Fringe Box



Letter: Council Must Engage With Public Over Local Plan

Published on: 10 Mar, 2014
Updated on: 10 Mar, 2014

From Susan Parker of the Guildford Green Belt Group (GGG)

The two ‘forum meetings held at Millmead last week (People Flock To Give Views On Data For New Local Plan) were not the result of some generous gesture by Guildford Borough Council in order to check on the data.

View Westwards from Landing Ground with the end of the Hog's Back in the centre and Guildford Cathedral to the right.

They were the result of an amendment proposed at the petition debate, and opposed by the council’s Executive. However, despite some debate, the council voted for full public involvement in the joint scrutiny committees which will be appraising the evidence base, especially the Green Belt and Countryside Study (GBCS).

It is debatable whether this forum actually met those requirements. Full public involvement in the joint scrutiny committees (which is what the council voted for) has not taken place and will not take place. This workshop offered a very limited time to express any detailed comment and there was no evidence of any intention on the part of consultants or councillors to amend or correct the evidence base. There will be no public involvement in the scrutiny committees, despite the vote in council. What price democracy?

The Guildford Green Belt Group (GGG) has commented in its press release last week that the obligation for full public involvement was not really met by this forum. The forum seemed more of a publicity exercise than a genuine attempt to gather information. The consultants, especially on the GBCS table, were not particularly interested in taking comments in relation to errors or changes, but in justifying what they had done.

The GBCS has been widely criticised for its inadequacies. Did you know that trees don’t belong in the green belt? – According to the consultants who prepared this study, Pegasus, any village surrounded by trees is liable to be “inset” from the green belt because it is not “open”.

This is despite the fact that generally “open” in a green belt context is taken to mean “not built upon” – the definition is that the characteristics of the green belt are openness and permanency. But Pegasus have a track record in other work they have done for developers of claiming that trees represent a permanent barrier – so you can build behind them – although this has been rejected by planning inspectors recently – see

Interestingly, Pegasus confirmed at the evening that no review or revision of the GBCS study has been commissioned by GBC, so presumably the joint scrutiny committee will be asked by the planning department to approve the inadequate document we have previously seen, and that so many people commented on as part of the Issues and Options Consultation. Why isn’t it being revised, given the errors?

Pegasus confirmed at the Forum that the original commission was to “identify land parcels” within the green belt, with the expectation of “rolling back” the green belt. These land parcels were to be identified in order to meet housing need, even though brown field land might be available instead “because that had to be reserved for commercial purposes”. Who made that decision? I wasn’t aware that this had been the subject of debate, or any kind of public question.

Many members of the public were very angry with the councillors and the consultants, and there were many angry words (one member of the public shouted out that the councilor he was talking to was a liar and had been elected under false pretences, and the councilor in turn denied all knowledge of this planning process). Who did know?

In any event, the steamroller now seems to be rolling on regardless.

It was also confirmed to me by Flo Churchill, the interim manager in charge of the Local Plan, that no formal brown field study like the GBCS has yet been commissioned, and that this is not a formal requirement for the Local Plan. Whether it is a formal requirement or not, the need to use brown field land first is a presumption within the NPPF (National Planning Policy Framework) and the newly published/revised NPPG (National Planning Policy Guidance). Where is the brown field study?

GGG has been criticised for not being more involved in the process, and for commenting on the sidelines. We have tried to engage councillors in debate, but they seem reluctant to talk to us on points of detail and have previously ignored invitations to discuss things directly.

But we would like to engage with the council. We would also like them to actually listen to us.

As a result, we have invited the council’s Executive to sit down in a workshop with us, together with other representative community groups that would wish to participate (one has already agreed) to discuss the SHMA (Strategic Housing Market Assessment) as part of the evidence base. This is the document that proposes an increase in Guildford’s housing of around 30%, despite a projected national increase in population over approximately the same period of about 12%.

It is time for the council to accept that consultation is not about just paying lip service to representations from the public. It is about engaging actively with the public, taking on board their valid objections, and acting upon them by revisiting flawed analyses, and amending plans and studies accordingly.

This isn’t delaying the process, it is trying to ensure that the evidence base is accurate and complete. We have no wish to sabotage the process as some councillors would have people believe. Some councillors appear to prefer blaming constructive critics whilst ignoring their own failure as councillors to carry out the Local Plan exercise correctly. We have particular concerns that the SHMA fails to meet the Duty to Co-operate, a legal obligation which the council must fulfill. Failure to do so can de-rail the Local Plan so this is really important.

