WORK IN PROGRESS
(3rd August 2013)
The Green Belt and Countryside Study sets out to “determine appropriate Potential Development Areas (PDAs) for future housing and other growth requirements if suitable land cannot be identified within built-up areas.” The Summary document sets out to provide background to the instruction from Guildford Borough Council to Pegasus Planning Group – which evolved over several years – and to illustrate how the four component volumes of the evidence base relate to each other. The Study has assessed specific parcels of land in relation to Green Belt planning policy, sustainability criteria and environmental capacity to determine appropriate areas for future development within the Borough. The Study has examined land across the Borough within Volumes I, II, III and IV as follows:
Volume I – Summary, Introduction and Background to the Study
Section 1 provides a Non-technical Summary of the Study. Section 2 provides an Introduction, including an overview of the purpose and scope of the Study. Section 3 provides a Review of Previous Green Belt Studies, and an evaluation of methodologies undertaken for other districts. Section 4 provides a Planning Policy Review, and the planning context within which the Study has been undertaken. Section 5 outlines the Role and Purpose of the Green Belt within Guildford Borough. Section 6 outlines the Green Belt and Countryside Methodologies used for assessing land within the surroundings of urban areas and for villages across the Borough.
Volume II – Land surrounding the Urban Areas of Guildford, Ash and Tongham Section 7 details the Methodology for Assessing Green Belt and ‘Countryside beyond the Green Belt’ within the surroundings of Urban Areas at Guildford, Ash and Tongham. Section 8 outlines the Study Findings for assessing Green Belt and Countryside beyond the Green Belt surrounding the Urban Areas of Guildford, Ash and Tongham. Section 9 details the Conclusions for Volume II.
Volume III – Land surrounding Villages across the Borough Section 10 details the Methodology for Assessing Green Belt Land surrounding Villages across the Borough. Section 11 outlines the Study Findings for assessing Green Belt Land surrounding Villages across the Borough. Section 12 details the Conclusions for Volume III.
Volume IV – Insetting of villages from the Green Belt Section 13 details the Methodology for the Insetting of Villages and defining Green Belt boundaries within Guildford Borough. Section 14 outlines the Study Findings for assessing the Insetting of Villages and defining Green Belt boundaries within Guildford Borough. Section 15 details the Conclusions for Volume IV.
Volume I, apart from setting out a summary of findings at 1.11 to 1.48 does not really add anything to the remaining volumes. The assessment looks at how well specific parcels of land serve the purposes of the Green Belt (as defined within PPG2 and the NPPF) – and it would be helpful if those had been reproduced at 1.5. Following identification of the parcels of land they were scored based upon how well they meet the purposes of the Green Belt – including the ability to check the unrestricted sprawl of large built-up areas; the prevention of neighbouring towns from merging into one another; assistance in safeguarding the countryside from encroachment; and the preservation of the setting and special character of historic towns. A similar approach was adopted in assessing the land parcels around the Borough’s villages. At 1.7 the Report notes that the Green belt parcels are “assessed against sustainability criteria and environmental capacity” but the authors leave it for the reader to trawl through the remaining documents to try to identify the specific tests. The report identifies that 16 PDAs on the periphery of urban areas would be capable of accommodating approximately 9,800 dwellings.
ALL OF THE SUMMARY FINDINGS LISTED IN VOLUME I WILL BE REVIEWED IN THE VOLUMES IN WHICH THEY OCCUR IN DETAIL.
Some of the characteristics set out in this Report should have found their way also into the Settlement Profile Report – the linkages between the documents should be much more formal and comprehensive. Equally, the Infrastructure Baseline does not provide good interface with this document. It is not clear from Volume 1 whether the Report considered any new settlements rather than simply the land around existing ones. Wisley Airfield might be one such area for consideration. At 3.9 the Summary refers to five purposes of the green belt designation (but omits them here); it then recites them as being in Section 9 of NPPF – they are:
- To check the unrestricted sprawl of large built-up areas
- To prevent neighbouring towns from merging into one another
- To assist in safeguarding the countryside from encroachment
- To preserve the setting and special character of historic towns
- To assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
At 4.10 the Report quotes from a key element of NPPF (Paragraph 83): “Green belt boundaries should only be altered in exceptional circumstances, through the preparation or review of the Local plan. The Framework comments that, at that time, authorities should consider the Green Belt boundaries having regard to their intended permanence in the long term, so that it would be capable of enduring beyond the plan period.” Other key paragraphs are recited in this section (NPPF Paragraphs 84, 85, 86, 99, 100, 115, 118, 132 and 156). Section 6 promises information about assessment methodology but does not actually deliver, relying on the reader to migrate to the relevant chapters of the other volumes.
