Last week (21st November 2017) the Full Council of Guildford Borough voted to submit its Local plan for Examination in Public by the Planning Inspectorate.
The plan has been subjected to an unprecedented amount of scrutiny and the Guildford Society has been through the tens of thousands of pages of drafts, evolving evidence base, consultation documentation and responses by other groups. This has been a major endeavour and we know, from their findings, that, however much they share the desire to have a Local Plan in place, this plan has some substantial flaws.
There are some political differences of opinion – the Sir Paul Beresford MP (Mole Valley) approach of ‘pile development high in the centre of Guildford to save development in his back yard’ (my words) versus the ‘spread out into a small percentage of the 89% of the Borough that is in the green belt and leave our town alone’ arguments. The truth is, there probably needs to be some of both things.
For far too many years (probably since the 1970’s) we seem to have been afraid to regenerate the town and we have failed to plan for enough homes in the rural communities – our young people have to move away because there is no realistic choice of staying local.
This planning inertia, however, hides a much greater failing by our politicians over the past twenty years or so.
- The failure to provide good enough infrastructure (of all kinds, be it education, health, utilities, roads, alternative transportation, etc);
- The failure to plan to unlock brownfield sites – perhaps allowing for increased density in some of the urban area estates where 15 dwellings per hectare is a norm, and wherever there are pockets and wider areas of relative deprivation that register on the national and not just the local scale; and
- The absence in the local plan of a cohesive vision for the town centre.
These failings are the main reason why green field development is required for this plan.
We need to provide for the development of sufficient homes to buy the time (which should have been invested for the past two decades by our politicians) to develop brownfield land.
It would make sense if there were an articulation of the interim nature of this local plan, aiming at ensuring that we do not need to raid the green belt for the next two or three plan periods at least. But there is no such strategic direction in the plan.
We know that the plan aims to provide 12,426 homes over the plan period, and that the Government’s simplified calculation of the Objective Assessment of Need suggests a further 2,600 homes would be needed in the same period. The plan suggests how it might deliver the 12,426 homes, including over a phased ramp up period from 2019 (450 homes) to 2034 (850 dwellings). The plan does not, as required by the National Planning Policy Framework, 2012 and National Planning Policy Guidance, 2014 (as amended), look ahead beyond the current plan period.
The Solum Inquiry heard that the Solum development “complies in all respects with the emerging Local Plan”.
The Guildford Society has made the comment that under this plan we do not know what we expect Guildford to look like in 15 years’ time. We do not know what our skyline will look like in the town, whether there will be adequate protection of key views (the Solum argument being that any harm done to views and settings of listed buildings may be outweighed by benefits – such as contributing to the housing shortfall). We also do not know if the green belt will be adequately protected, either in this plan period and beyond into subsequent periods.
It is a pity that so many key elements are absent from or silent in the submission draft local plan.
From submission of the plan in a couple of weeks’ time, there will be about nine weeks before the Inspectorate give their first feedback to Guildford Borough Council, and thereafter, a couple of months before an anticipated Examination in Public.
It will be interesting to see who will come to that Examination with planning consultants and QCs at hand, and who will sit this out with their fingers firmly crossed, hoping it will all work out in the end.
The Guildford Society and Guildford Vision Group have both been vocal and have contributed substantial detail in response to the consultations. It is likely both organisations will seek to take an active part in the process and will probably look to members and supporters to help them. No doubt the various green belt groups will require similar support to enable them to take part.
This could be the most significant watershed in the history of our town and borough, and is to be hoped, through active engagement, and with the diligence and expertise of a good Planning Inspector, we may end up with a plan that is fit for purpose. It is entirely rational, however, to fear that this will not be the plan to protect and save Guildford, its long-term green belt boundaries or its beautiful heritage town centre.
26th November 2017