Letter: How Can We Approve An Incomplete Local Plan?

Published on: 31 Jul, 2016
Updated on: 31 Jul, 2016

From Ben Paton

Part of the smoke referred to by Cllr Cross in his letter: I Can No Longer Tell The Council’s Smoke From Its Mirrors, is that the council is saying, on one hand, that the number of houses needed – as computed according to the Justin Gardner secret model – is completely unconstrained and that on the other hand constraints may yet emerge in the form of, for example, transportation assessments carried out in private between the council and Highways England.

That is not in the spirit of a public consultation because the public has been asked to opine on something which is still work-in-progress. How can it know what it is “approving”?

The discussions with Highways England are not part of the public consultation process. The results of those discussions will not be available as part of this consultation – which is now closed to new comments. They will emerge after the consultation has finished.

Shouldn’t the transport assessment with Highways England and SCC have been concluded before the Local Plan was sent out of consultation? Why wasn’t it?

Cllr Caroline Reeves (Lib Dem, Friary & St Nicolas) is quoted in The Dragon as saying: “However it has always been made clear that until we have the comments on the transport infrastructure from Highways England and Surrey County Council, we cannot decide what is feasible anywhere in the borough.”

Has it always been made clear? Where exactly is that stated in the Local Plan? This amounts to issuing the Local Plan without any qualifications and then saying – after it has been issued, in remarks from a councillor who is not on the Executive – that the Local Plan may in fact be qualified because of transportation constraints.

If the Local Plan is indeed qualified then it should say so in the body of its text – not in post consultation statements made “off stage” by councillors.

Proposing to build more houses in the next 20 years than in any previous 20 years in history on the basis that transport infrastructure will be supplied by other government agencies, over which the council has no direct control, is just “winging it”.

Everyone sitting in the daily traffic jams on the A3 and elsewhere in the borough should question how much more time they will wait queuing in their cars when there are 20% more houses, and probably around 28,000 more vehicles, in the borough.

Responses to Letter: How Can We Approve An Incomplete Local Plan?

Caroline Reeves Reply

August 3, 2016 at 2:13 pm

Unusually I agree with Ben Paton. His comment about what I wrote is correct and what I should have said is “…it has always been made clear by the Liberal Democrat Group at Guildford that until we have the comments on the transport infrastructure from Highways England and Surrey County Council, we cannot decide what is feasible anywhere in the borough.”

This was what we said when we published our Local Plan Principles document in December 2013, and it is still the case that we would only support major development that has funding for the supporting transport infrastructure.
- Ben Paton Reply
  
  August 3, 2016 at 11:50 pm
  
  Caroline Reeves’ comment rather begs the question: why did she vote in favour of the local plan if she “cannot decide what is feasible anywhere in the borough”?
  
  If the Scrutiny Committee, which she chairs, had scrutinised the SHMA in the first place then it might not have been necessary to “revisit” it now.
A Atkinson Reply

August 4, 2016 at 12:08 pm

Why indeed did Cllr Reeves vote in favour of the consultation? Mind you she has supported it all the way through the process. Did she understand that following a regulation 19 consultation, only minor changes can be made? If she has such an issue with it she should have done her civic duty and vote against the plan going to consultation in its current form.

The council in comments under the name of Cllr Spooner have said that all comments will be presented to the planning inspector and nowhere did it say that genuine issues raised would be used to rightly reshape the plan.

It is too late, and a bit rich, for Cllr Reeves to have voted the plan through for consultation yet state that it has been Lib Dem policy that they cannot decide until transport matters are resolved/detailed. If that is the case why on earth did she vote it through without them?

I recall Cllr Reeves saying something along the lines of, “We need to let the people say what they think,” when she voted in favour of the draft plan being released.

I see councillors as directors, looking after the best interests of all the shareholders – in this case the public. If the draft Local Plan was a business proposal of around £12-15billion (which the plan is) the development of a factory or power station, for example, the directors would be sacked if their proposal to the shareholders was that they did not accept responsibility for the proposal presented because it was incomplete, with questionable forecasts which had not been fully scrutinised.

Directors should say “I’m not putting my name to that as the proposal to the shareholders unless I’m 100% convinced it is the best proposal possible and financially robust.”

