Email message sent to MVDC Development Management Committee
From Simon Edge - BRA Chairman
Dear Development Management Committee members (substitutes) and Bookham Councillors
The Bookham Residents Association (BRA) has a number of concerns about the Planning Officer's report regarding the Preston Farm planning application MO/2024/0096.
This email provides clear evidence that the application being recommended for approval does not comply with the Local Plan and Council Policies by providing specific references to the issues of greatest concern to Bookham residents (see the 300+ Letter of Representation summary below). The BRA thinks the issues raised should be of concern to all Development Management Committee (DMC) Councillors, and Bookham Councillors, alike. The concerns are listed below, together with the BRA's comments in red text.
Understanding that DMC Councillors must not prejudice their position by commenting on individual applications, the BRA seeks to ensure that all Councillors are aware of the extent of the problems identified with the report so they can be taken into account when Councillors make their decision. For Bookham Councillors, who are not members of the DMC, the BRA asks that you lobby and speak at the DMC meeting to see that this application is refused, or at the very least deferred until the concerns listed in this email are attended to.
Concerns and Comments
The developable area has reduced but the housing target remains unchanged. Policy DS8 has an indicative capacity of 200 homes but under Local Plan Policy D3 (indicative density of 20/ha for Greenfield with Built Up Edge) it should be below 150.
No action has been taken and approval at DMC is sought for the full 200.
Thakeham Homes is now proposing a greater proportion of higher buildings, resulting in increased visual intrusion and loss of amenity for residents of Little Bookham Street.
No changes have been made.
Policy DS8 criterion 2 requires clearly defined Green Belt boundaries but these are not shown on the parameter plans for the southwestern boundary along the track.
There should be a condition and/or an updated parameter plan showing planting to ensure that this boundary is not encroached in the future.
The revised locations for the Community Centre and the Gypsy & Traveller Pitches, together with a reduced buffer zone, will have a greater impact on the Conservation Area. Policy DS8 criterion 3 calls for conserving and enhancing the setting of heritage assets.
The reduced buffer zone is being accepted and a low level of harm accepted, not meeting Policy DS8.
Country Park (Policy DS8 criterion 6) – some development costs and the long-term management costs are under-estimated, in part through a failure to compound inflation (increasing costs threefold). Without suitably surfaced paths, which have not been costed, the area will not be accessible to all throughout the year, contravening Local Plan Policy EN5.
No change to the capital works has been sought nor any correction of the costings.
Groundwater and surface water flood risk remain serious concerns. The emphasis remains on preventing flood risk through Sustainable Drainage Systems (Policy DS8 criterion 9). However, criterion 19 is seeking flood risk betterment. Videos have been submitted by residents showing the extent of flooding in gardens along Little Bookham Street and at the Fox Lane site exit; these can be accessed via the Planning Portal. Flood risk also potentially impacts the Country Park’s walking and cycling routes (referenced in criteria 6 and 7). See also Surrey CC's S19 Flooding response (Atkins ref 513415).
Account needs to be taken of the increasing risk from climate change, manifested through increased flooding, which is a frequent and regular occurrence during the wetter winter months and occurs also whenever there is heavy rain throughout the year.
Despite mapping data to the contrary, the Council has not accepted to date the evidence for chalk streams. Whilst Section 9.9 of the Planning Officer’s report reflects this, Section 4.14 of the same report notes Surrey Wildlife Trust giving weight to SERT’s confirmation of winterbourne chalk river headwaters, both are in the public domain (17/1/25 and 10/1/25 respectively).
Chalk streams are protected explicitly from pollution and abstraction under Paragraph 152 (2) (a) of the Levelling Up and Regeneration Act 2023. In the light of these latest communications, the chalk river headwaters within the developable area can no longer be dismissed and require appropriate protection. Furthermore, Local Plan Policy EN12 requires at minimum maintaining the environmental quality of any watercourses and seeks an assessment of likely impacts and appropriate mitigation strategies. This cannot be achieved without referencing all of the mapping data, including that uploaded to Natural England on 22 August 2024.
