Saturday, 29 November 2025

Waverley Local Plan: Issues and Options Consultation Response


Image credit: Waverley Borough Council

Waverley Borough Council (WBC) have recently issued notice of a consultation on “Issues and Options” for a proposed update to the Waverley Local Plan. I am responding to this, first, as a resident of Waverley (near Charterhouse School). And second, as campaign manager for the Godalming and Ash branch of Reform UK.

For those not already aware of this consultation, the notice is here: [[1]]. The issues and options document is at [[2]]. And responses can be submitted via [[3]]. The closing date for responses is Monday December 8th.

Context

The reason given for the update is “to ensure conformity with national planning policy following advice from the Planning Advisory Service.” So, this is top-down policy, being dictated to local councils by central government. The relevant legislation is the Planning and Infrastructure Bill, first introduced by Labour just eight months ago. It cleared its last stage in the House of Lords on 25th November: [[4]]. One headline is “a national target of building an additional 1.5 million homes [in England] by 2029.”

WBC is due to be abolished in 2027, and subsumed with five other councils (Guildford, Surrey Heath, Woking, Runnymede, Spelthorne) into a West Surrey unitary authority. Because of this, it seems rather odd that this is being done now, to come into effect in 2028. If all six councils must conform to national planning policies, why not pool their resources into a single plan for West Surrey, rather than doing the same thing six times over? It looks as if Labour are in a huge hurry over this, just as the Tories were over getting the May 2025 Surrey local elections postponed. The cynic in me asks why.

As to the characteristics of Waverley as a borough, the document refers to it, rightly, as “a predominantly rural area.” In which “over 70% of residents own their homes.” And it is “challenging for residents on lower incomes to afford to buy or rent a home.” Moreover, there is “a reliance on the use of the private car as the main means of transport by residents.” Unsurprising, because Waverley has a low population density compared to the rest of Surrey; indeed, slightly below the average for England.

Overview of my response

First, I’ll make some general comments on the following issues:

1)     The home building target.

2)     The objectives the document sets. It appears to put something it calls “environmental wellbeing” before the well-being of the people of Waverley.

3)     The emphasis on green policies, that are not in the interests of the people.

Following the general comments, I’ll address the specific consultation questions.

The new housing target

Warning to the mathematically challenged: there are numbers in this section!

In Waverley

Waverley’s estimated population at mid-2024 was 134,284 [[5]]. Its area is 345 square kilometres, and the 2024 population density was 389 residents per km2. The average number of people per household is 2.44 [[6]], meaning there are about 55,000 residential properties.

The new housing target is 29,160 over 20 years, or 1,458 per year. This represents an increase of 53% in both number of homes and population.

About 80% of Waverley land is protected from development, either as Green Belt or National Landscape. So, the great majority of these 29,160 new homes need to be built on 20% of the land: just 69 km2. The population density in those places would have to go up by more than 1,000 per km2! I agree with Waverley Council that the target is not a realistic one.

In the UK as a whole

If replicated across the whole UK, this 53% increase would make the population 106 million by 2044. But national estimates currently project a UK population of 76 million in 2044. So, it looks as if Waverley is being singled out for something of a “stuffing.” Or that the government is misleading us, and its real intentions are nearer 100+ million than 76.

A few months ago, I wrote about the UK population increase since 2000: [[7]]. I related it to the number of immigrants needed to keep the “potential support ratio” – of retired people to people of working age – constant. (136 million by 2050, say the UN). I concluded that successive governments since 2000 have been aiming for this extreme scenario, or as near as they can get. They don’t want the welfare state to go bankrupt on their watch.

This explains why whenever a government, Tory or Labour, promises to rein in immigration, it never happens. Immigration rates always go up, not down. This is a political time-bomb.

Objectives and Priorities

The document shows, on page 10, a list of draft objectives. It is divided into three parts: environmental, economic and social well-being. In that order.

We see some typical green mantras. Investment “to support and enhance nature recovery.” New housing with “access to jobs and services by non-car modes of travel.” “Delivering a net zero future.” And structures “resilient to the changing climate.” Lower down, we see: Premises in “sustainable locations.” “Small clusters of green businesses.” “Active and healthy lifestyles.” “Energy efficient new homes.” And “Walking, cycling and public transport are genuine choices for most residents.” I find myself asking, why are mantras like “sustainable locations” and “non-car modes of travel” seen as more important than the convenience and quality of life of the people of Waverley?

Now, I’m not against wildlife; my view is that, if it doesn’t bother me, I won’t bother it. But why should “stakeholders” (a word I detest) put the interests of wildlife or plants above the interests of people, by expecting us to pay for “biodiversity” or “nature recovery?”

My views on green policies

I take the Enlightenment view that to be lawful, any government must act for the benefit of the people. So, everything it does must be a nett positive to the people. Not just in aggregate, but to every individual among those it is tasked to serve. Thus, no government, at any level, may ever set policies that impose on anyone costs that exceed the nett benefits each of them gets. Everyone who has paid taxes must receive commensurable benefits.

