Guildford Greenbelt Group approved as a political party

Guildford Greenbelt Group has been approved by the Electoral Commission as a political party.

The press announcement about this is here:

Guildford Greenbelt Group (GGG)

Press announcement 11 November 2014

GUILDFORD GREENBELT GROUP (GGG) APPROVED AS AN INDEPENDENT POLITICAL PARTY

Guildford Greenbelt Group (GGG) is delighted to announce that the Electoral Commission has given permission for it to stand in future elections.

Political party status means that GGG can campaign, endorse candidates and will not be prevented from commenting on political matters in the run up to an election. GGG has a local emphasis, and is not a national party.  It is not affiliated with any other party. While many of the issues that are faced in the borough of Guildford and in the surrounding areas are being experienced by other communities across the country, GGG’s focus is on helping to resolve these issues from a local perspective and is completely committed to the borough of Guildford and its people.

 The GGG constitution states that:

• Brownfield land should be used for building before any green fields
• Housing numbers must reflect real local need, not developers’ wishes
• Existing legal protection for the Green Belt and the AONB should stand
• Green fields matter – they are not just building land
• The Metropolitan Green Belt is for the benefit of all

GGG is supported by many individuals and a large number of campaigning groups, residents’ associations and some parish councils across the whole borough of Guildford, in both the rural and the urban area.

GGG was formed in December 2013 in response to the Issues and Options document prepared by Guildford Borough Council. It has led the most coherent and vocal protest against the draft Local Plan and has led a number of public petitions resulting in public debates in the council chamber. These have varied from topics relating to the protection of the Greenbelt, discussion of the council’s strategy, consideration of specific sites, traveller housing and elements of the local plan, including the Strategic Housing Market Assessment (SHMA) and the housing number proposed for the borough. These petitions have led to a more informed level of debate both among existing councillors and in the wider public domain.

Since its foundation GGG has campaigned against the basis on which the SHMA was constructed (the terms of reference included prior consultation with house builders but not local communities) and the conclusions of that report (which inflated the calculations of need beyond the national statistics for growth). GGG has complained, in conjunction with other local groups, about a number of errors in calculation within the SHMA, and these complaints were confirmed by written comments by the Office of National Statistics which recommended adjustment. This resulted in an undertaking to correct the errors from Guildford Borough Council. It appears from recent GBC publications that the housing numbers are almost unchanged and those errors remain uncorrected.

GGG has also campaigned about other flawed areas within the evidence base of the local plan, including the Greenbelt and Countryside Study, which the consultants concerned have stated was for the purposes of “rolling back the Green Belt” and which indicated that the “openness” of the Green Belt was limited by the presence of trees. GGG has presented detailed criticism of the Settlement Hierarchy and the Sustainability Analysis, neither of which are fit for purpose.

GGG campaigned for Guildford Borough Council to withdraw and correct its draft local plan (subject to consultation over summer 2014) prior to its issue, on the basis that it was in breach of the National Planning Policy Framework (NPPF) and ministerial guidelines, based upon inadequate evidence, and had not met the duty to cooperate. The Executive ignored the Council’s own scrutiny committee which recommended revision of the housing number prior to issue of the plan. Despite this, the full Council voted to proceed with a consultation on the inadequate and flawed first draft, at very considerable public cost and consequential delay.

GGG encouraged members to write to comment on the local plan, provided information to assist members of the public to consider the issues, and is delighted to learn that the draft local plan over the summer had over 19500 responses . Guildford Borough Council noted the level and quality of these responses and it has now withdrawn that draft of the local plan, with a proposed reissue date of June 2015, after the next election.

However, Stephen Mansbridge, the Leader of Guildford Borough Council, has made public statements, after withdrawal of the local plan draft, noting that the “trajectory” of the local plan is unchanged.

Members of GGG have formed the view that it is necessary to stand as a party at the next local council elections because it is only the political process that will allow GGG to participate in decision-making, present detailed views within the council chamber and influence the preparation of the local plan. A formal application to stand as a political party was submitted in July 2014 and has now been approved.

Because the current political structure allows for the Executive model of local council management, overall control being held by the largest party. GGG considers that it is more democratic for all councillors, from all parties to have equal voting rights on decision making, and has started a petition for a referendum, run by a separate company Local Democracy Ltd, for a return to the committee system. If 5243 local voters sign this petition then there will be such a referendum, and it is likely to be most cost-effective and administratively convenient to hold this at the next election (and it appears that Guildford Borough Council are starting to plan for this). GGG have been informed that this petition must be presented in paper form and members of the public, whatever their views on GGG, are invited to sign this petition in order to support more democratic accountability. A copy of the petition can be downloaded from the website or is attached to this press release.

