Local Plan consultation Summer 2014

The consultation on this draft ENDS on 22 September at 23.59pm.


SAY WHAT MATTERS TO YOU: Whatever you want to say is valid, irrespective of the comments of the planning department or any councillors. They have said that they aren’t interested in the number of responses -but this may be because they would prefer not to receive them. Planning points are most likely to have an impact on re-drafting the Local Plan, and references to NPPF (National Planning Policy Framework – completed in 2012), planning law, NPPG (National Planning Policy Guidance – guidance substantially redrafted in April 2014), ministerial statements by planning ministers and other notes which have force within the planning process are particularly useful and are emphasised in the detailed illustration below. BUT SAY WHAT YOU FEEL. If you are concerned about congestion – about school places- doctor’s places – drains – water supply – damage to special places – damage to the environment – wildlife habitat – THESE ARE PLANNING POINTS TOO!

WHO CAN RESPOND? You can respond if you live in the borough. You can respond if you have connections to it (e.g. you are at university elsewhere but your parents’ home is in the borough – you still count as a resident.) If you grew up here but have since moved away you still have a connection – worth a response. If you work, play or shop in the borough, you can definitely respond. Guildford Borough Council is seeking responses from shoppers and users of Spectrum Leisure Centre. If you use the borough regularly for leisure activities -eg you organise Duke of Edinburgh trips through the borough, or you walk here, or you cycle here often -then you too are a stakeholder. If you visit National Trust properties here you are a stakeholder. Anyone who uses the Metropolitan Green Belt – and that means any residents in London – could be argued to be a stakeholder too. If you cycle through the Surrey lanes, you are a stakeholder. Since builders who don’t even have a business address in the borough have replied to the previous consultation, and been accepted by pro-development Guildford Borough Council, I think ALL who feel that they care about the area should be able to respond.


This is the link to the online consultation:


OR you can send a simple email to localplan@guildford.gov.uk

OR you can write to: Planning Policy
Planning Services
Guildford Borough Council
Millmead House
United Kingdom

More details about the Local Plan are given on https://getinvolved.guildford.gov.uk/consult.ti/DLPSS14/consultationHome

WHAT SHOULD I CONSIDER? When you respond to the Local Plan you should use your own words if you possibly can, because duplicated responses may be discounted. GBC have threatened to use plagiarism software used to identify duplicate responses and potentially ignore them! Note that this threat was made by Carol Humphrey, who has now resigned, so may no longer apply. However, there is no reason why you can’t make similar points- just use your own words as much as you can. And we don’t know how that would count as far as an Inspector -or the Secretary of State is concerned. So if you can, rephrase, but if you don’t have time, refer to this or feel free to cut and paste. Better to repeat than not submit a response! We have asked formally for guidance in how they will react to duplicate responses- will let you know when there is a reply.

Be aware when you look at each policy that only the words in the blue boxes will definitely count as part of the policy in the context of a planning appeal – so if you like the supporting words, suggest that they are included in the policy statement. On the other hand, if you don’t like anything, make sure that you object to this. PLEASE comment – either briefly or at more length! – because failure to comment on a policy will be taken as support.

Irrespective of any anecdotal remarks made by councillors or the planning department about how only certain comments will be taken into account, under NPPF 155 consultation with communities is an explicit requirement in plan-making – it is not optional: “Early and meaningful engagement and collaboration with neighbourhoods, local organisations and businesses is essential. A wide section of the community should be proactively engaged, so that Local Plans, as far as possible, reflect a collective vision and a set of agreed priorities for the sustainable development of the area including those contained in any neighbourhood plans that have been made”. So your priorities and your vision for the area are part of this process, and if you choose to reply, they represent part of the evidence base that an Inspector is required to take into account – the foreword to the NPPF states that it is “allowing people and communities back into planning”. So we are just requiring them to put that into practice.

Be aware that if you use the online consultation form it tends to crash while you are using it. A useful tip is to draft what you want to say in Word or your own word-processing programme, then cut and paste into the comment box on the form when completed.

THERE IS A SHORT DRAFT LETTER ON THE LINK SIMPLE DRAFT LETTER https://savesheregomshall.wordpress.com/simple-draft-letter/

LONGER ILLUSTRATION:This is a long response made on behalf of BCARA (Burrows Cross Area Residents’ Association), a local residents’ association, by Susan Parker. You are welcome to use these as a framework to stimulate your own thoughts or to extract any source material that is useful (these will be added to/revised as the plan is reviewed further – work in progress!):

Response Type: OBJECT

The Scrutiny Committee voted to revise the housing number in the draft SHMA (Strategic Housing Market Assessment) prior to issue of this consultation, because the SHMA number is overstated. This overstatement is due to a number of factors, including errors in the ONS (Office of National Statistics) key data used, misapplication of ONS data, using a time period that is short and that inflates the projection and other matters. As a result, most independent commentators have agreed that the housing number is overstated, and therefore should be reviewed prior to the issue of this document. Since the housing forecast informs most of this document it is fundamental and so changes in the housing forecast should be taken on board prior to this consultation process; a view shared by the Scrutiny Committee, by the MPs in the borough and by 15 councillors who opposed the plan to go to consultation at this stage (14 voted against; one absent due to illness wrote to confirm that he would have voted against). As a result, this plan should be revised prior to consultation.

Policy 1 Presumption in favour of sustainable development

Response Type OBJECT

This policy suggests that “policy decisions will be approved without delay and there is an intention to work proactively with applicants to mean that proposals can be approved wherever possible”.
This does not appear to accord with the requirements of NPPF 10 which notes that “plans and decisions need to take local circumstances into account so that they respond to the different opportunities for achieving sustainable development in different areas”.
Furthermore NPPF 14 notes that specific policies within the framework may require development to be restricted, and in this context, decision taking should not imply that development proposals should be approved in all circumstances.
NPPF 17 notes further that there are 12 planning principles which should be applied to underpin both plan-making and decision-taking and so these should be taken into account in the framing and the administering of the Local Plan. These include
“empowering local people to shape their surroundings”
“take account of the different roles and character of different areas, promoting the vitality of our urban areas, protecting the Green Belts around them [ note in this context that Guildford is in the Metropolitan Green Belt surrounding London, and therefore that all users of the Green Belt within London are stake holders for the purposes of this assessment], recognising the intrinsic character and beauty of the countryside and supporting thriving communities within it”
“support the transition to a low carbon future” [hardly promoted by increasing commuter dwellings!]
“contribute to conserving and enhancing the natural environment and reducing pollution”
“encourage the effective use of land by reusing land that has been previously developed (brownfield land) provided it is not of high environmental value”
“conserve heritage assets in a manner appropriate to their significance”
“actively manage patterns of growth to make the fullest possible use of public transport walking and cycling and focus significant development on locations which can be made sustainable”.
Of the 12 core principles set out in NPPF 17, Policy 1 seems to be disregarding at least 7 of these. These core principles must be taken into account in order to meet the requirement to comply with NPPF 17. Further discussion of the breach of the principles in relation to the Green Belt is considered elsewhere.

Policy 2: Planning for the borough – our spatial development strategy
Response Type OBJECT

The policy states that the provision will be for 13040 homes. This statistic is not warranted since the SHMA has been disputed, and the number of houses have been considered to be inaccurate by many commentators including ONS for a number of reasons: overstatement of student population, use of 5 year rather than 10 year statistics giving rise to a “blip”, failure to adjust for ONS restatement of core data, etc. [More detailed criticism of the calculations in the SHMA are given elsewhere]. Until the statistic is adjusted, this cannot be allowed to stand.
Further there is a reference to a need for land providing 10900-14800 additional jobs. As noted in the key statistics summary, Guildford already has almost full employment; there are not enough houses for those who already work in the area; and it is already congested. There is no capacity in terms of the geography in order to accommodate more employment land, because the workers cannot live here, will need to commute in, and this will lead to worse congestion. There are insufficient schools and medical facilities for the projected core growth in the population; where are the new workers expected to live? As a result, the need for employment land has not been demonstrated and needs to be questioned much more aggressively. Smart growth, including remote home working, makes sense in this location; aggressive 1950s style physical planning for low tech warehousing does not.
In relation to traveller sites, Guildford has a comparatively high proportion of the national traveller population. Clearly it is important to meet our proportion of national requirements, but over provision does not necessarily seem appropriate given other constraints.
In terms of the non-policy comments, it is not clear (4.4) why identified Green Belt villages should be targeted as a focus for development, and this strategy should be questioned. Which villages are identified as priorities for development and why?
In relation to point 4.9 it is noted that this is a higher rate of development than under the previous local plan period, and it is not clear why this has been determined as a policy. The council was elected on a mandate of protecting the Green Belt, rather than an aggressive policy of seeking above average growth. As noted in response to Policy 1 the requirements of NPPF and NPPG are constrained by local factors including the Green Belt and so there is no requirement to seek this higher rate of development.
Safeguarded land is subject to planning blight and is effectively available for planning for development after the end of the plan period (or even within it). As a result, the amount of safeguarded land should be restricted to the absolute minimum required under planning guidelines, and should be planned in the context of identifying longer term brownfield capacity rather than utilising scarce agricultural land.
It is noted that the table for housing totals 14660, not 13040, an excess provision of 1620 (i.e. more than enough to exclude all the extensions around the villages, as an illustration). The number of homes allocated in this table should not exceed the number in the policy under any circumstances (which is, as noted, itself overstated).
The hierarchy of centres is confused and rather garbled. It notes, for example, that potential new urban and rural local centres are identified in Table 2, including Shere – which is in the AONB and is not suitable as a rural local centre. 4.14 notes that small parades of shops in towns and villages are not designated centres. Shere is a very small village of historic importance within the AONB, and a major tourist attraction, recognisable from the Domesday Book description; it is not suitable as a rural local centre for further development. Economic development here is likely to be counterproductive since it will have a major negative impact on tourism, local visitors, the Tillingbourne trail, the film industry in Surrey and the attractiveness of the Surrey Hills AONB for cycling and other national events.

Policy 3: Homes for all

Response Type OBJECT

There are a number of problems with this policy.

The fundamental problem with this section is that this does not actually state the number of homes that are proposed, and so it is not possible to express a view on that number in terms of the proposed policy.

However the annual number of 652 homes per year is included in the Foreword on p3 in the section written by Stephen Mansbridge, the Leader of the Council. This is the result of the work done on the Strategic Housing Market Assessment (SHMA) but this itself is still in draft form, has been extensively disputed and is generally accepted as an inappropriate number. Since there is no possibility of expressing a comment on the Foreword, it seems appropriate to discuss the housing number in this section. Since the Local Plan is backdated to 2011, the Council seems to be working on the basis, not entirely justifiably, of multiplying this by a factor of 20 to cover the period to 2031. It would seem more appropriate to follow the requirements of planning inspectors as noted recently in guidance, and only apply this for the 16 years for which the plan will apply (2015-2031).

Comments on the housing number are set out below, and this is a brief summary since there is limited space to discuss this matter fully.

Policy 3 states:
“New residential development is required to deliver a wide choice of homes and meet a range of housing needs as set out in the latest Strategic Housing Market Assessment.” The requirement is to meet the housing target, not to meet the number in the SHMA, and in any event it is necessary to demonstrate that the SHMA is fit for purpose – which, at present, it is not.

It is unclear what is meant by “Concentrations of any one type of accommodation in any one place will be avoided.” Unclear statements or those designed to obscure meaning should also be avoided! This sentence is unclear, and its intentions are unclear, so it should be deleted.

Traveller accommodation should be proportionate to national need; by definition travellers – if they are travellers – move. While it would be clearly discriminatory to fail to provide a due proportion of those plots needed for travellers (especially those that are genuinely travellers as opposed to actually part of the settled population) it is not clear that Guildford Borough should offer a higher proportion of accommodation than would be proportionate to the national traveller population.

Some of the assertions included in point 4.17 should be subject to revision, given that they are reliant on the 2014 draft SHMA which, is, as further explored below, a deeply flawed document which is due for revision (also noted in the Foreword).

Point 4.19 is flawed. It notes “Any additional student accommodation built over and above projected need (as identified in the most up to date SHMA) will count towards the general housing requirement, based on the amount of accommodation it releases into the general housing market.” In fact, as clarified by Nick Boles in ministerial guidance and letters to our MPs, all built student accommodation should count towards the general housing requirement, not only the additional student accommodation. This is worryingly distorting.

Students are included in the housing needs calculation in full – one student counts as a member of the population. The housing calculation does not allocate a student room on a one-for-one basis but on a fractional basis in any event – and now GBC is proposing to allocate only incremental housing provision. This appears to be a deliberate distortion and the reasons for this bear examination. One solution to this might be that the student numbers should be excluded from the SHMA in their entirety, which would seem consistent given the comment in 4.19 that “Student accommodation needs are considered as separate from general housing needs.” If student needs are separate from housing provision, then why are student numbers included at all in the assessment of the population size in order to determine the needs for new housing? In fact, this distortion is particularly acute since the 20-24 age band – including most but not all of the student population in the borough- is the single largest age band, representing approximately 8% of the population of Guildford. This distortion in the housing analysis must be corrected since it will give rise to serious error in the planning process.

Housing number
As noted, this section (Policy 3) is silent on the housing number but refers to the SHMA, which is, as yet, only in draft.

The Foreword states: ”The number of 652 is the product of an intensely difficult balancing act: we need a sound plan, we need to ‘future proof’ the borough and not duck key problems, and we need to be sufficiently restrictive so as not to radically change or damage our environment. We continue with a draft Strategic Housing Market Assessment (SHMA) because we continue to challenge this document and we await new Office of National Statistics data which may affect the housing number”.

Given that the number of homes within the borough has been a hotly debated topic since the initial issues and options consultation in October- November last year, and that revised Office of National Statistics data are now available, together with corrections from the Office of National Statistics in relation to the Guildford housing numbers, it might have seemed sensible to revise the housing number and then revise the draft local plan in relation to this housing number before issue for consultation, as Guildford Greenbelt Group and a number of other commentators proposed. For some odd reason Cllr Mansbridge has suggested that to do this would have taken 4-5 years, but seems to feel that it will be possible to revise the local plan incorporating a changed housing number with the next draft.

Since the next draft will then only be subject to minor revisions, this does seems a disingenuous process.

Many of the objections to the SHMA are set out in the formal consultation in relation to that document and many detailed arguments put forward in terms of technical calculations are included there. The BCARA submission in terms of that SHMA is incorporated here in full by reference.
The SHMA numbers have been revised following the original consultation have not been fully addressed or considered, so the revision (from 680 to 652) but most of the points raised in that consultation remain unconsidered and unaddressed so this revision is not considered to be sufficient.

