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/
This website is published by The Guildford Dragon NEWS
Contact: Martin Giles mgilesdragon@gmail.com
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Colin Cross
March 25, 2018 at 8:31 pm
Perhaps the single most important statement made by the inspector was not any of the above, as forensic as they are, but his short second paragraph: “These questions do not deal with the detail of the allocated sites.
These may be the subject of further questions.”
One can safely assume that such questions will be forthcoming in due course and that prospect must be a chilling one for Guildford Borough Council’s Executive and Planning Policy Department.
We may not be attending that public examination in June after all.
Colin Cross is the Lib Dem borough councillor for Lovelace
Alan Cooper
March 26, 2018 at 10:21 am
Now the Slyfield Plan details are released for 1,500 homes. Several important questions have to be asked in relation to this.
The roads in that area are already congested and inadequate so will a relief road be built between Slyfield and Jacobs’s Well close to A3 for the release of traffic to and from Slyfield.
1,500 homes will bring probably 5,000 more residents to that area, so have the council considered additional medical facilities for that area such as a medical centre. How about schooling? Is there sufficient in that area?
Also what about policing? Is Surrey Police going to be able to cope and police what is, in essence, a large village and on outskirts of town?
I am told that there are now planning applications for housing within a few miles of Guildford and Woking for close to 6,000 additional houses, if approved.
Am I the only one concerned by this attempt to flood the area with this excessively large number?
Jim Allen
March 28, 2018 at 10:12 am
I would remind Mr Cooper that any additional roads around Slyfield need to be justified in the direction of travel before they are laid onto the map of permanency.
Last time no one knew where the traffic was coming from or going to – little point in dropping traffic into an already over congested area in the north when all the traffic wants to go south from the site.
Too often the siting is poor, providing no solution for the problem. Direct access to the A320 from the site is far more suggestive of a solution as opposed to a mitigation.
A Atkinson
March 27, 2018 at 6:52 pm
In reply to Mr Cooper, no, apart from the Conservative led council and central government.
Howard Smith
March 29, 2018 at 10:44 am
A massive list of issues from the planning inspector but the leadership at GBC describe it as a “step forward”.
I didn’t realise the Iraqi general Comical Ali, infamous for his ridiculously optimistic statements during the Iraq War, had morphed into Council Leader Spooner. “It’s all fine folks, it’s all going very well.”