Croft Nurseries, which is located upon the south-east side of Hookley Lane. The site is irregular in shape and adjoins the rear of existing dwellings within Hookley Lane and Springhill. The application does not include the entirety of the Croft Nurseries holding and excludes the land of the nursery to the south, which has no buildings upon it.

The site, which contains a variety of buildings in poor repair and which are used for storage and in connection with a haulage business, is partially used for open storage of a variety of items.

Two dwellings (one the subject of an agricultural occupancy condition) are sited in tandem, adjacent to the access way from Hookley Lane.

Background

Applications for a Certificate of Lawful Use and Development were submitted (WA99/0815 and WA99/1383) in relation to:

(i) the use of Area A as a horticultural nursery;

(ii) the use of Area B for haulage and associated activities; and

(iii) the use of Area C for external storage/scrap associated with the haulage and nursery business.

These areas are shown on the plan attached at Annexe A.

The use of Area A for horticultural purposes, including the operation of one rigid lorry and one van, and Area B for use as an operating centre for haulage purposes for the operation of three rigid lorries to include parking and maintenance has been granted a Certificate of Lawful Use.

The use of Area C for storage was refused a Certificate of Lawfulness.

Planning permission was refused under WA00/0423 and WA00/0424 for the erection of 28 dwellings. These applications related to the site of the current applications and the undeveloped land to the south. WA00/0423 was subsequently dismissed on appeal. The Inspector considered that the scheme represented inappropriate development within the Green Belt, caused unacceptable harm to the form and setting of the village and the local landscape, and did not comply with the Council’s policies on housing mix and affordable housing.


The Proposal

Full permission is sought in duplicate for the demolition of all buildings, including “The Croft” but excluding the bungalow “May Croft”.

It is proposed to erect 29 dwellings comprising two five-bedroomed; three four-bedroomed; eight three bedroomed; twelve two bedroomed and four one-bedroom units. Of the 29 units, nine (or 31%) would be “affordable” housing. The dwellings would be grouped around a central spine road. The submitted plan indicates that the remaining area of nursery land (outside of the application site) would be retained as open space to serve the development. A "Local Area for Play" is proposed within this open space.

The existing access from Hookley Lane would be widened and sight lines improved.

The applicants have offered to enter into a legal agreement to ensure that:

(i) the affordable housing is retained in perpetuity;

(ii) a management company to oversee future management of the open space and the LAP.


An appeal has been lodged against the Council’s failure to determine WA01/0622 within the statutory eight-week period.

Submissions in Support

In support of the application, the agents have put forward the following submissions:-

“As you can see from the enclosed site layout plan, the application site has been reduced in size over that previously put forward on the Croft Nursery site, and now reflects the area within the settlement boundary line as proposed by the Local Plan Inspector within his recent report. The remainder of the site would be left undeveloped as open space.

Accordingly, as the whole of the application site falls within the settlement boundary, it can be considered as an appropriate location for development. The criteria accompanying Policy RD1 allow for development within settlement envelopes if it is substantially surrounded by existing development; would not have an effect on the character and amenities of the village; would not adversely affect the urban/rural transition by using curtilages of buildings beyond the settlement; takes account of form, setting and local building styles; and generates a level of traffic compatible with the village and the surrounding highway network. The proposal is considered to comply with these criteria, and would be an appropriate addition to the housing stock of Elstead. The Inspector, at the Section 78 appeal (relating to the previous residential proposal on the wider Croft Nurseries area), considered that the nursery and haulage buildings detract from the character and appearance of the site, and that the previous development proposal went beyond the area defined as falling within the settlement by the Local Plan Inspector. We consider that the reduction in the scale of the proposal answers the criticisms weighed against the previous scheme.


The existing uses on the site, a haulage and nursery business, have been recognised by the Inspector at the Section 78 appeal, not to be well located in relation to the close proximity to houses, and it was recognised that the local residents would like to see the haulage use replaced by something less of a nuisance. Policy IC5 of the Local Plan identifies that the relocation of existing bad neighbour uses is desirable, if they give rise to undue disturbance or loss of amenity to neighbouring residential areas. The existing uses on the site have given rise to problems of disturbance, and could be more appropriately sited elsewhere within the Borough. The policy seeks to redevelop such sites for alternative industrial or commercial uses, that may be conditioned in order to protect residential amenity. In the case of the Croft Nursery site, as a result of its location, it is not considered to be suitable for redevelopment for commercial or industrial use, and if conditions as the policy suggests, would be even less attractive to potential operators than it is presently. Further evidence will be submitted in the near future in support of this case.