Following revision the work done was reviewed by Edge Analytics, a separate firm of consultants. They were careful not to criticise fellow professionals but were still unable to give more than an “amber tick” to the process.

To summarise these points very briefly:

1. The ONS (Office of National Statistics) data published on 29 May 2014 show that the original projections would have shown a population rising from 137580 (2011 to 156299 (2021) but the revised population projections from the ONS show this to be rising to 151439 in 2021 – a substantially lower increase. (See http://guildfordplan.com/2014/05/29/ons-new-population-projection/ this link for a further link to the ONS core data).
Note extract from National Planning Policy Guidance Paragraph: 017 Reference ID: 2a-017-20140306
“Account should also be taken of the most recent demographic evidence including the latest Office of National Statistics population estimates.”

2. The Office of National Statistics have also confirmed that the draft SHMA has errors contained within it. These are shown both in a letter to the Guildford Society and in a letter to a Guildford Greenbelt Group member (extract attached below: full letter submitted to GBC). This notes that the census for Guildford was overstated leading to an overestimate of the population by around 3%.
3. The trend analysis for Guildford used 5 year data rather than 10 year data. This results in an inflated set of numbers. Edge Analytics, in their review of the GL Hearn SHMA, note: “The dominant driver of population change in the last three years has been international migration. The growth component estimates for international migration in 2009/10, 2011/12 are inconsistent with (higher than) previous years. Given the continuing uncertainty associated with the robust estimation of UK international migration and the importance of the migration assumptions in the ‘5 Yr’ trend projection, it is recommended that further scrutiny of the international migration flows (student, worker and other) to and from the Borough is undertaken.”
4. The housing number is manipulated in order to encourage affordability. However, many commentators have noted that this is an unrealistic assumption. Guildford is in the Metropolitan Green Belt; it is highly attractive commuter territory, just outside the M25; it is between Heathrow and Gatwick; and it sits in beautiful countryside. However many homes are built here, they will be expensive because of the proximity of London, which still commands a significant premium to local prices. Edge Analytics (inter alia) note “Whilst it is evident that Guildford Borough has a particularly acute affordability issue, it is less clear how an upwards adjustment to housing provision would manifest itself as an improvement to the affordability position”.
5. The guidance set out in the NPPG in relation to trend analysis in terms of SHMA preparation requires use a longer term trend to iron out inconsistencies. However, it may be seen in the summary on p7 of the Edge Analytics report that the migration led 10 year analysis would generate a 10 year SHMA number of 470, not the GLH 5 year trend number of 671. As a result, the core data should be based on a number of 470, not 671.
6. The SHMA itself is subject to constraints as set out in the NPPF. These have however not been applied, and the simple SHMA number has been used in full.
7. Other elements are required. Local authorities are permitted to make an allowance for windfall sites in the five year allowance (NPPF 48). This has been done by Mole Valley, which has allocated 50 homes per year from windfall sites. It should be noted that this assessment does not include residential gardens. Guildford Borough Council should also allocate an amount in relation to this matter in terms of the housing supply.
8. NPPF 51 includes a requirement to identify and bring back into residential use empty housing and buildings in line with local housing and empty homes strategies and where appropriate acquire properties under compulsory purchase powers. In Guildford there are approximately 998 empty homes (per recent FOI request) of which 449 were empty for more than 6 months; these homes should be brought back into use as part of the housing supply.

“From: Steve Smallwood [mailto:steve.smallwood@ons.gsi.gov.uk]
Sent: 23 May 2014 14:19
Subject: Sub-national population projections
Thank you for your e-mail of 12 May 2014 and the link to the document by the Guildford Society and my apologies for the slight delay in responding.

Household projections are the responsibility of the Department for Communities and Local Government (DCLG). One of the major inputs to these are the sub-national population projections. I hope the following information is helpful in understanding the limitations of the 2011-based interim sub-national population projections. It is not for us to make statements to Guildford Borough Council, but you are welcome to share this response with them.

We have reviewed the Guildford Society document and can confirm that the document is broadly correct in describing how population statistics and projections are produced. The bedrock of the population statistics system is the Census. The Census provides a highly accurate estimate of the population, based on responses from around 94 per cent of people nationally. Advanced statistical techniques are used to estimate the numbers and characteristics of non-responding people so that a complete dataset, representative of the whole population, can be produced. Each year mid-year population estimates are ‘rolled-forward’ from the Census base by adding births, subtracting deaths and taking account of the net effect of international and internal migration estimates. After a Census, the mid-year estimates over the previous decade are reviewed against it, and the series rebased as necessary so that there is a consistent set of population estimates for all years between Censuses.

National population projections are normally produced every two years and are based on an analysis of observed trends in fertility, mortality and migration, with additional advice from external experts. ONS also produces sub-national projections for England. These use five-year trends in fertility, mortality and migration, and are controlled to the principal national population projection for England. The results are usually subject to consultation, and adjustments may be made if the numbers look implausible. This context is important when considering the issues raised by the Guildford Society on the figures used in compiling the household projections and the local plan.

The 2011 Census identified a very different population pattern for Guildford compared with the rolled forward mid-year estimates based on the 2001 Census. Broadly, the total population was around three per cent lower than previously estimated. This effect was particularly evident in the 20-29 age group and will have been largely due to issues with the assumptions on the movement of students into and out of Guildford (I have made some further comments on students below).

To meet the needs of DCLG for resource allocation purposes, ONS produced a set of sub-national population projections starting from the new mid-2011 population estimates that were based on the 2011 Census. However, at this point we had not revised the previous population estimates for the period 2002-2010. The historic assumptions of migration, births and deaths that were fed into these projections were, therefore, those derived from the mid-year estimates before reconciliation with the findings of the 2011 Census. In line with the National Statistics Code of Practice, ONS was very clear about the limitations of this approach in the statistical bulletin*. The projections only covered a ten year (rather than the more usual 25 year) time horizon due to their interim nature and limitations.

It appears that in Guildford’s case, use of the unrevised trends may have caused the population to be overestimated in the interim 2011-based sub-national projections – particularly for ages 22-29, indicative of assuming too few students leaving at the end of their studies. However, a new, 2012-based, set of sub-national population projections will be published on 29 May 2014. These will incorporate the reconciled population estimates for both the starting population and for the historic series used in setting the fertility, mortality and migration assumptions. I obviously cannot comment on the content of these prior to publication. I should note that the household projections will also include trends on household formation which will also drive the projection of the number of future households. So some of the household growth may come from trends other than the population numbers themselves.”

Policy 4 – affordable homes

Response type: OBJECT

It is entirely and unconditionally accepted that some affordable homes are needed within the borough for key workers, and that some key workers – nurses, other medical staff, firemen, some police staff and other key workers of essential social importance- find that they are not able to live within the borough. This is clearly undesirable, and mechanisms to provide affordable homes for key workers – perhaps either allocation related to specific employment, or tied housing associated with employment provided at subsidised rents – would almost certainly be welcomed by all members of the community.

There is a little more disquiet about the concept of entitlement, where it seems to be suggested by GBC that any potential owner who chooses to wish to live in one of the most desirable parts of the country should have a right to do so at a price they wish to pay (a notion which seems to subvert the principle of supply and demand and run counter to basic economics). This entitlement seems to be suggested by note 4.49, which states “Approximately half of all Guildford residents cannot afford to buy or rent a home on the open market, which meets their needs (draft SHMA 2014).” Quite apart from the fact that this is logically counterintuitive (if they can’t afford it, how come they are resident here?) this arithmetic has been historically challenged in the BCARA notes on the draft SHMA, and those notes are incorporated here by reference.

Generally, it is worth bearing in mind the point made by Edge Analytics in their review of the GL Hearn SHMA

Click to access Edge_Analytics_review_of_the_Guildford_SHMA_(March_2014).pdf

that :

“3.6 Whilst it is evident that Guildford Borough has a particularly acute affordability issue, it is less clear how an upwards adjustment to housing provision would manifest itself as an improvement to the affordability position”.

The recitation of the statistics within the draft SHMA 2014, restating the relative costs of housing, are in themselves subject to question and it may be argued that these notes (4.49-4.52 inclusive) do not belong in a Local Plan which is stating policies. These are arguments, not policies, and seeking to persuade of the merits of a predetermined case and are not appropriate in this context and should be deleted. They are perhaps indicative of the intention underlying the Local Plan draft, which is seeking to put forward a proposition rather than establish the community view.

In any event, the statistics have been questioned and are still subject to question, and should not be recited as statements of fact. It is demonstrable –eg from a survey of Rightmove, Primelocation or Zoopla (key market indicators, accepted themselves as evidence of value for probate by HMRC so of some statistical validity) that the prices within the London metropolitan area are sufficiently higher than the local area (typically a 3 bedroomed home in Guildford is equivalent to a 1 bedroom flat in Wandsworth or Lambeth, not even premium areas) that Guildford and its surroundings can be – and indeed are (within the London metropolitan press) seen as inherently affordable.

Note 4.54 in terms of fractional arrangement is uncontentious. Conversion of housing stock as described in 4.55 is similarly uncontroversial.

It is not clear that –as set out in 4.56 – that financial contributions in lieu of on-site provision is an acceptable option, but if so, it is important that areas for affordable homes are earmarked. This note to policy is discussed further in 4.47 and 4.48. As in other areas of policy, it is not reasonable to expect consultation to provide a “blank cheque” – all that 4.48 notes is that no formula has yet been calculated in relation to affordable housing payments in lieu of on-site provision; until a policy is formulated, the consultation process is null and void. (This is arguably true of the entire housing allocation, which is still under consideration).

It is not clear why there should be extensive off-campus student housing, when there is existing unused planning permission for more than 2121 student homes on campus at UniS. This unused planning permission for student accommodation should be required to be met before any further planning permission of any form whatsoever is granted to UniS, especially given the damaging impact of this underprovision on the supply of affordable homes within Guildford (HMOs etc).

The policy is indicating that 40% of homes to be built with equate to 5126 affordable homes. Interestingly this is another error – the Planning department do seem to be rather relaxed or careless in their use of calculators, and reluctant to revise numbers even when errors are drawn to their attention by the Office of National Statistics.

Annual required housing supply per Cllr Mansbridge’s introduction = 652

[Note that this number is considered to be too high by all commentators including ONS]

No. of years in the plan [including backdating – a disputed requirement] =20

20 x 652 =13 040

13040 x 40% = 5216.

Since this narrative is referring to 5126 this is presumably (yet another) arithmetical/typographical error.

It should be noted that 70% of the homes provided will be on greenfield sites according to the current draft plan, which would mean that the percentage to be applied should be 45%.

Since 5126 is presumably deemed sufficient, this would imply a lower housing requirement according to the planning department.

In terms of the argument re affordability, the fact that the provision of affordable homes is subject to viability (presumably as set out in the cascade in 4.44, varying or reducing the number of affordable homes if developers lack of economic viability) the tenuous and theoretical nature of this provision becomes evident. It becomes clear that this is merely a smokescreen in order to enable development throughout the borough, and there is no real interest in the provision of affordable homes.

This is further demonstrated by the article in the Surrey Advertiser on 4 July where it is noted that there is a target of 80 new affordable homes by 2016, and that construction is underway to provide 65 new affordable homes.

More affordable homes could be provided now on land owned by Guildford Borough Council if it were so minded. Furthermore some funds exist to do so; GBC has a policy of investing in commercial property for rent (a sector where there is currently oversupply, which in itself is a questionable use of public money, most recently a property of over £13 million during the autumn of 2013); it would be equally possible to invest in affordable residential property for rent for key workers, an area where there is enormous public support for those in real need. Given that economic viability assessed by developers will be the only real criterion applied to the market supply of affordable housing, it would seem more sensible for the borough to invest directly in affordable housing under its own control. It should also not have the viability criterion built into the key policy, as it currently is.

As a policy would seem sensible to provide affordable housing; to note that there will be no viability reduction except in the context of provision of housing on brownfield land, which is socially desirable; and to note that there should be priority allocation of affordable homes for key workers.

Policy 5: Rural Exception Homes
Response Type OBJECT

There are a number of problems with this policy.

Re traveller sites: the Secretary of State has made it clear that traveller sites are not appropriate in the Green Belt. As noted in a ministerial statement on traveller sites:
This notes:
“Our policy document, Planning policy for traveller sites, was issued in March 2012. It makes clear that both temporary and permanent traveller sites are inappropriate development in the green belt and that planning decisions should protect green belt land from such inappropriate development.
As set out in that document and in March 2012’s National Planning Policy Framework, inappropriate development in the green belt should not be approved except in very special circumstances. Having considered recent planning decisions by councils and the Planning Inspectorate, it has become apparent that, in some cases, the green belt is not always being given the sufficient protection that was the explicit policy intent of ministers.
The Secretary of State wishes to make clear that, in considering planning applications, although each case will depend on its facts, he considers that the single issue of unmet demand, whether for traveller sites or for conventional housing, is unlikely to outweigh harm to the green belt and other harm to constitute the ‘very special circumstances’ justifying inappropriate development in the green belt.”
Re rural exception sites, the NPPF deals with this in NPPF 54 which states:
“In rural areas, local planning authorities should be responsive to local circumstances and plan housing development to reflect local needs, particularly for affordable housing, including through rural exception sites where appropriate”.
This clause makes it clear that housing in rural locations should reflect local needs particularly for affordable housing. In this context local should imply with a direct connection to the community.

The following extract from the National Planning Policy Guidance is relevant:

Paragraph: 034 Reference ID: 3-034-20140306

Can unmet need for housing outweigh Green Belt Protection?

Unmet housing need (including for traveller sites) is unlikely to outweigh the harm to the Green Belt and other harm to constitute the “very special circumstances” justifying inappropriate development on a site within the Green Belt.

