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20/P/01503 | Demolition of the Goodhart-Rendel Community Hall and erection of a replacement community hall (Use Class D1) together with five residential dwellings (Use Class C3) together with a new internal road, car parking and associated landscaping. | Goodhart-Rendel Community Hall, Cranmore Lane, West Horsley, LEATHERHEAD, KT24 6BT
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  • Consultees Responded: 6
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Recycling & Waste Project Officer

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West Horsley Parish Council, West Horsley Village Hall

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Submission made on behalf of West Horsley Parish Council who strongly OBJECT to this application.

I have been instructed by West Horsley Parish Council to review the documentation submitted with the application and submit representations. Having discussed the application details with my client, I am instructed to OBJECT to the proposed development. In summary, the proposed development is in conflict with the following policies of the West Horsley?s Neighbourhood Plan and the Guildford Borough Council Local Plan:

? WH1 West Horsley Conservation Area
? WH2 Design Management within Village Settlement
? WH4 Housing Mix
? D3 Historic Environment

The conflicts and the evidence of harm are set out below.

Notwithstanding the harm identified below and the conflicts with the policies of the development plan, my client has advised that the ownership of the application site is not clear. I understand that my clients have corresponded separately with you on this matter, and have sought confirmation as to whether the correct certificate of ownership has been submitted. I would be grateful if you would confirm whether the application has, in fact, been validly made.

Planning applications should be determined in accordance with the Development Plan, unless material considerations indicate otherwise. As a result, the policy context for the development is important.

Development Plan

The Development Plan for the area consists of the Guildford Local Plan, adopted in April 2019, and the West Horsley Neighbourhood Plan, adopted in December 2018.

Guildford Local Plan- The site is within the Conservation Area and the settlement boundary of West Horsley. The village has been inset from the Green Belt.

In summary, the relevant policies for this development are;

? H1 Homes for all;
? D1 Place shaping;
? D3 Historic environment.

West Horsley Neighbourhood Plan- the site is located within the southern Settlement Area of the village, within a Conservation Area and an identified character area (Character Area 5). The relevant policies of the Neighbourhood Plan are:

? WH1 West Horsley Conservation Area;
? WH2 Design Management within Village Settlement;
? WH4 Housing Mix;
? WH13 Sustainable Urban Drainage;

Other material policy considerations include the NPPF, which sets out the definition of sustainable development (paragraph 11), as well as policy advice in relation to the density of development (paragraph 122), the design of development (paragraphs 124 - 132) and conserving and enhancing the historic environment (paragraphs 184- 202).

GBC have also recently consulted on the West Horsley Conservation Area Appraisal (consultation ended 24/02/2020), and this carries some weight as guidance to support the Neighbourhood Plan, with specific reference to policy WH1, and given that the application site is within the Conservation Area.

Main issues

Principle of development

This site is NOT an allocated site identified within the Local Plan.

This site is NOT identified as an available site within the recently updated Land Availability Assessment (2019).
The LAA clearly states on page 15:

"5.3 The LAA has considered the development potential of land in Guildford borough for housing and economic uses. The assessment has identified land in the borough that could deliver up to 14,840 new homes over the Local Plan period (including land with outstanding planning permission).
5.4 The study shows that up to 5,113 new homes are expected to be delivered within the first five years of the Plan period. This represents a Five-Year Housing Land Supply position of 6.84 years.?

GBC are clearly able to demonstrate that there is a five-year housing land supply, with a significant buffer included. Within West Horsley alone there are three allocated development sites that will provide more than 300 new dwellings in the village, with a further 110 on the allocated site in East Horsley. There is no reason why this application, for five more substantial houses on an important green field, should be approved.

The site is within the settlement boundary of the village and not within the Green Belt. As a result, the proposed development is not subject to any particular policies of restraint. In accordance with paragraph 11 of the NPPF, if the proposed development is in accordance with the development plan, it would fall within the definition of sustainable development, and there would be a presumption in favour of granting permission. Whether or not the proposal is in accordance with the development plan is set out below.

Housing mix

Policy WH4 of the Neighbourhood Plan and policy H1 of the Local Plan set out the required housing mix for development. Policy H1 sets out that "new development should provide a mix of housing tenures, types and sizes appropriate to the site size, characteristics and location?. Policy WH4 sets out that:

"Proposals for new residential development within the defined settlement boundary of West Horsley will be supported, provided they have had full regard to the need to deliver the following housing types:

i. Open market one, two- and three-bedroom market homes and bungalows suited to occupation by younger families and older households;?

