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

 

 

Summary of Local Areas

Having criticised the absence of core data for individual areas in the Borough, here is a summary of the demographics and multiple deprivation indices for each so-called Lower Super Output Area across the Borough.

The file is around 20Mb but it does contain a lot of data!

20140831_LandUses-MSOA-LSOA

The Guildford Society will be including it as part of its response to the Draft Local Plan.

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!

Guildford Borough Settlement Profiles

WORK IN PROGRESS

Introduction

This draft analysis is based upon GBC Draft Settlement Profiles and it aims to ensure the picture being painted of each settlement is as complete as possible.  The Profiles Report should explain some of the pressures on infrastructure, whilst differentiating between historic qualities of original hamlets, villages and towns and the communities that have grown up around them (largely during the twentieth century).  The links, the spaces and the surroundings are also critical elements.

In recognition that the entire Borough will be called upon to find a substantial number of housing sites across its area during the Local LPan period, this analysis seeks (without fear or favour) to prompt a review by each community to consider how it might be affected by extension – both favourably and unfavourably.  For example, a settlement such as Gomshall notes that it “is adequately served, with some appropriate facilities, but there are concerns that the bus, post office and village shop are underused and the village club is just surviving” (my emphasis).  This seems as though it should prompt analysis by the community as to how much additional development might enable the community facilities to thrive without adversely affecting the character, setting and even scale of the settlement.

Where major settlement changes would occur by the extension of the settlement or the loss of facilities, the residents should be actively encouraged to engage in a proactive debate and feed their comments, issues and options into the first major consultation on the Local Plan in the autumn.

There are also tight green belt restrictions around many of the settlements.  The green belt boundaries were drawn to prevent spread, sprawl and convergence of settlements.  There will inevitably be cause to reassess the green belt boundaries (and these will probably come within a specific green belt paper as part of the evidence base.  Any changes suggested to the green belt boundary under the Local Plan – and especially arising from consideration of each and every settlement – should be designed to be a permanent realignment and not part of a progressive or ongoing expansion of an inconvenient boundary.  Each settlement should view its own area in its wider context – and particularly taking account of the responses and aspirations of its neighbouring settlements.

Taking into account global planning practices and applying local knowledge and emotion, the Local Plan should identify:

  • Settlement centres and latent centres;
  • Places that need repair;
  • The way in which and extent to which the wholeness of a settlement is faltering or defective;
  • How to build or reinforce a neighbourhood or settlement so as to repair and heal the land and/or community.

This means that the Local Plan process should embrace at its heart the aim always to make the place better than it is at present. This may be obvious, if we are dealing with a part of the town in need of regeneration; but an extraordinary aim if we are faced with a place of great natural beauty. Yet there, too, we must make our target and our determination that when all is said and done, it will be more beautiful, and even better than it is today. (paraphrased from www.livingneighborhoods.org)

The ethos and approach above was embraced in the first two phases of a development outside Bishops Castle in Shropshire called The Wintles where the driver behind this high quality neighbourhood-based eco-friendly development was The Living Village Trust.  The emphasis there is on quality rather than profit and this principle is included here since we have high land values in our part of the country which might attract development in the wrong places, encouraged by a highly profitable change of land use.  Guildford Borough should be setting the highest standards for its settlements, and each infilling or extension scheme (or even any new settlement) should require similar principles to be adopted, whereby the extension is of a character and quality as good or better than the acknowledged heart of the original settlement.

The onus should be on land-owners and developers to give back a significant portion of windfall profit from gaining a planning consent for a change of designation from, say, agricultural to residential uses, and this should be enshrined in the planning policies promoted under the Local Plan.

The Profile Report

The Settlement Profile Report goes a little way towards identifying characteristics, but it does not explicitly lay down the gauntlet to the communities to identify development sites nor to look for qualitative tests in future planning policy that will protect and enhance their communities.  It does not give any indication for each settlement how to add to the built environment in a way that also enriches the settlement.  It does not call for the connections and infrastructure that will enable each neighbourhood and settlement to thrive.

In general, the Settlement Profile Report is somewhat static in nature and does not give enough of a flavour of how life operates in the settlements.  For example, the report highlights where services are provided in the settlement and where they are missing.  It does not consider where the nearest available (alternative) facilities are located.  It does not take account of which surrounding settlements rely upon the local amenities and facilities of any particular settlement and, in the case of, say, East Horsley, it refers to the two parades of shops and their related parking  and, rather than setting out how many car parking spaces are available versus need, it meekly notes that “the centre could benefit from some more available spaces“.

There are frequent references to the Thames Basin Heaths Special Protection Area (2009-2014) which will have expired by the time the Local Plan is prepared.  Given that the SPA touches on many settlements in this report, what (if anything) is the likely successor or extension to TBH SPA (2009-2014) expected to alter?

It would be useful to have an overall map of the Borough with the positions of the settlements marked on it (also showing the SPA, Areas of Great Landscape Value and Areas of Outstanding Natural Beauty boundaries) and also a map for each settlement with the settlement boundaries clearly marked.

Each settlement report should indicate the land area within the settlement boundary and typical and/or average dph (dwellings per hectare) figures so as to help understand the character of the settlement or its distinct parts and to ensure the character is not undermined by development which is out of keeping with its surroundings.

