Housing Numbers

Guildford Borough Council’s paper “How many new homes?” sets out to provide a range of different approaches to calculating housing numbers between 2011 and 2031.  The resulting picture is a potentially confusing one with estimates of NEED ranging from 181 homes per year to 1,066 new households per year.  This seems to be akin to a game of ‘pin the tail on the donkey’ – a blindfold stab in the dark.

Before going on to the paper itself, it might be helpful to review the requirement placed on us by the National Planning Policy Framework (NPPF) 2012.

NPPF (Section 6) Delivering a wide choice of high quality homes

47. To boost significantly the supply of housing, local planning authorities should:

  • use their evidence base to ensure that their Local Plan meets the full, objectively assessed needs for market and affordable housing in the housing market area, as far as is consistent with the policies set out in this Framework, including identifying key sites which are critical to the delivery of the housing strategy over the plan period;
  • identify and update annually a supply of specific deliverable sites sufficient to provide five years worth of housing against their housing requirements with an additional buffer of 5% (moved forward from later in the plan period) to ensure choice and competition in the market for land. Where there has been a record of persistent under delivery of housing, local planning authorities should increase the buffer to 20% (moved forward from later in the plan period) to provide a realistic prospect of achieving the planned supply and to ensure choice and competition in the market for land;
  • identify a supply of specific, developable12 sites or broad locations for 

    growth, for years 6-10 and, where possible, for years 11-15;

  • for market and affordable housing, illustrate the expected rate of housing delivery through a housing trajectory for the plan period and set out a housing implementation strategy for the full range of housing describing how they will maintain delivery of a five-year supply of housing land to meet their housing target; and
  • set out their own approach to housing density to reflect local circumstances.

My first question, therefore, is “WHAT IS OUR HOUSING AREA?”. Previous attempts to assess housing numbers have had Guildford and Waverley as the Strategic Housing Market. Given the expectation that Ash South and Tongham will take a substantial amount of development, it must, surely be relevant to consider Aldershot as part of our Strategic Housing Market.   In the absence of a new SHMA (Strategic Housing Market Assessment) it seems Guildford Borough Council is asking us to consider the Borough as our Strategic Housing Market.  This seems to me to be not only the wrong answer but inherently dangerous to our settlements and environment.

Perhaps the table used elsewhere in the Evidence Base (reproduced below) based on the 2001 Census – due to be updated when 2011 Census data is published in Spring 2014 – would show the wider Strategic Housing Market as it impacts on Guildford and vice versa.

201302_SCC-CongestionReport-Table4-2001

My second question is about NEED – how should this be defined, because it ought not to be confused for DEMAND;

And my third question is about CAPACITY – this is not the document to explore our capacity to accommodate housing BUT it is a salient point in order to be realistic.  Guildford Borough Council themselves within this document make comments against some of the scenarios: “We consider this housing number to be unachievable in the borough.”  It seems, therefore, appropriate to have some regard in reviewing this paper to CAPACITY.  The Evidence Base has not really explored CAPACITY in absolute terms, leaving us to guess what development we can absorb.  This paper introduces real fear in the absence of a statement of capacity (notwithstanding that changes to Green Belt and Infrastructure could change that number (let’s call that ‘CONDITIONAL CAPACITY’).

John Baylis (Guildford Society Planning Group) has drafted an excellent commentary – for which I am grateful and which I set out below.  I have added my comments in blue where I believe there is either question or scope for further discussion of the document itself (rather than the issues it brings forward.

The GBC Background Paper ‘How Many New Homes?’ October 2013

DRAFT

 

A note prepared by John Baylis for the Guildford Society

‘How Many New Homes?’ is a GBC background paper, which will inform selection of the housing number in the new Local Plan.

THE OPTIONS

The paper considers eleven options. They are set out in the paper’s Executive Summary and look at the future need for homes between 2011 and 2031. Quoting from the Executive Summary, the options are:

Official CLG numbers

1:   14,071 homes (an average of 704 a year) [an increase of 27.24% over the plan period above current (54,000) households]. This housing number is based on the government’s 2011 projections for household growth.

2:   8,300 to 9,480 homes (an average of between 415 and 474 a year) [15.37 to 17.56%]. This housing number is based on the government’s 2010 projections for household growth.

Migration-trend based housing numbers

3:   11,820 to 13,480 homes (an average of between 591 and 674 a year) [21.89 to 24.96%]. This housing number is based on a modified version of migration trends over the last five to ten years.

4:    3,620 to 4,520 homes (an average of 181 to 226 a year) [6.70 to 8.37%]. This housing number is based on an assumption that only the same number of people would move into Guildford borough as move out of the borough.

Jobs-led housing numbers

5:    7,160 to 8,520 homes (an average of 358 to 426 a year) [13.26 to 15.78%]. This housing number is based on the calculation, by Experian in spring 2010, of the number of new jobs that are likely to be created in the borough.

6:    11,440 to 13,100 homes (an average of 572 to 655 a year) [21.19 to 24.26%]. This housing number is based on the calculation, by the Institute of Employment Research (IER) in 2007, of the number of new jobs that are likely to be created in the borough.

7:     9,280 to 10,800 homes (an average of 464 to 540 a year) [17.19 to 20.00%]. This housing number is based on an average of the Experian and IER data for the number of new jobs that are likely to be created in the borough.

Dwelling-led housing numbers

8:    6,864 homes (an average of 312 a year) 12.71%]. This housing number is based on the number of homes that have actually been built in Guildford borough in the last 13 years.

9:     7,084 homes (an average of 322 a year) [13.12%]. The draft South East Plan proposed a lower housing number for Guildford borough than the final version of the plan. This housing number is the same as the one in that draft plan.

10:    21,320 homes (an average of 1,066 a year) [39.48%]. This housing number is based on a housing needs assessment model for meeting all of our existing and forecasted future need for affordable homes in the borough to 2031.

11:    14,168 homes (an average of 644 a year) [26.24%]. This housing number would meet about half of our existing and forecasted future need for affordable homes in the borough to 2031. The number is based on a model, which looks at how much supply and demand are balanced across the different tenures and property sizes.

Thus the projected numbers of homes needed in the future range from 181 to 226 new homes a year (based on hypothetical zero net migration) to 1,066 homes a year (meeting the entire SHMA affordable homes need figure).

The Council employed a specialist firm, Edge Analytics to assist with and to critically review the above findings. The second half of the paper comprises their report.

The paper notes that National government policy tells us we must plan for growth.

BACKGROUND

The borough had a population of just over 137,000 people in 2011, (Census 2011), an increase of 5.8 per cent from 2001 (0.6% per year).  The 2011 Census shows that there were just under 54,000 households in the borough.

There is a need for more affordable homes. As of 31 March 2013 there were 2,090 priority households on the Council’s housing waiting list (those in bands A-C, which are the highest priority of the five waiting list bands). [Based on a provision of 35% Affordable Houses from all housing development, this would assume 5,975 houses (an 11.06% increase in current housing stock) would have to be built just to provide for the 2,091 priority households]

From 2009 to 2031, the population projection data suggests the number of people aged 60 or over will increase from 28,300 to 38,700. For this and other reasons the number of people who will live alone in our borough will increase. In 1991, the number of single-person households made up 25 per cent of all households. By 2031, the data suggests that these households will account for 39 per cent. Past trends suggested household sizes were decreasing, but the recent Census in 2011 has surprisingly shown that household sizes have increased from 2001. [This may show the difference between NEED and DEMAND – for example, if we had more homes for single people, perhaps we would have filled them, maintaining the 2001 level; as it happens, we did not provide them and so people made other arrangements]

Over the six years 2007 to 2012 there have been about 1,630 births and 1,000 deaths in the borough each year, giving a ‘natural change’ of about 630 per year (0.46% per year) [at 2.43 people per household (current average) this equates to around 260 houses per year].

Over this same period the average net internal migration has been close to zero, about 15 per year, i.e. over the five years the total immigration from the rest of the UK has exceeded the total emigration by only about 70.

In 2001/02 immigration and emigration were equal at about 2,000. Over the three years 2009/12 the average immigration was about 3,500 and emigration 1,600, giving a net international migration of about 1,900 per year (about 1.4%) [about 782 homes per year]. This is far greater than the natural change and net internal migration figures above. The paper remarks that “International migration is estimated to have had the most significant impact upon population in recent years. This has been driven by both an estimated increase in immigration and a decline in the level of emigration (figure 6). The robustness of this trend is important as it can have a very significant impact on any trend projection that is developed for the Borough.”

The paper then goes on to predict the future net international immigration, and concludes it is has recently been around 0.14% and will fall to a steady 0.06% over the period up to 2031. There is no comment on the gross disparity of the 0.14% figure (source What homes where? tool) and the above 1.4% figure (source Edge Analytics July 2013). What homes where? predicts close to zero net internal immigration.

Total population change is the sum of natural change, and net internal and international immigration.

In the context of Option 1 above the paper then looks at total population predictions for the Borough. Fig 13 of the paper gives three very different prediction curves each based on different ONS statistics. The most likely curve would seem to be the ‘2008 – based’ curve predicting 153,000 by 2031, about 800 per year [equivalent to around 330 homes per year], about 0.6%. This is in accord with the present 0.46% natural change plus the 0.14% net international immigration, i.e. in accord with previous growth.

However the ONS gave a ‘2011 – interim prediction’ which predicts much more rapid growth, to about 156,000 by 2021 (see blue curve of Fig 13.) The curve gives 1.4% average growth per year and thus does not accord with previous growth. The government used this to predict household growth rates to 2021 and the Council have extrapolated this to give 68,251 households by 2031, a rise of 14,071. [at 2.43 people per household, this should equate to 64,198 households (4,053 fewer homes)]

THE OPTIONS

1. The 14,071 number comes directly from the above. The paper says “we consider this number to be unachievable”, comments on the unreliability of the number and notes that the government will produce revised predictions in mid-2014.

2. Edge Analytics used another ONS forecast, the ‘SNPP-2010’, which they argue to be more reliable, and adjusted it to accord with the 2011 census. It gives a net population growth of about 0.65% per year. This gives the range 8,300 to 9,840 new homes. The two different figures reflect predictions based on 2011 and 2008 statistics and account for the rise in average household sizes over this period (from 2.37 to 2.43). Larger households lead to a need for fewer homes.

3.  The prediction of 11,820 to 13,480 homes is based on net international immigration figures produced by the Office of National Statistics (ONS) for the five years to 2011, but with modification to the ONS long term assumptions. The predicted population growth is 21%, 1.05% per year, which is high compared with option 2.

4.  This prediction gives 3,620 to 4,520 homes, the lowest of any of the predictions. The paper comments that zero net migration is not the same as only providing for the needs of local people, as it takes into account movement of people in and out of the borough. The prediction is considered to be unrealistc.

5 and 6. The predictions are based on Edge Analysis modelling of the needs arising from the shortfalls in labour predicted by Experian and the IER over the period 2008 to 2031.

7. This projection uses employment projection data from the Council’s Employment Land Assessment (ELA).

Experian IER GBC ELA
Growth in employment :            7,825 (0.4% per year) 16,540 (0.9% per year) 12,165 (0.6% p.y.)
Growth in active labour supply:4,100 (0.25% per year) 4,100 (0.25% per year)  4,100 (0.25% p.y.)
Shortfall:                                        3,725 12,440  8,065
Pre-existing shortfall in 2008:  13,037 12,447 12,291
Shortfall in 2031:                        16,762 24,887 20,356

The majority of the housing needs arise from the existing shortfall.

8. The average new number of homes built over the period 2000/01 to 2012/13 is 312 per year. In the five years 2008/09 to 2012/13 this fell to an average of 207 per year.

20131013_HowManyNewHomes-p30

9. The submission draft South East Plan (2006) allocated Guildford borough 322 homes a year. The Council supported this number, subject to caveats regarding infrastructure provision and the protection of key areas of nature conservation. The majority of local people who responded to the South East Plan public consultation that ran in 2006 also supported this number. It originated in the Surrey Structure Plan of 2004 and is in accord with historic building rates.

The final SEP demanded 422 homes a year. This led to massive local objection during 2008 and 2009, supported by Councillors and our local MP Anne Milton. There were over 4,800 representations. The campaign’s slogan was ‘Don’t Wreck Guildford’.

10. The prediction of 1,066 homes per year comes from the West Surrey Strategic Housing Market Assessment (SHMA) produced as a result of co-operation between GBC and Waverley and published in 2009. Between 2011 to 2031 the estimated need will be 1,194 x 5 years to overcome the present backlog plus 1,028 x 15 years = 21,320 homes, which gives 1,066 a year. Council considers this housing number unrealistic for several reasons. [As noted above, it seems illogical to conclude that Guildford’s market is merely Guildford and Waverley – it should definitely include Rushmoor to make sense of the heralded large-scale expansion of Ash South and Tongham]

11. This housing number also came from the SHMA. The number is based on a model, which looks at how supply and demand are balanced across the different tenures and property sizes. It would mean building 12,880 homes between 2011 and 2031, an average of 644 new homes a year. The Council considers this housing number unrealistic.

The predictions of the eleven options are displayed in a histogram in Fig 18, p 34 of the paper:

20131013_HowManyNewHomes-p34

THE EDGE ANALYTICS REPORT

The Edge Analytics report gives more detail concerning the factors taken into account in arriving at the predictions. It emphasizes that it is important to recognise the high degree of uncertainty associated with evidence on international migration, particularly the recent estimates of emigration from Guildford Borough.

The report gives a brief outline of their POPGROUP model used for modelling and prediction.

At the end it says it has used a commuting ratio of 0.974 as the balance between the size of the resident labour force and the number of jobs available in Guildford. The meaning of this number is not clear. The total employment in the Borough is given as about 83,000 in Options 5 to 7, and the 2008 shortfall as around 12,000, equivalent ratio about 0.85.

The report does not attempt to do the sum the other way round. For given assumptions and build rates of new homes it should be possible to estimate what the effects will be on population, employment and immigration.

The report demonstrates the significant effects of the two different CLG household projection model assumptions used: Scenario A (2011 based) and Senario B (2008 based). These reflect the rise in household size.

The report has some useful summary tables. A combined summary table is given at the end of this note.

SOME COMMENTS

The starting point for debate on numbers is surely the draft SEP figure of 322 per year. Indeed the Council’s Executive agreed to use 322 homes a year as the borough’s interim housing number, until a local housing number is adopted as part of the new Local Plan.

This number was vigorously defended by nearly all the Borough during the 2008/09 campaign. The government proposed 422 was attacked from all sides. Linked below are an EGRA/G Soc leaflet from September 2008 and a Declaration dated 14 October 2008 which was co-signed by Anne Milton and delivered by the signatories to GOSE (as was).

SERP-Campaign

Nothing has changed locally since then, but there seems to be an acceptance that the 322 number cannot survive. The main change in terms of intention is that instead of locating the extra housing on one Green Belt site, a multitude of potential sites have been identified.

Option 4 would provide for the natural growth of the Borough and a flux of equal numbers of people in and out of the Borough. In addition to this most people would probably support provision of more affordable housing. Both could be accommodated within the 322 figure or thereabouts. The natural growth would provide some addition to the active labour supply.

The most obvious drivers for higher numbers are to meet the need to accommodate net international immigration and to meet the aspirations of business. It is a political decision as to whether the environment (Green Belt, character of the town) should be sacrificed to meet these needs.

 SUMMARY TABLE.  All figures are averages for 2011 to 2031.

In order of decreasing dwellings per year

Scenario A: dwellings per year B: dwellings per year Average of A &Bdwellings per year A:Population change per year A:Net migration per year B:Population change per year B:Net migration per year
10. All needs 1,066 1,066 1,066 2,725 1,660 2,436 1,428
1. Govt’s 2011 projection 704 704 704
11. Half affordable 644 644 644 1,585 739 1,365 560
3. Migration led 591 674 633 1,454 629 1,454 629
6. Jobs led (IER) 572 655 614 1,394 588 1,394 588
7. Jobs led (mid-range) 464 540 502 1,099 343 1,099 343
2. Govt’s 2010 projection 415 474 444 886 232 886 232
5. Jobs led (Exp.) 358 426 392 807 101 807 101
9. Dwellings led (SEP) 322 322 322 714 30 546  -109
8. Past completions 312 312 312 687 8 520 -130
4. Net nil migration 181 226 204 602 0 602 0

V1. 9.10.2013

As you can see this was an excellent summary by John Baylis for which I repeat my gratitude.  Feedback on John’s paper include:

From a former Planning Officer of a neighbouring authority:

Your paper is an impressive piece of work.

I would not disagree with your ‘Some Comments’ set out on pages 5 & 6 above the ‘Summary Table’.

My own comments are as follows;-

  1. It is impossible to assess the validity of the outcome figures of the various options since we do not know what assumptions are made in reaching their conclusions and even if we did it would be difficult to challenge those assumptions.
  2. You cannot simply seek to match jobs and housing numbers since social factors (such as people employed on short term contracts and both partners working) mean that these days people tend to ‘stay put’ in their existing house and simply travel (sometimes long distances) to their place of employment.
  3. In addition to the above, these days’ peoples’ work patterns are very different from 30 years ago. It is not unusual for people to work from home (allowing them to live some way from their ‘base’) and that pattern is likely to continue.
  4. Because of Guildford’s favoured geographical location (i.e. 30 miles from London, proximity to the A3/M25 giving easy access to Heathrow and Gatwick, access to attractive countryside, etc), Guildford will remain a favoured location and that will continue to be reflected in high property prices. This will inevitably result in people choosing to live distant from Guildford (where property is less costly) and travel into the town to work.
  5. Planning cannot control where people choose to buy houses or where people come from. Simply building more and more houses will inevitably result in more in-migration especially from London as property prices there continue to rise as a result of foreign investors
  6. And then there is the whole issue of the high price of property and the property market. At present so many young people cannot afford to buy houses and, as we know, developers only build if they can sell at a price which reflects development costs including land and profit. Ways of meeting local housing need is a key issue but this is an issue that is difficult for the Plan.

