Opinion: The Guildford Society’s View of How the Local Plan Update Should Be Conducted

Published on: 28 Mar, 2024
Updated on: 31 Mar, 2024

The Guildford Dragon invited the public speakers at February’s borough council meeting, held to decide on the update of Guildford’s Local Plan, to write articles explaining their views…

By Alistair Smith

Alistair Smith

chairman of The Guildford Society

Local Plan Update

The current Local Plan has currently produced several indifferent estates, myriad infill schemes in villages, and a town centre becoming a series of sites overdeveloped as small flats or student accommodation.  

Infrastructure provision (green space, schools, medical facilities, transport, water supply and sewage treatment) has been limited, with the management of the plan appearing to be driven by the desire to achieve housing number targets rather than creating sustainable balanced communities.

The Guildford Society is supportive of a Local Plan update, if approached with an open mind.  This must include recognising deficiencies in the current poorly developed and hastily consented 2019 Local Plan. Sadly, much of the damage caused by the 2019 plan cannot be rectified eg restoring villages to the green belt protection, and the uninspired development that has taken place recently.

Risks

The Society recognizes there are risks.  National planning policy is in turmoil As an example, there have been possibly three significant updates to the National Planning Policy Framework (NPPF) over 18 months; this doesn’t include what a government of a different political complexion might propose. Inevitably housing numbers will be an issue with a lack of clarity from both major parties as to how they are going manage numbers and the allocation of these numbers across the country.

A Guildford Local Plan update needs to be robustly developed, especially the evidence base, to cope with this churn.

Three years is a long time

The Local Plan update is likely to take circa three-plus years to complete.  It was noted that Cllr White, the lead councillor for Planning, at the council meeting to approve the update, expressed caution on achieving the 30-month timescale, proposed by central government.

For the next three years the borough will have to manage with the current policies embodied in the Local Plan Part 1 – Strategy and Sites (LPSS) and Part 2 Development Management Policies (DMP), whilst dealing with the relentless pressure from developers to approve schemes.

We urge GBC to manage this period in a more robust manner by:

1. 1. Being prepared to draft and add extra guidance/policies on matters such as heights, a major concern to the Society, design standards eg dual aspect flats, and for selected sites/areas to guide development.  A policy in draft carries weight in the planning process.  These extra guidance/policies can be “written in”, as required, into the updated Local Plan.  A further advantage of these policies would be to protect the council from endless appeals on schemes from well-funded developers.
   2. Managing existing policies effectively.  A particular concern is that site policies with their descriptions of use, dwelling numbers etc., which planning officers must have used in an iterative manner to understand potential bulk, height and density of developments, which were consulted upon to form the LPSS, appear to be used as a guide only.

It is accepted that site policies may require modification, but this should be done in an open manner and reasons given.  A current example is Guildford Park Road where car parking is being reduced and the area freed up for housing use.

The site off Guildford Park Road is currently used as a surface car park.

Although this is sensible, no details have been made available as to the relationship of parking reduction to an increase in dwellings.  The Local Plan proposed 120 dwellings with a multi-storey car park this appears to have moved to developers proposing over 300 dwellings with no car parking.  Similar issues affect the Law College application.

If confidence is going to be maintained in the Local Planning process policies need to be managed effectively and changes properly explained.

Update Method

The Society will be looking for evidence that the detailed plan and budget for the Local Plan update includes:

1. A comprehensive update of the Evidence Base

2. The evidence base must also include outputs from the recently adopted Economic Strategy, and from the Shaping Guildford’s Future program developed at the cost of circa £2.5M.  Shaping Guildford’s Future has a large body of supporting information, which should not be lost, and parts of it could be enacted in the form of extra policies as proposed above.

3. Details on how stronger policies are to be developed to handle critical issues such as:

• • • Improving Design Quality, including consideration of materials and making buildings adaptable to changing needs and climate change
    • Better Spatial Policies
    • Measures to address pollution
    • Transport in the borough and make Active Travel and Public Transport more attractive.

4. An updated local plan must be far more robust in requiring Infrastructure improvements, especially if we have to handle an increase in housing numbers.

Mr Jonathan Bore, the inspector of the current plan 2019, questioned robustly the delivery of improvements in supporting infrastructure, particularly the A3 – his concerns have been well founded.

Major proposed developments in an updated plan should be declared non-deliverable unless supporting infrastructure is delivered eg flood remediation, medical facilities and schools. This also required commitment from other bodies eg Surrey County Council, Thames Water, Network Rail etc.

We also believe that there needs to be a commitment to implement the Community Infrastructure Levy in the borough.

Guildford Deserves Better

We need a robust Local Plan that, as the NPPF requires, contributes to “ the achievement of sustainable development, including the provision of homes, commercial development, and supporting infrastructure in a sustainable manner. At a very high level, the objective of sustainable development can be summarised as meeting the needs of the present without compromising the ability of future generations to meet their own needs”. 

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