The proposed development consists of the following;

? 2 x 2 bed houses;
? 3 x 3 bed houses.

The proposed development does not deliver any 1-bedroom dwellings, and no bungalows are proposed. As a result, the policy requirement to provide open market housing suited for occupation by younger families and older households is compromised and conflicted with. This need has been further evidence by the most recent update of the West Horsley Housing Needs Survey published in June 2019, which supports the requirement for smaller homes within the Parish.

West Horsley Parish Council OBJECT to the principle of development because the proposal does not meet the needs of Policy WH4 Housing Mix

Impact on the character of the area, including the heritage assets

The application site is within the defined settlement area of the village, but also within the village Conservation Area. The Parish Council have produced a character appraisal of the Conservation Area (also identified as Area Five) as part of the evidence base for the Neighbourhood Plan. The appraisal identifies in section 5.2 that:

"The architectural styles found in the conservation area illustrate the historic development of the village. There are a few medieval framed buildings which survive as reminders of the scattered rural farmlands and barns such as Britains Farm, in The Street; Pincott Farm, in Pincott Lane.?

Paragraph 5.3 sets out that:

"Where land in Area Five has been built upon, the density of development is generally medium. Most are single family dwellings, varying from 2 to 3-bedroom houses and bungalows.?

The overall character of Cranmore Lane changes from a suburban feel at the northern end, with the built form dominating over landscaping. However, towards the southern end, around the application site, the local character is semi-rural, with hedges and landscaping edging the highway and limiting the impact of the buildings. The rural lane has no footpath along most of its length. The application site itself is currently occupied by the existing community hall with its car parking area to the frontage, with a grassed area to the rear, enclosed by a robust tree belt to the west boundary and a public footpath and the rear gardens of the properties fronting the access road to Cranmore School to the east.

The existing community hall is a single storey low level building with a shallow pitched roof with a height to the ridge of 4.5m. The replacement community hall has a height to the ridge of 8.5m in order to accommodate the proposed two storey building. The proposed styling of the new community hall is inappropriate and out of character with the Conservation Area and the Parish Council have real reservations about the proposed two-storey structural form of the new hall, especially in relation to views into and outside the Conservation Area.

The block of three terraced properties to the rear of the site will have a maximum height to the ridge from ground floor level of 10m. This terraced block will be seen from Cranmore Lane when viewed down the access to the site along the eastern boundary, together with the flank boundary of the semi-detached pair of properties in the middle of the site. The development on depth will be readily apparent, and the scale, height and bulk of the buildings will be clearly visible from Cranmore Lane and also from the public footpath to the eastern boundary. The majority of the dwellings in the southern portion of Cranmore Lane are either single storey with accommodation in the roof space or two storeys with shallow pitched roofs. There is no development in depth within the surrounding area, and this is not a particular feature of this part of the Conservation Area.

It is clear that the development of the site will result in substantial harm to the character of the area. This harm is in conflict with policy WH1 of the Neighbourhood Plan which sets out the following:

"Development proposals within the West Horsley Conservation Area or its setting, as shown on the Policies Map, will be supported provided they have full regard to the West Horsley Character Appraisal Report and the following design principles:
i. Proposals demonstrate an empathy with the diverse style of the existing built environment as detailed in Evidence Base: West Horsley Character Appraisal Report (October 2017);
ii. Buildings should be of good design and use high quality materials. Scales, heights and form of buildings should be sympathetic to the existing built environment. They should seek to include the use of locally used and prominent materials such as natural clay red brick roof and tile hanging, timber weatherboarding, painted roughcast render and knapped flint;
iii. Proposals retain or re-provide as appropriate low boundary walls, hedges and front gardens to match the existing arrangement on the same alignment; and
iv. Proposals retain or re-provide as necessary natural verges to the highway.

Proposals that will result in the unnecessary loss of mature trees and established hedgerows will be resisted.?

Policy D1 of the Local Plan sets out that;

(4) All new development will be designed to reflect the distinct local character of the area and will respond and reinforce locally distinct patterns of development, including landscape setting.

The proposed development does not demonstrate an empathy with the existing environment, as the development consists of buildings of a greater scale, height and bulk than those in the immediate surrounding area, and the development in depth does not allow for the provision of appropriate low boundary walls, hedges and front gardens to match the existing arrangement on the same alignment. The proposed development, due to its layout, does not respond to and reinforce locally distinct patterns of development.

