Policy P1: Surrey Hills Area of Outstanding Natural Beauty
Policy P1: Surrey Hils Area of Outstanding Natural Beauty
The Surrey Hills Area of Outstanding Natural Beauty (AONB) will be conserved and enhanced to maximise its special landscape qualities and protect it from inappropriate development. All proposals will be considered against whether they:
Development proposals will also be assessed against the provisions of the current Surrey Hills AONB Management Plan.
Whilst the AONB designation does not preclude specific types of development in the Surrey Hills and proposals will be assessed on their individual merits, there will be a presumption against major development in the AONB in accordance with the NPPF. Exceptions may only be made for proposals that meet both criteria specified in paragraph 116 of the NPPF.
The AGLV will be retained until such time as there has been a review of the AONB boundary. Proposals within the AGLV will be required to demonstrate that they would not result in harm to the AONB or the distinctive character of the AGLV itself.
We OBJECT to this policy as it stands.
Whilst the Guildford Greenbelt Group welcomes the inclusion of a policy to protect the AONB within its submission draft of the Local Plan, we strongly object to Policy P1 and its supporting text, which we consider has weakened the protection of the AONB and the AGLV from the previous draft Plan.
Much of our concern stems from the loose wording of the Policy, which in some places renders the policy ineffective, for example:
“All proposals will be considered against whether they…”
“All development proposals within and adjacent to the AONB will be expected to conserve or enhance its special qualities”
Terms such as “considered” and “expected” are not strong enough in prohibiting development proposals that do not conserve and enhance the AONB, and it is likely that developers will be able to use this loose wording to their advantage. Of particular concern is the paragraph 3, which begins:
“Whilst the AONB designation does not preclude specific types of development in the Surrey Hills and proposals will be assessed on their individual merits…”
This whole opening clause is unnecessary and almost invites development proposals. GGG believes that it should be deleted, and the sentence should therefore begin: “There is a presumption against major development in the AONB in accordance with NPPF.”
In addition to the weakness of the language, GGG is also concerned that the AONB criteria listed in the policy are not the most important ones in determining whether a planning application should be approved. Aside from the one outlined in the first bullet point (which relates to the AONB setting) none of these criteria is concerned with the key characteristics of AONB, ie landscape character, scenic beauty, important views, tranquility etc. Whether or not a development supports the rural economy or provides public access are of far less national importance than preserving the quality of the landscape itself.
GGG believes that the AONB Policy in the Draft Plan 2014 provided greater protection to the AONB, and would like to see the following sentences reinserted:
Finally, GGG would like to see a clause which gives protection to the candidate areas for AONB status in the forthcoming Surrey Hills AONB Boundary Review. We consider that all land that has been assessed as meeting the latest Natural England criteria for AONBs should be subject to the same level of protection as an AONB, not just land that has been designated AGLV.