It is important to stress that GGG does consider that there is a need for local affordable housing, to meet local needs.  GGG supports the building of a number of homes in the Borough (including affordable housing). GGG would consider that around 300-325 homes per annum for the life of the Plan (ie until 2031) might be sustainable (this is comparable with the number approved by Guildford Borough Council’s High Court action against the Labour Government’s regional plan in 2010). The plans proposed by GBC, which seem to be still in place, are for 652 homes per annum (or indeed more, since that figure is being backdated by GBC to 2011). This proposal would ruin the rural nature of Guildford borough’s Green Belt and countryside irrevocably. The more moderate housing target for which GGG is campaigning (comparable with other areas in the home counties) will satisfy local housing need whilst protecting the Borough from being overwhelmed by development pressure and unchecked demand.

However, the view of the membership is that there is definitely sufficient brownfield land to meet all genuine local need. The draft plan has inflated demand assumptions in order to create pre-determined justification for greenfield building, which would generate profits for developers in the local area. GBC have commented that there is indeed considerable brownfield land, especially in the urban area – and this is sufficient to meet even its own inflated housing target. GGG doesn’t want to build so many homes, but the point is that GBC’s housing target does not create any justification under current guidelines and law that will permit it to use Greenbelt land. However, GBC submits that the available brownfield cannot be used as part of the five year supply (although their own consultants disagree) and therefore that Greenbelt land needs to be used. GGG considers that this is unjustifiable.

GGG has members and supporters throughout the borough. GGG will now start the process of considering candidates who will stand in the elections in May 2015. New members will be able to put themselves forward for candidacy provided that they support GGG’s aims and values. New members are welcome and more information on GGG can be found on its website, and information for new members is also available at GGG’s public meetings.  The intention is to field candidates in all wards where existing councillors do not already have a history of acting and voting to protect our countryside and where councillors have supported the discredited draft local plan.

The very recent by-election in Lovelace ward, held towards the end of the consultation on the draft plan, shows the strength of public feeling on the Greenbelt.   This was won by a significant margin by Colin Cross, overturning a historical Conservative majority; and his campaigning stressed that he was a GGG supporter; clearly he has not yet had an opportunity to vote on or influence the drafting of the Local Plan.

Guildford Borough Council have announced that a new local plan will be issued in June 2015. It is unclear that this will be substantially different (see notes to editors).   Unless we see a radically different draft soon, with a substantially reduced housing number, that Local Plan constitutes a silent manifesto for all existing councillors. Any councillor that did not oppose that plan is implicated by its proposals.

GGG argues that it is necessary to change the local political framework so that local councillors listen to local people.

Voting for GGG will enable voters to get:

• Local interests represented
• Protection of our countryside
• Probity in planning
• High quality rational analysis by councillors
• Better decision making in the council chamber
• Realistic appraisal of infrastructure (including roads and schools) in planning
• Recognition of the importance of the environment in decision making

Susan Parker, GGG leader, commented:

“We are delighted that we can now stand for election as GGG candidates.

 “We believe in protection of our countryside. This will benefit all members of society, whether they live in the town or countryside, or in the London metropolitan area. The beautiful countryside in which Guildford is set makes it one of the best places to live in South East England, and it is a wonderful place to visit and for those in the urban area to come to for relaxation. But it is subject to enormous development pressures. In all our interests we need to protect our countryside.

 “Very few existing local councillors or elected representatives have spoken up for the countryside, and none have done so effectively.

 “We need to stand up for our countryside and so we will be standing at the next election.”

 

 

Notes for editors 

1. Further information on GGG is available on the GGG website http://guildfordgreenbeltgroup.co.uk

Or on its facebook page:

https://www.facebook.com/Guildfordgreenbelt

2. GGG public meetings, open to all members of the public, will be held as follows:

• 17 November 2014 -Send Social Club -7.30pm
• 9 December 2014 -St Albans Hall Wood Street Village -7.30pm
• 28 January 2015 -Fairlands Community Hall -7pm

3. For details on the current housing numbers proposed by GBC see documents published in November 2015, after supposed withdrawal of the draft Local Plan. However, this document only refers to the Local Plan being in draft, not subject to complete revision:

http://www.guildford.gov.uk/media/18112/Draft-Guildford-Borough-Housing-Strategy-2015-20/pdf/HOUSING_STRAT_2015-20_DRAFT_STRATEGY_Nov14.pdf

In particular see p10 which refers to proposed development per the Local Plan of 652 homes per annum

See also Appendix 1 to that housing strategy:

http://www.guildford.gov.uk/media/18113/Draft-Guildford-Borough-Housing-Strategy-2015-20—Appendix-1/pdf/Hsg_Strat_2015-20_DRAFT_Appendix_1_-_General_statistics_Nov14.pdf

this states that the objectively assessed housing need is for between 650 and 780 homes per year

 

 

 

 

 

 

Brownfield first is now government policy

We have had a major change in government policy – for which we should be grateful, I think – but we need to make sure that this is not just tokenism.

