Residents might already be aware of the planning application for Bonfire Hill that is currently live on the Waverley Borough Council planning website. Residents are welcome to submit their comments on this application – please copy and paste the following link where you will find the application http://planning360.waverley.gov.uk/planning/search-applications#VIEW?RefType=GFPlanning&KeyNo=422598&KeyText=Subject.
A copy of the Parish Council’s response may be found listed in the documents part of the application, and below.
A letter from Elstead Parish Council to Surrey County Council regarding drainage issues can be found here – https://elsteadvillage.co.uk/parish-council/letter-from-elstead-parish-council-re-bonfire-hill-drainage-issues/
Anyone wishing to submit their comments is reminded to ensure that they do it before 17th April 2020.
HILL – PC RESPONSE TO PLANNING APPLICATION WA/2020/0363
Elstead parish Council strongly objects to this application for 30
dwellings on land at Bonfire Hill, Elstead.
The application site is an area of elevated land dominating the
centre of Elstead village. It is outside the Settlement Area, within
the Metropolitan Green Belt and within the Surrey Hills AONB.
The National Planning Policy Framework (NPPF) makes it clear that
housing development within the Green Belt is generally inappropriate,
except in very special circumstances.
The WBC Local Plan Part 1 (LPP1) requirement for the Elstead and
Weyburn Neighbourhood Plan (NHP) area is to provide land for a
minimum of 160 new dwellings over the LPP1 period (2013-32). This
particular site was put forward as one of those to be considered in
the process of determining which sites within the NHP area would be
most appropriate for housing development. In all, 9 sites were
assessed by the NHP team’s professional advisers, Aecom. The
Bonfire Hill site was the only one of the 9 sites which was deemed to
be in the ‘red’ category (ie entirely unsuitable for
development), principally on account of its adverse landscape impact.
Aecom stated that the site was:
visible from surrounding properties the north, east and west and
would be highly visible from the wider AONB/AGLV due to its location
on a plateau’.
The latest draft of the Elstead and Weyburn NHP was published for
consultation on 11 March 2020 (this draft supersedes the earlier
draft published in 2018, prior to the release of the latest version
of the NPPF). The new draft NHP identifies 3 sites within the NHP
area which would more than meet the outstanding requirement for new
dwellings (63 in all, taking account of dwellings already built and
outstanding planning consents). These do not include this application
The NHP draft (para 5.18) also states:
Hill is a locally important green space in terms of landscape
character, historical value and recreational value. Any development
on Bonfire Hill will not be supported’.
provision was included to reflect the views of local residents on
their response to the NHP ‘Big Survey’ of 2015, which indicated
that large numbers of parishioners wanted to see Bonfire Hill
protected and definitely not developed.
Further, Bonfire Hill, in its entirety, is designated in the NHP
draft as Local Green Space (policy ESDQ4), on account of its dominant
position in the village, its accessibility (crossed by two ROWs) and
its recreational use (extensively used for tobogganing in snowy
The promoters of the site suggest that ‘very special circumstances’
should apply as they are putting forward the land to be used as a
‘Rural Exception Site’ to provide affordable housing, in
accordance with the provisions of para 145 f) of the NPPF. However,
this provision is for ‘limited’ (ie small-scale) schemes which
are designed to meet a defined local need. Elstead Parish Council
would strongly argue that this proposal (for 30 new dwellings) is
neither limited nor does it meet an established local need..
The latest Housing Needs Assessment (HNA) for Elstead and the
neighbouring parish of Peper Harow, carried out in 2019, identified
that there was a current demand from within the 2 parishes for 22 new
affordable homes (15 for rent and 7 for shared ownership). 21
affordable homes are about to be provided at the new Water Meadow
Place development within the NHP area. In addition, it can reasonably
be expected that 30% of the 63 new homes referred to in para 5 above
will be affordable. This would mean that at least 39 affordable homes
will be provided within the NHP area before very long, 17 more than
those identified as needed in the HNA. The Parish Council suggests
that WBC planners should also consult with WBC Housing Department
officers about the prospect of further provision for affordable homes
within the Borough’s own estate in the parish.
It is significant also that the draft NHP does not itself identify
any additional need for affordable homes, nor does it include
specific policies for this purpose (beyond those included in LPP1).
The provision of a significantly greater number of affordable homes
in the village could therefore only be justified in order to meet the
requirement for such homes outside the NHP area. This is not the
purpose of the Rural Exception Site policy. Nor would it represent a
sustainable housing policy. Inevitably, the occupiers of the
dwellings would probably need to work outside the village and because
of the paucity of public transport they would of necessity have to
use private cars. It should also be noted that homes provided under
the Rural Exception Site provisions would be additional
the number (160) allocated under LPP1. So the effect would be to
increase the Elstead and Weyburn allocation from a minimum of 160 to
a minimum of 190 (an uplift of nearly 20%).
The Parish Council notes that the promoters have commissioned a
drainage survey of the site. This indicates that water infiltration
techniques are deemed to be unsuitable (ie there is no prospect that
the development can be accommodated without causing surface water
flooding) and the only means of draining surface water from the
proposed development area is therefore to channel it into the foul
drainage system. This is unusual for Elstead and is inherently
undesirable, given the number of springs on the site (the names of
the surrounding roads – Springfield, Springhill, Springhaven – give
It is doubtful from the correspondence submitted by the developer
that Thames Water have themselves undertaken any on-site
investigation to assess the capacity of the local foul drainage
system to cope with what in wet weather would be a substantial
increase in volume. The developer’s own estimate of the maximum
amount of surface water to be channelled into the sewer system (4
litres per second) appears to be based purely on the area of land
involved. It takes no account of the specific hydrology of the site.
Local evidence suggests the run-off in wet weather will be much
greater than that predicted. During the recent wet period, one
resident on the land below Bonfire Hill was obliged to deploy pumps
to remove surface water at a rate of 5.6 litres per second over an
extended period – and this was from just one of the many springs on
the Bonfire Hill site. Surely it must be preferable to build new
dwellings on land which is not susceptible to such hazards.
The Parish Council notes that because the proposed new dwellings
would be classed as ‘affordable’, no Community Infrastructure
Levy would be payable. As a result, a large part of the affordable
element would be funded by the local taxpayer, even though the grant
of consent would provide a large uplift in the capital value of the
land. At the same time, it is proposed that an area of land on the
site would be made over to the Parish Council for community use.
There is however no proposed financial provision for the continued
maintenance of this land, the cost of which would therefore fall upon
Elstead parishioners. The Parish Council accordingly asks that in the
unlikely event of consent being granted for the application, a S106
agreement should be put in place to provide a capital sum sufficient
to provide for the maintenance of the transferred land in perpetuity.
For all the above reasons, these proposals have generated strong
opposition within the local community. It is significant that in
their comments on community engagement the promoters have made no
reference to this.
In summary therefore, Elstead Parish Council objections are as
application is not policy compliant, in that the site lies within
the Green Belt and the AONB
site has already been assessed by Aecom and deemed to be
‘unsuitable’ for development on account of the adverse
development would not be consistent with the draft Elstead and
Weyburn NHP, specifically para 5.18 and policy ESDQ4 (Local Green
proposals do not meet the requirements of the Rural Exception Site
provision in the NPPF
proposals do not adequately address the drainage problems of the
site and the solution proposed (disposal of surface water into the
sewer) is unsatisfactory and inadequate.
Parish Council would be very happy to discuss and expand upon these
points in a meeting with Waverley planners.