Crucially, the Profile Report does not seem to draw on information from the 2011 Census which would identify the population profile (age, gender, ethnicity, etc) for each settlement; nor does it use any of the lifestyle data from the census to underscore the nature of the community with a wider source of comparative data.

In further iterations of the Settlement Profile Report it is to be hoped some of this supplemental information will appear (as it does not emerge from the Draft Infrastructure Baseline Report).

NB: this analyses was largely written before publication of the green belt and Countryside Report and the Strategic Housing Land Availability Assessment.

Taking each village in turn:

Albury

The conclusion drawn is that Albury is a settlement with a village core and a number of outlying hamlets.  The infrastructure is poor because of the dispersal of settlements within Albury.

There is an emphatic statement in the Conclusion “If we were to remove the settlement boundary within the new Local plan then we would remove the scope for future infill development.”  This does not seem to be a wholly logical statement to a non-planner and the differnce between Green belt Villages with or without settlement boundaries needs explanation – probably in the introduction.

Perhaps the choice that the remaining text highlights is ‘Do we look for a suitable  site for limited extension of the village – to help make better infrastructure and facilities viable and to bring forward affordable housing – or should we assume there will be limited growth through periodic infilling?’  If the latter, how do we ensure that sufficient affordable housing comes forward to suit the identified needs of the community?

The references to the views into and from Albury and the characteristic of its woodland and open pasture mix should help to ensure that only suitable sites can be brought forward.  A range of qualitative requirements (and the Community Infrastructure Levy of which 25% would go to the Parish) should ensure that there is not so much windfall value in speculatively promoting unsustainable or undesirable sites.

Ash & Tongham Urban Area

In the section on Retail Facilities, there is reference to car parking for 29 cars.  This does not indicate whether the provision is too little, about sufficient or generous.  For the purposes of understanding the capacity for the local infrastructure to cope with fresh development, these kinds of information would be very important.

Ash & Tongham is close to the Local Authority boundary with Rushmoor and care should be taken to understand what (if any) impact there might be as a result of the Duty to Co-operate set out in NPPF.

The conclusion that Ash & Tongham “could support a level of development in the future which exceeds that of any of the Borough’s other settlements with the exception of Guildford urban area” seems to be made without reference to opportunities and risks of such expansion, nor on the basis of any assessment of CAPACITY.  This is not to say the assessment is wrong, but that it does not logically arise from the information provided.  How well are the local businesses trading, for example, and what level of development can help to ensure or enable the medium to long term viability of those businesses.

Ash Green

There is a hint of potential major development between Ash Green and Ash & Tongham, noting that “this strategic matter will be addressed in the Local plan Strategy and Sites document”.  The Settlement Profile Report should consider the scale of development that might be required to raise the village from ‘Fair’ to ‘Good’ and the implications on the village character if the settlements of Ash Green and Ash & Tongham were to merge or infill.

Chilworth

The description of Chilworth as “an urban character without a core and with very limited opportunity for infilling, constrained by the railway which cuts it in half and the green belt boundary which is drawn very tightly” suggests that there is no scope for development.

There is an apparent conflict, however, between statements in the sections ‘How well the village works’ and the ‘Conclusion’ namely and respectively: “The village is poorly served, with a lack of appropriate facilities…” and “Chilworth has a number of key community services and facilities which makes it one of the more sustainable villages”

Perhaps the choices that the remaining text highlights are ‘Do we (a) look for a suitable  site for limited extension of the village – to help make better infrastructure and facilities viable and to bring forward affordable housing; (b) consider the potential to redraw the green belt boundaries to enable high quality development that brings a more cohesive connected community with a more conventional mass and provides key local community amenities at the heart of the settlement; or (c) should we assume there will be limited growth through periodic infilling?’  If the latter, how do we ensure that sufficient affordable housing comes forward to suit the identified needs of the community?

The characteristic of its woodland and open pasture surroundings set against the downs should help to ensure that only suitable development can be brought forward.  A range of qualitative requirements (and the Community Infrastructure Levy of which 25% would go the Parish) should ensure that there is not so much windfall value in speculatively promoting unsustainable or undesirable sites.

Compton

This green belt village has a significant number of listed buildings (around 9%) and is mostly within a conservation area.  It has traffic from the A3 cutting through it and could be affected by alterations to the A3 around Guildford (improvements may encourage more traffic from the South to access the A3 through Compton, and suitable mitigation strategies may be required alongside any such proposals in the Local Plan).

Compton abuts the Local Authority boundary with Waverley and, care should be taken to understand what (if any) impact there might be as a result of the Duty to Co-operate set out in NPPF.

Compton does not have convenience shops but is served by bus services.  The conclusion in the draft is that “it is not a sustainable location for an extension” but perhaps the report should offer alternatives for residents to consider ‘Do we (a) look for a suitable  site for limited extension of the village – to help make better infrastructure and facilities viable and to bring forward affordable housing; (b) consider the potential to redraw the green belt boundaries to enable high quality development that brings a more cohesive connected community with a more conventional mass and provides key local community amenities at the heart of the settlement; or (c) should we assume there will be limited growth through periodic infilling?’  If the latter, how do we ensure that sufficient affordable housing comes forward to suit the identified needs of the community?

