Master Vision for Guildford

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

http://www.guildford.gov.uk/media/17154/Item-7—Guildford-Town-Centre-Vision-2014/pdf/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.

 

 

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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

Executive Committee agenda for 4 June 2014

Guildford Borough Council will be holding an executive committee meeting on 4 June 2014.

The agenda has been published in relation to that meeting, and it can be viewed on a webcast.

This is the page with the agenda and supporting documents:

http://www.guildford.gov.uk/article/12314/Special-Meeting—Executive—4-June-2014

Note that this is the discussion on the deliberations of the Scrutiny Committee, including the revision of the housing number (item no. 8)

http://www.guildford.gov.uk/media/17116/Item-34—Appendix-4a—Joint-Scrutiny-Committee-resolutions-and-officers-responsepdf/pdf/pdf46.pdf

with the Appendix A which is referred to:

http://www.guildford.gov.uk/media/17117/Item-35—Appendix-4b—Sub-Appendix-A-Joint-Scrutiny-Committee-Resolution-8pdf/pdf/pdf46.pdf

The housing number has not yet been revised from the planned 652 per annum.

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

 

 

GGG open letter to councillors dated 4 April 2014

Dear Councillor

I feel I need to write to express my view on some specific advice you were given by the planning department yesterday evening, since I was not permitted to express this view in the council chamber.

St Albans

It was stated yesterday evening that the St Albans (Hunston) decision only relates to a specific planning decision.

This is correct, but its interpretation of the law relates also to local plans. So that you can read the Appeal Court decision in full and form your own view, I am sending this to you again.

See in particular paragraph 6 (my highlighting):

“6. There is no doubt, that in proceeding their local plans, local planning authorities are required to ensure that the “full objectively assessed needs” for housing are to be met, “as far as is consistent with the policies set out in this Framework”. Those policies include the protection of Green Belt land. Indeed, a whole section of the Framework, Section 9, is devoted to that topic, a section which begins by saying “The Government attaches great importance to Green Belts”: Paragraph 79. The Framework seems to envisage some review in detail of Green Belt boundaries through the new Local Plan process, but states that “the general extent of Green Belts across the country is already established.” It seems clear, and is not in dispute in this appeal, that such a Local Plan could properly fall short of meeting the “full objectively assessed needs” for housing in its area because of the conflict which would otherwise arise with policies on the Green Belt or indeed on other designations hostile to development, such as those on Areas of Outstanding Natural Beauty or National Parks. What is likely to be significant in the preparation of this Local Plan for the district of St Albans is that virtually all the undeveloped land in the district outside the built up areas forms part of the Metropolitan Green Belt.”

Further I would note that paragraphs 27-33 are relevant, especially paragraph 29, which notes that the objectively assessed housing need is what should be considered, but that this should be considered in the context of the geographical area:

“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.”

As a result I think that the assertion made by Carol Humphrey (Head of Planning Services) that St Albans has no relevance in the context of the Local Plan is not correct. Furthermore I think that recent case law and recent Secretary of State decisions demonstrate that the shortfall in housing supply does not provide a sufficient justification to override the protection of the Green Belt not only in relation to specific planning appeals, but also in relation to any review of boundaries too.

Nick Boles letters

It was stated this evening by Carol Humphrey that the most important letter from Nick Boles was that on 13 March. It was implied that in some way this undermined any advice given in the first letter (which I have sent to you previously, which states “the Framework makes clear that a Green Belt boundary may be altered only in exceptional circumstances” ). You have all been sent all three letters, but I am sending the two letters from Nick Boles to you again. The first letter was clear advice specifically given to planning inspectors. The letter from planning inspectors queried this, and then Nick Boles stated that the advice given was a clarification of existing rulings. You wouldn’t expect a politician to admit to a U-turn in writing, I presume?

Nothing in the second letter undermines the clarification in the first. The first letter states that Green Belt is a policy that indicates development should be restricted. To quote again:

“local 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”

As noted in my open letter to you, this is a word for word quotation from paragraph 14 of the NPPF. So Nick Boles is right, it is clarification not change. The second letter from Nick Boles confirms that the NPPG “provides useful clarity on the practical application of policy. It should provide helpful support for Inspectors and should not normally be considered a reason for extending examinations.” I don’t see that this is a withdrawal of the original advice. He is stating that it isn’t the policy but the Inspectors’ interpretation of that policy that has been wrong. The fact that Nick Boles is suggesting that the rules were always as they are now doesn’t mean that his guidance on the current rules should be ignored.

The extremely clear statement about the Green Belt in these letters are that Green Belt is a policy which restricts development – and, as Nick Boles rightly notes, that policy is stated in the NPPF. You should be entitled to rely on this guidance from the Secretary of State, which he put out as an open letter with a view to its influencing local plans and the inspection process.

With kind regards

Susan Parker