- It does not seem appropriate to have applied different methodology to urban edge relative to villages. The village approach seems a more sensible screening methodology; from that point, land ruled out due to environmental constraints (eg AONB) should have been eliminated prior to the “sustainability” assessment (which is itself flawed and works to a pre NPPF definition – reflecting the fact that much of this work was carried out before NPPF was introduced). To have included figures for land parcels where the AONB designation would presume against development in not only flawed, but invites applications from land owners – and even from Guildford Borough Council, where they are the landowner as at South Warren Farm. In the latter case, Surrey county Council and Guildford Borough Council have been custodians of South Warren Farm on behalf of residents in order to prevent development. The AONB constraint is referred to for that site (Parcel E23) but only rather feebly and without ruling the parcel unsuitable for development.
- The areas in the Volume where there is a nearby Village (eg., Jacobs Well) are assessed against the village and not the urban area AND there is no particular effort to see if there is a major settlement that could be added within the green belt to reduce the need for realignment of the green belt around Guildford.
This volume sets out the scientific approach to the sites surrounding the Borough’s urban areas – Guildford and Tongham & Ash. There is a proper context to the work and there is no merit in summarising it here. Questions and concerns are set out as they arise when page-turning through the document. The key map for this section is available here (20130730_GreenBelt-Vol1-App2_PotentialDevelopmentAreas) (65Mb) STAGE 1 – Compartmentalisation and sub-division of land into separate land parcels The consultants divided the surroundings of Guildford into segments separated by A Roads and railways – on the whole this is a sensible strategy when seen against the NPPF guidelines, and it is puzzling for example, therefore, why the mainline railway north of Guildford is not considered to be a zone boundary. The railway lines represent a more permanent and defensible zone boundary than the A Roads which could be bridged or junctions could be added where a new settlement or significant extension warrants it.
The zones are:
From A322 (Worplesdon Road) to A320 (Woking Road) is set as Zone A (and includes land on both sides of the mainline railway)
From A320 (Woking Road) to A3 including land north of A3 between A3 and Authority border with Woking Borough Council is set as Zone B.
From A3 to London Road Line Railway is set as Zone C.
From London Road Line Railway to A246 (Epsom Road) is set as Zone D.
From A246 (Epsom Road) to A281 (Shalford Road) is set as Zone E (and includes land on both sides of the Gatwick line railway).
From A281 (Shalford Road) to A31 until its junction with A3 and the to south of A3 is set as Zone F and includes A3100 (Portsmouth Road)
From A3 to A31 (Hog’s Back) is set as Zone G.
From A31 (Hog’s Back) to A323 (Aldershot Road) is set as Zone H and includes both sides of the Aldershot line railway).
From A323 (Aldershot Road) to A322 (Worplesdon Road) is set as Zone J.
The land outside the Green Belt surrounding Tongham & Ash is set as Zone K. From these Zones, the land was subdivided into parcels so that [to be continued…]
For each parcel of land a binary score (0 or 1) is applied to qualify the parcel according to each of the following four Green Belt purposes:
- To check the unrestricted sprawl of large built-up areas
- To prevent neighbouring towns from merging into one another
- To assist in safeguarding the countryside from encroachment
- To preserve the setting and special character of historic towns
There is no score made for the fifth NPPF definition of purpose, namely: To assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
It seems odd that, where there are areas of the Guildford Urban Area that need regeneration, that no urban expansion could be seen as assisting with the regeneration – for example, if the area in town at Walnut Tree Close and Woodbridge Meadows or William Road could become new residential quarters by moving uses towards Slyfield at Parcel B3.
