Getting the Plan Right First Time

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

Three things come to mind:

1. Planning Rules

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

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

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


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that is intended to supersede another policy in the adopted development plan, it must state that fact and identify the superseded policy.

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

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

2. Knowledge

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

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

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

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

3. Spatial Hierarchy

GBC’s own plan and the accompanying Sustainability Appraisal set out clearly what the sequential hierarchy is for development – and Guildford’s own response to the Inspector’s pre-Examination questions shows that they recognise the sequential approach. (paragraphs 6.6.4 and following) set out the Spatial Hierarchy in order of priority with the most sustainable first:

Tier 1 – Guildford Town Centre

Tier 2 – Guildford Urban Area

Tier 3 – Ash & Tongham Urban Area

Tier 4 – Built-up Area of Villages

Tier 5 – Village ‘Gap’ Sites

Tier 6 – Brownfield in the Green Belt

Tier 7 – Countryside Beyond the Green Belt

Tier 8 – Green Belt Around Guildford

Tier 9 – New Settlement

Tier 10 – Green Belt Around Villages

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

The Guildford Society has continually and consistently made the point that the Settlement Profiles Report is not fit for purpose: (accessed 17th June 13:48)

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

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

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

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

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

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

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

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


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


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

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

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

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

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


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

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


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


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

Guildford Vision Group’s Published Masterplan Document

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

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

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


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

Dec2017 Regulation 22 Local Plan Submission

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

Local Plan Examination

Submission Local Plan (Reg 22)

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

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

Next steps

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

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

Programme Officer: Mr Chris Banks

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

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


Tel: 01903 783722

Documents submitted

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

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

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

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

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

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

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

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

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

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

Minor Modifications to the Proposed Submission Local Plan (2017)

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

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

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

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

Committee decisions

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

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


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

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

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


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

Purchasing a hard copy of the Submission Local Plan

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


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

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












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

Guildford let down by Planning Inspectorate over Solum

The Planning Inspector has today published his decision on the Solum, and it will send shock waves through the groups and Societies that had spent so much time and energy trying to prevent it.

Despatch Cover Letter – J Lyon – 22 Jan 2018

Appeal Decision 3161412

There will be more comment in due course, but in the meantime, this seems to be a victory for pigheaded planning and architectural thuggery, and a defeat for Localism and for scale and heritage.

This is a sad day for Guildford.

Farnham Road Bridge in Crisis

The Farnham Road Railway Bridge was initially constructed before 15 October 1849 when the Guildford to Godalming railway line was opened.

At the time of its construction, there was very little housing on the western side of the railway at Guildford. The bridge was a gateway into the town via a cart track across the Hog’s Back.

This map of Guildford’s Royal Park in the early 1600s shows the route along the Mount to the south of the park


By 1816, more than two hundred years later, the Farnham Road had been built (shown as New Road on the map below).

There is still very little development showing on the western side of the River Wey.

By 1835, Guildford was growing its industrial base – on 10 May 1844 the Guildford Junction Railway was authorised to construct a branch from there to the important manufacturing town of Guildford.

The line from Woking to Guildford opened on 1 May 1845.

By 1870 (the two plans below) the gasworks had arrived and the railway line from Guildford to Godalming had finally been opened on 15 October 1849.

In around 1885 or so Karl Benz is credited with inventing the automobile and so the Farnham Road Bridge had already been in situ for forty years before the first motor car was manufactured.

By 1896, the Clandon and Aldershot lines had been added.  We begin to see the first signs of a settlement to the east of the Farnham Road hospital.

The 1916 map (below) shows the railway lines in a similar configuration to today’s layout and so the cast iron section of the railway bridge must have been in place before 1916.

More development has taken place to the western side of the railway station, but still very limited.

By 1934, development on the western side of the railway was becoming quite substantial with much of Onslow Village having been developed by that time.

And here, looking at the town centre in 1938 we can see the roads as they were before Millbrook was opened and before York Road was extended to reach the Woodbridge Road.

Today, the Farnham Road Bridge carries much more (and heavier) traffic than it was ever designed to support, it remains the only crossing of the railway in the town centre and it cannot be a surprise to anyone who has seen bits of brick and dust dropping onto the tracks below when a heavy truck crosses it, that this bridge needs to be replaced.

The residential and commercial areas on the western side of the town, including the hospital, Cathedral, University, Research Park and much more besides rely on the Farnham Road Bridge to get across the railway into town, and Network Rail and Surrey County Council are discussing the need to close it to buses and trucks with immediate effect.

This is a known problem and the issue has been ducked too many times in the past.

Guildford Vision Group has a very interesting and worthwhile scheme to resolve this problem but this crisis has come along too soon for the solution to be implemented before the bridge needs major works just to stay open.

GSoc Response to 2017 R19 Consultation

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


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

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


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



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




Is NIMBY a derogative term?

There has been a trail of emails on the Guildford Dragon ( where correspondents have taken issue with the term NIMBY.

I have no particular concern with the term NIMBY (‘not in my back yard’) and nor do I have any particular beef against people who staunchly protect their back yards – it should be a sign that people care enough about their own environment to get energised about development proposals that affect them.

There is a difficulty with NIMBYism where there is a development of national, regional or even Borough-wide importance. This should not prevent (no insult intended) NIMBYs seeking to have that significant development put elsewhere, but it should be noted that there will be plenty of people elsewhere (who don’t live in the micro-environment) who will press for the significant development to happen whether there or elsewhere.

I am as capable of being a NIMBY as the next person and I like to think I am objective in my NIMBYism. I can wear the badge with some pride but I do always try to point out that I am a near resident and that my intervention is knowledgeable of both my area and the proposal itself.

Dedicated NIMYism may take a huge amount of effort investigating other potential solutions elsewhere to demonstrate how much better they would be. So NIMBYism is not necessarily a hyper-local introverted attitude.

It goes without saying that often NIMBYs are disappointed in major developments because we have spent so much energy fighting against the principle that when we lose (as sometimes we do) we have had little or no say in what the end development is actually like. This is the real conundrum – how do we say “No, Bu if it happens it should be like this…” without undermining our core arguments?

Incidentally, I would rather be a NIMBY than a BANANA (build absolutely nothing anywhere near anything/anybody).


Julian Lyon (8th January 2017)

Comparison of 2014 and 2016 draft Local Plan documents

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

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

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

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


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

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


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


Draft MasterPlan to be Reviewed by Scrutiny Committee

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

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

Draft Town Centre Master Plan

Item 04 Appendix 2 Scenario 1 (29Mb)

Item 04 Appendix 3 Scenario 2 (29Mb)

Item 04 Appendix 4 Viability Report

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

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


Comments welcomed.


Here are some draft slides showing something of the nature of Guildford’s constraints:




Is it any wonder there has had to be some thought about incursions into the Green Belt (whatever the political ramifications may be).

Here are some supporting statistics:


Does anyone have any ideas where even 345 homes per year would go in the long-term?

This is not for the faint-hearted, so pity the poor Councillors when they arrive at Millmead after May 7th!