Revision date: 06 03 2014

In fact it is clear that Guildford Borough Council sees rural exception housing not as an exception but as a normal mechanism for supply while disregarding the constraints of the Green Belt. It actually uses affordable housing within the villages not in order to meet local needs but as a response to the general housing list, which is inappropriate, per the NPPF. It is noted that in the Surrey Advertiser on 4 July that the 27 new homes being built in Gomshall are not earmarked for particular local need (which, under NPPF, they should be) but are part of the overall target of 80 new affordable homes across the borough. This is arguably in contravention of the requirements of NPPF where housing development in rural areas should reflect local (not borough-wide) need.
Such lack of earmarking has two potential problems. One is that there is increased pressure to consider rural exception sites which properly would not and should not be required – and the response to this would therefore be to earmark affordable housing within villages for demonstrable local need.
The other, which should not be overlooked, is that it has the capacity to create a rural poverty trap. In Gomshall (the site of a significant number of new affordable homes being built by GBC) the cost of a single bus fare to Guildford is currently £3.50 and the cost of a single train fare to Guildford is £3.80. This is likely to prove a significant obstacle in seeking employment or the facilities needed by most members of a community (cheaper food from supermarkets; hospitals; dentists; secondary schools; junior schools (none of these present in Gomshall)). Such a rural poverty trap is likely to be of less impact for those with family in the immediate area or those who work in the area; but for those on the general housing list it is inappropriate housing.
So if the affordable housing within villages is allocated to those with local connections, the need for the rural exception scheme falls away.
It should be noted that the NPPF requires the policies under which limited affordable housing for local need to be set out in the Local Plan; this should not set out the circumstances either of where these policies should apply, nor to whom they should apply – both would seem to be required.

One particularly shocking – developer led –initiative is the proposals implied within notes 4.66 and 4.67 which suggests that the rural exceptions scheme should be utilised to grant planning permission in the Green Belt OUTSIDE settlement boundaries for market housing. This is completely in contravention of NPPF:
“4.66 There may be situations where a developer demonstrates that a rural exception scheme would be unviable without public subsidy. In such situations, and where there are no alternative sites available to provide the identified local affordable housing needs (as required by national policy) we will consider permitting the minimum number of market homes to make the scheme viable at our discretion. We may also consider allowing at least one market home where this would result in a significant improvement in the housing mix (tenure, type or size) or rent levels. The inclusion of market housing must serve to benefit the rural affordable housing stock and not inflate the “threshold land value”. This is the price that a developer pays for the land.
4.67 Land values are generally high across the borough. Therefore where a developer proposes that at least one market house needs to be included to make the rural exception scheme viable, in considering the submitted development appraisal, we will limit the existing land value to no more than ten times the agricultural land value at the time. Where agreement cannot be reached, external consultants will be appointed at the developer’s cost to provide an independent assessment of the scheme’s viability. Any market housing must improve the mix of market housing in the village, and must be integrated into the rural exception development.”
NPPF 89 notes that “a local planning authority should regard the construction of new buildings as inappropriate in Green Belt. Exceptions to this are:.. limited affordable housing for local community needs under policies set out in the Local Plan”. New market housing does not meet this criterion and should not be permissible. Notes 4.66 and 4.67 are in clear breach of the requirements of NPPF and of planning law (St Albans, Gallagher homes) and should be deleted. There are no circumstances where it could or should be permissible to build market housing under the rural exceptions scheme.
Concerns have been expressed previously that the rural exceptions scheme could become a “Trojan Horse” policy allowing development that should not otherwise be permissible. This expression of that policy emphatically seems to embrace this concept.
This policy requires radical revision in order to
1. articulate the requirements under which the rural exception scheme might be permissible, making it clear that it will not be permitted except where there is demonstrable unfilled local need which cannot be met elsewhere
2. make it clear what the requirements are to qualify for the scheme
3. ensure it is made clear, as part of the policy (blue box), that this is an exceptional scheme only and that the overriding requirements of the NPPF, especially NPPF 87, 88 and 89, will apply in the administration of this policy so that it will only apply in exceptional circumstances.

Policy 6: Making better places
Response Type SUPPORT

This policy gets measured and partial support.
It is unclear what is intended by the comment that large scale residential developments should provide “an integrated mix of uses” and this comment is not supported. Residential areas can benefit from some open spaces, in a well designed context (garden squares or properly maintained parkland); there is a requirement for proper medical facilities and schooling (and it would seem appropriate for consultation to take place with the County Council to ensure that this provision will be available for larger developments). [ There is clearly an economic incentive (in the form of the Community Infrastructure Levy) for local authorities at borough level to grant planning permission, while the associated costs of much infrastructure in terms of schooling, roads or medical care will devolve on other authorities, and this needs to be resolved as part of the Duty to cooperate, or it may place an intolerable burden on existing borough and county residents to cross subsidise new development which they don’t want anyway].
There does not seem to be much justification for mixed use in the context of including employment land with residential land. A representative of Guildford Chamber of Commerce who addressed the Scrutiny Committee in relation to the MasterVision document noted that commercial providers would generally prefer to have areas where most builders were commercial (although flats above shops were in a different category) and that offices were desirable on a stand alone basis. Councillors also expressed concern about the risk to children travelling to school where there was substantial mixed use. On this basis, it would seem desirable to limit mixed use in most new developments and focus on well designed and integrated residential areas. The only exception to this would be in the town centre above retail development where there would be an improvement on the community structure and on the nighttime environment if there were residential flats in the floors above ground floor shops in the town.
The concept that where possible residential areas should allow short walking distances to amenities is warmly welcomed and strongly endorsed. The prospective development of housing at Walnut Tree Close, as indicated in the Master Vision document, would allow easy walking to both employment, the station, and shopping facilities (and development of housing in this area would also have the benefit of reducing the current town centre congestion). All speakers, including representatives of the commercial sector, at the Scrutiny Committee on the Master Vision document noted that the Walnut Tree Close area was not suitable for industrial or heavy commercial use and that redevelopment is highly appropriate for this area; good quality design (which is not incompatible with medium rise and higher density) would be desirable. In this context the remarks made by Prince Charles in relation to mansion blocks as part of urban regeneration in a sustainable context are pertinent. Inclusive and high quality design are extremely important factors and should be an absolute planning requirement; this too is warmly welcomed.
We would not altogether support the suggestion of substantial increased economic use of land, and feel that there is already sufficient vacant commercial space (both office space and industrial units) in the borough to meet reasonable needs for the foreseeable future. Development in the future is likely to want to use cheaper land than here for industrial and commercial units. Guildford should focus on the high added value economy, with the high knowledge base and the highly skilled and educated local population, for which the increased local broadband speed is a key advantage. As a result, it seems rather pedestrian planning to expect a “one size fits all” model which will involve substantial additional local factories and commercial sites – and these are really not required. In fact, such sites would damage some aspects of the local economy – tourism, the film industry, head offices for major organisations seeking prestige venues would all be damaged by too much incremental commercial development, and the cause of urban regeneration would be substantially improved by using some poorer quality parts of the industrial area as target zones for urban regeneration.

Policy 7: Sustainable design, construction and energy

Response Type OBJECT

Note 4.76 states: “The NPPF tells us that sustainable development means achieving growth while “ensuring that better lives for ourselves don’t mean worse lives for future generations”. In environmental terms, this means taking into account the impact of our consumption patterns on the environment’s ability to provide both for ourselves and for future generations. In practice this means being careful about how much we consume, using materials as many times as possible and favouring renewable resources like sunlight and plant materials over finite resources like minerals and fossil fuels.”

The definition that sustainable development means achieving growth while “ensuring that better lives for ourselves don’t mean worse lives for future generations” is acceptable and, as indicated by the quotation marks, did not originate with GBC but refers to the UN definition. This definition is however itself a little more stringent and is also included within the NPPF itself, not just the ministerial foreword. It is set out above policy 6 of the NPPF, and states that sustainable development is “meeting the needs of the present without compromising the ability of future generations to meet their own needs”; it also notes the guiding principles that includes “living within the planet’s environmental limits”. However, that definition is then adjusted by GBC to suggest that it is only consumption of materials and finite resources that is affected by this policy.

In planning terms, the most finite resource is clearly land, and this must be the cornerstone of this policy – and, at present, it is not. So – until this is taken on board –this policy cannot be accepted. Adding the odd solar panel, or using more wood in construction, does not make a project inherently sustainable (while these are useful additions, they are not key to the process).

Sustainable development must –in the context of planning building and future built development – take account of the availability of land, and it must also consider the constraints which should be applied to this (geographical, in relation to designation eg AONB, Green Belt, international and national environmental protections (SPA, SSSI etc) and other factors (ancient woodland, National Trust land etc)). This is a moral requirement. It is also constrained by the NPPF. As noted in the Ministerial Foreword to the NPPF, in the context of discussing sustainable development “Our natural environment is essential to our wellbeing, and it can be better looked after than it has been. Habitats that have been degraded can be restored. Species that have been isolated can be reconnected. Green Belt land that has been depleted of diversity can be refilled by nature – and opened to people to experience it, to the benefit of body and soul”.

Core planning principles, set out in NPPF 17, note that there is a requirement for planning to “take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the Green Belts around them, recognizing the intrinsic character and beauty of the countryside and supporting thriving rural communities within it”.

Within the section of the NPPF devoted to “Delivering sustainable development”, which is the heading on p6 covering the next 13 sections to p36 or point 149, section 9 – an element within this – is “Protecting Green Belt land” which covers points 79-92. NPPF 80 recites the 5 purposes of Green Belt land which are an element of that core sustainable vision
· “To check the unrestricted sprawl of large built up areas
· To prevent neighbouring towns 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.”
All these tests are met by all the Green Belt land in the borough of Guildford. There is substantial brownfield derelict and other urban land available, and so sustainable development must mean that the Local Plan uses this brownfield derelict and other urban land in preference to using any Green Belt land.

It should be noted, in this same section on Sustainable development, that the following comments are included: “Once established Green Belt boundaries should only be altered in exceptional circumstances” (NPPF 83) and NPPF 87 ”inappropriate development is by definition harmful to the Green Belt and should not be approved except in very special circumstances”.

Having established the principle that sustainable development must mean a strong focus on brownfield land and a fundamental rejection of the principle of using any Green Belt land where brownfield land is available, there is much within this policy that is otherwise acceptable. The energy and waste hierarchies are sensible, and the principles of sustainable design for new buildings are warmly welcomed.

It should be noted, in the context of carbon neutrality and lower carbon emissions, that building dormitory suburbs is not carbon neutral. There is a substantial carbon cost to building in the countryside where commuting becomes a requirement for work and for education, with consequently higher potential car use, and therefore higher carbon footprint. Building in the town is of enormous advantage because it is essentially less disadvantageous in carbon emission terms (denser homes have lower carbon impact both in terms of emissions when built and in terms of emissions generated by the construction process). It also means that the inhabitants of those buildings can live more efficiently in terms of transport use. For example, the proposed buildings in the Walnut Tree Close Area, envisaged by the Master Vision document prepared by Allies & Morrison, have the prospect of much lower net carbon emissions both during construction and in the very long term. As Allies & Morrison (GBC planning consultants) note on p13 of their document “Guildford has the potential to be a truly sustainable town. This is about more than energy efficient buildings and solar panels on roofs- it should shape every aspect of the town. Guildford needs a sustainable mix of uses , a transport network which favours public transport, walking and cycling whilst minimizing car use and an environment which promotes biodiversity and healthy living.” They also note on p 58 “A further aspect of Guildford’s setting in the landscape is the issue of future housing capacity and the need to deliver housing on brownfield sites to limit the need for the town to expand beyond its existing extents. The industrial area of Walnut Tree Close presents a strong opportunity for this. The area is within easy walk of the town centre and the station and development would significantly improve the river corridor and links between the town centre and the University”.

Policy 8: Surrey Hills Area of Outstanding Natural Beauty (AONB)
Response Type SUPPORT

This policy is broadly in accordance with the requirements of NPPF and is acceptable.

However, notes 4.105 and 4.106 must be included within the blue box for policy definition, or (as per the Appeal Court decision at Cherkley Court) their status is only advisory. These must represent an element of the actual policy, and if not then the support indicated above would become an objection.

NPPF 157 notes that Local Plans “should identify land where development would be inappropriate, for instance because of its environmental or historical significance”.

This should apply to the Surrey Hills AONB in its entirely except for localised brownfield sites; development would be inappropriate in this area. This should be fully documented as a key policy in the local plan.

It is essential that it is fully recognised that AONB should be afforded the highest status of protection per NPPF 115.

It would be appropriate to include wording replicating NPPF 116 “Planning permission should be refused for major developments in these designated areas except in exceptional circumstances and where it can be demonstrated that they are in the public interest. Consideration of such applications should consider an assessment of the need for the development including in terms of any national considerations, and detrimental effect on the environment, the landscape and recreational opportunities.” The suggestion in the current wording would seem to partly undermine the proposal as it stands.
In the context of this policy, consultation with the Surrey Hills AONB board in the context of planning issues would seem to be an important element of the monitoring process. Under NPPF 178 and 179 there is “a duty to cooperate on planning issues that cross administrative boundaries” (such as any matter that affects the Surrey Hills AONB) and to “work collaboratively with other bodies [e.g. Surrey Hills AONB board] to ensure that strategic priorities across local boundaries are properly coordinated and clearly reflected in individual Local Plans.”
It would also seem relevant to specify that the types of development that might be appropriate in the AONB are restricted. In this context NPPF 89 is relevant (and it should be noted that NPPF 89 relates to the Green Belt as a whole, and that the AONB should have an even higher level of protection) which states:

“A local planning authority should regard the construction of new buildings as inappropriate in Green Belt. Exceptions to this are:

buildings for agriculture or forestry
provision of appropriate facilities for outdoor sport, outdoor recreation and for cemeteries as long as it preserves the openness of the Green Belt and does not conflict with the purposes of including land within it
the extension or alteration of a building provided that it does not result in disproportionate additions over and above the size of the original building
the replacement of a building, provided the new building is in the same use and not materially larger that then one it replaces
limited infilling in villages and limited affordable housing for local community needs
limited infilling or the partial or complete redevelopment of previously developed (Brownfield land_ whether redundant or in continuing use (excluding temporary buildings) which would not have a greater impact on the openness of the Green Belt and the purpose of including Land within it than the existing development.”
Policy 9: Villages and major previously developed sites

Response Type OBJECT

It should be noted that the NPPF “provides a framework within which local people and their accountable councils can produce their own distinctive local and neighbourhood plans which reflect the needs and priorities of their communities.” (NPPF 1). Guildford Borough Council has disregarded the representations made to it during its initital consultation process of the Issues and Options Consultation. The Scrutiny Committtee of Guildford Borough Council voted to review and reduce the housing number, but was overruled by the Executive. The Executive was appointed by the leading party, locally the Conservatives, who were voted in on a manifesto (attached as a Jpeg) that emphasized that they would protect the Green Belt and fight inappropriate development- in other words, the majority of voters – the local people covered by this Local Plan – voted to protect the Green Belt. The full manifestor stated:
“Following the successful defeat of the South East Plan by Guildford Borough Council and Guildford residents we will continue to fight to preserve the character of our town and villages. To preserve gardens and the Green Belt we will continue to work on finding brownfield sites that can support housing instead.”

This has now been completed ignored, with the emphasis into becoming a “Growth Hub” – which was NOT in the manifesto, in any form, and is included only tangentially in the Corporate Plan, and that Corporate Plan itself not subject to any public consultation whatsoever.

In addition to NPPF 1, the Core Planning Principles set out in NPPF 17 include, as the FIRST (and therefore most important) principle, that “planning should:
· Be genuinely plan-led, empowering local people to shape their surroundings, with succinct local and neighbourhood plans setting out a positive vision for the future of the area”.
Furthermore, if this were not enough, in the section on Plan-making, NPPF 155 states:
“Early and meaningful engagement and collaboration with neighbourhoods, local organisations and businesses is essential. [It is not clear that early collaboration with prospective developers is either required or legal]. A wide section of the community should be proactively engaged so that Local Plans, as far as possible, reflect a collective vision and a set of agreed priorities for the sustainable development of the area, including those contained in any neighbourhood plans that have been made”.

Local People are supposed to be represented within the NPPF, and any plan which does not meet with the consent of local people is arguably unsound. The failure to amend a plan following consultation, and to take the points made into account, is arguably in breach of NPPF and consequential challenge.

Under NPPF 83 “Local Plan boundaries should only be altered in exceptional circumstances through the preparation of review of the Local Plan. At that time, authorities should consider the Green Belt boundaries having regard to their intended permanence in the long term so that they should be capable of enduring beyond the plan period.”

Further, under NPPF 84 “When drawing up or reviewing Green Belt boundaries local planning authorities should take account of the need to promote sustainable patterns of development. They should consider the consequences for sustainable development of channeling development towards urban areas inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the outer Green Belt boundary.”

Guildford Borough Council has stated in 4.111 “All our villages, except Ash Green, and our major previously developed sites are currently washed over by the Green Belt designation. National planning policy states that only those villages whose open character make an important contribution to the openness of the Green Belt should be included in the Green Belt.”

This is categorically not what National Planning Policy states. It is arguable that GBC is arguing aggressively for a pro-development building strategy outside villages and mis-stating national policy as a result. It might be argued that the NPPF, in its rules 83 and 84 recited above, is offering a permissive ability to review the Green Belt, rather than a prescriptive requirement to do so, and so Guildford Borough Council is rather aggressively seeking to attack the Green Belt in a manner which is inappropriate and not prescribed. Its incentives for so doing have been considered elsewhere, but seem associated with the probable receipts of New Homes Bonus and Community Infrastructure Levy, and the consequential impact on local funding, to the detriment of existing residents.

Furthermore, it should be noted that Guildford Borough Council continues in 4.111 “Those [ie villages] that do not should instead be inset from the Green Belt, removing their Green Belt status. It also states that we should not include land in the Green Belt which is unnecessary to keep permanently open.”

This is a distortion of NPPF 85 which actually states:
“When defining boundaries, local planning authorities should
· Ensure consistency with the Local Plan strategy for meeting identified requirements for sustainable development
· Not include land which it is unnecessary to keep permanently open
· Where necessary, identify in their plans areas of “safeguarded land” between the urban area and the Green Belt, in order to meet longer-term development needs stretching well beyond the plan period
· Make clear that the safeguarded land is not allocated for development at the present time….
· Define boundaries clearly, using physical features that are readily recognizable and likely to be permanent”.

There is a requirement to define defensible boundaries to the Green Belt, but absolutely NOT a requirement to inset villages from the Green Belt, which is a distortion of NPPF, at least not as far as the text of the NPPF states. Those defensible boundaries are required to be those which are likely to be permanent. This is recited in 4.113:
“In accordance with national policy, Green Belt boundaries need to follow defensible lines that are easily recognisable and likely to be permanent. This includes for instance roads, railway lines, woodlands and hedgerows.”

Of course, the outer edge of the existing settlement is perhaps the best definition of a boundary which could be likely to be permanent. Features such as trees or hedgerows can be moved or removed or, being plants, can die, or be blown down. It is proposed that the settlement boundaries should only be revised where the line of the existing settlement has already changed, to reflect historic fact, rather than to extend the settlements out over open fields.

Each village will note its own concerns in relation to the proposed settlement boundaries as set out in the maps but it does seem curious that most of the villages, whether inset or remaining within the Green Belt, have altered settlement boundaries, frequently circling areas which are not currently built up or part of the settlement, in other words extending the settlement boundaries.

The fact that Shere and Gomshall within the AONB will remain washed over by the Green Belt is welcomed. There are local concerns over the extensions to the boundaries of all the villages in Shere ward, including Shere and Gomshall but also particularly Peaslake and Holmbury St Mary which have very substantial village extensions. [Local comment here on specific boundary markers is required].

Broadly, the principle of only developing within the defined boundaries of villages is supported as set out in the policy.

Safeguarded land should be minimized in order to avoid planning blight for those areas.

There should be an emphasis on development within major previously developed sites (eg Peasmarsh industrial estate, HM Prison Send) before developing sites within villages so an additional hierarchical tier should be inserted.

The statement in the policy that “We are keen to support economic growth in our rural areas, whilst protecting the best and most versatile agricultural land, and will support the sustainable growth and expansion of business and enterprise through conversion of existing buildings and well designed new buildings.
We are also keen to retain existing and support the development of new local services and community facilities. In accordance with the NPPF, we will allow small-scale development for main town centre uses (see glossary) without applying the sequential approach. In Guildford borough, small-scale development means those of less than 280 sq m (gross).”

It is noted that “main town centre uses” per the glossary states: “Retail development (including warehouse clubs and factory outlet centres); leisure, entertainment facilities the more intensive sport and recreation uses (including cinemas, restaurants, drive-through restaurants, bars and pubs, night-clubs, casinos, health and fitness centres, indoor bowling centres, and bingo halls); offices (including office open to the public); and arts, culture and tourism development (including theatres, museums, galleries and concert halls, hotels and conference facilities).”

Many of these uses would not be appropriate either to villages in the Green Belt or villages inset within it – indoor bowling, casinos, warehouses etc would not be appropriate for most villages in Surrey , and therefore the section in the policy marked above in red should perhaps be deleted.

The provision and take up of reliable and high speed broadband, and the increased impact of home working and smart working are welcomed. Access to high speed broadband as a priority is welcomed and this is one of few aspects of the LEP’s policy that is welcomed in relation to the rural environment.

In this context, it seems entirely inappropriate that a monitoring indicator is net additional employment floorspace completed by category. “Smart” and home-working do not involve a calculation of incremental floorspace and to evaluate incremental economic growth by the size of floorspace allocated is an inappropriate measure in the Green Belt. By definition such work uses do not use space – and there will be a net reduction in space if agricultural land is lost, since this too is employment space. It is important to recognize – as this Local Plan does not – that the main employment within the countryside is related to that countryside, whether due to agriculture, tourism (so that “unproductive” or open space land has a positive economic impact too), film, or ancillary activities related to the above, and that to reduce the countryside footprint by building sites is to reduce economic land. The only use of land that has no ongoing positive impact for the community is to use it as a building site, whereupon it is lost in terms of ongoing economic benefit to all except the future owners.

Furthermore to seek to monitor this policy also by net dwelling completions is again to be reductive and to appraise development only by number of homes, rather than by the contribution in a wider context that any homes may make. This is in contravention of NPPF, which under the core planning principles in NPPF 17 requires that local authorities “always seek to secure high quality design and a good standard of amenity for all existing and future occupants of land and buildings”, and that they “take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the Green Belts around them, recognizing the intrinsic character and beauty of the countryside and supporting thriving communities within it”. To appraise building within the Green Belt merely in terms of numbers of buildings or net additional floorspace does not meet the requirements of those principles.

Any homes built in the countryside should be subject to the most onerous design standards in order to conform with local requirements. This is not only because any new homes built will affect the existing villages, but also because rural tourism is a very significant economic driver (as noted in the policy, approx. 25 per cent. of employment and 36 per cent. of businesses). These are not all factories and warehouses; many of these businesses are tourism related, and to built inappropriately will be to destroy an economic power house within the borough.

Villages should be protected; new building in villages should be within the existing settlement boundaries, and new settlement boundaries should only reflect the historic changes of the settlement areas; building should not extend into the open countryside of the Green Belt; and new building should focus on brownfield sites within the urban areas.

Policy 10: Green Belt and the countryside

Response Type OBJECT

To comment on this policy click this link

As ever, there is an element of support in this objection. The desire to protect the Green Belt in accordance with the NPPF is wholly supported. However, it is disconcerting that most of the policy in the section on Green Belt and the countryside relates to the countryside which is not designated as Green Belt.
Given that 89% of the borough is designated Green Belt, and there is just a small amount of countryside that is outside the Green Belt boundary, this is both disproportionate and inappropriate. There seems more concern, within this policy, to prevent inappropriate development within the countryside beyond the Green Belt, and to encourage potential development within the Green Belt, than to enforce the principles within the NPPF of the Green Belt itself.

The first bullet point within the policy notes the requirement to judge the suitability of any development in the Green Belt in accordance with the NPPF.

It would seem appropriate to note point 4.122 should be included within the policy not merely as guidance notes to it, which, as was demonstrated in relation to Cherkley Court, do not have the force of policy. So this item should be flagged as a blue item.
“4.122 National planning policy sets out the fundamental aim, characteristics and purposes of the Green Belt. The Government attaches great importance to Green Belts and there is a general presumption against new development in the Green Belt. National planning policy includes guidance on the types of development that may be appropriate in the Green Belt, which we will use to determine all planning applications. “

In the context of the particular points made within the policy, taking the comments in order, the comment about Green Belt within the policy seems particularly grudging and aspiring to promote development within the Green Belt- which seems to be the policy of the Council, in contradiction to the wishes of residents within the borough.

In fact the NPPF is very clear that the protection of the Green Belt is a core principle. While review of the Green Belt boundaries is permissible at the Local Plan stage, the intention to “roll back” the Green Belt, as stated by the planning department and as given as an instruction to Pegasus as part of the Green Belt and Countryside Study is wholly inappropriate.

The Core planning principles set out within NPPF 17 note that the plan is intended to result in “empowering local people to shape their surroundings”. In this context, the responses of residents to this consultation are critical, and should have much greater weight attached to them than the aspirations of potential developers who are not stake holders within the borough and have no ongoing long term interest in it.

Other Core planning principles included in NPPF 17 include
Taking “account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the Green Belts around them, recognizing the intrinsic character and beauty of the countryside and supporting thriving rural communities within it”
“Supporting the transition to a low carbon future in a changing climate”
“Contribute to conserving and enhancing the natural environment and reducing pollution. Allocation of land for development should prefer land of lesser environmental value [ie brownfield land]”
“encourage the effective use of land by reusing land that has been previously developed (brownfield land) provided it is not of high environmental value”
“Focus significant development in areas which are or can be made sustainable”

All of these principles should be rehearsed formally within the policy, and should be enshrined within it.

Instead, the policy notes “we will use the NPPF to judge the suitability of development in the Green Belt, including those settlements not identified in Policy 9” – ie implicitly to consider development within the Green Belt as though it is a positive and desired prospect, rather than last resort – and then goes on to talk about protection of the countryside beyond the Green Belt with a view to protecting that countryside and restricting development there in preference.

Note 4.123 states
“National planning policy requires that Green Belt boundaries are only amended in exceptional circumstances and that this must be undertaken through the Local Plan process. Given the NPPF requirement to plan for enough sustainable development to meet our needs, we have undertaken a comprehensive review of our Green Belt boundary. This will enable us to demonstrate the level of development we consider we could accommodate whilst retaining the role and main purposes of the Green Belt. We have amended the Green Belt boundary to include the specific development sites around our urban and village settlement boundaries, and to accommodate the new free standing settlement at the former Wisley airfield, as set out in Site Allocation 66.”
This is unacceptable.
It does not seem reasonable to argue for a high housing number, higher than warranted by demographics and based on flawed data (as noted by the Office of National Statistics); to refuse to apply corrections noted as required by the Office of National Statistics in relation to flawed data; to refuse to apply constraints arising from the use of Green Belt land, in rejection of repeated submisssions, formal and otherwise, by the community within the borough; and then to use that high (overstated) housing number to justify a policy of reducing the Green Belt extensively (with extensive Green Belt sites in Ockham, Horsley, Gosden Hill Farm, Send, Blackwell Farm, Worplesdon and Burnt Common – providing more than 9000 homes on Green Belt land of the total of 13040 proposed for the borough – about 70% of the planned housing provision).

If the planning policy is sufficiently aggressive as to disregard existing Green Belt, to propose significant development in that area, then it is inappropriate to consider proposing new areas for Green Belt while attacking the areas most under threat at the boundary of the London metropolitan area. It is unclear why, for example, the strategic gap that separates the Ash and Tongham urban areas from neighbouring Aldershot is of enormous significance to the borough as a whole, but that the strategic gap that separates Effingham from Bookham (and the Leatherhead conurbation, itself spreading out from Ashstead and the beginnings of London sprawl) is not even more important. Similarly, it is not clear why the boundaries between the separate villages of West Horsley and East Horsley have been so comprehensively blurred within the documentation so as to suggest that two separate villages are in fact one village, and that an extremely pretty – tiny – rural village should be swallowed up by a much larger one (also attractive, but of a different character) from which it is currently completely separated. The divisions between the rural villlages in the north east of the borough – Effingham, East Horsley, West Horsley, West Clandon, East Clandon, Ockham, Ripley, Send – are physically small but structurally important, in many cases just a few fields. To allow the building of around 7000 homes in this area will merging of settlements, and thereby, ultimately cause the merging of towns. It will cause massive congestion which is clearly unsustainable – in contravention of another core principle. Car use will be obligatory since these villages do not have the necessary facilities for urban life, and schooling, medical services and recreation are missing; the infrastructure requirements of building homes in this area have not been fully addressed by Guildford Borough Council and have resulted in some dissension between Guildford Borough Council (which will receive the Community Infrastructure Levy from building in these villages) and Surrey County Council (which will have to bear the costs associated with new roads, new schools and other matters, which are not planned for, for which land has not been allocated and which will cause further disruption and even further congestion on roads that already are gridlocked at peak times).

It does not seem reasonable to argue for a high housing number, higher than warranted by demographics and based on flawed data (as noted by the Office of National Statistics); to refuse to apply constraints arising from the use of Green Belt land, in rejection of repeated submisssions, formal and otherwise, by the community within the borough; to use that high overstated housing number to justify a policy of reducing the Green Belt extensively (with extensive Green Belt sites in Ockham, Horsley, Gosden Hill Farm, Send, Blackwell Farm, Worplesdon and Burnt Common – providing around 7000 homes on Green Belt land) and then to say within the policy that the countryside beyond the Green Belt should only be considered for rural uses, and effectively to extend to it the protections that should be currently in place for the existing Green Belt.

The Green Belt should be protected, and the five purposes of Green Belt (as set out in NPPF 80) noted in the context of GBC planning policy:
· “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”

All these purposes of Green Belt land are emphatically met by all the Green Belt areas targeted for development – and of these, the most critical is the prevention of urban sprawl. London’s conurbation stretches out in suburban extent as far as the M25 and the boundaries of the borough. Effingham, in its boundary with Bookham, and Ockham, in its boundary with Cobham, are at the points of maximum developmental pressure, and the development pressure there of the unrestricted sprawl of London, is critical to the very concept of the Green Belt.

The policy states:
“In the countryside not designated as Green Belt, only the following types of development will be permitted:
• development which requires a countryside location or where a rural location can be justified; or
• proposals for the reuse of existing rural buildings for employment, visitor accommodation or community use; or
• appropriate expansion or redevelopment of existing buildings, where the need has been demonstrated and provided the development is proportionate to the nature and scale of the site, its setting and countryside location; or
• small scale development to maintain and enhance the rural economy.

This in itself seems attractive as a policy. However, this matter is complicated; it would not necessarily be problematical if it were not for the aggressive assault on the Green Belt indicated in the planning proposals encapsulated within the SHLAA and the draft Local Plan. It would seem at the very best to be special pleading in relation to the Leader of the Council’s ward and area, and not appropriate.

This policy needs to be re-worked so that the countryside beyond the Green Belt is not given MORE protection than that within the Green Belt, as currently seems to be the case. Give this valuable agricultural land protection, by all means. But do not do so at the expense of the Green Belt. Protect the most vulnerable land first, and only when the most vulnerable land is genuinely protected, then protect the land which is at the furthest reach of the borough, furthest from London, with the longest commuting distance to London, and so at least development threat. As noted in Gallagher Homes v Solihull, the NPPF is based on PPG2 which is quoted in a similar context to this proposal:
“If such an alteration is proposed the Secretary of State will wish to be satisfied that the authority has considered opportunities for development within the urban areas contained by and beyond the Green Belt.”
In other words, before altering Green Belt boundaries (to use for building) land beyond the Green Belt should be considered as building land first; and first of all, brownfield urban land should be used. Provided that the Green Belt is not subject to the wholesale assault then this might be acceptable. It will not be acceptable as a trade-off for loss of the Green Belt in one of the prettiest parts of the borough; and it is unlikely to succeed in planning terms in any event.

It is unacceptable, having planned to build 70% of proposed new building on Green Belt land, then to say that the countryside beyond the Green Belt should only be considered for rural uses, and effectively to extend to it the protections that should be currently in place for the existing Green Belt – and, further, to extend the Green Belt in that locality. IF the need for housing and development is so overriding that it must be built on green fields, then the fields that are not currently Green Belt should be prioritized, even if they happen to lie within the ward of the Leader of the Council. This is, however, not a position that we would endorse; we consider that all countryside land is of value, and that brownfield land within the existing urban areas is sufficient to meet all reasonable planning requirements for the duration of the local plan, and that this is sustainable, rational and viable. In this context the extension of new Green Belt boundaries to the area proposed might be welcomed and regarded as desirable by all residents of the borough. But while the Green Belt is being attacked in other areas, any extension of new Green Belt cannot be countenanced, and this would seem to be justified by case law (Gallagher Homes v Solihull).

That similar attempt in Solihull was wholly unsuccessful, and the Court of Appeal decision will represent a precedent in this regard. There is a requirement, per that decision, to use other land before any Green Belt land is considered for development. There should be no thought that the land in Tongham or near Ash will “make up” for loss of Green Belt land in the east of the borough or adjacent to Guildford – it is unlikely to be granted as a Green Belt extension by the planning process,so there will be serious net loss to the borough. This is a bribe or Trojan horse, and should be seen as such.

The fact that the Leader of the Council resides in Ash and represents a ward there, and that he has appointed three other members of the Executive who also represent Ash, should not be allowed to influence policy for the borough as a whole, and this must represent a conflict of interest that cannot be allowed in the final submission.

Policy 11: Ash and Tongham Strategic Location for Growth Policy
Response Type OBJECT

The urban areas of Ash and Tongham are of importance within the borough, even though they are on the edge of the borough, and they also represent an important strategic location for growth. This does seem reasonable because they are well sited in terms of road network, and the areas are already urbanised. So the proposal to class these areas as a strategic location for growth is supported, with some reservations.

However, as noted in the comments on the preceding policy, it does not seem entirely appropriate to seek to reduce Green Belt designation everywhere else in the borough, on the grounds of overwhelming housing need, but then to propose designating 140 hectares of additional Green Belt in this area. This does not seem balanced; and it does not seem likely to succeed in planning terms either, and may in fact destabilise the local plan in its entirety, and so should perhaps be questioned.

If the planning policy is sufficiently aggressive as to disregard existing Green Belt, to propose significant development in that area, then it is inappropriate, and in contravention of existing planning law, (Gallagher Homes v Solihull as determined by the Court of Appeal) to consider proposing new areas for Green Belt. This proposal also is seeking to protect areas which are less threatened while attacking the areas most under threat at the boundary of the London metropolitan area. It is unclear why the strategic gap that separates the Ash and Tongham urban areas from neighbouring Aldershot is of enormous significance to the borough as a whole, but that the strategic gap that separates Effingham from Bookham (and the Leatherhead conurbation, itself spreading out from Ashstead and the beginnings of London sprawl) is not even more important.

The desire to protect the strategic gap between Ash and Tongham and Ash Green is warmly welcomed, and provided that this does not arise because of a loss of Green Belt land elsewhere, the proposal to include some of this land within the Green Belt is welcomed too. However, if there is a trade-off, then the Green Belt designation should not be given to this new area because other areas have lost their Green Belt status. In any event this strategy is in itself likely to cause the plan to be unsound because it will not comply with planning law; this proposed extension of Green Belt designation to Ash and Tongham is unlikely to succeed, because it is not inherently better at serving the purposes of the Green Belt than other areas threatened by development, and a similar attempt in Solihull was wholly unsuccessful, and the Court of Appeal decision will represent a precedent in this regard.

As noted in Gallagher Homes v Solihull, the NPPF is based on PPG2 which is quoted in a similar context to this proposal:
“If such an alteration is proposed the Secretary of State will wish to be satisfied that the authority has considered opportunities for development within the urban areas contained by and beyond the Green Belt.”
In other words, before altering Green Belt boundaries (to use for building) land beyond the Green Belt should be considered as building land first; and first of all, brownfield urban land should be used. Provided that the Green Belt is not subject to the wholesale assault then this extension might be acceptable to the wider community within the borough. It will not be acceptable as a trade-off for loss of the Green Belt elsewhere.

It is also not clear what the impact will be of designating SANG in this area, and whether this will be used to permit building on Green Belt or land otherwise protected because of the Thames Basin Heath SPA designation elsewhere.

It is also noted that – unlike other areas within the borough – there is much attention to the required infrastructure in terms of sufficient school places; improvements to the capacity and provision of new Doctors and Dentists’ surgeries; improvements to the local road network; and provision of a local centre. Such reference is not made in relation to the policy on Homes for All. It would seem appropriate to take the section of the policy included within policy 11 below

“We will produce a vision and subsequent Supplementary Planning Document to illustrate how development proposals for new homes and jobs in the strategic location will contribute to the provision of the following infrastructure:
• Suitable Alternative Natural Greenspace (SANG)
• sufficient school places
• improvements to the capacity of or provision of new Doctors and Dentist Surgeries
• improvements to the Local Road Network as outlined in the Infrastructure Schedule
• provision of shopping appropriate community and social facilities to meet the needs of residents”

The phrase relating to SANG could usefully be deleted, since SANG is a complex matter. To grant “Suitable Alternative Natural Greenspace” designations has implications in terms of substituting planning permissions elsewhere- if one area becomes SANG, then another green space elsewhere becomes available as a building site. Green space that is already green space (and hence suitable for SANG designation) will not become greener due to a new designation (probably less so, since it will require a new car park) – this is merely a window for development in other locations. So this phrase should be completely deleted.

With the exception of that phrase, it is proposed that this section is deleted from policy 11 in its entirely and the blue text above inserted instead into Policy 4 – “Homes for all”. All new homes will require access to roads, doctors, dentists, education for children and local community centres, not just Ash & Tongham.

Other parts of the borough might wonder why such particular provision is being made for Ash and Tongham in particular – the designation of a policy in the Local Plan for these two areas alone – rather than in relation to all new developments.
Again, the fact that the Leader of the Council represents these wards should not imply a disproportionate attention to the needs of residents in this area; he should remember that he is leader of the whole of Guildford Borough Council, not merely the councilor for Ash and Tongham.

Policy 12 Historic environment

Response type: Object

As with other comments there is an element of support to this response, but it cannot be wholly supported and the balance is therefore to object to the detail of this policy. There should be more emphasis on protection and less on the nature of acceptable “development” in the context of the historic environment.

The wording of NPPF 126 and NPPF 131 is that local authorities “should set out a positive strategy for the conservation and enjoyment of the historic environment”…In both developing this strategy and in determining planning applications, local authorities “should recognise that heritage assets are an irreplaceable resource and conserve them in a manner appropriate to their significance…and take into account:

the desirability of sustaining and enhancing the significance of heritage assets and putting them to viable uses consistent with their conservation
the wider social, cultural, economic and environmental benefits that conservation of the historic environment can bring
opportunities to draw on the contribution made by the historic environment to the character of a place.”
As noted in NPPF 132 “great weight should be given to an asset’s conservation. Significance can be harmed or lost through alteration or destruction of the heritage asset or development within its setting”.

The emphasis in this proposed policy on enhancement seems to imply that the assets in the borough are in a state of general decay, but in fact the most important emphasis for most of the heritage assets is protection, preservation especially from inappropriate adjacent development.

As a result, the comment in the blue policy box Policy 12 “We will support development that recognises, protects and enhances the borough’s distinctive heritage and landscape assets, character and their settings, and will seek to ensure that it makes a positive contribution” is of some considerable concern. Development should be restricted in proximity to the borough’s heritage assets, in accordance with NPPF 132 and NPPF 126 and particularly NPPF 133

“Where a proposed development will lead to substantial harm or to total loss of significance of a designated heritage asset, local planning authorities should refuse consent unless it can be demonstrated that the substantial harm or loss is necessary to achieve substantial public benefits that outweigh that harm or loss”.

The wording of the second part of the draft policy includes: “Where new development would have an impact on heritage assets, it should make a positive contribution to local character and distinctiveness having regard to the significance of the heritage assets and their setting”. In fact most residents within the borough would prefer a local plan that emphasises the importance of heritage assets and seeks to preserve and protect them. This will have a beneficial impact on the environment for local people and also have a positive impact on local tourism, and other ancillary industries, economically important within the borough, such as tourism.

Policy 13 Economic Development

Response: OBJECT

Re note 4.141 NPPF 7 does indeed note that one of the three strands of sustainable development is the economic development element which involves “ensuring sufficient land of the right type [preferably brownfield] is available to support growth and innovation.” Of course the other two, equally important strands to sustainable development outlined in NPPF 7 are the social role which includes creating a high quality built environment which reflects the community’s needs and the environmental role, which means “protecting and enhancing our natural built and historic environment”. Environmental protection is as important within the definition as economic development, and Guildford Borough Council is in danger of forgetting or ignoring this. NPPF 8 notes specifically that “these roles should not be taken in isolation[ which this note specifically is choosing to do, in contravention of NPPF7 and 8] because they are mutually dependent’.

NPPF 10 also notes that plans and decisions need to take local circumstances into account so that they respond to the different opportunities for achieving sustainable development in different areas.

NPPF 13 notes that planning authorities “should meet objectively assessed needs unless any specific policies in the Framework indicate development should be restricted”. Nick Boles has written to Anne Milton MP and Sir Paul Beresford MP in relation to the proposals in the Guildford Local Plan in specific relation to this plan quoting his note to Inspectors that Green Belt is such a policy – so development should be restricted because of the constraint imposed by the Green Belt.

NPPF 17 notes the requirement to “proactively support sustainable economic development.” Guildford Borough Council seems to have forgotten the sustainable element here, as ever. Economic development can be supported proactively if sustainable, and taking the environment and the local circumstances into account. There is not a requirement for aggressive unsustainable growth ignoring local constraints, environmental factors and circumstances. The other core principles included in NPPF 17 include empowering local people to shape their surroundings, take account of the different roles and character of different areas including protecting Green Belts; conserve and enhance the natural environment- (and note, as a core principle, that allocation of land should prefer land of lesser environmental value), reusing brownfield land, and conserve heritage assets .

Note 4.141 continues with a quotation from NPPF 20. But NPPF 20 is subsumed as one clause within the economic subdivision of NPPF referring to Sustainable Development (1 Building a strong competitive economy NPPF 18-22). It is not a core principle and the emphasis cast upon it is a distortion of the 12 core principles and 3 fundamental dimensions of sustainable development within the planning system.

Note 4.142 refers to the Corporate Plan. This is a document issued by the Council in October 2013. After repeated demands to see it from members of the community, since it was alluded to in the Issues and Options document, it was finally made available on the GBC website in November 2013, just at the time the Issues and Options consultation was closed (so no comment on this plan has ever been possible). It has never been subject to formal consultation or approval by the community, nor have the principles within it been discussed, although the draft Plan refers to it having been consulted upon. There appears to have been some extremely limited form of selective questionnaire on corporate strategy referred to in the evidence base (with reference to very few, unnamed, “members of the public”) but this document was not the subject of a widespread enquiry, and the Corporate Plan, in its final form, has not been offered to the public for consultation at all.

Most people within Guildford would not agree with the Corporate Plan that there is a need (note 4.143) that one of the priorities is to increase the availability of commercial space required for businesses to grow.

There is substantial unused employment land within the borough.