Accordingly, the existing uses on the site would have to be retained. It should be noted that these uses are unconditioned, which could result in the site being used by the existing, or a different, operator much more intensively in terms of hours of use without any new applications being made. Clearly, this limits the opportunity to impose conditions or limitations on the uses, and given the existing problems that the nearby residents have expressed in relation to the site, this development is seen as an opportunity to protect the amenity of residents in to the future.

……… A concern was also expressed by the Section 78 appeal Inspector in relation to the effect that the traffic generated by the residential properties would have on the amenity of nearby residents. As the site layout plan indicates, a 1.8 metre high sound attenuating fence is proposed along side the access road, which would serve to shield the effects of passing traffic from the closest residential property.”

The applicants have also submitted an appraisal of the site prepared by Consultant Surveyors and Valuers regarding the viability of the site for continued commercial use. This concludes that:

“For the locational, access and other factors described in this Report, I am of the firm opinion that there would be no reasonable prospects for achieving either a letting or freehold disposal of property for continued commercial use.

In addition, I have looked at the prospects for a redevelopment of this site, either to provide industrial units, or offices, but conclude that such redevelopment would not be viable.

I have been informed that the current owner of the site intends to relocate his business to a more appropriate site better suiting his business activity, ideally providing purpose-built accommodation in an established industrial area with proper infrastructure.


However, this will not be possible if the current application for change of use to residential is not successful in relation to the subject property. Under these circumstances, the current owner of the site is likely to remain at the subject property and continue his business activities as they are from the site for the foreseeable future.”

Planning Policies

The entirety of the site lies within the Green Belt, within an Area of Outstanding Natural Beauty and Area of Great Landscape Value. As such, Policies PE2 and PE7 of the Surrey Structure Plan and Policies GB1 and RE1 of the adopted Local Plan apply. The adopted Local Plan does not define settlement boundaries. The Council has previously and consistently taken the view that this site lies outside of the built settlement of Elstead.

The Replacement Local Plan proposes that Elstead be identified as a rural settlement to which Policy RD1 should apply. This policy permits small-scale development which is well related in scale and location to existing development and which complies with a number of criteria.

The Local Plan Inspector recommended that Areas “A” and “B”, as shown on the Lawful Development Certificate granted on appeal on 21st February 2000, together with a small rectangle of land immediately south of Area B, to the rear of the dwelling “Farthings”, should be included within the Elstead settlement boundary.

The Inspector, at the last Inquiry, noted the Local Plan Inspector's recommendations regarding the Elstead Settlement boundary and stated that, whilst it was not for her to define the boundary, she did consider the first main issue to be whether the proposal would materially harm the form and setting of Elstead and the surrounding area. She concluded that the proposal would significantly harm the form and setting of Elstead and its surroundings.

There are very marginal differences between the Local Plan Inspector’s proposed line and the application site boundary. These differences are so inconsequential as to be irrelevant.

The Council has considered the Inspector’s recommendations and has resolved, in respect of the above recommendation, as follows:

“The inclusion of “Area A” (the area for which a Certificate of Lawfulness for horticultural purposes was granted in February 2000) within the developed part of Elstead would be inconsistent with Annexe C of PPG3 and with the Inspector’s conclusions on Sunray Poultry Farm, Elstead. Annexe C of PPG3 (Housing) clearly states that land and buildings used for agricultural and forestry purposes are excluded from the definition of “previously developed land” (Brownfield land). It is, however, appropriate to include “Area B” (the area for which a Certificate of Lawfulness for haulage and associated activities [limited to three vehicles] was granted in February 2000) within the developed part of Elstead.”

The Council proposes to modify the Replacement Local Plan according to this resolution.


Having regard to the advanced stage of the Local Plan Review, considerable weight should be afforded to the Modified Plan and Proposals.

