BRA Representation Document
On 5th November the BRA submitted their formal representation to Mole Valley District Council Draft Local Plan - Regulation 19. The Document has been prepared on behalf of the BRA by Brian Madge Ltd - Planning Consultants.
The BRA are opposed to the development of the Green Belt as detailed in the report
Executive Summary and Conclusions
This representation is submitted on behalf of Bookhams Resident’s Association (BRA) and focuses upon the Draft Mole Valley Local Plan (as published for Regulation 19 purposes) as it is proposed with particular regard to changes to Green Belt policy and the allocation of LAND NORTH WEST OF PRESTON FARM, BOOKHAM for mixed use development (Policy DS8) and Development Site DS11, LAND BEHIND HUNTER’S MOON for 5 dwellings
The BRA suggests the proposal fails four of the tests to demonstrate exceptional circumstances in that;
- The development would inherently be sprawl
- The development would further merge Bookham and Effingham
- The development will urbanise the area and encourage encroachment
- The development in part releases the pressure to develop in the urban area and particularly its town centres.
The BRA suggests the contribution made by windfall sites is underestimated and shows that in the past 12 months there has been a gain of 24 units in this locality. These approvals were made under the current policy framework. It follows if a new policy approach towards density were adopted this number could be greater. If Bookham is identified to achieve 469 units over 17 years (2020-2037) this can be averaged to 27 units per annum, only two units more than achieved last year. A new approach to density at 50dph must close that gap. If a more strident stance on compact development were established, that deficit would disappear. It thus follows that the housing need to release green belt land in Bookham is not proven. The BRA believes the Plan is unsound for the reasons below;
- exceptional circumstances do not exist as the housing analysis is incomplete and underestimates brownfield and underutilised land and opportunities arising from increased densities
- the plan underestimates the merging of settlements arising from extant consents and the proposed development of Preston Farm. The prevention of such coalescence is a fundamental cornerstone of Green Belt policy
- infrastructure demands arising from traffic, health requirements and schooling are insufficiently developed
- the site is not a sustainable location
Thus the Plan as submitted is not consistent with achieving sustainable development. The Plan currently has a flawed strategy which fails to take account of the reasonable alternatives as regard the re-use of urban land and opportunities arising from increased density. Finally, in promoting the merging of Effingham and Bookham, it is not consistent with national policy.