We are waiting for a reply to that invitation.

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Responses to Letter: Council Must Engage With Public Over Local Plan

  1. Bernard Parke Reply

    March 10, 2014 at 10:41 pm

    A threat of fielding candidates for the green belt in local election would concentrate the minds of our present councillors.

  2. John Robson Reply

    March 14, 2014 at 11:25 am

    Guildford Borough Council (GBC) appear to be getting a tad militant these days as their current approach to the green belt appears to be totally contradictory to the guidance provided by Westminster.

    Nick Boles’ recent ministerial statement on the simplification of “planning practice guidance” stated that the intention of the exercise included, but was not limited to: “Re-affirming Green belt protection, noting that un-met housing need is unlikely to outweigh harm to the green belt and other harm to constitute very special circumstances justifying inappropriate development.” And: “Stressing the importance of bringing brownfield into use and made clear that authorities do not have to allocate sites on the basis of providing maximum possible return for landowners and developers.”

    Does the foregoing place GBC at risk of a legal challenge from central Government? Will Westminster be forced to launch legal action to protect Guildford’s green belt from development should GBC determine that green belt in lieu of brownfield development presents the path of least resistance / maximisation of developer riches?

    We note this being the polar opposite to what happened the last time green belt was under threat as in 2010 GBC successfully sued central Government in order to protect the Greenbelt?

    Ms Parker, with respect, given the intransigence shown by our locally elected officials, maybe efforts would be better placed by lobbying central Government who appear to correctly prioritise the development of brownfield sites prior to decimating the 13% of green belt that remains in England.

  3. Helen Jefferies Reply

    March 14, 2014 at 12:02 pm

    My understanding is that plans for fielding candidates in the next election are already under way.

  4. Michael Bruton Reply

    March 14, 2014 at 4:49 pm

    I agree with Bernard Parke and Susan Parker. And I have just looked out the 2011 Guildford Conservatives election manifesto. Our councillors should do the same. The Conservatives promised in 2011 to protect the green belt as a key part of that manifesto – no equivocation, no doubt – We Conservatives will protect the green belt!

    Fast forward three years. Following a so called ‘consultation’ – the ‘Issues and Options’ document – we now have the Strategic Management Housing Assessment (SHMA). It has more holes in it than a colander.

    So many believe now that Guildford Conservatives are preparing to hand over the green belt to the bulldozer and the concrete mixer – and for 800 new homes per annum over 20 years – 16,000 new homes and mainly in the green belt. In one meeting I attended, a developer asserted that 800 homes per year should be a minimum!

    In mid 2015, and before the plan is completed, there will be borough elections in Guildford. Having talked to many within the borough it is likely that there will be a number of independent candidates standing against Conservatives (or others) who support the industrialisation of the countryside and the swamping of Guildford itself and its villages, from Normandy to Shere, with mass housing.

    When a major political party like the Conservatives goes back on its word, either nationally or locally, then it forfeits trust. Fortunately Guildford Borough Residents’ Groups appreciate that we are all in this together versus the prospect of turning the borough into one with traffic gridlock, inadequate infrastructure and a green belt damaged irrevocably.

    Relatively recently, Guildford Borough Council took the Government to court over the now defunct South East Plan and won – settling on 322 new homes per annum. Now they plan 800 per annum. Most people I know support both market and affordable organic housing development in Guildford town and the villages. But 800 a year versus 322 per year? And on greenfield versus brownfield?

    The tragedy is that none of this is necessary. This month planning minister Nick Boles wrote to the Planning Inspectorate emphasising the permanence of the green belt in all but the most exceptional circumstances – and that any exceptions would have to be very, very exceptional. All Guildford councillors have received a copy of Nick Boles’ letter.

    Surrey/Guildford exists not just for those of us who live here. It is also London’s ‘lung’ and a recreation area for its 8,000,000 residents as well. Do we want to ruin that?

    As someone who is instinctively Conservative, I feel that I was ‘taken in’ by the Guildford Conservative manifesto in 2011 and by those in the Horsleys who canvassed my support for that manifesto. That is why independent candidates across the borough in 2015 can be a way to frustrate local Conservative politicians’ enthusiasm for concreting over our beautiful countryside and turning Guildford into a mega town.

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