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):
- 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.
- A local plan or a supplementary planning document must contain a reasoned justification of the policies contained in it.
- Any policies contained in a supplementary planning document must not conflict with the adopted development plan.
- Subject to paragraph (5), the policies contained in a local plan must be consistent with the adopted development plan.
- 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that is intended to supersede another policy in the adopted development plan, it must state that fact and identify the superseded policy.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.
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.
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:
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||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||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||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||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||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||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.