Local Plan – the FRA submits Representations

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The 'Proposed Submission Version' of the Mole Valley Local Plan was published for comment by MVDC on 20th September 2021 for a seven week period to 7th November 2021. Comments received by MVDC during this time will be forwarded to the Planning Inspectorate for consideration as part of their examination of the Plan.

FRA has been considering how the proposed final version might directly or indirectly impact upon Fetcham.

As had been anticipated, Fetcham Springs had been taken out of consideration for any development, as has the Elmer works land, previously earmarked for 55 housing units.

Other significant changes included:

  • Amount of Green Belt ‘take’ reduced.
  • Some Infrastructure allocations, include former Bookham Youth Centre site for a potential Health Centre.
  • Rentwood, School Lane newly included for 22 housing units within Fetcham.
  • Land north of Guildford Road, Bookham for 164 units removed.
  • Land to north and south of Barnett Wood Lane, Leatherhead, removed.
  • Annual new homes target cut from 449 to to 353 dwellings.

In our considered opinion the remaining threat to Fetcham is the absence of infrastructure allocations to enable Fetcham to cope with existing shortcomings and the consequences of development within Fetcham, including ongoing infill and at Rentwood; as well as the significant developments in neighbouring Leatherhead and the Bookhams. We are also concerned about the absence of undertakings to coordinate the planning of strategic infrastructure such as flooding prevention, main drainage, health services, roads, parking, public transport etc.

The FRA's submission is reproduced here in full ...

