At the Joint Scrutiny Committee Meeting on 15th May, Guildford’s Senior Planning Officer, Carol Humphrey, was asked to provide the evidence of integration as this is not in the public domain. In reply, she stated that “there is no obligation under NPPF to prepare an integrated evidence base” and she then went on to quote from the following from paragraph 158 of the National Planning Policy Framework:
- Each local planning authority should ensure that the Local Plan is based on “adequate, up-to-date and relevant evidence about the economic, social and environmental characteristics and prospects of the area.”
She did add the word ‘proportionate’ but she not finish NPPF Paragraph 158 (Using a proportionate evidence base), the remainder of which reads:
- Local planning authorities should ensure that their assessment of and strategies for housing, employment and other uses are integrated, and that they take full account of relevant market and economic signals.
National Planning Policy Guidance (NPPG) says:
“Appropriate and proportionate evidence is essential for producing a sound Local Plan, and paragraph 158 onwards of the National Planning Policy Framework sets out the types of evidence that may be required. This is not a prescriptive list; the evidence should be focused tightly on supporting and justifying the particular policies in the Local Plan. Evidence of cooperation and considering different options for meeting development needs will be key for this process.
The evidence needs to inform what is in the plan and shape its development rather than being collected retrospectively. It should also be kept up-to-date. For example when approaching submission, if key studies are already reliant on data that is a few years old, they should be updated to reflect the most recent information available (and, if necessary, the plan adjusted in the light of this information and the comments received at the publication stage).
Local planning authorities should publish documents that form part of the evidence base as they are completed, rather than waiting until options are published or a Local Plan is published for representations. This will help local communities and other interests consider the issues and engage with the authority at an early stage in developing the Local Plan.”
Guildford is being asked to take on a massive amount of housing which can only really be considered IF the evidence base is integrated in terms of the assessments of housing, employment and other uses (as required by Paragraph 158 of NPPF) and they should focus tightly on supporting and justifying particular policies – in other words we should be able to see the train of thought and the evidence on which that is based.
As an example of the challenges inherent in a non-transparent approach, the policy of 40% to 45% affordable housing is set out in the Local Plan draft, as is the requirement for CIL contributions. The viability of developments with CIL and a high affordable housing threshold is not covered in the evidence base and so it is not clear that the affordable housing policy is truly deliverable – developers will negotiate reductions in affordable housing quotas due to lack of viability. This means the affordable housing target may not be sustainable and so the Local Plan may fail on a reasonable test of probability of outcomes. This is only one such example, but the effects of getting affordable housing allocations wrong can be seen in London where Ken Livingstone’s 50% affordable housing target led to a massive contraction in development as schemes ceased to be viable – even in high value areas.
Key to the allocation of sites is the suitability and completeness of the Settlement Profiles which should help inform the needs of local areas and, frankly, the opportunities to enhance sustainability of settlements through development. This MUST be a part of the Evidence Base which informs the assessment of housing strategies – ergo, it must be part of an integrated evidence base.
If the senior officer’s line is that there is no need to have an integrated evidence base, it will be small wonder if the policies and allocations fail, when put to the test.
This is not the time for semantics. This is a time for excellent, unimpeachable, up-to-date and joined-up evidence to inform and shape a sustainable Local Plan that gets Guildford to where we collectively need to be.
If bad decisions are based on good evidence, that is politics. If poor decisions are based on inadequate evidence, that would be negligence. Our Councillors need the highest standards of evidence (in the same way that good maths students show their workings) and we need to keep the pressure on our Councillors to make great decisions.