East Clandon

This green belt village has a significant number of listed buildings (around 45%) and is mostly within a conservation area.  The village is an ancient settlement clustered around the church, pub and village hall just off the A246 Epsom Road.

There seems to be a contradiction where, under ‘Community Services’, the text says “the settlement is also lacking key community facilities and services such as a doctor’s surgery, a post office or any shopping facilities” and under ‘How Well the Village Works’ the text says “The village is reasonably served with facilities but access is minimal”.

There are two options considered for East Clandon, whereas perhaps a third option might be to look for a suitable  site for limited extension of the village – to help make better infrastructure and facilities viable and to bring forward affordable housing.  Clearly this would be difficult to achieve and  an extensive range of qualitative requirements (and the Community Infrastructure Levy of which 25% would go the Parish) should ensure that there is not so much windfall value in speculatively promoting unsustainable or undesirable sites.

East Horsley

East Horsley is a large and relatively populous settlement.  The report notes that “the only service the settlement lacks is a secondary school” but the report does not indicate whether this is an aspiration or if the residents are happy to frequent nearby schools in Effingham.  Equally, the report does not indicate how East Horsely’s population measures up to justifying having one.  This should probably cross reference (or be cross-referenced with) the Infrastructure Baseline.

The report discusses the two local centres but does not provide a count of shop units, numbers of parking spaces or even provide qualitative data on the viability of the shops.  Equally, there is no indication as to whether the customers for those facilities are drawn from the settlement or from further afield (see comments on Effingham, Ockham and West Horsley, for example).

The conclusion states that “if suitable sites are found within this area it could support additional housing development in the future”.  Given the relatively low number of buses, and the availability of train services from two stations and local shopping in two centres, the focus for any new development should perhaps be around the station(s) and/or close to the local facilities so as to limit or avoid incursions into the green belt, but a significant high quality extension could be considered with a once and for all change to green belt boundaries if it can be shown that the character of the settlement and its sustainability would not be impaired by such extension.  Clearly this would be difficult to achieve and  an extensive range of qualitative requirements (and the Community Infrastructure Levy of which 25% would go the Parish) should ensure that there is not so much windfall value in speculatively promoting unsustainable or undesirable sites.

Effingham

Effingham is located close to the Local Authority Boundary with Mole Valley and care should be taken to understand what (if any) impact there might be as a result of the Duty to Co-operate set out in NPPF.

The proximity of Effingham to East Horsley, and the presence in each centre of facilities for the residents, suggest that analysis should be undertaken as to whether there could be infilling between communities.  This might allow a more cohesive view of community transport, facilities and amenities – especially as the village economy “is not seen as being particularly thriving”.

The conclusion notes that “Effingham is one of the largest villages in the borough and contains a number of key services and as such if suitable sites are found within this area it could support additional housing development in the future through an extension and a rural exception site to provide affordable homes for local people.”  Clearly this would be difficult to achieve and  an extensive range of qualitative requirements (and the Community Infrastructure Levy of which 25% would go the Parish) should ensure that there is not so much windfall value in speculatively promoting unsustainable or undesirable sites.

Fairlands

There is reference to Fairlands suffering from flooding in various locations but there is no indication whether this is fluvial or pluvial.

The conclusion states that “if suitable sites are found within this area it could support additional housing development in the future”.  The focus for any new development should perhaps be close to the local facilities so as to limit or avoid incursions into the green belt, but a significant high quality extension could be considered with a once and for all change to green belt boundaries if it can be shown that the character of the settlement and its sustainability would not be impaired by such extension.  Clearly this would be difficult to achieve and  an extensive range of qualitative requirements (and the Community Infrastructure Levy of which 25% would go the Parish) should ensure that there is not so much windfall value in speculatively promoting unsustainable or undesirable sites.

This view may also be affected by any urban expansion of Guildford towards Fairlands, the potential for a Park Barn station and any northern realignment of the A3.

Gomshall

For a relatively small village settlement, Gomshall is well-served for facilities and amenities.  The report does, however, note that “there are concerns that the bus, post office and village shop are underused and the village club is just surviving” (my emphasis).

The conclusion is then drawn that the village is “not a sustainable location for an extension.”

On the contrary, this would seem to indicate that the village may need extension to make its facilities viable.

Perhaps the choices are ‘Do we (a) look for a suitable  site for limited extension of the village – to help make better infrastructure and facilities viable and to bring forward affordable housing; (b) consider the potential to redraw the green belt boundaries to enable high quality development that helps to ensure key local community amenities at the heart of the settlement remain viable; or (c) should we assume there will be limited growth through periodic infilling?’  If the latter, how do we ensure that sufficient affordable housing comes forward to suit the identified needs of the community?

Clearly any extension would be difficult to achieve and an extensive range of qualitative requirements (and the Community Infrastructure Levy of which 25% would go the Parish) should ensure that there is not so much windfall value in speculatively promoting unsustainable or undesirable sites.