George Osborne gave a major speech at the Mansion House – full text is here:

https://www.gov.uk/government/speeches/mansion-house-2014-speech-by-the-chancellor-of-the-exchequer

Scroll down the speech to find this:

“We’ve got the biggest programme of new social housing in a generation; we’re regenerating the worst of our housing estates; and we’ve got the first garden city for almost a century underway in Ebbsfleet.

Now we need to do more. Much more.

We have beautiful landscapes, and they too are part of the inheritance of the next generation. To preserve them, we must make other compromises.

If we want to limit development on important green spaces, we have to remove all the obstacles that remain to development on brown field sites.

Today we do that with these radical steps.

Councils will be required to put local development orders on over 90% of brownfield sites that are suitable for housing.

This urban planning revolution will mean that in effect development on these sites will be pre-approved – local authorities will be able to specify the type of housing, not whether there is housing.

And it will mean planning permission for up to 200,000 new homes – while at the same time protecting our green spaces.

Tomorrow, Boris Johnson and I will jointly set out plans for new housing zones across London backed by new infrastructure, so that we see thousands of new homes for London families.

And we’ll take the same approach in the rest of the country; with almost half a billion pounds of financial assistance in total set aside to make it work.

Now I suspect there will be people who object to new building, even on the brownfields of our cities.”

This is good news. It was followed by a statement by Eric Pickles, Secretary of State, who gave this press announcement:

https://www.gov.uk/government/news/government-initiatives-to-help-build-more-new-homes-on-brownfield-land

Communities Secretary Eric Pickles said:

“We’re determined to make the very best use of derelict land and former industrial sites to provide the homes this country desperately needs in a way that protects our valued countryside. By ensuring commitments to housing development are in place early and having dedicated housing zones, building becomes, quicker and easier for homebuilders, businesses and councils.”

He also was quoted in the Daily Telegraph on 14 June 2014 as saying “We’ve always been a green and pleasant land and we must stay that way, prerving the best of our countryside  and other green spaces…we’ve also been facing a serious housing shortage in this country, and we’ve got to increase supply in line with demand.  I’m determined that we rise to that challenge without building unnecessarily on undeveloped land.  The way to do that is to use brownfield better”.

Master Vision for Guildford

The Master Vision document – commissioned from planners Allies & Morrison – has now been published and you can read it here:

Click to access Guildford_Town_Centre_Vision_2014.pdf

This sets out a number of issues including proposing housing in the Walnut Tree Close area, protecting the green surroundings of the town, and some issues concerning road traffic, the planning of the Gyratory in Guildford Town Centre etc.

The vision for increased residential housing on brownfield in the town centre is excellent and warmly welcomed.  This document was approved as a draft by the Scrutiny Committee on Wednesday 11 June, so this document will go to consultation to be included within the Local Plan, and it is of course possible to comment on this separately too.

There were 7 public speakers at the Scrutiny Committee.  All but one thought that the Walnut Tree Close area should be used for primarily residential development and was a potentially very sustainable site for medium density housing, which could present a very exciting opportunity for  Guildford both as a town (more cohesive, less poor quality land in the centre of town) and as a borough (the potential use of previously developed land in the town centre could allow protection of the Green Belt).  Even the spokesman for the business community, who wanted office usage near the station, agreed that it was a poor site for industrial units and that there should be HGVs going along Walnut Tree Close, and that those existing industrial units could constructively be moved. So the public response was unanimous in agreeing that industrial units should be moved from Walnut Tree Close.

 

 

Full steam ahead

Last night (4/6/14) the Executive Committee at Guildford Borough Council voted unanimously  to approve the draft Local Plan.

The draft local plan still contains the housing number of 652 homes per annum, which, backdated to 2011 (why?) gives a total until 2031 of 13040 homes to be built – which represents approximately one quarter of the existing number of homes in the borough.

It seems that the Scrutiny Committee requirement to revise the housing number has been disregarded.  At the Executive Committee, Cllr Phillips, who proposed that revision as a recommendation, said:  “I was pleased that the joint Scrutiny Committee accepted my suggestion… to have another look at the housing numbers. We have in here in Appendix A the detail of how you arrive at the housing numbers and [that].. a meeting has been arranged..between the lead councillor, the head of planning services, the managing director.. [etc] and members of the policy team and appointed advisers such as GL Hearn and Edge Analytics to review the housing numbers. It was hoped that we would have an answer by today. Can you tell me, has this happened? Have you looked at this yet? If you have, what is the housing number and has it reduced as we were hoping it would be?”. It was confirmed that the meeting had not yet taken place,. Cllr Juneja, the lead member for planning, noted that the number had not been reduced at present but would be “challenged” by the Executive.

A private meeting was held on 6 June 2014 to review the housing number.  Anne Milton MP arranged for some of her constituents to meet with GL Hearn, the consultants who prepared the report; but those who are not Mrs Milton’s constituents were not been invited to that meeting.  (Mrs Milton seems not to have realised that the parliamentary constituency of Guildford, and the borough of Guildford, have different boundaries, and other MPs’ constituents are not included in that consultation.)

