Guidelines for raising an objection
Objection guidelines
Because this application relates to waste, it is the responsibility of Surrey County Council to decide its outcome. Both Waverley Borough Council and Guildford Borough Council have been consulted by Surrey County Council because the sandpit straddles the boundary between them. However, neither Waverley Borough Council nor Guildford Borough Council is consulting with residents and you cannot directly raise any comments with them on their planning portals. This is why you must register any objections you have directly with Surrey County Council. Please click here for the full application.
Instructions for raising an objection
To register your comments with Surrey County Council, you can access their website through the attached link.
This link will take you to a page where you need to accept their terms and conditions by clicking on “Accept”. Thereafter you can register your objection via a simple single screen. There is space for 2,000 characters and you can add documents as attachments if you wish. Then press SUBMIT.
If for any reason this link does not work then you can access the appropriate page by going to www.surreycc.gov.uk, go down the screen to the section “Land Planning and Development”, then to “Planning” and then to “Applications Register” where you can enter the reference 2021/0150 and you will get to the same place as indicated above.
Logistics and Timeline
Objections can now be made until the end of the year.
In order for your objection to be effective, it is CRITICAL that it is written in your own words. Copying or cribbing will be spotted and these “duplicate” applications will not count. We have provided some issues below for you to consider. Please choose relevant ones of interest to you. There is no need to object on all issues, but PLEASE object in your own words.
Equally important is that your objection is based on personal experience or concern and relates to one of the issues identified below, Your objection does not need to be any more detailed than you are comfortable with. Experts will be providing detailed responses based on individual areas of expertise.
Who should object?
Everyone who lives in, travels in or enjoys The Surrey Hills. If this application gets approval, it will open the flood gates for further heavy traffic, noise and pollution in The Surrey Hills.
Everyone who could be affected by the HGV route. The applicant proposes that the route to the site would be via the A25. Either via Dorking and the A24 / A23 / M25 or from the west, using A3 / A31 / M25. There is no mention of where the inert waste would come from. The applicant states 22,345 inbound HGV tippers over 4 years. These would not all come from the same location. They could come from all over Surrey, Sussex, Hampshire, Kent, Middlesex, Berkshire, even London. This project could impact all the surrounding communities in The Surrey Hills. There is no guarantee all HGVs will use the A25. An HGV driver arriving from, for example, Chichester area could use SatNav and come via Shamley Green or Chilworth/Albury. An HGV driver arriving from Crawley could use SatNav and come via Ewhurst or Peaslake. Using the A25 going North West, residents of Clandon and Newlands Corner as well as road users would be at special risk.
We urge all and everyone who wants to protect Surrey’s unique and protected character to object. .
What is important is that:
You raise an objection
It is personal and in your own words
It is lodged ASAP
Please remember: Multiple objections from different individuals in the same household are permitted
When you submit your online objection you should receive an acknowledgement email from SCC within 24 hours. If you do not receive an email it is likely your objection has not been received and we recommend you submit your objection again
Issues which may concern you
Need, Plans & Frameworks
Need - There is no justification for the proposed infilling with the consequent risks of pollution and inconvenience to residents and visitors to the Surrey Hills Area of Outstanding Natural Beauty. The applicant says that the infill is advisable because the slopes surrounding the north side of the sandpit are unstable. This has not been established and is not supported by any evidence or local landowners. Indeed, the applicant’s own report describes the need as Low to Moderate. Even if some of the northern slope does need stabilising, there is still a question of whether there are less drastic ways of addressing this which the applicant has not considered.
Plans and frameworks - The application mentions multiple central and local plans and frameworks including NPPF / NPPG / MfS (2007) / Surrey Transport Plan (LTP3). Yet the applicant fails to explain just how the proposal will be compliant.
National Planning Policy Framework (“NPPF”) states pedestrians and cycle movements should be given priority
National Planning Policy Guidance (“NPPG”) requires the reduction of traffic generation and its detrimental impacts, reduction of emissions and climate impacts, improvements to health outcomes and quality of life, improvements to road safety
Leisure
The Guildford Local Plan aspires “to improve and diversify the leisure and visitor experience in the borough … Protecting our special natural landscapes and preserving our historic built environment will be important to achieving this”
This proposal does not support the Guildford Local Plan. Neither does it support the Waverley Local Plan, the Surrey Hills AONB Management Plan 2020-2025 or the Waverley Borough Cycling Plan in that it creates risks and erodes the visitor experience to walkers, cyclists and horses.
Both national and local cycling polices aim “to maximise the role of cycling as a transport mode”. Local Surrey CC objectives are “to develop a network of safe, convenient and continuous cycle routes”. The application shows no regard for these policies and fails to mention or consider the impact on 15 footpaths and bridleways which cross their proposed route.
The proposal fails to comply with many policies of Surrey Hills (SHAONB), SCC LTP, SCC Rights of Way Improvement Plan (2014), Waverley Cycling Plan, Guildford Local Plan.
Over 60% of the proposed route from A25 to WoodHill is part of the National Cycle Network (Route N22) . One of the key objectives of this UK wide network is to “feel safe”!
