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)
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.
On the face of it this is a good document – an encouraging start to compiling the evidence base.
Looking at in greater detail, there are certainly some omissions (or at least details which would benefit the Local Plan process if included).
First the good…
The report is well written and is largely quite approachable.
The sections make sense and the content is reasonably comprehensive.
The authors do not shy away from some of Guildford’s trickier issues such as congestion and poor pedestrian and cycling routes.
And then the missed opportunities…
The report (1.1.2) sets out to provide “an overview of the quality and capacity of the existing provision of infrastructure of different types”.
In 1.2.1 the report should include the Rivers and canal as a heading (Wey, Tillingbourne, etc). This would ensure the river is in the heart of the town and Borough.
At 1.3.9 there is an expectation that “additional infrastructure capacity (will) mostly be funded from development” without looking to suggest a mechanism to raise infrastructure funding against tax revenues if a suitable funding scheme can be found.
At 1.4.4 the document refers to masterplans being called for if there is a “significant development site” to be included on the Local Plan Strategy and Sites document. This is clearly a welcome statement and should be taken to include all sites brought forward before the Local Plan is adopted.
1.5.1 sets out an approach to partnership and it is to be hoped that a similar delivery partnership can be established for the town centre in Guildford.
1.6.3 refers to working with infrastructure providers as the Council prepares the Local Plan. It is reasonable to request that a method statement of purpose be provided to explain how emerging needs will be integrated into the Evidence Base and be assessed ESPECIALLY where there may be competition for spare infrastructure capacity.
At 2.1.3 – or in an Appendix – it would be helpful to list all of the junctions (however minor) on the A3, including an assessment of the quality, capacity and other issues where known.
The Evidence Base document ‘Surrey Future: Congestion Programme – SCC March 2013′ does not cover adequately the situation of the A3 and the adjacent Local Road Network and should have covered the above comments relating to 2.1.3, the evidence of origins and destinations and the details which give rise to the authors’ comment in 2.1.14, notably “the result is that traffic congestion in Guildford can adversely affect conditions on the A3 and vice versa“.
The document only highlights congestion hotspots and merely offers modal shift and rapid response to “incidents” as the way forward (2.2.29 and 2.2.30) and seems a rather weak response to any criticism that the last major infrastructure investment by Surrey County Council and the highways Agency in the Borough was for the A3 ‘bypass’ in 1981.
At 2.1.12 The Infrastructure Baseline Report report indicates the A31, approaching and entering Guildford, and the A3 through Guildford as amongst those incurring highest costs due to congestion in the County; and by 2026 will include areas “severely over capacity”. (201303_SCC_Congestion-Programme-FINAL) – the two illustrations in Figure 5 and the map in Figure 7 of the report show this very well:
Another apparent omission is that in compiling an up-to-date destinations and origins survey on the A3 (and the local roads) to identify the types of journey being made and to establish whether there are opportunities to reduce trips, this should also take account of the increase of traffic on the A3 since the Hindhead Tunnel opened – there should by now be concrete evidence available of this latter effect which should be placed in the public domain and should form part of the evidence for the Infrastructure Base.
A major consideration at 2.1.16 is the extent to which communities are severed by the A3, railway lines and the River Wey. Placing this important issue in the section on A3 but not elsewhere risks its importance being understated. A full quantitative and qualitative list of crossing points of each linear obstruction should be provided in the appendices along with areas where the lack of crossing points is causing major issues or leads to bottlenecks on the nearest alternative access. It should also be noted whether there are any rights (under CPO or otherwise) for bridging rights to be acquired.
Note (2.1.22): it is unlikely that small changes in the Borough will ease the congestion, especially when we take into consideration the scope and scale of development proposed in the Strategic Housing Land Availability Assessment and the Employment Land Assessment.
Note (2.2.2): it is clear throughout the Evidence Base (and other supporting and background documents) that existing congestion is threatening both the economy and the future growth of Guildford.
