Office of National Statistics data show Guildford Borough Council’s housing numbers are too high

The Office of National Statistics (ONS) has just published new population projection data for the whole country (yesterday, 27/2/2015), which can be found here:

National Planning Policy Guidance was updated yesterday too, to reflect the fact that this ONS projection, as the most up to date assessment of future housing growth, should be the basis of assessment of housing need – see the new guidelines here:

The Office of National Statistics estimates that the population in Guildford borough will grow by a total of 21,600 people between 2012 and 2031.

We have reviewed housing need, taking into account outstanding planning permissions, because these clearly affect the number of homes that will be needed.

Our provisional calculation suggests that an annual housing provision below 400 homes per annum would meet Guildford’s housing needs, including that of any incoming population.  This number is before any adjustment for constraints, such as Green Belt, infrastructure, congestion and air quality.

Why is Guildford Borough suggesting that we need 816 new homes per annum- more than double this?



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.


If you would like to learn more about Guildford Green Belt Group, visit our website –

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

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:


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:

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:
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.

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.


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

Nick Boles letter to the Planning Inspectorate 3 March 2014

Nick Boles letter-1

This is the letter from Nick Boles to the Planning Inpectorate which states “a Green Belt boundary can 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 meet objectively assessed needs unless  specific policies in the Framework indicate that development should be restricted. Crucially, Green Belt is identified as one such policy.”

It is also made clear that Mr Boles expected that this advice would be heeded by the Planning Inspectorate.

Some commentators have instanced the reply from the Planning Inspectorate, and the second letter from Mr Boles, as indicating a withdrawal from this clear statement.  This is not the case- the second letter makes it clear that the NPPF still applies.  But then, the statement above is actually a quotation from the NPPF – see the GGG open letter to councillors dated 25 March 2014 which makes that clear (link here ). So of course it isn’t rejecting the NPPF.

Mr Boles’ statement clearly states that if policies in the Framework (especially Green Belt) indicate that development should be restricted, there is no obligation to meet objectively assessed needs. This is the opposite of the statements currently made by the planning officers in the summary to the Executive for the meeting on 4 June 2014.  We would suggest that they reconsider this advice, which seems to be in contradiction to clear ministerial guidance.