Letter: Local Plan Balances Needs Across the Borough

Published on: 11 Apr, 2017
Updated on: 11 Apr, 2017

From Sue Sturgeon

managing director, Guildford Borough Council

A recent letter from Cllr Colin Cross [The Local Plan? Heaven Help Us All] incorrectly states that we have not applied green belt, sustainability or infrastructure restraints to the updated Local Plan.

We have applied constraints in determining whether we can sustainably accommodate the development required to meet the objectively assessed needs (OAN).

We have applied a ‘brownfield first’ policy of proposing sites where there has been development in the past, however there are insufficient suitable and available sites to meet the OAN.

We then looked at possible sites on greenfield land on the edge of Ash and Tongham. Finally, we considered green belt land that could be used to sustainably contribute towards meeting needs.

Our Evidence and Sustainability Appraisal demonstrates that there is sufficient land that could be removed from the green belt to meet needs without compromising the main purposes of the green belt. The plan avoids the use of high sensitivity green belt sites.

This is particularly the case now that we have removed the strategic site at Normandy and Flexford, which was previously proposed for 1,100 homes on the basis that it could accommodate a new secondary school.

This was the exceptional circumstance and justification for allocating it in spite of it being high sensitivity green belt. The new school is now being accommodated on Blackwell Farm and the justification for the site no longer exists.

With regards to infrastructure the plan is clear that the strategic sites are contingent on the delivery of major infrastructure, in particular the improvements to the A3. We cannot deliver the full Local Plan unless the supporting level of infrastructure is also delivered.

The letter incorrectly quotes the number of homes lost from the plan. The decrease in the housing requirement over the plan period (2015 – 2034) represents a clear reduction of 1,400 homes over the plan period compared to the 2016 draft plan.

In addition to the 1,400 homes lost, we have also phased 600 homes beyond the plan period (300 at both Blackwell Farm and Gosden Hill). Taking this into account, there is an overall combined reduction of approximately 2,000 homes in the plan.

The council has a responsibility to plan ahead and our updated Local Plan will run until 2034. It is important that your readers are aware of the facts.

Responses to Letter: Local Plan Balances Needs Across the Borough

Lisa Wright Reply

April 11, 2017 at 6:52 pm

Firstly, the need is questionable, to say the least.

Green belt is a constraint. Bunging a school in here and there to provide exceptional circumstances in order to build on it just doesn’t wash with Guildford residents. How can you possibly need two large senior schools within a mile of each other at Park Barn and Blackwell Farm?

Lets face it. GBC chose a plan to cash in on the government new homes bonus which is a huge sum of money and the Community Infrastructure Levy (CIL) payments.

Local Conservative councillors are providing as many green fields to developers as they think they can get away with to keep Mrs May and the Tory government happy (and the directors of off-shore companies and local large educational institutions).

We’ve heard it all before.

This Local Plan is a sham, we know it, council knows it, developers know it.

The question is, who has the strength to say “No”.

MP Anne Milton? Cllr Spooner? Cllr Furniss? Anyone associated with the Conservative Party? Or, none of the above?
Ben Paton Reply

April 11, 2017 at 10:00 pm

1. GBC has not produced a proper Objectively Assessed Need for housing. It has not disclosed the Justin Gardner Consulting calculations on which it is based. They cannot be checked and therefore cannot be objective.

2. No constraints have been put on on the ‘Assessed Need’ (which is not objective). Para 47 of the NPPF states councils should ‘use their evidence base to ensure that their Local Plan meets the full, objectively assessed needs … as far as is consistent with the policies set out in this Framework…’ The draft Local Plan does not reduce the assessed need for other policies in the NPPF such as the Environment or Heritage or Transport.

3.The Green Belt and Countryside Study is not objective. The Local Plan does not set out genuine ‘exceptional circumstances’ that justify removing land from the green belt – or for adding to it in the council leader’s area, Ash. This Local Plan was first launched before the council had even begun a Transport Assessment or a Habitat Regulations Assessment.

4. Promoting the Local Plan is a political activity. Why is the managing director of GBC entering into this debate? The managing director’s role is to administer the policies decided on by the politicians not to promote the formulation of particular policies.
This Local Plan process is over budget (over £4m spent so far), about seven years late, and based on a SHMA that has never been disclosed to councillors or officials, let alone been subject to any critical scrutiny.

This is the managing director who failed to investigate whether former councillor Monika Juneja’s claims to be a barrister were true and who later reported to the council that the council’s Code of Conduct had not been breached. She sent to the Old Bailey a character reference for Monika Juneja.

This chief executive is thoroughly discredited. Her promotion of this Local Plan is a sign of how few supporters it has outside the clique that concocted it.
- Guildford Borough Council Reply
  
  April 13, 2017 at 12:06 pm
  
  Sue Sturgeon is a highly professional and experienced lead officer with nearly 40 years of public service. Her letter is correcting publicly stated inaccuracies to make sure local people are aware of the facts. It is not expressing a political viewpoint.
Ben Paton Reply

April 11, 2017 at 10:14 pm

The judge in Gallaher v Solihull stated:- ‘Para 47 requires full housing needs to be objectively assessed, and then a distinct assessment made as to whether (and, if so, to what extent) other policies dictate or justify constraint. Here, numbers matter; because the larger the need, the more pressure will or might be applied to infringe on other inconsistent policies. The balancing exercise required by paragraph 47 cannot be performed without being informed by the actual full housing need.’ [para 94 of the judgement]

If this local plan applies constraints to the Assessed Need for housing, as Ms Sturgeon states, then she should be able to refer us to the amounts by which the Assessed Need has been reduced to take account of those constraints.

So what are the amounts? In which paragraphs and pages of the local plan do the figures that ‘constrain’ the Assessed Need appear and which policies cause a constraint to be applied? If she cannot tell us where the figures appear and their amounts then it is not a ‘fact’ that the housing need figure has been constrained. The statement that ‘we have applied constraints in determining whether we can sustainably accommodate the development required…’ is blatantly untrue.

It is another example of Guildford Borough Council bending some facts and inventing others to serve its own purpose. Numbers do matter. That’s why Guildford Borough Council should disclose them rather than invent them.
Colin Cross Reply

April 14, 2017 at 12:39 pm

Dealing purely in the facts and looking solely at the overall reduction in the new total housing requirement, Ms Sturgeon [managing director of Guildford Borough Council] is clearly stating that the actual figure is 2,000 not 1,400. However, wherever you look, even in the official GBC press release, the figure shown is 1,400. Even Cllr Spooner has quoted this figure, so surely it is correct.

Therefore instead of correcting publicly stated inaccuracies she is promoting her own inaccurate figure and misleading the public rather than making them aware.

This is hardly the act we expect of someone carrying such high office.

Colin Cross is the Lib Dem borough councillor for Lovelace
David Roberts Reply

April 15, 2017 at 3:44 pm

Sue Sturgeon’s job as a civil servant is to provide private, politically neutral advice to the council (including Cllr Cross) – not to lock horns with an elected councillor in the press.

Her respected successor should take note.