Representations on the Draft Mole Valley Local Plan 2020-2037

by

Fetcham Residents Association

  1. Introduction
    1. This representation is submitted by the Fetcham Residents Association (FRA) and considers the implications of the Draft Mole Valley Local Plan, as now proposed, upon our neighbourhood.
    2. Our representation is in regard to the Soundness of the Plan; and to whether the Plan provides an Infrastructure Strategy that adequately provides for additional already unmet need being generated by development in adjacent neighbourhoods within Mole Valley, as well as by neighbouring authorities.
    3. Our concern is for the impact upon Fetcham’s infrastructure from the development of the land allocations within adjacent sites in Leatherhead and the Bookhams.
    4. We also express concern related to one of the allocations of land for mixed use within Fetcham; with an opportunity being potentially lost to improve one aspect of our local infrastructure, whilst also having further detrimental effect upon other aspects of that infrastructure.
    5. Consequently, we wish to highlight what we consider to be the inadequacy of substance provided within Section 7: Infrastructure, and Section 8: Infrastructure Delivery.
  2. Allocated Sites within Fetcham – (CHAPTER 9)
    1. It should be considered significant that within the boundaries of Fetcham, only two sites are allocated for ‘Residential’ or ‘Residential and Commercial, Services and Business’. This we believe to be fair reflection of the existing use of available land, without incursion into precious Green Belt, further disastrous building on floodplains or sprawl extending into the few remaining green margins with neighbour communities.
    2. FETCHAM (Policy DS39): We have no issue with the inclusion of land at 167 Cobham Road, Fetcham and have been supportive of the modest development, as already approved, of this site in the historical centre of the village.
    3. FETCHAM (Policy DS38): The conditional inclusion of Rentwood, School Lane, Fetcham is recognised as a development we could support. However, our overriding concerns are about the shortfall in current infrastructure in the immediate and surrounding areas.
      1. Our preferred use of the site has been and could yet remain, to at least include a much needed Medical centre.
      2. We would be concerned about the additional demand upon the existing inadequate storm and waste-water services in an area already badly affected by natural springs. Note that Fetcham falls almost wholly within the areas of ‘Critical Drainage’ indicated in Appendix 19.
      3. Already deteriorating public transport services, additional vehicle movements and parking issues created by such development immediately opposite our Pre-School and Infant School facility will pose significant safety issues, despite recent designation as a 20mph zone and some traffic calming measures in the immediate area.
  3. Infrastructure Policies – (CHAPTER 7)
    1. Objectives 14 & 15 set out in CHAPTER 2 - Vision and Objectives, do little more than state the need to either minimise the impact of infrastructure impact, or at best to acknowledge the needs for and needs of, sustainable transport.
    2. Looked for details within Chapter 8 for how these ‘objectives’ might be achieved indicate little more than a reliance upon developers to contribute towards ’integrated’, ‘well designed’, and ‘improved’ schemes.
    3. No consideration is evident of Masterplannng of District or Neighbourhood needs, or of mechanisms to ensure essential coordination of individual developers inputs towards delivering those needs.
      1. Transport (Policy INF1): the only provision for road improvements is the safeguarding of land for a short section of the A24.
      2. Parking (Policy INF2): the need to avoid on-street parking is acknowledged. But then measures to prevent its proliferation are either tempered by exemptions applied to the already overcrowded streets in the main towns of Dorking & Leatherhead, and by the expectation that restricting off-street parking will automatically limit the number of vehicles per dwelling to the space available. WE would suggest that is not a Parking Policy, but a fanciful wish, beyond the ability of MVDC to grant.
      3. Flood Risk(Policy INF3): the persistence of policies permitting some mitigated development within some Flood Zones is disappointing. We would suggest that the time has come to exclude ALL development, except for infrastructure and water- compatible use, from Flood Zones. And to also consider imposing a severe restriction on the development of land within an appropriate buffer zone – beyond the current least-risk zones. Sustainable Drainage systems should also be mandatory for ALL developments and not only subject to their feasibility. If the provision of such drainage systems is not feasible; then the development site should be designated as not being feasible to develop.
      4. Community Facilities (Policy INF4): The FRA does not believe we have any arguments with the policies as described, other than the observation that the assessment of attempted proposals to deliver such facilities have been less than transparent in the recent past.
      5. Digital Infrastructure (Policy INF5): We recognise the needs and the benefits of improved digital telecommunications. However, we are disappointed that the criteria for siting additional masts, as determined to be required, does not place greater onus on the providers and the LPA to actively seek design, size and location alternatives if needed. Where the amenity of occupiers of neighbouring mast sites would otherwise be clearly harmed; creative solutions, including compensation, acceptable to all parties should be required to be found as a matter of a policy.
      6. Gatwick Airport (Policy INF6): the FRA has no comment to add to the debate.
  4. Delivery Policies (CHAPTER 8)
    1. We consider that the opening declaration of POLICY D1: Infrastructure Delivery (8.1) to be flawed in the presumption that existing infrastructure assets are adequate for existing needs of existing residents.
      1. Due to the historical absence of large developable sites, Fetcham has been, and remains, under considerable pressure from aggressive infilling and the replacement of small with larger dwellings.
      2. Much of this development avoids direct conditional provision of complementary across-the-board infrastructure.
      3. The cumulative result being significant shortcomings and deterioration of the infrastructure being experienced by the entire community.
      4. Whilst cross-boundary impacts are acknowledged (Policy D1, 8.5), there are no indications provided as to HOW, or WHEN such impacts would be assessed or addressed.
        1. Surrounded by areas within which significant development may be anticipated, the impact of that development will inevitably be felt by Fetcham.
          1. Further pressure upon medical, dentistry and pharmacy services, with no new provision for GP services agreed; as required under the Statements of Common Ground to be part of the Local plan.   
          2. Additional demands upon our already oversubscribed schools, as was again required via Statements of Common Ground.
          3. Increased use of our deteriorating roads by through traffic and for commuter parking. Fetcham has recently experienced traffic gridlock on one road due to minor roadwork in Bookham High Street, this would become the normal level with increased development in Bookham and Leatherhead.
    2. Consequentially, we contend that any delivery of new infrastructure to ensure that future needs are met will require a great deal more than ‘reinforcement’ of existing or only provision of new to support new development.
    3. Reliance solely on developers to be providers of new infrastructure will inevitably fail to rectify existing shortfalls.
    4. We remain disappointed that the entire Policy D1 is lacking commitment to drive and where needed, invest in a comprehensive and properly coordinated upgrading of all aspects of Mole Valleys Infrastructure.
      1. Such much needed investment would be readily recoverable from developers.
      2. Piecemeal additions or fixes could be avoided.
      3. Existing weak links could be addressed, avoiding them blighting the performance of new elements.

The FRA would welcome the opportunity to appear at the Local Plan Examination to stress our request for the inclusion of forward planning of Infrastructure by Mole Valley District Council.

Richard Bradfield

Fetcham Residents Association

05/11/21


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