My approach to political policy is objective and evidence-based. And I find cost versus benefit analysis, from the point of view of the people affected, to be of vital importance. When I apply this to green policies and arguments for them, I find them very seriously wanting. Virtually all green policies are a major nett negative to large numbers of people, including me.

Sustainability

When I was young, the word “sustainability” meant “ability to endure into the future.” Over the last half century, though, the UN and its fellow-travellers have perverted this into something more like “giving up prosperity today for the sake of future generations.”

This is obviously nonsense. We do not know who these future generations will be, or how close to us in spirit. Further, we have paid taxes, and they have not. So, government ought to be satisfying our needs, not those of unknowns in some unclear future.

It is also my view that centrally planned “sustainable development” can never be sustainable. That isn’t the way we work as a species. By our nature, we do what we can to make our environment of maximum benefit to us. Then, we fix any resulting problems as we find them.

Climate change and “net zero”

The climate does change, and CO2 from human activities can cause some global warming. But I’ve never seen any hard evidence that this has led to actual problems. I’ve shown at [[8]] that there is no climate crisis, that could objectively justify any political action at all.

I regard net zero policies as not only unachievable and unaffordable, but also unnecessary. The arguments for these policies are not based on evidence, but on scares and hype that have been broadcast for years by organizations such as the Met Office, the BBC and a lot of the mainstream media. Not to mention the UN’s Intergovernmental Panel on Climate Change (IPCC), which since 1990 has again and again presented the situation in a far more alarmist way than is warranted by the scientific facts.

As to objective cost-benefit analysis for these policies, a couple of years ago I told, in some detail, the back-story of how the UK government, over decades, has gone out of its way to make sure that no such analysis has ever been done. It’s here: [[9]].

Biodiversity and “nature recovery”

The word “biodiversity” did not even exist before the 1980s. Though a “Convention on Biological Diversity” was one of the agreements at the 1992 Rio “Earth Summit,” the word did not become widely used until the Tories released their “25 Year Environment Plan” in 2018. They subsequently embedded the mantras of “biodiversity net gain” and “nature recovery” in the Environment Act 2021.

The UN has its own counterpart to the IPCC in this area. This is IPBES (Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services). IPBES issued a 2019 report claiming that impacts of human activities were threatening a million species with extinction. But the facts say otherwise: [[10]]. Further, I myself have several times asked environmentalists to name one species to whose extinction I have contributed, and to say what I did, and roughly when, towards that extinction. I’ve never received an answer.

Moreover, it seems to me that the talk of “biodiversity net gain” and “nature recovery” is no more than a switch in the direction of the propaganda; from making unfounded accusations, towards declaiming sound-good mantras. Where is the hard evidence, that proves that these measures are objectively necessary?

Until I see evidence that shows, beyond reasonable doubt, that my own acts have contributed to extinguishing species or in some objective way damaging nature, I refuse to accept any guilt. Nor will I accept any cost to “fix” anything I’m not responsible for!

Air pollution and “clean air”

In the past, air pollution was a real problem. That was exemplified by the Great London Smog of 1952. But, as with climate change, I am not satisfied that the arguments claiming to show that air pollution is a major problem today are either honest or scientific. I wrote about this here: [[11]]. Moreover, I know of no air pollution problems on any road I regularly drive, except perhaps a very short stretch of the A3100 just west of Godalming centre.

There are further similarities with what has happened over biodiversity and climate change. There is a UN agency involved: the World Health Organization (WHO). It has presided over a re-direction of the propaganda, from “air pollution,” via “air quality,” to good-sounding, but ultimately destructive, “clean air” policies.

Moreover, the WHO has been primarily responsible for the culture of arbitrary, collective, ever-tightening and ultimately infeasible limits on what we may do, that has been forced on us over the last 30 years and more. Not only over air pollution, for which the Waverley document quotes the WHO’s latest “guidelines” with almost religious fervour. But also, in its “vision zero” road safety strategy, that has brought ever-reducing speed limits all over our area, particularly on country roads.

Responses to the consultation questions

For those questions to be answered from the perspective of individual settlements, I can speak only for Godalming and Farncombe.

Q5: pros and cons of development approaches?

1)     Development in the 4 main settlements.

a)     Godalming already has a higher population density (2,252 per km2) than Cranleigh, Haslemere or Farnham. It should not be singled out for even more crowding!

b)     Scope for further development close enough to the town centre to allow “more use of sustainable modes of transport” is very limited. The low-hanging fruit – Prime Place, the Atrium, Magna Apartments – is already taken. And such places do nothing to ease housing difficulties for less well-off residents.

c)     Catteshall Lane and The Mill developments have only been achieved by converting office/industrial space to residential use. It would not be sustainable to repeat this.

d)     Significant additions to the Godalming population would put extra pressure on its railway station, and on parking both for it and for shopping and supermarkets.

