Agenda item

Proposed Submission Local Plan: Strategy and Sites


The Planning Policy Manager gave a presentation on the proposed submission Local Plan: Strategy and Sites including:


·         An overview of the timetable; the recommendations of the Board would be considered by the Special Meeting of Executive on 11 May followed by the Extraordinary Meeting of Council on 24 May.  If approved for consultation

Commence statutory regulation 19 consultation on 6 June 2016 for 6-week period.

·         The scope and evolution of the local plan;

·         The main site changes and an;

·         Outline of infrastructural improvements proposed.


The Leader of the Council acknowledged the significant improvements made to the draft local plan and looked forward to receiving the Boards comments, which would be fully taken into account.


Prior to consideration of this item, the following people addressed the Board in accordance with Public Speaking Procedure Rule 3a (vi):


·         Mrs Hilda Brazil (on behalf of Guildford’s Gypsy Community, Effingham Parish Councillor and Joint Chair of Surrey Gypsy Traveller Communities Forum)

·         Dr Malcolm Parry (CEO and Managing Director of Surrey Research Park)

·         Ms Carol Squires (Surrey Chambers of Commerce)

·         Mr Alf Turner (Deputy Chief Executive of Royal Surrey Hospital)

·         Mr Charles Collins (Savills)

·         Ms Amanda Mullarkey (on behalf of Guildford’s Residents Association)


The Board was invited to provide views/comment on the draft Local Plan so far and raised a number of points, including concerns in relation to:


·         The issue of over-allocation of land, creating a surplus over the OAN and the potential of neighbouring authorities using that surplus for their own housing supply.

·         The local plan relied on the Green Belt and Countryside Study 2014 (GBCS) as its evidence base to remove areas of the Green Belt on the basis that, in its judgement, they did not make a significant contribution to its openness. The GBCS was viewed as a subjective study.  The Green Belt should be a constraint on housing numbers in the Local Plan.

·         Concern over settlement boundaries, specifically plot allocation A41 located to the south of East Lane in West Horsley, which was bordered by a natural woodland boundary.  To the East are four houses, these had been included in the local plan as a natural defensible border, which was not the reality.  It was contrary to paragraphs 85 and 86 of the NPPF as the plot did add to the openness of the Green Belt.  The 300 metres of woodland was the natural boundary, not the four houses. The removal of plot A41 should be considered as it was out of character with the surrounding area.

·         Concern over insufficient infrastructure and public transport in East and West Horsley.  The roads frequently become single carriageways and were incapable of being widened without compulsory purchase orders.  The roads would not be able to cope with the addition of 524 homes, as well as the proposed 2000 homes at Wisley Airfield.  The local primary school was already full and the appendix showed no plans for a further school despite proposing hundreds of additional houses in the Horsley’s.  The quantity and concentration of development proposed in the rural east of the borough was disproportionate to the level of development in the Borough as a whole. 

·         Issue of over-development of green land in Ash, South and Tongham with a current lack of infrastructure, schools, shops and healthcare provision.  Welcomed extension of Green Belt to the west of Ash Green. 

·         A correction required on page 133, should read Onslow on the summary page and not Friary and St. Nicolas.    Two sites in Onslow were of concern, the Cathedral and Blackwell Farm.  Welcomed the removal of Blackwell Farm from Onslow and was pleased to see the designation of that land as either AGLV or AONB.  Welcomed two new railway stations.  Please extend the platforms and provide additional rail track at the existing Guildford Station prior to the new stations being built. 

·         The Normandy and Flexford site – it was questioned whether its infrastructure was sufficient to cope with the additional traffic and water disposal.  Question how the housing figure was derived for that area.

·         Pleased with the protection of sites within the Green Belt and AONB in the Holy Trinity ward as well as the removal of Fairlands from the plan.

·         Concern over the number of sites, earmarked for development in the ward of Shalford, particularly the larger proposed development at Blackwell Farm.  If a site was allocated in the plan for development, was it likely to happen?  How flexible was the plan in relation to changes in circumstances such as the EU Referendum and would all planning priorities still apply?  Would the necessary infrastructural requirements be implemented first?

·         In Appendix 1, question of how to effectively monitor the impact that any future applications for Houses in Multiple Occupation (HMO’s) had on an area, concern if that went far enough.  Example given whereby, houses were frequently purchased by investors and avoided having to apply for planning permission for an HMO by keeping the number of occupants below the threshold of six.  To therefore consider including HMO’s in the monitoring indicators table.