The numbers may change – but they will not change before the draft that goes to public consultation. And, at a guess, substantive change may be unlikely thereafter.

We were also told  at the Executive  Committee meeting by Cllr Mansbridge and others that:

• electrification of the North Downs line is possible (or maybe probable)
• brownfield land is being considered, and that there will be a parallel document to consider the brownfield land “by the river” (this may be the Walnut Tree Close area, or perhaps Slyfield) as a master vision document, to be consulted on possibly in parallel with the Local Plan
• there may be prospects from the Highways Agency for new and improved roads (location unspecified – and actually that doesn’t excite me at all; roadbuilding is not an enticing prospect)

You can view the webcast of the meeting here:

http://www.guildford.public-i.tv/core/portal/webcast_interactive/137661

GGG open letter to councillors 29 May 2014

Dear Councillor

You may have seen the summary of the agenda for the Executive Committee on 4th June. If you are not on the Executive Committee, you may not have seen this, or yet taken the time to read it. GGG feels that it merits serious criticism, and actually represents a serious failure of the democratic process.

We would therefore ask you to challenge it, as it requires reconsideration.

You will be aware that planning is a matter of major concern nationally, with many people terrified about an apparent assault on the countryside and apparent reluctance among house builders to consider the prioritisation of brownfield land. This has been a topic that has led to comment by a number of significant experts, including Sir Simon Jenkins, Dame Helen Ghosh, Shaun Spiers, Sir Andrew Motion, Sir Richard Rodgers and others. Civic Voice has expressed concern regarding a democratic deficit in the planning process. Greg Mulholland MP has a private member’s bill requesting a revision of the NPPF, with a second reading on 6 June 2014 (GGG has asked all 4 MPs to vote in favour). There is a parliamentary select committee currently reviewing the efficient operations of the NPPF. You may also be aware that there is much comment about a housing bubble in London and the South East, likely to be near the top of the market at present and that mortgage approvals are currently falling; house building is at a periodic high, where the current constraint on the number of homes being built is the national supply of bricks. Not all those homes will be lived in: 18% of homes built in London are sold to non-resident buyers and stay empty; this too calls into question the real need, national or local. Further there are, nationally, 1 million empty homes (not 2nd homes).

This situation is currently fluid and there is scope for political decision-making as part of this process, as the Scrutiny Committee noted. It is arguable that the impact of concern about this issue has already affected elections, both locally and the European elections. As you may be aware, both the Green Party and UKIP are staunch supporters of the countryside and, from different standpoints, oppose greenfield building; and the impact on the recent elections of this matter has perhaps not yet been fully considered by the main political parties. This is not a simple and straightforward procedural planning matter. It requires your judgement.

For your information, we are including a note on the use of brownfield land in Guildford prepared by GGG, which we consider indicates that there is substantial brownfield land within the borough that could be utilised for the purposes of development. It is an illustrative brief document, but we are in the process of preparing a more detailed work. We do not consider that there is a need to consider greenfield sites in preference. Conversely, there is precedent that Local Plans have been subjected to judicial review if there has not been a proper review of the alternatives to use of the Green Belt. We would also note, if you were not aware, that Mole Valley initially considered that it needed to plan to use 2% of its Green Belt for housing, but MVDC is now implementing its Local Plan well in excess of its housing target using only brownfield areas.

If you are not on the Scrutiny Committee, you may not have seen the results of that Scrutiny Committee, and so for your information we are attaching a GGG press announcement summarising the conclusions of that meeting.

The draft local plan report is here: http://www.guildford.gov.uk/media/17112/Item-3—Draft-Local-Plan-Reportpdf/pdf/pdf46.pdf

Scrutiny Committee decision disregarded
We note that agenda item 8 reiterates the conclusion of the Scrutiny Committee:
“To express concern over the housing number as set out in the Draft Local Plan and to ask the Head of Planning and the Lead Councillor for Planning to review the housing number before going to Executive for consideration on 4 June and Council on 19 June 2014″.

The officer response does not indicate that such a review has been carried out, but states: ” A meeting is being arranged [ie has not yet taken place] between the Lead Councillor, the Head of Planning Services, the Executive Head of Development, the Head of Housing Advice, the Managing Director, members of the Policy Team and appointed advisers such as GL Hearn and Edge Analytics to review the housing number for inclusion in the draft Local Plan. A full and detailed explanation of how the housing number was arrived at is attached to this note as Sub Appendix A”.

The Scrutiny Committee required review of the planning number. That has not taken place and there has not even been a preliminary meeting. It is not clear how the Local Plan can be processed for approval by the Full Council without the revision of the housing number as required by the Scrutiny Committee. We would question what the function of the Scrutiny Committee is when its conclusions can be wholly disregarded by the Executive Committee. Far from being revised and reviewed, the number is unchanged, with an intention to hold a meeting at a future date and a series of apparently spurious justifications given for not revising the number as the Scrutiny Committee required.