Also relevant to this proposal are Policies IC2 and IC5 of the Replacement Local Plan. Policy IC2 indicates that the loss of suitably located industrial and commercial land will be resisted. Policy IC5 states that where bad neighbour uses exist on suitably located sites, the preference is for a redevelopment for industrial/commercial purposes. Additional policies that are relevant are those in respect of housing provision (Policy H1 of the Replacement Local Plan), monitoring and phasing of housing development (Policy H2 of the Replacement Local Plan), density and size of dwellings (Policy H4 of the Replacement Local Plan), and subsidised affordable housing (Policy H5 of the Replacement Local Plan). Finally, Policy H10 of the Replacement Local Plan requires the provision of amenity and play space for housing developments.

Surrey County Council has been consulted on the strategic implications of this development and states:

“1. The proposals are not justified by being limited in scale or by reference to local needs purposes, and are therefore inappropriate development related to a Green Belt settlement, contrary to Policy PE2, and Review Policy LO6, and Government guidance given in PPG2 (Green Belts) concerning the protection of the Green Belt.

2. The proposals are incompatible in terms of density and the protection of local character, contrary to Policy RU1 and Review Policy LO4 concerning rural settlements.

3. The proposals are contrary to Policies DP4 and DP5, and Review Policy LO7, concerning overall housing provision and phasing, and Policy DP6 and Review Policies SE6 and DN12, concerning the restriction of such provision to within urban areas at an appropriate quality and density.

4. The proposals do not include a satisfactory element of affordable housing, contrary to Policy DP3, as continued under Review Policy DN10 concerning housing type and needs, Review Policy DN11 concerning affordability, and Government guidance contained in PPG3 (Housing), concerning the provision of low cost rural housing for local needs purposes.

5. The proposals are for development which is unsustainable, contrary to Government guidance contained in PPG3 (Housing), referring to the need to locate new housing development in locations where a reduction of car transport is possible and the use of alternative modes of travel can be made. The proposals are not in accordance with the guidance contained in PPG13 (Transport) which also seeks to reduce the reliance of the private car as a primary means of travel.

6. The proposals would not conserve or enhance landscape quality, contrary to Policy PE7, as continued under Review Policy SE6 for the protection of an Area of Outstanding Natural Beauty and Great Landscape Value, Policy PE14 requiring environmental enhancement, and Review Policy LO4 concerning maintaining the character of the settlement.


7. Without a commitment to proper archaeological investigation, the proposals are contrary to Policy PE13, continued under Review Policy SE4 concerning the protection of the heritage.”

Main Planning Issues

These applications are considered to materially conflict with adopted Development Plan policies. The main body of the site is considered to lie beyond the built-up extent of the village and the proposal would amount to inappropriate development which, by definition, would harm the openness of the Green Belt.

Notwithstanding the recommendations of the Local Plan Inspector and the proposed modifications to the Replacement Local Plan, the Local Plan Review still has a number of stages to go through before it is adopted. It is therefore wrong to argue, as the applicants’ agents do in their covering letter, that because the Inspector has concluded that the site should be included within the Elstead settlement boundary area, it is so included and should be “considered as an appropriate location for development”. As the Replacement Local Plan has not been adopted and this element of the Plan has not been finalised, the application site remains subject to Metropolitan Green Belt, Area of Outstanding Natural Beauty and Area of Great Landscape Value policies. It is clearly in conflict with those policies and should be treated as such. It also constitutes a departure from the Development Plan and no reasons have been put forward by the appellants’ agents to justify such a departure.

Moreover, the Council has recommended that only Area "B" (see Annexe A) be included within the settlement. It is likely that the final adopted Replacement Plan will include the amended boundary as proposed by the Council (Area B only).

Moreover, officers consider that the proposal conflicts with Policies IC2 and IC5 of the Replacement Local Plan. The area of land subject to a Certificate of Lawfulness for haulage uses is considered to be suitably located (according to the tests set out in Policy IC2) and could be redeveloped for light industrial (B1) purposes without causing unreasonable harm to neighbouring amenities. In the interests of maintaining a local employment basis, the officers consider that the existing haulage area could, in preference to housing, be redeveloped for light industrial/commercial employment purposes (B1). The conclusions of the agents’ consultant surveyors regarding the unsuitability of the site for a viable commercial/industrial redevelopment are noted. However, no actual marketing exercise has been carried out to back up these views.