I know these comments do little to help reach a conclusion but I think they do demonstrate the impossibility of thinking there is a ‘right’ answer in terms of numbers. I would question whether the GBC paper ‘How Many New Homes?’ adequately takes account of the reality of the complex patterns of work/living of people in 2013.

Employment Land Assessment Commentary

WORK IN PROGRESS

This post looks at the Employment Land Assessment and aims to place it (and my responses to it) in the context of other parts of the Evidence Base.

As an overriding view, this document does not purport to be a strategy document for employment land – it aims to spell out the need for employment growth based on assumed population growth and it identifies where employment land is today and where more land needs to be provided to meet demand.

My main issue with this is that it is an organic approach to a situation that has been failing for many years, where a radical and ambitious approach is required.  Failing areas such as Walnut Tree Close and Woodbridge Meadows may well be better served as a new residential quarter, whereas, properly connected, these businesses may have greater success in the other established business centres or even a new centre in the Borough.

On page 12 of the Report there is an assessment (Table 1) of the effectiveness of the Employment Policies in the 2003 Local Plan:

  • Policy E1 FAILED
  • Policy E2 Some Success
  • Policy E3 PARTIAL FAILURE
  • Policy E4 FAILED
  • Policy RE15 Some success at BTRE Vokes, FAILURE at Peasmarsh

This should be the clearest possible indicator that organic solutions will probably be insufficient.

Corporate Real Estate Executives for major companies have taken Guildford off the list of destinations for headquarters or significant operations due to two main longstanding issues:

  • TRAFFIC CONGESTION
  • LACK OF HOUSING THAT WORKERS CAN AFFORD

The Local Plan gives us a perfect opportunity to rebalance the policy environment and marketing Guildford as OPEN TO BUSINESSES

Guildford Urban Area has three principal employment centres:

  1. Town Centre (Friary & St Nicholas Ward) – 23.5% of the employment floor area accommodating 31.4% of the employees*
  2. University & Research park (Onslow Ward) – 25.7% and 39.6%
  3. Slyfield (Stoke Ward) – 26.6% and 12.7%

(figures from Table 2, p19)

* approximately 12% of the Town Centre Floor Space was noted in the ELA (Table 49) as available on the market in July 2013

Each of these areas has major constraints to business and enterprise growth –

Town Centre has major congestion issues throughout but especially in the Walnut Tree Close – Woodbridge Meadows corridor (325,000 square feet of space accommodating 511 employees).  Here the traffic congestion is so bad that it can take over an hour at peak times to get out onto the local road network.  Unsurprisingly, business have taken opportunities of lease expiries and break options to relocate – typically away from Guildford.

University & Research Park is also blighted by traffic congestion but mainly as a result of strategic failures of the A3.  Again, reports of 45 minutes to an hour to leave the research park area put a great strain on an otherwise exemplary business environment for high-technology companies (knowledge industries).

Slyfield has more industrial property than offices but relies on good quality logistics links to major highways.  Traffic is once a gain an issue here – a link to the A3 would be a partial solution but there also needs to be a much better public transport link from early morning to mid/late evening to ensure that employees can get to Slyfield for shift work and non-standard hours.

Each of these locations can be resolved with careful and wider-reaching planning – a Master Plan for the wider town centre; a Master Plan for the University Quarter (including the proposed or potential westward extension of the town); a Slyfield Master Plan to include potential expansion both northwards and southwards (as noted in the SHLAA and my commentary on Jacobs Well in particular).

These Master Plans should enable communication between themselves to ensure they do not preclude each other’s solutions but they should form Area Action Plans and be brought forward with the Local Plan as Development Plan Documents.

Above all, the Employment Strategy needs to be bolder than envisioned in the ELA – and the Economic Strategy needs to be more defined than the ‘Economic Vision’ document forming part of the Evidence Base.

One final point in the introduction to my response:  There needs to be a strong policy decision taken as soon as possible to establish how Guildford Borough Council will handle applications under the new General Development Order regulations that will allow conversion of office buildings to residential. This is a key issue when considering the propensity to attract businesses to Guildford and to provide enough jobs for a growing local population.  Whilst this is referred to in 2.3 (p13), there is no clear direction offered or recommendation made.  Guildford Borough Council could make such a statement and reinforce it through the Planning Committee pending the production and adoption of the Local Plan so as to avoid any undesirable or uncontrolled erosion of the commercial footprint.

Introduction (p7)

There is nothing particularly controversial (or exciting) in the Introduction except that NO REFERENCE IS MADE IN THE INTRODUCTION TO THE RECENT CHANGES IN GDO REGULATIONS GOVERNING THE (AUTOMATIC) DEVELOPMENT RIGHT TO CONVERT OFFICE SPACE INTO RESIDENTIAL USES AS A POTENTIAL THREAT TO COMMERCIAL FOOTPRINT.

At 1.1 the ELA states that it “assesses how much employment land we are likely to need within Guildford Borough to 2031.”

Stage One – Taking Stock (p9)

This section begins with a Policy Context – looking at National, County and Local Authority policies.

At 2.1.5 the Report cites Paragraph 161 of the NPPF which explains the need to assess the “needs for land or floor space for ECONOMIC DEVELOPMENT” and the need to asses the “existing and future supply of land…to meet the identified needs.”

Neither the Economic Strategy nor the ELA seeks to identify an ambitious target for growth by attracting specific industries or sectors to Guildford.  It seems only the University has such a strategy and its strategic Business Plan is not taken into account in the ELA or as an informative document in the Evidence Base.  This should be addressed in the Evidence Base (whilst it is currently under development) so as to ensure that Guildford is capable of attracting and retaining businesses to be located in the town or its major business areas or elsewhere in the Borough.

Stage One does not give any indication of the prize to be won by Guildford Borough Council of being able to keep a large portion of incremental business rate growth – which could go a long way towards bringing about the infrastructure improvements we need in order to attract and retain businesses.  THERE IS, IT SEEMS, A VIRTUOUS CIRCLE WHICH HAS BEEN IGNORED IN THE ELA.

At 2.1.9 the five bullet points in the Economic Strategy (2013-2031) are set out, namely, Leadership, Infrastructure, Enterprise, Innovation, and Skils & Employment.

It is unfortunate that the Economic Strategy does not specifically focus on ATTRACTING businesses to relocate to Guildford to replace those lost whilst the infrastructure and housing problems were getting progressively worse.

At the footnote (2) to 2.2.1 (p11) the definition of ‘deliverable’ should be consistent with other definitions and uses of the same word across the Evidence Base.

At 2.4.4 the Report refers to the Enterprise M3 (EM3) Strategy for Growth document (final document published April 2013).

The suite of documents is available below:

From these there are some clearly emphasised comments:

  • “The Enterprise M3 area is an important economy and a successful economy against a range of indicators, and a place where businesses have wanted to locate and grow.”
  • “The March 2013 announcement by the Defence Secretary concerning the Basing Plan and the restructuring of army bases will result in a £100m boost for Aldershot with new bases and accommodation for troops returning from bases in Germany.”
  • “In 2013 there is more than 800,000 square metres of vacant industrial and office space which could, if full, house 50-70,000 jobs.”

There are some clearly identified issues set out in the Introduction:

  • It is a high cost location for businesses and their employees (it is ranked 8th out of 48 localities in respect of cost base – based on research by Local Futures).
  • The growth of the labour force is not keeping pace with the potential growth of business, especially as there is significant out-commuting to London (the area is only ranked 39th out of 48 localities in respect of the growth of the labour force);
  • Although improvements to transport have improved accessibility to Heathrow, uncertainty over the longer term plans for London’s airports will inevitably impact on the investment and location decisions of businesses;
  • There are growing problems of unreliable transport connections by road and rail with increased congestion and journey times on some routes;
  • There is a need for essential investments in infrastructure and the built environment, to meet the needs of local businesses, adapt to climate change and create a low carbon economy;
  • The innovation infrastructure is stretched and would need to expand if growth ambitions were to be met – occupancy rates at Surrey Research Park are already 95%;
  • There is a shortage of larger (25 hectare plus) sites – only two across the Enterprise M3 area.  This may prevent the relocation of major businesses and discourage sizeable inward investment projects;
  • In situ business growth is constrained for land and planning reasons. Some larger businesses have not always had close relationships with local public sector partners to help remove constraints to growth (including in situ expansion, tailored skills programmes and collaborations with research agencies);
  • Provision and take-up of reliable and high speed broadband has been a major issue reported by rural businesses in the Enterprise M3 area;
  • In aggregate terms there is not a problem with the stock of office and industrial floorspace, much of it high quality. Market demand has been weak but there are other factors determining demand including high rentals. Some of the vacant space should be considered for other uses to avoid surplus property having a detrimental impact on local services and market perceptions of the area.

One main part of the Strategy is:

Infrastructure and Place: Many of the constraints on business growth concern infrastructure – road and rail ‘bottlenecks’ causing congestion and slow/unreliable journey times, limitations on the capacity of the rail network, a shortage of housing for local workers, differential supply of reliable high speed broadband, access and capacity issues in relation to Heathrow and Gatwick airports. These are current problems that will worsen without investment.

The strategic actions include:

4.  Promote inward investment – especially in key sectors (2015-2020: work with property industry and local authorities to promote availability of industrial and commercial space)

5.  Develop visitor economy, with a focus on business tourism

6.  Drive innovation in all that we do, fostering a culture of entrepreneurship combined with driving business growth in niche sectors such as aerospace/space, cyber security, digital economy and pharmaceuticals (target: Strengthen the innovation brand and develop an average of 30 new businesses involved in knowledge networks per year.

7.  Increase supply of labour, especially high level skills capacity

9.  Establish an effective housing development strategy channelling investment, using a new Housing Investment Board (Targets: Boost level of housing completion year on year; Increase affordability of housing; Support housing in proximity of key economic centres/infrastructure; Support conversion of unused office space to housing.

10. Address congestion, along with road, rail and air bottlenecks (Target: Prioritisation of funding and the overseeing of the delivery of major local transport schemes).

WHILST THIS MAY BE A QUESTION OF STYLE OVER SUBSTANCE, I FEEL MUCH MORE SHOULD HAVE BEEN MADE OF THE AIMS AND TARGETS OF EM3 AND HOW THE LOCAL PLAN COULD/SHOULD HELP TO DELIVER STRATEGIC OUTCOMES.

Much of the character of the Borough’s economy is left to Appendix B (p80).  Of note in the highlights at 2.5 to 2.7 are:

  • The assessment of job numbers and job creations are five years out of date (2002 to 2008).  This refers to the 2009 Guildford Economic Study and not to the most recent Economic Strategy Report. The Evidence Base should be Up to Date and Integrated (NPPF)
  • At 2.6.1 the Report refers to a local business survey conducted in 2008.  This is, once again five years out of date and circumstances are fundamentally different now. The Evidence Base should be Up to Date and Integrated (NPPF).
  • At 2.7 the Report refers to eighteen sites identified as strategic employment sites. These are listed in Appendix T (p150) and characterised in Appendix U (from p155).  There is no attempt to consider any linkages between employment sites and, by and large, the information is superficial rather than strategic.

Stage Two – Estimating Future Employment Land Requirements

This section considers three approaches to estimate demand:

  • Employee Demand
  • Employee Supply
  • Projections of Past Take-up of Employment and Economic Development Land

Approach 1 – Employee Demand

The Report uses an “average estimate of floor space per employee” to calculate the amount of employment floor space that will be needed.  From my professional experience, this is a rather blunt instrument with which to carry out exploratory surgery.

New ways of working (referred to in the Report as “Smart Working”) are actually making projected demand rather difficult to estimate.  In some business sectors, corporate real estate executives are targeting ratios like one desk per two or more employees for offices;  at the same time, retailers adopting a click and collect or home delivery service are typically employing more people in the same footprint.

On the other hand, a major trend towards self-storage facilities means that only very few people are employed in a fairly substantial facility.

At 3.3 (Employee Demand Forecast 1: Economic Downturn Forecast) the forecast was recorded as having been made in Spring 2010 – three years ago and five years before the Local Plan is expected to come into force.  The forecast only covers the period to 2026 and so the officers have applied a projection for the balance of five years.

These analyses are spelt out in Table 3 – 2031 Forecast Adjustments (p24) in which an assessment of employment numbers is made and then applied to a 2009 baseline of typical space use density, leading to a total from Table 4 – Extra Floor Space and Land Required 2006 to 2031 (p25) which actually only estimates additional floorspace and not land take.

This summary of 36,000 square metres of net floor space required (which seems a very low number for a 25-year period under any circumstances) is not translated into the amount of land erquired to accommodate it in this scenario.

3.3.16 says: “We hope the majority of the [General Industrial] land will be re-used for [Business] or [Storage and Distribution] but if the location is totally unsuitable it may be released for other uses such as residential“.  It seems odd to have a statement of hope rather than prediction or assertion in a Report such as this.

At 3.4 (Employee Demand Forecast 2: Strong Economy Forecast) the figures were drawn from a 2008 forecast by Experian – even further out of date from the commencement of the Local Plan.  This forecast, ranging from 2007 to 2017 has been projected by officers to run through to 2031 (140% longer than the original range).

According to this approach, the net additional floorspace required (again no land requirement estimate is provided) is 164,000 square metres – a 24.22% increase in the current floor areas summarised in Table 2 (p19).

At 3.5 (Employee Demand Forecast 3: Mid-range Forecast) officers have derived a mid-range forecast which, for most figures with some rounding, seems to be a mathematical average rather than a mid-range economic forecast.

According to this approach the requirement is 99,000 square metres of space and, yet again, no reference to the likely land requirement to accommodate this requirement over the Plan period.

Approach 2 – Employee Supply Based Forecasts

The principal high level comment to make about this approach is that, whilst it considers the propensity and likelihood for new residents to commute to other employment centres (especially London) it fails to take into account major growth areas such as Aldershot (which is receiving large numbers of troops returning from Germany – with their families including, potentially, working wives).  Appendix Q does show data from the 2001 Census and the 2011 Census data is not yet available.

Furthermore, the Retail Demand Study (Roger Tym & Partners) suggests that there is latent demand by 2021 for more than 60,000 square metres of town centre retail space.  This will absorb some of the employees [but has not been modelled in this Report.]

It may well be that this section of the evidence base will need to be thoroughly reassessed in 2014 upon publication of the 2011 census data to understand the current origins and destinations of economically active members of the community, and having regard to Economic Impact Assessments prepared as part of applications for planning permission for the North Street development.

Figures taken from The Office of National Statistics (ONS) – particularly at Tables 10 and 11 do not take account of the gradual increase of the state pension age being introduced over the life of the Local Plan.  This will inevitably increase the number of people of working age and should be factored into a demand-side study such as this.

At Table 15 – Employee Supply Forecast – Extra Floor Space Required 2010 to 2031 – a figure of floor space per worker for the various sectors is set out.  This is interesting inasmuch as it suggests that the current space use allocations will subsist for the next twenty years or so – property industry evidence shows that some sectors are trending down (notably offices which shows the largest supply) and some are flat or increasing.  What is not clear is what assumptions should be made to accommodate and attract the types of businesses set out in the EM3 strategy – notably, aerospace/space, cyber security, digital economy and pharmaceuticals.

Approach 3 – Comparing Forecasts Against Past Commercial Floor Space Take Up

Generally the content of this section is logical – there must be some question as to how much store should be set by previous organic growth versus a strategic plan to grow.

At 3.8.10 there is a section on B8 (Warehousing) demand for which has varied considerably between 1998-2004 and 2005-2008.  The key question is whether there is any means by which to assess likely future growth (or inhibit it if other employment growth is preferred) or whether the Local Plan will need to be sufficiently flexible to accommodate it if necessary.  It should be noted that the growth of internet shopping means that regional distribution centres are likely to be in greater demand rather than less.

Factors Impacting upon New Job Creation and the Need for Additional Floor Space

The trends considered are Off-shoring and Home-Shoring.  There is a further trend of Near-Shoring (although for our purposes since Guildford is a high-cost centre, it is likely this will operate in similar fashion to off-shoring.

The key consideration for Guildford is that it is likely to attract the residual (head office or similar) functions with a higher value-add.  One potential issue for this will be that Guildford will find it difficult to provide relatively unskilled white collar jobs – the typical activities that tend to be off-shored.  A major analysis should be undertaken to establish how to either up-skill young workers or to attract a wider range of businesses despite the higher underlying costs of living and being in Guildford.

There is little current evidence to show that trends in home-working are either permanent or lead to reduced floor area in the long term.  It is clear that home-working (or perhaps hub-working – explained below) have the propensity to reduce space use.  Some of the older office stock may well not lend itself to the type of flexibility required for home-working to lead to structural space reduction – for example, older network cabling, poor layouts, etc., can be a major constraint for businesses wishing to do more with less space.

Hub-working is a new trend for individuals to gather in a working environment (more formal than the ‘Starbucks’ office) and, whilst it uses space, this could be provided in community facilities across the Borough rather than in established business centres.