Policy WH2 of the Neighbourhood Plan is criteria based and includes the following;

? Buildings should be of good design and use high quality materials. Scales, heights and form of buildings should be sympathetic to the existing built environment;
? Where appropriate, the provision of 'pocket parks' and natural green spaces for wildlife should be included;
? Parking provision should not overly dominate the street scene and should maintain the character of the area.

The heights of the proposed buildings are set out above. The scale of the buildings is considered to be excessive in the context of the development to the north of the site in Cranmore Lane which in the main are single storey with accommodation in the roof space, and in the local vicinity of the southern part of The Street. It is rare to find a building above 8.2m in height in West Horsley.

The density, scale and layout of the proposed scheme does not make any provision for any meaningful green spaces or wildlife.

Policy D3 of the Local Plan sets out that:

"The historic environment will be conserved and enhanced in a manner appropriate to its significance. Development of the highest design quality that will sustain and, where appropriate, enhance the special interest, character and significance of the borough?s heritage assets and their settings and make a positive contribution to local character and distinctiveness will be supported.?

It is submitted that, for the reasons set out above, the proposed development neither conserves nor enhances the historic environment. The significance of the heritage assets is high, being a Conservation Area and the setting is important. The proposal does not make a positive contribution to local character or distinctiveness, and therefore should not be supported.

The proposed development also consists of a significant area of hardstanding within the centre of the site. In fact, virtually all of the public realm is laid to hardstanding, to provide for access, car parking and turning areas. There are no front garden areas, and virtually no opportunities for planting to create landscaped areas to soften the impact of the development. The amount of hardstanding and the provision of the car parking leads to a parking and car dominated layout, which is at odds with the character of the area.

The proposed development is not sensitively designed, and is therefore harmful to the character of the area, and the heritage assets in particular.

West Horsley Parish Council OBJECT to the design and layout of the development because the proposal does not meet the requirements of policies WH1, WH2, D1 and D3.

There are a number of other matters which West Horsley Parish Council would like to draw to the Officer?s attention:

1. The impact of additional traffic on Cranmore Lane. With the Land at Britains Farm application recently approved for five new homes and its proposed exit adjacent to this site, the additional traffic generated from an improved community hall with enhanced facilities and thereby increased usage, as well as the amount of additional housing proposed at the back of the building, will significantly increase the number of trips along this narrow country lane. Local residents on Cranmore Lane have raised this in a number of letters submitted to object to the application.
2. The impact of noise and the effect of neighbouring amenity has also been raised as a key concern from those living adjacent and nearby to the site ? this has been picked up by the response from the Environmental Officer and needs careful consideration. If the application should be approved a condition must be applied to protect our residents and the operating hours of the Hall restricted. It is noted that in considering the previous application for the redevelopment of the site (reference 15/P/2006), the Council refused planning permission for a number of reasons, one of which included the harmful impact on the amenities of adjoining residential properties as a result of the likely noise and general disturbance created by the users of the Hall. This would be particularly noticeable with vehicles arriving at and leaving the venue, with the slamming of vehicle doors and the impact of headlights, particularly late at night. The case officer?s report noted in relation to that proposal that "Also weighing against the proposal is the potential impact on the amenity of neighbouring properties from the new community hall and car park. Given that there is already a community hall on the site, the harm would be less than substantial, but still significant?.
3. Lack of established need for a new hall. Accepting that this is not a material planning consideration, there appears to be no assessment of need for a replacement hall by the applicant to demonstrate the need for new facilities and how they would be used. An analysis of local facilities should be undertaken to demonstrate clearly how this new facility will add value to those existing. This was raised at the appeal during 2016 and it was quite apparent that no consideration had been given to existing facilities and no assessment of future need to justify a new hall.
4. Concern over the ownership and right of the Trustees to enter into a development agreement with an external party. As the Parish Council have brought to your attention, the Goodhart-Rendel Hall and the land on which it stands was originally gifted by a deed of trust in perpetuity to the villages of West and East Horsley, and West and East Clandon. Following initial investigations by the Parish Council a summary of the key findings and issues are provided in Appendix 1. We would request that these are resolved before this application is considered.

Given the above comments, my client OBJECTS to the proposed development, and requests that planning permission is refused There are clear conflicts with the policies of the Development Plan, which includes West Horsley?s Neighbourhood Plan. If it would assist to discuss any of the above matters, I would be happy to do so and can be contacted on the details below.