No constraints applied, with no justification given
In Appendix A it is stated, as if a matter of fact, that
“If it can be demonstrated that we can meet our objectively assessed housing need over the plan period, using suitable and deliverable land, then a housing number lower than our objectively assessed housing need will not be found sound at examination.” This assertion is not demonstrable from the evidence of other areas and is not necessarily valid. No evidence is adduced for this statement. It would appear to contradict ministerial advice and the letters sent to our MPs by Nick Boles and the written advice from Nick Boles to the Planning Inspectorate in relation to the application of constraints arising from the Green Belt. It is a further demonstration that there has been no attempt made to apply any constraints whatsoever to the planning process. No such constraints have been applied relative to the number generated by the revised SHMA.

Conversely, there is precedent that Local Plans have been subject to judicial review if there has not been a proper review of the alternatives to use of the Green Belt.

It would appear from ministerial advice that there is not a requirement to meet objectively assessed housing need in full if Green Belt constraints apply (see letters from Nick Boles previously circulated). There is no suggestion in those letters that these requirements are just transferred into an adjacent area, but that Green Belt is a justification for actual reduction of objectively assessed housing need. This might arguably seem to be a grey area in terms of ministerial advice, but is certainly not merely a process of reallocation to adjacent authorities as the officer’s report would seem to suggest. This, like other remarks made on an advisory basis by the planning department, does not seem wholly accurate. Councillors should note that there is a precedent for judicial review of a Local Plan on the basis of poor advice by a planning department, if that advice is not demonstrably accurate and impartial. It is not clear that this advice is accurate.

Objectively assessed need was inflated, but has not been revised
In any event, it had been extensively argued at the Scrutiny Committee meeting, by councillors, that the objectively assessed housing need as arrived at in the SHMA is overstated. The numbers use an inflated trend – if necessary we can reiterate these arguments. This conclusion has been disregarded. The ONS data has been revised and the preliminary conclusions from The Guildford Society on their website indicate that this would give rise to an even lower estimate of housing need than should have been considered. However, this is not taken into account in the documents, which were published on the same day as the ONS data and therefore presumably have not yet taken these into account. Case law differentiates between housing need (the core data), housing requirement and housing targets. Constraints apply to the housing requirement (as generated by the SHMA) to arrive at the housing target (lower than the SHMA almost everywhere, but not here- the numbers are the same; the applicable constraints are not applied). The preliminary view that housing need can be justified at a SHMA number of around 470 should fall therefore, and with the application of constraints the combined residents’ view that the housing target numbers should be 300-345 remains constant.

5 year supply of housing land not in place
It has also been argued to the Council that there is in fact a 5 year supply of housing land and the arguments set out in relation to this matter have been ignored. Existing planning permissions are, by definition, available, suitable and achievable (with some small exceptions). When these are added to student housing permissions, there is already a very substantial supply of housing, before any new sites are considered. If the available brownfield sites within the town are included, even taking into account only those available within the initial 5 years, then there is a 5 year supply.

Existing planning permissions total 1480 (source: revised SHLAA). Student housing permissions total 2121 (source: UniS planning officer) (these specifically count towards the housing total, per Nick Boles’ letter to Sir Paul Beresford). The total is therefore 3601 (1480+2121=3601). Using the SHMA number (itself overstated) of 652, with a 5% uplift, gives a total of 3423 (652 x 5 x 105% =3423). It is therefore demonstrable that existing permissions exceed even the high objective assessment of need (3601>3423). Why, therefore, is it repeatedly stated that there no 5 year supply? Even if some of the existing planning permissions should be deferred (which must in itself imply that the developers are engaged in land banking which will distort the planning process) there is surely some land that is available so that a 5 year supply can be recognised? This is clearly the case.

The reiteration that this supply does not exist as if it is a given fact seems to imply a predetermined choice of course of action, and seems to suggest some desire to uplift the requirement by 20% to distort the decision making process, which is not acceptable.

In addition, there has been an elaborate game of double and negative circular counting to demonstrate that the current estimate of need should be backdated to 2011 to create a shortfall that could never have been anticipated. This is patently ridiculous, and throws the whole assessment and calculation into disrepute. Who are the numbers designed to persuade?

It is clear that using the previous local plan numbers and then the agreed interim measure of 322 – as agreed by the High Court – means that for the 10 year period to 2011 (or, if you prefer, the 10 year period to 2013) there was no historic shortfall. These numbers too can be supplied again if you wish.

Lack of revision as required by Scrutiny Committee
As we have seen previously, both in relation to the proposed involvement of the public in the scrutiny of the evidence base and the revision of the SHMA, the later drafts of parts of the Local Plan documentation seem to be revised remarkably little from the initial drafts, and the process of consultation and review, either with councillors or members of the public, does not appear to result in any modification.