There are a number of empty retail units in Tunsgate Square and it has been reported that there is difficulty filling these units – clearly the case since some units in this high quality, central development have been empty for years. The Next development on Ladymead has moved more town central type retail into a shed/out of town format on a trading estate. On this basis it is not clear that there is the capacity for retail development that is proposed by the Council both in terms of the North Street development and the future master vision in relation to Bridge Street and the river corridor. There is appetite for central residential development that is being suppressed in order to favour retail development; but the probability is that, certainly with the proposed restrictions on car use in the town centre, and existing high car parking charges and limited parking availability, that there will be little need for the proposed retail development. Again the report is anecdotal but it appears that the North Street development is not clear cut in terms of retail profitability, which would seem to explain in part the protracted delays in the process of development of that brownfield area.

In terms of industrial and commercial sites, there are sites vacant at Midleton industrial estate (one of which owned by GBC has just been converted into a trampolining business); Slyfield industrial estate; Merrow Depot; Walnut Tree Close; Cathedral Hill commercial centre and many other areas.

This would seem to argue that there is an ability to support existing businesses and that there is already an appropriate quantity and range of employment land in the borough to enable the local economy to function efficiently [Note 4.142].

Given that the LEP is concerned that future growth is likely to be restricted by congestion (note 4.152); that the roads within the area are already severely congested; and that increased housing and any increase in commercial land will increase congestion further; the capacity of the area to cope with major growth would seem to be limited.

On this basis, the intention to provide 10900-14800 B class jobs would seem to be questionable. As defined by Appendix 1 to the Local Plan, these are defined as follows:

“These are defined in the Use Classes Order 1987 (as amended):

B1: Business:

a) Offices other than in a use within class A2

b) Research and Development- laboratories, studios

c) Light industry

B2 General industrial the carrying on of an industrial process other than one falling within class B1 (excluding incineration purposes, chemical treatment or landfill or hazardous waste)

B8: Storage or distribution- storage or as a distribution centre (including open air storage)”

Note that this precludes financial and professional uses including any services (which are class A2). As a result, this means that the employment is tending to presume lower education profile, and fewer professional and highly qualified jobs.

This is questionable in an area where employment is already high; where the population is more highly skilled and educated than the national average and where jobs are also more highly paid than the national average. It is not intelligent to plan on storage or distribution in this area, nor light industry or general industrial processes. Workers here are in short supply and relatively expensive. As noted in the Foreword by Stephen Mansbridge “We recognize that Guildford is an expensive place to live and work.” And as noted in Key Facts to the Local Plan “the workforce is generally well educated, highly skilled and well paid”.

It is arguable that there is a need to feature the high skills of the university and the tech areas that will follow from the university skills base. However, there is already vacant space on the Cathedral Hill industrial site and other sites which can be used for this development.

Furthermore, much of the highly skilled growth areas are not particularly land hungry. This is evidenced if anything by Old Street Roundabout in London – a physically small geographical area which commands an international reputation as a technological centre. Also the “smart” growth which is most profitable, and which could trade on the skills of the University and the highly skilled work force can involve either professional offices (not included in the land proposals above, and not land hungry either) or can involve high levels of hot-desking and home-working.

We are continually told that the existing population need homes (although not as many as are indicated, clearly); and that they are almost fully employed. On this basis, it is unclear that there is a need for these jobs, and if this land is reserved, the jobs will create further congestion.

There is heavy reliance on the Employment Land Assessment. All commentators, including the Scrutiny Committee, have noted that there are failings in this document and that it needs to be re-worked. As a result it is a poor basis for any kind of policy analysis, and the evidence will be contested and challenged if it is relied on to formulate policy.

As a result, it is entirely unclear that there is the need proposed for 21.6 to 29.2 hectares of new land for 10900 -14800 jobs – land hungry, relatively low skilled and low tech, and unlikely to find workers who can provide the relevant low skills at an attractive price in this well paid, highly educated enclave.

Furthermore, as ever, the urban guided planning philosophy also entirely fails to recognize the real phenomenon of rural employment. Some of this is genuine “smart” growth of the kind that the council ought to be promoting, and states that they are keen to encourage (Note 4.151). Faster broadband, where it exists, is a genuinely useful tool which allows remote working for the highly educated populace. The University of Surrey generates a significant proportion of this highly skilled group. It also boasts about the highly skilled external population and the high calibre of local residents in its publicity material. The Surrey Hills AONB is proud to be classified as an “Elite Employment Enclave” where a high proportion of around 40% of households include a company director; such groups can often work flexibly. However, too much industrialization, commercialization and physical building will result in a change in the environment that attracts these flexible and affluent members of the community, and would result in these same groups moving to a more desirable and pleasant location. This would have a negative impact on the local economy.

In addition to smart working among an educated group, and its economic upside, there is the fact that the rural area is founded on an agricultural framework that has persisted for two thousand years and is a viable, successful and profitable series of businesses. The land on which GBC proposes to build is viable and profitable agricultural land which supports existing businesses. Some of these are simple farms, producing food which our country needs. This should not be underestimated. The University of Cambridge has noted a significant decline in the UK’s food security or ability to feed itself – a significant factor in an era of increased climate change and global insecurity. This report, produced in conjunction with a number of other groups including CLA, NFU, Sainsbury’s, Asda and Nestle noted that the UK would require up to 7m hectares more agriculatural land to meet the country’s needs for food by 2030, roughly the period covered by the plan. To replace valuable and necessary agricultural land with storage depots which will make the environment unpleasant for residents, destroy a viable business, and that are likely to remain empty and unprofitable unless they undercut existing viable depots elsewhere, seems to benefit only those who build the depots.

In addition to the essential task – which, please note, is a business – of food production, an increasing number of our farmers are engaged in high added value food processing and delivery, which is also an extremely profitable business and of growing local interest. The Surrey Hills label is helpful in this regard, and the local farmers’ markets and farm shops are increasingly important and highly profitable outlets. The Tillingbourne Trout Farm, the Kingfisher Watercress beds, the raising of beef, lamb, pork, and poultry in the Surrey Hills at Drydown Farm or Manor Farm; the grapes grown to make sparkling wine around Silent Pool, the Hog’s Back brewery, fruit grown throughout the borough and many other businesses are of enormous significance to the borough and should be encouraged. It will be harder to cultivate a label advertising premium quality organic food from the North Downs if it becomes known principally as a storage depot for IKEA and Argos.

And, as noted in the section on tourism, the tourist sector is a major influence, along with the increasing film business, on the economy of Surrey. Too much low grade development and you will kill the goose that lays the golden (guilden) eggs.

Economic growth is indeed needed by the country. Some of that growth is perhaps needed in Surrey, although we already produce a disproportionate share of the national wealth and are the most densely populated rural county. Many would argue that this is not an appropriate destination for economic pump-priming and that areas which have more need of employment, (for example in the Black Country, the North West, the North East or Wales) would be better recipients of Government finance to encourage economic growth. We don’t particularly want it; we don’t particularly need it; and we are trying to cope with the organic growth we have, we certainly don’t need to stimulate it further. The M3LEP has a stated agenda, evidenced by its minutes, of influencing government policy in relation to housebuilding; and this is perhaps because housebuilders sit on the Land and Property Group of the M3 LEP, which would once have constituted a conflict of interest and certainly still appears to do so as far as the public are concerned.

But the ability to generate wealth is not related to the size or number of warehouses built. This is unintelligent and old thinking – wealth is not related to the size of factories. If anything, there is a converse relationship. Build factories and warehouses, increase congestion, see the town centre stagnate with empty retail centres and more small empty shops, and the countryside become sterile – becoming a medium size undistinguished town or outer suburb with a huge hinterland of sheds and Edge City, on the outskirts of London’s urban sprawl, akin to perhaps Croydon, and destroy jobs, destroy the economy locally, and reduce the attractiveness of the area for corporate headquarters or highly skilled business, for film and tourism, and indeed for some who might be attracted to come to Surrey University.

Protect the Green Belt with minimal or no incursion; don’t build any new warehouses and use the already allocated industrial land more efficiently; increase the broadband speeds throughout the borough; and watch the economy grow.

Policy 14: The leisure and visitor experience
Response Type SUPPORT

The importance of tourism and leisure within the borough is acknowledged by GBC, and thus far this policy is welcomed. As a result, the principles underlying this policy are given measured and qualified support.
The emphasis however on development in order to facilitate tourism seems fundamentally misguided, and, as in other areas of the plan, seems to regard both the planning function and local government as a whole as the marketing and sourcing department of the building and civil engineering industries. This is inappropriate and therefore this element merits objection. This area of England is important, and it is primarily visited by tourists, not because of tourist centres nor even because of rural sites of significance such as Clandon Park or Hatchlands Park, important though those National Trust sites are.

The importance to the borough of the countryside qua countryside, embodying rural tourism, rural agriculture and its related impact on the local economy cannot be overstated. In this part of England agriculture is prosperous and prospering; and the importance of the countryside to the country as a whole is enormous. People want to visit the countryside – and then choose for example a National Trust house to be a particular focus for the visit. But it is the agricultural rural idyll that draws the visitors, and if it becomes too tourist managed, it will be damaged.

It should also be noted that activities such as Duke of Edinburgh walks rely heavily on the North Downs for schools in most of the South West quadrant of London. These schools would not send parties of teenagers through the countryside every weekend of spring and early summer if the sites were overdeveloped. Walks along the nationally important North Downs Way or Pilgrims’ Way are of enormous popular importance to all sections of the community. These do not need “facilities” except the informal facilities of cafes, pubs and restaurants that exist within the villages.

The National Gardens Scheme is hugely popular in attracting visitors to the area, as are schemes such as Shere and Peaslake Open Gardens. These typically attract significant numbers of visitors, with a significant impact on charities both local and national, but also of course encouraging visitors to our area, with a consequential beneficial impact on the local economy.

Furthermore, it should be noted that the cycle trips that are of increasing national importance rely heavily on the Surrey Countryside. It was not accidental that the Olympic cycle route was routed through the Surrey villages, through or past Ripley, Ockham, Clandon, Shere and Gomshall; and that this was regarded as the archetypal illustration of the English countryside at its best for an international audience; and it is not accidental that these cycle races have been repeated and extended many times with at least an annual anniversary of the Olympic route and many sub-cycling tours in addition; the countryside, not the specific sites within it, is a key attraction.

Lack of development is in itself a key element of the attraction to tourists, and this should not be disregarded as a key element of the planning process, which should constrain inappropriate development as much as it should promote development which is socially and environmentally desirable (eg in the renovation of brownfield sites).

The agro-tourism sector has also been ignored. While slightly outside the borough, Denbies wine is becoming internationally regarded, and this is being replicated within the borough too. (Even the Queen serves sparkling wine from our hills near Silent Pool..) Watercress, beer, lamb and beef, trout and cheese are all produced locally in our countryside – those viable industries exist on land which house builders would like to turn into unproductive and stagnant executive homes – killing the tourism goose that lays the golden eggs.

Set out below are extracts from the submission to the Issues and Options consultation by the Burrows Cross Area Residents’ Association which indicates, just for the villages within the ward of Shere, some of the tourist sites which are of historic, cultural and tourist interest. These are illustrative only, and many other areas within the borough have equivalent points of local and regional interest. It indicates some of the tourist significance of this area. It should be noted that tourism relies heavily on the agricultural and rural qualities of the landscape in the area, not just to visit particular sites but for walking and cycling on a routine basis.

Extracts from issues and options consultation:

NPPF 132 notes an obligation to restrict development in the vicinity of heritage assets. It has already been noted that heritage assets are significant in the villages of Shere (Norman church (1190), mediaeval village buildings (The Old Forge, The Old Prison, Weaver’s House, Wheelwright Cottage), many other listed buildings including the restaurant of Kinghams in a mediaeval building or The White Horse pub, filmed in The Holiday (tourism, local business)) and Gomshall (17th Mill, tudor houses including the King John House, NT property and land at Netley House). The area also has bronze age hill forts, a Roman temple, High House Shere (1630, Grade 2 listed).
This brief history of Shere (incorporated in full by reference) gives an indication of its historical importance: http://www.sheredelight.com/history.html
This website also gives an indication of the importance of the undamaged nature of the villages and the surroundings to an important local industry, which is filming. See http://www.sheredelight.com/films.html. It should be noted that NPPF enjoins local authorities to consider the impact of development on any existing business, and that if this is adverse, then they should not give permission. The impact on the film industry of any development in this area should not be underrated. This would have a significantly negative impact on the local economy of the borough as a whole.
Gomshall’s history is summarised usefully on the Wikipedia site: (incorporated by reference): http://en.wikipedia.org/wiki/Gomshall. This notes that the Manor of Gumesele was a Saxon feudal landholding; that Gomshall appears in Domesday Book of 1086 as Gomeselle. It was held by William the Conqueror.
In 1154, Henry II of England divided the Manor of Gumesele into three: West Gomshall (granted to an abbey in Netley so known as Netley after 1240), East Gomshall (granted to an Abbey in Tower Hill in 1376 so now known as Tower Hill) and Somersbury (now Gomshall). This demonstrates that the current boundaries of the village are recognizable from the Domesday book, and that this is in itself of cultural importance. To develop on land adjacent to these boundaries would be wholly inappropriate since that would be to alter the village boundaries that have lasted on a very long term basis as permanent and established features of the landscape, as required by NPPF.
Local industries developed based on the plentiful and constant water supply of the River Tillingbourne. Leather tanning is a historic industry, now gone. Gomshall Mill was the corn mill. Some other businesses based on the Tillingbourne survive, and would be damaged by over development. These include watercress growing (at the Kingfisher Watercress Beds in Abinger) and trout farming (between Abinger and Gomshall, in the area bounded by this study – for both of which clean water is a particular essential ingredient. Damage the water supply and you will kill the business). In addition to these food suppliers, many of the local fields are farmed organically and contribute to the Surrey Hills organic food brands (beef, lamb, pork). The importance of the agricultural industry should not be ignored; it is not reasonable to perceive that building a house is “Growth” or “development” while destroying a farm or an agricultural business (which of course economically is negative growth). Those farms have a hugely positive tourist impact too.
The AA has prepared a walking guide of historical sites associated with Romans and Celts in this parish. http://www.theaa.com/walks/with-the-romans-and-celts-at-farley-421068
The area of Abinger Roughs and Netley Park is listed on the NT website; this link is incorporated into this section by reference: http://www.nationaltrust.org.uk/abinger-roughs-and-netley-park/how-to-get-here/?findPlace=Abinger%20Roughs%20and%20Netley%20Park&type=&view=map. The guide to the locality from the NT (see website link, incorporated by reference) is relevant in the context of local wildlife, which are abundant throughout this parish not just in the area identified by the NT. http://www.nationaltrust.org.uk/cs/Satellite?blobcol=urldata&blobheader=application%2Fpdf&blobkey=id&blobtable=MungoBlobs&blobwhere=1349108282364&ssbinary=true
NPPF 126 notes that local authorities have a duty to recognise that heritage assets (and their setting) are an irreplaceable resource and that they have a duty to conserve them.
NPPF 123 notes that planning decisions should protect areas of tranquility which have remained relatively undisturbed by noise and are prized for their recreational and amenity value for this reason. In this locality the most prevalent noise is that of birdsong. It is not appropriate to consider this as a possible area for development.
NPPF 118 notes that planning permission should be refused for development resulting in the loss or deterioration of irreplaceable habitats.
The NT guide to Netley Park and the Abinger Roughs notes in the context of local wildlife: “Lots of birds can be seen and heard on the Roughs. Near the rhododendrons is a good spot – look out for: goldcrests, woodpeckers, wrens, treecreepers, song thrushes, chaffinches and dunnocks.” Some of these species, and also the other species noted by the NT such as noctule bats, are of conservation importance and they should not be disturbed. (Source: http://www.nationaltrust.org.uk/abinger-roughs-and-netley-park/wildlife/).
NPPF 115 notes that “Great weight should be given to conserving landscape and scenic beauty in National Parks, the Broads and Areas of Outstanding Natural Beauty”. It is not acceptable to destroy any part of this area, protected over the last two millennia and substantively unchanged, in order to make a short term developmental profit even for a tourism related project. It further comments that the conservation of wildlife and cultural heritage are important considerations in all these areas. NPPF 116 notes that planning permission should be refused in these areas except in exceptional circumstances. This should be incorporated into the local plan.
Overriding force should be given to the Green Belt provisions of NPPF 88 and 89 which generally notes that substantial weight should be given to any harm to the Green Belt and that the construction of new buildings is generally inappropriate.
GBC should be reminded that the AONB has status equivalent to that of a National Park.
Interestingly in National Parks, the National Park authority has overall responsibility for planning policy. For the South Downs National Park, the guidance is of relevance http://www.southdowns.gov.uk/__data/assets/pdf_file/0013/123232/Agenda_Item_8_Appendix_1_20101203.pdf. This states:
“National Parks have two statutory purposes which must be taken into account when considering planning proposals that could have an impact upon a National Park.
1. To conserve and enhance their natural beauty, wildlife and cultural heritage
2. To promote opportunities for the public understanding and enjoyment of these special qualities.
If there is a conflict between these two policies then the first must take precedence.”

