Getting the Plan Right First Time

As the Guildford Local Plan Examination in Public progresses, I am reminded of the proposed North Street Development Brief and Town Centre Interim Frameworks that the Council was seeking to introduce in 2012.

Three things come to mind:

1. Planning Rules

NPPF and the 2012 Planning Regulations had both been adopted by the Government – and remain in force today and have done throughout the preparation of the Local Plan post-2012.

NPPF (Paragraph 153) says: “Each local planning authority should produce a Local Plan for its area. This can be reviewed in whole or in part to respond flexibly to changing circumstances. Any additional development plan documents should only be used where clearly justified.”

The Town and Country Planning (Local Planning) (England) Regulations 2012 say at Clause 8 (Form and content of local plans and supplementary planning documents: general):

8.

  1. A local plan or a supplementary planning document must—
    a) contain the date on which the document is adopted; and
    b) indicate whether the document is a local plan or a supplementary planning document.
  2. A local plan or a supplementary planning document must contain a reasoned justification of the policies contained in it.
  3. Any policies contained in a supplementary planning document must not conflict with the adopted development plan.
  4. Subject to paragraph (5), the policies contained in a local plan must be consistent with the adopted development plan.
  5. Where a local plan contains a policy that is intended to supersede another policy in the adopted development plan, it must state that fact and identify the superseded policy.

The combination of these regulatory instruments is that, for a Local Plan to be positively prepared, it should not start out with an expectation that a Development Plan Document (DPD) will be required imminently upon adoption of the Local Plan.

For the Town Centre Regeneration Strategy to be implemented will require an Area Action Plan for the Town Centre which will need to be a DPD.

2. Knowledge

GBC were aware at that date that the town centre should be planned as part of the Local Plan process – because GVG provided two QC opinions to demonstrate to the Council that it would be unlawful to adopt documents that SHOULD have had Development Plan Document status.

Both QC Opinions were provided to the Council at the time and this led to the demise of the then Council Leader, Cllr Tony Rooth

https://www.guildford-dragon.com/2012/09/21/executive-member-resignation-led-to-council-leaders-departure/

That was almost six years ago and in the meantime, the Guildford Vision Group – a group of mostly retired professionals have, without much resource except for good will, brought forward a plan for the town centre that is well thought through and aspirational, whilst aiming to deliver a town centre that has a good mix of uses, plenty of public open space, pedestrianisation and (following discussions with the bus companies) accessible by public transport.

Why, in all this time, has the Council achieved so little for the town centre?  Probably because it has been so heavily focused on the A3 (beyond its control), and this because its Spatial Hierarchy is so heavily weighted towards Green Belt sites.

3. Spatial Hierarchy

GBC’s own plan and the accompanying Sustainability Appraisal set out clearly what the sequential hierarchy is for development – and Guildford’s own response to the Inspector’s pre-Examination questions shows that they recognise the sequential approach.

http://www.guildford.gov.uk/newlocalplan/CHttpHandler.ashx?id=24623&p=0 (paragraphs 6.6.4 and following) set out the Spatial Hierarchy in order of priority with the most sustainable first:

Tier 1 – Guildford Town Centre

Tier 2 – Guildford Urban Area

Tier 3 – Ash & Tongham Urban Area

Tier 4 – Built-up Area of Villages

Tier 5 – Village ‘Gap’ Sites

Tier 6 – Brownfield in the Green Belt

Tier 7 – Countryside Beyond the Green Belt

Tier 8 – Green Belt Around Guildford

Tier 9 – New Settlement

Tier 10 – Green Belt Around Villages

Table 6.3 (page 36) shows that in each of the Options from Tiers 1-6 and 8, the developments were treated as a ‘Given’ (or ‘maxed out’).

The Guildford Society has continually and consistently made the point that the Settlement Profiles Report is not fit for purpose:

https://www.guildford.gov.uk/media/15088/Settlement-Profiles/pdf/Settlement_profiles.pdf (accessed 17th June 13:48)

The report makes the point that: “Each section concludes with commentary regarding the extent to which we feel each settlement could support additional growth. We have based this on a range of considerations including the category of settlement and environmental constraints. This does not include whether there is available capacity on land in that area. Those with a very poor range of services and facilities that have scored low within the settlement hierarchy are not sustainable locations. In accordance with national policy, we should be directing development towards sustainable settlements only.”

