Letter: Local Plan Consultation – It Might Be a Mess But We Should All Have Our Say

Published on: 2 Oct, 2013
Updated on: 2 Oct, 2013

From Julian Lyon

Guildford Vision Group and Guildford Society

I note (and am grateful for) Cllr White’s valiant efforts in her letter ‘We Must All Stop Shouting At Each Other’ to try to calm local residents down. This consultation process risks being hijacked by emotional response rather than a considered process of evaluation of options.

On the other hand, this is all entirely predictable, notwithstanding Hon Alderman Parke’s reference to ‘Nimbyism’ ruling supreme.

I am afraid the councillors in general, and the officers in particular, seem to have failed to grasp either the seriousness of putting potentially inflammatory documents out into the evidence base (many commissioned and mostly written before the National Planning Policy Framework was introduced in 2012) or the folly of signalling as ‘potential development areas’ such sites as E22 and E23 (Warren Farm and Burwood farm) when the council’s housing numbers, published a few days ago, are so hopelessly uninformative, leading me to tweet “So range of housing is 181 to 1066 per year – blindfold & pin anyone?”.

Two recent Planning decisions (St Albans – High Court (http://www.39essex.com/docs/general/hunston_judgment_handown.pdf) – and Reigate – Inspectorate (https://bdsdocs.reigate-banstead.gov.uk/Planning/lg/GFPlanningDocuments.page;jsessionid=F5ACB750A41E9545EFFB158F734107EE)) should leave us in no doubt that the failure to meet five year targets meets the requirement of ‘Very Special Circumstances’.

This means that, coupled with the identification of sites as ‘Potential Development Areas’ (PDAs) there is now a very sizeable risk to all green areas around Guildford that were identified as PDAs whether or not they made the final cut in the Strategic Housing Land Availability Assessment (SHLAA). There may, in practice, be precious little that local residents can do to protect such sites as might be brought forward as a fait accompli.

It is all well and good to consider all land as part of the Local Plan but this should have started from a clear (council-backed) presumption against development in key areas (as I called for at the recent full council meeting on 17th September) setting out the reasons for that position. Thereafter, in the consultation, the council could have asked a question such as “Do you think we are right to rule out development of sites such as E22 and E23 in the Surrey Hills Area of Outstanding Natural Beauty?”.

I also genuinely fear for the town centre in the absence of a clear, ambitious and innovative master plan to resolve long-term degeneration of key sites, dysfunctional transportation systems and connections and traffic congestion. This is apparently now going to follow the Local Plan and, presumably, planning consent for the major sites such as North street and Solum.

The assessment of more than half of the Borough’s population as “Guildford Urban Area” rather than looking at the granular neighbourhoods that give the town and its surroundings such character, leads to some strange outcomes in analysis in the Green Belt & Countryside and Strategic Housing Land Availability Assessment documents. I also asked the full council on 17th September to instruct officers to seek separate assessments of the neighbourhoods as part of an update to the Settlement Profiles Report. I am not aware this has been taken on board either.

I now fear for the setting and context of Guildford as a result of what I see as the careless, apparently haphazard juxtaposition of various streams of work which appear neither integrated (as required by the NPPF) nor necessarily fit for purpose.

We are at a very dangerous stage and the recent shocking extraordinary council meeting on the housing development at Ash South demonstrates how chaotic our council is on these matters, and this in an area of the borough expected to take in the region of 2,500 more homes over and above that proposal.

In general I am aiming (with my Guildford Society hat on) to ensure that, to the extent possible, the Local Plan is fit for purpose and does actually protect and enhance Guildford whilst giving us room to grow in a locally-sustainable way. That does not stop my blood boiling at some of the nonsensical conclusions about specific areas left hanging for the duration of the Local Plan consultation process.

Cllr White suggests that we must see development spread across the Borough (and she may be right) but should we not also consider fully two other options:

Have we already almost reached saturation point and, if so, will any substantial extension of Guildford cause harm to the town? Do we absolutely need to touch the Green Belt around Guildford (apparently not if the lowest projected housing need figures were adopted)?
Should we consider one or two major expansion areas which should be able to bring with them great, state-of-the art public transportation connections between homes and jobs and if so, where might those best be accommodated without causing the harm referred to in 1 above?

The problem with the arguments as they have been allowed to blow up (notwithstanding that they have helped raise the profile of the Local Plan consultation) is that the more we are told we should accept or consider in pejorative terms, the more this chips away at the principles of a proper consultation.

The background to this consultation is unfortunately one of fear rather than opportunity; of damnation rather than of salvation. The only questions remaining being how to ensure such catastrophes do not occur, at least, ‘Not In My Back Yard’.

I sincerely hope the council can bring this back on track, make some firm leadership decisions and statements about their interim treatment of development and ensure a positive and forward-thinking consultation that draws meaningful responses from all quarters, from all communities and from all age-groups.

And, finally, every one of us has it within our gift to tell the council what we want our town and borough to be like. Please let us not assume someone else will say this for us. We need to fill in the forms, go to the events laid on by the council, by Residents’ Associations and the Guildford Society and we need to tell the consultation team what we think.