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):


  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that is intended to supersede another policy in the adopted development plan, it must state that fact and identify the superseded policy.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

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. (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: (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.


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:


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


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.

Guildford Society Hearing Statement

The Guildford Society has submitted its Hearing Statement to the Inspector’s Programme Officer ahead of the Guildford Local Plan Examination in Public which begins on 5th June.

Here is a full set of the GSoc documents:

(cover letter)

(main document)

(GSoc SANG Paper by Alderman Bridger)

(GSoc Infrastructure Topic Paper by the Transport Group)

(Correspondence requesting confirmation from GBC on which if any groups were excluded from interacting with officers at the Council)

(copy of internal email instruction to officers to not engage with the Guildford Vision Group)

(Correspondence requesting explanation from GBC about the £5m contribution agreed with the Dunsfold developers to mitigate against impact of development on Guildford)

(Guildford Borough Council response on Dunsfold showing an increase of traffic on the gyratory of circa 300 cars over the three peak hours)

(Agreed Statement of Common Ground with the Guildford Vision Group – highlighting GSoc’s support for the GVG Master Plan)

(file 9 is a large (160mB) document containing the GVG Master Plan)

Representations were limited to 5,000 words and (headings apart) the GSoc response keeps to that restriction, albeit many comments the Society would have wished to make were omitted.

This submission follows the previous responses to the earlier consultations on this draft Local Plan which can all be found on this website (referenced below):

The Guildford Society Submission
(response to the Issues and Options consultation 2013)

Guildford Society Local Plan Submission
(response to Local Plan Regulation 18 consultation 2014)

GSoc Local Plan Reg19 Consultation Submission
(response to Local Plan Regulation 19 consultation 2016)

GSoc Response to 2017 R19 Consultation
(response to Local Plan Regulation 19 consultation 2017)

Finally, here is a personal commentary written by the Chair of the Guildford Society, Julian Lyon, at the end of March, following comments by the Inspector on the submission draft local plan:




Guildford Vision Group’s Published Masterplan Document

There has been a question in the media about where to find the GVG published Masterplan.

It has been available (buried in the Guildford Borough Council website) for several weeks.

Here is a copy of it – bearing in mind it remains a live document and has been produced by a non-for-profit group on a shoe-string with fantastic support from Leonard Deign Architects:


This really does show what the Local Plan is missing in the town centre.

Local Plan – comments on Inspector’s Feedback to GBC

As I understand it, GBC has had a QC and a Planning Inspector on its team to try to navigate its course through the Local Plan process.

The report by HM Planning Inspector (Jonathan Bore) dated 23rd March seems to suggest some basic flaws in the draft plan “many of which will require the council to produce Main Modifications to the plan’s policies and text”.

Let’s take a look at the report and Mr Bore’s comments along with some context from the Guildford Society’s comments in respect of the most recent consultation.

Mr Bore begins by challenging the SHMA (Strategic Housing Market Assessment). He questions why there is no analysis of the deterioration of affordability ratios between 2014 and 2016. He highlights the approach taken by GLHearn to adjust the OAN (Objective Assessment of Need) to reflect household formation rates amongst the 25-34 age group and pointed to his (Mr Bore’s) rejection of a similar approach (by GL Hearn) in Waverley.

Mr Bore notes that “the level of identified affordable housing need is exceptionally high“ and requests a paper be produced by the Council to identify the required uplift to the OAN that would be “expected to improve market housing affordability and deliver as many as possible affordable homes”. Mr Bore states that this should be a “policy off” analysis.

It should be noted that one of the criticisms the Guildford Society has consistently made throughout the Local Plan process has been that the Evidence Base has followed the plan rather than the policies being based on the evidence (the latter being a “policy off” approach).

There is a duty to co-operate baked into the NPPF (National Planning Policy Framework) and this should have meant including in the OAN the unmet needs of surrounding boroughs (the majority of whose local plans are more recent and settled). Mr Bore requests a paper from Guildford Borough Council to demonstrate how unmet housing need in the Housing Market Area will be accommodated.

Mr Bore expresses his concern about the Council’s proposed stepped housing trajectory (however sensible that may be under the circumstances) and says “this appears to be an unacceptable aspect of the plan and the Council needs to consider the steps that should be taken to improve housing delivery in the earlier years of the plan.” He requests a paper from the Council with an amended trajectory and in particular the relationship between improvements to the A3 and other infrastructure projects and that trajectory.

The Guildford Society expressed concern about the stepped trajectory because, in each of the first five years of the Local Plan period, Guildford would not be able to demonstrate it can meet its 5-year housing land supply target and all and any development proposal (in line with the plan or not) would be fair game – the very antithesis of positive plan-making.