This is unacceptable. It has been repeatedly stated by council officers that planning is not a referendum. Neither, however, is it the preserve of the planning department alone. The Localism Act enjoins a duty of consultation, and the right of communities to be heard. This does not mean that consultation with those communities should be an empty process.

Furthermore, and even more significantly, the choices of elected representatives should not be ignored. The decisions made by the Council should not just be set aside as if merely consultative.

It is not clear whether this failure to respond to the decision of the Scrutiny Committee is an abuse of Executive Committee power within the council, or whether the Planning Department are acting independently without the Executive Committee’s remit. In either event, we consider that the formal decisions made by councillors at the Scrutiny Committee should be followed and respected. As accepted by the Chief Planning Officer at that committee, political decisions are a matter for elected councillors, but, once made, they must be carried out and not ignored.

If there are areas within this document that you would like to discuss further, do please contact us.

With regards

Guildford Greenbelt Group

Brownfield land IS available

Guildford Greenbelt Group has published a paper on the brownfield land which is available in the borough, describing how the land at Walnut Tree Close could be used for a combination of affordable housing and private property, so that there is no need to attack the Green Belt in the borough.

This is reproduced here:

Guildford Green Belt Group (GGG)

Housing Solutions: Brownfield or Greenfield?

There can be little question that Britain needs more homes, and that affordable and social housing must be a large proportion of new dwellings built. This need is particularly acute in the south east, with the demand for housing being driven largely by London. Guildford is not immune to this, and so there is considerable debate about what would be an appropriate housing target for Guildford. Irrespective of what this is, Guildford Borough Council has adopted the position that much of this target will have to be built in the Green Belt or countryside within the borough. In addition, GBC have identified large swathes of Green Belt land that they think should be released for commercial and industrial purposes. So is the answer to all of Guildford’s development problems really to be found in the borough’s green fields?

GGG say that this is not the case; that the key to the housing problem and the supply of future sites for employment is recycling. Not the recycling of household goods, but the recycling of land – land that has been used being reused; but more efficiently. Using green fields to solve today’s problems is simply not sustainable; we have to use our resources more efficiently, and one of our most important resources is land. So we should use new, innovative designs to ensure that we maximise the efficiency of land use. Without doing this, we will not prepare our town or its residents for future success. Land recycling and use efficiency are key differences between Guildford Borough Council and Guildford Green Belt Group.

Efficiency of land use – what does this mean?

This is a very simple concept. We have to do more to recycle land, and when it is available for development, to use it more efficiently. Good design and high construction standards are key. The picture below shows an example of what this means.

This new development is close to the River Wey and Power Close. It is a mixed development of light commercial and residential. However, a great deal of the ground area is given to car parking. Efficient land use would ensure that car parking was provided underneath buildings, whether for residents or employees. Given that this development is about 1 mile from Guildford station, this is an area that could have been considered for residential use only, with commercial premises provided in some of the under-occupied industrial parks in and around Guildford. This development is a mix of 2, 3 and 4 storey buildings, with the commercial buildings primarily being 2 storeys. This makes no sense at all. Where site factors (such as topography, perspective relative to other buildings, etc) permit, building height should be the maximum possible, though some leeway should be given so that the design can encompass differing roof levels. In terms of efficient land use, zoning should be important, so that sites within walking distance from important infrastructure elements, such as the railway station, the town centre, hospitals, parks, etc should be primarily used to provide homes. This would help to reduce the traffic load in the city centre. Commercial uses (other than retail) could be confined to sites alongside major roads and within commercial and industrial parks – to minimise traffic entering the town centre. Park and ride car parks absorb huge land areas, there is no reason why multi-level car parks could not be provided, with the remainder of the area currently under tarmac being used to provide mini malls, devoted to e-tailing “click and collect” collection points, so that people only interested in collecting pre-ordered goods do not have to enter the centre of the town.

What is Brownfield? What is Greenfield?

The term brownfield applies to land that has previously been used – for housing, by industry or for commercial premises. There are numerous issues that may present obstacles to the recycling of these brownfield sites, but for the sake of future generations, surely it is better to find ways to overcome these obstacles, rather than simply identifying new green field sites for development? One of the dangers in using new green field sites is that some already built areas will become rundown and derelict. Equally, it is important to plan for the changing pattern of retail shopping, to embrace the changes that shopping on line will bring. Our cities and town centres have yet to reflect these changes. In Guildford, we have a once in a century opportunity to build a town centre fit for the new century; looking forward, not based on the past. Unfortunately, based on current GBC policies, this opportunity is likely to be lost, with their single minded pursuit of “rolling back the Green Belt”, to the detriment of the future of the town and its environs.

