Our council leadership has taken two great gambles with the Local Plan.
The Local Plan – Two Great Council Gambles
The failure of its strategy may well lead to even more housing coming our way, and in ways and places we haven’t bargained for.
Gamble 1 – New Housing & Infrastructure
The Council has sought to contain the new housing number by making any development dependent on provision of adequate infrastructure. There is no certainty this will work as a strategy. Specifically in so doing, it has not met, among other things, the Government’s requirement for a five year housing supply to be identified and achievable from the start of the Plan period.
Gamble 2 – Green Belt vs Brownfield
And in not looking hard enough at brownfield sites, especially in the town centre, something GVG has been urging it to do, the Council has taken the easier route and looked to Green Belt sites to provide land for new housing. This too is a gamble, as planning legislation, regulations and guidance combine to make it quite clear that there must be exceptional circumstances to reverse any Green Belt designation.
The Inspector Calls
The Inspector appointed to examine the Local Plan is already on the Green Belt case. He asks:
‘Please can the Council provide me with a single paper setting out (a) a clear explanation of what it considers to be the strategic level exceptional circumstances justifying the release of the amount of Green Belt land indicated in the plan and its broad spatial distribution; (b) an explanation of what it considers to be the local level exceptional circumstances relating to each specific site from the Green Belt; and (c) an explanation of why it considers that there are exceptional circumstances that require the addition to the Green Belt between Ash Green Village and Ash and Tongham.’
The Inspector is also questioning the Council’s proposal for widespread ‘insetting’ of Green Belt villages and settlements, where hitherto the Green belt has ‘washed over’ them. The consequence of ‘insetting’ is to modify local planning guidance to make new house building more achievable in these formerly well-protected and often historic areas much loved by their electorates.
Insufficient New Housing
The main shortcoming of the Council’s Plan is that it has also almost certainly provided insufficient new housing numbers across the entire Plan period to 2034, partly by choice but, as we may well discover at the Public Examination starting in June, by an inaccurate interpretation of the calculation formula, despite many warnings from resident groups and others.
In his first comments and demands, the Planning Inspector appointed to examine the Council’s Plan has made it clear that he is questioning the whole basis of the Council’s approach when it comes to the provision of new housing. He says:
‘I am very concerned about the proposed stepped housing trajectory which indicates that the plan will deliver much lower numbers of homes in its early years than are actually needed. 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.’
If the Plan is about anything, it is about the provision of new housing. If the Council’s great gambles fail, the consequences for all of us will likely be very disturbing.
Where’s The Evidence?
What the Inspector seems to be suggesting is that, where the Council claims an infrastructure shortfall, its evidence base for such a claim is unsound. If the Inspector is right, then the Council’s rationale for the under provision of new housing at the start of the Plan period is completely undermined. He also suggests that the infrastructure needs are inadequately set out as well.
Study Your Profile
The evidence, or rather lack of it, is to be found in the ’Settlement Profiles Report’. The Guildford Society pointed out the deficiencies of the Profiles Report very early on in the Plan process but its advice went unheeded. The Settlement Profile should help positive planning at settlement level by looking at the micro economy of defined areas across the Borough. It measures their issues, threats, opportunities, concerns, micro-economies, relative deprivation, infrastructure, connectivity and characteristics. The level of study is supported by statistics recognised and used by central government.
Most settlement profiles had at least some input from their Parish Councils. Guildford Urban Area has none and the report, written by the Council itself, is a very poor reflection of this key area.
Urban Guildford Loses Out
One glaring aspect of the Profiles Report is that Guildford town is seen as just one settlement, among 30 others across the borough. Each, of whatever size, merits a three page analysis. With a population of 74,000 the Guildford Urban Area dwarfs the other ‘settlements’ in the borough, such as Ash Green (pop: 593), Chilworth (pop: 1852) and Send (pop: 2314). Thus in the town, the three-page Profile provides poor guidance and does not distinguish between, for example, the micro-economies of Burpham and Stoughton. It does not distinguish between infrastructure needs of, say, Merrow and Park Barn. Thus the three-page Report on the urban area of Guildford leaves it with a very superficial conclusion:
‘Conclusion
Guildford is designated as an urban area and contains a high level of services. As such it could support a level of development which exceeds that of any of the borough’s other settlements. If suitable sites are found, there is the option to extend the urban area to enable more development however this may lead to development away from key services. The sustainability of any extension should be assessed in more detail through other evidence base studies. This will include further work to assess the level of infrastructure needed to support the level of growth.’
This is the quality of the evidence base against which planning policies are formed to judge future developments of a size such as Solum’s at the station.
Our Masterplan May Yet Have Its Day
GVG has long called for a masterplan for the town centre. GVG draws most encouragement from these words from the Inspector. In a series of questions, he asks:
- ‘How many years has the redevelopment in North Street, Guildford been under consideration, how long has it had planning permission and has that permission been renewed? Against a background of changing retailing patterns with continued strong growth in internet retailing, what consideration has the Council given to re-evaluating the balance of uses in this location having regard to the need to accommodate additional homes?
- There is nothing about the masterplanning of large sites, 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. These considerations need to go into a new policy ….. and the wording needs to be designed with advice from a masterplanner / urban This is essential given the number of
major housing and mixed use allocations in the plan.” - Please can the Council produce a paper setting out what steps should be taken and policy revisions made to accommodate a greater amount of the housing growth in the town centre and on other eligible brownfield land including suitable employment land and ’
We share the Inspector’s concerns over developments in the retail market. We have engaged with the North Street developer over the past year or more. We are proposing a much more mixed use scheme, with a substantial housing element, which now the Council may at last recognise. We want a professionally masterplanned scheme. We want an attractive centre extension of mixed uses, with appropriate massing for the County Town. We do not want a ‘mega mall’ with a housing estate on top.
You Have Contributed To Our Plan
GVG has asked to be allowed to present its masterplan for the town centre to the Inspector. The plan has evolved through interaction and consultation with residents, businesses and visitors alike over the past six years. We have been very heartened by the level of support for our plan shown at the two public meetings we held last year when over 500 people attended.
Guildford Residents Should Have Their Say
With the new crossing we propose, the centre of Guildford and the riverside is given back to pedestrians. Our plan delivers over 2,000 more homes in the town centre than the number planned by the Council. Our plan delivers this number while respecting and enhancing Guildford’s heritage and lovely setting. If only the same could be said for the Solum scheme – the Network rail planning application which GBC should have managed so much better before losing the planning appeal, courtesy of inadequate or absent planning policies. This is why it is so important that we all speak out. Guildford is our town and we should all have a meaningful say in its future.
GVG press release: Council gambling with our future says Guildford Vision Group April 2018
Photo by Jonathan Petersson on Unsplash