Another consistent Guildford Society criticism of the Evidence Base has been the woeful, flawed, and to-date-unamended Settlement Profiles Report. Mr Bore highlights that the Spatial Development Strategy shows no indication of “the numerical balance of housing development between different settlements”. The Council has been hamstrung by its poor Evidence Base in this regard which neither indicates what development might be required in each settlement nor establishes the basis on which the provision might be achieved – and neither does it establish any quantum that might be taken on by any neighbourhood plan. Again he requests a paper to show how this might look in practice.

Mr Bore’s fifth point is straight out of the Guildford Society list of criticisms. Mr Bore identifies that, with so much identified unmet housing need, the Council persists in favouring alternative uses to protect other uses. This approach was demonstrated by the choice to build a Waitrose supermarket on an unsuitable site in the town centre over and above using the site for housing (a broadly similar land value) which could have accommodated 250 homes at a similar density to the nearby Printing House Square.

The Guildford Society questions the need for the quantity of retail space on the North Street development and also supports the principles of the Guildford Vision Group in seeking to regenerate the riverside in such a way that many of the inefficient land uses can be replaced by residential units.

The Guildford Vision Group has highlighted that the Council’s failings in planning the town centre has led to additional pressures on the Green Belt. Mr Bore agrees.

It is interesting to note that Guildford Borough Council has a Town Centre Regeneration Strategy (TCRS) that is in several respects non-compliant with the Local Plan because of its repurposing of designated employment land for residential development. The Council did not adopt the TCRS because it would undermine its Local Plan process, and yet, the Inspector is saying that this was precisely what was needed to help deliver unmet housing need.

The Guildford Vision Group approach looks highly coherent in this regard against the Council’s “same old” approach to spatial planning.

Mr Bore questions the strategy for student housing – and the Local Plan draft for simply setting a campus-based rule without applying a land allocation and quantum to the plan to deliver it.

The Guildford Society has been critical since 2013 of the Green Belt Evidence Base which failed to make the case for (a) any development in the Green Belt; and (b) for the exceptional or very special circumstances in each case for incursions into the Green Belt or the redrawing of the Green Belt boundaries. The Society has not taken the one-size-fits-all approach of arguing that no adjustment of the Green Belt need be made. Rather we have argued that any adjustment needs to be well argued, permanent and sustainable. The Society has also argued that, as part of redrawing the Green Belt boundaries, the Council needs to have identified how it will provide land for future Plan periods so that its policies are sustainable in the long term.

The Inspector has agreed that the Green Belt policies lack clear explanation of exceptional circumstances (strategic and local – back to the settlement profiles again).

The Guildford Society and the Guildford Vision Group have both consistently criticised the draft plan for its failure to require good urban design. Mr Bore has agreed. He says “there is nothing about the masterplanning of large sites” and goes on to note another bugbear of both groups as to “how the public can engage in the overall masterplanning process or how overall masterplans and the different components of the larger schemes are to be subject to design review – essential parts of the urban design process”. Mr Bore goes on to say that “the Council should take advice on the techniques available for reviewing both the quality of existing places (such as Place Check) and on the quality of the design of emerging schemes (for example through public comment on 3D modelling)”. This could have been written to express the issues with Solum and similar schemes, but equally the stand-offish behaviour of the Council with regard to the Guildford Vision Group’s excellent strategic views (whether one agrees with them or not).

Mr Bore makes various other points which I will not cover here, but he is very clear in his condemnation of the proposed indicators (most of the negative) scattered through the plan.

The comments on Employment demonstrate that Guildford Borough Council is failing businesses. We already know that three major corporations with their headquarters located in Guildford in about 200,000 square feet are planning to move away from Guildford with the principal reasons being traffic congestion and poor transport connectivity, and the lack of homes in the borough that employees can afford.

The Inspector’s comments also seem to suggest that he finds the draft Local Plan to be incoherent in its land use allocations, and that is exactly what this Local Plan is meant to be for, and it does not plan positively (particularly in its monitoring indicators). In many of the places Guildford Borough Council has sought to include behavioural or sustainability controls, Mr Bore has found them to be unduly onerous and requires them to reflect the NPPF.

Mr Bore comments relatively little on infrastructure but does hold out an olive branch to the Council’s attempts to restrict development before infrastructure is in place. He suggests that there should be allowance for a so-called ‘Grampian’ condition which could achieve this. It is not clear how this would sit with the requirement to retain a 5-year housing land supply at all times as it would almost certainly lead to uncontrollable development or a meaningless housing target. This seems to be inconsistent with Mr Bore’s earlier dismissal of Guildford Borough Council’s proposed stepped housing target. It does, however, echo what many respondents to every consultation since 2013 have said about housing and infrastructure.

The Council’s approach to the town centre – singularly lacking in the Local Plan – is predicated on modal shift. The inspector dismisses as “unlawful” one of the main planks for reducing town centre traffic, namely, the denial of access by residents, through planning restrictions, to parking permits.