Other guidance is worth noting. The National Parks and Access to the Countryside Act 1949 legislated for the designation of AONBs and National Parks. Their purpose was to be similar – to conserve and enhance natural beauty. The Countryside Commission defined the purpose of AONB designation in a statement of 1991.
Purpose of AONB Designation
• “…Is primarily to conserve and enhance natural beauty.
• In pursuing the primary purpose of designation, account should be taken of the needs of agriculture, forestry, and other rural industries and of the economic and social needs of local communities. Particular regard should be paid to promoting sustainable forms of social and economic development that in themselves conserve and enhance the environment.
• Recreation is not an objective of designation but the demand for recreation should be met so far as this is consistent with the conservation of natural beauty and the needs of agriculture, forestry and other uses.”
Areas of Outstanding Natural Beauty: A policy statement (Countryside Commission, CCP 356, 1991), p5
AONBs and National Parks are recognised in England to be on a par legally because of their nationally important landscapes. The National Planning Policy Framework confirms that AONBs are equivalent to National Parks in terms of their landscape quality, scenic beauty and their planning status.
The statutory duty enjoined upon GBC is not to seek to develop but to protect this area – “to conserve and enhance natural beauty”. GBC appears to have objective seeking growth which is in conflict with the requirements to protect. This is already covered by NPPF in relation to Green Belt status, which is in itself glossed by ministerial guidance, as previously noted (Eric Pickles, Brandon Lewis and others).
Development within the AONB of any form is likely to be damaging. In addition to the overriding restriction on such development under NPPF, the following statement referred to by Natural England is of significance:
“The United Nations Environment Programme (UNEP) has recently drawn attention to studies finding that although developed land covers only a small proportion of North America’s land base, it has a large impact on ecosystem services. For example, roads occupy just 1% of the US land area, but they alter the ecological structures and functions of about 22% or more of the land. In US regions with rapid ‘exurban’ (or extensive residential) growth, species richness and endemism diminish as urban cover increases, threatening biodiversity. The fragmentation of natural habitat threatens more than 500 endangered US wildlife species with extinction. It also provides new entry points for invasive species already introduced through other pathways”. 13.Source: United Nations Environment Programme, Global Environment Outlook GE04 – environment for development , 2007,
p.259 at Box 6.30, itself quoted by Natural England.
In other words, seeking growth of any kind within the AONB is inherently undesirable and in conflict with the overriding principles of biodiversity, and therefore sustainability.
In particular, in relation to the area around Gomshall, Shere and Peaslake, these villages within the AONB are defined within boundaries established over the last thousand years, with the sites of the villages recognisable from the Domesday book boundaries. While there have been some houses built in the rural surroundings, these are few and disparate.

The defined quality is one of the most attractive features of these villages, and that causes many film makers to choose these villages as archetypal English villages.

Policy 15

Guildford Town Centre

Response: OBJECT

You can respond to this policy by clicking this link:


Guildford Town Centre is historically important with a beautiful High Street, an historic Guildhall, a very important Castle which is not sufficiently protected or developed as a tourist attraction, views out to the surrounding Green Belt, and a thriving retail economy which does not depend on monolithic standard high street shops but which has a surprising number of individual shops which are still successful. It is unusual in that the High Street has few empty shops (although there are vacant spaces in the Tunsgate development, which is a warning for excess development and shows the risk of moving the retail centre from the existing High Street). Sightlines, and the framing of the town centre views within the surrounding countryside, should be a key element of policy. A supplementary planning document for the town should be subject to the central consultation within this plan or the plan itself, dependent on what happens to the central planning area, may be deemed invalid (cf Wandsworth Local Plan, where the local plan as submitted was sufficiently different to that consulted on that it was rejected by the Inspector).

There is nothing in the policy to stress the importance of preserving the town centre or protecting it.

This policy lack design requirements – which are permitted and encouraged under NPPF 59, in that these “should concentrate on guiding the overall scale, density, massing, height, landscape, layout, materials and access of new development in relation to neighbouring buildings and the local area more generally”. Design policies should be included within the local plan in relation to all new buildings, and this is an area on which there will be very strong local views, especially in relation to sightlines, height, landscape, massing and scale. It is unclear why the local plan is so vague in this area, and this is a matter that requires remedy. Arguably, the vagueness, and the lack of detail, are such that the Local Plan will require a second (additional) consultation prior to the formal consultation on the submission stage. IF this is not done, it is arguable that the plan is sufficiently vague and uncertain that it is not a formal consultation document but just another issues and options document, and so a further consultation may be required by an inspector.

This is not a town that will be improved by 50 0000 sq m additional retail floorspace (note that the amount set out in the Policy is MORE than that set out in detail in Note 4.178 , just as the housing number is LESS than that set out in the SHLAA). This is a bias towards retail and commercial, and away from town residential development that means that this policy is designed to focus the town centre as a shopping mall, to the exclusion of residents, and is contradiction to the evidence base or the process of consultation as proposed. The introductory emphasis of Note 4.170 that “Guildford’s retail and service centres are the heart of our communities” is a comment that may be seriously contested by many of the residents of the borough.

The lack of integration with the Master Vision document as drafted by Allies & Morrison is of some concern in this policy. It is notable that this is alluded to but that the document is not incorporated by reference and is subject to a separate and not integrated consultation exercise. It is therefore unclear that this Local Plan has been properly consulted on and this is cause for concern.

Another, extremely profound cause for concern is the preference for building on Green Belt land as opposed to the land within Guildford Town Centre.

It is notable that the Policy restricts the number of potential homes to be built within Guildford Town Centre to 1500, even fewer than implied within the SHLAA document. This is in contradiction to note 4.176 which states – outside the policy “As the most sustainable location in the borough, Guildford town centre is the most suitable location for the larger developments of town centre uses, and for housing”.

This policy is inherently flawed. It is unclear from the drafting whether Guildford Town Centre relates only to the Town Centre or to the whole urban area, and this is an unacceptable vagueness.

Either way, as set out in the introduction, the proposal is to build 13040 homes (itself a number subject to dispute); the Local Plan is limiting the number to be built in the town centre to a mere 1500 or 11.5% of the total housing proposed, having noted that it is the most sustainable centre for housing. Currently approximately 50% of the population of Guildford Borough live within this one urban area. The proposals suggest an expansion of the population of the borough by 25%, of which 90% will be on extra-urban areas; in other words, the character of the town will be dominated by a shopping centre (possibly large and monolithic – certainly substantial) and the surrounding green countryside will become suburban extra-London sprawl. This is not a recipe for growth and success; it is a recipe for damaging the character of the area, both town and country, beyond all repair. If some of the brownfield land in the town were allocated – at medium urban densities, on a low rise basis – for good quality well designed housing – then the Green Belt could be protected. The council will lose some CIL payments from developers but this should not drive policy nor should it determine planning decisions. The builders may lose potentially lucrative sites set in attractive countryside but this is the point of having a planning policy.

This figure of 1500 to be built in the town centre would seem to be a numerical error in any event. It is recognised in the notes to the policy that the town centre is the most sustainable location for housing. The most current version of the SHLAA published in June 2014 notes that the available sites for building in the town centre are 1929. So 1929 is a minimum number of homes that can be built in the town centre and urban area, and the SHLAA notes that this does not include any new homes to be built in the North Street redevelopment area. Why is the policy EVEN less than that set out in the SHLAA?

It is arguable that more use of the Walnut Tree Close area could generate more housing; not on a high rise basis, but on a higher density basis, especially with smaller homes which are targeted at first time buyers or young families, as opposed to the 5 bedroom homes which developers wish to build on the Green Belt.

It is noted that the largest areas of industrial brownfield land within the borough are particularly in the Walnut Tree Close area and in the Slyfield industrial area.

These areas could support much more housing than the relatively small numbers indicated in the policy on the town centre, under a town centre regeneration scheme. This would have huge benefits for the community as a whole since relatively run down areas would be subject to regeneration, the river banks would be cleaner and more attractive. Density could be reasonably high; it is recognized that Victorian terraced homes can give a density of 200 dph. This is not very different from the proposed town centre densities being envisaged by the Council in internal documents, so these should be included in the consultation process.

It is vitally important for the borough as a whole, including for the benefit of the town, that the run-down Walnut Tree Close area is used for well designed housing, as indicated by the Mastervision document first draft compiled by Allies and Morrison. John Rigg of Savills and Guildford Vision Group has indicated to the Scrutiny Committee of GBC that initial commercial projections indicated that the Walnut Tree Close area alone could provide 4000 homes (which compares with the projection from GBC of 370 homes in the same area). Allies & Morrison, who have expertise in urban regeneration, initially indicated that they believed that this site could be available for regeneration within the critical 5 year window required for the local plan. This is in accordance with the requirements of NPPF 51 which notes a requirement “to identify and bring back into use empty housing and building in line with local housing and empty homes strategies, and should normally approve planning applications for change to residential use and associated development from commercial buildings (currently in the B use classes) where there is an identified need for additional housing in that area”.

As has been noted elsewhere, for reasons that are not altogether clear but appear to be connected to a misunderstanding of central government direction and a desire to maximize the Community Infrastructure Levy, there is an aggressive desire to push development on to the Green Belt at all costs, ignoring or eliminating for other reasons sites which could be used in the town for residential purposes. This has informed recent planning decisions (both the Aldi site and the Waitrose site were originally zoned for residential purposes and were eminently suitable for this) and this bias seems to be informing the Local Plan.

That regeneration zone would be highly sustainable, because it would be within 1 mile of the railway station, adjacent to the A3, and would eliminate an area of huge congestion in the town because if the industrial sites were replaced by housing then the residents would commute by train or walk to work rather than having to drive in to an industrial estate.

It certainly does not seem appropriate to create substantial new parkland on current hard standing. The protections to which this policy refers largely describe existing open space, which is of great importance. But to determine not to utilize brownfield land for residential use at an appropriate density in order to force building on to the Green Belt would seem to be in contradiction of the principles of use of the Green Belt applied in the Gallaher Homes v Solihull court of appeal case, where the hierarchy of use is clearly defined, with urban brownfield required to be used as a first option.

However, the local plan appears to be distorted due to the influence of housebuilders who sit on the M3LEP planning committee, and have a stated agenda of wishing to develop the Green Belt and to influence both local and national policy accordingly. This appears to the community to represent a profound conflict of interest, and one which the planning process should be designed to control, not accommodate.

Notes 4.177 to 4.183 deal with an aggressive expansion of retail capacity within the town, from the existing 58383 m2 (basic retail need) plus 12646 m2(convenience) (IE current total 71027 m2).

This is intended, by 2031, to increase to 95483 m2 plus 13858 m2, a revised total of 109352 m2). This is a gross increase of almost 54% compared to the current level of retail; and, setting the lower increase in convenience need to one side, and increase of 63.5% in core retail. This is a ridiculous strategy in the current economic climate. It is concerning that there is an implied intention to expand local centres for retail further outside the main town centre in addition to the excessive proposed expansion in the town centre.

Retail is a declining market, certainly in physical terms, and most town centres are expected to have less rather than more retail over the next few years. This has been discussed by Deloittes, which in reviewing UK market trends anticipates a decline in retail over the next 3-5 years of between 30 and 40 per cent. http://www.deloitte.com/view/en_GB/uk/industries/consumer-business/issues-trends/fc69973880fa5310VgnVCM2000001b56f00aRCRD.htm

This is endorsed by the Centre for Retail Research which anticipates a loss of 22600 stores, and a decline of 22%. http://www.retailresearch.org/retail2018.php

No commentators are expecting an increase in retail requirement of 63%, in a town with limited and arguably decreasing car parking, and an increasing population. The proposals within this plan propose an increase in local population of 25%, a decrease in car parking, and significant expansion of cycling as a means of transport. On this basis, it is unclear why people will be increasing the amount of physical (as opposed to online) shopping in which they engage. As a result, it is not at all clear that the existing retail profile of the town can be supported, and the aggressive proposed expansion seems to be a recipe for vacant sites, leading to a diminution in overall retail viability and an increased failure rate for existing businesses.