Using the binary approach for Purpose 1 would see a parcel well away from an existing settlement scoring 0 (suggesting it might be suitable for development under Purpose 1) but an edge of settlement parcel would score 1 (tends against development) even though it may be a more sustainable site.
For Purpose 2 the measure is broadly appropriate but would exclude a parcel where there may be an appropriate choice to make whether to coalesce settlements (eg., Slyfield and Jacobs Well).
For Purpose 3 the measure is again broadly appropriate but this should again not be allowed to preclude a site where a valid once-and-for-all settlement extension is a plausible and pragmatic option.
Purpose 4 is a valid measure, assuming there is no development that could enhance the setting and character of the historic settlement (eg., development should not be permitted on the Hog’s Back that is visible from the high Street and forms part of the historic setting of Guildford).
At 7.16 the Report notes criteria against which the lowest scoring green belt parcels are assessed. This includes the walking distance to the nearest Town or District Centre. Since the District Centres are not identified in the Settlement Profile Report, this demonstrates a lack of integration of the evidence base. Equally, some of the sustainability criteria are geographic facts, whereas some other categories could actually be created as part of a development.
At 7.21 the Report focuses very heavily on walking distances based on the Institution of Highways and Transportation (IHT) guidance (2000) but does not challenge the criteria, nor does it take any account of cycling routes and times.
At 7.24 the Report notes that railway stations are an essential facility in determining the sustainability of a land parcel. There is no indication whether the suggested new stations at Park Barn and Merrow have been taken into account in assessing parcels in their particular areas (some sort of conditionality might need to apply but the current absence of the station might affect the deemed sustainability and rule out potential for development.
7.27 highlights an issue with the Thames Basin Heaths Special Protection Areas (SPA) in that sites that would otherwise be suitable for extension become undevelopable due to the SPA. The current SPA runs to 2014 and, as part of the Local Plan process, Guildford should consider whether it needs to be amended so as not to frustrate the allocation of the most suitable extension sites.
The Report generally seems to only include facilities within Guildford Borough, whereas many of the settlements in the Borough are close to the boundaries with other Local Authorities. Any cross-boundary facilities should be allowed to form part of the analysis for each parcel.
Indeed, a further issue is highlighted in Table 5.4 (pp14-17) where many of the criteria are measured against the Guildford Borough Local Plan Proposals Map (Adopted 2003). These include some aspirations marked on the plan which do not appear to have been qualified as having been implemented. Equally, other aspects like, say, cycle routes may exist that were not on the 2003 Proposals Plan. Equally, there needs to be a robust process to upgrade this information against future proposals for plan areas and site allocations so as to ensure the data is fit for purpose in the context of the new emerging Local Plan.
Volume II – Section 8 – Study Findings
Selected comments are made here but a full look at the Report is essential for anyone with special interest or knowledge. These comments are intended as GENERAL remarks to try to ensure that all potential sites can be compared and only the most suitable selected.
Section 8 – Stage 2 screening and Stage 3 sustainability assessment
B1 scores 3 and B3 scores 4 (excluding them from consideration as a suitable Green Belt site for development).
The infilling of the area between Slyfield and Jacobs Well may be desirable in the context of, say, better connections to the A3 and Burpham. This could be designed so as to:
- Help ensure the viability of the small parade of shops;
- Local employment opportunities are already substantial at Slyfield and could be substantially increased in the new Local Plan;
- Access to Guildford town centre is via a designated cycle route which could be accessed by a coalescence or extension.
Under the Consultants’ scoring method these parcels are omitted without detailed assessment at Stage 3, and yet parcel B8 (scoring 2) is included for Stage 3 assessment.
C1 scores 1 and C2 scores 2 – C2 scoring higher because it “prevents neighbouring settlements from merging”.
The land at C1 (Gosden Hill Farm) is proposed as development which would comprise establishing a new railway station on the London Road line at Merrow. It seems very odd to suggest that C1 and C2 are qualitatively different in terms of preventing neighbouring settlements from merging.
E1 scores 1 and is, therefore, included as a land parcel for consideration.
In this instance, the creation of the Merrow Park & Ride seems to have raised the spectre of development by extending the settlement eastwards.