One of the brownfield areas that has great potential for residential redevelopment is the area approximately centred on Walnut Tree Close. As this area is close to the railway station and town centre it should be redeveloped as a residential area, with pedestrian and cycle paths within a green corridor (to include Dapdune Wharf, etc) alongside both river banks. There are parts of this area; including car parks alongside the railway station, within Walnut Tree Close and Woodbridge Meadows that are ripe for redevelopment. On the other side of the river, there are areas that could also be considered for redevelopment as well as disused buildings (owned by GBC) that should be revitalised. Some of these areas are shown below.

These redundant sites, and others, could easily provide large numbers of new homes, in a beautiful riverside setting. Compare these sites, as well as the picture of the disused building below, with a riverside development which could result from a planned and phased large scale redevelopment of this area. This is just one site of several that would lessen or even eliminate the need to build on green field sites within the borough.

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If you would like to learn more about Guildford Green Belt Group, visit our website – http://guildfordgreenbeltgroup.co.uk/home/4581459298

If you want to ensure that Guildford moves forward whilst ensuring future generations do not suffer from decisions that will be made over the next few years, then join our “land recycling first” campaign – and sign the GGG petition on the Guildford Borough council website http://petitions.guildford.gov.uk

GGG open letter to councillors 12 March 2014

Guildford Greenbelt Group

12 March 2014
Dear Councillor

Planning issues

GGG has been criticised publicly for not discussing matters with Councillors. We welcome any opportunity to do so. The formal debates that have arisen in the context of petitions have not allowed exploration of many points of detail.

As a preliminary, we feel it may be helpful to prepare a digest of some recent cases and statements to send to you in an open letter. We feel these are material in the context of the Local Plan. We would be pleased to meet any councillors to discuss local concerns in some detail, in an informal discussion; please let us know if you would be willing to meet us.

We would note that we have also proposed having a detailed working meeting on the SHMA (Strategic Housing Market Assessment) which is currently being revised. GRA (Guildford Residents’ Association) have agreed to join with us in proposing a combined meeting in order to meet the Council’s undertaking for full public involvement in that reappraisal. We have asked Cllr Mansbridge to hold such a meeting , involving the SHMA consultants GL Hearn, together with such members of the executive committee as Cllr Mansbridge feels appropriate.

Some of the key recent developments are:

NPPG

The National Planning Policy Guidance has been recently revised (on 6 March 2014). The weblink, if you wish to read this guidance in full, is here: http://planningguidance.planningportal.gov.uk

The changes include lower CIL charges for developers of brownfield sites as an incentive to build on brownfield land. The covering Parliamentary statement written by Nick Boles notes:

The Coalition Government is committed to reforming the planning system to make it simpler, clearer and easier for people to use, allowing local communities to shape where development should and should not go. Planning should not be the exclusive preserve of lawyers, developers or town hall officials.
We are also committed to ensuring that countryside and environmental protections continue to be safeguarded, and devolving power down not just to local councils, but also down to neighbourhoods and local residents.

The new guidance also includes scope to block potential development of greenfield sites if the infrastructure is insufficient, including sewage outflows.

The comments in the parliamentary debate by Greg Clark giving the definition of sustainability are also useful:

“We followed the suggestion of the Communities and Local Government Committee and used the classic Brundtland definition, which is about protecting the ability of future generations to enjoy the benefits that the present generation enjoys. We have also included the five principles of the UK’s sustainable development strategy. In practice, the policies outlined in the national planning policy framework will determine, in each case, what is and is not sustainable. For example, it is not sustainable to have a shopping development outside the town centre and it is not sustainable to build in the green belt.”
Saltford Decision

This decision was a decision called in by the Secretary of State in relation to an appeal by Crest Nicholson (who you may know are partners on the M3LEP (the Local Enterprise Partnership covering Surrey and Hampshire) Land and Property Group and developers of a large site in Waverley), advised by Pegasus (who of course prepared GBC’s Green Belt and Countryside Study). Crest Nicholson’s appeal was rejected.
See the letter sent by the Secretary of State on 4 March 2014 in relation to this:

Click to access 14-03-04_3-in-1_Manor_Road_Saltford_2195351.pdf

The Secretary of State considered that a site of 99 houses in the Green Belt adjacent to a settlement was a significant development within the Green Belt and so was calling in this policy.
Note that Bath and NE Somerset has an inadequate land supply and does not have a 5 year supply of housing land.

Whitchurch decision

This decision (5 March 2014) was recovered for the Secretary of State’s determination because it involved proposals for significant development (295 houses) in the Green Belt, which was re-considered on the basis that the proposal was reduced to 200 houses. This letter was also addressed to Pegasus (see above). The written Ministerial Statement on the Green Belt of 17 January 2014 is a material planning consideration in this regard. There is no 5 year housing supply, there is significant and acknowledged shortfall in the 5 year supply, and the local plan is not yet finalised, with housing policies not yet up to date. This appeal was rejected, and planning permission refused, because of the substantial harm to the openness of the Green Belt, the visual harm to the Green Belt, and harm to the character and appearance of the area.
See

Click to access 14-03-05_3-in-1_Stockwood_Lane_Whitchurch_2199958.pdf

Natural England letter re Thames Basin Heath Special Protection Area

Natural England have noted general objections to developments in the TBHSPA.
A letter is attached in full as Appendix 2. This notes the obligation to protect the habitats of the nightjar, Dartford warbler and woodlark in the TBHSPA. This covers much of the northern part of the borough from Ash to Effingham.

