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

  1. 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
  1. 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

 

 

 

 

 

 

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Call for a referendum on Local Governance

Guildford Greenbelt Group (GGG) Press announcement 13 June 2014

RESTORING DEMOCRACY

GUILDFORD GREENBELT GROUP TO SEEK PUBLIC REFERENDUM TO REMOVE GUILDFORD COUNCIL’S EXECUTIVE COMMITTEE AND RESTORE DEMOCRACY

 Move is result of Executive Committee’s failure to follow procedures and respond to its own Scrutiny Committee’s demands for revisions on housing numbers ahead of Guildford Plan consultation

 Guildford Greenbelt Group (GGG), the organisation representing residents concerned by Guildford Council’s plan to build major developments on Surrey’s Green Belt, is to petition for a referendum to remove the council’s Executive Committee and restore a more democratic system.

The Group says it has been left with no alternative following the Executive Committee meeting on Wednesday 4 June which ignored demands by the council’s own Scrutiny Committee to revise the Plan’s inflated required housing number of 652 per year before the Plan goes to public consultation.

Instead the Executive Committee went ahead and approved the current Plan for public consultation – meaning that the public will be told that 652 is the required figure for housing each year.

Susan Parker, Chair of GGG, said: “The Executive Committee has ignored calls from the council’s own Scrutiny Committee to review the housing target and the housing requirement calculations it is based on.

“As a result, we feel we have no option other than to petition for a Referendum to return the Council to a more democratic structure which will better respond to residents’ and councillors’ concerns.

“Guildford area residents who want to ensure the Council’s decision making process is more accountable and transparent, and that the law protecting the Green Belt is properly applied, can start now by signing this petition which will be posted on our website at http://guildfordgreenbeltgroup.co.uk/

The Metropolitan Green Belt was created in the public interest by national planning policy to prevent urban sprawl and stop towns merging into each other. An inflated housing number is not in the public interest and jeopardises the permanence and credibility of our Green Belt.

Under the Localism Act, councils have to hold a referendum if five per cent of the electorate sign a petition calling for one – in the borough of Guildford, that would require 5243 signatures.

The referendum will enable the people of Guildford to choose to support either the Executive system in place at present or a committee structure where the decisions of committees shape policy.

At present, the Council is governed by an Executive system, which means the Leader (appointed by the largest party) and nine other councillors (appointed by the Leader) make all the significant decisions.

Under the committee system all elected councillors are able to participate in the process of local government, which would mean that the decisions of councillors would be followed and respected.

Since 2011, when the Localism Act came into force, nine councils have scrapped the executive for a committee system and at least seven others are considering it. If enough signatures are collected in the borough of Guildford, a referendum vote must be held.

BACKGROUND

On Wednesday 4 June, the Guildford Borough Council (GBC) held an Executive Committee meeting which unanimously approved the Local Plan for public consultation with an unchanged housing requirement figure of 652 houses per annum, which, backdated to 2011, gives a minimum new housing number of 13040. Over the next 17 years that would result in the housing stock in the borough increasing by approximately 25%.

 

On 15 May, GBC’s Scrutiny Committee voted to revise the housing number. It was agreed that this revision should to take place before the Executive Committee meeting on 4 June. GGG therefore considers that Executive governance has ceased to work in Guildford.

 

Cllr Phillips, who proposed the formal recommendation from the Scrutiny Committee that the numbers in the draft Local Plan be revised, asked at the Executive Committee meeting as the first speaker in the Councillors’ part of the debate:

 

I was pleased that the joint Scrutiny Committee accepted my suggestion… to have another look at 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 indicated that a meeting would take place on Friday 6 June, that the number had not been reduced at present but would be “challenged” by the Executive.

 

That meeting has now taken place and there is still no change to the proposed housing number. It seems that 652 will be included as the housing target in the draft Local Plan.

 

GGG is concerned that the Executive Committee has chosen to ignore the valid recommendation from its own Scrutiny Committee in terms of the plan process.

 

Councillors at that committee appreciated constituents’ and residents’ groups’ genuine concerns at the calculation of the housing numbers, and argued cogently for a consequential revision.

