Supplementary Green Belt Study

Guildford Borough Council has today (30th April 2014) published an addendum to Volume 2 and a new Volume 5.

Together these documents add a further 485 pages to the Evidence Base.

Clearly this will take some time to digest and so I have provided them below – in two large files incorporating all of the appendices.

20140430_GreenBelt-Vol2_Addendum (176Mb) and 20140430_GreenBelt-Vol5 (316Mb).

Unfortunately, the plans in the appendices have not been optimised for web viewing which is why the files are so large.

If you would prefer to download them in smaller doses, the Guildford Borough Council link is:

As we will soon be expecting the Draft Local Plan to be issued for consultation, the opportunity may be short to study these documents in great detail.  If it can be done it will be done, and you will be able to read any comments on this site in due course.


Author: GuildfordPlan

GuildfordPlan is a 'whiteboard' set up by Julian Lyon to think out loud as part of the process of preparing the Guildford Society representations to the various Local Plan Consultations

8 thoughts on “Supplementary Green Belt Study”

  1. The comment on the introduction is that “To help with the Local Plan strategy and sites document, we need to have a good understanding about how much growth we should be planning for. National planning policy (the National Planning Policy Framework) says that our Local Plan should meet our full objectively assessed housing need. Our work shows that we are unable to meet these needs from development in the urban areas and villages.” This is incorrect and misleading, on a number of counts:

    1. Objectively assessed housing need has NOT yet been determined. There were a large number of errors and miscalculations identified in the Strategic Housing Market Assessment (SHMA) which gives rise to a pre-constraint assessment of market need. This led to a significant inflation of apparent need, generating apparent growth within Guildford alone of 30%, while the national projection for the same period is 11%.

    2. Objectively assessed need should be subject to constraints, and does not need to be met in full. Furthermore, the guidance given to Inspectors by the Secretary of State is clear that constraints should be applied to that value in order to determine how much of that “need” can be met locally- see letter from Nick Boles 3 March 2014- which is in accordance with the National Planning Policy Framework and indeed quotes from it verbatim, stating the local authorities “should meet objectively assessed needs unless specific policies in the framework indicate development should be restricted. Crucially, Green Belt is identified as one such policy”. Nothing in any subsequent letter deviates from this guidance.

    3. A brownfield land study is currently being completed by Scott Brownrigg, as is a Guildford urban master vision by Allies & Morrison. We do not yet know what these studies will show. In any event, the national database of previously developed land shows that Guildford has substantial previously developed land within the urban area. Allies & Morrison, in conversation, were very receptive to the idea of a major urban regeneration zone along Walnut Tree Close to the A25, on both banks of the Wey. This could involve substantial residential development at appropriate urban densities; and it is arguable, that, with a realistic housing target, Guildford has sufficient land to meet all its real requirements within the urban boundary.

    Susan Parker
    Chair, Guildford Greenbelt Group.

    1. I accept your demand-side remarks and also reference to alternative sources of supply – these will inevitably need to be weighed up in the Local Plan as it emerges.

      This Green belt & Countryside Report (with addenda and supplementary volume) is a supply-side analysis that looks at the relative merits of parcels of green belt land.

      It is fair to say that sites in the Green Belt come forward under the very special circumstances rules between Local Plan processes – and are treated on their respective merits under the Planning Regulations.

      In this case, I have not seen anywhere an attempt to suggest that the Exceptional Circumstances exist for any of the ‘Potential Development Areas’ to be removed from the Green Belt. This will be a case to be made if any realignment is proposed – and I fully anticipate Guildford Borough Council would expect some robust representations to the extent that no exceptional circumstances exist.

      I look forward to the debate and I hope it will be constructive and that it will take account of the wide range of needs that depend upon the Local Plan for their satisfaction.

      In the meantime, thanks for your comments.

  2. On first opening…. in your appraisal documents ammended – you fail to identify that C1 is in actual fact a plot bordered by Merrow common not housing – included in this site is three sections of ancient woodland alson missing from the identification – the Ancient woodland stopped further encroachment into green belt since 1949 instigation of the preservation order on this woodland as trees to the North east of Merrow Lane were not under threat the order at that time never xtended past the road – this order should now extend past the road to the edge of the Arable land.

    Land parcel C1 also fails to mention SNCI but not the Ancient woodland or common land status

    As for access if you exclude the common land and ancient woodland Merrow lane is the boundary and does not cross this land… and there is no Urban in this area it is all country side with some rural buildings
    Thus in fact there are two parcels of land the Merrow common ancient woodland which seperates Gosden hill farm package from the Edge of the Gosden hill road properties and the true farmland of Gosden hill farm – attempting to join together common land & ancient woodland with tree preservation orders on it with farm land is a deliberate attempt to prove a negative…

    Without reading further I will presume your other favoured buildings sites have been treated in a siumilor derogitory manner while those who have shouted from the roof tops wwaving their wallets and specialist knowledge have been treated with less derision and contempt.

    1. Hi Jim. If you want to comment to GBC please make sure you comment on their document to them. I am just reporting on the documents and will give my comments in due course as before.

  3. Since I posted my first comment above, Guildford Borough Council has issued a second press announcement stressing that no decisions have yet been made about sites to be developed. They have also modified the website version of the first press announcement, so that the incorrect statement (quoted above) re the NPPF has now been deleted.