Guildford Urban Area

A population of just over half of the borough living in the Guildford Urban Area ahve been lumped together as one settlement and, collectively, characterised by being the only part of the Borough without parish or town council representation.  For the size and complexity of the Guildford Urban Area, it has a relatively short entry in the Profile Report.

There are so many parts of the Guildford Urban Area whose characters and backgrounds are fundamentally different (as are their issues) and whose facilities and access vary considerably.  No reference is made to the Neighbourhood Area of Burpham, and it might be reasonable to expect that other areas might choose to go down the same neighbourhood planning path.

It seems clear, therefore, that this section should be broken up into the sub-districts which have their own nuclei of facilities and transportation issues.  These should probably be:

  • Town Centre
  • Guildford Park
  • Onslow Village (including Dennisville)
  • Park Barn
  • Rydes Hill
  • Woodbridge Hill
  • Stoughton
  • Stoke
  • Bellfields
  • Slyfield
  • Burpham
  • Merrow
  • Charlotteville
  • Warwicks Bench
  • St Catherines

The section on Character seems to be woefully inadequate.  The Urban Area is dissected also by the River Wey; also poorly connected is the west side of Guildford (including a large proportion of employment and education).

Under Community services and facilities there is an orphaned “Northern”.

Under Retail and Employment, much of this section should cross refer to the Guildford Economic Strategy Report 2013 and the Infrastructure Baseline.  Missing from this settlement report is some indication of the employment levels and where employees typically live – for example, a separate report on Park Barn would highlight some issues with higher than average unemployment.

Under Transport, the settlement report refers to the River Wey as “a transportation route primarily for recreation and tourism purposes”.  This is omitted from the Infrastructure Baseline.  Reference to the A3 should also highlight that it connects the town to the wider motorway network.

In sections 2.2.12-2.2.16 of the Infrastructure Baseline there is no specific mention of the A320 junction at Stoke Crossroads (but there is reference to the general fragile state of the road network at peak hours).  In the Settlement Report it is mentioned that “The Stoke crossroads and junction with the A3 are already at their capacity.  A lack of investment in associated junctions will continue to have an adverse effect on the communities and major businesses operating in the Guildford urban area.”

This analysis – whilst on the one hand differing in content and tone from the Infrastructure Baseline, fails to deal equally with each approach road to the town – all of which have specific and severe issues.  The Farnham Road (A31) for example, has restrictions of weight and is often backed up along its entire length from the Hog’s Back.

The A3 backs up from the A31 to the Burpham turn at evening rush hour, due in large part to vlumes of traffic and a 60m climb from its bridge over the River Wey to the cutting in the Hog’s Back.  This affects the businesses and quality of life and access for a large proportion of the settlement to the north and west.

In the Conclusion, there is the comment that Guildford “could support a level of development which exceeds that of any of the borough’s other settlements”.  This may well be the case and there may be very difficult decisions to be taken about the future of the green belt boundary (note my comments in the introduction).  These decisions should be taken on the basis of a much more detailed settlement assessment having subdivided the area as described above.

A decision, for example, to expand the town from Warwicks Bench would have to take account of a character assessment of that residential settlement whereby it has no immediately local facilities and would necessitate a trip into the town centre – with no bus routes available for public transport.  On the other hand, an extension to Burpham might have good access to local services and facilities and reasonable access to public transport.

There needs to be a comprehensive CAPACITY study for the Guildford Urban Area and each subsidiary settlement to show how the infrastructure (outlined in the Infrastructure Baseline) can be upgraded to accommodate growth since so much of the settlement’s infrastructure is already at or near (or even exceeding) its designed capacity.

In summary, in any event, the focus of development should be town centre first – residential sites like the recently lost Bellerby site should be resisted for non-residential uses.  Where any outward expansion of Guildford is required for a new settlement or a settlement extension, the revised green belt boundary should be drawn so as to represent a new permanent boundary.  Such extensions should probably be planned with a critical mass to enable local services and facilities to be provided or where there are accessible services in existing settlements within easy access.  Clearly any extension would be difficult to achieve and an extensive range of qualitative requirements (and the Community Infrastructure Levy) should ensure that there is not so much windfall value in speculatively promoting unsustainable or undesirable sites.  As there is no Parish Council, it would be important to ensure that an adequate proportion of CIL goes to mitigate local effects of extension and to provide the necessary infrastructure.

Holmbury St Mary

Holmbury St Mary is located close to the Local Authority Boundary with Mole Valley and care should be taken to understand what (if any) impact there might be as a result of the Duty to Co-operate set out in NPPF.

The Report highlights that Holmbury St Mary is poorly designed as a settlement because “there have been too many extensions permitted and there is a need for affordable housing.”  This implies that the settlement is effectively in need of repair and, whilst it is possible that too many extensions of inferior quality have failed to respect the character, fabric and scale of the settlement, that does not mean that a well-designed extension would be unable to heal some of the issues and restore a better quality of community to the settlement. Clearly any extension would be difficult to achieve and an extensive range of qualitative requirements (and the Community Infrastructure Levy, 25% of which would go to the Parish Council for local infrastructure projects) should ensure that there is not so much windfall value in speculatively promoting unsustainable or undesirable sites.