 

The figure for Housing Need is set out in the Local Plan Evidence base in the Strategic Housing Market Assessment or SHMA prepared by GL Hearn. Following public demands for a review of the evidence base, Edge Analytics have reviewed GL Hearn’s original SHMA, and only given it “an amber tick”. Residents and campaign groups have questioned the calculations behind the housing number, and noted specific errors. Despite this the housing target number has only gone down by 18 houses per annum (from 670 to 652).

 

As a result the extent of the reliance that can be placed on the Executive’s challenge is limited.

 

This is not the first time that the process of democratic decision-making within the council has been set aside as a result of the decisions of the Executive.

 

Previously, on 13 January 2014, GBC agreed by formal vote that

 

The Council will enable full public involvement in this reappraisal of the evidence base, especially the Green Belt and Countryside Study, by holding a special joint meeting of the two Scrutiny Committees”.

 

In response to this on 4 March 2014 GBC held the Local Plan Scrutiny Forum to discuss the evidence base.

 

The Forum consisted of two parallel mass workshops, each lasting around 2 hours, with no formal record of the comments made. GGG does not consider that this met the undertaking of full public involvement in the reappraisal of the evidence base, but instead represented a measure of tokenism which has been previously displayed in the consultation process.

 

As a result, GGG is calling for a change in the operations of local government and will present a petition calling for a public referendum on the governance of Guildford Borough Council.   This formal petition is available to download from http://guildfordgreenbeltgroup.co.uk

 

-ends-

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.

or

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 on 15 May 2014

This open letter was sent to all councillors just before the Scrutiny Committee on 15 May 2014

Guildford Greenbelt Group

 

 

 

15 May 2014

 

Dear Councillor

 

Scrutiny committee

 

Susan Parker will be speaking on behalf of GGG at the Scrutiny Committee this evening. Various concerns will be raised.

 

However, as background, this letter deals with some of the numerical concerns that GGG have with the current draft Local Plan. As a 3 minute presentation is not the best format for delving into figures, it may be helpful to run through some of those numbers in advance of tonight’s committee meeting so that you are all informed of the detail.

 

The Local Plan draft that you will be considering has, in the foreword, the comment that “The plan has to take into account our persistent under-delivery of housing and the almost complete absence of a 5 year land supply.”

 

We feel that both these statements are fundamental to your understanding of the proposals and the decisions that you will be making. We also feel that both are factually incorrect.

We would like to demonstrate both points – for those of you who are more comfortable with Excel, we are attaching an Excel spreadsheet with the source analysis included so that you can review the calculations.

Persistent under-delivery of housing

GGG does not believe that this statement is true or fair.

We consider (as noted below) that the draft SHMA has many faults. However, it is useful for some base data, and we would note that the consultancy employed by GBC to prepare this document, GL Hearn, comment in paragraph 2.44 on page 27 of the draft SHMA

“Over the 2001-11 decade housing delivery totalled 3187 homes in the Borough (net) relative to planned housing delivery of 3180 homes. The planned housing provision was based on the former RSS housing target which was capacity driven. In the period preceding the demographic projections in this report (which start from 2011) there was thus no net shortfall in housing provision”.

Further, GL Hearn comment in paragraph 2.46 on page 28

“Guildford Borough.. did meet its housing target for the 2001-11 decade as a whole”.

There is a reference to undersupply for the 12 year period to 2013. But this doesn’t arise, since the plan is for the 20 year period to 2031, backdated to 2011. So it is wrong to take the incremental period 2011-13 into account here.

Just to clarify that statement more fully: the draft Local plan suggests a housing need of 652 (this number is not accepted, and more discussion on this later). This translates in the introduction to the draft Local Plan to a total housing requirement of 13040 (which is derived as 20 x 652 = 13040). The plan runs until 2031. So the 20 year period concluding in 2031 must start in 2011. As a result, the supply that needs to be appraised in terms of historic underperformance prior to the plan period must be the supply until 2011.

There is an alternative scenario, where we stop pretending that the plan should run from 1 January 2012. If the inspectors and you as councillors are only looking forward, and not backdating the plan then the supply that we will need to consider will only relate to 16 years, not 20 years. As a result the total would not be 13040 (20 x 652) but would be 16 x 652 = 10432.

We have accepted the backdating as a principle, since this is proposed by the Council, but this principle, if accepted, must be consistently followed. You cannot backdate the requirement, but ignore the historic supply which relates to that requirement, and have a series of mismatched time periods. It must therefore be accepted that there is no historic undersupply, as confirmed by GBC’s own consultants.

