Getting the Plan Right First Time

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

Three things come to mind:

1. Planning Rules

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

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

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

8.

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that is intended to supersede another policy in the adopted development plan, it must state that fact and identify the superseded policy.

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

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

2. Knowledge

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

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

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

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

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

3. Spatial Hierarchy

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

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

Tier 1 – Guildford Town Centre

Tier 2 – Guildford Urban Area

Tier 3 – Ash & Tongham Urban Area

Tier 4 – Built-up Area of Villages

Tier 5 – Village ‘Gap’ Sites

Tier 6 – Brownfield in the Green Belt

Tier 7 – Countryside Beyond the Green Belt

Tier 8 – Green Belt Around Guildford

Tier 9 – New Settlement

Tier 10 – Green Belt Around Villages

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

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

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

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

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

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

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

There is no settlement report for Guildford Town Centre, and so Tiers 1 and 2 are both amalgamated into the Guildford Urban Area (representing a population of 73,779 – just over half of the Borough’s population, and warranting two and a half pages in the Report).  Here the report says: “Guildford is designated as an urban area and contains a high level of services. As such it could support a level of development which exceeds that of any of the borough’s other settlements.

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

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

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

 

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

Conclusion

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

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

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

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

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

 

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

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

20140904_LandUses-MSOA-LSOA_FINAL

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

20170714_IMD-Charts_FINAL_V3

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

Guildford Society Hearing Statement

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

Here is a full set of the GSoc documents:

0_20180510_GSoc-EIP-Submission-LETTER
(cover letter)

1_20180510_GSoc-EIP-Submission-MAIN
(main document)

2_20180510_GSoc-EIP-Submission-APPENDIX1
(GSoc SANG Paper by Alderman Bridger)

3_20180510_GSoc-EIP-Submission-APPENDIX2
(GSoc Infrastructure Topic Paper by the Transport Group)

4_20180510_GSoc-EIP-Submission-APPENDIX3a
(Correspondence requesting confirmation from GBC on which if any groups were excluded from interacting with officers at the Council)

5_20180510_GSoc-EIP-Submission-APPENDIX3b
(copy of internal email instruction to officers to not engage with the Guildford Vision Group)

6_20180510_GSoc-EIP-Submission-APPENDIX4a
(Correspondence requesting explanation from GBC about the £5m contribution agreed with the Dunsfold developers to mitigate against impact of development on Guildford)

7_20180510_GSoc-EIP-Submission-APPENDIX4b
(Guildford Borough Council response on Dunsfold showing an increase of traffic on the gyratory of circa 300 cars over the three peak hours)

8_20180510_GSoc-EIP-Submission-APPENDIX5
(Agreed Statement of Common Ground with the Guildford Vision Group – highlighting GSoc’s support for the GVG Master Plan)

9_20180510_GSoc-EIP-Submission-APPENDIX5-1
(file 9 is a large (160mB) document containing the GVG Master Plan)

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

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

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

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

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

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

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

20180331_LocalPLanCommentary_FINAL

 

 

Local Plan – comments on Inspector’s Feedback to GBC

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

GSoc Response to 2017 R19 Consultation

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

20170724_GSOC_RESPONSE_R19-LOCALPLAN_FINAL-redactedsignature

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

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

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

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

20170724_Addendum-and-Corrigendum

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

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

20170724_GSOC_RESPONSE_R19-LOCALPLAN_FINAL_revised_Redacted

 

 

Reg 19 Local Plan Consultation 2017

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

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

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

Guildford_borough_Proposed_Submission_Local_Plan_(2017)_and_Appendices_A-G

Guildford_borough_Proposed_Submission_Local_Plan_(2017)_Appendix_H_Maps_A-G

Guildford_borough_Proposed_Submission_Local_Plan_(2017)_Appendix_H_Maps_H-P

Guildford_borough_Proposed_Submission_Local_Plan_(2017)_Appendix_H_Maps_R-W

ERRATA_for_Proposed_Submission_Local_Plan_June_2017

Continue reading “Reg 19 Local Plan Consultation 2017”

GSoc Local Plan Reg19 Consultation Submission

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

Here is the Submission with its accompanying documents:

20160717_GSOC_Response_to_ConsultationDraftReg19LocalPlan_FINAL

20160718_Reg19ConsultationQuestionnaire-GSOC

201409_DandH-PositionPapers

20160715_R18-2014_to_R19-2016_Comparison_Policies

20160715_R18-2014_to_R19-2016_Comparison_Sites-Part1

Julian Lyon
Chair, The Guildford Society

18th July 2016

 

Final Draft for Council Approval

On 24th May the Full Council will consider the Draft Local Plan and determine whether it is ready to go out for Regulation 19 Consultation.