Part of the land parcel identified for potential development is within the Area of Outstanding Natural Beauty (AONB) and yet potential development does not seem to have been precluded by it (see ISSUES above).
Parcel E1 does not appear to be listed in the Strategic Housing Land Availability Assessment although it is recommended that the green belt boundary be redrawn to exclude E1.
E22 and E23 score 1 and 2 respectively DESPITE BOTH BEING DESIGNATED AS AONB.
The AONB is a designation which helps protect the character of Guildford’s surroundings and the Borough as a whole. To have included figures for land parcels where the AONB designation would presume against development is not only flawed, but invites applications from land owners – and even from Guildford Borough Council, where they are the landowner as at South Warren Farm. In the latter case, Surrey county Council and Guildford Borough Council have been custodians of South Warren Farm on behalf of residents in order to prevent development. The AONB constraint is referred to for that site (Parcel E23) but only rather feebly and without ruling the parcel unsuitable for development.
Parcels E22 & E23 do not appear to be listed in the Strategic Housing Land Availability Assessment although it is recommended that the green belt boundary be redrawn to exclude them both.
E24 scores 2 and E25 scores 1 suggesting they should be considered for potential development – although clearly in the AONB – and, ironically, they would score higher if E22 and E23 were developed.
Clearly development should not be appropriate in this location as it represents a key element of the character of the east of Guildford Borough – this includes Tyting Farm for which specific plans are being advanced to preserve the landscape of this site owned by Guildford Borough Council.
All of Zone G is covered by AONB although 7 of 19 parcels would appear to satisfy the criteria for sustainability assessment.
H1 and H2 score 1 and H3 and H4 score 0.
The land at H1 and H2 are owned by the University of Surrey and may have been earmarked for University expansion – Research Park, Teaching Campus and/or Student Accommodation. Part of H1 is in the AONB as is part of H3.
Infrastructure between the Onslow Village area and the town centre is fragile as is the A3 that runs past these sites. Analysis of these areas must, therefore, take into account not only the presence of infrastructure but also its suitability for intensification of use.
If H1 and H2 were to be taken out of the green belt and brought forward for development, H3 and H4 would still, presumably, only score 1 each, suggesting an almost limitless westward sprawl along the north side of the Hog’s Back. This may indicate some flaw in the binary scoring methodology.
Parcel J1 scores 3, J2 scores 1 and J3 scores 2.
It seems as though there is a clear split in J1 between the western half and the eastern half. The eastern half could probably infill between Stoughton and Liddington New Road.
Plot J2 is a finger of green which, if J3 were developed, should probably remain as public amenity space and should be protected by the Local Plan rather than earmarked for potential development.
The land designated with the letter K surrounding Tongham and Ash seems to have been treated with different criteria to that around Guildford.
For example, K8 and K9 both scored 3 (which would rule them out for consideration around Guildford, and yet they are put forward for the sustainability test and are ranked 6th and 1st= respectively. This suggests that the methodology applied to one urban settlement or the other could be challenged and there is no obvious explanation in the report.
Section 8 – Stage 4 environmental capacity
There follows a summary of each parcel that the Report recommends is taken out of the Green Belt – omitting some parcels without specific explanation.
It should be noted that the use of coloured plans is prejudicial towards colour blind readers and care should be taken to ensure that no-one is excluded from reading and understanding the specific zoning and restrictions of the parcels of land.
Equally, the summary sheets could usefully set out the scores from the previous exercises in each table so as to place the overall context within the findings.
No specific comments have been made so far in relation to each parcel (other than have already been made above).
Section 8.6 – Recommended Revisions to Green Belt Boundaries Surrounding Urban Areas
The individual plot maps are slightly confusing where two almost adjacent parcels are affected, as the plans only show each successive part in the context of the existing boundary and not also in the context of the other proposed changes. There does not seem to be an overall master plan in the report to show the cumulative impact of all of the recommendations.
Parcels E22 and E23 are both in an Area of Great Landscape Value and an Area of Outstanding Natural Beauty and should not be taken out of the green belt.
Far better that a significant new settlement in a less sensitive environment should be promoted and excluded from green belt ahead of areas that safeguard the character and appearance of the environs of our historic town.