The Society has noted that this misses the point in some respects, because there should also be an assessment of what development might help to make the settlement sustainable.  In general, the principle of the approach sounds fine.

The conclusion for Tier 3 – Ash & Tongham Urban Area (which represents about 20,000 people or 14% of the Borough’s population, and which warrants only 3 pages in the report) says: “Ash and Tongham is designated an urban area and contains a high level of services. As such it could support a level of development in the future which exceeds that of any of the borough’s other settlements with the exception of Guildford urban area. The land to the east of the urban area is designated as countryside in the NPPF. There is the option to extend the urban area into the countryside to enable more development. However, this may lead to development located further away from key services. We will need to carry out further detailed work to assess the sustainability of any extension.

As the current version of the Local Plan Evidence Base, this should have been updated to explain the results of the “further detailed work”. This should have identified Options that would then have been carried forward into the Sustainability Appraisal – or, if it really is a ‘Given’, this should have been clearly explained in the Settlement Profiles Report.

There is no settlement report for Guildford Town Centre, and so Tiers 1 and 2 are both amalgamated into the Guildford Urban Area (representing a population of 73,779 – just over half of the Borough’s population, and warranting two and a half pages in the Report).  Here the report says: “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.

Here, therefore, we would assume that the greatest proportion of development would have been planned for Tiers 1 and 2.

The Sustainability Appraisal options for various growth scenarios show the following (Table 6.3):

Option Scenario Overall Tier 1 Tier 2 Tier 3 % Tier 1 % Tier 2 % Tier 3 % Tiers 1-3
1 Lower growth options          13,600          1,150          1,368               79 8.46% 10.06% 0.58% 19.10%
2 Higher growth option for variable 3          14,080          1,150          1,368               79 8.17% 9.72% 0.56% 18.44%
3 Higher growth option for variable 1          14,200          1,150          1,368               79 8.10% 9.63% 0.56% 18.29%
4 Higher growth option for variable 2          14,600          1,150          1,368               79 7.88% 9.37% 0.54% 17.79%
5 Higher growth option for variables 1 and 3          14,680          1,150          1,368               79 7.83% 9.32% 0.54% 17.69%
6 Higher growth option for variables 2 and 3          15,080          1,150          1,368               79 7.63% 9.07% 0.52% 17.22%
7 Higher growth option for variables 1 and 2          15,200          1,150          1,368               79 7.57% 9.00% 0.52% 17.09%
8 Higher growth option for all three variables          15,680          1,150          1,368               79 7.33% 8.72% 0.50% 16.56%

 

There is nothing in the Settlement Profiles Report that suggests this set of scenarios is a reasonable response to the spatial planning hierarchy, nor that this is a sustainable plan.

Conclusion

For the Town Centre Regeneration Strategy to be implemented – which shows an option to include additional homes in the Town Centre – it follows that the process of preparing the Submitted Local Plan has not been positively done.

The case for Exceptional or Very Special Circumstances for putting forward land in Tiers 8 to 10 may have been based on a false premise.

The Guildford Vision Group Plan shows that yet more town centre homes could have been identified.

The Guildford Society has said, in its representations to each stage of the consultation, that the Council has failed to look properly at the remainder of the Guildford Urban Area.  The Society provided a helpful summary of statistics for each area (Lower Super Output Area or LSOA) which shows – as below – the characteristics of the urban area are highly diverse.