Stage 3 – Comparing the Forecasts with Past trends for Employment Land

Figure 7 (p47) maps the trend lines modelled in the three approaches above for Offices:

OfficeSpaceChart

The ELA Report correctly identifies the vision in the Guildford Borough Economic Strategy (2013-2031) for Guildford to have “world class businesses with capacity to expand…” and “an evolving and vibrant economy”.

The ELA, however, sets its recommended provision at between the medium and high levels in Approach One above, rather than look at the previous provision as a target. It does, however, state that the policy will be monitored and the ELA updated on a three-yearly basis.

I would recommend that the provision should be capable of providing more than the target based upon demand but not less than the lower threshold.  this should enable tired old buildings and locations to be eliminated and relocated without companies having to leave the area to transform and grow.

It is worth highlighting that the likely incremental Business Rate receipts to Guildford Borough Council from an increase in office floor area of 65,000 to 110,000 square metres would be in the region of £8m to £12m per year by 2031.  This could provide a good revenue from which to fund infrastructure improvements.

Figure 8 (p49) shows a similar analysis of Industrial floor space, but on this chart the demand and trend are declining.

IndustrialSpaceChart

There is a considerable gap between the trend line and the employee forecast lines and, despite the downward trend and forecast, the ELA is recommending a modest increase in industrial floor space by 20,000 square metres over the Local Plan period.  I think this is appropriate and, even more desirable, it is to Guildford’s benefit if the quality of the supply were to be substantially improved.

Once again, the ELA recognises the remarks in the Guildford Economic Strategy, and this time looks to provide scope for a greater amount of space than trend or forecast to help realise the goals of that strategy.

Figure 9 (p52) shows an analysis of Distribution and Storage floor space.

DistributionSpaceChart

Even more so than for Industrial space, there is a major disparity between the historic trend line and the employee demand lines.  This is the third of three charts which has historic trend above employee demand and this would tend to suggest that the employee demand is either underestimated or that Guildford’s economy is close to saturation point.

Given the comments about the regional economy and targets for growth, it is reasonable to deduce that the employee demand figures are simply wrong.

The ELA does at least conclude that the target floorspace should be between the trend and demand forecasts at 40,000 -70,000 square metres.

Baseline Floor Space Requirements

The ELA Report deduces that the total floor space to be provided needs to be between a range of 105,000 square metres (10.5 Hectares) to 200,000 square metres (20.0 Hectares).

I have modelled the totals for the three property types below, together with the ELA recommended range:

TotalDemand

Clearly, the upper limit of the ELA recommendation does not provide sufficient space to maintain trend and, for a Local Plan relying on or promoting growth, this seems to be a weakness in the Evidence Base.  There should be a t least enough total space to meet the previous trends and Land Allocation strategies should ensure good quality, connected space is provided to set Guildford’s businesses at or above regional and national norms.

Below I have reproduced the Press Statement issued by Guildford Borough Council on release of the ELA:

Employment land study makes case for economic growth

Today, we have released a study into how much land we need to provide local jobs in the future. The Employment Land Assessment has found there is currently not enough employment land to meet future growth needs in our borough.

The research is one in a series of evidence-based documents that will support the development of the Local Plan for our borough. Together, the documents look into the availability of land for housing and business growth over the next 20 years.

“This evidence will help us understand how we can protect local jobs in the coming years and attract new jobs to the area,” says Cllr Monika Juneja, Lead Councillor for Planning and Governance.

“The new Local Plan must protect existing major employment sites. It also needs to ensure employers have a degree of choice and flexibility when looking for new premises to ensure they can operate efficiently.

“If we don’t provide enough space for future growth, existing businesses could move out of the borough and new businesses may not be able to establish themselves,” she added. “We need to make sure existing small local companies, emerging businesses and large companies are able to invest in our community.

“We don’t want people to have to leave the borough to find jobs – we want to preserve the vibrant, thriving economic life of our borough, now and in the future.”

The ELA, in failing to recommend the provision of employment land at even the same rate as previous trend, far from ‘making the case for Economic Growth’ seems to limit the propensity for Guildford to grow through the Plan period.  This does not seem to be the panacea suggested in the press statement.

Meeting the Need for Additional Floor Space

There is regular reference in the Report to the poor quality of much of the existing employment accommodation and this is rightly remarked on in 4.6.3 in the context of a shortage of Grade A Office Space in the Borough “which is needed to attract inward investment in the borough and meet goal (sic) to ‘ensure that Guildford borough will be the top-performing economy in Surrey in the years up to 2031 and beyond’ (Guildford Borough Economic Strategy 2013-2031)“.

This section of the report examines vacant premises as at July 2013 and unimplemented planning permissions as at January 2013.  It puts these into the following table (Table 28)

Demand-ExgSupply

This shows a total available supply that, based on historic trends would run out in 2020 and, at the ELA assessment of High Demand, would run out in 2022 (as shown below).

TotalDemand_Supply

The analysis in this section of the ELA does not account for any businesses who might be attracted to Guildford if the strategies likely to be adopted in the Local Plan are successful in terms of resolving the long-standing issues identified in the Economic Strategy, namely, traffic congestion and housing affordable to workers.

This all seems to show that there will be a substantial shortfall through the Plan Period.

Having arrived at an “Absolute Maximum” supply level of 135,600 sqm by a combination of the figures above and by the more efficient use of the existing buildings, the report then goes through a Reality Check at 4.10.  This revises the figure down to 74,300 sqm.

At this level of supply we will have run out of available space between 2017 (trend) and 2019 (high) as shown below:

TotalDemand_Supply-REALITY

The ELA then goes into Stage Four – Meeting the needs medium to long

There is a minor discrepancy between 4.10.9 (which notes there are seven potential additional sites) and 5.1.8 and Table 32 which both say eight.

NOTE; In my comments on the SHLAA and the SPR, I noted that we should consider a more extensive increase in Slyfield.  This taken with the Onslow/Shalford ward extension at Blackwell Farm (H1 and H2 of the GBCS) should be able to accommodate the level of commercial space required.

The ELA concludes on page 69 that for 2013 to 2031 we should make a provision of between 105,000 and 200,000 sqm of office/industrial/warehousing space, further concluding that:

“6.1.5 If we do not protect our existing major employment sites from alternative development proposals: the borough may increasingly have a dormitory role with increasing levels of (net) out-commuting, there may be a reduction in available local job opportunities for local residents which is particularly important for those who are less well qualified to travel outside the borough for employment, locally grown businesses may be forced to locate and/or relocate outside the borough as a result of lack of choice and availability of sites and premises.

6.1.6 We believe the new Local Plan needs to strongly protect its locally strategic employment sites identified in figure 3 (p14) and table 2 (p15). This would comply with the National Planning Policy Framework (paragraph 21) which states councils should
“set criteria, or identify strategic sites, for local and inward investment to match the strategy and to meet anticipated needs over the plan period”.
Loss of these sites to alternative uses runs the risk of constraining employment growth, limiting economic diversification and fuelling a significant imbalance between the size of the resident workforce and the number of locally available jobs.”

There are 23 appendices to the Report and most of these have not been carefully reviewed in this commentary.

Appendix B – Employment and Industrial Characteristics Review of Guildford

On page 81 the ELA refers to a July 2010 Lambert Smith Hampton office report but reports 2012 take-up.

On page 82 the Lambert Smith Hampton data on Industrial and Distribution is from March 2011 and includes the comment “The general shortage of industrial land could herald the return of speculative development in late 2011/early 2012.” This clearly did not happen and must call into question the accuracy of the remaining data and any assumptions formed on the basis thereof.

On page 83 Figure 1 shows the Regional property Markets in the South East from a CBRE market study of 2007 – well out of date.

On page 84 Lambert Smith Hampton’s office report from page 81 is duplicated – and again at page 149

On page 85 the LSH industrial and distribution report from page 82 is duplicated and again at page 149.

On page 134 the 2007 CBRE figure from page 83 is repeated.

Summary

Wearing my Corporate Real Estate hat, there is no indication from the ELA that Guildford is open to attracting major new business, and this needs to be properly discussed in the Issues and options consultation.  If we wish to attract larger businesses and be once again a focus for headquarters as well as having a thriving small and medium sized business sector, we will absolutely need to be bolder with our numbers and strategy, taking more of a leaf out to the EM3 book and setting an objective to compete with all other regional centres.  This, however, needs to be done in a sensitive and well-thought way to avoid having a surfeit of empty space and a failing market such as Bracknell is suffering from in the present market.

SHLAA Sites

This commentary is a first look at some of the sites being advanced for the Strategic Housing Land Availability Assessment.

Noting my comments on the SHLAA document itself, I am beginning this site specific review with the Green belt sites identified.

It is worth pointing out that inclusion in the SHLAA does not imply planning would be granted and the Report does not make that sufficiently clear.

Land Currently in the Green Belt

Beginning on page 284 of the SHLAA:

Site Ref 46: Green Belt and Countryside Report land parcels C1 and C2

Identified in the South East Regional Plan in 2009 as a target area for release of Green Belt Land.

Suggests 300 homes towards the 1-5 year target (although it later describes this as “the possibility of some first phase completions occurring in the first five years”) and a further 1,331 homes in the 6-10 year window.

The site is 88.83 Hectares (that is 219.5 acres) of mostly ‘moderate’ agricultural land.

There will no doubt be some serious questions here from local residents but perhaps the biggest challenge is to understand how these sites have been assessed in the Green Belt and Countryside Report which has led to them being brought forward from the Green Belt for development as a priority.

C1-C2C1-C2-Photo

These images show the designation of the site(s) in the GBCS Report alongside an aerial photo from Google Maps.

Below is the extract from the SHLAA:

C1-C2_Plan

The GBCS Report Appendices to Volume 2 include two files:

20130730_GreenBelt-Vol2-Parcel_C1

20130730_GreenBelt-Vol2-Parcel_C2

For parcel C1 (Gosden Hill Farm) the walking routes seem to disregard the presence of woodland which was part of Merrow Common.  The GBCS Report (Volume 2) notes for C1 that “Woodland to the south west of the land parcel between Merrow Lane and Gosden Hill Road is designated as an SNCI“.  In what way is it appropriate to consider a direct route as below for the purposes of calculating the sustainability score?  What should the score be in reality if the route were drawn to circumvent the Merrow Common woodland?:

C1-example

I am aware of more detailed concerns about these particular sites (not least that distance to the nearest A road shows a walking route to the 6-lane dualled A3 (see below), and that the cultural facility measured in the Report actually closed in 2009).

C2-example

Clearly some careful re-examination of the fact-based assessment needs to be done before these sites can be compared with other sites in the Evidence Base.

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Site Ref 311 (part): Green Belt and Countryside Report land parcels H1 and H2

The first thought I had when I read this entry was “why on earth is this land in Shalford Ward?” – see Ward Boundaries below:

ShalfordWard

Suggests 300 homes towards the 1-5 year target (although it later describes this as “the possibility of some first phase completions occurring in the first five years”) and a further 1,633 homes in the 6-10 year window.

The site is 139.68 Hectares (that is 345.2 acres) of mostly ‘moderate’ agricultural land.

There will no doubt be some serious questions here from local residents – most if not all of whom will live in the adjoining Onslow Ward.

Part of the site is in an Area of Outstanding Natural Beauty and Area of Great Landscape Value – this part should have been screened out of consideration before assessment within the Green Belt and Countryside Report.

The Green Belt and Countryside Report plan is shown below with an aerial photo from Google Maps:

Zone-HH1-H2-Photo

Below is the extract from the SHLAA:

H1-H2_Plan

The GBCS Report Appendices to Volume 2 include two files:

20130730_GreenBelt-Vol2-Parcel_H1

20130730_GreenBelt-Vol2-Parcel_H2

For parcel H2 the walking routes seem to disregard the presence of woodland (Strawberry Grove and Manor Copse).  The GBCS Report (Volume 2) notes for H2 that “Strawberry Grove and Manor Copse located to the east of the land parcel are designated as Ancient Woodland.  This designation also applies to a tree belt which extends from the north of Strawberry Grove to the railway line“.  In what way is it appropriate to consider a direct route as below for the purposes of calculating the sustainability score?  What should the score be in reality if the route were drawn to circumvent the Ancient Woodland?

H2-example

The walking route on the above example is between the centre of parcel H2 to the nearest town or district centre.  The route shown goes to Guildford Town centre when Wood Street Village, Park Barn and Onslow Village all have district centres nearer than the Centre of Guildford.  Perhaps this aberration is due to the failure of the Settlement Profile Report to consider the Guildford Urban Area as a collection of neighbourhoods around the Town Centre.

THE OTHER KEY ELEMENT FOR CONSIDERATION HERE IS THAT THIS IS LAND THAT WAS EARMARKED FOR FUTURE UNIVERSITY EXPANSION AND COULD BE A CRITICAL COMPONENT OF GROWTH (EG., OF THE RESEARCH PARK).  IT SHOULD NOT, NECESSARILY BE BROUGHT FORWARD AS A MAJOR HOUSING SITE.

——————————————————————————————————————–

Site Ref 2014: Green Belt and Countryside Report land parcels H8-A and H8-B

These parcels relate to land to the south and west of Fairlands, and should be taken in the context of Site Ref 311 (part) described above.

AreaH_CombinedEffect

These two areas taken together represent a substantial incursion into the Green belt to the West of Guildford which, whilst they may be appropriate in isolation, should ask the question whether there is a likely future coalescence and whether there should be a more detailed study of the area to identify the merits or harm in extension of Guildford from Park Barn to Fairlands and Wood Street Village, together with suitable infrastructure and facilities to serve a new neighbourhood.

The proposed Fairlands expansion is 27.66 Hectares (63.8 acres) and is planned with an average density of 30 dph (dwellings per Hectare) as against the 40 dph applied to the urban extension.  There is no reference in the Settlements Profile Report to the current density of Fairlands and, for this to be a village extension and to be in character with the existing settlement, surely some analysis should have been done at Settlement level to inform a supply-side study such as this.

Thinking Bigger…

In Volume III of the Green Belt and Countryside Report a further area is identified for removal from the Green Belt:

H8_Plan

If it is appropriate to extend Fairlands on parcels H8A and H8B, then why not consider a more ambitious expansion that could link better with facilities and transport routes by creating a critical mass and by planning on a larger scale:

H8A-H8B_extended

The orange areas would amount to around 100 Hectares (or, say, 250 acres) and could provide in the region of, say, 1,500 homes.

Links from the orange land (H8C and the southern section of H8) to H2 (which could then provide the university and research park extensions – employment – and could support local amenities) would suggest that a comprehensive urban expansion in this area could bring major benefits to the town.  Equally these could link into the proposed new Park Barn Station (or, better still, some form of transit system linking the university, hospital, park & ride and these new settlement areas to the town)

Monorail

The above image showing a potential Docklands Light Railway type system is included simply to illustrate how these could be connected communities and could take local traffic off the roads (including the various shuttle bus services currently running from the station to the Research park and to Guildford Business Park) and solving some of the university’s connectivity issues across its two campuses.

The thinking behind this is that, if a major realignment of the Green Belt is required, it should be defensible and should accommodate sustainable development.  A driverless train service like the Docklands Light Railway could run, say, three or four pairs of carriages around the loop and not be constrained by hours of operation in the way current bus services are.  this means commuting to and from employment areas should be easier and it should also support the evening economy in town as well as hospital visiting.

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Jacobs Well and Slyfield and Site 245

Missing from the Housing Land Availability Assessment (due to the way the land was scored in the Green Belt and Countryside Report) is the potential to redraw the Guildford Urban Area Boundary around the north side of Jacobs Well.  This is not a recommendation for implementation but seems to be a perfectly logical possible alternative to expansion in other areas which should be considered.

A new Urban Area Boundary would be defensible and the increase in housing where jobs are located and where intensification of employment uses is considered in the Employment Land Assessment seems to accord with the requirements of sustainability – notwithstanding that it requires the swallowing up of an existing settlement into Guildford Urban Area.

B3_Plan

Parts of Parcel B3 and Parcel B2 could be excluded from Green Belt and developed in such a way that the area could have stronger transportation links to Guildford – ensuring that the area as a business area and residential quarter is less reliant upon car travel and that journey times are more predictable.

In the plan below (introduced as an example and thought-starter rather than as a proposal) the yellow area is Site Ref 245 in the Strategic Housing Land Availability Assessment.  The orange areas are currently not included as potential sites for development in the Green Belt, I have suggested potential for a Park & Ride on the lower part of the site with access to and from the A3 at Burpham (catering for Guildford-bound traffic from the A3 north) with connections between Slyfield and Clay Lane (blue dashes) and a potential Park & Ride bus route joining the A320 close to its junction with the A3.  This assumes that the scale of development would be such as to enable infrastructure and services in this way.  I have assumed a green buffer along the river for both flood protection and environmental reasons.  I would reiterate, I have included this as a means of identifying choices of places and ways to amend the green Belt boundary and to allow development that can be made to be sustainable, deliverable and to ensure future defensible boundaries.

B2-B3_Extension

As a broad assessment, I would consider this could accommodate an additional 1,000 to 1,500 homes and some additional employment areas to meet or go towards the needs identified in the Employment Land Assessment.  This could perhaps be achieved earlier than the 11-15 year timescale suggested in the SHLAA for Site 245.

Placing a Park & Ride that could be accessible from both the Woking Road (A320) and the A3 could mean that the existing Park & Ride at Spectrum could be used for another purpose – potentially for housing development or for some other purpose.

Furthermore, this might be a more appropriate once-and-for-all redrawing of the Green belt Boundary than carving out the area of A4 (Whitmoor Common) and A1 (Stringers Common).