This response by Mr Bore may be the beginning of the unravelling of the Council’s unrealistic approach to town centre land-use planning, infrastructure and masterplanning. It certainly makes the Guildford Vision Group look to be a much more coherent force in planning the town than the Local Planning Authority.

It is not ‘back to the drawing board’ for the Council but it does seem an awful lot of time and money has been wasted – perhaps a lot of this could have been prevented had the Local Plan Forum not been quietly dispensed with in the post-Mansbridge era.

It does now seem unlikely that the Council can meet its own proposed timetable for the Local Plan and it seems inevitable that it will need to undergo further consultation. This would give plenty of opportunity for inserting a positive plan for the Town Centre, and it would seem appropriate to incorporate the well-considered Vision Group plan, in large part of not in full, within the body of the Local Plan – as had been argued back in 2014 when the leaders of the Council (at the time) were arguing that to include the town centre masterplan would delay the urgently needed Local Plan.

Dec2017 Regulation 22 Local Plan Submission

Here is a facsimile from 2nd February 2018 of the Guildford Borough Council Local Plan page:

Local Plan Examination

Submission Local Plan (Reg 22)

The Submission Local Plan: strategy and sites (2017) sets out the vision for the borough and our approach to development between 2015 and 2034. When adopted, the plan will play an important role in shaping Guildford’s future – how our towns and villages develop, protecting and enhancing our natural environment, developing our local economy, improving leisure and visitor facilities, and supporting more sustainable forms of travel.

The Guildford borough Submission Local Plan: strategy and sites (2017) was submitted to the Secretary of State for Local Government on 13 December 2017 for independent examination.

Next steps

The plan will now be independently examined by a planning inspector. The planning inspector appointed by the Secretary of State is Mr Jonathan Bore BA MRTPI DipUD.

The timetable for the examination is in the hands of the Planning Inspectorate. We will provide further details of the examination, including a timetable, on the website once further details are known.

Programme Officer: Mr Chris Banks

A Programme Officer, Mr Chris Banks, of Banks Solutions, has been appointed to manage the administration of the examination on behalf of the appointed Inspector and acts as the liaison between the Inspector and representatives of the Councils. The Programme Officer has no involvement with the preparation of the plan and reports directly to the Inspector. Any correspondence or queries relating to the examination process should be directed to the Programme Officer:

Address: C/O Banks Solutions, 64 Lavinia Way, East Preston, West Sussex, BN16 1EF


Tel: 01903 783722

Documents submitted

The submission documentation includes the Submission Local Plan: strategy and sites (2017); a Schedule of Proposed Minor Modifications, a Consultation Statement (containing the main issues raised during the 2016 and 2017 Regulation 19 consultations, and the two earlier Regulation 18 consultations on the plan, and our responses to those representations).

The Submission Local Plan: strategy and sites (2017) and Consultation Statement are available to download from the links below:

pdf icon Submission Local Plan: strategy and sites (2017): Policies and site allocations [17Mb](This link will open in a new window)

pdf icon Submission Local Plan: strategy and sites (2017) Appendix H: Maps A-G [6Mb](This link will open in a new window)

pdf icon Submission Local Plan: strategy and sites (2017) Appendix H: Maps H-P [8Mb](This link will open in a new window)

pdf icon Submission Local Plan: strategy and sites (2017) Appendix H: Maps R-W [4Mb](This link will open in a new window)

pdf icon Consultation Statement (Regulation 22) (2017) [13Mb](This link will open in a new window)

A list of all of the submission core and supporting evidence documents is available below. All documents in this list are available to download from web links.

pdf icon Submission core and supporting documents [474kb](This link will open in a new window)

Hard copies of any of the documents in this list are available for inspection at the Council offices in Millmead during our normal opening hours. Copies of the Local Plan and Policies Maps, Schedule of Minor Modifications, Sustainability Appraisal, Habitats Regulations Assessment and Consultation Statement will also be available for inspection at the Council offices or at any of the Borough’s libraries during their normal opening hours.

Minor Modifications to the Proposed Submission Local Plan (2017)

We have prepared a schedule containing proposed minor modifications to the Submission Local Plan (2017). These are recommendations to the inspector of a minor nature that, whilst not going to the heart of the plan’s soundness, will improve the clarity and usability of the Submission Local Plan. We submitted this schedule to the independent Planning Inspector, alongside the Submission Local Plan and other documents. We have also submitted a track-changed version of the Submission Local Plan which includes the proposed minor modifications. You can view the documents below.

pdf icon Minor modifications to and Errata for the Submission Local Plan 2017 [484kb](This link will open in a new window)

pdf icon Track changed version of the Submission Local Plan 2017 – Document and Appendices A – G [19Mb](This link will open in a new window)

pdf icon Track changed version of the Submission Local Plan 2017 – Appendix H – Maps [22Mb](This link will open in a new window)

Committee decisions

At its meeting on 20 November 2017, the Council’s Executive committee resolved to seek the agreement of Full Council for approval to submit the Submission Local Plan (2017) and accompanying documents to the Secretary of State for independent examination.