Colin Smith M 07879 472 627 colin@colinsmithplanning The Logans, 146 Brambletye Park Road, Redhill, Surrey RH1 6ED


Appendix to Goodhart Rendel objection

Ownership concerns:
1. Land was transferred to 8 grantees and their successors by a Deed of Gift dated 26th May 1932 to hold upon trust, see copy of the Deed of Gift provided to Ms McSharry 1 October 2020.
2. Certain restrictions were placed on the use of the land by that Deed, see paragraph 4 of the schedule to the Deed.
3. The Title Deeds at H M Land Registry show the land as owned by the Goodhart Rendel Community Hall, Title Number: SY839628, not the successors to the Trustees to whom the land was transferred by the Deed of Gift, see copy of Title provided to Ms McSharry 1 October 2020.
4. As provided in the Deed of Gift the Hall was used as the clubhouse of the East and West Horsley Royal British Legion.
5. East and West Horsley Royal British Legion Club Ltd was registered on the Mutuals Public Register, number 20286R, on 13 June 1972. The land and the building thereon were not shown as assets in the Financial Statements submitted to that organisation.
6. The name was changed to the Goodhart Rendel Community Hall in 2015/16 and was first registered as such with the Charity Commission on 6 June 2016 as a CIO, Charity Number: 1167485, but the Financial Statements do not show the land and buildings as an asset although the Title is in that name.
7. At present we do not know of the history of the land and the building thereon since the Deed of Gift 26 May 1932, but we are attempting to ascertain this.

Until the ownership and any restrictions as to the use of the land are clarified we believe any planning permission should NOT be granted.

The application should be withdrawn until this matter is resolved.

Environmental Health Officer

Comment Date:

Planning Consultation ? Goodhart-Rendel Community Hall, Cranmore Lane, W. Horsley

Ref: 20/P/01503



The application is for demolition of the Goodhart-Rendel Community Hall and erection of a replacement community hall (Use Class D1) together with five residential dwellings (Use Class C3) together with a new internal road, car parking and associated landscaping.



NOISE

There is one existing and one future noise source that the proposed dwellings may be affected by. Firstly, the existing MUGA pitch of Cranmore School. The Noise impact assessment provided by the applicant states that the MUGA is an existing noise source and future residents would be expecting to hear noise from children in short durations in break and lunch times. This does not take into account playing times on the MUGA pitch and does not take into account the Agent of Change principle.



The report concludes that a 2m high acoustic barrier along the east side of plot 1 will be sufficient for mitigation of noise from the MUGA pitch. Unfortunately there is no noise contour plot with the noise assessment which shows the results of the computational modelling, therefore it is not possible to confirm one side of acoustic fencing is sufficient, given the layout of the gardens of plots 1-3 and the MUGA pitch.



The second source of noise is the proposed use of the community hall. The noise assessment has been conducted on the basis that the nearest noise sensitive premises to the ground floor function room is the existing residence on the opposite side of Cranmore Lane. Calculations have been undertaken on this premise. Whilst the location may currently be the nearest noise sensitive premises, the proposed dwellings (Plots 4 & 5) will be much closer once built and therefore any calculations should be based on these dwellings to ensure the future residences will not be unduly affected by noise from events held at the community hall. Construction of the hall, windows and ventilation, and likewise construction of Plots 4 & 5, should ensure that these plots will not be subjected to noise from events at the community hall.



AIR QUALITY

I refer to the Environmental Protection UK Guidance on Land use planning and development control: Planning for Air Quality, 2017 (https://iaqm.co.uk/text/guidance/air-quality-planning-guidance.pdf). This is not a legal document but provides important guidance on air quality considerations to all new developments and planning control that can be applied. The guidance recommends that all new developments should incorporate good principles of design with regard to minimising emissions and the reduction of impacts on local air quality. The good design principles are discussed in chapter 5 of the document and that would be relevant to this development are:



- All gas-fired boilers to meet a minimum standard of <40 mg NOx/kWh.



08.10.20



Ian Croll

Environmental Health Officer

Regulatory Services

Surrey County Council Highways

Comment Date:

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Thames Water Development Control (Planning)

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SCC SuDS Team

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Tim Holman

Consultation Date: Thu 17 Sep 2020

Design & Conservation

Consultation Date: Thu 17 Sep 2020

an Idox solution

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