Site 245 is 41 Hectares (101.3 Acres) and is currently an industrial estate and sewage works.  It is proposed for 1,000 homes in years 11-15.

There is a specific area master-planning group (SARP which stands for something like Slyfield Area Regeneration Partnership) that has been established to bring forward this site.  This would seem to be a suitable site for housing as long as the river corridor is protected and if the site can be properly linked to established residential districts and associated services and facilities.  Once again there is no specific regard to settlements within the Guildford Urban Area and so no assessment in the Evidence Base can be directly applied and cross-referenced with this proposal.

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Other Green Belt areas included in the SHLAA are village extensions that can properly be assessed by the Parish councils and/or residents’ groups, and they affect the Guildford Urban Area only to the extent that a failure to find sufficient rural sites will place a greater burden on the urban area.

ONE AREA OF OMISSION SEEMS TO BE THE FAILURE TO IDENTIFY A SITE FOR A NEW SETTLEMENT (SUCH AS WISLEY AIRFIELD) IN THE SHLAA, AND THIS SHOULD BE ADDRESSED FOR CONSIDERATION UNDER THE ISSUES AND OPTIONS CONSULTATION.

Countryside Outside the Green Belt

In general, it is not my intention to focus on the urban area of Ash South and Tongham.

On the other hand, from the pages of the Surrey Advertiser (9th August) there is a public outcry about a planning application for 400 houses on land that forms part of Sites 45 and 33 (SHLAA p262).  this does not bode well for a process whereby a far larger urban extension (or series of extensions) is proposed.

Set out below is the summary of sites from SHLAA.

Site Ref GBCS Ref Ward Area (Ha) TOTAL Houses 0-5 Houses 6-10 Houses 11-15
45, 33 K7 Ash South & Tongham              42.00               685                              685                                –                                  –
1450 Ash South & Tongham                0.11                    2                                  2                                –                                  –
51, 21, 2004, 57, 11, 10, 2005 K9 Ash Wharf and Ash South & Tongham              13.15               328                                 –                            328                                  –
36 K5 Ash South & Tongham                3.55                  35                                 –                               35                                  –
2000, 1163, 394 K2 Ash South & Tongham              18.56               464                                 –                            464                                  –
1211 K9 Ash South & Tongham                2.91                  75                                 –                               75                                  –
2001 K6 Ash South & Tongham                2.87                  71                                 –                               71                                  –
2002 K6 Ash South & Tongham                1.90                  62                                 –                               62                                  –
338, 2006 K8 Ash South & Tongham              11.20               242                                 –                            242                                  –
1451 Ash South & Tongham                0.50                    3                                 –                                 3                                  –
 TOTALS              96.75            1,967                              687                         1,280                                  –

The reliance on 687 units from this area in the years 0-5 is probably reasonable assuming planning permission is granted for the current application (400 units).  If not, there is a risk to the five year supply totals.

Identified Village Settlements

In general, development opportunities in the Identified Village Settlements (SHLAA p. 176 onwards) are village extensions that can properly be assessed by the Parish councils and/or residents’ groups, and they affect the Guildford Urban Area only to the extent that a failure to find sufficient rural sites will place a greater burden on the urban area.

Guildford Urban Area

As a general comment, many Guildford Borough Council-owned garage blocks are included for development.  These may provide amenities for neighbouring housing and, to the extent that residents currently park their cars in the garages, such development may lead to a greater problem of on-street parking – an issue that already causes some problems with residents in Guildford.

A few of the proposed housing sites in the Guildford Urban Area have been selected below for critical analysis or comment.

Site 50 – Land at Guildford Cathedral

The area of land shown (3.28 Hectares) does not adequately reflect the proposal making it very difficult to evaluate.

CathedralHill

The Achievability Assessment suggests that this can be delivered within five years

Looking at the scale of housing opposite and superimposing this fronting onto the road, it should be possible to achieve around 25 family homes whilst respecting the upper slopes and protecting a similar area of hillside undeveloped to the west as on the opposite (university) side before the refectory car park.

Site 92 – Land Adjoining Boxgrove County Primary School

Given the stated shortfall in school places in the town centre, care will need to taken to ensure that this space will not be required for school expansion to meet the needs of an extension to the Guildford Urban Area.

Site 100 – Land on both sides of Walnut Tree Close (GU1 1TP)

This land is valuable residential land currently underused for commercial purposes.

Walnut Tree Close

The plan below shows park land alongside the River Wey (complementing the green area and National Trust site on the other side of the river.  The dark blue area (assumed to be around 2.5 Hectares of the 4.5 Hectare site identified) should be able to accommodate housing at a greater density – say around [175 dwellings per hectare, providing in the region of 400 homes].  The current alignment of Walnut Tree Close could be smoothed out to improve movement (dotted in red) and there is scope for a new railway and river crossing at around the point shown (narrowest part of the railway) which would help to remove traffic from Guildford town centre and to access the University and the Cathedral from a wider area of Guildford.

Walnut Tree Close_Development

The Employment Land Assessment indicates that this site currently has 20,000 square metres of floor space at relatively low levels of mass and density.

The SHLAA suggests that the time scale for development could be 6-10 years and this may be realistic if the buildings all fall vacant within the time scale – probably with a route reserved for the river/rail crossing and the realignment of Walnut Tree Close completed.

Businesses could be displaced to Slyfield as long as the transport infrastructure were to be improved for public transport access between the town centre (and station) and Slyfield.  The ELA suggests there are around 670 jobs located on the site but in reality this seems to be outdated as some of the buildings are already being demolished and others seem barely used.

This suggestion would see a much larger number of urban-living homes provided in an area badly in need of regeneration.  The fact that the development would back onto the railway should give scope for some development height and mass which might not be acceptable elsewhere.  parking should be at half-basement level to help raise the living accommodation clear of flood levels.

Site 136 – Merrow Depot

The area shown in the Employment Land Assessment includes the industrial estate fronting onto the through road part of Merrow Lane.

The SHLAA entry is restricted to the land owned by Surrey County Council.

This site is across the railway from Site 46 (C1 & C2) – see above – and there has been talk in the past of creating a new station at Merrow in about this position to serve any urban extension and the employment centred in Appendix U7 of the ELA.

Prior to development of either this or Site 46, there should be a full study of the combined effects of the developments and also any benefits of using all of this site for commercial purposes (or even community facilities that a development on the scale of Site 46 might require) centred around a new station.

Site 232 – Bus Depot, Leas Road, Guildford

The bus depot should be relocated to a business environment such as Slyfield.

It also seems to be worthwhile identifying an alternative site for Safeguard Coaches (Madrid Road) and regenerating their site for housing  – that site does not appear in the SHLAA.

For Site 232, the time frame may be optimistic given the presence of fuel tank(s) on the site and the potential need for remediation of the soil in a sensitive location.

Site 1584 – Former Pond Meadow School, Guildford

Given the stated shortfall in school places in the town centre, care will need to taken to ensure that this space will not be required for school expansion to meet the needs of the nearby extensions to the Guildford Urban Area.

Other sites in the Guildford Urban Area will attract specific comments from residents and neighbours and none of them seems to offer strategic opportunity or threat.

Missing Sites in the Guildford Urban Area

In addition to the Safeguard Coaches site at Madrid Road, there is also a former GSA building in Madrid Road that does not seem to be occupied and that could be suitable for development.  See below.

MadridRoad

The principal site that goes unmentioned is the Farnham Road Hospital where there may be merit in relocating the hospital use to a site on or near to the Royal Surrey County Hospital and regenerating the site (including conversion of the significant building(s)) for new homes. See below. This includes the adjoining site (Site 129) shown in the Town Centre section of the SHLAA report as being available for development in 6 to 10 years.

FarnhamRoad

Guildford Town Centre

The most odd finding in the Town centre section of the SHLAA Report is the disparity between dwellings per hectare across the range of sites without explanation.

Site 134, for example (Guildford Plaza) should be capable of a reasonable density – especially having regard to the scale of building that previously occupied this plot.  It is shown as accommodating only 37 dwellings per hectare although the site levels would probably allow underground parking and still to make good use of the frontages of the site.

Site 171, Guildford Railway Station shows 54 dwellings per hectare.  This is largely because the entire railway station is included in the site. In actual fact, the area for housing (including the station forecourt) is probably around 2 hectares and so the density is more like 190 dwellings per hectare.

Site 173, Bedford Road shows 83 dwellings per hectare, whereas Site 174, Bright Hill Car Park shows 106 dwellings per hectare.

Much greater clarity is required to establish on what basis the density figures were derived.

Site 171 – Guildford Mainline Station (aka SOLUM)

This site represents a linear development along each side of the railway station which, if implemented, would preclude future access for a new relief road across the railway.

A potential route for the road is shown at Site 100 (above) and would impact only the very end of the site. Other potential routes show a bridge closer to the station and great care should be exercised to understand the opportunities for wider infrastructure improvements as part of the Solum development.

Site 178 – Guildford Park Car Park and Site 1107 – Jewsons

The  plot designated Site 178 includes (at its north-east corner) a relatively new office building – never let – recently converted into student housing (shown in Navy Blue below)

GuildfordParkCarPark

 

This plan shows a possible route for a relief road (following on from Site 100 above).

On the other side of the railway is Site 1107, Jewsons which would probably be able to remain in situ (or ideally, to be brought forward for residential development irrespective of the alignment of the relief road as shown in Site 100 above.

Careful analysis should be carried out to establish that such development does not preclude the relieving of traffic in Guildford town centre and the creation of the first railway bridge crossing in the town centre for around 150 years.

Site 1422 – Dolphin House, North Street

The site line is probably drawn too tightly around this site whose opportunity would the wider regeneration of the top of North Street.  This could also include the red-lined area  and might provide a high quality town centre housing development (above retail) which properly respects both the houses in Martyr Road and Abbots Hospital.

DolphinHouse

Other Town centre Sites

Sites 1419 (Debenhams) and 1420 (Guildford Borough Council Offices) could each be characterised by their ability to possibly be relocated within a regeneration of North Street.  These should form part of a strategic study alongside the planning of the town centre regeneration and should be explored with an open mind.

The Library site (Site 1236) could be freed up by relocating the library into the North street development and, because of its position behind Guildford House, could be opened up as an enlarged pocket park, framing the important rear façade of Guildford House and creating an oasis of calm in the town centre.  This should also include the relocation of the employment centre offices to open up the Old Cloth Hall to views up North Street.

NO REFERENCE HAS BEEN MADE TO THE POTENTIAL TO SITE RESIDENTIAL USES AS PART OF THE NORTH STREET DEVELOPMENT AND THE INTENDED RESIDENTIAL UNITS ON THE BELLERBY SITE (AS PART OF THE SUPERMARKET DEVELOPMENT) HAVE ALSO APPARENTLY BEEN OMITTED.

Summary

There will be many people who disagree with my comments and I am happy to hear all feedback.

The key observations are:

The SHLAA has not considered all options;

The SHLAA has relied on some of the flawed outcomes of the Green belt and Countryside Study;

The SHLAA should help to guide a long term vision of the various different parts of the town and Borough, and yet there is no real attention given to the settlements within the overall Settlement of Guildford Urban Area – for this the Settlement Profile Report is deficient.

In the Employment Land Assessment, there is not enough granular detail as to where employment might be provided, or what mixes are supposed, when considering residential use of part or all of employment land.

In the Infrastructure Baseline Report, there is a clear concern about the traffic congestion in the town centre and this should be addressed in the other reports even if to note that prior to any major development, a detailed assessment must be undertaken to avoid the preclusion of a long term solution to traffic or transportation deficiencies.

No guidance or recommendation is made as to the need or desirability to create a new settlement in the countryside (albeit three suggestions are floated briefly in the introduction.  It would have been useful to see some indication of the scale and numbers of units such development might accommodate and to ensure that new settlements would be discussed as part of the Issues and options Consultation in late 2013.

Strategic Housing Land Availability Assessment

The Strategic Housing Land Availability Assessment has been published as part of the Guildford Borough Council Evidence Base and not as a consultation draft.  Weighing in at almost 400 pages this seems more daunting than the reality – many pages are made up of individual site assessments.

The first observation is that there is no estimated target number of housing units to provide over the plan period (although on page 5 there is reference to “our interim housing number is currently 322 homes a year“).

If we assume the Borough-wide housing need of 322 units, this would suggest the required number of housing sites to find over the fifteen years of the Local Plan would be 4,830 homes.  NPPF says that, for any five year period, Local Authorities must have identified their five year need plus 5% or 20% depending on their prior ability to satisfy housing need.

Figure one on page 9 shows that the number of housing units completed in 2008/9, 2009/10, 2010/11 and 2011/12 has remained resolutely below 250 units per year, suggesting that the 20% margin would apply to 5-year housing numbers.

Consequently, at any time during the plan period, Guildford Borough Council would need to have identified available and viable land for 1,932 dwellings for delivery within five years.

So, over the plan period, this suggests that housing need is 4,830 homes (fifteen years at, 322 units plus a floating allocation of 65 units to cover NPPF obligations).

The SHLAA identifies land for 11,799 new homes (no indication as to what percentage increase in new homes across the borough that would represent) and does not explain why the Report has seen fit to aim to provide around double the likely level of supply (for example, if there is a need to make up for several years of underdevelopment).

Any statement of need for housing should be kept under constant review as Local Plan policies emerge and as, say, employment land is identified so as to ensure that there is sufficient housing to accommodate the needs of employers and their staff.

The SHLAA was prepared in conjunction with the Employment Land Assesment (ELA) – published on 7th August – and the Strategic Housing Market Assessment (SHMA) – not yet published at the time of writing this review.

The tables 1-6 set out the results of the assessments for Guildford Town Centre, Guildford Urban Area, Western Urban Area, Identified Village Settlements, Rural Exception Sites and Previously Developed Land in the Green Belt respectively.

The figures from tables 1-6 should have been sub-totalled and the shortfall identified so that:

Years 1-5   631 units (required 1,675, hence shortfall 1,044 units)

Years 6-10   1,096 units (required 1,610, hence shortfall 514 units)

Years 11-15   1,896 units (required 1,610, hence surplus of 286 units)

The next stage would be to assess how many housing units could be brought forward from later periods to meet some or all of the shortfall.  Assuming the basis of the Report is sound and that all such units have been accelerated (not totally clear from the text), there would be a need to find the additional dwellings from Green Belt or Countryside beyond the Green Belt.

Table 7 identifies 724, 1,280 and 0 potential new homes for the three periods respectively from Land in the Countryside but Outside the Green Belt.

If implemented, these housing units would still leave a nominal shortfall in Years 1-5 of 320 (64 dwellings per year), a nominal surplus in years 6-10 by 766 (153 dwellings per year surplus) and years 11-15 are unaffected with a surplus of 286 units.

OVER THE PLAN PERIOD, THIS SUGGESTS THERE WOULD BE 732 MORE HOMES THAN TARGET CREATED BETWEEN YEARS 1 AND 15 (AN OVERALL TOTAL OF 5,562 HOMES) WITHOUT NEEDING TO REDRAW ANY GREEN BELT BOUNDARIES.

The main problem, however, is that the five year supply from Years 1-5 is insufficient to meet the requirements set out in NPPF without using land in the Green Belt.

Table 8 sets out the summary of assumed development on land assessed as suitable for housing that is currently in the Green Belt.

Table 8 shows Years 1-5 at 1,214 in the Green Belt as currently drawn (an oversupply of 894 units against the 322 homes target per year referred to above).  No justification is given as to why such oversupply should be provided;

At Years 6-10 table 8 suggests an additional 4,873 homes (on top of the surplus from tables 1-7), making a total surplus of 5,639 homes. Again no justification is given as to why such oversupply should be identified.

At Years 11-15 table 8 suggests 115 homes could be provided in the Green Belt, adding to the surplus of 286 from tables 1-7, totalling 401 homes above target level.

Further analysis of the various sites will follow although it is not expected that this analysis will be a thorough one for each plot proposed.

[to be continued…]

Green Belt and Countryside Study

WORK IN PROGRESS

(3rd August 2013)

The Green Belt and Countryside Study sets out to “determine appropriate Potential Development Areas (PDAs) for future housing and other growth requirements if suitable land cannot be identified within built-up areas.” The Summary document sets out to provide background to the instruction from Guildford Borough Council to Pegasus Planning Group – which evolved over several years – and to illustrate how the four component volumes of the evidence base relate to each other. The Study has assessed specific parcels of land in relation to Green Belt planning policy, sustainability criteria and environmental capacity to determine appropriate areas for future development within the Borough. The Study has examined land across the Borough within Volumes I, II, III and IV as follows:

Volume I – Summary, Introduction and Background to the Study

Section 1 provides a Non-technical Summary of the Study. Section 2 provides an Introduction, including an overview of the purpose and scope of the Study. Section 3 provides a Review of Previous Green Belt Studies, and an evaluation of methodologies undertaken for other districts. Section 4 provides a Planning Policy Review, and the planning context within which the Study has been undertaken. Section 5 outlines the Role and Purpose of the Green Belt within Guildford Borough. Section 6 outlines the Green Belt and Countryside Methodologies used for assessing land within the surroundings of urban areas and for villages across the Borough.

Volume II – Land surrounding the Urban Areas of Guildford, Ash and Tongham Section 7 details the Methodology for Assessing Green Belt and ‘Countryside beyond the Green Belt’ within the surroundings of Urban Areas at Guildford, Ash and Tongham. Section 8 outlines the Study Findings for assessing Green Belt and Countryside beyond the Green Belt surrounding the Urban Areas of Guildford, Ash and Tongham. Section 9 details the Conclusions for Volume II.