Furthermore, you could not assert that the historic housing needs should be backdated, and that because it is now higher, you failed to deliver against a hypothetical, unrecognised housing target. This is an exercise in the ridiculous. No authority in the country can supply against hypothetical retrospective targets – are we supposed to build now on a wholly unrestricted basis in case someone at some stage in the future might possibly apply some higher hypothetical target? Why should you even assume that targets will continually rise? What if some targets, in the future, were perhaps to restrict housing supply or fine you for excessive use of agricultural land – might you then be penalised retrospectively for oversupply or excessive land use now? Clearly, this would be wholly unreasonable, and obviously ridiculous. So, how, in 2011, could you decide that the housing target in 2014 would in fact be retrospectively applied to 2011 and so you needed to build double the amount the High Court agreed?  You cannot assume the impact of future targets when making decisions. You have to compare against actual targets at the time. Compared to actual targets in place there was no undersupply, as confirmed by your own consultants.

And, with all due respect to the planning department, the fact that they assert a thing does not demonstrate the fact. You as Councillors need to interrogate them and require that they prove assertions; because if you do not, an Inspector will.

GGG would prefer not to backdate the requirement, and only to look at the plan going forward. We would prefer to recognise that the date is 15 May 2014 and that we are looking at actual supply for the future, not historic supply. We would prefer a total housing target on the basis of 16 years supply, not 20 years, which is the consequence of that recognition. (16 x 652 = 10432 – ie a reduction from 13040). The Council want to backdate the plan instead, and we have accepted this. But consistency must be applied. If you want to backdate the requirement, then you have to look at historic supply up to the date of that requirement.

 

 

 

Absence of a 5 year land supply

Again, this statement does not seem confirmed by the documents prepared on behalf of Guildford Borough Council.

The SHLAA (current draft) notes (page 9) that existing planning permissions include

Guildford urban area 1480
Ash, Tongham and villages 830
Subtotal 2310
Disputed permission re Ash & Tongham 400
Revised subtotal 1910

 

As previously noted, this plan is backdated to 2011. We are therefore in a position where we are including (in the forward plan) the housing requirement for the years 2011-13. We are effectively pretending that we are in 2011. As a result, looking forward, we should also deduct the actual completions in that period, since these are also relevant to the calculation.

If we cease to pretend we are in 2011, three years’ housing requirement fall away, and the total housing required falls to a total of 10432 by 2031. (16 x652 =10432)

Historic completions are:

2011/12 source – SHMA draft p26 261
2012/13 source – SHMA draft p 26 230
2013/14 tbc 0
Total historic completions (plus 2013/14) 491

 

These can either be deducted from the requirement or added to the “5 year supply”.

Added in there should also be the number in relation to student housing which has been confirmed as applicable to the calculation by Nick Boles in his letter to Paul Beresford (copy letter attached).

This gives the following subtotals:

Historic completions 491
Existing planning permissions 1910
Student planning permissions 2121
Current housing supply 4522

 

This is before any new sites are taken into account at all. This is just existing planning permission and existing completions.

The SHLAA seems to adjust existing permissions in order to suggest that many will not be completed within a five year period. However, since these are in the control of the local authority this should not be acceptable. The University, for example, has suggested that they may choose not to build until 2017; but all these homes could be built tomorrow if the builders so decided. Why should the local authority, and the community, be held to ransom by builders deciding not to build when they have existing permissions? The permissions exist; they must be taken into account.

If there is no shortfall, it is necessary to provide a 5 year buffer of 5%. If there is a shortfall, then the buffer becomes 20%. However, there seem to be sufficient existing planning permissions. The five year housing supply may be calculated – using the disputed SHMA number – as follows:

5 years x 652 homes per year x 105% = 3413

It will be noted that 4522 exceeds 3413. Just to nail the sum

4522-3413 = 1109.

In other words, 1109 of the existing planning permissions would have to be unavailable in the five year period, and there have to be would be NO available extra land on which planning permission is being sought, before there is any question of a failure to provide a 5 year housing supply.

It is therefore demonstrable that before any additional sites are taken into account, the borough does have a 5 year housing supply.