At 2.2.13 it should be noted that traffic movements are expected to increase in line with growth of the Science Park, University, retail and demand for housing. Employment demand is expected to increase by some 15% between 2006 and 2031. (GBC ELA – 2013) – or between 6-10% per year according to the SCC Congestion Strategy Report (p16 – Figure 2 – see below). Car availability in Surrey has been increasing steadily at more than 60% above the National Average (SCC Transport Statistics 2009).
At 2.2.20 the Onslow Village, Ashenden and Dennisville areas should also be included as having a major issue with on-street parking relating to the University in particular. The majority of employment is in the Onslow Ward and particular attention needs to be given to resolving conflicts of movement and parking to the west of the London Mainline railway.
Whereas this major scheme “being developed for the present Guildford gyratory area” (2.2.21) can result in improvements, they are only likely to be stop gaps as a significant change in the infrastructure is needed for the long term (2013 – 2026).
Furthermore, improving Park & Ride and car parking (2.2.22) will not make sufficient difference to congestion as current available data for the gyratory shows that at least 40% of traffic is either cross-town or through-town traffic.
The scheme from 2000 referred to in 2.2.24 (to provide a shared bridge for buses to the University at the northern edge of Guildford Park Car Park) is no longer viable due to developments in Walnut Tree Close since 2000 unless incorporated into a major restructuring of the Strategic Road Network in the area.
At 2.2.26 the first bullet point (pedestrian crossings at Chertsey Street, North Street and High Street) appears to be based on a suggested re-arrangement of bus routes (some terminating in this area) which is not considered viable. There are equally or more important pedestrian issues to be addressed elsewhere and it seems odd to single this out in this section.
The second and third bullet points in 2.2.26 (junctions between Jacobs Well Road and A320 Woking Road, and Junction of Jacobs Well Road and Clay Lane should be incorporated into planned or envisioned developments at Slyfield.
At 2.3.3 there is an error of omission or of adding up as the car parks listed are FOUR of the six largest car parks.
Also at 2.3.3 it may be worth calculating an average purchasing power per car space as a part of ensuring the ongoing vitality and viability of the town centre. This can only ever be a rough guide but would help to ensure the provision of parking was proportionate to the economic aspirations for the town.
At 2.3.5 (car parking demand) the occupancy data lacks explanation and context – for example, it is clear that a reduction of the retail economy where 2011-2012 was 5% lower than the 2005-2008 period. The effect of car parking charges in the evenings seems to show up in the Friday evening occupancy figures but no assessment is included to consider the economic benefit of charging £1 for car parks when it means streets are full of kerbside ‘free’ yellow-line parking.
At 2.4 (buses) – a Surrey County Council responsibility that absolutely impacts the Borough and our residents and visitors – fails to note that the evidence bases are inadequate (for example, the 2011 Surrey Transport Plan seems to concludes that bus provision should simply be ‘more of the same’). There is no demand study, for example, to show how behaviours might change if more buses were available for commuter hours and for the evening economy.
Furthermore, this section should include an audit of the various bus services that are provided across the Borough – the numbers of passengers, the hours of service, the frequency of services, the cost of the services. This section in particular needs to integrate with the Settlements Report so as to ensure that good data is available for all parts of the Local Plan process. The Settlement Report refers to bus services as poor or good but does not qualify such pejorative terms.
At 2.4.12 the hours for park and ride (7.30am to 7.30pm) do not seem to fit at, say, Onslow Park and Ride, with opportunities to service hospital visiting; the hours or operation are not consistent with promoting the evening economy in town.
At 2.4.8 it is worth noting that the 2001 Census (quoted in SCC Congestion programme – 2013) gives 55% of Guildford’s labour force as resident locally; although probably now out-dated, this indicates the importance of Park & Ride facilities and bus services for providing for commuters from other parts of the Borough into the town centre. See Table 4 from the SCC report below:
A similar analysis should have been done to understand the movements of residents in the Borough between homes and workplaces for the purposes of the Evidence Base.