Here are the papers for that meeting:

Proposed Submission Local Plan

1. Final document including sites – Compressed

2. Appendix A – Glossary

3. Appendix B – TC shopping frontages 2016

4. Appendix C – Infrastructure Schedule April 2016

5. Appendix D – Evidence Base

6. Appendix E – Superseded Policies

7. Appendix F – Overview of borough map

8. Appendix G – Policy and Monitoring

9. Appendix H – Maps – Compressed

Supporting draft environmental screening:

draft Guildford BC Local Plan – SA Report 160513

Draft Guildford LP HRA April 2016 for issue

Supporting draft Infrastructure Delivery Plan:

draft IDP May 2016 for FC LAA 2016

Summary of 2014 Consultation responses:

Statement of Representations Procedure

1 Consultation Statement introduction and appendices 1- 4a

2 Appendix 4b Responses to policies 1 – 19

3 Appendix 4c Comments on Site Allocations Appendices question responses

Here are the main changes from the original travelling draft (presented to the Executive Advisory Committee) to the present version:

Item 03 1 – Table of main changes between EAB and Executive

Main changes between Exec and Full Council

 

Comparison of 2014 and 2016 draft Local Plan documents

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

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

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

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

20160416_R18-2014_to_R19-2016_Comparison_Sites-Part1

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

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

20160414_JKyte_LocalPlanPoliciesChanges2016

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

 

Latest Draft Plan (Apr 2016)

Guildford has published its draft Regulation 19 Consultation Draft Local Plan (two drafts because it is not yet approved for consultation and not yet adopted) and the first stage will be when it is presented to a Council Committee on 13th April.

As before, I have created links here to a point-in-time version with the evidence base as it stood on 9th April 2016 (but to keep up with the actual document, here are the links to the Council web site.

http://www.guildford.gov.uk/newlocalplan

The draft documents are here:

EAB Draft – GBC Proposed Submission Local Plan – Report and Appendix A-G – 1 of 2_Red

Appendix H Maps with watermark_reduced

LAA 2016

These are prepared along with the officers’ summary to the Council meeting on 13th April.

Proposed Submission Local Plan Strategy and Sites

The Evidence Base can be accessed from here but is reproduced below as at 9th April 2016 (be aware many of these are large files and, whilst we have not listed the sizes here, the relevant page on the Guildford Borough Council website is linked at each heading):

Surrey Hills AONB Areas of Search Natural Beauty Evaluation

AONB_MAP_-_AONB_Boundary_Review_-_Recommended_areas_for_consideration

AONB_MAP_-_Draft_LCA_Landscape_Typologies_and_Character_Areas

AONB_MAP_-_Study_Area_and_Existing_AONB_and_AGLV

AONB_Natural_Beauty_Evaluation_Report_(Oct_2013)

Conservation Area Character Appraisals

CA_Abbotswood

CA_Abbotswood_Buildings

CA_Abbotswood_Townscape

CA_Bridge_Street_Area_Appraisal__2_

CA_Bridge_Street_Conservation_Area

CA_Charlotteville_Cons_App_for_web_doc_1_2

CA_Charlotteville_Cons_App_for_web_doc_3

CA_Charlotteville_Cons_App_for_web_doc_4_5

CA_Charlotteville_Cons_App_for_web_doc_6

CA_Charlotteville_Cons_App_for_web_doc_6_maps-1

CA_Charlotteville_Cons_App_for_web_doc_6_maps-2

CA_Charlotteville_Cons_App_for_web_doc_6_maps-3

CA_Charlotteville_Cons_App_for_web_doc_6_maps-4

CA_Chilworth_cons_area_appraisal_for_web

CA_Chilworth_Conservation_Area_Map_boundary

CA_EastClandonCharacterAppraisal

CA_EastClandonMap

CA_Guildford_town_centre_6_Appendix_1_Characte_Areas_map

CA_Guildford_town_centre_6_Appendix_1_Character_Areas_map_1

CA_Guildford_town_centre_6_Appendix_1_Character_Areas_map_2

CA_Guildford_town_centre_6_Appendix_1_Character_Areas_map_3

CA_Guildford_town_centre_6_Appendix_1_Character_Areas_map_4

CA_Guildford_town_centre_CAA_low_res_ CA_OnslowVillageApprovedText

CA_Pirbright_Area_Map_all_info_layers

CA_Pirbright_Area_Map_Article_4_buildings

CA_Pirbright_Area_Map_old_and_proposed_boundaries

CA_Pirbright_Conservation_Area_1973_Boundary

CA_Pirbright_Conservation_Area_Appraisal_book_low_res1

CA_Pirbright_Map_1872_County_Series_Epoch_1

CA_ShereCharacterAppraisal

CA_ShereMap

CA_St_Catherines_Conservation_Area_Appraisal_full_book

CA_Waterden_Road_Conservation_Area_Appraisal_loe_res

Employment land needs assessment

ELA_Employment_Land_Assessment_2015

Guildford Renewable Energy Mapping Study

Energy_Guildford_Renewables_Mapping_Final Environmental_sustainability_and_climate_change

Green Belt and Countryside Study

Summary Document:

GBCS_Summary_Document_January_2013

Volume I plus Appendix I & II

GBCS_Volume_I_Guildford_Borough_Green_Belt_and_Countryside_Study

Volume II plus Appendix IV

GBCS_Volume_II_Guildford_Borough_Green_Belt_and_Countryside_Study

Volume II Appendix III

GBCS_BNL.0287_GBS_VOL_II_APP_III

GBCS Land_Parcel_A1

GBCS_Land_Parcel_A4

GBCS_Land_Parcel_B6

GBCS_Land_Parcel_C1

GBCS_Land_Parcel_C2

GBCS_Land_Parcel_E1

GBCS_Land_Parcel_E21

GBCS_Land_Parcel_E22

GBCS_Land_Parcel_E23

GBCS_Land_Parcel_E24

GBCS_Land_Parcel_H1

GBCS_Land_Parcel_H2

GBCS_Land_Parcel_J2

GBCS_Land_Parcel_J3

GBCS_Land_Parcel_K2

GBCS_Land_Parcel_K5

GBCS_Land_Parcel_K6

GBCS_Land_Parcel_K7

GBCS_Land_Parcel_K9

GBCS_Sustainability_Assessment_Key

Volume II Addendum

GBCS_Volume_II_Addendum_17_04_2014

GBCS_Addendum_to_GBCS_Volume_V_brief

GBCS_Appendix_1_Green_Belt_Purposes_Schedule

GBCS_Appendix_2_Green_Belt_Sensitivity_Map

GBCS_Appendix_3_ECA_Schedules

GBCS_Appendix_4_ECA_Mapping

GBCS_Appendix_5_Sustainability_Walking_Distances

GBCS_Appendix_6_Sustainability_Schedules

GBCS_Appendix_7_Residential_Capacity

GBCS_Appendix_8_PDAs_for_Urban_Areas

Volume III plus Appendix V, VII

GBCS_Volume_III_Guildford_Borough_Green_Belt_and_Countryside_Study

Volume III Appendix VI

GBCS_BNL.0287_GBS_VOL_III_APP_VI GBCS_brief_2009

GBCS_Chilworth

GBCS_East_Horsley_and_West_Horsley_(North)

GBCS_Effingham

GBCS_Fairlands

GBCS_Flexford

GBCS_Normandy

GBCS_Ockham

GBCS_Peasmarsh

GBCS_Pirbright

GBCS_Ripley

GBCS_Send

GBCS_Send_Marsh_Burntcommon

GBCS_Shalford

GBCS_West_Clandon_North_and_South

GBCS_West_Horsley_(South)

GBCS_Wood_Street_Village

Volume IV

GBCS_Volume_IV_17_04_2014

GBCS_Appendix_VIII_Village_Insetting

Volume V

GBCS_Volume_V_17_04_2014

GBCS_Section_17_Adjoining_Borough

GBCS_Section_18_Area_of_Outstanding_Natural_Beauty

GBCS_Section_19_Countryside_Beyond_the_Green_Belt

GBCS_Section_20_Major_Previously_Developed_Sites

GBCS_Section_21_Major_Village_Expansions

GBCS_Section_22_New_Settlement_at_Wisley_Airfield

GBCS_Appendix_IX_Potential_development_areas_surrounding_urban_areas_and_villages

GBCS_Appendix_X_Insetting

GBCS_Appendix_XI_Major_Village_Expansions

GBCS_Appendix_XII_GBC_Settlement_Hierarchy

GBCS_Appendix_XIII_Farncombe_Walking_Distances

GBCS_Appendix_XIII_Sustainability_Schedule_PDAs

GBCS_Appendix_XIV_Gomshall_Walking_Distances

GBCS_Appendix_XIV_Shere_Walking_Distances

GBCS_Appendix_XIV_Sustainability_Schedule_PDAs

GBCS_Appendix_XV_K3_Sustainability_Schedule

GBCS_Appendix_XV_K3_Walking_Distances

GBCS_Appendix_XVI__Burntcommon_Walking_Distance_B14

GBCS_Appendix_XVI_Burntcommon_Walking_Distance_B12_13

GBCS_Appendix_XVI_Normandy_Flexford_Walking_Distance_H12

GBCS_Appendix_XVI_Send_Walking_Distance_B16

GBCS_Appendix_XVI_Sustainability_Schedules_PMDAs

GBCS_Appendix_XVII_Key_Environmental_Designations

GBCS_Appendix_XVII_Key_Local_Plan_Policies_Guildford

GBCS_Appendix_XVII_Key_Local_Plan_Policies_Waverley

GBCS_Appendix_XVII_Key_Local_Plan_Policies_Woking

Volume VI

GBCS_Volume_VI_Final_Version

Briefing Notes and FAQs

GBCS_Addendum_to_GBCS_Volume_V_brief

GBCS_BNL.0287_GBS_VOL_III_APP_VI GBCS_brief_2009

GBCS_Brief_for_Volume_V

GBCS_Briefing_note_and_FAQs

GBCS_Note_from_Lead_Member_for_Planning_and_Governance

Maps

GBCS_Maps_Appendix_X_Insetting

GBCS_Maps_Appendix_XI_Major_Village_Expansions

GBCS_Maps_Potential_development_areas_surrounding_urban_areas_and_villages

Planning for open space and green infrastructure

GOS_Main_Report

GOS_Appendix_1_Policy_Background

GOS_Appendix_2_S106_Contributions

GOS_Appendix_3_Map_of_Wards

GOS_Appendix_4_Survey_Sheets

GOS_Appendix_5_Consultation_Review

GOS_Appendix_6_Vision_for_Open_Space

GOS_Appendix_8_Quantitative_Data

GOS_Appendix_9_Quantitative_Data_and_NPFA_Standards

GOS_Appendix_10_Qualitative_Data

GOS_Appendix_11_Discussion_of_Findings

GOS_Appendix_12_Proposed_Standards

GOS_Appendix_13_List_of_all_sites_audited

Retail and Leisure Study

GRLSU_Final_Report_and_Appendices_25-09-15

Habitat Regulations Assessment (HRA)

HRA_briefing_note_and_FAQs

HRA_July_2014_-_Main_Report

HRA_Screening

HRHRA_A_July_2014_-_Figure_1_-_Location_of_Thames_Basin_Heaths_SPA_within_Guildford_Borough

