Local Plan – comments on Inspector’s Feedback to GBC

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

GSoc Response to 2017 R19 Consultation

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

20170724_GSOC_RESPONSE_R19-LOCALPLAN_FINAL-redactedsignature

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

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

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

20170724_Addendum-and-Corrigendum

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

20170724_GSOC_RESPONSE_R19-LOCALPLAN_FINAL_revised_Redacted

 

 

Time running out for comment

The Consultation Period ends on 22nd September and the Guildford Vision Group and Guildford Society talks on Town Centre Vision (3rd September at the Millmead Centre) and Local Plan Submission (15th September at the Trinity Centre) are coming up fast.

The Clock is Ticking – or is it a Time Bomb?

Julian D S Lyon MBA FRICS
 
The Consultation Periods for the Town Centre Vision and the Draft Local Plan both end on 22nd September.
 
Guildford Vision Group and Guildford Society talks on Town Centre Vision (3rd September at the Millmead Centre) and Local Plan Submission (15th September at the Trinity Centre) are coming up fast.
 
The Town Centre Vision is a vital component of the Local Plan – a once in fifty to a hundred year opportunity to reclaim the riverside from traffic and create a fabulous environment in which to live, work, study and play.  The Surrey Advertiser (Friday 29th September) gave a glimpse of the GVG concept plan to reroute the traffic to the west of the town centre and to create pedestrian priority around the river and between the town centre and the station, university and cathedral.
 
A viable and vibrant town centre needs plenty of people living in the town, and yet much of the town centre (believe it or not) scores in the most deprived 3% of local super output areas (‘LSOA‘s) in the country for outdoor living environment! Simply piling more housing into town without comprehensively resolving that issue would simply be wrong.
 
The Local Plan – if you had just arrived here and read the column inches in the media – would seem to be all about the complete devastation of the green belt and the imposition of an astronomic number of homes per year.
 
However much it may feel like that is the case, the reality is different.
 
The amount of green belt (in net terms) proposed for development is quite small and the housing numbers at 652 are high but our run rate to 2011 since 1931 averages 495 homes per year.  Recent press reports emphasise the pressures on our population numbers and the Government is trying to deal with a current housing shortage.
 
The approach has been wrong.  Perhaps some of the sites proposed are wrong.  The mathematics seem to be inexplicably wrong. The evidence base is a poor starting point for some fundamental changes to our spatial planning.  These are all good reasons to respond robustly to the Local Plan Consultation.
 
On the other hand, there are some major spatial planning issues that really need addressing:
 
We have (in this generally wealthy borough) thirteen LSOAs in the poorest 50% in the country and one in the poorest 25% nationally under the Multiple Deprivation Index.  This in itself seems like a small local area to work on but drilling down into details tells a different story. 
 
  • We have several areas in the most deprived 5% in the country for access to housing and services.
  • We have one particular area where, even in this generally well-educated borough, we are in the poorest 2.5% in the county for young person’s education and skills.
  • We have some wild extremes of performance across the borough in many of the other deprivation domains
 
Alongside this challenging set of statistics, we know our infrastructure has lacked meaningful investment for decades.
 
Guildford, as a second tier authority, cannot solve many of these issues alone – there needs to be a shadow unitary authority to actually get things done – but it can lay the groundwork by allocating land for solutions and delivering real vision and leadership through the Local Plan.  
 
There are many other issues that the Local Plan should seek to resolve.  Many of these issues will require major investment and, absent contributions from Government, we will need developments to help finance some of these solutions.
 
My experience tells me that small-scale developments will not fund such deficits and so, from the data I have examined rather than from reading the evidence base, I am persuaded that we need to think bigger than nibbling at the edges or pulling up the drawbridge.
 
Looking at the town centre again, we do need more people living in the town centre but we need them and the current residents to have better access to a great outdoor environment – designed for living in, not requiring a constant fight with traffic to get from A to B, without having to breathe in pollutants from traffic sitting in queues belching exhaust fumes into the air.  Town centre homes can reduce the pressure on the green belt but preserving one environment (green belt) whilst destroying another (Guildford Urban Area) would not be sustainable.
 

I do not think the Local Plan has got it right and the Guildford Society will be responding robustly.

 
Despite the personalisation of the public responses – born out of understandable frustration but, in my view, quite misdirected – I do believe that Cllr Mansbridge is the kind of leader who can make a difference.  We have two specific tasks in the next three weeks and thereafter:
 
  • submit our objective responses to the Draft Plan, the Town Centre Vision (Oh, yes, and the Habitats consultation and the upcoming Surrey County Council Transport consultation); and
  • follow up to ensure our respective comments are noted and reflected in the next iteration.
I hope we will finish up with a Local Plan that gets to grips with the issues, seizes the right opportunities and leaves the majority of the borough intact.  To paraphrase Cllr Mansbridge’s recent statement:
 
IN ORDER FOR MUCH OF THE BOROUGH TO STAY PRETTY MUCH THE SAME, SOME THINGS WILL HAVE TO CHANGE, and the Local Plan is about making those changes in the least impactful way.

How Many New Homes?

Conspicuous by its absence on the Guildford Local Plan Microsite but, nevertheless, a key component of the Local Plan consultation is the Council’s document “How Many New Homes?”

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

A commentary on this document will follow on this site in due course but in the meantime, a copy of the document as it stands at 30th September 2013 is attached here – 20130930_HowManyNewHomes

The first glance at this will lead to some sharp intakes of breath – housing numbers are anything from  3,620 to 23,446 homes over the Plan period (181 to 1,066 per year).  This paper will need very careful analysis because the implications are likely to be monumental for Guildford.

The Guildford Urban Area is likely to have to take the majority of the residential development.  It has a population of circa 77,000 and at 2.43 people per dwelling (GBC average) this suggests there are around 31,700 households in the urban area.  Now look again at the suggested high end number and consider the impact on the town and its surroundings.

These documents really needed to come with a major health warning if we are to have a serious principled debate and to avoid a local revolt against the Local Plan process and those steering it.

More to follow!

The reading fest begins

Guildford Borough Council has published the first clutch of documents to form the EVIDENCE BASE for the Local Plan for Guildford Borough.

The first document is the Guildford Economic Strategy Report 2013 which sets out to highlight opportunity and threat in the local economy.  This report was presented to and adopted by the Council Executive Committee on 18th July 2013.

There is a consultation expiring on 26th July 2013 into the Methodology of assessment of Traveller Housing Sites (Traveller Strategic Housing Allocation – Consultation Draft).

There is an ABSOLUTELY KEY draft document for consultation, namely the Infrastructure Baseline.

The next two drafts to be adopted into the Local plan process are related to the hierarchy of Settlements:

Guildford Borough Settlement Hierarchy-Evidence and

Guildford Borough Settlement Profiles

Each of these documents represents the start of a long process of evaluation of evidence before the publication of the Issues and Options consultation in the autumn.