At 2.4.13 there are no details as to where the priorities are and what ‘corridor improvements’ are proposed.
The reference at 2.4.15 to providing bus facilities “elsewhere” represents a challenge for the infrastructure baseline which should probably be focussed more on the types and numbers of buses, the extent to which the bus interchange is a critical factor for bus users and what this tells us about where a replacement facility might be accommodated. It is, however, appropriate to identify the likely interim solution and to plan to ensure that, for potentially many months if not years, there will need to be adequate capacity in the town centre road network to accommodate a different set of traffic flows than those seen today.
In the bus section, there is no reference to the MVA Bus Station Study – October 2011 (or any more recent incarnation) which should be included in the Evidence Base and should be referenced clearly in the Infrastructure Baseline. The MVA study contains bus routes, numbers at peak hours, etc.
At 2.4.17 the word “serious” should be inserted to read “There are serious problems with traffic congestion…”
The bus fleet (and the contracts negotiated by Surrey County Council with the bus operators) should be quickly migrated from dirty diesel buses with street-level exhausts to cleaner technologies. Failure to tackle this issue will lead to Guildford taking more old buses from other local authorities which are pushing for clean buses.
At 2.5.4 the baseline report refers to numbers of pedestrians on Bridge Street. Guildford Society has data that shows 2000 pedestrians per hour cross the Debenhams Puffin Crossing on a Saturday morning.
Paragraphs 2.5.7 and 2.5.9 do not tell the full story. NCR22 extends south from Guildford across Shalford park and clear of the A281 through Shalford. It then joins the disused Cranleigh line at Broadford (A248) and continues south on this route (the Downs Link) and it is very well used.
The chart at Figure C and text in 2.5.13 does not indicate if the respondents were asked how many would like to be able to cycle or walk 30 minutes if it were safe or pleasant to do so.
At 2.5.14, neither a North-South through route nor increased access to Surrey University from the north appear to have been considered.
At 2.5.15 there is no flagship scheme nor any priorities identified to emphasise the importance being attached to the need for better cycle routes.
2.5.18 should highlight the fact that there has been no significant improvement in the pedestrian experience in the town centre since the High Street was pedestrianised in the late 1970’s.
At 2.6.12, it needs to be noted that the schemes referred to are included in the new County Rail Strategy as well as the need to consider new stations for Park Barn and Merrow.
Section 4 – Green infrastructure – should include a section on the rivers and streams and canals in the Borough, and it may also be pertinent to include land in the ownership and/or stewardship of the National Trust within the Green Infrastructure. Equally parts of the rural environment around villages and in between – including areas such as St Martha’s hill and the Hogs Back should be included in the Green infrastructure section.
At 5.2.6 it should be noted that there are smaller organisations such as Italia Conti that provide specialised courses in Higher Education.
7.3.17 might also include Addison Court in Charlotteville.
At Section 8.3 the document makes a notable omission in that the Lido is not mentioned, and neither are the sports facilities at Shalford Park.
Furthermore, there are numerous recreation grounds and village greens around the Borough which should either be referenced in 8.3 or elsewhere in the document along with other community open space and community halls and allotments.
The document itself is a positive and largely comprehensive assessment of the infrastructure baseline and the comments made here can be easily integrated into the Evidence Base, providing supplementary evidence rather than contradictory views.
It would be useful if there were more specific detail in the annexes of the stage each type of infrastructure (and its component parts) has reached – including breaking points and pinch points that, by design and/or investment, could be resolved.
A traffic-light system could be employed to highlight:
Red – at or exceeding capacity
Amber – approaching capacity
Green – working well within capacity
For example, looking at the provision of school places, it would be reasonably straightforward to show the schools on a map with a traffic-light symbol so that, from first glance, it is possible to see where development would have to be limited or contributing to overcoming capacity limits.
A similar approach to roads and junctions would enable clear mapped identification of issues and capacity restrictions.