Volume III – Land surrounding Villages across the Borough Section 10 details the Methodology for Assessing Green Belt Land surrounding Villages across the Borough. Section 11 outlines the Study Findings for assessing Green Belt Land surrounding Villages across the Borough. Section 12 details the Conclusions for Volume III.

Volume IV – Insetting of villages from the Green Belt Section 13 details the Methodology for the Insetting of Villages and defining Green Belt boundaries within Guildford Borough. Section 14 outlines the Study Findings for assessing the Insetting of Villages and defining Green Belt boundaries within Guildford Borough. Section 15 details the Conclusions for Volume IV.

VOLUME I

Volume I, apart from setting out a summary of findings at 1.11 to 1.48 does not really add anything to the remaining volumes. The assessment looks at how well specific parcels of land serve the purposes of the Green Belt (as defined within PPG2 and the NPPF) – and it would be helpful if those had been reproduced at 1.5. Following identification of the parcels of land they were scored based upon how well they meet the purposes of the Green Belt – including the ability to check the unrestricted sprawl of large built-up areas; the prevention of neighbouring towns from merging into one another; assistance in safeguarding the countryside from encroachment; and the preservation of the setting and special character of historic towns. A similar approach was adopted in assessing the land parcels around the Borough’s villages. At 1.7 the Report notes that the Green belt parcels are “assessed against sustainability criteria and environmental capacity” but the authors leave it for the reader to trawl through the remaining documents to try to identify the specific tests. The report identifies that 16 PDAs on the periphery of urban areas would be capable of accommodating approximately 9,800 dwellings.

ALL OF THE SUMMARY FINDINGS LISTED IN VOLUME I WILL BE REVIEWED IN THE VOLUMES IN WHICH THEY OCCUR IN DETAIL.

Some of the characteristics set out in this Report should have found their way also into the Settlement Profile Report – the linkages between the documents should be much more formal and comprehensive.  Equally, the Infrastructure Baseline does not provide good interface with this document. It is not clear from Volume 1 whether the Report considered any new settlements rather than simply the land around existing ones.  Wisley Airfield might be one such area for consideration. At 3.9 the Summary refers to five purposes of the green belt designation (but omits them here); it then recites them as being in Section 9 of NPPF – they are:

  • To check the unrestricted sprawl of large built-up areas
  • To prevent neighbouring towns from merging into one another
  • To assist in safeguarding the countryside from encroachment
  • To preserve the setting and special character of historic towns
  • To assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

At 4.10 the Report quotes from a key element of NPPF (Paragraph 83): “Green belt boundaries should only be altered in exceptional circumstances, through the preparation or review of the Local plan.  The Framework comments that, at that time, authorities should consider the Green Belt boundaries having regard to their intended permanence in the long term, so that it would be capable of enduring beyond the plan period.” Other key paragraphs are recited in this section (NPPF Paragraphs 84, 85, 86, 99, 100, 115, 118, 132 and 156). Section 6 promises information about assessment methodology but does not actually deliver, relying on the reader to migrate to the relevant chapters of the other volumes.

MAIN ISSUES:

  1. It does not seem appropriate to have applied different methodology to urban edge relative to villages.  The village approach seems a more sensible screening methodology; from that point, land ruled out due to environmental constraints (eg AONB) should have been eliminated prior to the “sustainability” assessment (which is itself flawed and works to a pre NPPF definition – reflecting the fact that much of this work was carried out before NPPF was introduced).  To have included figures for land parcels where the AONB designation would presume against development in not only flawed, but invites applications from land owners – and even from Guildford Borough Council, where they are the landowner as at South Warren Farm.  In the latter case, Surrey county Council and Guildford Borough Council have been custodians of South Warren Farm on behalf of residents in order to prevent development.  The AONB constraint is referred to for that site (Parcel E23) but only rather feebly and without ruling the parcel unsuitable for development.
  2. The areas in the Volume where there is a nearby Village (eg., Jacobs Well) are assessed against the village and not the urban area AND there is no particular effort to see if there is a major settlement that could be added within the green belt to reduce the need for realignment of the green belt around Guildford.

VOLUME II

This volume sets out the scientific approach to the sites surrounding the Borough’s urban areas – Guildford and Tongham & Ash. There is a proper context to the work and there is no merit in summarising it here.  Questions and concerns are set out as they arise when page-turning through the document. The key map for this section is available here (20130730_GreenBelt-Vol1-App2_PotentialDevelopmentAreas) (65Mb) STAGE 1 – Compartmentalisation and sub-division of land into separate land parcels The consultants divided the surroundings of Guildford into segments separated by A Roads and railways – on the whole this is a sensible strategy when seen against the NPPF guidelines, and it is puzzling for example, therefore, why the mainline railway north of Guildford is not considered to be a zone boundary. The railway lines represent a more permanent and defensible zone boundary than the A Roads which could be bridged or junctions could be added where a new settlement or significant extension warrants it.

The zones are:

From A322 (Worplesdon Road) to A320 (Woking Road) is set as Zone A (and includes land on both sides of the mainline railway)

Zone-A

From A320 (Woking Road) to A3 including land north of A3 between A3 and Authority border with Woking Borough Council is set as Zone B.

Zone-B

From A3 to London Road Line Railway is set as Zone C.

Zone-C

From London Road Line Railway to A246 (Epsom Road) is set as Zone D.

Zone-D

From A246 (Epsom Road) to A281 (Shalford Road) is set as Zone E (and includes land on both sides of the Gatwick line railway).

Zone-E

From A281 (Shalford Road) to A31 until its junction with A3 and the to south of A3 is set as Zone F and includes A3100 (Portsmouth Road)

Zone-F

From A3 to A31 (Hog’s Back) is set as Zone G.

Zone-G

From A31 (Hog’s Back) to A323 (Aldershot Road) is set as Zone H and includes both sides of the Aldershot line railway).

Zone-H

From A323 (Aldershot Road) to A322 (Worplesdon Road) is set as Zone J.

Zone-J

The land outside the Green Belt surrounding Tongham & Ash is set as Zone K. From these Zones, the land was subdivided into parcels so that [to be continued…]

Zone-K

For each parcel of land a binary score (0 or 1) is applied to qualify the parcel according to each of the following four Green Belt purposes:

  1. To check the unrestricted sprawl of large built-up areas
  2. To prevent neighbouring towns from merging into one another
  3. To assist in safeguarding the countryside from encroachment
  4. To preserve the setting and special character of historic towns

There is no score made for the fifth NPPF definition of purpose, namely: To assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

It seems odd that, where there are areas of the Guildford Urban Area that need regeneration, that no urban expansion could be seen as assisting with the regeneration – for example, if the area in town at Walnut Tree Close and Woodbridge Meadows or William Road could become new residential quarters by moving uses towards Slyfield at Parcel B3.

Using the binary approach for Purpose 1 would see a parcel well away from an existing settlement scoring 0 (suggesting it might be suitable for development under Purpose 1) but an edge of settlement parcel would score 1 (tends against development) even though it may be a more sustainable site.

For Purpose 2 the measure is broadly appropriate but would exclude a parcel where there may be an appropriate choice to make whether to coalesce settlements (eg., Slyfield and Jacobs Well).

For Purpose 3 the measure is again broadly appropriate but this should again not be allowed to preclude a site where a valid once-and-for-all settlement extension is a plausible and pragmatic option.

Purpose 4 is a valid measure, assuming there is no development that could enhance the setting and character of the historic settlement (eg., development should not be permitted on the Hog’s Back that is visible from the high Street and forms part of the historic setting of Guildford).

At 7.16 the Report notes criteria against which the lowest scoring green belt parcels are assessed.  This includes the walking distance to the nearest Town or District Centre.  Since the District Centres are not identified in the Settlement Profile Report, this demonstrates a lack of integration of the evidence base.  Equally, some of the sustainability criteria are geographic facts, whereas some other categories could actually be created as part of a development.

At 7.21 the Report focuses very heavily on walking distances based on the Institution of Highways and Transportation (IHT) guidance (2000) but does not challenge the criteria, nor does it take any account of cycling routes and times.

At 7.24 the Report notes that railway stations are an essential facility in determining the sustainability of a land parcel.  There is no indication whether the suggested new stations at Park Barn and Merrow have been taken into account in assessing parcels in their particular areas (some sort of conditionality might need to apply but the current absence of the station might affect the deemed sustainability and rule out potential for development.

7.27 highlights an issue with the Thames Basin Heaths Special Protection Areas (SPA) in that sites that would otherwise be suitable for extension become undevelopable due to the SPA.  The current SPA runs to 2014 and, as part of the Local Plan process, Guildford should consider whether it needs to be amended so as not to frustrate the allocation of the most suitable extension sites.

The Report generally seems to only include facilities within Guildford Borough, whereas many of the settlements in the Borough are close to the boundaries with other Local Authorities.  Any cross-boundary facilities should be allowed to form part of the analysis for each parcel.

Indeed, a further issue is highlighted in Table 5.4 (pp14-17) where many of the criteria are measured against the Guildford Borough Local Plan Proposals Map (Adopted 2003).  These include some aspirations marked on the plan which do not appear to have been qualified as having been implemented.  Equally, other aspects like, say, cycle routes may exist that were not on the 2003 Proposals Plan.  Equally, there needs to be a robust process to upgrade this information against future proposals for plan areas and site allocations so as to ensure the data is fit for purpose in the context of the new emerging Local Plan.

Volume II – Section 8 – Study Findings

Selected comments are made here but a full look at the Report is essential for anyone with special interest or knowledge.  These comments are intended as GENERAL remarks to try to ensure that all potential sites can be compared and only the most suitable selected.

Section 8 – Stage 2 screening and Stage 3 sustainability assessment

B1 scores 3 and B3 scores 4 (excluding them from consideration as a suitable Green Belt site for development).

B1-B3

The infilling of the area between Slyfield and Jacobs Well may be desirable in the context of, say, better connections to the A3 and Burpham.  This could be designed so as to:

  • Help ensure the viability of the small parade of shops;
  • Local employment opportunities are already substantial at Slyfield and could be substantially increased in the new Local Plan;
  • Access to Guildford town centre is via a designated cycle route which could be accessed by a coalescence or extension.

Under the Consultants’ scoring method these parcels are omitted without detailed assessment at Stage 3, and yet parcel B8 (scoring 2) is included for Stage 3 assessment.

C1 scores 1 and C2 scores 2 – C2 scoring higher because it  “prevents neighbouring settlements from merging”.

C1-C2

The land at C1 (Gosden Hill Farm) is proposed as development which would comprise establishing a new railway station on the London Road line at Merrow.  It seems very odd to suggest that C1 and C2 are qualitatively different in terms of preventing neighbouring settlements from merging.

E1 scores 1 and is, therefore, included as a land parcel for consideration.

E1

In this instance, the creation of the Merrow Park & Ride seems to have raised the spectre of development by extending the settlement eastwards.

Part of the land parcel identified for potential development is within the Area of Outstanding Natural Beauty (AONB) and yet potential development does not seem to have been precluded by it (see ISSUES above).

Parcel E1 does not appear to be listed in the Strategic Housing Land Availability Assessment although it is recommended that the green belt boundary be redrawn to exclude E1.

E22 and E23 score 1 and 2 respectively DESPITE BOTH BEING DESIGNATED AS AONB.

E22-E23

The AONB is a designation which helps protect the character of Guildford’s surroundings and the Borough as a whole.  To have included figures for land parcels where the AONB designation would presume against development is not only flawed, but invites applications from land owners – and even from Guildford Borough Council, where they are the landowner as at South Warren Farm.  In the latter case, Surrey county Council and Guildford Borough Council have been custodians of South Warren Farm on behalf of residents in order to prevent development.  The AONB constraint is referred to for that site (Parcel E23) but only rather feebly and without ruling the parcel unsuitable for development.

Parcels E22 & E23 do not appear to be listed in the Strategic Housing Land Availability Assessment although it is recommended that the green belt boundary be redrawn to exclude them both.

E24 scores 2 and E25 scores 1 suggesting they should be considered for potential development – although clearly in the AONB – and, ironically, they would score higher if E22 and E23 were developed.

E24-E25

Clearly development should not be appropriate in this location as it represents a key element of the character of the east of Guildford Borough – this includes Tyting Farm for which specific plans are being advanced to preserve the landscape of this site owned by Guildford Borough Council.

All of Zone G is covered by AONB although 7 of 19 parcels would appear to satisfy the criteria for sustainability assessment.

H1 and H2 score 1 and H3 and H4 score 0.

H1-H2-H3-H4

The land at H1 and H2 are owned by the University of Surrey and may have been earmarked for University expansion – Research Park, Teaching Campus and/or Student Accommodation.  Part of H1 is in the AONB as is part of H3.

Infrastructure between the Onslow Village area and the town centre is fragile as is the A3 that runs past these sites.  Analysis of these areas must, therefore, take into account not only the presence of infrastructure but also its suitability for intensification of use.

If H1 and H2 were to be taken out of the green belt and brought forward for development, H3 and H4 would still, presumably, only score 1 each, suggesting an almost limitless westward sprawl along the north side of the Hog’s Back.  This may indicate some flaw in the binary scoring methodology.

Parcel J1 scores 3, J2 scores 1 and J3 scores 2.

J1-J2-J3

It seems as though there is a clear split in J1 between the western half and the eastern half.  The eastern half could probably infill between Stoughton and Liddington New Road.

Plot J2 is a finger of green which, if J3 were developed, should probably remain as public amenity space and should be protected by the Local Plan rather than earmarked for potential development.

The land designated with the letter K surrounding Tongham and Ash seems to have been treated with different criteria to that around Guildford.

For example, K8 and K9 both scored 3 (which would rule them out for consideration around Guildford, and yet they are put forward for the sustainability test and are ranked 6th and 1st= respectively. This suggests that the methodology applied to one urban settlement or the other could be challenged and there is no obvious explanation in the report.

Section 8 – Stage 4 environmental capacity

There follows a summary of each parcel that the Report recommends is taken out of the Green Belt – omitting some parcels without specific explanation.

It should be noted that the use of coloured plans is prejudicial towards colour blind readers and care should be taken to ensure that no-one is excluded from reading and understanding the specific zoning and restrictions of the parcels of land.

Equally, the summary sheets could usefully set out the scores from the previous exercises in each table so as to place the overall context within the findings.

No specific comments have been made so far in relation to each parcel (other than have already been made above).

Section 8.6 – Recommended Revisions to Green Belt Boundaries Surrounding Urban Areas

The individual plot maps are slightly confusing where two almost adjacent parcels are affected, as the plans only show each successive part in the context of the existing boundary and not also in the context of the other proposed changes.  There does not seem to be an overall master plan in the report to show the cumulative impact of all of the recommendations.

Parcels E22 and E23 are both in an Area of Great Landscape Value and an Area of Outstanding Natural Beauty and should not be taken out of the green belt.

Far better that a significant new settlement in a less sensitive environment should be promoted and excluded from green belt ahead of areas that safeguard the character and appearance of the environs of our historic town.

Section 8.7 – Estimated Residential Development Capacity

The table of estimated capacity from urban encroachments on the green belt and countryside outside the green belt should note both the Areas of Great Landscape Value and should score as zero development on those parcels that fall into AGLV and AONB designations.  To do otherwise is to send a signal to developers that those sites might be capable of substantial development and might make planning policies that preclude development indefensible where those parcels have been removed from the green belt.

There should be a broad estimate of the number of residents that might be accommodated in the extension areas mooted and express that number as a percentage of the current Guildford Urban Area population and the Ash & Tongham population respectively.  At a rate of, say, 2.15 per household, there would be a 20% increase in Guildford urban population even before allowing for additional housing numbers on non-green-belt brownfield sites.  At teh same rate, Ash & Tongham would have a population increase of 30%.

VOLUME II – Conclusion

The conclusion does not comprise a recommendation and does not seek to eliminate the sites such as E22 and E23 where the existing countryside designations coupled with their current green belt status would suggest there is no justification for taking them out of the green belt.

VOLUME III

This Volume III takes account of extensions or infilling in villages across the Borough. Each such village – unlike the Guildford Urban Area – has a Parish Council in addition to having Borough Councillors. As a result this review is not intended to be a comprehensive assessment of the rural settlements and their green belt surroundings.

It is worth reiterating two concerns from earlier –

  1. The methodology of screening sites for the villages should also have been used for the Guildford Urban Area;
  2. There is insufficient (if any) attention given to potential options to coalesce settlements with the urban areas to create a once-and-for-all extension without such extensive potential nibbling away of the Green Belt;

At 10.2 the Report notes that “if (the approach adopted for the urban settlements) was applied to the assessment of villages, a number of the villages, potentially including those which performed well in terms of environmental constraints and sustainability criteria, would not have been considered.” This is a clear indication of the inadequacy of the urban land approach.

At 10.7 the Report continues that “the (Potential Development Areas) surrounding villages were only considered to be viable if the purposes of the Green Belt would not be significantly compromised, and if the land parcels were not significantly constrained by environmental designations” which, if applied to the urban areas, would not have allowed the parcels E22 and E23 to be recommended for removal from the Green Belt.

Jacobs Well:

As previously noted, consideration should be given to expanding the Guildford Urban Area to meet Jacobs Well by infilling between Slyfield and Jacobs Well and A3.

This suggestion is to have regard to the ability to provide further housing around a key employment area, bring about sufficient critical mass for improved facilities and services, and to recognise that the North of Jacobs Well represents a long term defensible green belt boundary.

By using infill sites such as this might protect the Downs from development or removal from Green Belt (eg E22 and E23).

In general, the Report is too conservative in some areas (such as Ripley which has the facilities and services to support more development towards the A3, or Send and Send Marsh which could be coalesced whilst retaining the protection of their outer boundaries, etc) and fails to shine a spotlight on potential new settlements (such as at Wisley Airfield) as an alternative green belt solution rather than a comprehensive and broad brush realignment of the Green Belt across the Borough.

The schedule of potential development areas should include a measure of the percentage increase in the existing settlement that the PDA represents.

Equally, because the Settlement Profile Report (qv) does not set out the typical and variance of housing density in each settlement, there is no way to sense check the housing numbers postulated in the schedule. This is indicative of a wider concern about the Report, namely that it is too generic and does not provide enough guidance as to the merits of retaining the majority of the Green Belt in tact whilst carving out sufficient land for a new settlement that could be designed to be sustainable (as defined by the Report) and could be created with strong defensible green belt boundaries.

VOLUME IV

This section deals with the inserting or otherwise of villages and other settlements and I have not reviews this in detail because this should arise from the thorough review of Volume III and any amendments that may need to be made.

Further comments may be added to this site as fellow reviewers make their views known and, especially where others have more intimate knowledge of the various settlements than I do.

As a final note of caution, I am not advocating any specific development but am seeking to ensure there is a proper debate with alternatives and that some issues that have been omitted or underplayed are raised before a draft Local Plan is issued for consultation based on this evidence base.

PLEASE SEND ME A COMMENT WITH YOUR THOUGHTS…

 

Guildford Borough Settlement Profiles

WORK IN PROGRESS

Introduction

This draft analysis is based upon GBC Draft Settlement Profiles and it aims to ensure the picture being painted of each settlement is as complete as possible.  The Profiles Report should explain some of the pressures on infrastructure, whilst differentiating between historic qualities of original hamlets, villages and towns and the communities that have grown up around them (largely during the twentieth century).  The links, the spaces and the surroundings are also critical elements.

In recognition that the entire Borough will be called upon to find a substantial number of housing sites across its area during the Local LPan period, this analysis seeks (without fear or favour) to prompt a review by each community to consider how it might be affected by extension – both favourably and unfavourably.  For example, a settlement such as Gomshall notes that it “is adequately served, with some appropriate facilities, but there are concerns that the bus, post office and village shop are underused and the village club is just surviving” (my emphasis).  This seems as though it should prompt analysis by the community as to how much additional development might enable the community facilities to thrive without adversely affecting the character, setting and even scale of the settlement.

Where major settlement changes would occur by the extension of the settlement or the loss of facilities, the residents should be actively encouraged to engage in a proactive debate and feed their comments, issues and options into the first major consultation on the Local Plan in the autumn.

There are also tight green belt restrictions around many of the settlements.  The green belt boundaries were drawn to prevent spread, sprawl and convergence of settlements.  There will inevitably be cause to reassess the green belt boundaries (and these will probably come within a specific green belt paper as part of the evidence base.  Any changes suggested to the green belt boundary under the Local Plan – and especially arising from consideration of each and every settlement – should be designed to be a permanent realignment and not part of a progressive or ongoing expansion of an inconvenient boundary.  Each settlement should view its own area in its wider context – and particularly taking account of the responses and aspirations of its neighbouring settlements.

Taking into account global planning practices and applying local knowledge and emotion, the Local Plan should identify:

  • Settlement centres and latent centres;
  • Places that need repair;
  • The way in which and extent to which the wholeness of a settlement is faltering or defective;
  • How to build or reinforce a neighbourhood or settlement so as to repair and heal the land and/or community.

This means that the Local Plan process should embrace at its heart the aim always to make the place better than it is at present. This may be obvious, if we are dealing with a part of the town in need of regeneration; but an extraordinary aim if we are faced with a place of great natural beauty. Yet there, too, we must make our target and our determination that when all is said and done, it will be more beautiful, and even better than it is today. (paraphrased from www.livingneighborhoods.org)

The ethos and approach above was embraced in the first two phases of a development outside Bishops Castle in Shropshire called The Wintles where the driver behind this high quality neighbourhood-based eco-friendly development was The Living Village Trust.  The emphasis there is on quality rather than profit and this principle is included here since we have high land values in our part of the country which might attract development in the wrong places, encouraged by a highly profitable change of land use.  Guildford Borough should be setting the highest standards for its settlements, and each infilling or extension scheme (or even any new settlement) should require similar principles to be adopted, whereby the extension is of a character and quality as good or better than the acknowledged heart of the original settlement.

The onus should be on land-owners and developers to give back a significant portion of windfall profit from gaining a planning consent for a change of designation from, say, agricultural to residential uses, and this should be enshrined in the planning policies promoted under the Local Plan.

The Profile Report

The Settlement Profile Report goes a little way towards identifying characteristics, but it does not explicitly lay down the gauntlet to the communities to identify development sites nor to look for qualitative tests in future planning policy that will protect and enhance their communities.  It does not give any indication for each settlement how to add to the built environment in a way that also enriches the settlement.  It does not call for the connections and infrastructure that will enable each neighbourhood and settlement to thrive.

In general, the Settlement Profile Report is somewhat static in nature and does not give enough of a flavour of how life operates in the settlements.  For example, the report highlights where services are provided in the settlement and where they are missing.  It does not consider where the nearest available (alternative) facilities are located.  It does not take account of which surrounding settlements rely upon the local amenities and facilities of any particular settlement and, in the case of, say, East Horsley, it refers to the two parades of shops and their related parking  and, rather than setting out how many car parking spaces are available versus need, it meekly notes that “the centre could benefit from some more available spaces“.

There are frequent references to the Thames Basin Heaths Special Protection Area (2009-2014) which will have expired by the time the Local Plan is prepared.  Given that the SPA touches on many settlements in this report, what (if anything) is the likely successor or extension to TBH SPA (2009-2014) expected to alter?

It would be useful to have an overall map of the Borough with the positions of the settlements marked on it (also showing the SPA, Areas of Great Landscape Value and Areas of Outstanding Natural Beauty boundaries) and also a map for each settlement with the settlement boundaries clearly marked.

Each settlement report should indicate the land area within the settlement boundary and typical and/or average dph (dwellings per hectare) figures so as to help understand the character of the settlement or its distinct parts and to ensure the character is not undermined by development which is out of keeping with its surroundings.

Crucially, the Profile Report does not seem to draw on information from the 2011 Census which would identify the population profile (age, gender, ethnicity, etc) for each settlement; nor does it use any of the lifestyle data from the census to underscore the nature of the community with a wider source of comparative data.

In further iterations of the Settlement Profile Report it is to be hoped some of this supplemental information will appear (as it does not emerge from the Draft Infrastructure Baseline Report).

NB: this analyses was largely written before publication of the green belt and Countryside Report and the Strategic Housing Land Availability Assessment.

Taking each village in turn:

Albury

The conclusion drawn is that Albury is a settlement with a village core and a number of outlying hamlets.  The infrastructure is poor because of the dispersal of settlements within Albury.

There is an emphatic statement in the Conclusion “If we were to remove the settlement boundary within the new Local plan then we would remove the scope for future infill development.”  This does not seem to be a wholly logical statement to a non-planner and the differnce between Green belt Villages with or without settlement boundaries needs explanation – probably in the introduction.

Perhaps the choice that the remaining text highlights is ‘Do we look for a suitable  site for limited extension of the village – to help make better infrastructure and facilities viable and to bring forward affordable housing – or should we assume there will be limited growth through periodic infilling?’  If the latter, how do we ensure that sufficient affordable housing comes forward to suit the identified needs of the community?

The references to the views into and from Albury and the characteristic of its woodland and open pasture mix should help to ensure that only suitable sites can be brought forward.  A range of qualitative requirements (and the Community Infrastructure Levy of which 25% would go to the Parish) should ensure that there is not so much windfall value in speculatively promoting unsustainable or undesirable sites.

Ash & Tongham Urban Area

In the section on Retail Facilities, there is reference to car parking for 29 cars.  This does not indicate whether the provision is too little, about sufficient or generous.  For the purposes of understanding the capacity for the local infrastructure to cope with fresh development, these kinds of information would be very important.

Ash & Tongham is close to the Local Authority boundary with Rushmoor and care should be taken to understand what (if any) impact there might be as a result of the Duty to Co-operate set out in NPPF.

The conclusion that Ash & Tongham “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” seems to be made without reference to opportunities and risks of such expansion, nor on the basis of any assessment of CAPACITY.  This is not to say the assessment is wrong, but that it does not logically arise from the information provided.  How well are the local businesses trading, for example, and what level of development can help to ensure or enable the medium to long term viability of those businesses.

Ash Green

There is a hint of potential major development between Ash Green and Ash & Tongham, noting that “this strategic matter will be addressed in the Local plan Strategy and Sites document”.  The Settlement Profile Report should consider the scale of development that might be required to raise the village from ‘Fair’ to ‘Good’ and the implications on the village character if the settlements of Ash Green and Ash & Tongham were to merge or infill.

Chilworth

The description of Chilworth as “an urban character without a core and with very limited opportunity for infilling, constrained by the railway which cuts it in half and the green belt boundary which is drawn very tightly” suggests that there is no scope for development.

There is an apparent conflict, however, between statements in the sections ‘How well the village works’ and the ‘Conclusion’ namely and respectively: “The village is poorly served, with a lack of appropriate facilities…” and “Chilworth has a number of key community services and facilities which makes it one of the more sustainable villages”

Perhaps the choices that the remaining text highlights are ‘Do we (a) look for a suitable  site for limited extension of the village – to help make better infrastructure and facilities viable and to bring forward affordable housing; (b) consider the potential to redraw the green belt boundaries to enable high quality development that brings a more cohesive connected community with a more conventional mass and provides key local community amenities at the heart of the settlement; or (c) should we assume there will be limited growth through periodic infilling?’  If the latter, how do we ensure that sufficient affordable housing comes forward to suit the identified needs of the community?

The characteristic of its woodland and open pasture surroundings set against the downs should help to ensure that only suitable development can be brought forward.  A range of qualitative requirements (and the Community Infrastructure Levy of which 25% would go the Parish) should ensure that there is not so much windfall value in speculatively promoting unsustainable or undesirable sites.

Compton

This green belt village has a significant number of listed buildings (around 9%) and is mostly within a conservation area.  It has traffic from the A3 cutting through it and could be affected by alterations to the A3 around Guildford (improvements may encourage more traffic from the South to access the A3 through Compton, and suitable mitigation strategies may be required alongside any such proposals in the Local Plan).

Compton abuts the Local Authority boundary with Waverley and, care should be taken to understand what (if any) impact there might be as a result of the Duty to Co-operate set out in NPPF.

Compton does not have convenience shops but is served by bus services.  The conclusion in the draft is that “it is not a sustainable location for an extension” but perhaps the report should offer alternatives for residents to consider ‘Do we (a) look for a suitable  site for limited extension of the village – to help make better infrastructure and facilities viable and to bring forward affordable housing; (b) consider the potential to redraw the green belt boundaries to enable high quality development that brings a more cohesive connected community with a more conventional mass and provides key local community amenities at the heart of the settlement; or (c) should we assume there will be limited growth through periodic infilling?’  If the latter, how do we ensure that sufficient affordable housing comes forward to suit the identified needs of the community?

East Clandon

This green belt village has a significant number of listed buildings (around 45%) and is mostly within a conservation area.  The village is an ancient settlement clustered around the church, pub and village hall just off the A246 Epsom Road.

There seems to be a contradiction where, under ‘Community Services’, the text says “the settlement is also lacking key community facilities and services such as a doctor’s surgery, a post office or any shopping facilities” and under ‘How Well the Village Works’ the text says “The village is reasonably served with facilities but access is minimal”.

There are two options considered for East Clandon, whereas perhaps a third option might be to look for a suitable  site for limited extension of the village – to help make better infrastructure and facilities viable and to bring forward affordable housing.  Clearly this would be difficult to achieve and  an extensive range of qualitative requirements (and the Community Infrastructure Levy of which 25% would go the Parish) should ensure that there is not so much windfall value in speculatively promoting unsustainable or undesirable sites.

East Horsley

East Horsley is a large and relatively populous settlement.  The report notes that “the only service the settlement lacks is a secondary school” but the report does not indicate whether this is an aspiration or if the residents are happy to frequent nearby schools in Effingham.  Equally, the report does not indicate how East Horsely’s population measures up to justifying having one.  This should probably cross reference (or be cross-referenced with) the Infrastructure Baseline.

The report discusses the two local centres but does not provide a count of shop units, numbers of parking spaces or even provide qualitative data on the viability of the shops.  Equally, there is no indication as to whether the customers for those facilities are drawn from the settlement or from further afield (see comments on Effingham, Ockham and West Horsley, for example).

The conclusion states that “if suitable sites are found within this area it could support additional housing development in the future”.  Given the relatively low number of buses, and the availability of train services from two stations and local shopping in two centres, the focus for any new development should perhaps be around the station(s) and/or close to the local facilities so as to limit or avoid incursions into the green belt, but a significant high quality extension could be considered with a once and for all change to green belt boundaries if it can be shown that the character of the settlement and its sustainability would not be impaired by such extension.  Clearly this would be difficult to achieve and  an extensive range of qualitative requirements (and the Community Infrastructure Levy of which 25% would go the Parish) should ensure that there is not so much windfall value in speculatively promoting unsustainable or undesirable sites.

Effingham

Effingham is located close to the Local Authority Boundary with Mole Valley and care should be taken to understand what (if any) impact there might be as a result of the Duty to Co-operate set out in NPPF.

The proximity of Effingham to East Horsley, and the presence in each centre of facilities for the residents, suggest that analysis should be undertaken as to whether there could be infilling between communities.  This might allow a more cohesive view of community transport, facilities and amenities – especially as the village economy “is not seen as being particularly thriving”.

The conclusion notes that “Effingham is one of the largest villages in the borough and contains a number of key services and as such if suitable sites are found within this area it could support additional housing development in the future through an extension and a rural exception site to provide affordable homes for local people.”  Clearly this would be difficult to achieve and  an extensive range of qualitative requirements (and the Community Infrastructure Levy of which 25% would go the Parish) should ensure that there is not so much windfall value in speculatively promoting unsustainable or undesirable sites.

Fairlands

There is reference to Fairlands suffering from flooding in various locations but there is no indication whether this is fluvial or pluvial.

The conclusion states that “if suitable sites are found within this area it could support additional housing development in the future”.  The focus for any new development should perhaps be close to the local facilities so as to limit or avoid incursions into the green belt, but a significant high quality extension could be considered with a once and for all change to green belt boundaries if it can be shown that the character of the settlement and its sustainability would not be impaired by such extension.  Clearly this would be difficult to achieve and  an extensive range of qualitative requirements (and the Community Infrastructure Levy of which 25% would go the Parish) should ensure that there is not so much windfall value in speculatively promoting unsustainable or undesirable sites.

This view may also be affected by any urban expansion of Guildford towards Fairlands, the potential for a Park Barn station and any northern realignment of the A3.

Gomshall

For a relatively small village settlement, Gomshall is well-served for facilities and amenities.  The report does, however, note that “there are concerns that the bus, post office and village shop are underused and the village club is just surviving” (my emphasis).

The conclusion is then drawn that the village is “not a sustainable location for an extension.”

On the contrary, this would seem to indicate that the village may need extension to make its facilities viable.

Perhaps the choices are ‘Do we (a) look for a suitable  site for limited extension of the village – to help make better infrastructure and facilities viable and to bring forward affordable housing; (b) consider the potential to redraw the green belt boundaries to enable high quality development that helps to ensure key local community amenities at the heart of the settlement remain viable; or (c) should we assume there will be limited growth through periodic infilling?’  If the latter, how do we ensure that sufficient affordable housing comes forward to suit the identified needs of the community?

Clearly any extension would be difficult to achieve and an extensive range of qualitative requirements (and the Community Infrastructure Levy of which 25% would go the Parish) should ensure that there is not so much windfall value in speculatively promoting unsustainable or undesirable sites.

Guildford Urban Area

A population of just over half of the borough living in the Guildford Urban Area ahve been lumped together as one settlement and, collectively, characterised by being the only part of the Borough without parish or town council representation.  For the size and complexity of the Guildford Urban Area, it has a relatively short entry in the Profile Report.

There are so many parts of the Guildford Urban Area whose characters and backgrounds are fundamentally different (as are their issues) and whose facilities and access vary considerably.  No reference is made to the Neighbourhood Area of Burpham, and it might be reasonable to expect that other areas might choose to go down the same neighbourhood planning path.

It seems clear, therefore, that this section should be broken up into the sub-districts which have their own nuclei of facilities and transportation issues.  These should probably be:

  • Town Centre
  • Guildford Park
  • Onslow Village (including Dennisville)
  • Park Barn
  • Rydes Hill
  • Woodbridge Hill
  • Stoughton
  • Stoke
  • Bellfields
  • Slyfield
  • Burpham
  • Merrow
  • Charlotteville
  • Warwicks Bench
  • St Catherines

The section on Character seems to be woefully inadequate.  The Urban Area is dissected also by the River Wey; also poorly connected is the west side of Guildford (including a large proportion of employment and education).

Under Community services and facilities there is an orphaned “Northern”.