Tier General Area (GSoc Description) LSOA dpH Band C or Lower All Rented Social Rented
Urban Area Stoughton 006A          33.22 41.47% 35.88% 12.09%
Urban Area Woodbridge Hill 006B          28.65 54.61% 26.94% 1.76%
Urban Area Stoughton (N) 006C          29.35 66.83% 27.06% 17.33%
Urban Area Stoughton – Grange Road 006D          21.26 45.72% 22.96% 9.08%
Urban Area Bellfields (N) 007A          17.13 69.42% 40.68% 28.73%
Urban Area Slyfield 007B          15.10 28.31% 36.13% 24.02%
Urban Area Bellfields (S) 007C          15.21 78.43% 63.45% 52.82%
Urban Area Slyfield (E) – includes Employment & SARP 007D            4.23 1.96% 43.76% 29.03%
Urban Area Burpham (Sainsburys) – includes A3 008A            9.99 61.82% 30.57% 0.93%
Urban Area Burpham (E) – includes part of Gosden Hill Farm 008B            7.15 12.50% 16.01% 7.77%
Urban Area Merrow Park 008C          19.16 15.83% 35.49% 17.15%
Urban Area Merrow Common – includes some Green Belt land 008D          11.66 8.00% 19.44% 3.45%
Urban Area Bushy Hill 008E          25.40 7.70% 47.00% 36.67%
Urban Area Worplesdon Road (N) 009A          22.65 53.54% 14.31% 2.41%
Urban Area Westborough 009B          22.37 25.05% 53.67% 39.74%
Urban Area Aldershot Road (E) 009C          19.46 54.01% 32.59% 7.59%
Urban Area Shepherd’s Lane 009D          23.47 31.79% 14.75% 2.11%
Urban Area Burpham Weylea Farm – includes part of A3 011A          15.74 6.19% 21.73% 0.79%
Urban Area Boxgrove 011B          10.91 4.37% 17.08% 2.19%
Urban Area Abbotswood – includes Spectrum site 011C            7.39 7.65% 12.01% 1.05%
Urban Area Horseshoe Lane – includes part of Merrow Downs 011D          10.10 9.66% 14.80% 5.61%
Urban Area Merrow Downs – includes large part of the downs 011E            2.58 64.91% 12.80% 2.11%
Urban Area Dennisville & Manor Park – includes sports ground 012A            2.99 0.76% 37.92% 8.49%
Urban Area Park Barn (W) 012B          25.13 0.45% 51.73% 38.35%
Urban Area Park Barn – includes the school 012C          19.77 24.81% 63.28% 47.54%
Urban Area Park Barn (E) 012D          20.38 15.89% 74.56% 59.94%
Town Centre Stoke Park & London Road – includes Stoke Park 013A            7.94 30.42% 30.43% 7.24%
Town Centre Ladymead & Stocton Road – includes Retail Park 013B          20.45 13.13% 43.49% 10.25%
Town Centre York Road – includes non residential uses 013C          38.25 13.63% 53.31% 19.73%
Town Centre Epsom Road & Waterden Road 013D          31.84 10.00% 43.34% 1.37%
Town Centre High Street & Sydenham Road 013E          19.01 41.97% 47.49% 10.54%
Town Centre York Road (E) 013F          45.49 36.65% 57.37% 12.69%
Town Centre Walnut Tree Close & Station – includes other uses 015A          15.14 12.84% 43.47% 11.11%
Urban Area Onslow Village (W) 015B            9.52 9.59% 9.89% 1.08%
Town Centre Guildford Park, Cathedral, University Main Campus 015C            5.96 20.90% 58.59% 21.88%
Urban Area Old Palace & Poltimore 015D          15.62 5.22% 34.62% 22.24%
Urban Area The Mount & Guildown – includes AoNB 016A            3.70 55.57% 15.94% 0.31%
Town Centre Portsmouth Road 016B          21.83 45.38% 43.31% 16.00%
Urban Area Pewley Down – includes the downs and Tyting 016C            1.78 19.56% 28.13% 8.59%
Urban Area Pewley & Shalford Park – includes part Chantries 016D            2.87 78.97% 9.54% 1.24%

 

At higher density, it is reasonable to assume a substantial increase in homes could be promoted through the Local Plan process, but little has been done.

Below are links to the full dataset provided as the Society’s 2014 consultation response:

20140904_LandUses-MSOA-LSOA_FINAL

and the updated analysis of LSOAs submitted in response to the 2016 consultation:

20170714_IMD-Charts_FINAL_V3

In each case, by using the LSOA code in the third column above, it is possible to demonstrate the relative deprivation of this specific area relative to the 32,844 LSOAs in England.

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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