Letter from Nick Boles to Planning Inspectorate

In addition to the revision of the NPPG, Nick Boles has written a letter (3 March 2014) to the Head of the Planning Inspectorate (attached in full as Appendix 1). This notes that protections for the Green Belt remain in force through the NPPF. In particular, it states:
“The Framework makes it clear that a Green Belt boundary may be altered only in exceptional circumstances and reiterates the importance and permanence of the Green Belt. The special role of Green Belt is also recognised in the framing of the presumption in favour of sustainable development, which sets out that authorities should meet objectively assessed needs unless specific policies in the Framework indicate development should be restricted. Crucially, Green Belt is identified as one such policy”.

St Albans case: Hunston Developments

The Discussion, especially paragraphs 26 and onwards, is of particular relevance. As you will note, St Albans had a very out of date plan and no five year housing supply; therefore the developer contended that the green belt provisions could be set aside to justify building. The Court of Appeal has revised the High Court decision and determined (to quote):

28. The crucial question for an inspector in such a case is not: is there a shortfall in housing land supply? It is: have very special circumstances been demonstrated to outweigh the Green Belt objection? As Mr Stinchcombe recognised in the course of the hearing, such circumstances are not automatically demonstrated simply because there is a less than a five year supply of housing land. The judge in the court below acknowledged as much at paragraph 30 of his judgment. Self-evidently, one of the considerations to be reflected in the decision on “very special circumstances” is likely to be the scale of the shortfall.
29. But there may be other factors as well. One of those is the planning context in which that shortfall is to be seen. The context may be that the district in question is subject on a considerable scale to policies protecting much or most of the undeveloped land from development except in exceptional or very special circumstances, whether because such land is an Area of Outstanding Natural Beauty, National Park or Green Belt. If that is the case, then it may be wholly unsurprising that there is not a five year supply of housing land when measured simply against the unvarnished figures of household projections. A decision-maker would then be entitled to conclude, if such were the planning judgment, that some degree of shortfall in housing land supply, as measured simply by household formation rates, was inevitable. That may well affect the weight to be attached to the shortfall.
30. I therefore reject Mr Stinchcombe’s submission that it is impossible for an inspector to take into account the fact that such broader, district-wide constraints exist. The Green Belt may come into play both in that broader context and in the site specific context where it is the trigger for the requirement that very special circumstances be shown. This is not circular, nor is it double-counting, but rather a reflection of the fact that in a case like the present it is not only the appeal site which has a Green Belt designation but the great bulk of the undeveloped land in the district outside the built-up areas. This is an approach which takes proper account of the need to read the Framework as a whole and indeed to read paragraph 47 as a whole. It would, in my judgment, be irrational to say that one took account of the constraints embodied in the polices in the Framework, such as Green Belt, when preparing the local plan, as paragraph 47(1) clearly intends, and yet to require a decision-maker to close his or her eyes to the existence of those constraints when making a development control decision. They are clearly relevant planning considerations in both exercises.
Hunston cannot appeal since they technically won the case, which has been referred back to the PINs with the specific guidance that they must decide the case on the basis of the law as defined in this case. The law may be subsequently varied, but only by primary legislation, a subsequent Court of Appeal judgment, or a Supreme Court judgement.

Conclusion

Our view is that, taken in conjunction, there is much protection for the Green Belt which should be recognised in the Local Plan. We think the Council should not plan on building on Green Belt areas to meet housing need, and that to plan to build most new housing on the Green Belt is in contravention of planning guidance. The requirement to utilise brownfield land for housing, and to utilise it efficiently, has recently increased. We think this must become a material consideration in the context of how this resource is viewed and how the Local Plan is applied.

It perhaps seems time for GBC to consider formalising a brownfield site review along the lines of the Green Belt and Countryside Study previously undertaken, to be undertaken in conjunction with the progress of the Local Plan. GBC has spent much of our money in funding a Green Belt study; and has just reacted to this proposal by suggesting that it is our (GGG’s) responsibility to suggest brownfield sites. This is not the responsibility of the public or its representative groups, but the duty of the Council acting for its electorate. It is the legal responsibility of the Council, under NPPG, furthermore, to consult with the public in relation to matters of policy, such as the priority to be allocated to brownfield land in relation to development.

Yours faithfully,

Guildford Greenbelt Group

Appendix 1

Letter from Nick Boles to the Planning Inspectorate 3 March 2014

Appendix 2

Letter from Natural England re Thames Basin Heath SPA