Under Retail and Employment, much of this section should cross refer to the Guildford Economic Strategy Report 2013 and the Infrastructure Baseline.  Missing from this settlement report is some indication of the employment levels and where employees typically live – for example, a separate report on Park Barn would highlight some issues with higher than average unemployment.

Under Transport, the settlement report refers to the River Wey as “a transportation route primarily for recreation and tourism purposes”.  This is omitted from the Infrastructure Baseline.  Reference to the A3 should also highlight that it connects the town to the wider motorway network.

In sections 2.2.12-2.2.16 of the Infrastructure Baseline there is no specific mention of the A320 junction at Stoke Crossroads (but there is reference to the general fragile state of the road network at peak hours).  In the Settlement Report it is mentioned that “The Stoke crossroads and junction with the A3 are already at their capacity.  A lack of investment in associated junctions will continue to have an adverse effect on the communities and major businesses operating in the Guildford urban area.”

This analysis – whilst on the one hand differing in content and tone from the Infrastructure Baseline, fails to deal equally with each approach road to the town – all of which have specific and severe issues.  The Farnham Road (A31) for example, has restrictions of weight and is often backed up along its entire length from the Hog’s Back.

The A3 backs up from the A31 to the Burpham turn at evening rush hour, due in large part to vlumes of traffic and a 60m climb from its bridge over the River Wey to the cutting in the Hog’s Back.  This affects the businesses and quality of life and access for a large proportion of the settlement to the north and west.

In the Conclusion, there is the comment that Guildford “could support a level of development which exceeds that of any of the borough’s other settlements”.  This may well be the case and there may be very difficult decisions to be taken about the future of the green belt boundary (note my comments in the introduction).  These decisions should be taken on the basis of a much more detailed settlement assessment having subdivided the area as described above.

A decision, for example, to expand the town from Warwicks Bench would have to take account of a character assessment of that residential settlement whereby it has no immediately local facilities and would necessitate a trip into the town centre – with no bus routes available for public transport.  On the other hand, an extension to Burpham might have good access to local services and facilities and reasonable access to public transport.

There needs to be a comprehensive CAPACITY study for the Guildford Urban Area and each subsidiary settlement to show how the infrastructure (outlined in the Infrastructure Baseline) can be upgraded to accommodate growth since so much of the settlement’s infrastructure is already at or near (or even exceeding) its designed capacity.

In summary, in any event, the focus of development should be town centre first – residential sites like the recently lost Bellerby site should be resisted for non-residential uses.  Where any outward expansion of Guildford is required for a new settlement or a settlement extension, the revised green belt boundary should be drawn so as to represent a new permanent boundary.  Such extensions should probably be planned with a critical mass to enable local services and facilities to be provided or where there are accessible services in existing settlements within easy access.  Clearly any extension would be difficult to achieve and an extensive range of qualitative requirements (and the Community Infrastructure Levy) should ensure that there is not so much windfall value in speculatively promoting unsustainable or undesirable sites.  As there is no Parish Council, it would be important to ensure that an adequate proportion of CIL goes to mitigate local effects of extension and to provide the necessary infrastructure.

Holmbury St Mary

Holmbury St Mary is located close to the Local Authority Boundary with Mole Valley and care should be taken to understand what (if any) impact there might be as a result of the Duty to Co-operate set out in NPPF.

The Report highlights that Holmbury St Mary is poorly designed as a settlement because “there have been too many extensions permitted and there is a need for affordable housing.”  This implies that the settlement is effectively in need of repair and, whilst it is possible that too many extensions of inferior quality have failed to respect the character, fabric and scale of the settlement, that does not mean that a well-designed extension would be unable to heal some of the issues and restore a better quality of community to the settlement. Clearly any extension would be difficult to achieve and an extensive range of qualitative requirements (and the Community Infrastructure Levy, 25% of which would go to the Parish Council for local infrastructure projects) should ensure that there is not so much windfall value in speculatively promoting unsustainable or undesirable sites.

Jacobs Well

The Report (at ‘Character’) notes that “the settlement has an urban character due to its proximity to the urban area of Guildford, at its closest it is 200m away from the norther edge of Slyfield.”

Perhaps, as part of the Local Plan process, there should be consideration given to what would be the merits or harm in closing the 200m gap and infilling the area between Slyfield and Jacobs Well.  Clearly any extension or infilling such as this would be difficult to achieve and an extensive range of qualitative requirements (and the Community Infrastructure Levy, 25% of which would go to the Parish Council for local infrastructure projects) should ensure that there is not so much windfall value in speculatively promoting unsustainable or undesirable sites.

Normandy and Flexford

Whilst the Report puts these together, it is somewhat schizophrenic in its attempts to combine and yet treat these two areas separately.  No such schizophrenia applies to the Report’s treatment of the Guildford Urban Area (see above)!

The Report notes the lack of a convenience shop “which would be of benefit to the local community”.  There is no reference as to the options available for convenience shopping for residents of the two areas.

Perhaps, as part of the Local Plan process, and because the two areas see themselves as one settlement, there should be consideration given to what would be the merits or harm in infilling the area between them, incorporating a convenience store and some of the other missing facilities.  Clearly any infilling such as this would be difficult to achieve and an extensive range of qualitative requirements (and the Community Infrastructure Levy, 25% of which would go to the Parish Council for local infrastructure projects) should ensure that there is not so much windfall value in speculatively promoting unsustainable or undesirable sites.

Ockham

Ockham is located close to the Local Authority Boundary with Mole Valley, and care should be taken to understand what (if any) impact there might be as a result of the Duty to Co-operate set out in NPPF.

Under ‘Transport’ there is reference to a school bus service passing through once a day.  This presumably means once at each end of the day and does not specify which schools it serves, nor whether it meets the needs of the school age children in the community.

The Report does not give any great weight to links between Ockham and East Horsley (recognising it as “the nearest area with services”) and ignores any such links with the larger centre of Ripley. The Report also fails to establish how interaction with such centres works in practice other than to highlight reliance on the private car.

Ockham is around double the size of Holmbury St Mary which, unlike Ockham, has a settlement boundary, and, whilst the Report concludes that Ockham does not have the facilities to support sustainable development, the question should be asked whether it would benefit from a significant extension that made such facilities viable – always assuming a suitable extension could be found.  Perhaps a new settlement on Wisley Airfield might fulfill this purpose and, properly planned and on a significant scale, could provide a new service centre with local shops, etc. Clearly any such extension would be difficult to achieve and an extensive range of qualitative requirements (and the Community Infrastructure Levy, 25% of which would go to the Parish Council for local infrastructure projects) should ensure that there is not so much windfall value in speculatively promoting unsustainable or undesirable sites.

Peaslake

From the description in the Report, the village of Peaslake seems to be settled in a mould whereby there is nothing for young people to do, and nowhere for them to live if they wish to remain in the village to raise their families.  Ordinarily this might be described as a poorly functioning and unsustainable community.

The physical limits and the AoNB designation almost certainly dictate that little scope exists for any substantial development.

On the other hand, as a settlement, Peaslake may well benefit from additional development which could help support services or transport connections. Clearly any such extension would be difficult to achieve and an extensive range of qualitative requirements (and the Community Infrastructure Levy, 25% of which would go to the Parish Council for local infrastructure projects) should ensure that there is not so much windfall value in speculatively promoting unsustainable or undesirable sites.

Peasmarsh

The Report barely acknowledges the existence of Godalming and ignores Farncombe, and yet Peasmarsh sits at the edge of Guildford Borough, close to its Local Authority boundary with Waverley, and reasonably close to Farncombe.

As it is located close to the Local Authority Boundary with Waverley, care should be taken to understand what (if any) impact there might be as a result of the Duty to Co-operate set out in NPPF.

There is some confusion in the ‘Transport’ section about rail connections and destinations: “The nearest train station is Shalford, 1.5km to the north east. This line links Guildford town and London Waterloo and is faster than the direct train from Guildford to London”.  Clearly this requires rewriting.

The Report notes that Peasmarsh contains five of the 12 key community services (with no reference as to where the nearest missing services are to be found), whereas under the section ‘How well the village works’ the text notes that “the village is poorly served with a lack of appropriate facilities”.  These two statements do not appear to be consistent.

Perhaps there has been overzealous use of cutting and pasting in the Report – as demonstrated by the sentences in ‘Conclusion’:

  1. “Peasmarsh is a relatively small settlement and does not contain many key community services or facilities (small village)” This contradicts the earlier comments.
  2. “The closest convenience store is located in East Horsley and due to poor public transport is mainly accessible by the private vehicle” This is patently geographically wrong.

Every settlement should be reviewed to ensure the data is relevant to that settlement and not a misplaced ‘pasting’ of some other settlement’s criteria.

Peasmarsh is characterised as a “suburban village” and yet is treated as a more protected settlement (from infilling or extension) than many others.  The Local Plan process should consider whether it could accommodate any significant development by a well-planned extension that helped bring the missing services or facilities to the settlement.  Clearly any such extension would be difficult to achieve and an extensive range of qualitative requirements (and the Community Infrastructure Levy, 25% of which would go to the Parish Council for local infrastructure projects) should ensure that there is not so much windfall value in speculatively promoting unsustainable or undesirable sites.

Pirbright

This is the only settlement in the Report that lists the total area as well as the number of dwellings, allowing a calculation of average settlement density – there are 565 dwellings in 1906 Hectares. This clearly does not cover the settlement area alone, measuring the density in hectares per dwelling rather than dwellings per hectare!

Pirbright is located close to the Local Authority Boundary with Woking, and care should be taken to understand what (if any) impact there might be as a result of the Duty to Co-operate set out in NPPF.

Under the section ‘Community services …’ (which in this settlement are amalgamated whereas elsewhere they are in separate subheadings) there is an apparent contradiction whereby we have “one comparison shop” and then “comparison shops within the settlement”.

The settlement is characterised by a collection of hamlets and the Local Plan process should consider whether, perhaps, these could accommodate well-designed extensions, drawing on the availability of accessibility and services in the heart of the village. Clearly any such extension would be difficult to achieve and an extensive range of qualitative requirements (and the Community Infrastructure Levy, 25% of which would go to the Parish Council for local infrastructure projects) should ensure that there is not so much windfall value in speculatively promoting unsustainable or undesirable sites.

Puttenham

Puttenham is a poorly served village owing to its lack of a post office or village shop, which forces residents (in the absence of buses) to go by car to Guildford or Godalming.

Perhaps the Local Plan process should consider an expansion on the east side (protecting the historic heart of the village) on the other side of the main road with traffic calming and with a village centre that could provide the facilities and services that are so lacking.  This could be designed as a high quality rural settlement and would require the redrawing of the Green Belt boundary.  This needs also to respect the Area of Great Landscape Value.  Clearly any such extension would be difficult to achieve and an extensive range of qualitative requirements (and the Community Infrastructure Levy, 25% of which would go to the Parish Council for local infrastructure projects) should ensure that there is not so much windfall value in speculatively promoting unsustainable or undesirable sites.

Ripley

Ripley is located close to the Local Authority Boundaries with both Woking and Mole Valley, and care should be taken to understand what (if any) impact there might be as a result of the Duty to Co-operate set out in NPPF.

Ripley is affected by the way the A3 bypassed it and by the single direction junctions at each end which drives traffic through the settlement.  on the one hand this may be a good way to ensure the village is visited and thrives; on the other hand, the through traffic may adversely affect the character of the settlement itself.

Under ‘Conclusion’ the Report should encourage consideration as to whether a significant high quality extension could be accommodated without adversely affecting the character and “market town” feel of Ripley as a settlement. Clearly any such extension would be difficult to achieve and an extensive range of qualitative requirements (and the Community Infrastructure Levy, 25% of which would go to the Parish Council for local infrastructure projects) should ensure that there is not so much windfall value in speculatively promoting unsustainable or undesirable sites.

Seale and The Sands

Under the heading ‘Form’, the final sentence “…and consists of low density” does not quite make sense.

Seale and The Sands are located close to the Local Authority Boundary with Waverley, and care should be taken to understand what (if any) impact there might be as a result of the Duty to Co-operate set out in NPPF.

The Report does not venture to suggest where (and how far away) residents have to go to reach the nearest facilities that these areas do not provide.

Seale and The Sands may well benefit from additional development which could help support services or transport connections. Clearly any such extension would be difficult to achieve and an extensive range of qualitative requirements (and the Community Infrastructure Levy, 25% of which would go to the Parish Council for local infrastructure projects) should ensure that there is not so much windfall value in speculatively promoting unsustainable or undesirable sites.

Send

Send is located close to the Local Authority Boundary with Woking, and care should be taken to understand what (if any) impact there might be as a result of the Duty to Co-operate set out in NPPF.

Despite its proximity to Ripley, Send is described (under ‘Transport’): “despite its size, there is a limited bus service that runs through the settlement between Woking and Guildford town.”

The Local Plan process should consider whether it could accommodate any significant development by a well-planned extension that helped bring better transport services to the settlement or improve the viability of the local facilities.  Clearly any such extension would be difficult to achieve and an extensive range of qualitative requirements (and the Community Infrastructure Levy, 25% of which would go to the Parish Council for local infrastructure projects) should ensure that there is not so much windfall value in speculatively promoting unsustainable or undesirable sites.

Send Marsh/Burntcommon

Send Marsh is located close to the Local Authority Boundary with Woking, and care should be taken to understand what (if any) impact there might be as a result of the Duty to Co-operate set out in NPPF.

Under ‘Character’ there is reference to the slip road from the A3 leading nito the settlement. It should perhaps be noted that this only feeds from the northbound carriageway of the A3.

Whereas Send is described as semi-rural, Send Marsh is described as having a “suburban character”, and under ‘Transport’ the bus service which in Send is described as ‘limited’ is considered to be ‘reasonable’. Under ‘how well the village works’, however, the Report says: “Send Marsh scores very poorly as public transport is very limited“.

The Local Plan process should consider whether it could accommodate any significant development by a well-planned extension to help bring better transport services to the settlement and to develop the village economy which “is not seen as being particularly thriving”.  Clearly any such extension would be difficult to achieve and an extensive range of qualitative requirements (and the Community Infrastructure Levy, 25% of which would go to the Parish Council for local infrastructure projects) should ensure that there is not so much windfall value in speculatively promoting unsustainable or undesirable sites.

Shackleford

Shackleford is located close to the Local Authority Boundary with Waverley, and care should be taken to understand what (if any) impact there might be as a result of the Duty to Co-operate set out in NPPF.

The Report notes that Shackleford Parish Council has recently completed a rural housing needs survey – and yet it does not give any indication as to what the survey found.  This seems to be an unfortunate omission.

The Report – as described earlier – is a static summariser of dynamic communities.  The ‘Conclusion’ notes that “Shackleford contains a very few community services and facilities (loose knit/hamlet) and as such is not a sustainable location for additional development.”

On the contrary, the Local Plan process should question the viability of local shops and a post office if there is no growth – the risk from internet shopping and from surrounding towns and villages will put increasing pressure on them.  Consequently, the Report should consider the economic argument for exxtending the settlement with high quality, complementary development in keeping with the character and scale of the existing properties.  This would require a rethinking of the Green Belt boundaries and this should be designed to meet future needs once and for all.  Clearly any such extension would be difficult to achieve and an extensive range of qualitative requirements (and the Community Infrastructure Levy, 25% of which would go to the Parish Council for local infrastructure projects) should ensure that there is not so much windfall value in speculatively promoting unsustainable or undesirable sites.

Shalford

Despite its size (and perhaps due to its proximity to Guildford or Waitrose in Godalming) Shalford has a medium-sized local centre but no convenience or grocery store.  This factor means that Shalford scores only 20 out of 40 – the same as Albury.  this suggests a substantial underperformance in Shalford relative to expectations.

The Local Plan process should consider whether Shalford and surroundings could accommodate any significant development by a well-planned extension to help to develop the village economy which “is not seen as being particularly thriving” and to provide the scope for a convenience store.  Clearly any such extension would be difficult to achieve and an extensive range of qualitative requirements (and the Community Infrastructure Levy, 25% of which would go to the Parish Council for local infrastructure projects) should ensure that there is not so much windfall value in speculatively promoting unsustainable or undesirable sites.

Shere

Shere is an important village with a heritage celebrated internationally through its use as a backdrop in films and its ‘chocolate-box’ village centre.

Whilst there is no designation above a Conservation Area, Guildford should, perhaps think in terms of establishing a ‘Local heritage’ designation whereby street-scenes are treated as if they are listed.  Views into and out of the village will be of great importance as well.

Under ‘Transport’ the report notes that “Shere has a good bus service”, whereas at ‘how well the village works’ “Shere scores poorly as public transport is limited”.  Such contradictions are not helpful in assessing the needs of the village.

Under ‘Conclusion’ the text notes that “development is limited to infilling…” and that  “if a suitable site can be found, there is scope for a rural; exception site to provide affordable homes for local people”.

These references should be heavily qualified in respect of Shere to the extent that infilling or a rural exception site should respect the heritage qualities and visitor attraction of the village centre, and this should mean that there should be an exceptionally high threshold for quality design in keeping with the historic settlement.

On the other hand, the Local Plan process should consider whether Shere and surroundings could accommodate any significant development by a well-planned extension to help to develop the village economy which “is not seen as being particularly thriving”, which itself would help to preserve the character and vitality of the village.  Clearly any such extension would be difficult to achieve and an extensive range of qualitative requirements (and the Community Infrastructure Levy, 25% of which would go to the Parish Council for local infrastructure projects) should ensure that there is not so much windfall value in speculatively promoting unsustainable or undesirable sites.

