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:

0_20180510_GSoc-EIP-Submission-LETTER
(cover letter)

1_20180510_GSoc-EIP-Submission-MAIN
(main document)

2_20180510_GSoc-EIP-Submission-APPENDIX1
(GSoc SANG Paper by Alderman Bridger)

3_20180510_GSoc-EIP-Submission-APPENDIX2
(GSoc Infrastructure Topic Paper by the Transport Group)

4_20180510_GSoc-EIP-Submission-APPENDIX3a
(Correspondence requesting confirmation from GBC on which if any groups were excluded from interacting with officers at the Council)

5_20180510_GSoc-EIP-Submission-APPENDIX3b
(copy of internal email instruction to officers to not engage with the Guildford Vision Group)

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)

7_20180510_GSoc-EIP-Submission-APPENDIX4b
(Guildford Borough Council response on Dunsfold showing an increase of traffic on the gyratory of circa 300 cars over the three peak hours)

8_20180510_GSoc-EIP-Submission-APPENDIX5
(Agreed Statement of Common Ground with the Guildford Vision Group – highlighting GSoc’s support for the GVG Master Plan)

9_20180510_GSoc-EIP-Submission-APPENDIX5-1
(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:

20180331_LocalPLanCommentary_FINAL

 

 

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.

Guildford 5-yr Housing Strategy

Guildford Borough Council has launched its five-year housing strategy consultation (ends 16th December 2014)

A link to the consultation page is here and the documents are attached below:

Draft_Local_Plan_consultation_questionnaire_and_monitoring_form

Hsg_Strat_2015-20_DRAFT_Appendix_1_-_General_statistics_Nov14

Hsg_Strat_2015-20_DRAFT_Appendix_2_-_Updated_guidance_on_rents_and_affordability_Nov14

Hsg_Strat_2015-20_DRAFT_Appendix_3_-_Affordable_housing_stock_in_the_borough_Nov14

Hsg_Strat_2015-20_DRAFT_Appendix_4_-_Rural_housing_needs_surveys_Nov14

Other documents referred to are:

Housing_Needs_Assessment_Report

Housing_Strategy_Interim_Statement

Homelessness_Strategy_2013_-_2018

There is perhaps some irony that the Lead Member for housing, Cllr Sarah Creedy, sets great store by the ambition to “maximise the proportion of affordable housing” provided, and yet the development company she owns with her husband was apparently unable to provide a commitment to a single affordable unit in a conversion to nine flats of a building in Central Guildford.  It may be we are not in possession  of all of the facts but here was an opportunity for Cllr Creedy to commit to, say, one of the homes being rented out at 80% of market rent or sold on an equity share basis without substantially diluting their return.

Aim 1.8 sets out the following: “Ensure that the mix of new affordable homes on any development is appropriate for the proposed locality taking account of the existing supply and local need

Of signifcant interest in the Local Plan process is the section on HMOs (Houses in Multiple Occupation) on page 36 of the main document:

“Houses in Multiple Occupation
Houses in Multiple Occupation (HMOs) or shared houses provide flexible accommodation for a range of households within the private rented sector. They comprise a significant part of the private rented market in Guildford.
We carried out a mapping exercise in 2011 to identify the extent of HMOs. This indicated that there were approximately 2521 in the borough, of which 1417 were in the Guildford town wards of Friary and St Nicolas, Westborough and Onslow. Moreover, there are likely to be many more HMOs created in the borough since then, due to the introduction of permitted planning rights in 2010. These rights allow a change of use of a house or flat from being occupied by a single household to a HMO for between 2-6 people.
The necessity for HMOs is accepted as an inevitable result of the lack of housing, house prices within the town, and the popular and expanding higher education institutions. While there is often an assumption that HMOs in Guildford are lived in by students, this is often not the case.
Many young professionals who are unable to afford to live in the town without sharing occupy HMOs. For some tenants it is the accommodation of choice. Furthermore, the cost of transport from outside the borough can outweigh rental costs so many people who live in HMOs are working in the Guildford area to avoid commuter journeys, or because of the close proximity to the borough’s rail stations.
The expansion of the private rented sector and HMOs in particular has given rise a number of perceived issues which are affecting residents.
They are the impact of having a high concentration of HMOs in parts of the town can contribute to:
 Poor housing standards in HMOs and non-compliance with housing standards
 Poor neighbourhood relations, including antisocial behaviour
 Nuisance from noise, rubbish and parking

The aspirations in the document (from a cursory read) do not seem misplaced but it is important to recognise that this is a key opportunity to ensure that one of the principal inputs to the Local Plan (demand side) has been reviewed.

As always we welcome comments and feedback.

 

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!

Green Belt and Housing Land Allocation

On 30th July the Council published the next suite of documents in its Evidence Base ahead of the Issues and Options Consultation in the Autumn.

Green Belt and Countryside

The first set of documents relate to the Green Belt and Countryside (GBC’s microsite is here).

The study currently consists of:

  • Summary document – overview of the study
  • Volume I – summary, introduction and background to the study
  • Volume II – Green Belt and ‘Countryside beyond the Green Belt’ within the surroundings of the urban areas at Guildford, Ash and Tongham
  • Volume III – Green Belt surrounding villages across the borough
  • Volume IV – insetting of villages from the Green Belt.

At publication, the documents under this section are:

Summary document

Volume I plus Appendix I and II

Volume II plus Appendix IV

Volume II Appendix III

Volume III plus Appendix V, VII

Volume III Appendix VI

Volume IV plus Appendix VIII

Maps

To help you to easily find summary information, there are two separate maps which show:

Strategic Housing Land Allocation

The second and VITAL document released on 31st July was the Strategic Housing land Avilability Assessment (GBC’s microsite is here)

This includes a single (large) document:

20130731_StrategicHousingLandAvailabilityAssessment (27Mb)

Both of these documents will be analysed and comments will be posted on a separate Post in due course.