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Allotment site

PLANNING APPLICATION WA/2025/00581: OBJECT

Summary of Objection

Bramley Parish Council strongly objects to planning application WA/2025/00581 for the following reasons:

  • Conflict with the Bramley Neighbourhood Plan adopted in 2022
  • Not a Rural Exception Site
  • Harm to Countryside and Landscape
  • Infrastructure and Sustainability Concerns
  • Environmental Damage
  • Inadequate Community Engagement
  • Overwhelming Local Opposition
  • No Overriding Public Benefit

Based on the above considerations, Bramley Parish Council respectfully urges Waverley Borough Council to REFUSE this application.

Detailed Objection

  1. Conflict with the Bramley Neighbourhood Plan

The proposal directly conflicts with the Bramley Neighbourhood Plan (made 2020), which is part of the statutory development plan. The development site is located outside the defined settlement boundary and is not identified for development. Specifically:

  • Policy BP1 (Spatial Plan for the Parish): The site is outside the settlement boundary, an area designated for open countryside. The Neighbourhood Plan actively seeks to prevent sprawl and preserve the rural character of Bramley.
  • Policy BP3 (Maintaining the Rural Character of the Parish): The development is urbanisation westward which is against the North/south linear nature of the village. The development would therefore degrade the distinctive rural setting in this sensitive location – maintenance of which is one of the key objectives of the Neighbourhood Plan. This proposal is not an infill site and would encroach into National Landscape countryside, undermining Bramley’s rural identity.
  • Policy BP4 (Design Principles): The plan lacks sensitivity to the existing built form and the surrounding landscape and its setting.

As a statutory document, the Neighbourhood Plan holds significant weight and must be adhered to. The proposal’s conflict with these policies is a key reason for our objection.

  1. Conflict with the National Planning Policy Framework (NPPF)

The proposal also conflicts with several principles set out in the National Planning Policy Framework (NPPF), particularly in relation to sustainable development and the protection of the environment:

  • Paragraph 15 and 16: These paragraphs stress the importance of the plan-led system, stating that planning decisions must be made in accordance with the development plan unless material considerations indicate otherwise. This application conflicts with both the Bramley Neighbourhood Plan and the Waverley Local Plan, and there is no overriding justification to approve the proposal.
  • Paragraphs 84 and 85: These sections highlight that development in rural areas must be sensitive to the character of the countryside. The proposed development would significantly harm the open rural character of the area and is incompatible with the objectives of the NPPF, which seeks to protect the countryside from unnecessary and harmful development.
  • Paragraph 174: The NPPF requires planning policies and decisions to protect and enhance valued landscapes. The proposed development would result in the loss of open countryside, biodiversity, and ecological networks. There are insufficient plans for mitigation, making it inconsistent with national guidance on landscape protection.
  • Paragraph 180: The proposal fails to meet the requirements of the NPPF in terms of biodiversity protection. It would likely harm protected species and habitats, without providing sufficient measures for biodiversity enhancement, which is a requirement under this paragraph.
  • Paragraphs 110 and 111: This proposal is likely to exacerbate traffic congestion on the A281 and will negatively impact the local road network. The proposal will propagate an over-reliance on cars, contradicting the aims of the NPPF.
  1. Conflict with the Surrey Hills National Landscape (formerly AONB)

The site lies within the setting of the Surrey Hills National Landscape (formerly Area of Outstanding Natural Beauty, AONB). Approximately two-thirds of the site is located within the National Landscape, while the remaining one-third is a ‘candidate area’ in the final stage for inclusion in the National Landscape. This means that the site is situated in a highly sensitive area, and any development would directly affect the integrity and character of this designated landscape.

  • NPPF Paragraph 180: The NPPF stresses the need for great weight to be given to conserving and enhancing the landscape and scenic beauty of National Landscapes. Development within the setting of such areas must be carefully controlled, and harm to these landscapes must be avoided or minimised. In this case, the proposal would cause harm by introducing built structures into the rural landscape, which would degrade the views into and out of the Surrey Hills and this beautiful valley. View from the West and from the south will be substantially harmed. The site reaches westward far beyond the historic village development line and juts into clear greenfield National Landscape. It is the strong judgement of the local community that the development will detract and diminish this area, not conserve and enhance.
  • Judicial Review of Blackwell Solar Farm: In a recent judicial review concerning a development near the Surrey Hills National Landscape (Blackwell Solar Farm), the court quashed the decision to approve the application, finding that the local authority had failed to properly assess the harm to the setting of the AONB. The court ruled that planning authorities must consider the impact of developments on the setting of National Landscapes, even if the development is outside the formal boundary. This case sets a significant precedent and is directly comparable to this location, strengthening reasons for objection to the proposed development, as the site is both National Landscape Lane and directly within the setting of the Surrey Hills National Landscape.

The impact of the proposed development on the Surrey Hills National Landscape is therefore a key reason for the objection, and we urge Waverley Borough Council to carefully consider the significant harm to the landscape if approved.

  1. Failure to Meet Rural Exception Site Criteria

The application does not meet the criteria for a rural exception site. According to national policy and local guidelines, rural exception sites must be primarily for affordable housing to address an identified local need. The application fails to demonstrate a robust case for affordable housing need specific to Bramley, and there is no evidence that the proposed development would primarily deliver affordable housing appropriate to current need i.e. social rented. The proposal also conflicts with Policy BP1 and relevant national policies, further justifying refusal.

