Following publication of the Draft Local Plan in readiness for the Council’s Joint Scrutiny Committee Meeting on Thursday 15th May, the overriding sentiment is of disappointment.
The senior planning officer told the previous Joint Scrutiny Committee meeting that the Evidence Base was not itself integrated but that it would all come together in the Local Plan and that that was ‘the job of the Local Plan’.
Unfortunately, the inadequacies of the Evidence Base (which urgently needs some major overlays of fundamental information) are only too visible in the Draft Local Plan.
The Evidence Base remains so piecemeal that, either:
a) The officers have a lot of information they have not shared; or
b) They have made numerous guesses (or leapt to various conclusions) which, on the face of it, threatens to fundamentally and adversely impact the Borough and our Town.
This is not about NIMBYism; it is not about where the housing number eventually ends up; it is not even about whether Green Belt is used to accommodate growth; it is not about a 2011 retail report based on ten-year-old data. It is about the whole package. It is about prematurity:
- the SHMA is still being challenged – and the underlying data contested with the Office for National Statistics – who are due to issue a new set of numbers within weeks;
- the fundamental Vision for the town centre has not yet been presented;
- the infrastructure baseline is insufficiently detailed;
- the Settlement Profiles still see more than half of the Borough population living in an amorphous area without definition (the Guildford Urban Area) – and it still has errors such as, for example, that the nearest convenience store to Peasmarsh is at East Horsley (p59) – no wonder we have such cross-town traffic issues in Guildford!.
…and that is just picking up a few of the issues.
The NPPF call for Integrated Evidence is NOT adhered to in this Draft; the senior planning officer has apparently not fulfilled her promise; in this form the Local Plan would be open to challenge for years; in this form, the Draft is not ready for publication as a consultation draft. Pressing ahead through fear of what will happen if there is a delay is not political courage; it is community madness.
To launch this draft spatial strategy for Guildford would be tantamount to sending an astronaut into space without a space suit!
Disappointingly, the draft Guildford Borough Local Plan: Strategy and Sites is NOT YET fit for consultation.
Irrespective of the state of readiness for consultation, this Draft Local Plan reads like a plan WITHOUT AMBITION but accommodating vast development. It exchanges its fear of planning by Inspectorate or of a mad developer feeding frenzy in the absence of a plan for a disjointed wholesale urbanisation of countryside with a series of ‘policies’ 20-123 which neither build on existing characteristics nor do they apply any perceived controls.
Imagine sending a five year-old to the supermarket for the weekly shop with the instruction: “buy some food” and expecting to be able to put together seven square meals for your family with the results and you have some idea of the planning deficit here!
No successful town has managed to assimilate such large-scale development without planned interventions by a strong Council, for example to:
- assemble land areas (often in partnership with a developer or developers) – this might apply to an area like Walnut Tree Close that could be a major new sustainable masterplanned residential quarter
- establish major enabling infrastructure (the GTAMS green snake or golden thread is interesting and environmentally beneficial in the current context, but much more needs to be done to take the traffic canyon out of the town centre)
- regenerate challenging neighbourhoods (the plan notes the presence of several areas in the ‘most deprived’ list for Surrey – and then does nothing to address underlying issues)
Having read thousands upon thousands of pages of this plan and evidence base, there is little to commend it – it seems like a magnified version of the pillories, piecemeal Town Centre Development Plan, which itself was little more than a prospectus of sites that could be developed. Localism and NPPF surely has to offer us more than this to define the next fifteen years for Guildford’s and shape its long term future.
Here are a few notes to accompany this summary – the entire suite of documents has not yet been annotated:
ONS will publish new population projections in Summer 2014 and new household projections a little later in the year. These may differ sharply from the base numbers used for the SHMA and other key evidence.
The plan has, nevertheless, been based on 652 homes. Let’s think about that for a moment. We built around 3,200 homes over the ten years from 2001 – just meeting our targets.
This target of 652 is from 2011 to 2031.
In the first two years of that period we built a total of 491 new homes. Our target for the five years from 2011 up to 2016 when the local plan would be in place) would be 3,260 homes. At the current rate of building, we already have a shortfall of over 400 homes per year for five years to incorporate into our forward planning figures – which transslates to an extra 134 homes per year over fifteen years – and, having consistently fallen short of the new target we may even have to show a five year supply figure of 652 + 134 + 20% = 4,712 dwellings over five years – a shortfall we will have created for ourselves simply by adopting this new target.
