The consultation on the Local Plan runs until 22 September. This is the really important consultation – there will be another, but that will be smaller points of detail. This is the time when we can change what the Local Plan says.
You can respond in detail to the policies (and there are some suggested points on the Local Plan page). You can respond to GBC’s questionnaire (although that is only 7 questions asking about very broad brush issues like “do you agree with the evidence base” – and it will be subject to some kind of interpretation. Maybe respond briefly and cross refer to any points of detail!). Or – if pushed for time -you can just respond with a letter, sent by email, handed in or by physical post.
A sample draft letter might look something like this – do change the wording, since duplicated letters may be disregarded!
Email to: email@example.com
Or write to:
Local Plan Consultation,
Guildford Borough Council,
Guildford, GU2 4BB
Dear Head of Planning
I wish to register objections to the Local Plan on a number of counts.
Our Green Belt is precious. It is what protects London from urban sprawl; it preserves air quality; it prevents flooding; it is the city’s playground. It is for us to conserve and protect it. There are 5 legal purposes for Green Belt, and it meets them all:
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.
NO EXCEPTIONAL CIRCUMSTANCES
The local plan proposes ~ 9000 new homes to be built on existing Green Belt land (compared with ~ 50 000 current homes in Guildford, so approx. equal to 18% of the existing homes in the borough) – a huge proportion. The National Planning Policy Framework (NPPF) requires any change of Green Belt boundaries to demonstrate exceptional circumstances. Unmet housing need is NOT an exceptional circumstance in law. No exceptional circumstances have been disclosed. So the Green Belt boundaries should NOT be changed.
The total housing numbers proposed are for 13040 homes over 15 years from 2016 to 2031. This number is too high. It does not taken any account of the constraints that apply locally, some of which have been flagged as valid by Nick Boles, Minister for planning, e.g. that there is Green Belt over a high proportion of the borough, which is a legal justification for not meeting objectively assessed housing need. It is based on a Strategic Housing Market Assessment (SHMA) which the full council required to be amended by the then Lead Councillor for Planning and the Head of Planning. No amendment has taken place; those individuals are no longer in their posts. It is based on faulty data from the Office of National Statistics (which has now been corrected) – but there has been no consequential adjustment to the draft SHMA. A new, revised, SHMA on a joint basis with Woking and Waverley has not yet been published and is not part of the evidence base. This has not been subject to any consultation and the number arising from that is unknown. How can anyone comment on the proposed plan when the fundamental housing number is still so uncertain?
There is brownfield land available in the town centre which is being earmarked for commercial development rather than for housing. This is enough to meet our real needs for affordable local homes. There are enough vacant commercial sites to cope with genuine business need, and we have enough retail capacity already, so urban brownfield/derelict land should be used for housing.
DRAINS, WATER SUPPLY, FLOOD RISK, CONGESTION
Our drains, our water supply, our medical facilities and our roads cannot cope with the proposed number of new homes. Building this number of homes will lead to flood risk here and downstream (along the Wey and Thames). The planned development on Green Belt is therefore unsustainable.
In conclusion, I must ask you to revise the housing number, reconsider the pro-development agenda, and to amend the Local Plan to utilise brownfield land rather than green field sites.