These applications for residential development would also be inconsistent with the aim of conserving and enhancing the landscape within the Area of Outstanding Natural Beauty and Area of Great Landscape Value. Any perceived benefits arising from the provision of a comparatively modest area of public open space and the removal of the haulage use would be outweighed by the highly urban character, scale and extent of the proposed residential development across the application site. The location of the open space within the southern apex of the site would make little positive contribution to the form and character of the development.


The officers do not accept the applicant's assertions that this should be considered a “Brownfield” site or that very special circumstances exist which could justify permitting this development as an exception to adopted policies. PPG3's definition of previously developed land specifically excludes land containing agricultural buildings. The “benefit” arising from alternative residential development is, in the officers' view, outweighed by the adverse environmental impact this development would have upon the character and amenity of this part of Elstead and its surrounding rural area. The owner's proposal to relocate the existing haulage business in no way justifies this proposal.

There is not considered to be any exceptional justification for residential development of this size and scale given the fact that a 14.6 year land supply is available for residential development, easily exceeding the Structure Plan allocation for the Borough. In addition, the sequential approach in PPG3 means that sites such as Croft Nurseries will come low down the order of preferences should additional land ever need to be released. The development therefore conflicts with Policies DP4 and DP5 of the Structure Plan concerning housing provision and phasing.

The development is also considered to represent an unsustainable form of development contrary to Policy DP6 of the Structure Plan concerning the proper location of housing within urban areas and guidance in PPGs 3 and 13 referring to the need to locate new housing development in locations where a reduction of car transport is possible and the use of alternative modes of travel can be made.

In its original form, the scheme provided only 79% of one, two and three-bedroomed dwellings. Following concern expressed by the officers regarding non-compliance with Policy H4 on mix, the scheme has been amended to provide 82% one, two and three-bedroomed units. No further objection is therefore raised on mix grounds. The proposal would provide a density of 30.5 d.p.h. which falls just within the acceptable range for purposes of H4. Notwithstanding the concerns of the County Council, the officers consider that the density level complies with PPG3 and Policy H4 and no objection is raised on this ground.

In respect of subsidised affordable housing, whilst 31% of the dwellings are indicated as “affordable”, no details are given on the terms they would be provided to a Registered Social Landlord. This matter could however be resolved by the satisfactory conclusion of a Section 106 Agreement. Finally, in its amended form, the proposal indicates a Local Area of Play to the south of the site. However, the officers are concerned about this element of the proposal. In the first instance, the proposed play area is located outside of the application site, albeit within land also owned by the applicant. The land to the south is indicated as "amenity space". However, this is considered to represent an undesirable encroachment of residentially-related development to within the undeveloped part of the nursery holding, upon which the Council has consistently refused consent for residential development. Moreover, it is considered that the play area should be integrated within the development in a more accessible and supervised siting. The area to the south outside of the application site, rather than designated as amenity area should, in the officers' view, be returned to pasture land, consistent with the requirement of Area of Outstanding Natural Beauty and Area of Great Landscape Value policies that development should enhance the natural qualities of the landscape.


Recommendation

A.1 WA01/0621

That permission be REFUSED for the following reasons:

1. Standard Metropolitan Green Belt: Outside Settlements (20.1) *(insert after 1994 "and Policy LO6 of the Structure Plan Review (Deposit Draft) 2001") *(insert after 1993 “and Policy C1 of the Waverley Borough Replacement Local Plan (Deposit Draft) 1999”)

2. Standard Area of Outstanding Natural Beauty (21.1) *(insert after 1994 "and Policy SE6 of the Structure Plan Review (Deposit Draft) 2001") *(insert after 1993 “and Policy C3 of the Waverley Borough Replacement Local Plan (Deposit Draft) 1999”)

3. Standard Area of Great Landscape Value (21.2) *(insert after 1994 "and Policy SE6 of the Structure Plan Review (Deposit Draft) 2001") *(insert after 1993 “and Policy C3 of the Waverley Borough Replacement Local Plan (Deposit Draft) 1999”)

4. Standard Rural Areas: Neighbours' Amenities (20.6) - *(introduction) *(residential) *(As such, the proposal would conflict with Policy DE1 of the Waverley Borough Local Plan 1993 and Policies D1 and D4 of the Waverley Borough Replacement Local Plan (Deposit Draft) 1999)

5. The proposal materially conflicts with Policies DP4 and DP5 of the Surrey Structure Plan 1994, Policy LO7 of the Structure Plan Review (Deposit Draft) 2001, Policies H1 and H2 of the Waverley Borough Replacement Local Plan (Deposit Draft) 1999 concerning housing provision and phasing.