Wanborough

Wanborough is close to the settlement of Flexford (reported alongside Normandy as being regarded as a single settlement).

The proximity of Wanborough to Flexford should be taken into account when considering whether there could be any extension to the settlement and it should probably be the case that this should only happen between these two villages.  Clearly any such extension would be difficult to achieve and an extensive range of qualitative requirements (and the Community Infrastructure Levy, 25% of which would go to the Parish Council for local infrastructure projects) should ensure that there is not so much windfall value in speculatively promoting unsustainable or undesirable sites.

West Clandon (North and South)

The two parts of West Clandon are separated by the railway (one road bridge links the two).  This should be noted as a severed community in the context of the Infrastructure Baseline.  Equally, the station at West Clandon could be treated as more of a village hub and could be regenerated to provide local convenience shopping – identified as lacking in the Settlement Profile Report.

There is an extraordinary statement in the report to the extent that “West Clandon scores poorly as public transport is limited to travelling by train to either Guildford town or London”.  This would seem like a well-connected settlement by many yardsticks.  Perhaps there needs to be a greater availability of low-cost tickets between Clandon and Guildford (London Road) so as to enable the connection to work better but not so as to increase any passenger burden on Guildford mainline station.

The report concludes (among other things) that “this raises the question as to whether an extension to the village could enable service improvements through future mixed use development and improve access to key services for local residents.”

Indeed, the Local Plan process should consider whether West Clandon could accommodate any significant development by a well-planned extension to help to introduce the missing facilities and to develop the village economy which “is not seen as being particularly thriving”.  Clearly any such extension would be difficult to achieve and an extensive range of qualitative requirements (and the Community Infrastructure Levy, 25% of which would go to the Parish Council for local infrastructure projects) should ensure that there is not so much windfall value in speculatively promoting unsustainable or undesirable sites.

West Horsley (North and South)

The two parts of West Horsley are separated by the railway (two road bridges link the two).  This should be noted as a severed community in the context of the Infrastructure Baseline, but unlike West Clandon, it does not benefit from the station – the nearest being at East Horsley.

The Report notes that East Horsely and West Horsely parish councils recently completed a joint rural housing needs survey.  The authors do not see fit, however, to set out the perceived requirement in this Report.

The Report does consider West Horsley to be “the most sustainable rural settlement in the Borough” and highlights the potential to support additional housing development in the future. Clearly any such extension would be difficult to achieve and an extensive range of qualitative requirements (and the Community Infrastructure Levy, 25% of which would go to the Parish Council for local infrastructure projects) should ensure that there is not so much windfall value in speculatively promoting unsustainable or undesirable sites.

Wood Street Village

Wood Street is located “just to the west of Guildford” and could be somewhat affected by an extension of the Guildford Urban Area on its western reaches.  The village works well, scoring highly despite having public transport “so poor that residents have to rely on the private car”.

There may well be scope for a significant extension and could be linked to rail services if Park Barn Station were to become a reality.  Clearly any such extension would be difficult to achieve and an extensive range of qualitative requirements (and the Community Infrastructure Levy, 25% of which would go to the Parish Council for local infrastructure projects) should ensure that there is not so much windfall value in speculatively promoting unsustainable or undesirable sites.

Worplesdon

Worplesdon is located close to the Local Authority Boundary with Woking, and care should be taken to understand what (if any) impact there might be as a result of the Duty to Co-operate set out in NPPF.

The Report highlights that “there is a poor bus service that serves the settlement”.  Perhaps the Council should consider whether a Park & Ride facility with a combined bus service could improve this situation.

The Report notes that Worplesdon parish council recently completed a joint rural housing needs survey.  The authors do not see fit, however, to set out the perceived requirement in this Report.

Worplesdon is identified as a settlement which would support potential extension. Clearly any such extension would be difficult to achieve and an extensive range of qualitative requirements (and the Community Infrastructure Levy, 25% of which would go to the Parish Council for local infrastructure projects) should ensure that there is not so much windfall value in speculatively promoting unsustainable or undesirable sites.

Conclusion

Having been through the document carefully, there are clearly some contradictions and some glaring ‘cut and paste’ errors.  It is important that these are ironed out before the Local plan is developed from a compromised baseline.

The main concern about the Settlement Profile Report is the treatment of the Guildford Urban Area as one amorphous settlement. That is not only plainly wrong, it also misses a clear opportunity to look at the impact of extensions to subdivisions of Guildford which the Strategic Housing Land Availability Assessment seeks to do.  It also means that a close focus on the separate issue of Guildford Town centre and on each of its surrounding suburban settlements is much harder to achieve.

This shortcoming also, therefore, fails to note the establishment of the Burpham Neighbourhood Forum.

 

Draft response to Infrastructure Baseline

On the face of it this is a good document – an encouraging start to compiling the evidence base.

Looking at in greater detail, there are certainly some omissions (or at least details which would benefit the Local Plan process if included).

First the good…

The report is well written and is largely quite approachable.

The sections make sense and the content is reasonably comprehensive.

The authors do not shy away from some of Guildford’s trickier issues such as congestion and poor pedestrian and cycling routes.

And then the missed opportunities…

The report (1.1.2) sets out to provide “an overview of the quality and capacity of the existing provision of infrastructure of different types”.

In 1.2.1 the report should include the Rivers and canal as a heading (Wey, Tillingbourne, etc). This would ensure the river is in the heart of the town and Borough.

At 1.3.9 there is an expectation that “additional infrastructure capacity (will) mostly be funded from development” without looking to suggest a mechanism to raise infrastructure funding against tax revenues if a suitable funding scheme can be found.

At 1.4.4 the document refers to masterplans being called for if there is a “significant development site” to be included on the Local Plan Strategy and Sites document. This is clearly a welcome statement and should be taken to include all sites brought forward before the Local Plan is adopted.

1.5.1 sets out an approach to partnership and it is to be hoped that a similar delivery partnership can be established for the town centre in Guildford.

1.6.3 refers to working with infrastructure providers as the Council prepares the Local Plan.  It is reasonable to request that a method statement of purpose be provided to explain how emerging needs will be integrated into the Evidence Base and be assessed ESPECIALLY where there may be competition for spare infrastructure capacity.

At 2.1.3 – or in an Appendix – it would be helpful to list all of the junctions (however minor) on the A3, including an assessment of the quality, capacity and other issues where known.

The Evidence Base document ‘Surrey Future: Congestion Programme – SCC March 2013′ does not cover adequately the situation of the A3 and the adjacent Local Road Network and should have covered the above comments relating to 2.1.3, the evidence of origins and destinations and the details which give rise to the authors’ comment in 2.1.14, notably “the result is that traffic congestion in Guildford can adversely affect conditions on the A3 and vice versa“.

The document only highlights congestion hotspots and merely offers modal shift and rapid response to “incidents” as the way forward (2.2.29 and 2.2.30) and seems a rather weak response to any criticism that the last major infrastructure investment by Surrey County Council and the highways Agency in the Borough was for the A3 ‘bypass’ in 1981.

At 2.1.12 The Infrastructure Baseline Report report indicates the A31, approaching and entering Guildford, and the A3 through Guildford as amongst those incurring highest costs due to congestion in the County; and by 2026 will include areas “severely over capacity”. (201303_SCC_Congestion-Programme-FINAL)  – the two illustrations in Figure 5 and the map in Figure 7 of the report show this very well:

201302_SCC-CongestionReport-Fig5-2011 201302_SCC-CongestionReport-Fig5-2026 201302_SCC-CongestionReport-Fig7

Another apparent omission is that in compiling an up-to-date destinations and origins survey on the A3 (and the local roads) to identify the types of journey being made and to establish whether there are opportunities to reduce trips, this should also take account of the increase of traffic on the A3 since the Hindhead Tunnel opened – there should by now be concrete evidence available of this latter effect which should be placed in the public domain and should form part of the evidence for the Infrastructure Base.

A major consideration at 2.1.16 is the extent to which communities are severed by the A3, railway lines and the River Wey.  Placing this important issue in the section on A3 but not elsewhere risks its importance being understated.  A full quantitative and qualitative list of crossing points of each linear obstruction should be provided in the appendices along with areas where the lack of crossing points is causing major issues or leads to bottlenecks on the nearest alternative access.  It should also be noted whether there are any rights (under CPO or otherwise) for bridging rights to be acquired.

Note (2.1.22): it is unlikely that small changes in the Borough will ease the congestion, especially when we take into consideration the scope and scale of development proposed in the Strategic Housing Land Availability Assessment and the Employment Land Assessment.

Note (2.2.2): it is clear throughout the Evidence Base (and other supporting and background documents) that existing congestion is threatening both the economy and the future growth of Guildford.

At 2.2.13 it should be noted that traffic movements are expected to increase in line with growth of the Science Park, University, retail and demand for housing. Employment demand is expected to increase by some 15% between 2006 and 2031. (GBC ELA – 2013) – or between 6-10% per year according to the SCC Congestion Strategy Report (p16 – Figure 2 – see below).  Car availability in Surrey has been increasing steadily at more than 60% above the National Average (SCC Transport Statistics 2009).

201302_SCC-CongestionReport-Fig2_2012-2031  

At 2.2.20 the Onslow Village, Ashenden and Dennisville areas should also be included as having a major issue with on-street parking relating to the University in particular.  The majority of employment is in the Onslow Ward and particular attention needs to be given to resolving conflicts of movement and parking to the west of the London Mainline railway.

Whereas this major scheme “being developed for the present Guildford gyratory area” (2.2.21) can result in improvements, they are only likely to be stop gaps as a significant change in the infrastructure is needed for the long term (2013 – 2026).

Furthermore, improving Park & Ride and car parking (2.2.22) will not make sufficient difference to congestion as current available data for the gyratory shows that at least 40% of traffic is either cross-town or through-town traffic.

The scheme from 2000 referred to in 2.2.24 (to provide a shared bridge for buses to the University at the northern edge of Guildford Park Car Park) is no longer viable due to developments in Walnut Tree Close since 2000 unless incorporated into a major restructuring of the Strategic Road Network in the area.

At 2.2.26 the first bullet point (pedestrian crossings at Chertsey Street, North Street and High Street) appears to be based on a suggested re-arrangement of bus routes (some terminating in this area) which is not considered viable.  There are equally or more important pedestrian issues to be addressed elsewhere and it seems odd to single this out in this section.

The second and third bullet points in 2.2.26 (junctions between Jacobs Well Road and A320 Woking Road, and Junction of Jacobs Well Road and Clay Lane should be incorporated into planned or envisioned developments at Slyfield.

At 2.3.3 there is an error of omission or of adding up as the car parks listed are FOUR of the six largest car parks.

Also at 2.3.3 it may be worth calculating an average purchasing power per car space as a part of ensuring the ongoing vitality and viability of the town centre.  This can only ever be a rough guide but would help to ensure the provision of parking was proportionate to the economic aspirations for the town.

At 2.3.5 (car parking demand) the occupancy data lacks explanation and context – for example, it is clear that a reduction of the retail economy where 2011-2012 was 5% lower than the 2005-2008 period.  The effect of car parking charges in the evenings seems to show up in the Friday evening occupancy figures but no assessment is included to consider the economic benefit of charging £1 for car parks when it means streets are full of kerbside ‘free’ yellow-line parking.

At 2.4 (buses) – a Surrey County Council responsibility that absolutely impacts the Borough and our residents and visitors – fails to note that the evidence bases are inadequate (for example, the 2011 Surrey Transport Plan seems to concludes that bus provision should simply be ‘more of the same’). There is no demand study, for example, to show how behaviours might change if more buses were available for commuter hours and for the evening economy.

Furthermore, this section should include an audit of the various bus services that are provided across the Borough – the numbers of passengers, the hours of service, the frequency of services, the cost of the services.  This section in particular needs to integrate with the Settlements Report so as to ensure that good data is available for all parts of the Local Plan process.  The Settlement Report refers to bus services as poor or good but does not qualify such pejorative terms.

At 2.4.12 the hours for park and ride (7.30am to 7.30pm) do not seem to fit at, say, Onslow Park and Ride, with opportunities to service hospital visiting; the hours or operation are not consistent with promoting the evening economy in town.

At 2.4.8 it is worth noting that the 2001 Census (quoted in SCC Congestion programme – 2013) gives 55% of Guildford’s labour force as resident locally; although probably now out-dated, this indicates the importance of Park & Ride facilities and bus services for providing for commuters from other parts of the Borough into the town centre. See Table 4 from the SCC report below:

201302_SCC-CongestionReport-Table4-2001

 

A similar analysis should have been done to understand the movements of residents in the Borough between homes and workplaces for the purposes of the Evidence Base.

At 2.4.13 there are no details as to where the priorities are and what ‘corridor improvements’ are proposed.

The reference at 2.4.15 to providing bus facilities “elsewhere” represents a challenge for the infrastructure baseline which should probably be focussed more on the types and numbers of buses, the extent to which the bus interchange is a critical factor for bus users and what this tells us about where a replacement facility might be accommodated.  It is, however, appropriate to identify the likely interim solution and to plan to ensure that, for potentially many months if not years, there will need to be adequate capacity in the town centre road network to accommodate a different set of traffic flows than those seen today.

In the bus section, there is no reference to the MVA Bus Station Study – October 2011 (or any more recent incarnation) which should be included in the Evidence Base and should be referenced clearly in the Infrastructure Baseline.  The MVA study contains bus routes, numbers at peak hours, etc.

At 2.4.17 the word “serious” should be inserted to read “There are serious problems with traffic congestion…”

The bus fleet (and the contracts negotiated by Surrey County Council with the bus operators) should be quickly migrated from dirty diesel buses with street-level exhausts to cleaner technologies.  Failure to tackle this issue will lead to Guildford taking more old buses from other local authorities which are pushing for clean buses.

At 2.5.4 the baseline report refers to numbers of pedestrians on Bridge Street.  Guildford Society has data that shows 2000 pedestrians per hour cross the Debenhams Puffin Crossing on a Saturday morning.

Paragraphs 2.5.7 and 2.5.9 do not tell the full story.  NCR22 extends south from Guildford across Shalford park and clear of the A281 through Shalford.  It then joins the disused Cranleigh line at Broadford (A248) and continues south on this route (the Downs Link) and it is very well used.

The chart at Figure C and text in 2.5.13 does not indicate if the respondents were asked how many would like to be able to cycle or walk 30 minutes if it were safe or pleasant to do so.

At 2.5.14, neither a North-South through route nor increased access to Surrey University from the north appear to have been considered.

At 2.5.15 there is no flagship scheme nor any priorities identified to emphasise the importance being attached to the need for better cycle routes.

2.5.18 should highlight the fact that there has been no significant improvement in the pedestrian experience in the town centre since the High Street was pedestrianised in the late 1970’s.

At 2.6.12, it needs to be noted that the schemes referred to are included in the new County Rail Strategy as well as the need to consider new stations for Park Barn and Merrow.

Section 4 – Green infrastructure – should include a section on the rivers and streams and canals in the Borough, and it may also be pertinent to include land in the ownership and/or stewardship of the National Trust within the Green Infrastructure.  Equally parts of the rural environment around villages and in between – including areas such as St Martha’s hill and the Hogs Back should be included in the Green infrastructure section.

At 5.2.6 it should be noted that there are smaller organisations such as Italia Conti that provide specialised courses in Higher Education.

7.3.17 might also include Addison Court in Charlotteville.

At Section 8.3 the document makes a notable omission in that the Lido is not mentioned, and neither are the sports facilities at Shalford Park.

Furthermore, there are numerous recreation grounds and village greens around the Borough which should either be referenced in 8.3 or elsewhere in the document along with other community open space and community halls and allotments.

SUMMARY

The document itself is a positive and largely comprehensive assessment of the infrastructure baseline and the comments made here can be easily integrated into the Evidence Base, providing supplementary evidence rather than contradictory views.

It would be useful if there were more specific detail in the annexes of the stage each type of infrastructure (and its component parts) has reached – including breaking points and pinch points that, by design and/or investment, could be resolved.

A traffic-light system could be employed to highlight:

TrafficLight-failing  Red – at or exceeding capacity

TrafficLight-nearingcapacity  Amber – approaching capacity

TrafficLight-workingwell  Green – working well within capacity

For example, looking at the provision of school places, it would be reasonably straightforward to show the schools on a map with a traffic-light symbol so that, from first glance, it is possible to see where development would have to be limited or contributing to overcoming capacity limits.

A similar approach to roads and junctions would enable clear mapped identification of issues and capacity restrictions.

Traveller Strategic Housing Land Availability Assessment Methodology

The Local Plan Evidence Base includes a substantial number of documents.  In Guildford, the Council is bringing forward many if not all of these emerging documents during the course of the summer 2013 ahead of launching the Issues and Options Consultation.

The Traveller Strategic Housing Land Availability Assessment Methodology is one such document for which consultation is due to close on 26th July.  The consultation document can be found on the GBC microsite here.

Broadly, the document provides no suggestions as to specific sites and seems to follow national guidelines.

The only significant omission is in Table 3 at 13.2, where the analysis should also include a ranking of suitability and take account of alternative uses for the land – where a site could be developed to a higher density to meet local housing need and/or higher buildings could be accommodated, these should be noted and should affect the suitability ranking.

Guildford Borough has scarce land resources and substantial competing demands.  It is a vital part of the plan process to ensure the most efficient use of scarce resources – but this must not be at the expense of minority groups for whom alternatives will need to be found.

NOTE: the two paragraphs of text in bold were submitted using an on-line form on Guildford Borough Council’s website on 26th July 2013 on behalf of The Guildford Society.