Green Belt Protection – Law & Case Precedent

• The sites lie within the Metropolitan Green Belt, legally protected to stop urban sprawl and preserve countryside. Developers may argue about "Grey Belt", land of supposedly lower value, but this is only a political idea, not law or policy.
• The NPPF (2023, Chapter 13) says housing here is "inappropriate" unless very special circumstances are proven. No very special circumstances have been demonstrated.
• Courts (Redhill Aerodrome 2014; Timmins 2014; Samuel Smith 2020) confirm Green Belt harm must carry substantial weight.

Approving this scheme would be contrary to national policy and the plan-led system, and combined with adjacent proposals would cause severe cumulative harm to openness, landscape, traffic, schools, and healthcare. Once built on, this countryside is gone forever.

Grey Belt – Why Mayford Does Not Qualify

The government’s NPPF "Grey Belt" idea applies only to land of limited Green Belt value.

• Built or enclosed land? No - these are open fields, not previously developed or surrounded by buildings.
• Little role in stopping towns merging? No - these sites preserve the historic separation of Mayford and Woking, recorded since the Domesday Book.
• Urban land uses? No - the sites are semi-rural, with hedgerows and countryside character.
• Little role in historic setting? No - the escarpment is protected under Policy CS24 and defines Woking’s landscape setting.

Plot 0832 also adjoins a Grade II listed building, giving it clear heritage value.
Mayford is true Green Belt, not "Grey Belt". Attempts to downgrade it are misleading and contrary to policy.

Local Plan & Housing Need Already Met

• The sites are not allocated for development in the Woking Site Allocations DPD, which was found "sound" by the Planning Inspector.
• Under Section 38(6) of the Planning and Compulsory Purchase Act 2004, decisions must follow the adopted plan unless justified.
• Woking’s Annual Monitoring Report and Five-Year Housing Supply confirm housing delivery is on track.

New government targets are a matter for future plan-making, not ad hoc approval.

Landscape, Amenity & Environmental Impact

• These sites are not "Grey Belt" but form part of the Escarpment and Rising Ground of Landscape Importance, protected under Woking Core Strategy Policy CS24.
• Applications 0831 and 0832 have been submitted separately, Considered together, they may exceed thresholds under the EIA Regulations (e.g. >150 dwellings or sensitive sites). The Council should assess cumulative impacts and require screening for a full Environmental Impact Assessment.
• Environment Act 2021: Requires all new developments to deliver at least 10% Biodiversity Net Gain (BNG), secured and monitored for 30 years. The Mayford schemes rely on vague "off-site" measures that are not legally guaranteed.
• Proposed heights (up to 11m, three storeys) will dominate the skyline and overlook homes, causing loss of privacy, daylight, and rural character. Urban lighting will erode dark skies, harming amenity and wildlife.

NO EIA provided, leaving serious cumulative impacts on landscape, ecology, and residents untested.

Transport, Flood Risk & Infrastructure

• Local roads (Saunders Lane, Hook Hill Lane) are narrow, congested, and unsafe. Traffic surveys were done in August, underestimating real volumes.
• Surrey County Council’s own accessibility scoring system rates this location 41–53 out of 100 for connectivity. This is considered poor to below average, meaning residents here would be heavily car-dependent with limited access to public transport, schools, shops, and services.
• The site is low-lying and waterlogged, with no winter infiltration testing or robust drainage plan.
• Schools and GP surgeries are already oversubscribed, with no binding commitments to expand services.

The scheme does not demonstrate compliance with NPPF 111, 159–169 and 20, leaving residents exposed to unsafe roads, flood risk and overstretched services.