Your guide to responding to the Draft Local Plan

It would appear that much of the evidence has been developed to support a predetermined purpose of excessive growth in population and housing with no regard to capacity resulting in the “need” to build large developments in the green belt.

• There has been insufficient work done on the capacity of the town centre/urban area to accommodate housing despite the fact that that everyone acknowledges that this is the most sustainable solution.
• The evidence base is inadequate, incomplete and generally not fit for purpose.
  • For example the list of evidence in Appendix C refers to 2014 ELA (which is not available), only refers to GBCS vols 1-4 yet plan refers to vols 5 and 6.
  • The SHMA [Strategic Housing Market Assessment] is in draft form, uses out of date ONS figures
• The ELA 2013 uses flawed methodology e.g.
  • Forecasts increase in retail employment of 11% (2006-2031) whereas the CERR forecasts that 11% of retail will close by 2018 and this trend will continue.
  • Omitted to include the space used by commercial offices
  • Predicts growth in employment in warehousing despite being amongst the highest land prices in the country/most congested roads
• The Settlement Hierarchy figures have been manipulated to suit the desired outcome.  E.g.
  • Use of Private schools in provision of education
  • Inclusion of walk to school routes with no footpaths along single track roads.
• The GBCS is subjective and inconsistent.
• The SHLAA is inconsistent, includes land that is not available, sometimes includes the need for SANG and sometimes doesn’t.
• The Sustainability Appraisal and Habitats Regulations Assessment were not published until 6 August some 5 weeks after the consultation started.
• The transport studies are bases on zero population growth.
• The duty to cooperate paper has not been published.
• There is no up to date Retail Study.
• There is no up to date Visitor Strategy
• There is no Infrastructure Delivery Plan

This non-exhaustive list clearly demonstrates that the evidence base is flawed.  No effort has been made to track changes in any documentation meaning that the job of reviewing the paperwork is unnecessarily difficult and not transparent and therefore the public has no faith whatsoever in the majority of the evidence base.

Policy 1 – Presumption in favour of sustainable development  – OBJECT

• This policy is incomplete and misleading.
• Policies should be written with the intention of being enforceable for the life of the plan.

It is in breach of NPPF 14 which states “specific policies in this framework indicate development should be restricted” [e.g. sites protected by the Birds and Habitats Directive, land designated SSSI/AONB/Green belt, locations at risk of flooding etc.

It is in breach of NPPF 119 which states “the presumption in favour of sustainable development does not apply where development requiring assessment under the Birds or Habitats directive is being considered, planned or determined”.

It is in breach of NPPF 17 which outlines 12 core principles which should underline the plan e.g.

• “Be genuinely plan-led, empowering local people to shape their surroundings….
• “Actively manage patterns of growth to make the fullest use of public transport….”

No monitoring is proposed for reductions in growth estimates and the effect this would have on housing or employment land and this is an omission.

No monitoring is proposed for the cumulative effect of development and this is an omission.

Policy 2 – planning for the borough – our spatial development strategy –  OBJECT

This policy is in breach of NPPF 158 “Each local planning authority should ensure that the Local Plan is based on adequate, up-to-date and relevant evidence …”

The evidence is flawed, not up to date, and does not include e.g.:

• The use of the latest ONS figures released in May 2014 well in advance of the consultation.

• windfalls

• Reuse of empty housing

• Use of student accommodation

• Incorrect application of backdating the plan to inflate the figure.

• Use of a five year trend when a ten year period is much more appropriate

• Incorrect assumptions on how to handle the student population e.g. those on sandwich courses, inflated numbers due to the one off introduction of tuition fees etc.

• It is not subject to constraints

• The lower population figures have a knock on effect on the need for employment land and this has not been addressed.

• Does not reflect latest government policy on the reuse of office buildings to residential.

• It is not clear whether the housing number of 13,040 homes will be adjusted to take into account the likely start date of 2015 (i.e. a build rate of 652/annum) or be backdated and require a build rate of 815.

• Does not reflect government policy to reduce international migration which accounts for well in excess of 50% of the projected population growth in the borough.

• The figures are inconsistent. E.g. The SHMA quotes a population of 166,031 by 2031 and the draft Plan uses a figure of 155,400.  To date there has been no logical explanation for this significant variation in the key data.

• Flexibility is built into the plan but there is no requirement for brownfield to be used first so that green belt developments will take place first and the borough could easily be left with unused brownfield sites and a run-down urban area which is in serious need of regeneration.

• There is no justification whatsoever to build on the green belt or to inset the villages until all alternatives in the more sustainable urban areas have been used. Sufficient capacity exists in the urban area to provide for objectively assessed need.

Policy 3 – Homes for all – OBJECT

This policy is unenforceable and gives developers an opt-out on alleged viability waivers.  Why should Guildford be providing homes for all?