Infrastructure

Infrastructure_1491_Guildford_borough_Infrastructure_baseline_1307011

Landscape Character Assessment

LCA_Borough_Mastermap_V01_120ppi

LCA_Countryside_Character_Areas

LCA_Landscape_Character_Assessment2007_029

LCA_Rural_Assessment_Master_Copy

LCA_Rural-Urban_Fringe_Assessment_-_Master_Copy

LCA_Townscape_Assessment_Master_copy

Sustainability Appraisal

SA_Guildford_Local_Plan_SS_Interim_SA_Report

SA_Guildford_non_tech_summary_SA_Local_Plan_SS

SA_Initial_SA_Aug_2013

SA_Responses_to_SA_scoping_report

SA_Scoping_Report_FINAL_ISSUED_July2013

SA_Site_assessment_criteria

Settlement hierarchy

Settlements_Guildford_borough_Settlement_profiles

Settlements_Settlement_hierarchy_May_2014

Strategic Flood Risk Assessment

SFRA_Appendix_A_Catchment_overview

SFRA_Appendix_B_Flood_defences

SFRA_Appendix_C_Flood_risk_from_rivers_-_1

SFRA_Appendix_C_Flood_risk_from_rivers_-_2

SFRA_Appendix_C_Flood_risk_from_rivers_-_3

SFRA_Appendix_C_Flood_risk_from_rivers_-_4

SFRA_Appendix_C_Flood_risk_from_rivers_-_5

SFRA_Appendix_D_Flood_risk_from_surface_water_1

SFRA_Appendix_D_Flood_risk_from_surface_water_2

SFRA_Appendix_D_Flood_risk_from_surface_water_3

SFRA_Appendix_E_Flood_risk_from_groundwater_1

SFRA_Appendix_F_Flood_risk_from_sewers

SFRA_Appendix_G_Flood_Risk_from_Artificial_Sources

SFRA_Guildford_Borough_SFRA_Summary_Document

SFRA_Guildford_Borough_SFRA_Volume_1_Decision_Support_Document

SFRA_Guildford_Borough_SFRA_Volume_2_Technical_Report

Land Availability Assessment (LAA)

SHLAA_for_publication_1_May_2014(1)

SHLAA_FULL_SHLAA_June_2014

Strategic Housing Market Assessment (SHMA)

SHMA_Briefing_note

SHMA_Final_West_Surrey_SHMA

SHMA_West_Surrey_SHMA_Brief

SHMA_West_Surrey_SHMA_Summary_-_Guildford

Sites of Nature Conservation Importance

SNCI_evidence_base

Surface Water Management Plan

SW_Ash_SW_Study_-_Appendix_F_-_Action_Plans_for_Hotspots_(2)

SW_Ash_SW_Study_Revised_Technical_Report_Rev_4

SW_AshLodgeDrive_CatchmentBoundary

SW_AshStationArea_CatchmentBoundary

SW_Guildford_SWMP_Appendix_G_-_Action_Plans_for_Hotspots_(2)

SW_Guildford_SWMP_FINAL_Technical_Report_(2)

Access and transport

Transport_GLD Transport Strategy Annex 24.11.2014

Transport_GLD Transport Strategy Main doc 24.11.2014

Transport_GOTCHA_Technical_Note_1_-_Appendices_A_to_C_-_Issue_1_1109151

Transport_GOTCHA_Technical_Note_1_-_Note_-_Issue_1_110915

Transport_GTAMS_Appraisal_of_Interventions_Report_-_Final_Updated_March_2015

Transport_GTAMS_Baseline_and_BAU_Report_-_Final_Updated_March_2015

Transport_GTAMS_CouncilReport_pdf36

Transport_GTAMS_Strategy_Report_-_Final_Updated_March_2015

Transport_OGSTAR_(SCC_Jan_2014)

Transport_OGSTAR_Addendum_1

Traveller Strategic Housing Land Availability Assessment (SHLAA)

Traveller_SHLAA_June_2014_update_published_version

Guildford Local Plan and Affordable Housing Viability Study

Viability_Guildford_Borough_Residential_Appraisals

Viability_Guildford_Development_Viability_Study_2014

 

 

Draft MasterPlan to be Reviewed by Scrutiny Committee

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

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

Draft Town Centre Master Plan

Item 04 Appendix 2 Scenario 1 (29Mb)

Item 04 Appendix 3 Scenario 2 (29Mb)

Item 04 Appendix 4 Viability Report

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

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

 

Comments welcomed.