Jacobs Well

The Report (at ‘Character’) notes that “the settlement has an urban character due to its proximity to the urban area of Guildford, at its closest it is 200m away from the norther edge of Slyfield.”

Perhaps, as part of the Local Plan process, there should be consideration given to what would be the merits or harm in closing the 200m gap and infilling the area between Slyfield and Jacobs Well.  Clearly any extension or infilling such as this would be difficult to achieve and an extensive range of qualitative requirements (and the Community Infrastructure Levy, 25% of which would go to the Parish Council for local infrastructure projects) should ensure that there is not so much windfall value in speculatively promoting unsustainable or undesirable sites.

Normandy and Flexford

Whilst the Report puts these together, it is somewhat schizophrenic in its attempts to combine and yet treat these two areas separately.  No such schizophrenia applies to the Report’s treatment of the Guildford Urban Area (see above)!

The Report notes the lack of a convenience shop “which would be of benefit to the local community”.  There is no reference as to the options available for convenience shopping for residents of the two areas.

Perhaps, as part of the Local Plan process, and because the two areas see themselves as one settlement, there should be consideration given to what would be the merits or harm in infilling the area between them, incorporating a convenience store and some of the other missing facilities.  Clearly any infilling such as this would be difficult to achieve and an extensive range of qualitative requirements (and the Community Infrastructure Levy, 25% of which would go to the Parish Council for local infrastructure projects) should ensure that there is not so much windfall value in speculatively promoting unsustainable or undesirable sites.

Ockham

Ockham is located close to the Local Authority Boundary with Mole Valley, and care should be taken to understand what (if any) impact there might be as a result of the Duty to Co-operate set out in NPPF.

Under ‘Transport’ there is reference to a school bus service passing through once a day.  This presumably means once at each end of the day and does not specify which schools it serves, nor whether it meets the needs of the school age children in the community.

The Report does not give any great weight to links between Ockham and East Horsley (recognising it as “the nearest area with services”) and ignores any such links with the larger centre of Ripley. The Report also fails to establish how interaction with such centres works in practice other than to highlight reliance on the private car.

Ockham is around double the size of Holmbury St Mary which, unlike Ockham, has a settlement boundary, and, whilst the Report concludes that Ockham does not have the facilities to support sustainable development, the question should be asked whether it would benefit from a significant extension that made such facilities viable – always assuming a suitable extension could be found.  Perhaps a new settlement on Wisley Airfield might fulfill this purpose and, properly planned and on a significant scale, could provide a new service centre with local shops, etc. Clearly any such extension would be difficult to achieve and an extensive range of qualitative requirements (and the Community Infrastructure Levy, 25% of which would go to the Parish Council for local infrastructure projects) should ensure that there is not so much windfall value in speculatively promoting unsustainable or undesirable sites.

Peaslake

From the description in the Report, the village of Peaslake seems to be settled in a mould whereby there is nothing for young people to do, and nowhere for them to live if they wish to remain in the village to raise their families.  Ordinarily this might be described as a poorly functioning and unsustainable community.

The physical limits and the AoNB designation almost certainly dictate that little scope exists for any substantial development.

On the other hand, as a settlement, Peaslake may well benefit from additional development which could help support services or transport connections. Clearly any such extension would be difficult to achieve and an extensive range of qualitative requirements (and the Community Infrastructure Levy, 25% of which would go to the Parish Council for local infrastructure projects) should ensure that there is not so much windfall value in speculatively promoting unsustainable or undesirable sites.

Peasmarsh

The Report barely acknowledges the existence of Godalming and ignores Farncombe, and yet Peasmarsh sits at the edge of Guildford Borough, close to its Local Authority boundary with Waverley, and reasonably close to Farncombe.

As it is located close to the Local Authority Boundary with Waverley, care should be taken to understand what (if any) impact there might be as a result of the Duty to Co-operate set out in NPPF.

There is some confusion in the ‘Transport’ section about rail connections and destinations: “The nearest train station is Shalford, 1.5km to the north east. This line links Guildford town and London Waterloo and is faster than the direct train from Guildford to London”.  Clearly this requires rewriting.

The Report notes that Peasmarsh contains five of the 12 key community services (with no reference as to where the nearest missing services are to be found), whereas under the section ‘How well the village works’ the text notes that “the village is poorly served with a lack of appropriate facilities”.  These two statements do not appear to be consistent.

Perhaps there has been overzealous use of cutting and pasting in the Report – as demonstrated by the sentences in ‘Conclusion’:

  1. “Peasmarsh is a relatively small settlement and does not contain many key community services or facilities (small village)” This contradicts the earlier comments.
  2. “The closest convenience store is located in East Horsley and due to poor public transport is mainly accessible by the private vehicle” This is patently geographically wrong.

Every settlement should be reviewed to ensure the data is relevant to that settlement and not a misplaced ‘pasting’ of some other settlement’s criteria.

Peasmarsh is characterised as a “suburban village” and yet is treated as a more protected settlement (from infilling or extension) than many others.  The Local Plan process should consider whether it could accommodate any significant development by a well-planned extension that helped bring the missing services or facilities to the settlement.  Clearly any such extension would be difficult to achieve and an extensive range of qualitative requirements (and the Community Infrastructure Levy, 25% of which would go to the Parish Council for local infrastructure projects) should ensure that there is not so much windfall value in speculatively promoting unsustainable or undesirable sites.

