Guildford Society Hearing Statement

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

Here is a full set of the GSoc documents:

(cover letter)

(main document)

(GSoc SANG Paper by Alderman Bridger)

(GSoc Infrastructure Topic Paper by the Transport Group)

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

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

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

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

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

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

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

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

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

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

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

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

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




Guildford Vision Group’s Published Masterplan Document

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

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

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


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

Local Plan – comments on Inspector’s Feedback to GBC

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Dec2017 Regulation 22 Local Plan Submission

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

Local Plan Examination

Submission Local Plan (Reg 22)

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

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

Next steps

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

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

Programme Officer: Mr Chris Banks

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

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


Tel: 01903 783722

Documents submitted

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

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

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

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

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

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

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

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

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

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

Minor Modifications to the Proposed Submission Local Plan (2017)

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

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

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

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

Committee decisions

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

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


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

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

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


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

Purchasing a hard copy of the Submission Local Plan

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


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

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












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

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.

Local Plan Submission

Last week (21st November 2017) the Full Council of Guildford Borough voted to submit its Local plan for Examination in Public by the Planning Inspectorate.

The plan has been subjected to an unprecedented amount of scrutiny and the Guildford Society has been through the tens of thousands of pages of drafts, evolving evidence base, consultation documentation and responses by other groups. This has been a major endeavour and we know, from their findings, that, however much they share the desire to have a Local Plan in place, this plan has some substantial flaws.

There are some political differences of opinion – the Sir Paul Beresford MP (Mole Valley) approach of ‘pile development high in the centre of Guildford to save development in his back yard’ (my words) versus the ‘spread out into a small percentage of the 89% of the Borough that is in the green belt and leave our town alone’ arguments. The truth is, there probably needs to be some of both things.

For far too many years (probably since the 1970’s) we seem to have been afraid to regenerate the town and we have failed to plan for enough homes in the rural communities – our young people have to move away because there is no realistic choice of staying local.

This planning inertia, however, hides a much greater failing by our politicians over the past twenty years or so.

  • The failure to provide good enough infrastructure (of all kinds, be it education, health, utilities, roads, alternative transportation, etc);
  • The failure to plan to unlock brownfield sites – perhaps allowing for increased density in some of the urban area estates where 15 dwellings per hectare is a norm, and wherever there are pockets and wider areas of relative deprivation that register on the national and not just the local scale; and
  • The absence in the local plan of a cohesive vision for the town centre.

These failings are the main reason why green field development is required for this plan.

We need to provide for the development of sufficient homes to buy the time (which should have been invested for the past two decades by our politicians) to develop brownfield land.

It would make sense if there were an articulation of the interim nature of this local plan, aiming at ensuring that we do not need to raid the green belt for the next two or three plan periods at least. But there is no such strategic direction in the plan.

We know that the plan aims to provide 12,426 homes over the plan period, and that the Government’s simplified calculation of the Objective Assessment of Need suggests a further 2,600 homes would be needed in the same period. The plan suggests how it might deliver the 12,426 homes, including over a phased ramp up period from 2019 (450 homes) to 2034 (850 dwellings). The plan does not, as required by the National Planning Policy Framework, 2012 and National Planning Policy Guidance, 2014 (as amended), look ahead beyond the current plan period.

The Solum Inquiry heard that the Solum development “complies in all respects with the emerging Local Plan”.

The Guildford Society has made the comment that under this plan we do not know what we expect Guildford to look like in 15 years’ time. We do not know what our skyline will look like in the town, whether there will be adequate protection of key views (the Solum argument being that any harm done to views and settings of listed buildings may be outweighed by benefits – such as contributing to the housing shortfall). We also do not know if the green belt will be adequately protected, either in this plan period and beyond into subsequent periods.

It is a pity that so many key elements are absent from or silent in the submission draft local plan.

From submission of the plan in a couple of weeks’ time, there will be about nine weeks before the Inspectorate give their first feedback to Guildford Borough Council, and thereafter, a couple of months before an anticipated Examination in Public.

It will be interesting to see who will come to that Examination with planning consultants and QCs at hand, and who will sit this out with their fingers firmly crossed, hoping it will all work out in the end.

The Guildford Society and Guildford Vision Group have both been vocal and have contributed substantial detail in response to the consultations. It is likely both organisations will seek to take an active part in the process and will probably look to members and supporters to help them. No doubt the various green belt groups will require similar support to enable them to take part.

This could be the most significant watershed in the history of our town and borough, and is to be hoped, through active engagement, and with the diligence and expertise of a good Planning Inspector, we may end up with a plan that is fit for purpose. It is entirely rational, however, to fear that this will not be the plan to protect and save Guildford, its long-term green belt boundaries or its beautiful heritage town centre.

Julian Lyon
26th November 2017

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.

New Regulation 19 Consultation launches on the 9th June

The new Guildford Borough Regulation 19 Local Plan Consultation will open on 9th June 2017 and run for 6 weeks.

The new Regulation 19 Local Plan Consultation will open on 9th June 2017 and run for 6 weeks.

As before, this site will capture the consultation and the evidence base as it is at the date of consultation.

The updated proposed submission draft local plan should be evidence based and so it is important to track both the evolution of the plan itself and the underlying evidence base.

On this site you will find the 2014 Regulation 18 consultation with its evidence base, the 2016 Regulation 19 consultation with its evidence base and the 2017 Regulation 19 consultation with its evidence base (after it is launched on 9th June).


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)

Reg19 Local Plan Consultation Launched

Guildford Borough Council has finally launched its Regulation 19 Consultation Draft Local Plan. The consultation runs from Monday 6th June 2016 for 6 weeks.

The Borough Council’s Local Plan website is here.

On this site we have followed the process so far, and at each consultation we have added the full evidence base AT THAT TIME.

Here, then, are the Consultation documents (be aware some of these are really rather large files (the Guildford Borough website shows just how big each file is but altogether there are 184 files at 2.2Gb):
















Evidence Base from the list in the Consultation Draft: