Good letter in the Guildford Dragon. See their site for the follow on comments.
Letter: The Draft Local Plan Is Not Logical
The logic of Guildford’s Draft Local Plan is flawed. It is not a plan, it is merely a forecast, an extrapolation of very recent trends, assuming that no other factors will affect those trends. This, to use a planning inspectors’ phrase, is not a “true reflection of reality”.
There is no recognition or discussion of the consequences of trying to expand Guildford’s population so drastically. The more that Guildford Borough expands, the more it comes up against the constraints of geography, etc. Logically, we should be planning for a slower rate of growth in the future, not an acceleration. To dress an extrapolation of past trends as if it were some sort of “evidence base” is misleading.
I wish to make four points:
1. The target for new homes seems to have been arrived at regardless of the very significant constraints imposed by geography and finance. Guildford’s road and rail network is already overloaded.
How will the existing congestion be overcome? How much worse will this become as a result of housing developments in neighbouring boroughs, such as the substantial expansion planned in the Cranleigh area? What further problems will be created by a 20 per cent increase in population?
Moreover extra land will need to be set aside for new schools, hospitals, etc. How will these be funded? As the plan does not discuss this aspect, should we deduce that the planning department at Guildford Borough Council (GBC) does not think it relevant?
2. Although the draft plan refers to “local market dynamics and the supply/demand balance”, it fails to explore how this balance will be affected by the supply and prices of houses that are built.
Obviously if more houses are built, more immigration into the borough will be attracted. The plan seems to be to build houses to allow for an increase in the population to 166,052, i.e. an increase of 28,850 (20.7 per cent) over the next 20 years.
3. Net immigration at 16,340 (12 per cent) accounts for more than half of the future growth. It would be more logical to conclude that since immigration is largely responsible for the housing shortage, there is now no scope for providing for further immigration into the borough.
I note that, following an inspector’s comments in the case of Hart Rural District Council, Waverley Borough Council was unable to sustain the argument that there should be no net migration, but Waverley is only 61 per cent Green Belt, and they were not considering such a high proportion of growth from immigration.
4. The report downplays the importance of green belt policy. The green belt is meant to provide a limitation on the inexorable growth of London. Nick Boles, until July the planning minister, stated quite categorically in March this year “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”.
If the local authority wishes to adjust the green belt it may do so, but “it must be transparently clear that it is the local authority that has chosen this path”. It could not be plainer: this overrides NPPF (National Planning Policy Framework) guidance. As the Draft Local Plan does not argue otherwise, I can only assume that GBC Officers are not aware of the minister’s statement.
The lengthy documents produced by Guildford’s planning officers are very laborious, and lack a clear overview. There is no explanation of why, after all the consultation on the 2013 draft plan, the target has been raised from 322 homes p.a. to between 652 and 780.
The officers merely respond: “…guidance is clear that we must allow for migration to the borough. A zero net migration model is not a true reflection of reality and adopting such an approach would lead to an unsound plan”. Net immigration at 16,340 is very far from zero. And no reference is made to Nick Boles’ assurances. Did he mean what he said?
I am clearly not alone in being dismayed at the fundamental changes being planned, without any apparent appreciation of the consequences.
Given that most of the comments on the October 2013 “consultation” have been totally ignored, one must wonder whether the current consultation, closing on 22 September, will meet the same fate?