THE LOCAL PLAN IS NOW AVAILABLE FOR ONLINE CONSULTATION
It can be viewed here:
You can comment by letter, by email or using the online comment documents. If you comment, then it may be possible to request involvement in the decision process involving the Inspector; if you do not comment, you will not be able to do so. Even if you commented on the Issues and Options document you must PLEASE comment again. Only these comments, in relation to this draft, can be taken into account by an Inspector (there is nothing to stop you making the same comments or using your previous draft notes in relation to the comments before).
When this process is over, the draft will be revised. There will be a second draft but changes at that stage may be minimal, (unless the process is overturned). Local plans are overturned only when
a Planning Inspector rules that it is required
a judge rules this – following a judicial review (for which cause needs to be demonstrated)
the Secretary of State “calls in” a local plan
the Council themselves decide to withdraw the Local Plan (perhaps due to a change in the Council membership after an election)
This is our chance to change the Local Plan using the formal planning process as part of the consultation. While consultation has been largely ignored at the earlier stages, there is a duty to consult with local communities and local communities should be listened to as part of the consultation process; therefore it is REALLY important that as many of us as possible comment over the 12 weeks to 22 September 2014.
As we have a chance to study the document, we will post details of key issues on this website.
Planning law makes it clear that only the comment in blue boxes (actual planning policy) applies for the purpose of planning decisions. The narrative, the description, and the subsequent notes can all be set aside in planning decisions. This was decided by the Appeal Court in the recent case re Cherkley Court. SO it is really important to focus on the planning policy blue boxes; and if the blue boxes do not contain something that is essential, then this is worthy of comment. It is something that is easily missed.
So, for example, in relation to the Area of Outstanding Natural Beauty (Policy 8), the policy box does NOT contain the words:
4.105 The NPPF is clear that AONB should be afforded the highest level of protection in terms of landscape and scenic beauty. As the local planning authority we have a duty and an opportunity to ensure that this regard is enshrined in our Local Plan.
This comes just below the Policy – but it is not included within it. These words should be included as part of the policy. Otherwise they may have no effect in future planning decisions. This is important – so if you want these words to be part of the policy they must be included in the blue box – you need to say so!
Comments will be posted on this website in terms of points of detail, which may be useful to all.
Note also in relation to Policy 2 that Shere is marked as a potential new rural urban centre. (!). This means that it will take a place in the hierarchy of potential development that we may feel is not appropriate.
When you click on the link above, you can comment on most pages, giving responses to detailed points of policy.
In addition, it is possible to comment much more briefly on a questionnaire – see http://www.guildford.gov.uk/media/17348/Draft-Local-Plan-questionnaire/pdf/Draft_Local_Plan_consultation_questionnaire_and_monitoring_form.pdf
This is probably designed to make it easy to “support” policy, and not to get detailed comment, but if you have no time for any more response, then this would be better than nothing!
Ideally, perhaps one person in a household could respond in detail and another respond to the abbreviated questionnaire. The key thing is to respond, and for all interested people to do so.
Guildford is accepting responses from any interested parties, including students who studied at University of Surrey but have now moved away, people who want to live here, builders and developers. If you care about the AONB, care about the Metropolitan Green Belt or use the countryside as a tourist or occasional visitor, you are a stakeholder too and you should feel free to express a view to Guildford Borough Council.
If you object to a policy, make sure that you say so.
(Just in case you used these for reference):
The Full Council approved this draft for consultation, subject to further small changes at the discretion of the Planning department:
using these maps
You may have downloaded a plan from this page earlier, which was a slightly earlier draft. The changes are itemised here, plus there are some other changes to some maps.
Just in case you need to check which version you used, this is the earlier draft that councillors approved at the Executive Committee – so if you downloaded this version, be aware that it has since changed!
and these are the maps that they were using (again since changed)
The draft proposed 13040 new homes to be built by 2031, on the basis of 652 homes per year, backdated for some reason to 2011. There is no need to backdate to 2011; in fact planning advice indicates that this is not a requirement because the plan will take effect from the date of adoption. If not backdated, even using 652 as a housing number, the plan would only run for 16 years, triggering a housing requirement of 10432 (16 x 652 =10 432). However, despite this, the plan chooses to backdate, perhaps to increase the number of required homes?
The Scrutiny Committee voted on 15 May 2014 to revise the housing number from this target because they accepted the argument that this number was too high, and they agreed it was calculated on a flawed basis. However, while the Executive Committee said they would “challenge” this number, they have not revised it as the Scrutiny Committee voted for. The Executive Committee voted unanimously to approve the result on 4 June 2014.
The Executive Committee met on 4 June 2014- the meeting was broadcast on a webcast, and can be viewed here:
While the Executive Committee still claim that they will “challenge” the number, they have claimed this since the first draft SHMA in January, and the number has so far been reduced from the original 670 homes per annum to 652 per annum after “challenges”. The Scrutiny Committee, campaign groups, CPRE, residents associations and MPs have all questioned this number but despite that the Executive Committee remains obdurate; it is seeking to justify 652 come what may.
Policy 18: Sustainable transport for new developments
Response Type OBJECT
There are a number of problems with this policy.
Congestion is a widely recognised factor in the local area of Guildford, and this is a major factor in the public response to the proposed housing numbers, which represent approximately a 25% increase in housing numbers in a borough that is already profoundly congested. The population recognises that to increase the population by this level within the existing transport provision is not feasible, and this informs much of the public response to the proposed level of housing accommodation.
It is not clear that this recognition, which is widespread through the borough, is shared by those who have drafted the Local Plan. Most of the suggested solutions are ostrich like, in that they fail to recognise the realities of the situation.
