Letter: Questions To Council Leader On Latest Moves Over Local Plan

Published on: 24 Jan, 2015
Updated on: 26 Jan, 2015

From Janette Panton, on behalf of FLAG (Fairlands & Liddington Hall Action Group)

I write in response to Cllr Stephen Mansbridge’s recent press release with regards requesting that Guildford Borough Council (GBC) can spread their past shortfall in housing over the life of the Local Plan rather than have to meet this shortfall within five years.

It is my belief that this is purely a ploy to continue to woo the electorate in the run up to May and have them believe he is listening and will afford the green belt the protection it should be given.

I am bewildered that Cllr Mansbridge states GBC will rigorously reassess sites using the existing evidence base. The same evidence base which is very much biased in favour of excessive development and the same evidence base which is flawed on many counts, prepared by consultants who also work with developers.

How are we expected to believe that the next draft Local Plan will be any different to the last? Surely one of the things GBC should be doing is rigorously re-examining and amending, where necessary, the existing evidence base to ensure we do have a sound Local Plan for Guildford.

There is no need for Cllr Mansbridge to remind us of the many constraints for Guildford, such as 89% green belt and major infrastructure problems. These are things action groups, parish councils and residents have been shouting from the rooftops about since 2013. Things that Cllr Mansbridge chose to ignore when insisting that the Draft Local Plan must go to consultation.

A few things which ought to be mentioned are the major shortfall in funding for Surrey County Council to meet its existing school place requirements moving forward, let alone the many thousands more that would be required due to excessive new housing.

The leader of Guildford Borough Council, Cllr Stephen Mansbridge.

Surrey Police have a major funding shortfall and are being forced to reduce numbers of front line officers. What effect will a large increase in the borough population have on the crime rate with dwindling police resources and a worrying lack of police presence which is already prevalent on our streets?

I have a couple of questions for Cllr Mansbridge. Firstly, can he please advise who at GBC is being held responsible for the wasted £140k cost of the last consultation period? Had you listened this money could have been put to better use.

You are now expecting Guildford residents to foot the bill and pay for yet another consultation which clearly could have been avoided. Secondly, when are you going to credit Guildford residents with the intelligence to see through the facade of your promises to revise the Local Plan, conveniently delaying this until after the election?

Responses to Letter: Questions To Council Leader On Latest Moves Over Local Plan

Jules Cranwell Reply

January 25, 2015 at 9:06 am

Yes, this late supposed change of heart is the most cynical and obvious electioneering.

As in 2011, we can expect this sudden commitment to the green belt to evaporate, should the Tory cabal be kept in power in May.

We can stop them, by voting GGG.

http://guildfordgreenbeltgroup.co.uk/
Sarah Wilson Reply

January 27, 2015 at 10:44 pm

What I would like to know is: “If I vote for the GGG at election time what chances does the borough have getting a local plan acceptable to the government inspector and not thrown out like so many other boroughs?”

At the moment I suspect no chance at all!

My problem with the GGG is that all I hear is “We told you so” and negativity and this isn’t going to get the borough anywhere when it comes to the serious business of formulating an acceptable Local Plan.

I would be much more impressed if they were to issue their manifesto in particular with regards to their local plan proposals. This way I could make a real decision on whether to follow them or not.

I don’t want to be a NIMBY nor a lemming. Susan Parker please give us your plans including what housing number the GGG might push for in the light of the wider SHMA recently released.

Thank you to the Guildford Dragon for a great website.
- Ben Paton Reply
  
  January 31, 2015 at 7:29 pm
  
  Is the SHMA sound?
  
  There are two SHMAs. The first considers Guildford’s housing market area. The second also took into account adjacent housing market areas.
  
  The first SHMA was presumably at best unsatisfactory and at worst unsound. Otherwise it would not have been necessary to commission the second.
  
  It is know that there are mistakes in the first SHMA housing projections because these were based on ONS statistics which projected population based on a population bulge caused by the presence of a university. In my opinion that was a mistake. It probably renders the first SHMA unsound. The second is supposed to have addressed this mistake. However the model is not disclosed.
  
  The demographic model used to project housing need has never been disclosed by GBC. GBC is required by law to calculate an Objectively Assessed Housing Need. How can a need be objective if the calculations are not disclosed? Doesn’t ‘objective’ mean that the numbers can be objectively verified?
  
  Even if the SHMA is sound is it sufficient basis for determining a Housing Target? No. The NPPF states clearly that constraints must be taken into account. No constraints – such as the green belt or environment or heritage constraints – have been applied.
  
  As for legal requirements you may wish to read
  Gallagher v Solihull April, 2014 (High Court England & Wales)
  and
  St Albans v Hunston Properties December, 2013 (Court of Appeal)
  
  Both of these case post date the NPPF and are authoritative coming down from the Court of Appeal.
  