Full Council then considered these items on 21 November 2017 and approved the decision to submit the plan. The report and minutes for the Full Council meeting are available to download and view from the Agenda and minutes web page.


We consulted on the Proposed Submission Local Plan: strategy and sites (2016) between 6 June and 18 July 2016. In accordance with Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulations 2012.

To take account of further work and the responses received during this consultation we proposed changes to the plan and updated part of the evidence base that informed its preparation. The Proposed Submission Local Plan: Strategy and sites (2017) included these proposed changes. A further Regulation 19 consultation on these proposed changes was held between 9 June and 24 July 2017.

To see these, and earlier versions of the Local Plan please visit the Previous Consultations web page.


Representations from both the 2016 and 2017 consultations on the Regulation 19 Submission Local Plan are available to download from our Planning Policy Consultations web pages.

Purchasing a hard copy of the Submission Local Plan

A hard copy of the Submission Local Plan (2017) (including maps) can be purchased from Guildford Borough Council for a cost of £42.50 plus postage costs (£5.50 for first class, £3.00 for second class. Additional postage costs may apply if ordering more than one copy). Please call 01483 444471 or email to request a copy.


For the sake of completeness and independence (in case the links break or are changed)…

Set out below are those documents as they stood on 2nd February 2018:












We will reproduce the Evidence Base over the coming days and weeks as we have done in previous consultations.

GSoc Response to 2017 R19 Consultation

After a six week period to review literally thousands of pages of plan and evidence base, here is the response from the Guildford Society:


This document has been prepared as a record of the concerns the Guildford Society has about the plan as drafted, but not with the aim of killing or delaying the adoption of a sound local plan for Guildford, which the Society agrees is very important.

A file with a hard copy of this response was delivered by hand to Guildford Borough Council at 08.15 am on 24th June 2017 before the 12.00 noon deadline.


An addendum was provided by email to Tracey Coleman at Guildford Borough Council at 11.18 with some further comment from the Guildford Society Local Economy Group:



Here is a complete version with the Addendum inserted at the appropriate paragraphs:




Reg 19 Local Plan Consultation 2017

Guildford Borough Council’s consultation website with all of the documents can be found here.

The consultation ends at 12.00pm (noon) on 24th July 2017.

The consultation documents as they stand at 12.37pm on 17th June 2017 are set out below:






Continue reading “Reg 19 Local Plan Consultation 2017”

GSoc Local Plan Reg19 Consultation Submission

The Guildford Society’s submission in respect of the Local Plan was delivered by hand to the Council before the deadline of 23.59pm Monday 18th July.

Here is the Submission with its accompanying documents:






Julian Lyon
Chair, The Guildford Society

18th July 2016


Comparison of 2014 and 2016 draft Local Plan documents

Following publication of the preliminary version of the 2016 Regulation 19 Consultation Draft Local Plan (‘R19 Draft‘), it seems appropriate to compare it to the Regulation 18 Consultation Draft (‘R18 Draft‘) and the Guildford Society response to the R18 Draft.

I have, therefore, set the policies side by side along with the GSoc comments in the file below:

20160416_R18-2014_to_R19-2016_Comparison_Policies (more than 200 pages)  This does not include a comparison of the site-specific policies or the proposed site allocations.

I have analysed the Guildford Town Centre and Guildford Urban Area sites as a comparison between 2014 and 2016 and GSoc’s 2014 comments:


I will in due course add the remaining sites from the 2016 draft plan in a similar format.

Jennie Kyte has prepared a very helpful summary (below) which I have just reformatted a little but have made no changes to:


Taken together these documents should help with navigation and orientation of the new draft plan.


Draft MasterPlan to be Reviewed by Scrutiny Committee

The draft Guildford Town Centre Master Plan documents have been published today – all 200Mb+ of them!

Without any commentary from us at this stage, and because the GBC website seems to be unable to cope with the file sizes, they can be downloaded from this site (below):

Draft Town Centre Master Plan

Item 04 Appendix 2 Scenario 1 (29Mb)

Item 04 Appendix 3 Scenario 2 (29Mb)

Item 04 Appendix 4 Viability Report

Pages 1-61 of Item 04 Appendix 1 Town Centre Masterplan – the report.compressed (62Mb)

Pages 62-138 of Item 04 Appendix 1 Town Centre Masterplan – the report.compressed (116Mb)


Comments welcomed.