Put an independent industry leader in the middle of the council during this process and they would have been be doing flip flops in astonishment.
George Potter Reply

August 4, 2016 at 1:42 pm

My understanding is that Caroline Reeves, along with every other councillor, has not voted in favour of the Local Plan.

They may have voted for the draft Local Plan to go out to consultation but this is very different from voting for a final version of the plan to be adopted. The vote on whether the Local Plan will be adopted or not can’t legally happen until after the consultation process has finished.

It seems very reasonable to me that some councillors might have been so dissatisfied with the Local Plan that they’ve voted against it going out to consultation while other councillors (including, perhaps, Caroline Reeves) might not have agreed with everything in the plan but voted for it to go out to consultation, nonetheless, so that it’s possible to move onto the next stage in the process where further modifications might be able to be made.

For instance, until the consultation is complete then there can’t be any feedback from the Highways Agency on the infrastructure situation. And without the infrastructure situation being formally documented then it’s not possible for the council to reduce the housing target to take account of infrastructure constraints.

I know that oversimplification to paint everyone as either a hero or villain might be tempting but, unfortunately, the processes around Local Plan seem rather more nuanced than that.
- Adrian Atkinson Reply
  
  August 13, 2016 at 12:22 pm
  
  Further to Mr Potter’s comment and those since, Cllr Spooner yet again puts in writing that there is no intention of altering the plan the councillors voted to go to consultation. The feedback from the public and other stakeholders will be merely tabulated for easy reading by the inspector.
  
  “We wanted to reach out to as many people as possible and will review every comment, so they can all easily be shared with the independent planning inspector and published for everyone to read”
  
  https://guildford-dragon.com/2016/08/10/local-plan-consultation-council-report-another-large-response/
  
  This is the second time this line that responses will only be presented to the inspector and not used to shape the errors in the plan has been given. It seems that all the councillors who voted for consultation on the basis of subsequent changes after the consultation have been had, or were those councillors in on it all along? They said they were, “Just voting for consultation”. What tosh.
  
  I hope Mr Potter will now realise that Guildford is heading for a disaster following the “trajectory” former Cllrs Mansbridge and Juneja set some years ago, so eagerly grasped and followed by the current leadership.
  - Ben Paton Reply
    
    August 14, 2016 at 10:44 am
    
    The idea that councillors were just voting for consultation and not really voting for the plan is just a great big fib. Mr Spooner has made it clear that the plan that went out for consultation is the plan that will be submitted to the inspector. Aside from dotting ‘i’s and crossing ‘t’s he has little choice under Reg 19.
    
    The reality is councillors have been too lazy to read the small print and that they have indeed been ‘had’. The same applies to councillors’ failure to scrutinise the SHMA – which was so ‘sound’ that Mr Spooner now wishes to ‘revisit’ it post consultation.
Adrian Atkinson Reply

August 5, 2016 at 6:19 am

Further to Mr Potter’s comment regarding process, my understanding the the current consultation is “Regulation 19”, after which only minor changes should be made. Therefore, if major changes are to be made eg housing numbers, sites as a result of housing numbers changes, transport and infrastructure etc then the council would have to revert back to a “Regulation 18” consultation – ie back to two years ago.

It would have been much more prudent and less costly to get it right first time round. By all means a process needs to be followed but what is at issue here is the content.

Hiding behind the line, councillors did not vote for the plan they voted for consultation, is feeble. That’s what happened last time round and where has it got us? Nowhere. The same fundamental issues remain.

At the Regulation 19 stage, exceptional circumstances should be presented to justify any green belt boundary changes but they are conspicuous by their absence. Put simply, the draft plan was not fit for consultation and councillors should have voted accordingly.
Jim Allen Reply

August 9, 2016 at 10:45 am

Back in the late 50’s new towns were planned with road layouts and services – Milton Keynes and Bracknell to name but two. I am not saying I like the layouts, but, Bracknell (much as I dislike saying it) has put their Local Plan through with apparently no problem.

If it is the intention of the GBC to make a “new town” of Guildford – then surely it should be described as such by central government and giving all the powers it needs display models of the intended schemes – road locations and infrastructure services for the next 50 – 100 years, not mess around with a 20 year plan already late by some 10 years.

There is no acceptance in the plan that some things simply cannot happen because of other factors and natural constraints, just increased housing numbers every time it is re-visited.

Its almost as if the council Executive are collectively punishing the community by making housing numbers rise every time someone challenges their poorly thought through ideas.