This matter is particularly fundamental. Where local plans are not finalised, the existence of a sufficient 5 year housing supply provides protection against the prospect of planning by appeal, which we have repeatedly been told is of major concern to councillors. We consider that it can be demonstrated that (even on the basis of the draft SHMA, itself open to question) a 5 year supply is in existence. As a result, there should be a sufficient defence against possible appeal by developers in relation to prospective planning proposals being rejected prior to the implementation of the Local Plan.

SHMA basis

It has been noted by many commentators that the SHMA numbers are incorrect and overstated. They rely on 5 year demographics rather than 10 year demographics, and this results in an exaggeration of the blip from boom years when the university has grown. While this is no doubt to be applauded, the regression trend cannot be extrapolated from one year’s blip – it distorts a total. There are a number of other anomalies and errors.

This has been picked up by Edge Analytics in the review commissioned by Guildford Borough Council and included on the evidence base, which notes that it can only give “an amber tick” to the statement that “assumptions, judgments and findings are fully justified and presented in an open and transparent manner”. It further notes that this arises because the choice of scenario assumptions has an important bearing on the housing numbers.

So the housing numbers only have an “amber” tick, and the 10 year comparables that Edge suggest (see page 17 of their report) would show a range of alternatives. We would propose that the “migration led” scenario of 470 is most appropriate. This is of course comparable to the 652 number that is generated by GL Hearn.

However, note also that the GL Hearn number is that generated by the SHMA. As noted in the press by GGG, that number should then be subject to constraints (as noted also in the letter from Nick Boles to the planning inspectorate). No constraints have been applied; it is unclear why this decision has been made.

It has been asserted by the planning department that constraints have indeed been applied. If so, no reduction has been made, so the constraints do not appear to have constrained anything. The number generated by the SHMA is the unadjusted housing need number from the SHMA. If constraints have indeed been applied, why is the number unchanged?

The NPPG envisages that a SHMA number will be generated to demonstrate housing need; that the SHMA will then be subject to review and constraint due to local circumstances; and that this will result in a housing target. This process is neatly discussed, with useful definitions of the various categories, in the recent legal case Gallagher Homes v Solihull. The SHMA result, and the actual housing target, should be different in almost all cases. Why, for Guildford, which has an exceptionally high anomalous number in the draft SHMA (disproportionate to that of adjoining authorities), is there no constraint applied? Is it that the planning department want to find the highest possible housing number? Why?

We would suggest that taking constraints arising from capacity into account would generate a number in the region 300-345.

NB if the 345 housing requirement number were to be used, this would generate a consequential 5 year supply number of 1811 homes (including the 5 per cent.uplift).

5 years x 345 homes per year x 105% = 1811

Duty to cooperate

GGG have noted that GBC has a duty to cooperate and has made this point repeatedly since formation last year, in its letters to Councillors (including our first letter, in December 2013) and in its formal submissions and press announcements, together with a concern that this duty is not being properly fulfilled.

We do have much sympathy with the administrative difficulties of managing a duty to cooperate in the context of a timing mismatch in plan preparation with neighbouring authorities. GGG has noted in the context of our submission to the parliamentary committee reviewing the NPPF that this is effectively almost unworkable.

Notwithstanding this, inspectors are likely to pay particular attention to this requirement, and we would note that Runnymede has now joined Waverley as an authority that has failed in its duty to cooperate. As we have repeatedly stated, not in a spirit of delaying this process but in the spirit of seeking to facilitate the best possible local plan, it is important to get it right, and a rushed plan is a plan that might fail.

We would note that if councillors had listened to GGG in relation to this in December 2013, rather than dismissing our point, the Local Plan would have been somewhat more advanced at this stage. We would urge you to listen to our concerns, and those of other residents’ groups, rather than to press on regardless with a plan that has so many flaws.

Summary

We consider that the Local Plan has a number of failing elements, which must be tested and challenged by councillors, not merely accepted.

We consider that councillors have not been well advised, and that they have placed too much reliance on the unsupported statements made by the planning department, some of which have proved unreliable.

We also consider that it is the responsibility of the Scrutiny Committee to make those challenges (and consequent corrections) at this time, with the utmost speed, rather than to proceed with a failing plan now.

These include:

  1. The assumption that the SHMA number is correct (we know it is not)
  2. The failure to apply constraints to the SHMA number (this must be constrained)
  3. The failure to meet the duty to cooperate (this must be done or the plan will fail)
  4. The belief that we do not have a 5 year land supply (we do and this is demonstrable)
  5. The belief that we have had persistent under-delivery of housing (no underdelivery)

Please make these corrections before the draft Local Plan is put forward as part of the consultation exercise.