So, an adopted target of 652 could easily become a requirement for us, within our seriously constrained supply of land and heavily strained infrastructure, to provide 943 homes per year.
That would be even worse at 1,378 per year for five years if we have to pick up the entire self-inflicted shortfall within the first five years of the Local Plan! (4.28 times our current target EVERY YEAR for five years!). At, say, 2 people per dwelling on average, this would be an annual population growth of 2% – an annualised growth rate not seen in Guildford since the decade from 1881 to 1891, which was driven in part by the enlargement of Guildford Station and improved connections to London (this was a time when Charlotteville and the rows of houses up the hill from Sydenham Road were developed. At 1,378 dwellings per year, this would see Guildford expand by 13.5% in just five years.
Over the Local Plan period (from 2016 by which time it will have been adopted to 2031), we would expect to see 15×652 plus 5×400 = 11,780 new dwellings – a 22% increase in households in Guildford in just fifteen years – and the Local Plan Draft does not begin to set out how the current deficit in infrastructure will be dealt with so quickly. The Draft Local Plan does not highlight the measures that will need to be taken in the communities and neighbourhoods to accommodate such unprecedented growth because the Settlement Profiles are so poor and do not take account of separate neighbourhoods.
THAT IS A CLEAR FAILING OF A NON-INTEGRATED EVIDENCE BASE WHICH HAS NOT ‘COME TOGETHER’ IN THIS DRAFT PLAN
Based on the prematurity of housing numbers, the proposed Green Belt releases are also premature – this could have been dealt with by a subsequent Development Plan Document examined in public and which would have allowed the Local Plan to treat Green Belt as a ‘Constraint’ to the housing numbers but not to shy away from a moral if not legal obligation to consider Green belt releases.
In fact, the problem here is also that the SHLAA suggests some unallocated sites removed from the Green Belt capable of providing 1600 or so homes. This suggests that the removal of land from the Green Belt will not lead to a permanent redrawing of the Boundary.
At the current level of ‘objectively assessed need’ and the proposed adopted housing figure, this suggests you will need to make another major raid on the Green Belt in the next Local Plan as the so-called unallocated contingency would barely last two and a half years beyond the Local Plan – even assuming the other figures are even correct.
The Draft Local Plan does not set out clearly how changes to the Green Belt boundary will be permanent and sustainable.
We have a major infrastructure deficit in Guildford. As a transport hub we are in trouble, and the amount of traffic churning out air pollution in queues in the heart of our town centre is already causing major qualitative blight for residents and visitors to our town.
It cannot be appropriate to add any development to west of Guildford without resolving the limitations of the Farnham Road bridge as the single crossing point over the railway. This is not to ADD capacity but to deal with current constraints.
The Infrastructure Schedule is uninspiring and born out of the shortcomings of the Infrastructure Baseline – which is insufficiently detailed and which fails adequately to deal (in a strategic planning sense) with fundamental flaws within in linking several communities.
The Schedule actually spends significant time setting out a list of initiatives that are listed for delivery in 2014/15 – before this plan is even expected to be adopted.
The Plan does not – as it should – bring forward strategic vision but sets out tactical initiatives already planned. This is poor and disappointing.
Settlement Profiles Report:
Very little policy direction in the Guildford Urban Area – unsurprising since there is not much background information in the Evidence Base.
This really does need an up to date overlay of character statements and a segmented approach to the neighbourhoods – Guildown is not the same as Stoughton, for example – and then some potential positive direction looking at specific opportunities to regenerate areas or enhance them.
These are areas of Guildford housing more than half of the population where there is no Parish Council to respond to the Council questionnaire.
And then there are the transcription errors!
Guildford Urban Area:
“Community Services and Facilities:
Guildford urban area is well equipped with social and community facilities, it offers all of the community facilities and services assessed, and offers more leisure facilities including the Spectrum leisure centre. Northern………………………..” (the rest of the sentence is missing)
Residents within Guildford urban area have access to a range of transport options.” Well some have better access than others…!
Guildford is designated as an urban area and contains a high level of services. As such it could support a level of development which exceeds that of any of the borough’s other settlements. If suitable sites are found, there is the option to extend the urban area to enable more development however this may lead to development away from key services. The sustainability of any extension should be assessed in more detail through other evidence base studies. This will include further work to assess the level of infrastructure needed to support the level of growth.” – no, this is what Neighbourhood profiles would do – which would allow you to see which areas could support development, which areas might need infrastructure enhancements to enable their development and which areas should accommodate relatively organic development rather than major projects.