The number of homes provided should not exceed the capacity of the borough.  E.g.

• The policy as worded gives a carte blanche for the UNIS to continue to expand provided that it has the ability to house 60% of its FTE students.  The housing demand from the remaining uncapped 40% will continue to exert upward pressure on housing costs to the detriment of all local people in need of accommodation.
• The UNIS should be the subject of a separate policy which requires it to build accommodation for a greater % of its students, and that requires it to build out its existing extant permissions.
• The policy should include wording which states that “All new homes require access to roads, healthcare provision, education and local community centres prior to being occupied”

The policy is worded very badly and represents a wish list rather than a definitive policy: E.g.

• We will expect a minimum…
• They will be expected to make…
• We will consider on a case by case basis evidence of viability

The policy needs to be reworded with a view to implementation I.e.  We require… 

The implied requirement for any large site of in excess of 500 homes to provide traveller sites is unenforceable on some sites due to environmental constraints. This eventuality is not covered in the policy. This is an omission.

It would appear that the borough wishes to provide more than its fair share of traveller sites and as these cannot be sited in the green belt large swathes of green belt adjustment will need to be made.

Provision of traveller sites needs to be proportionate taking into account all the relevant constraints.

Policy 4 – Affordable Homes –  OBJECT

The viability clause needs to be removed as it is open to abuse by developers.    

Until a corrected and robust SHMA is published it is impossible to assess the true local need for affordable homes.

Lack of available land is a huge constraint in the borough.  If developers are allowed to make payments in lieu of building affordable homes the shortage of suitable sites will be exacerbated.

There needs to be a requirement that the affordable homes provided remain affordable in perpetuity.

We dispute the assertion that increasing the supply of housing will make housing more affordable.  Even the consultants agree “..It is less clear how an upwards adjustment to housing provision would manifest itself as an improvement to the affordability position.” House prices in the area are driven by the market values in London and the cost of borrowing.

Policy 5 – Rural Exception Homes – OBJECT

• Traveller sites are inappropriate in the green belt and rural exception sites located in the greenbelt are therefore not an appropriate solution for travellers.

• Rural exception sites, should be exceptional, for local need only, and for affordable homes only. They should not be used as a back door route to Greenfield sites for market housing.

• Paragraphs 4.66 and 4.77 should be deleted.

Policy 6 – making better places – OBJECT

• This policy is unenforceable.  How can it be possible to provide “places for communities to meet and interact, such as play and recreation and other public spaces in large developments” when the criteria for “large developments is over 0.5 hectare?
• This policy, like many others needs to be reworded to “require” rather than “expect” to ensure that it is enforceable.
• We support the requirement to give priority to non-car based modes of transport.

Policy 7 – Sustainable design, construction and energy – OBJECT

• This policy is unenforceable.  It needs to be reworded to “require” rather than “expect”.
• The viability get out clause is concerning as this will be used as an excuse not to comply.  Reference to viability needs to be removed.
• If there is a true move towards low carbon economy there should be a requirement for all developments to provide electric charging points for cars
• Green fields and open spaces contribute hugely to reducing flood risk.  Concreting over the green belt will exacerbate what is already a very fragile situation.  This has not been considered.
• The wording of this policy does not comply with NPPF 154 – e.g. what does “we will give strong support and encouragement” really mean?
• The requirement for “biodiversity improvements” and “water efficiency measures” needs to be expanded upon because otherwise it is meaningless.

Policy 8 – Surrey Hills Area of Outstanding Natural Beauty – PARTIAL SUPPORT

• The wording of this policy is too subjective.  There should be a list of types of development which would be considered appropriate to remove much of the subjectivity.
• The policy needs to be reworded replacing the word “can” with “comply”
• It is not only proposals within the AGLV which could have a ”negative impact upon views into and out of the AONB”.  This needs to be rewritten to read “Proposals which have a negative impact upon the views to and from the AONB will not be acceptable”.

Policy 9 – Villages and major previously developed sites – OBJECT

• The GBCS is so flawed in both methodology and content that it cannot be relied upon as evidence.
• The draft SHMA is also flawed and so no sound evidence exists for the need to inset villages.
• The “need” to alter the boundaries of the greenbelt cannot be demonstrated.
• It has been demonstrated without doubt that the scores in the Settlement Hierarchy which informs this policy have been manipulated.
• The proposed safeguarding of land for development is unnecessary until all other land in the urban areas, and sites beyond the greenbelt have been exhausted.  The safeguarding creates blight on property in affected areas.
• East Horsley is proposed to be reclassified as a Rural District Centre which would allow uses such s factory outlets, warehouse clubs, casinos etc.
• The policy needs to include a commitment to get superfast broadband accessible by ALL residents in the borough by end 2015 as this will provide much greater support to rural industry than anything else

Policy 10 – Green Belt and Countryside – OBJECT

This policy is disingenuous it states “We will continue to protect the Metropolitan Green Belt” yet the draft plan policies propose wholesale changes to the Green Belt.