  • Affordable Housing Provision: While the proposal includes 14 affordable units out of 26 total, this does not meet the criteria of a rural exception site, where 100% of the units must be affordable. This is confirmed by the Waverley Borough Council Housing Strategy Team, who have noted that the site does not qualify as a rural exception site under the council’s Policy AHN2. The applicant has failed to demonstrate that the site meets the necessary criteria for such a designation, including being closely related to the settlement boundary and small scale.
  • Affordable Housing Need: Waverley Borough Council’s Housing Strategy Team has provided data on the need for affordable housing in the borough. As of the most recent data, there are 746 households in need of an affordable home to rent borough-wide, with 16 households from Bramley currently on the housing register, requesting affordable homes (1- and 2-bedroom units). However, this number is relatively small in comparison to the overall housing targets already met by Bramley.
  1. Housing Need and Existing Supply
  • Bramley has already exceeded its housing targets as set out in both the Bramley Neighbourhood Plan and Waverley Local Plan.
  • The Bramley Housing Needs Survey carried out in February 2023 identified 16 households from Bramley on the Housing Needs Register, seeking affordable homes to rent. Of these, 14 households require one-bedroom homes, and 2 households require two-bedroom homes. The proposed development will therefore not satisfy actual demand.
  • In recent years Bramley Parish Council has already delivered on several housing developments within the village, which have been aligned within the settlement boundary and have contributed to meeting the local housing requirements.
  • The Parish Council is actively involved in the ‘Call for Sites’ process as part of the Local Plan and has identified several alternative sites within the settlement boundary that are more suitable for future development. These sites would deliver the necessary housing supply in a sustainable manner without encroaching into the open countryside.

Given these points, Bramley Parish Council believes the proposed development is not necessary to address housing need and is not in line with local or national policy.

  1. Harm to Countryside and Landscape

The development would significantly harm the open countryside and would intrude into a sensitive rural area, disrupting the local landscape character and visual amenity. The proposal conflicts with Waverley Local Plan Part 1 Policy RE1, which seeks to preserve the countryside beyond the Green Belt. This development would represent an urban sprawl, which is not supported by local or national planning policy.

  1. Highways, Infrastructure, and Sustainability Issues

The local infrastructure is already under considerable strain, particularly the A281, which suffers from congestion.

  • Transport Statement: The proposal’s site access is poorly designed, with a sharp angle leading onto the A281, resulting in poor sightlines. Park Drive meets the A281 just north of a chicane with poor sight lines. Access is deemed by local people to be a significant concern and increased traffic in this junction would increase danger for road users and pedestrians.
  • Once on Park Drive, the road access thins to a point where the width is insufficient for the proposed development. The applicants report understates the number of residences already using Park Drive.
  • The Dunsfold Park planning process and transport assessment confirmed that traffic volumes on the A281 are already exceeding capacity especially at peak times. This development (and particularly the access point) would further exacerbate these issues.
  • The proposal will contribute to a higher reliance on car usage, conflicting with sustainable development principles.

 

  1. Environmental Impact and Wildlife

The site is currently an allotment and provides valuable green space that supports local biodiversity. It hosts a range of wildlife, including badger sets and slowworms, which would be displaced if development proceeds.

This would lead to habitat loss, increased surface water runoff, and diminished ecological connectivity, contrary to Policy BP7 (Protecting and Enhancing the Natural Environment). There is insufficient evidence to show that this development would protect or enhance local wildlife, and the lack of biodiversity enhancement further weakens the case for approval.

  1. Community Engagement and Feedback

The Statement of Community Involvement submitted by the applicant is inaccurate in describing the nature of engagement with Bramley Parish Council.

In response to the application Bramley Parish Council held a community feedback meeting on 15th April 2025, attended by approximately 90 residents, where 100% of attendees indicated they wanted Bramley Parish Council to object to this application. This clear and overwhelming local opposition is also reflected in the applicant’s community engagement report.

Bramley Parish Council is engaged in the ‘Call for Sites’ process as part of the new local plan, and alternative sites within the settlement boundary and/or less sensitive areas have already been identified to meet future housing needs.

  1. Flooding and Drainage Issues

Residents, especially those along Mill Lane, Park Drive and Halsey Meadows have raised significant concerns about the inadequate drainage and flooding issues in the area. The site is known to be extremely wet and experiences flooding after heavy rainfall. Runoff from the site flows towards Mill Lane, exacerbating the risk of flooding in this area. While the applicant has proposed a large attenuation tank to manage surface water, it is widely anticipated that this will be insufficient to cope with the volume of water generated by rainfall, especially considering the site's natural waterlogging issues.

  1. Loss of Allotment Site and Community Assets

It is acknowledged that, although not directly a planning matter, the proposal would result in the loss of the current allotment site. This site is an important community asset, providing residents with space for growing food and contributing to Bramley’s sense of community.

Additionally, feedback from the Bramley Bonfire Committee has raised concerns that the proposed development would prevent the annual Bramley Bonfire and Fireworks event from taking place. This is due to issues with insurance and safety distance requirements, which would no longer be achievable in the absence of the allotment and with the development of the site. Many residents provided feedback about concern of this loss which is an important community annual event

Conclusion

For all the reasons set out above, Bramley Parish Council strongly urges Waverley Borough Council to REFUSE this application. The development would cause significant harm to the environment, the local community, and the landscape, and it does not meet the criteria set out in national or local planning policy.

We trust that the Council will give full consideration to the concerns raised in this letter, particularly in light of the overwhelming local opposition and the significant policy conflicts highlighted.


Bramley Parish Council