  They are freely available on the internet.
  
  On any objective appraisal of the facts GBC, in my opinion GBC has not done a good job.
  
  In its response to the draft Local Plan, Natural England states that as currently written it is unsound. Other respondents point out other fundamental failings. That’s why it has been postponed until after the election.
  
  Has the council done enough to merit the trust of the electorate? Not by a long measure.
Susan Parker Reply

January 28, 2015 at 11:48 am

We will be publishing our manifesto shortly after our draft has been approved by our membership.

If elected, and if GGG are in a position to make decisions, we will get a revised and workable local plan issued within a short time frame, with a view to planning on building the minimum number of homes that will pass the planning inspectorate, with an emphasis on affordable homes and key worker homes. There isn’t a need to build more executive homes on greenfield land, We don’t have any time for the special pleading of developers wanting to make a profit out of agricultural land.

I think it is important to recognise that a local plan needs a sound SHMA (and yes, we did tell the council that the previous SHMA was unsound a year ago, and no, they didn’t listen, at a huge additional cost to the public purse).

The current SHMA isn’t sound either, and would also be contested. It has many of the flaws of the previous version, and needs to be amended. If elected, we would get the SHMA redone so that it is sound.

Furthermore, the SHMA doesn’t give the housing target. When the SHMA number is agreed (which isn’t currently the case) that number will be subject to the constraints which are imposed by the NPPF in order to calculate our housing target.

What we have in any SHMA is a starting point – then the local council decide what can be achieved. I think, given the constraints of the AONB, the SPA, green belt and our serious problems with transport infrastructure, not to mention the inadequacy of existing schools and hospitals to cope with an increase of 25% in our population over the next 15 years, we should not be considering a housing target of more than around 300-350 homes per annum.

I think that is defensible and it is notable that this level was accepted as defensible when the previous Guildford Borough Council chose to defend it at the High Court in 2010.

This is also the figure that was agreed by the combined residents’ groups of GGG, Save Hog’s Back, Guildford Residents’ Association, The Guildford Society, EGRA, the Guildford Vision Group, and CPRE and submitted to Guildford Borough Council as part of our joint objection to the previous SHMA.

There are three documents which are the legal requirements for a local plan, one of which is a SHMA. In fact GBC hadn’t prepared the other two legally required documents last summer, so the whole exercise was a waste both of our time and our money.

We propose to reissue a new and redrafted local plan which focuses on real local needs. We think that can be achieved within a year, and maybe less.
Sarah Wilson Reply

January 28, 2015 at 6:42 pm

Thank you Susan for clarifying GGG position regarding their manifesto.

I am also very interested to hear that you consider the new SHMA unsound.

Is there something wrong with the methodology? Having read it myself they seem to have tackled many of the concerns thrown up by the first SHMA and included extra factors such as affordability and economic growth into the mix.

Also, whilst I realise the numbers are still much higher than considered acceptable to the GGG, I am worried that using the previous successful High Court challenge as a defence might not wash with the inspectors at examination stage because that was all pre NPPF.

This whole thing is really going to all come down to what the inspector determines at examination. “Is the plan put forward by the GGG acceptable or not?”. “Is the plan put forward by GBC acceptable or not?”

With respect, I think the GGG would benefit from hiring unbiassed professionals and/ or a critical friend to advise them on what is going to be acceptable.

I can see no point in the GGG doing all this work and campaigning if at the end of it their ideas are unworkable nor acceptable to the inspector.

For instance, I have read other posts by you where you suggest that all industry should be relocated to Slyfield and the resultant land freed up for housing.

Well, this is all well and good as an idea, but does the GGG honestly think that legal powers exist to forcibly relocate businesses, compulsorily purchasing land for housing because it sounds something more likely in China than Guildford.

Maybe there is someone out there who knows the answer to this. I understand that councils do have compulsory purchase powers but thought they were for major infrastructure such as roads, rail and airports, but not relocating businesses for the sake of housing. There are obviously many questions that need answering by those in the know.
Janette Panton Reply

January 29, 2015 at 11:19 am

I am pleased to see my letter is opening up some debate around the Local Plan.

I am extremely disappointed however, that Cllr Mansbridge has not responded to my questions.

I really would like some answers particularly as to who is being held accountable for wasting £140k of our money?
Roland McKinney Reply

January 30, 2015 at 2:26 pm

I think you could add £1.5 million (and counting) on consultants’ reports that made up the background to the d(r)aft Local Plan.

Many of these plans were very poor quality and a dreadful waste of money. So was this money well spent? I think not.

Considering that GBC has a large planning department, I am at a loss to know why all of these studies have to be done by external consultants.

Why not use the in-house expertise available? And look closely at what is produced to ensure it is of a high quality, which I am sure the GBC planning department is quite capable of providing, given the right leadership.