Surrey County Council voted unanimously to protect the Green Belt yet this has been totally ignored.

• The 12 core planning principles of NPPF 17 need to be included in this policy.
• There is no evidence that “planning should be genuinely plan-led, empowering local people to shape their surroundings..” has been adhered to as the comments made by residents in the SSIO consultation have in the main been totally ignored.

• There is no distinction between how the Green Belt is to be treated and how the land Countryside beyond the Green Belt is to be treated.  The differences need to be clarified as a matter of urgency.
• There is no commitment to the permanence of the Green Belt and this needs to be explicit
• Para 4.122 needs to be included in the policy wording
• Until such time that the SHMA, SHLAA and GBCS evidence is robust enough to be considered sound we do not see any evidence to change the boundaries of the Green Belt either in terms of insetting villages or removing site 66 from the Green Belt.

There is no need to designate new Green Belt land – this is not the Guildford Green Belt rather the Metropolitan Green Belt, designed to protect Greater London.  It is not clear why this is the only addition to the Green Belt except for the fact that it is in the ward of the leader of the council!

Policy 11 – Ash and Tongham Strategic Location for Growth – OBJECT

We note that at least three members of the Executive Committee are based in Ash/Tongham

• It is not clear why Ash and Tongham should have been singled out for improvements in infrastructure capacity to meet the need of residents and that other areas proposed for significant developments, strategic and otherwise have not been afforded the same luxury.
• It is not clear why there should be a separation area here and not between other villages which will coalesce under the proposed plan [e.g. East and West Horsley, Onslow and Park Barn/Wood St Village, Bookham and Effingham]
• It is not clear why Green Belt elsewhere  should be sacrificed yet additional Green Belt be proposed here.

Policy 12 – Historic Environment – OBJECT

• This policy is too loosely worded.
• It should include the much of the wording from NPPF 133 “Where a proposed development will lead to substantial harm to or total loss of significance of a designated heritage asset local planning authorities should refuse consent unless it can be demonstrated that the substantial harm or loss is necessary to achieve substantial public benefits that outweigh that harm or loss.”
• It is clear that there is a lot of documentation missing.  E.g. Conservation area appraisals have not been completed.

Policy 13 – Economic Development – OBJECT

This provision of jobs should be closely related to the population growth for the duration of the plan.  As this has not yet been established it is impossible to judge how much support for jobs and employment space is needed.

• New employment sites in the Green Belt are unacceptable and should not be considered until the brownfield land in the urban area has been properly utilised.
• This policy stems from the Corporate Plan which was never the subject of public scrutiny.
• The majority of people will not be aware that the planning classes referred to are for warehousing, office and industrial use.  These types of development need to be situated where there is excellent infrastructure in place and is therefore completely unsuitable for sites surrounded by narrow local roads which cannot accommodate HGVs.  This type of use is not consistent with the high cost of land in the borough or the availability of lower skilled workers.
• Existing incubator sites and start-up space e.g. at Surrey Research Park are under-utilised : all car parking at these sites should be underground, this frees up a significant area which could be put to better use than open air car parks.
• The Employment Land Assessment needs urgent review and cannot be relied upon to inform this policy.

This policy needs to include the area known as Walnut Tree Close/Woodbridge Meadows which should be designated a regeneration zone as it is currently run down and a poor use of land which could provide an extremely sustainable location for offices and residential use.

Policy 14 – The leisure and visitor experience – OBJECT

There is a reference to a yet to be published visitor strategy – this should have been done as part of the evidence base in advance of the publication of the draft Local Plan.

• This policy fails to list some of the main entertainment facilities in the town centre, e.g. Yvonne Arnaud and  including those owned by the council e.g. G-Live.
• It is not clear why there is a need to improved accommodation facilities when the university has this type of facility available for almost half of the year.
• This policy is loosely worded and unenforceable.  Any reference to “expect” should be replaced with “require”.
• This policy makes no mention of the contribution of the outstanding countryside in the borough which is highly valued by walkers, cyclists and many others. This is an omission.

Policy 15 – Guildford Town Centre – OBJECT

This policy makes no sense without a definition of exactly what is meant by “Guildford Town Centre”.  Notwithstanding the above, the Vision is imprecise… What is meant for example by “We will invest in creating high quality public realm”?

Many residents would question that the Council is following its own vision …”we pledge that we will continue and extend an active dialogue with our residents and other stakeholders” – it is one thing to have a dialogue, but if the council doesn’t show any evidence of listening there is little point in the electorate wasting further time on a dialogue.

