Letter: This Is The Process the Local Plan Review Should Follow

Published on: 26 Nov, 2023
Updated on: 26 Nov, 2023

From: Julian Lyon

R4GV candidate at the May 2019 GBC elections

In response to: Scope of Mandatory Local Plan Review To Be Considered

There is a clear process that should be followed in the Local Plan review:

1. Start with the evidence base.
2. Update any out-of-date reports.
3. Identify the robustness of the plan based on the updated evidence.
4. Propose changes to the Plan.
5. Consult-Listen-Amend, Consult-Listen-Amend, Consult-Listen Amend.
6. Present a final version to the Planning Inspectorate for Examination in Public.

Perhaps Dragon readers can help point our councillors and strategic planning officers in the direction of parts of the evidence base that need to be updated.

For me, there are quite a few aged documents, some of which were completely inadequate in the first place and led to (or supported) some pretty poor policy decisions and land allocations:

A) The Retail Needs Study (at least ten years old with a bit of tinkering in the meantime) – I think we all know the retail and leisure landscape has changed fundamentally in the meantime, and the loss of Debenhams and House of Fraser make the 40,000 sq metre allocation and statement of even larger retail need in the current Local Plan look particularly daft and out of touch.

B) I know I keep banging on about this but it is important as a basis for any planning for any of our settlements: The Settlement Profiles Report was written in 2014. It was poor then and contained numerous errors. It lumped the whole Guildford Urban Area into one four-page description which failed to address the particular needs of different wards/communities/suburbs of Guildford – consequently, the existing Local Plan does not seek to solve these.

C) The Infrastructure Baseline needs updating and screening for all the promised infrastructure improvements that have happened (I can’t think of any) and taking into account the issues that have been identified over water supply, sewage, power, lack of GPs, etc.

D) The Sustainability Appraisal needs to be run on an appropriate range of options – the original appraisal was run on the basis of competing erosions of the green belt with no variation of options in the urban areas.

This should at least have tested the options of (1) develop on green belt sites versus (2) developing taller buildings in the urban area. While this would not have resolved the question of how many homes, it might have fed helpfully into two debates: did we really need to raid the green belt (as much as we did) and what really is the harm of building taller buildings in the town centre?

Who knows, we might well have had an evidence-based heights and views policy in the Local Plan as a result and we might have been allowed a more objective debate about the green belt.

E) The Green Belt and Countryside Report (GB&C Report) is unhelpful to those seeking to protect against further swathes of development on additional incursions into the green belt. The report effectively recommends continuous incursions until development would close the gap between settlements.

If housing need is said to be greater (not just in Guildford Borough but elsewhere and there is no capacity to accommodate it, policymakers can look at the GB&C Report and identify additional sites which it identifies as having minimal harm to develop.

The GB&C report also fails to value the fifth reason for maintaining the green belt which is to encourage brownfield development and regeneration.

F) The Housing Needs and Employment Needs should be updated in open source, by which I mean there should be no hidden algorithms that no one can understand. The full study needs to be defensible and arguable so that the council and its residents can inform the debate about need versus demand.

This will also enable a much stronger affordable housing policy to be implemented, similar to the way the London Plan sets out to drive minimum affordable housing standards.

G) The Town Centre Plan needs to be a key part of the evidence base and incorporated into the Local Plan.

I could go on but these are my “starters for ten”!