Section 8.7 – Estimated Residential Development Capacity
The table of estimated capacity from urban encroachments on the green belt and countryside outside the green belt should note both the Areas of Great Landscape Value and should score as zero development on those parcels that fall into AGLV and AONB designations. To do otherwise is to send a signal to developers that those sites might be capable of substantial development and might make planning policies that preclude development indefensible where those parcels have been removed from the green belt.
There should be a broad estimate of the number of residents that might be accommodated in the extension areas mooted and express that number as a percentage of the current Guildford Urban Area population and the Ash & Tongham population respectively. At a rate of, say, 2.15 per household, there would be a 20% increase in Guildford urban population even before allowing for additional housing numbers on non-green-belt brownfield sites. At teh same rate, Ash & Tongham would have a population increase of 30%.
VOLUME II – Conclusion
The conclusion does not comprise a recommendation and does not seek to eliminate the sites such as E22 and E23 where the existing countryside designations coupled with their current green belt status would suggest there is no justification for taking them out of the green belt.
This Volume III takes account of extensions or infilling in villages across the Borough. Each such village – unlike the Guildford Urban Area – has a Parish Council in addition to having Borough Councillors. As a result this review is not intended to be a comprehensive assessment of the rural settlements and their green belt surroundings.
It is worth reiterating two concerns from earlier –
- The methodology of screening sites for the villages should also have been used for the Guildford Urban Area;
- There is insufficient (if any) attention given to potential options to coalesce settlements with the urban areas to create a once-and-for-all extension without such extensive potential nibbling away of the Green Belt;
At 10.2 the Report notes that “if (the approach adopted for the urban settlements) was applied to the assessment of villages, a number of the villages, potentially including those which performed well in terms of environmental constraints and sustainability criteria, would not have been considered.” This is a clear indication of the inadequacy of the urban land approach.
At 10.7 the Report continues that “the (Potential Development Areas) surrounding villages were only considered to be viable if the purposes of the Green Belt would not be significantly compromised, and if the land parcels were not significantly constrained by environmental designations” which, if applied to the urban areas, would not have allowed the parcels E22 and E23 to be recommended for removal from the Green Belt.
As previously noted, consideration should be given to expanding the Guildford Urban Area to meet Jacobs Well by infilling between Slyfield and Jacobs Well and A3.
This suggestion is to have regard to the ability to provide further housing around a key employment area, bring about sufficient critical mass for improved facilities and services, and to recognise that the North of Jacobs Well represents a long term defensible green belt boundary.
By using infill sites such as this might protect the Downs from development or removal from Green Belt (eg E22 and E23).
In general, the Report is too conservative in some areas (such as Ripley which has the facilities and services to support more development towards the A3, or Send and Send Marsh which could be coalesced whilst retaining the protection of their outer boundaries, etc) and fails to shine a spotlight on potential new settlements (such as at Wisley Airfield) as an alternative green belt solution rather than a comprehensive and broad brush realignment of the Green Belt across the Borough.
The schedule of potential development areas should include a measure of the percentage increase in the existing settlement that the PDA represents.
Equally, because the Settlement Profile Report (qv) does not set out the typical and variance of housing density in each settlement, there is no way to sense check the housing numbers postulated in the schedule. This is indicative of a wider concern about the Report, namely that it is too generic and does not provide enough guidance as to the merits of retaining the majority of the Green Belt in tact whilst carving out sufficient land for a new settlement that could be designed to be sustainable (as defined by the Report) and could be created with strong defensible green belt boundaries.
This section deals with the inserting or otherwise of villages and other settlements and I have not reviews this in detail because this should arise from the thorough review of Volume III and any amendments that may need to be made.
Further comments may be added to this site as fellow reviewers make their views known and, especially where others have more intimate knowledge of the various settlements than I do.
As a final note of caution, I am not advocating any specific development but am seeking to ensure there is a proper debate with alternatives and that some issues that have been omitted or underplayed are raised before a draft Local Plan is issued for consultation based on this evidence base.
PLEASE SEND ME A COMMENT WITH YOUR THOUGHTS…