    I hope that this indicates that GBC have started to listen to the community in Guildford, but given the cavalier, inaccurate and at times ignorant responses to the detailed comments made on the Issues & Options consultation, I am not hopeful.

    It is notable that Greg Mulhollland MP is using a ten minute motion this evening to raise the fact that NPPF requires local authorities to consult with communities, but that this is often ignored by planners and developers. It is certainly true of Guildford’s planners. Had GBC consulted with the communities of Guildford Borough, rather than with developers, over the last year or two, perhaps they would not need to amend a press announcement and issue a supplement as well on the day of issue. Try getting it right first time, GBC (- and also make sure you consult the whole community. The whole borough pays council tax – so please don’t always ignore the countryside voters).

    Eagle Radio are hosting a forum next week for Guildford Borough Council (I’ve not been invited on the panel). GBC commented that they wanted to consult “real” people (clearly all the people who responded to the issues and options consultation were imitation people. That comment was also subject to a revised announcement and is no longer visible on the website).

    Many people took very considerable time and trouble to respond to consultations on the Issues and Options consultation and to the SHMA. We expect GBC to take time to read those responses and trouble to amend the Local Plan to reflect the views of the community. Consultation does not just mean a process of asking questions – it also means listening to the answers and changing plans accordingly.

    If Guildford do not recognise those responses in the draft Local Plan that we anticipate in the next few weeks, then there is a failure in local democracy. If so, then GGG will be willing to stand for election for the Local Council next year in order to resolve the problem.

    Susan Parker
    Guildford Greenbelt Group.

  4. I hope our townies will speak up strongly for the Guildford countryside, which is as much a resource for them as for those who live there. The Green Belt is a major covenant to our children and grandchildren, not to be thrown away for a bit of short-term “development”.

    Guildford Borough Council seem to think local opposition can be bludgeoned into submission by piling up more consultancy reports (alias “evidence”).

    They are wrong, because we do actually read this stuff and take issue with it.

    Take Vol IV of the Green Belt and Countryside Study – a masterpiece of obfuscation by property consultants Pegasus. Paragraphs 13.16-17 deliberately misrepresent the terms “openness” and “open character” used in the Government’s National Policy Planning Framework (or NPPF) to define one of the main purposes of the Green Belt.

    Common sense says that “open” countryside is any which is continuous and uninterrupted by built development. But Pegasus narrow this down to countryside perceived as exposed to distant view or observation. The first, simple definition relates to what’s on it, and so to its ecological value; the other only refers to what it superficially looks like. It is nonsense to argue that the intention of the NPPF is to say that woodland or highly indented natural landscapes cannot be “open” countryside and therefore shouldn’t be in the Green Belt – that only wide, open country views should be. Incredibly, however, this is how Pegasus come to argue that most of the borough’s villages should be kicked out of the Green Belt.

    Pegasus argue that paragraph 86 of the NPPF oblige them to take the “perception” of Green Belt openness into account. But the NPPF doesn’t even mention perception. On the contrary, it plainly states that a village surrounded by Green Belt should stay there if this makes an “important contribution” to stopping development constricting the Green Belt’s openness. Since no further elucidation of “openness” is offered in any Government guidance, it is the obvious, commonsense definition that counts and which is sure to win the argument in any procedural or legal contest in future.

  5. Much of what GBC want to do the Green Belt is now simply impossible – their policy of wholesale revisions to the Green Belt boundary is not possible. This is because of a Planning Court judgement issued just a few days ago. It is of course a complex judgement, as these tend to be, but it lays down, in no uncertain terms, what is necessary for revisions to the Green Belt boundary. A few quotations later, but GBC seem to think they are able to change Green belt boundaries at will because they are producing a Local Plan. This is simply not the case, they have to demonstrate “exceptional circumstances” and what constitutes “exceptional circumstances” is laid down in law. So GBC’s Local Plan process is in tatters, in the light of this judgement they will have to go back to the drawing board. The scope of the brown field study will have to extended with a healthy dose of realism.

    Some quotations from the Approved Judgement (Case No: CO/17668/2013)
    From paragraph 125
    “However, it is not arguable that the mere process of preparing a new local plan could itself be regarded as an exceptional circumstance justifying an alteration to a Green Belt boundary. National guidance has always dealt with revisions of the Green Belt in the context of reviews of local plans…… and has always required “exceptional circumstances” to justify a revision. The NPPF makes no change to this.”

    “Exceptional circumstances are required for any revision of the boundary, whether the proposal is to extend or diminish the Green Belt.”

    “Whilst each case is fact-sensitive and the question of whether circumstances are exceptional for these purposes requires an exercise of planning judgment, what is capable of amounting to exceptional circumstances is a matter of law, and a plan-maker may err in law if he fails to adopt a lawful approach to exceptional circumstances. Once a Green Belt has been established and approved, it requires more than general planning concepts to justify an alteration.”

    From paragraph 130
    “In other words, something must have occurred subsequent to the definition of the Green Belt boundary that justifies a change. The fact that, after the definition of the Green Belt boundary, the local authority or an inspector may form a different view on where the boundary should lie, however cogent that view on planning grounds, that cannot of itself constitute an exceptional circumstance which necessitates and therefore justifies a change.”

  6. but how does that interlink with insetting of villages? is that different from changing the Green belt boundary?

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