Guildford is a commuter town, which (compared to London) offers better quality of life and lower house prices, so it will continue to be a commuter town for the foreseeable future. As a result, access to the stations for commuting is of significance. It is not realistic to assume that traffic to stations for commuters can be replaced either by bus services (slow, intermittent, expensive, and in many cases absent completely) or by cycles (what if if is raining? can a city executive be expected to cycle to the station in the rain in order to catch a train for a day’s work? Hardly).
The comment made above in note 4.216 “For the average person cycling has the potential to substitute for short car trips, particularly under five kilometres, and walking for trips under one kilometre” is utterly unrealistic for many sectors of the population. Cycling is attractive, and, for the urban young, especially students, it is both practical and cheap, and can be quick. However, as noted, those en route to work cannot be assumed to be able to cycle in working clothes. Elderly members of the community, those transporting small children, and the disabled cannot participate in cycling except to a limited extent. Effectively the “average” person deemed to be capable of travelling 5 km to substitute for car trips is an able bodied adult not travelling to somewhere where smart clothing is required, not needing to arrive clean (or with showering facilities on arrival, not provided by all employers); this is not sufficiently widespread in terms of the local demographic for travellers that it should be allowed to determine policy – and of course, not needing to transport, for example, supermarket shopping after the trip. What about the disabled? the elderly? those looking after more than one child? Are they to be housebound? This is not a reasonable strategy.
Before transport and buildings are determined on the basis of such a policy, it is also imperative that safe cycle routes are implemented through the borough. Cycle lanes which disappear, which travel over potholes and which allow cyclists to be threatened by HGVs are not conducive to wider cycle usage, nor should wider cycle usage be encouraged until it can be demonstrated that it is safe.
The concept of the park and ride, (Policy 1d “secure appropriate improvements to public and community transport, including infrastructure and park and ride requirements”) with access into the town limited for those who live outside the town, is similarly flawed. Park and Ride is, however, expensive, cumbersome and slow. It should be noted that in Oxford it has had a disastrous impact on small local retailers, who may have a strong view in terms of objecting to this. Most of the facilities required by rural residents are in the town and so the town is the only place that they can be obtained. Supermarkets, most schools, workplaces, medical facilities (except for GPs) even dentists are not available outside the Guildford urban area. So access to the town is essential and this is desirable –most rural residents do not want to see the urbanization of the countryside, and that view is shared by most of the residents of the Guildford urban area too.
Use of park and rides, with the consequential disruption and inconvenience, might be more acceptable as part of the cost of protecting the Green Belt, if the current Green Belt were to remain unchanged. But under the current proposals, the Green Belt is being aggressively eroded, with the bulk of the proposed population increase being dumped on the countryside around Guildford. This proposal is combined with aggressive exclusion from the town of those who are living in peripheral communities, which will increasingly resemble housing estates. This is a strategy for sink estates through Surrey instead of the Green Belt – this is not a strategy for growth. Head offices will choose to go elsewhere, because Chief Executives will not choose to live in a housing estate.
A further bizarre aspect of this policy is the way in which it is suggested that it be monitored, which is indicative of extraordinarily muddled thinking.
It will be monitored only by:
• CIL receipts and expenditure
• Planning obligations delivering infrastructure
In other words, it will be monitored not in terms of traffic flows, nor in terms of time taken on journeys, nor in terms of increased pollution, but only in terms of the money received by the local council. These monitoring criteria are indicative of the nature of the choices made and exhibit the reasons for those choices – which are unacceptable. The people who live in the borough have a need to use roads. The public transport links are expensive and inefficient, and as a result, cars are used. Buses are slow, and very expensive.
Of additional concern is the element of the policy which states: “We will expect new developments to demonstrate adequate provision to mitigate the likely impacts, including cumulative impacts, of the proposal on the performance of the Local Road Network and Strategic Road Network. This provision should include the mitigation of environmental impacts, such as noise and pollution, and impact on amenity and health. This will be achieved through direct improvements and/or Section 106 contributions and/or the Community Infrastructure Levy (CIL), to address transport impacts in the wider area including across the borough boundary.”
Cross subsidy in terms of infrastructure is envisaged and must be challenged. In other words, the funding of the new developments through CIL and S 106 is expected to contribute to the transport impacts across the borough, and there is negligible concern for the transport problems created within those new developments or in areas adjacent to them. This is not acceptable to existing residents and is likely to cause some problems with the future residents too, who may arguably feel aggrieved that the road funding associated with their developments is being subverted to other areas. While this may be permissible under the revised CIL regulations it is questionable whether it is morally acceptable to grant planning permission to build on the Green Belt in order to cross subsidise the building of roads or other infrastructure in the town centre or elsewhere across the borough or outside it.
S 4.219 states “In assessing whether the development proposal is likely to give rise to a material increase in travel demand, the Council will consider the existing use of the building(s) and/or site, existing transport conditions in the immediate and wider area, and likely transport generation from the development proposals.” This is a subsidiary proposal not part of the core policy – but it is surely much more important than that. Surely the essence of sustainability must be to minimize inessential carbon use, and the highest possible increased carbon use must be derived from incremental and unnecessary dormitory accommodation? Urban building must be inherently more sustainable, especially in the context of transport provision and increase. This must be taken into account in the granting of permission, and to disregard this issue is to minimise the impact of incremental building, especially of dormitory suburbs, on climate change. The fact that there may be a small amount of available funding to pay for a bridge or some improvements to the gyratory is not an acceptable reason to allow permission for building housing estates in the Green Belt.