Yours faithfully,

 

Guildford Greenbelt Group


 

Appendix 1

Letter from Nick Boles MP to Sir Paul Beresford MP 7 February 2014

Letter attached in full but note in particular:

Can student housing be included in a local authority’s Local Plan housing numbers?

Yes. Student housing makes a significant contribution towards housing supply by taking pressure off housing stock. The Government has clarified guidelines to make it clear that local authorities can include student housing in the calculation of, and the monitoring toward, housing needs regardless of whether they are communal or sited on a university campus.”

 

Housing numbers are too high

Key Local Groups Combine on

New Homes Target for Guildford

 

For Immediate Release: Wednesday 7 May 2014

 

Eight key local groups have come together to agree a target new homes figure of 300-345 per year for the life of the new Guildford Local Plan. The groups are The Guildford Society, Guildford Vision Group, Guildford Residents’ Association, East Guildford Residents’ Association, Save Hogs Back, Guildford Greenbelt Group and CPRE Surrey.

Publication of the first consultation Draft of the Local Plan is expected today. Once approved, the Plan will shape the future development of the borough and determine the new annual housing target for the next 20 years.

The arguments used by the group to arrive at a proposed 300-345 housing target for the Local Plan are based on the rationale of the National Planning Policy Framework & Practice Guidance. Please see attached reasoning.

The groups all agree it is important to take account of Guildford’s unique combination of characteristics to ensure the evidence properly assesses housing need for the Borough.

  • Guildford is a highly interconnected town which is not only influenced by London but also has its own high value economy and a student population.
  • Guildford is also a special case due to its topography as a gap town complete with converging road, rail and river routes, the surrounding Green Belt and the plethora of special designations such as ‘Area of Outstanding Natural Beauty’ and ‘Special Protection Area’.

Says Bill Stokoe, chair of The Guildford Society: “The group considers that, although it would be challenging to identify sufficient land to accommodate 300-345 homes a year, a target in this range would allow us to meet the social and economic obligations of the Borough without harming the value of our countryside and built environment. Debate could focus how to accommodate new development with minimal harm to character and how to open up opportunities for positive change.”

Ends

 

Housing Provision in Guildford Borough

 

The Guildford Society, Guildford Vision Group, East Guildford Residents’ Association, Guildford Residents’ Association, Guildford Green Belt Group, Save Hogs Back and CPRE Surrey all agree that a housing target in the region of 300-345 homes a year is the maximum appropriate for Guildford. This is based on an assessment that the Strategic Housing Market Assessment (SHMA) figure should be in the order of 450 a year and that once constraints are taken into account, an annual figure of 300-345, although hard to deliver within the constraints, could be achieved over the life of the plan until 2031.

 

Housing Need Assessment

All groups have previously submitted reasoned responses on housing need. We consider that once the inflationary distortions have been removed from the draft SHMA, the figure should be in the order of 450. Corrections required include basing general forward projections on a more representative historical 10 year period, projecting realistic student growth not based on a one off increase, disaggregating the student population from forward housing demand and from net international migration, reflecting increased birth rate in household size, and removal of the biased, one way application of the duty to cooperate.

 

Demographic/ Migration Drivers

Guildford Borough Council’s report “How Many New Homes” identifies that “International migration is estimated to have had the most significant impact upon population in recent years”. Edge Analytics (July 2013 report) advise that “Adopting long term growth assumptions for Guildford Borough based on uncertain estimates of international migration is not recommended, particularly given the evidence suggested by the 10 year migration history, with a lower annual net impact evident.”

 

The Guildford Society has carried out a high-level analysis of the Communities and Local Government/ Office for National Statistics (ONS) household projections to demonstrate that they over-estimate the number of new homes required. This analysis shows that the projected need for homes is c. 500 per year. However, there are also further questions over the ONS data that need professional demographic analysis to resolve, but which point to a lower need per year. For example, ONS overcrowding data has been updated showing the suppressed household formation is not as bad in Guilford as expected, migration projections based off 5-years cause the recent increase in overseas students to be projected forward contrary to the University’s expectations, etc.

