Local Plan Inspector ‘Very Concerned’ with ‘Unacceptable’ Speed of Housing Development

Published on: 24 Mar, 2018
Updated on: 26 Mar, 2018

The planning inspector examining Guildford’s Local Plan yesterday (March 23) raised nine pages of questions, requests and modifications with Guildford Borough Council (GBC).

The response from Inspector Jonathan Bore asks fundamental questions relating to housing supply numbers, green belt, affordable housing, North Street development, and other issues relating to specific planning policies.

The most significant key questions posed by the inspector relate to the speed of new homes delivery: justification of green belt development; improved affordability; evidence of joint working with neighbouring councils; lack of ambition re student housing; better use of brownfield sites and the development of North Street.

In relation to the housing trajectory, which shows proposed housing delivery over the life of the plan, the inspector states: “I am very concerned about the proposed stepped housing trajectory which indicates that the plan will deliver much lower numbers of homes in its early years than are actually needed.

“This appears to be an unacceptable aspect of the plan and the council needs to consider the steps that should be taken to improve housing delivery in the earlier years of the plan.

“Please produce a paper on this subject, with an amended trajectory, and the relationship of the trajectory to the A3 improvements and other infrastructure projects needs to be explained.”

In relation to green belt the inspector asks: “…please can the council provide me with a single paper setting out (a) a clear explanation of what it considers to be the strategic level exceptional circumstances justifying the release of the amount of green belt land indicated in the plan and its broad spatial distribution; (b) an explanation of what it considers to be the local level exceptional circumstance relating to each specific site from the green belt; and (c) an explanation of why it considers that there are exceptional circumstances that require the addition to the green belt between Ash Green Village and Ash and Tongham.”

This is likely to be a disappointment to Council Leader Spooner whose constituents in South Ash & Tongham as well as those in the other two Ash wards have stated vociferously their concerns about the existing level of development in Ash.

The inspector is also concerned that the Local Plan, as submitted, will not adequately tackle housing affordability. He states: “I cannot see any analysis to demonstrate that the proposed 9% uplift to the OAN (Objectively Assessed Need) based on household formation in the 25-34 age group can reasonably be expected to improve overall affordability.’ and he draws the council’s attention to the fact that an identical proposal was rejected in Waverley.

In relation to the wider Housing Market Area (HMA), which covers Guildford, Woking and Waverley, concerns are raised over the fact that the Guildford plan has no allowance for unmet need. The inspector says: “I understand that the HMA authorities intend to work together to address future shortfalls, but meanwhile there is a present need and it needs to be addressed now.”

And questioning the proposed North Street development the inspector hints that as some councillors and council critics have said, housing rather than retail may be appropriate. Jonathan Bore asks: “Against a backdrop of changing retailing, what consideration has the council given to re-evaluating the balance of uses in this location having regard to the need to accommodate additional homes?”

Other key concerns include the fact that the thresholds for affordable housing (in draft Policy H2, for five homes or more) are not in accordance with the relevant written ministerial statement of 28 November 2014 or the consultation draft of the revised NPPF. The inspector suggests this policy will need to be changed. There is also confusion over the wording of the policy (H3) relating to rural exception sites and whether such sites are acceptable, or not, in the green belt.

Also noted is that draft policy ID3(4) seeks to prevent future residents from seeking parking permits. The inspector notes this is actually unlawful and must be deleted from the plan.

The policy regarding Historic Environment (D3) is also criticised. The inspector says it: “…does not reflect the approach in section 12 of the NPPF, since it does not deal properly with the significance of the heritage asset and the degree of harm, and does not makes a distinction of approach between designated and non-designated heritage assets.”

The Dragon understands planning policy officers are already working to respond to the inspector’s queries, questions and requests but it is unclear at this stage whether the council will seek to defend its position or accept that amendments are necessary.

Possible amendments could include allocating new sites for development, increasing density and bringing forward in time development proposed for later in the plan. The future of the proposed new green belt at Ash and Tongham is likely to now be more doubtful.

If no agreement is reached with the inspector there may be a further exchange of correspondence or an “exploratory meeting” to discuss in more depth. The formal hearings are due to open in June but not all Local Plans make it to that stage.

Yet more queries raised by the inspector relate to self-build homes, Gypsies and Travellers and effective monitoring of development in the AONB.

The inspector’s full document as submitted can be found on the council’s website:
http://www.guildford.gov.uk/newlocalplan/CHttpHandler.ashx?id=27281&p=0

Share This Post