6. The development represents an unsustainable form of development contrary to Policy DP6 of the Surrey Structure Plan 1994 concerning the proper location of housing within urban areas. The development also conflicts with Government Guidance in PPGs 3 and 13 regarding the need to locate new housing development in locations where a reduction of car transport is possible and the use of alternative modes of travel can be made.

7. Notwithstanding the above reasons, the development does not make provision for affordable housing in accordance with Government Guidance and Policy DP3 of the Surrey Structure Plan 1994, Policy DN11 of the Structure Plan Review (Deposit Draft) 2001 and Policy H5 of the Replacement Waverley Borough Local Plan (Deposit Draft) 1999.

8. Without a proper archaeological investigation, the proposals are contrary to Policy PE13 of the Surrey Structure Plan 1994 and Policy SE4 of the Structure Plan Review (Deposit Draft) 2001.

9. The proposal does not make suitable provision for amenity and play space for the development in relation to Policy H10 of the Waverley Borough Replacement Local Plan (Deposit Draft) 1999.


A.2 WA01/0622

That, had it still been within the Council’s power to determine this application, then permission would have been REFUSED for the following reasons:-

1. Standard Metropolitan Green Belt: Outside Settlements (20.1) *(insert after 1994 "and Policy LO6 of the Structure Plan Review (Deposit Draft) 2001") *(insert after 1993 “and Policy C1 of the Waverley Borough Replacement Local Plan (Deposit Draft) 1999”)

2. Standard Area of Outstanding Natural Beauty (21.1) *(insert after 1994 "and Policy SE6 of the Structure Plan Review (Deposit Draft) 2001") *(insert after 1993 “and Policy C3 of the Waverley Borough Replacement Local Plan (Deposit Draft) 1999”)

3. Standard Area of Great Landscape Value (21.2) *(insert after 1994 "and Policy SE6 of the Structure Plan Review (Deposit Draft) 2001") *(insert after 1993 “and Policy C3 of the Waverley Borough Replacement Local Plan (Deposit Draft) 1999”)

4. Standard Rural Areas: Neighbours' Amenities (20.6) - *(introduction) *(residential) *(As such, the proposal would conflict with Policy DE1 of the Waverley Borough Local Plan 1993 and Policies D1 and D4 of the Waverley Borough Replacement Local Plan (Deposit Draft) 1999)

5. The proposal materially conflicts with Policies DP4 and DP5 of the Surrey Structure Plan 1994, Policy LO7 of the Structure Plan Review 2001, Policies H1 and H2 of the Waverley Borough Replacement Local Plan (Deposit Draft) 1999 concerning housing provision and phasing.

6. The development represents an unsustainable form of development contrary to Policy DP6 of the Surrey Structure Plan 1994 concerning the proper location of housing within urban areas. The development also conflicts with Government Guidance in PPGs 3 and 13 regarding the need to locate new housing development in locations where a reduction of car transport is possible and the use of alternative modes of travel can be made.

7. Notwithstanding the above reasons, the development does not make provision for affordable housing in accordance with Government Guidance and Policy DP3 of the Surrey Structure Plan 1994, Policy DN11 of the Structure Plan Review (Deposit Draft) 2001 and Policy H5 of the Replacement Waverley Borough Local Plan (Deposit Draft) 1999.

8. Without a proper archaeological investigation, the proposals are contrary to Policy PE13 of the Surrey Structure Plan 1994 and Policy SE4 of the Structure Plan Review (Deposit Draft) 2001.

9. The proposal does not make suitable provision for amenity and play space for the development in relation to Policy H10 of the Waverley Borough Replacement Local Plan (Deposit Draft) 1999.
* * * * *

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