The swept paths used to demonstrate access to the Gypsy & Traveller Pitches remains based on unusually short vehicle combinations.
This does not meet Policy DS8 criterion 13 regarding safe vehicular access. The access to site needs be based on vehicle combinations that would be used in reality to ensure their free and safe movement onsite.
The proximity of the site access to Preston Cross roundabout will worsen congestion on the Lower Road.
Policy DS8 criterion 14 seeks no significant impact on traffic from developments both individually and cumulatively. Notwithstanding an increased level of traffic being accepted by the Highways Authority, the BRA questions how the projection of an increase of +46% to + 59% (west and east of Preston Farm respectively) as set out in its LoR of 20/3/24 can be dismissed as insignificant?
The sewerage infrastructure is failing already, before connecting further homes. A major upgrade is required. Thames Water is accepting the connection of new homes on the proviso of no groundwater entering its network. The existing sewer across the site already fails to meet this and residents in the Saddlery and on Little Bookham Street have reported sewage backing up into homes. See Thames Water references including 00408507 and Environment Agency reference 02174462.
No plans are announced for a major upgrade of infrastructure. This does not comply with Policy DS8 criterion 15 which seeks “necessary upgrades to off-site wastewater infrastructure”. A condition is required to ensure compliance.
Following from the consultation which closed on 19 December 2024, 50 additional letters of representation were added to the Planning Portal. Three-quarters of these came from residents adjacent or very close to the development area, so the most directly affected. Concerns raised in more than 30% of these letters are reflected in the graph below. The total number of letters of representation stands now just over 300 since the beginning of 2024.
Summary of application for outline planning permission
The application for outline planning permission is to go before the Council’s Development Management Committee at its next meeting on 5th February 2025. The Planning Officer’s recommendation is to grant approval, subject to conditions and receipt of a satisfactory legal agreement before 28th March 2025.
In the last round of consultation in December 2024, the BRA raised numerous concerns on behalf of residents. The bold/italic text indicates how these have been addressed in the Planning Officer’s report to the DMC.
Item | ||
|---|---|---|
The developable area has reduced but the housing target remains unchanged. 200 homes are proposed where under Council Policy it should be only 140 – 145. | No action has been taken and approval at DMC would be for the full 200. | |
Thakeham Homes is proposing a greater proportion of higher buildings, resulting in more visual intrusion and loss of amenity for residents of Little Bookham Street. | No changes have been made. | |
Country Park – some development costs and the long-term management costs are under-estimated. Without suitably surfaced paths, the area will not be accessible to all year-round. | No change to proposals nor any indication of costings being corrected. | |
The revised locations for the Community Centre and the Gypsy & Traveller Pitches, together with a reduced buffer zone, will have a greater impact on the Conservation Area. | The reduced buffer zone is being accepted. | |
Groundwater and flood risk remain serious concerns. | The emphasis remains on preventing flood risk through Sustainable Drainage Systems. | |
Despite mapping data to the contrary, the Council has not accepted to date the evidence for chalk streams. | The report references Surrey Wildlife Trust visiting the site in January 2025 and SERT’s opinion that chalk streams are present, but the content of its submission is not in the public domain. | |
The sewerage infrastructure is failing already, before connecting further homes. A major upgrade is required. | No plans are announced for a major upgrade of infrastructure. | |
The proximity of the site access to Preston Cross roundabout will worsen congestion on the Lower Road. | The increased level of traffic is accepted by the Highways Authority and not being challenged. |
This last consultation has elicited 50 further letters of representation, bringing the total to over 300. When the DMC meets:
Where the proposals do not accord with the Council’s policies, how will these conflicts be resolved?
Will the representations of residents be considered?
The BRA will attend and once more raise the concerns of residents at this meeting.
For details on attending, see MVDC Development Management Committee