Transport
There are multiple transport issues - volume of traffic on rural roads, damage to rural roads built after WWII which were not built to sustain such loads, destruction of verges, multiple stretches of road where 20 tonne, 8 wheel HGV tippers (32 tonne fully loaded) and other vehicles cannot pass, road narrows to 3.45m at narrowest point and is frequently below 4m.
20 tonne HGV tippers are 8.84 metres long, 3.66 metres high and 2.74 metres wide. This leaves just 71 cm for other vehicles to pass in many places along the proposed route. Even the applicant says that the entrance to the sandpit will need to be widened to 7.5 metres to allow two HGV tippers to pass each other safely.
Surrey CC Transport Plan (LTP3) April 2018 is a statutory requirement and makes reference to “improve the quality of life” and “improve road safety”.
The applicant fails to explain how an additional 44 HGV journeys, each day for 4 years, will improve the quality of life for us, the local residents and improve road safety for walkers, cyclists and horse riders.
Climate & ancient woodland
There will be climate and environmental issues on ancient woodland and other protected natural areas.
Already high levels of climate damaging gases will be further increased due to the heavy increase of proposed traffic.
The pollution from 44 HGV movements each day for 4 years will not support the Waverley Local Plan (Objective 20) or Waverley’s Clean Air strategy.
Inert material controls will not prevent accidental and deliberate dumping of materials such as Knotweed and Asbestos which will leach into the sand based soil infrastructure.
Safety
Health and safety risks will be increased to motorists and pedestrians, horses and cyclists. Large 8.8m long HGV tippers driving on narrow country lanes and on right angle turns WILL create a hazard. Winter conditions will be an additional concern especially on blind corners and hill sections when heavy HGV tippers will bring greater risks. Of particular concern will be the safety of hundreds of children who take part in the Duke of Edinburgh Scheme.
The proposal has failed to address how the safety of hundreds of walkers, children, horse riders, cyclists will be protected
Surrey Hills Area of Outstanding Natural Beauty (AONB)
The primary purpose of AONB designation is “to conserve and enhance the natural beauty of the area”. Section 85 of the CRoW Act requires public bodies to meet their legal duty to “have regard” to the purpose of conserving and enhancing the natural beauty of an AONB.”
The sandpit proposal should be regarded as a major development as per the criteria given in the NPPF (National Policy Planning Framework)
involves waste
is a change of use on an area over 1000m²
is a “development” on a site more than 1 ha
is situated in the AONB
It can be argued in many ways regarding noise, pollution, safety, quality of life, impact on wildlife etc that the application is not in the public interest and therefore should be rejected.
The Roman Temple on Farley Heath
The applicant’s own EIA confirms there will be damage to the Roman Temple, which is a schedule 1 asset…running counter to local policy within the Guildford Local Plan, Policy D3 and the Waverley Local Plan, Policy HA1 both of which protect historical assets from such damage. As the proposed damage mitigation strategy will still result in damage to the schedule 1 asset, an asset of the UK’s most valuable category this damage cannot be overlooked. As the protection runs below the surface of the road and verges it is very difficult to protect it from 32 tonne fully laden loads.
Environment Impact Assessment (EIA)
It is believed that the EIA risk assessment is based on erroneous and out of date data and was not scoped to involve all environmental factors.
The EIA fails to adequately consider the impact of noise pollution with the additional 44 HGV journeys each day (for 4 years).
The EIA fails to adequately address the unmanageable risks of pollution resulting from the importation of what could primarily be construction rubble. It would be impossible to verify that such loads do not include any contaminants which would then leach from the infill material into the groundwater.
Brook Rail Crossing
There is a significant increase in danger especially during the winter months, of 32 tonne fully loaded HGV tippers potentially not being able to stop when coming down the hill, crashing through the barriers and getting stuck on the railway line.
GBC no longer grit the rural roads during the winter.
Allowing 22 inbound HGVs each day is increasing the risk of a disaster and major derailment.
What is INERT Waste?
Waste that cannot disintegrate naturally, either biologically or chemically, is referred to as inert waste. Examples of inert waste include glass, plaster, drywall, siding, shingles, insulation, metal, wood, bricks, asphalt or cement concrete, and other building construction materials.
Surrey Hills to become a National Park?
There are various proposed campaigns to support a greater protection of The Surrey Hills. Jeremy Hunt, local MP, is a great supporter having grown up in the area and is campaigning to get National Park status.
What will it mean? If The Surrey Hills had National Park status it would have a planning authority in its own right and would have access to even more funding to protect the space and biodiversity.
It would be ironic for Surrey County Council to approve an application like this whilst at the same time supporting The Surrey Hills AONB.
Surrey County Council website states, “The Surrey Hills is a nationally designated landscape whose distinctive character and natural beauty is so precious that it is safeguarded in the national interest.”
Problems submitting an online objection?
If you are having problems submitting your comments to Surrey County Council then please email SCC planning at mwcd@surreycc.gov.uk
- Please include their Reference Number Ref: 2021/0150
- If you do not get an email acknowledgement, please resend your email until you receive an acknowledgement.
We would also advise you to email your local borough council to lodge your complaint with them
Guildford Borough Council using Ref: GU/22/CON/00015. Email address is planningenquiries@guildford.gov.uk
Waverley Borough Council using Ref: WA/2022/00997. Email address is consultation.planning@waverley.gov.uk