Pirbright

This is the only settlement in the Report that lists the total area as well as the number of dwellings, allowing a calculation of average settlement density – there are 565 dwellings in 1906 Hectares. This clearly does not cover the settlement area alone, measuring the density in hectares per dwelling rather than dwellings per hectare!

Pirbright is located close to the Local Authority Boundary with Woking, and care should be taken to understand what (if any) impact there might be as a result of the Duty to Co-operate set out in NPPF.

Under the section ‘Community services …’ (which in this settlement are amalgamated whereas elsewhere they are in separate subheadings) there is an apparent contradiction whereby we have “one comparison shop” and then “comparison shops within the settlement”.

The settlement is characterised by a collection of hamlets and the Local Plan process should consider whether, perhaps, these could accommodate well-designed extensions, drawing on the availability of accessibility and services in the heart of the village. Clearly any such extension would be difficult to achieve and an extensive range of qualitative requirements (and the Community Infrastructure Levy, 25% of which would go to the Parish Council for local infrastructure projects) should ensure that there is not so much windfall value in speculatively promoting unsustainable or undesirable sites.

Puttenham

Puttenham is a poorly served village owing to its lack of a post office or village shop, which forces residents (in the absence of buses) to go by car to Guildford or Godalming.

Perhaps the Local Plan process should consider an expansion on the east side (protecting the historic heart of the village) on the other side of the main road with traffic calming and with a village centre that could provide the facilities and services that are so lacking.  This could be designed as a high quality rural settlement and would require the redrawing of the Green Belt boundary.  This needs also to respect the Area of Great Landscape Value.  Clearly any such extension would be difficult to achieve and an extensive range of qualitative requirements (and the Community Infrastructure Levy, 25% of which would go to the Parish Council for local infrastructure projects) should ensure that there is not so much windfall value in speculatively promoting unsustainable or undesirable sites.

Ripley

Ripley is located close to the Local Authority Boundaries with both Woking and Mole Valley, and care should be taken to understand what (if any) impact there might be as a result of the Duty to Co-operate set out in NPPF.

Ripley is affected by the way the A3 bypassed it and by the single direction junctions at each end which drives traffic through the settlement.  on the one hand this may be a good way to ensure the village is visited and thrives; on the other hand, the through traffic may adversely affect the character of the settlement itself.

Under ‘Conclusion’ the Report should encourage consideration as to whether a significant high quality extension could be accommodated without adversely affecting the character and “market town” feel of Ripley as a settlement. Clearly any such extension would be difficult to achieve and an extensive range of qualitative requirements (and the Community Infrastructure Levy, 25% of which would go to the Parish Council for local infrastructure projects) should ensure that there is not so much windfall value in speculatively promoting unsustainable or undesirable sites.

Seale and The Sands

Under the heading ‘Form’, the final sentence “…and consists of low density” does not quite make sense.

Seale and The Sands are located close to the Local Authority Boundary with Waverley, and care should be taken to understand what (if any) impact there might be as a result of the Duty to Co-operate set out in NPPF.

The Report does not venture to suggest where (and how far away) residents have to go to reach the nearest facilities that these areas do not provide.

Seale and The Sands may well benefit from additional development which could help support services or transport connections. Clearly any such extension would be difficult to achieve and an extensive range of qualitative requirements (and the Community Infrastructure Levy, 25% of which would go to the Parish Council for local infrastructure projects) should ensure that there is not so much windfall value in speculatively promoting unsustainable or undesirable sites.

Send

Send is located close to the Local Authority Boundary with Woking, and care should be taken to understand what (if any) impact there might be as a result of the Duty to Co-operate set out in NPPF.

Despite its proximity to Ripley, Send is described (under ‘Transport’): “despite its size, there is a limited bus service that runs through the settlement between Woking and Guildford town.”

The Local Plan process should consider whether it could accommodate any significant development by a well-planned extension that helped bring better transport services to the settlement or improve the viability of the local facilities.  Clearly any such extension would be difficult to achieve and an extensive range of qualitative requirements (and the Community Infrastructure Levy, 25% of which would go to the Parish Council for local infrastructure projects) should ensure that there is not so much windfall value in speculatively promoting unsustainable or undesirable sites.

Send Marsh/Burntcommon

Send Marsh is located close to the Local Authority Boundary with Woking, and care should be taken to understand what (if any) impact there might be as a result of the Duty to Co-operate set out in NPPF.

Under ‘Character’ there is reference to the slip road from the A3 leading nito the settlement. It should perhaps be noted that this only feeds from the northbound carriageway of the A3.

Whereas Send is described as semi-rural, Send Marsh is described as having a “suburban character”, and under ‘Transport’ the bus service which in Send is described as ‘limited’ is considered to be ‘reasonable’. Under ‘how well the village works’, however, the Report says: “Send Marsh scores very poorly as public transport is very limited“.