It should be noted that Kingston, a larger and more dominant local retail competitor, is also expanding its retail offering. There are only so many shops that a region can support, certainly now.

Tesco is unlocking its landbank to build homes rather than stores at present because of changes in shopping habits:


The capacity for more retail within the borough is limited; and given congestion and limited car parking this is not a sane strategy for the borough. Less aggressive retail expansion, with less dominant anchor tenants, would generate much more land for brownfield redevelopment use and would not require nearly as aggressive a landtake from green belt sites. This would be preferable for all residents of the borough. There may be some concern about congestion from town residents, but it should be noted that retail expansion is likely to generate much more substantial vehicle use (both commercial and personal) than local residents.

The North Street redevelopment project currently appears skewed in its priorities. It is understood that John Lewis is being approached as an anchor tenant; but like many anchor tenants is likely to have very considerable requirements in terms of land use, car parking access, reduced rental payments etc which will skew the overall retail requirement of the redevelopment, reducing the amount of residential land that could be offered as part of this project.

This project has taken some years to gain commercial interest, partly because it is not necessarily commercially viable to offer this within Guildford. Therefore there are questions about the desirability of increasing the retail offering in this context, particularly given the fragility of the retail sector nationally and the potential impact on the iconic and important High Street.

This policy would seem to be in contravention of NPPF 23 which notes the obligation to retain and enhance existing markets and only where appropriate to reintroduce or create new ones, but ensuring that markets remain attractive and competitive.

It is further noted that the plan designates up to 9.9 hectares of new warehouse sites (category B8). Some of these sites are within the urban area. This is low grade employment, low productivity land in an area with high employment, high salary rates, little available land, high congestion and notoriously poor transport links, and many warehouse sites are currently empty. This is not an intelligent use of land; there should be a net reduction in this type of site within the borough, this form of development is unsustainable and undesirable; this is not an appropriate strategic location for such business. This would release more land for housing.

Reduce the scale of the new retail, commercial and industrial sites proposed within the town centre, with a beneficial impact on land available for brownfield housing redevelopment, and there will be a commensurate benefit in terms of sustainability and profitability. The aggressive development projects are likely to result in damage to the town with out of scale developments which could destroy the qualities that make the town centre desirable.

As with various other policies, there seems to be an element of confusion in the drafting of this policy, in that it is not clear whether this policy is expected to address Guildford Town Centre alone or the hierarchy of settlement centres. The hierarchy referred to in Note 4.171 as listed in Table 2 is founded on the Settlement Hierarchy – itself dependent on research which, it was stressed at the time of collection, was not key to the evidence base. If evidence is collected on a flawed or arguably dishonest premise, then that evidence is itself perhaps questionable.

In the context of the latter, the profound errors in the Settlement hierarchy are notable. All villages and settlements have noted that there are problems with this database. These were recognized by GBC after the consultation forum, so that the questionnaire was sent out again but with a sufficiently short response time (2 weeks) that it was not necessarily feasible for most parish councils to respond or even to hold a parish council meeting to discuss the questionnaire. Where the evidence base is flawed, the decisions based upon it cannot be relied upon.

The comments in relation to some of the flaws within the Settlement hierarchy are attached as comments to that document, but are incorporated in full by reference here.

Policy 16: District and Local Centres
Response Type OBJECT
This policy seems unclear and requires clarification – in particular this comment within the policy is not at all clear in terms of its interpretation, so it is not possible either to support or object to it without much greater clarification:

“In order to protect the liveliness and economic resilience of our district and local centres, we will direct developments of town centre uses consistent with the scale and function of the centre to a district or local centre. We will not apply this sequential approach to small developments of town centre uses of less than 280sqm (gross) in rural areas.”

Does this mean that those who wish to be engaged provision of shopping facilities will be directed to provide these in district or local centres instead of the town centre? Should the provision of retail within district or local centres not be subject to local demand rather than central direction, and therefore why should this be a formal policy at all – and if so, why is it prescriptive rather than permissive?

It might be acceptable to state, for example:
“we will permit developments of town centre uses consistent within the scale and function of a centre within that district or local centre, but will not permit developments which exceed appropriate limits which meet local design requirements”.

If too much retail activity is “directed” to district centres, has it been considered what the impact on town centre retail will be, given the expected decline economically in the retail sector overall, the huge expected expansion in retail capacity as part of the town centre redevelopment of North Street, the consequential loss of business within the High Street etc? Why is there the expectation that the only two businesses that are viable are retail and building and therefore all areas of the borough must have huge amounts of both? Do we need extensive retail in local centres?

Furthermore, this sentence is even more unclear: “We will not apply this sequential approach to small developments of town centre uses of less than 280sqm (gross) in rural areas.” Does this mean that any development of the appropriate size will be permissible in rural areas? Or that no developments will be so permitted? (Somehow that seems unlikely). Why should there be less constraint, given that in the countryside outside the green belt Policy no. 10 states that “only development which requires a countryside location or where a rural location can be justified will be permitted”? What does this policy mean?

As has been clear before, this borough’s plan seems to be to attack the Green Belt and the countryside as a principle, irrespective of any possible justification. Why should there not be a sequential test for development within the rural areas, and why should planning restrictions not be applied to these? Or does this policy mean something different – in which case please clarify the meaning as a matter of urgency. Since the meaning is so unclear, it cannot be said that proper public consultation can take place on this comment.

It is noted that there is a proposal 4.192 which states “We will assess the need for additional retail floorspace [even more? How much do you really think we need to shop in an era of internet shopping? Why is the planning department immured in the 1950’s!] arising from planned developments and the capacity of each centre to accommodate these and will define the detailed boundary of each centre, including the new local centre, for the next stage, the publication plan”.

So this plan is not a plan on which we can consult in this area either. Not only is the housing number uncertain, produced on evidence which is recognized to be flawed, on the basis of errors within the Office of National Statistics’ data; it then uses that flawed number to allocate an uncertain number of homes; with inadequate appraisal of the traffic or infrastructure consequences; and it ducks the issue in relation to the impact on district and local centres, which it proves incapable of defining.

How can we consult on a moving target? How can we respond to undefined non-proposals which are left so amorphous that they are meaningless?

This is not a plan on which consultation can take place because there is nothing to which it is possible to object or approve. This is an issues and options consultation by another name and is so fluid as to be completely meaningless for plan preparation purposes. That future “publication plan” will by definition be the first time in which this issue can be addressed by the public, and therefore must be subject to the normal two stage consultation since there has been no opportunity to consult on the issue at this stage.

Policy 17: Infrastructure

Response type: OBJECT

Some infrastructure, as identified within 4.199 and 4.200 – is within the control and remit of Guildford Borough Council – they have some influence in relation to planning – but much is under the control, and is the fiscal responsibility of, Surrey County Council, who have largely not been consulted as to the proposed and required roads, medical facilities, school requirements, and other required infrastructure that would be associated with large increases in the population.

Many of the responses to the Issues and Options consultation dealt with problems with the infrastructure within the borough and the fact that the borough already has extremely severe road congestion. This is identified in the council’s own evidence base, in notes 4.201 and 4.202 (“in parts of the borough some existin g infrastructure is currently at or near to capacity or of poor quality”; “Much existing infrastructure .. has little capacity to cope with population growth and new housing development”) and in the Key Facts section of this document 1 (Strategy and Sites – Strategic Policies and Appendices A-F). This notes, in relation to infrastructure, that there is “pressure on existing infrastructure and additional stress caused by our borough continuing to grow and develop”; that increasing population and the high quality of life and environment “ places a high demand on school places and access to amenities such as open spaces has struggled to keep pace with Guildford’s popularity” and that there is “growing pressure on car parking and congestion” and “We are also aware of the pressure on local facilities in village settlements”.

Although there is an assertion that the congestion associated with current levels of economic activity and population is understood, this does not seem to be the case. In fact, it is notable that the study conducted was fundamentally flawed in that no scenario had any relation to the actual proposed number of homes that are suggested within the local plan. Business as usual 2031 was defined in terms of Scenario 1 of the SCC Growth Scenarios. This includes existing land use and approved planned developments only- in other words, there was no projection for any growth whatsoever. Population and employment projected for 2031 are effectively those applicable at present; in other words this was a nil growth scenario. As a result, analysis and appraisal using these forecasts is useless as evidence for the plan.

BAU mode share seems incorrectly calculated; this seems to subtract Scenario 1 vehicle trips from the overall trip growth based on population and employment.

The GTAMS report is therefore apparently to be revised and reissued as confirmed by Cllr Palmer, who has noted that the interventions will be retested using a more relevant scenario.

Appraisal of sustainable intervention uses assumptions about mode share (low, medium and high shifts away from car) but this gives no explanation whatever of the measures that are expected to achieve them, and the costs for sustainable transport are the same for all levels of mode shift (high, medium and low) which is clearly an untenable assumption. There is no reference to the specific measures that will result is a shift from car use.

It is not realistic to assume that car use can effectively be replaced for all or even many users. Those who are disabled or infirm cannot easily substitute car journeys with bike travel: the elderly; the disabled; those caring for young children (particularly uncertain bike users and those with multiple children to care for); those wishing to use cars for supermarket or other bulky shopping; those who wish to commute to work and have no facilities for showering or changing on arrival; those who have lengthy and tiring commutes at present, for which the car is the final (short) element of a long journey (for those commuting into London from outside Guildford, a daily 3 hour commute is typical; this cannot realistically be extended by extensive cycling). All these factors mean that the replacement of the car with cycle use is likely to be overstated by many studies, particularly given narrow roads which do not allow effective or safe bike lanes.

Funding is not the only nor the main obstacle to improving infrastructure within the borough, and this seems not to be recognized in the introductory points 4.196-4.198. Guildford is a gap town, set in a bowl within the Surrey Hills Area of Outstanding Natural Beauty to the south of the borough, and with large sections of the borough affected by the Thames Basin Heath Special Protection Area to the north. There is a ribbon through the middle of the borough which contains rail and road links to London, but is already heavily congested, is Green Belt, AONB, SPA or more than one of the above. Very little of the borough is available for extensive development of infrastructure or any building.

The economic drivers within the policy note an intention to pool Community Infrastructure Levy from most new build development and to use CIL receipts to assist in provision of infrastructure needed to support the delivery of the plan. As with other aspects of planning, there is a failure to recognize that out of town settlements in particular have particularly high requirements for additional new basic infrastructure in order to exist at all – roads, sewers, water provision, electricity, gas, telephone and broadband links will all need to be provided and in many cases the links to existing services will need to be upgraded before these can be implemented. The ability to divert funds from CIL to other uses will be inherently limited, not least that otherwise the proposed settlements will not be able to function. The Council strategy of taking CIL from new build in the Green Belt sees to be to pay for roads within the town centre, as indicated in the policy “Our use of CIL receipts and of planning obligations will ensure that vital infrastructure is available when needed and where necessary through the use of phasing provisions” – but this is not feasible. Planning obligations alone will not deliver the required infrastructure, and it will not be possible to divert funds from out of town settlements, as noted in 4.204, which notes that legislation prevents the use of planning obligations to fund existing infrastructure deficits.

The absolute constraint on developmental capacity within the borough represented by the infrastructure limitations cannot be swept aside, and this must be recognized in the context of the proposed housing provision.

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 into normal traffic lanes , 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, which currently, locally, it is not.

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.
Policy 19: Green and blue infrastructure
Response Type SUPPORT

The policy on Green and Blue infrastructure is broadly supported with an important and major caveat; and if disregarded this should count as an objection.

However, it is noted that the largest areas of industrial brownfield land within the borough are near to or adjacent to the River Wey, particularly in the Walnut Tree Close area and in the Slyfield industrial area.

These areas could support much more housing than the relatively small numbers indicated in the policy on the town centre, under a town centre regeneration scheme. This would have huge benefits for the community as a whole since relatively run down areas would be subject to regeneration, the river banks would be cleaner and more attractive.

It is vitally important for the town as a whole that the run-down Walnut Tree Close area is used for well designed housing, as indicated by the Mastervision document first draft compiled by Allies and Morrison. John Rigg of Savills and Guildford Vision Group has indicated to the Scrutiny Committee of GBC that initial commercial projections indicated that the Walnut Tree Close area alone could provide 4000 homes (which compares with the projection from GBC of 370 homes in the same area). Both Allies & Morrison and GVG initially indicated that they believed that this site could be available for regeneration within the critical 5 year window required for the local plan.

As has been noted elsewhere, for reasons that are not altogether clear but appear to be connected to a misunderstanding of central government direction and a desire to maximize the Community Infrastructure Levy, there is an aggressive desire to push development on to the Green Belt at all costs, ignoring or eliminating for other reasons sites which could be used in the town for residential purposes. This has informed recent planning decisions (both the Aldi site and the Waitrose site were originally zoned for residential purposes and were eminently suitable for this) and this bias seems to be informing the Local Plan.

As a result, it is important that the desire for Green and Blue infrastructure does not become an excuse for preventing regeneration of Walnut Tree Close. It is noted that the Council has stated that “The Council is keen to protect the watercourses from inappropriate development that would spoil their character”. The bus station adjacent to the River Wey, and the empty car parks associated with empty factory space, are hardly attractive development – well designed mid height (3-4 storey) apartment blocks would be a great improvement to the river corridor, offer major scope for sustainable regeneration, and would prevent the need for any incursion into the Green Belt to meet reasonable housing needs.

That regeneration zone would be highly sustainable, because it would be within 1 mile of the railway station, adjacent to the A3, and would eliminate an area of huge congestion in the town because if the industrial sites were replaced by housing then the residents would commute by train or walk to work rather than having to drive in to an industrial estate.

It certainly does not seem appropriate to create substantial new parkland on current hard standing. The protections to which this policy refers largely describe existing open space, which is of great importance. But to determine not to utilize brownfield land for residential use at an appropriate density in order to force building on to the Green Belt would seem to be in contradiction of the principles of use of the Green Belt applied in the Gallaher Homes v Solihull court of appeal case, where the hierarchy of use is clearly defined, with urban brownfield required to be used as a first option.

So broad support for the policy, with the note that this should be explicitly amended to permit construction of a regeneration zone on the brownfield areas surrounding the river in the middle of the town.