Public Scrutiny to Begin

Following a long introduction – almost entirely hijacked by Housing Numbers and Green Belt issues, the Guildford Draft Local Plan opens for Public consultation on 1st of July for 12 weeks.

The Guildford Society will be hosting an open meeting on 17th July to introduce its view on the document itself and will follow that by a further session in September to present its proposed representation.  You can find out more about these and other GSoc meetings at http://www.guildfordsociety.org.uk.

There are some very key issues in the draft document – all of these need thorough examination along with the associated evidence base (which will be reproduced on this site at the launch of the consultation so that we can assess the report against the evidence base at the time and not be hoodwinked as the evidence evolves.

The Green Belt and Countryside Report (with its thousand or so page addendum) will energise many and as a starting point, it is disappointing that this report – flawed in its conception prior to the 2012 NPPF and in its failure fully to capture the options and its pejorative treatment by the planning department.  That is a legitimate target for analysis and representation in responses to the Local Plan.

My own (Julian Lyon) view is that the Green Belt report and its treatment in the draft Local Plan is half-baked and therefore not ready to form a key plank of this significant planning policy document.  The Green Belt, in my clear opinion, remains a constraint as far as the capacity of the Borough for development is concerned.  This should, therefore, inform the housing target.

Please do not confuse this assessment with an absolute rejection of the principle of realigning the green belt or allowing some development in the green belt.  It is not.  If the case were proven that real harm would be inflicted on Guildford and the Borough, the remedying of which would outweigh the harm to the Green Belt of releasing some strategic sites, this would be legitimate grounds for advancing each case on its merits.  What it is, however, is the recognition that the debate over the relaxation of a legitimate constraint risks scuppering or substantially emasculating the entire Local Plan.

It is also the case that the evidence is not yet so overwhelming and emphatic as to demonstrate an absolute imperative to realign the green belt.

My recommendation is to treat the Green Belt as a constraint for the purposes of the Local Plan, anticipate that we will fall short of the Objectively Assessed Housing Need (unconstrained) and plan for an early review of the Green Belt as a separate exercise undertaken with neighbouring Local Authorities (ideally on a Surrey-wide basis) to ensure the integrity and long-term protection of the Green Belt is maintained.

Such a twin-track approach has been undertaken elsewhere (Dacorum’s Local Plan was found sound because, despite selecting a target number below Objectively Assessed Need, they committed to an early review within five years.

This leads on to the Housing Numbers which have caused much angst.  On this site I have tried to provide an objective analysis of the data and the reasoned assessment of the reports.  I find it very difficult to reconcile the outputs provided by GL Hearn in their Strategic Housing Market Assessment (SHMA) and the response a group of local experts received when we challenged them.

The key point to note – before the detailed analysis takes over – is that the draft Local Plan number of 652 (which may yet change between now and 1st July) was derived from data before the Office for National Statistics adjusted the population projection downwards (see elsewhere on this site for details).  We can expect robust arguments to the effect that this number should be significantly reduced.

There is a policy in the Draft Local Plan (Policy 4) which sets out to fix a problem of the affordability of homes for those on the housing list (about 3,500 – remaining resolutely constant year on year) and for key workers who currently have to commute large distances to their places of employment.  Fixing this is a reasonable aspiration, nobly led by Councillor Creedy, and so the policy sets a level of 40% (45%) of new brownfield (Green Belt) homes to be affordable.

In the Surrey Advertiser (20th June) page 4, are two development proposals which together total 58 units.  The schemes are being brought forward under the 2003 Local Plan which has as its target 30% affordable homes.  There is a get out for developers who do not have to provide this level of affordable housing if it is not viable.  The Surrey Advertiser reports that “affordable housing was judged by applicants to not be viable on either site” and this at 30%.  One has to question, therefore, whether a policy based on self-assessment by the applicants and which would have determined the amount the applicants paid for the land (to the extent that if the policy is weak the highest bidder for the land might assume minimal affordable housing) could ever deliver the numbers of affordable homes Guildford needs irrespective of the housing target.

GL Hearn stated clearly that their assessment of the housing need was substantially driven by the non-affordability of homes in Guildford.

There are three further topics for consideration at this point which are worthy of greater scrutiny:

  • Employment Land and Employment Growth
  • Infrastructure and the historic Infrastructure Deficit
  • The Town Centre Vision

I do not propose to go into detail on these except to highlight that the Town Centre should be regarded as key infrastructure for the Borough as a whole – albeit it contains and requires its own infrastructure.

There are no clear links between Employment, Infrastructure constraints and Housing numbers.  The NPPF is clear in its call for Local Plans to show clearly that these aspects are integrated.  This Draft Local Plan is based on some very poor evidence (shortcomings identified here on this site and elsewhere) although there may be a flood of new evidence documents published as the consultation goes out.

There is no real attempt to establish the CAPACITY of Guildford for growth and there is no clearly set out strategy for increasing that capacity through the Local Plan to meet the objectives of the Local Plan itself.

For this reason I spoke at the Joint Scrutiny Committee meeting several weeks ago to say the plan is not yet ready for consultation.  At the Full Council meeting on 19th June fourteen of the forty-one Councillors to vote one way or the other agreed with me.

Twenty-seven did not and so the consultation begins and we have to tackle both the shortcomings of the document itself as well as its content.

As an aside, I would be surprised if we do not see applications from several land owners in the Green Belt come forward with Outline Planning Applications over the next several weeks.  Pandora’s box is open and the responses we give to the Local Plan process may well need to be replicated to the extent the applications are premature, inadequately provided with infrastructure due to the historic deficit or that the harm done to the Green Belt outweighs any Very Special Circumstances they may argue as mitigation for their proposals.

The ball is in play, the game is in progress and we are told that every view will count so, whatever you do, do not rely on someone else to make your points for you.  Respond for yourself and help to shape responses of groups like The Guildford Society.

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About 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