 

Similarly, the Guildford Residents’ Association and Guildford Greenbelt Group show that excluding the effect of student population change completely results in a more accurate prediction of the true needs of the Borough. The migration-led ten year figure of 470 homes per annum is considered a much more robust starting point for the analysis, as it is relatively less affected by the isolated high-growth in student numbers from 2008-11. A proper and robust analysis of demographic drivers is expected to reduce the true need from the “raw” starting point of 470 to a figure around 400.

 

Economic Growth and Employment

The Guildford Society response to the Draft SHMA takes account of employment growth and shows the need arising from employment to be 463 homes. Given the constraints, we consider the Local Plan needs to improve Guildford’s transportation hubs to ensure in-commuters can easily access places of employment so as to ensure that the economy is not restricted by the housing constraints.

 

 

Affordable Housing Need

Care needs to be taken in translating a register of demand for affordable homes into an annual need figure. The Save Hogs Back Campaign contend that affordable need is accommodated within the overall figures we propose. Using data from the 2014 draft SHMA, it can be shown that the affordable need is between 170 and 257 pa. This is based on GBC’s current assumptions that 35% of income is the maximum that can be spent on housing and that the maximum affordable rental should be 70% of the market value, and also assumes that GBC will continue to make use of the private rented sector.

 

Methodology, Assumptions and Sensitivity Testing

Local circumstances can lead a Local Authority to adopt a methodology that is appropriate to its area and to undertake sensitivity testing of assumptions based on the underlying demographic projections. The National Planning Practice Guidance recognises preparing a SHMA to assess housing needs is “not an exact science” and the House of Commons Library has made clear that the “Government does not want to lay down in detail the method of calculating housing need”, except that this must be based upon evidence.

 

Given Guildford’s unique combination of characteristics (a highly interconnected town with its own high value economy, student population and proximity to London) it is reasonable for GBC to ensure evidence properly assesses housing need for Guildford Borough rather than rigidly following one standard methodology. GBC should use the provisions in the NPPG to ensure the methodology and assumptions in the need assessment are appropriate for Guildford as well as being robust.

 

Taking the different approaches together, the groups agree that a SHMA properly reflecting Guildford Borough is in the region of 450 per year.

 

Built Housing Targets

GBC does not need to make any adjustment for historic under performance. As noted by GL Hearn (p27 paragraph 2.44), housing delivery totalled 3187 homes in the Borough compared to planned housing provision of 3180 homes. In the period preceding the demographic projections in this report (which start from 2011) there was thus no shortfall in housing provision.

 

Clearly the significant constraints in the Borough need to be taken into account when determining the target for homes to be completed per year. These constraints are well known and include:

  • National landscape designations such as AONB and potential AONB
  • International and national biodiversity protection including the Thames Basin Heaths SPA, SACs, National Nature Reserves, SSSIs,
  • Ancient woodland and Sites of Nature Conservation Importance
  • Ancient monuments, National Trust properties, historic gardens and other archaeological sites and built heritage of importance (eg Conservation Areas)
  • Metropolitan Green Belt
  • Topography of a gap town with a river, rail and roads running through it
  • Floodplain, waterways, Wey Navigation & protection of aquifer water sources
  • Ministry of Defence Land
  • Registered commons
  • Provision for critical infrastructure (water supply, power, sanitation, waste) including safeguarded sites
  • Strategic agricultural land for farming

 

Once these constraints are overlaid, this reduces the ability to fulfil unconstrained identified need to the region of 300-345. In reality, it will be a challenge to identify sufficient land to meet this annual target. However, we believe a figure in the order of 300 can be met and potentially exceeded periodically with a visionary and creative partnership between the Council, other authorities and other partners. This will allow us to meet the social and economic obligations of the Borough without harming the value of our countryside and built environment.

 

Comparison with other authorities

Whilst not a formal step in the Local Plan process, it is well worth comparing Guildford’s targets with those of other neighbouring authorities. Those with agreed targets include:

Epsom 181

Tandridge 125

Spelthorne 166

Mole Valley 188

Surrey Heath 190

Rushmoor 374 (includes a major brownfield opportunity)

Elmbridge 225

Woking 292

This benchmarking demonstrates that a target for GBC of 300-345 is in line with other neighbouring authorities and demonstrates to the public that Guildford is delivering its “fair share” of housing.

 

April 2014