The Local Plan process should consider whether it could accommodate any significant development by a well-planned extension to help bring better transport services to the settlement and to develop the village economy which “is not seen as being particularly thriving”.  Clearly any such extension would be difficult to achieve and an extensive range of qualitative requirements (and the Community Infrastructure Levy, 25% of which would go to the Parish Council for local infrastructure projects) should ensure that there is not so much windfall value in speculatively promoting unsustainable or undesirable sites.

Shackleford

Shackleford is located close to the Local Authority Boundary with Waverley, and care should be taken to understand what (if any) impact there might be as a result of the Duty to Co-operate set out in NPPF.

The Report notes that Shackleford Parish Council has recently completed a rural housing needs survey – and yet it does not give any indication as to what the survey found.  This seems to be an unfortunate omission.

The Report – as described earlier – is a static summariser of dynamic communities.  The ‘Conclusion’ notes that “Shackleford contains a very few community services and facilities (loose knit/hamlet) and as such is not a sustainable location for additional development.”

On the contrary, the Local Plan process should question the viability of local shops and a post office if there is no growth – the risk from internet shopping and from surrounding towns and villages will put increasing pressure on them.  Consequently, the Report should consider the economic argument for exxtending the settlement with high quality, complementary development in keeping with the character and scale of the existing properties.  This would require a rethinking of the Green Belt boundaries and this should be designed to meet future needs once and for all.  Clearly any such extension would be difficult to achieve and an extensive range of qualitative requirements (and the Community Infrastructure Levy, 25% of which would go to the Parish Council for local infrastructure projects) should ensure that there is not so much windfall value in speculatively promoting unsustainable or undesirable sites.

Shalford

Despite its size (and perhaps due to its proximity to Guildford or Waitrose in Godalming) Shalford has a medium-sized local centre but no convenience or grocery store.  This factor means that Shalford scores only 20 out of 40 – the same as Albury.  this suggests a substantial underperformance in Shalford relative to expectations.

The Local Plan process should consider whether Shalford and surroundings could accommodate any significant development by a well-planned extension to help to develop the village economy which “is not seen as being particularly thriving” and to provide the scope for a convenience store.  Clearly any such extension would be difficult to achieve and an extensive range of qualitative requirements (and the Community Infrastructure Levy, 25% of which would go to the Parish Council for local infrastructure projects) should ensure that there is not so much windfall value in speculatively promoting unsustainable or undesirable sites.

Shere

Shere is an important village with a heritage celebrated internationally through its use as a backdrop in films and its ‘chocolate-box’ village centre.

Whilst there is no designation above a Conservation Area, Guildford should, perhaps think in terms of establishing a ‘Local heritage’ designation whereby street-scenes are treated as if they are listed.  Views into and out of the village will be of great importance as well.

Under ‘Transport’ the report notes that “Shere has a good bus service”, whereas at ‘how well the village works’ “Shere scores poorly as public transport is limited”.  Such contradictions are not helpful in assessing the needs of the village.

Under ‘Conclusion’ the text notes that “development is limited to infilling…” and that  “if a suitable site can be found, there is scope for a rural; exception site to provide affordable homes for local people”.

These references should be heavily qualified in respect of Shere to the extent that infilling or a rural exception site should respect the heritage qualities and visitor attraction of the village centre, and this should mean that there should be an exceptionally high threshold for quality design in keeping with the historic settlement.

On the other hand, the Local Plan process should consider whether Shere and surroundings could accommodate any significant development by a well-planned extension to help to develop the village economy which “is not seen as being particularly thriving”, which itself would help to preserve the character and vitality of the village.  Clearly any such extension would be difficult to achieve and an extensive range of qualitative requirements (and the Community Infrastructure Levy, 25% of which would go to the Parish Council for local infrastructure projects) should ensure that there is not so much windfall value in speculatively promoting unsustainable or undesirable sites.

Wanborough

Wanborough is close to the settlement of Flexford (reported alongside Normandy as being regarded as a single settlement).

The proximity of Wanborough to Flexford should be taken into account when considering whether there could be any extension to the settlement and it should probably be the case that this should only happen between these two villages.  Clearly any such extension would be difficult to achieve and an extensive range of qualitative requirements (and the Community Infrastructure Levy, 25% of which would go to the Parish Council for local infrastructure projects) should ensure that there is not so much windfall value in speculatively promoting unsustainable or undesirable sites.

West Clandon (North and South)

The two parts of West Clandon are separated by the railway (one road bridge links the two).  This should be noted as a severed community in the context of the Infrastructure Baseline.  Equally, the station at West Clandon could be treated as more of a village hub and could be regenerated to provide local convenience shopping – identified as lacking in the Settlement Profile Report.

There is an extraordinary statement in the report to the extent that “West Clandon scores poorly as public transport is limited to travelling by train to either Guildford town or London”.  This would seem like a well-connected settlement by many yardsticks.  Perhaps there needs to be a greater availability of low-cost tickets between Clandon and Guildford (London Road) so as to enable the connection to work better but not so as to increase any passenger burden on Guildford mainline station.

The report concludes (among other things) that “this raises the question as to whether an extension to the village could enable service improvements through future mixed use development and improve access to key services for local residents.”

