Fringe Box



Letter: The Draft Local Plan Is Not Logical

Published on: 30 Jul, 2014
Updated on: 30 Jul, 2014

Local Plan Letters imageFrom Graham Moore

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?

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Responses to Letter: The Draft Local Plan Is Not Logical

  1. Susan Parker Reply

    July 30, 2014 at 9:07 am

    Mr Moore’s summary is very clear and straightforward and I would concur with his views strongly. It may also be that he is right that the planning department will choose to disregard the comments made in the current consultation.

    However, I still would urge all members of the public to express their views fully in the formal consultation, particularly in relation to the wording of the policies to be included in the Local Plan.

    The GGG [Guildford Greenbelt Group] has published its own comments in relation to this. This is not intended as a prescriptive template but as one set of notes that may prompt people across the borough to express their own views and that may be helpful in terms of points included within NPPF etc. (see

    This is the stage where the Draft Local Plan is due to be substantively changed, so it is desperately important that the public responds. Even if the planning department don’t formally recognise the public response, the responses will be relevant in the context of the planning inspector’s review of the plan, and may need to be taken into account.

    The responses may also be relevant to the possibility of the Secretary of State “calling-in” in the plan and taking it away from Guildford Borough Council’s planning department and they will have an impact on the local councillors who will realise how much their voters care about the issues (you can email copies of your responses to councillors) and this should affect the way that those councillors vote on the plan in future.

    And – if the councillors proceed regardless but are voted out at the next election – it will inform the way the councillors who are appointed after May 2015 choose to implement or change the Draft Local Plan.

    Susan Parker is an organiser of the Guildford Greenbelt Group.

  2. Jim Allen Reply

    July 30, 2014 at 9:13 am

    At long last a comprehensive and logical assessment of the situation. I could not agree more with the writer.

  3. Ben Paton Reply

    July 30, 2014 at 10:54 am

    The voice of common sense.

    But will it be drowned out by councillors overcome by “group think” and conventional thinking?

    Guildford Borough Council (GBC) states that the generally high price of houses across the borough is one of a combination of factors which constitute “exceptional circumstances” required to justify building on the green belt.

    Similar group think overwhelmed Spanish politicians. They too succumbed to the facile logic that because houses had become more expensive there must be a shortage.

    And there was compelling evidence for house prices in Spain. See below from Wikipedia

    “According to the reports of the Bank of Spain, between 1976 and 2003, the price of housing in Spain has doubled in real terms, which means, in nominal terms, a multiplication by 16. In the period of 1997—2006, the price of housing in Spain had risen about 150% in nominal terms, equivalent to 100% growth in real terms. It is stated that from 2000 to 2009, 5 million new housing units had been added to the existing stock of 20 million.”

    Was there a shortage of houses in Spain? Or was it really a bubble driven by developers anxious to make more and more money?

    And what is the rate of unemployment in Spain today? It is reported to be around 20 per cent. And where are many young Spanish people? In London serving in any Pret a Manger you care to buy a sandwich in.

    The moral of the story? Don’t believe everything developers, politicians and economists tell you. And just because houses are very expensive it is not just because they are scarce. The supply of credit is relevant too.

    The Governor of the Bank of England may blame a shortage of houses. But printing money and expanding the central bank’s balance sheet many fold has a great deal to do with it. As has the desire of much of Europe to come and live and work in the South East of England.

    It is not worth sacrificing the green belt to developers on the basis of their short term, self interested and specious arguments.

    If the example of Spain is not compelling then we could explore what happened in Ireland. But that’s another story.

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