2)     Development on brownfield sites throughout the borough. This looks to be the least bad of the five options.

3)     Expanding larger centres into the countryside. For Godalming and Farncombe, this has all the drawbacks of approach 1.

4)     Growing smaller villages.

a)     Likely to face significant local opposition.

b)     The council will have to admit that away from the main public transport routes, a car is an essential to live in Waverley.

5)     New settlement. Dunsfold Park is a possible, to combine with approach 2. But why not (tongue firmly in cheek) simply build one high-rise city, to hold 70,000 people? Milton Keynes without cars, perhaps? Of course, you would need to sell the idea to both developers and potential residents. Good luck with that.

Q8: further comment on development?

Quart into pint pot doesn’t go.

Q17: how important is the environment to you?

This whole exercise makes me think that the council is putting something it calls “the environment” up on a pedestal, like some deity to be worshipped. One that makes wildlife and plants more important than human beings. But wildlife and plants don’t pay taxes! So, governments should always put human needs and desires ahead of green nonsense.

As to specifics, places like the Wey canal towpath, Broadwater Park, and the hills surrounding Godalming are surely worth preserving, because of their value to human beings. As is quick, easy, convenient access to wherever each of us needs or wants to go.

Q36: main transport challenges locally?

Context: I used to be a cyclist – I once rode coast-to-coast across North America! But cycling is not practical for someone aged 72, who lives at the top of a steep hill. So, now I am primarily a driver and pedestrian. Though I do ride in a taxi once or twice a week.

1)     As driver:

a)     Far too much parking on through routes, making what should be a two-way traffic flow into alternating one-way (e.g. Chalk Rd, Farncombe end of Nightingale Rd). Worse when the roads have speed-bumps (e.g. Green Lane).

b)     Far too many road works, which far too often close vital roads altogether.

c)     Delays at Farncombe level crossings, even after you have gone over them.

d)     Potholes – though not as bad recently as a couple of years ago.

e)     The sourpusses that want 20mph speed limits, or more chicanes or speed-bumps.

2)     As pedestrian:

a)     Lack of pedestrian crossing(s) on Charterhouse Rd.

b)     Steep hills.

Q38: effectiveness of public transport?

Local public transport has never met, and still fails to meet, my requirements.

1)     At various times, I worked in Shalford, Crawley, Bracknell and Tongham. None of these is accessible time-efficiently by public transport to or from Charterhouse.

2)     Bus 46 is the only public transport that goes within half a mile of my home, or anywhere near its altitude. It’s at best an hourly service, is very slow, is often late, and doesn’t run in the evenings or on Sundays.

3)     To use bus 70/71/72 requires 20 minutes’ walk to/from the nearest bus stop, with a steep climb on the way back.

4)     To use the train without driving to the station requires walking to Farncombe (15 minutes) or Godalming (25 minutes). Both have very steep climbs on the way back.

5)     Public transport is of no use when I have a load to carry. (I play the tuba in a brass band!)

Recently, far from “improving public transport links” around Godalming, the trend has been in the opposite direction. E.G. withdrawal of buses 503 and 523, and re-routing of bus 72 away from Catteshall. And I do not expect any significant improvements in public transport around Godalming in the future, since they could not be commercially justified.

Q39: groups whose transport needs are not adequately met?

Public transport around Godalming does not adequately meet the needs of anyone who:

1)     Lives away from (including above) the major public transport routes, or

2)     Needs to make cross-country journeys, or

3)     Needs to carry loads (including supermarket shopping), or

4)     Is old enough to be no longer able to do “active travel.”

If they (we) couldn’t afford to run a car, they (we) would lose mobility entirely, except for taxis. Which are too expensive to use every day. So, the stated objective of “reducing social isolation and loneliness” isn’t going to happen, if older people in Waverley can no longer afford to drive cars!

Q40: barriers to walking or cycling for daily journeys?

Age and hilliness.

Q52/56: do town and local centre boundaries need to be changed?

For Godalming and Farncombe, no.

Q66/67: climate change and “net zero?”

Since human-caused climate change has never been proven to be a real problem, mitigation and resilience are irrelevant. As to adaptation to weather events, I’d suggest one rule: don’t build on flood plains! (I remember the floods of 1988…)

Q70: allocate sites for renewable energy projects?

No. Windmills are ugly, cause noise that can damage people’s health, kill birds, and can lose blades. How can anyone rational support both biodiversity and on-shore wind power?

Moreover, solar energy doesn’t work at scale in this latitude. Besides which, the intermittency of renewable energy sources causes serious issues for grid reliability, with associated costs. And this, contrary to government narratives, is why electricity prices have gone up and up as the penetration of renewables has increased.

I think this may be a good moment to stop.


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