Indeed, the Local Plan process should consider whether West Clandon could accommodate any significant development by a well-planned extension to help to introduce the missing facilities and to develop the village economy which “is not seen as being particularly thriving”.  Clearly any such extension would be difficult to achieve and an extensive range of qualitative requirements (and the Community Infrastructure Levy, 25% of which would go to the Parish Council for local infrastructure projects) should ensure that there is not so much windfall value in speculatively promoting unsustainable or undesirable sites.

West Horsley (North and South)

The two parts of West Horsley are separated by the railway (two road bridges link the two).  This should be noted as a severed community in the context of the Infrastructure Baseline, but unlike West Clandon, it does not benefit from the station – the nearest being at East Horsley.

The Report notes that East Horsely and West Horsely parish councils recently completed a joint rural housing needs survey.  The authors do not see fit, however, to set out the perceived requirement in this Report.

The Report does consider West Horsley to be “the most sustainable rural settlement in the Borough” and highlights the potential to support additional housing development in the future. Clearly any such extension would be difficult to achieve and an extensive range of qualitative requirements (and the Community Infrastructure Levy, 25% of which would go to the Parish Council for local infrastructure projects) should ensure that there is not so much windfall value in speculatively promoting unsustainable or undesirable sites.

Wood Street Village

Wood Street is located “just to the west of Guildford” and could be somewhat affected by an extension of the Guildford Urban Area on its western reaches.  The village works well, scoring highly despite having public transport “so poor that residents have to rely on the private car”.

There may well be scope for a significant extension and could be linked to rail services if Park Barn Station were to become a reality.  Clearly any such extension would be difficult to achieve and an extensive range of qualitative requirements (and the Community Infrastructure Levy, 25% of which would go to the Parish Council for local infrastructure projects) should ensure that there is not so much windfall value in speculatively promoting unsustainable or undesirable sites.

Worplesdon

Worplesdon is located close to the Local Authority Boundary with Woking, and care should be taken to understand what (if any) impact there might be as a result of the Duty to Co-operate set out in NPPF.

The Report highlights that “there is a poor bus service that serves the settlement”.  Perhaps the Council should consider whether a Park & Ride facility with a combined bus service could improve this situation.

The Report notes that Worplesdon parish council recently completed a joint rural housing needs survey.  The authors do not see fit, however, to set out the perceived requirement in this Report.

Worplesdon is identified as a settlement which would support potential extension. Clearly any such extension would be difficult to achieve and an extensive range of qualitative requirements (and the Community Infrastructure Levy, 25% of which would go to the Parish Council for local infrastructure projects) should ensure that there is not so much windfall value in speculatively promoting unsustainable or undesirable sites.

Conclusion

Having been through the document carefully, there are clearly some contradictions and some glaring ‘cut and paste’ errors.  It is important that these are ironed out before the Local plan is developed from a compromised baseline.

The main concern about the Settlement Profile Report is the treatment of the Guildford Urban Area as one amorphous settlement. That is not only plainly wrong, it also misses a clear opportunity to look at the impact of extensions to subdivisions of Guildford which the Strategic Housing Land Availability Assessment seeks to do.  It also means that a close focus on the separate issue of Guildford Town centre and on each of its surrounding suburban settlements is much harder to achieve.

This shortcoming also, therefore, fails to note the establishment of the Burpham Neighbourhood Forum.

 

Draft response to Infrastructure Baseline

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:

201302_SCC-CongestionReport-Fig5-2011 201302_SCC-CongestionReport-Fig5-2026 201302_SCC-CongestionReport-Fig7

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).

201302_SCC-CongestionReport-Fig2_2012-2031  

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:

201302_SCC-CongestionReport-Table4-2001

 

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.

SUMMARY

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:

TrafficLight-failing  Red – at or exceeding capacity

TrafficLight-nearingcapacity  Amber – approaching capacity

TrafficLight-workingwell  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.

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.

Local Plan Evidence Base

Guildford’s Local Plan process is at a very early stage and it all begins with a comprehensive integrated up-to-date evidence base.

Guildford’s Evidence Base can be found here.

The Local Plan should PROTEC T and ENHANCE the things we value, help RESOLVE urban planning issues that we have and ENABLE and PROVIDE for LOCALLY SUSTAINABLE GROWTH.

The Evidence Base should provide a BASELINE which, taken together, can establish CAPACITY assuming nothing is done.

The Evidence Base and Local Plan Issues and Options Consultation should identify what NEEDS to be done to facilitate additional capacity.

The Local Plan itself should then provide the framework and mechanisms to DELIVER locally sustainable growth whilst resolving issues and protecting and enhancing existing treasures.

The key to the early part of this process – even before the issues and options consultation – will be to understand the constraints on capacity (such as infrastructure, topography, green belt boundaries, etc)

This site will aim to provide an additional source of information and comment, but not to replace or compete with the official Guildford Borough Council Local Plan page.

The beginning of a long journey

This blog site will be used to track and comment on the Local Plan process for Guildford.  It is not intended to be comprehensive but simply aims to provide an opportunity for people of Guildford to access key documents and monitor progress.

The site is NOT a substitute for visiting the Guildford Borough Council website (www.guildford.gov.uk)