• It is vitally important that a Master Vision for the town centre, such as that proposed by Allies and Morrison is quickly brought to a position where capacity of the area can be established.  The Master Vision study was commission too late and too cheaply to have been of significant use and this should have been a key part of the evidence base.
• The reliance on the huge increase in retail development is totally at odds with the trends predicted by industry experts.
• The attraction of Guildford as a retail destination is that independent shops are not swamped by high street chains.

Policy 16 – District and Local Centres – OBJECT

• This policy is based on the flawed Settlement Hierarchy which needs to be redone.
• We reject the designation of East Horsley as a District Centre
• What is meant by “In order to keep these areas lively we will encourage and facilitate new homes provided above ground floor level”?
• The key evidence documents listed in this policy are not the latest versions

Any new retail developments, regardless of location in the borough should be required to provide for underground car parking.

Policy 17 – Infrastructure – OBJECT

• It is completely unacceptable that the research on infrastructure has not been completed prior to the draft Local Plan going out to consultation
• There is no understanding of the capacity of the borough as evidenced by the late inclusion of a secondary school in West Clandon.
• The whole of the draft Local Plan is unsound on this policy alone
• There has been no work on the cumulative effect of all of the policies on infrastructure and this omission is scandalous.
• Viability waivers should not be necessary
• There is no mention of superfast broadband which should be included as a key piece of infrastructure

Policy 18 – Sustainable transport for new developments – OBJECT

• This policy is weak and needs rewording replacing “expect” with “require” so that it is enforceable.
• New developments should be sited where walk to work, walk to train is possible.  Reliance on buses or private cars cannot meet the requirements of a low carbon, sustainable economy.
• Residents of Strategic sites in the countryside will rely on the car and increase congestion in the town centre as residents travel to shop.

Policy 19 – Green and Blue Infrastructure – OBJECT

It is not clear what is meant by Blue infrastructure. 

• This policy must to more than “aim” to protect.  The policy needs rewording as it is unlikely that all development will be able to provide additional green and blue infrastructure.
• It needs further definition, which should contain protection of public rights of way, allotments, public green space etc.
• There is a clear opportunity to enhance the setting of the River Wey through the town centre.  It is currently bordered by open air car parks, a bus depot and other inappropriate development.  This is a highly sustainable area and the regeneration of Walnut Tree Close/Woodbridge Meadows presents the opportunity to improve the town and reduce the risk to the Green Belt. It is imperative  that this opportunity is not compromised by the final wording of this policy.

POLICY 66 – Former Wisley Airfield – OBJECT

This policy is not sustainable.  The amount of the site considered “Previously Developed Land” is less than 20%, much of this is too close to the SPA to be available for development

A development at this location will

• NEGATIVELY IMPACT THE OPENNESS OF THE GREEN BELT
• Not be sustainable as:
  • insufficient land is available
  • it is impossible to provide safe walking and cycling routes to the nearest station particularly in winter as the roads are unlit
  • Will be impossible to provide enough jobs onsite for residents resulting in further traffic on the local road network
  • No existing access to public transport and it is unrealistic to assume that residents will not rely on the private car
  • Public transport is limited by the weight restrictions imposed on surrounding roads which are narrow and unsuitable for PSVs
• negatively impact the SPA and result in the destruction of the SNCI
  • any onsite SANG provide would increase footfall on the SPA which is to be avoided
  • onsite SANG is not effective
  • be impossible to stop pets damaging protected local wildlife habitats
• add a substantial increase in traffic to the overstretched local road network
• impact negatively on the nearby section of the A3 resulting in a further deterioration in air quality [already the worst in the borough]
• takes no account of the Ockham DVOR beacon and the restrictions on development around it
• negatively impact the surrounding Ockham conservation area due to increased traffic passing through the village
• negatively impact the views from the AONB
• negatively impact the night sky – there are currently no street lights within a two mile radius (with the exception of the Ockham Park junction
• impact negatively on the water table – the village is regularly awash with raw sewage as the drainage infrastructure is unable to cope
• impact negatively on numerous existing Public Rights of Way which are well used by local residents and others on a daily basis
• reduce the availability of good quality agricultural land
• negatively impact the Royal Horticultural Society Gardens which is the largest tourist attraction in South East England due to additional traffic at the Ockham Park roundabout
• result in the coalescence of the new development and the hamlet of Ockham
• impact negatively on the habitat of the protected species known to inhabit the site
• impact negatively on existing wildlife corridors especially nocturnal species which will be unable to survive
• the site outlined in Policy 66 does not include access to the Ockham Park roundabout – there is therefore no access to the Strategic Route network proposed.
• Exacerbate pressure on local schools which are unable to accommodate existing children.  There is no space allocated for schools onsite so all children will need to commute to school [none will be able to walk or cycle]
• Be impacted negatively by the consented InVessel Composting facility
• Irrevocably harm the rural nature of the site
• Impact negatively on the surrounding area as infrastructure will need to be improved (out of keeping with a rural environment)