·         On page 110 Policy 12: ‘Supporting the Department for Transport’s “road Investment Strategy”’ 4.6.14 refers to road period 1 2015-16 and 2019-20 and road period 2 as taking place in 2020-21 and 2024-25.  The A3 improvements are referred to as being scheduled to take place in road period 2 and then in 4.6.18 it refers to the A3 improvements taking place in road period 1.  Clarification sought therefore as to which road period the improvements to the A3 were scheduled to take place in?

·         Welcomed suggestion in the site allocation policy that takeaway’s should not be located within so many metres of schools.

·         Commended the additional railway stations, particularly at Park Barn, which would hopefully reduce the level of congestion currently experienced in Westborough.

·         Welcomed the fact that the high sensitive green belt areas had been protected as for example the Green Belt sensitivity analysis was being used as a constraint in the ward of Effingham.  

·         Questioned the methodology used in the Green Belt and Countryside Study.

·         Commended the provision of two new schools in Effingham as well as being sited in sustainable locations to the east of the borough.

·         Welcomed the positive and constructive placement of Gypsy and Traveller sites across the borough.

·         Concern over how inset boundaries are chosen.  Board members stressed importance of being permitted to suggest amendments to inset boundaries prior to the local plan going to consultation.

·         Unconvinced that the current strategic Guildford transport strategy would deal effectively with cumulative impact of developments.  To the south of the A3, no infrastructural improvements had been proposed apart from a potential bus service, which was inadequate.

·         Disappointed that constraints such as lack of infrastructure, flooding and Green Belt had not been taken into consideration to reduce housing target number to below the OAN number.  Concerned that the Green Belt within the AONB was now readily available for development.  Issue that the sensitivity analysis changes according to where the boundary of land parcels is. 

·         Disproportionate amount of development to the east of the borough culminating in over 5000 homes within a 6-mile radius with a lack of adequate infrastructure and schools.  Please revisit allocation of development to the east of the borough.

·         Require a fundamental reappraisal of objectively assessed growth and housing need.

·         Utilise brownfield land for warehousing and not houses. 

·         Green belt land and infrastructure constraints do not limit build rates, once sites have been allocated and settlement boundaries inset the presumption will be in favour of development.  Infrastructure should be a constraint and we have to look at the problems we have on our roads and railway networks now.

·         Commended the suggestion from the University of Surrey to increase their accommodation provision to students to 80-90%.

·         Concern about the effects of developments cumulatively upon the green approach to Guildford, particularly in relation to the developments proposed for Guildford Burnt Common Triangle and Gosden Hill Farm.

·         In The West Surrey SHMA and local plan, the percentage growth rate of housing over the next twenty years was 25.04% and the previous rate per decade was under 12%.  The growth rate of greater London was 10% for the whole of the last two centuries and 10.6% for the whole of the 20th century.  Was therefore concerned about a plan that proposed housing developments to exceed the rate of London over the last two centuries.

·         Concern in relation to the SHMA and unattributed population change.

·         Issue of under counting of windfall rates that were probably 80-90 per year but was documented in the plan as 42 per year. 

·         Concern about the A3 and how the improvements would give better access to yet more traffic.  It was very unpleasant now for residents living close to the A3 in terms of loss of the enjoyment of their amenities in terms of noise and pollution. 

·         Concern over the naming of particular ‘pockets of deprivation’ as currently used to describe some wards.

·         The impact of Blackwell Farm development in the Onslow ward as vehicular access to and from the site would be via Egerton Road.  Even if the A3 was widened, the additional traffic generated by the proposed developments in the surrounding area, as well as traffic to and from the Cathedral, Hospital and Research Park would exacerbate traffic levels in Egerton Road overall.

·         Board members emphasised the need to provide affordable housing for not only the low-paid but for people like doctors and nurses and provide good-sized family homes.

·         The need to ensure adequate provision of infrastructure in Guildford town such as North Street and the Town Centre Masterplan to cope with the additional proposed developments in light of existing problems with water, sewage, power and noise from the A3.  Need to control developments at brownfield sites in terms of design.

·         In terms of increasing accommodation facilities for university students, needed to be mindful that often it was more expensive to live on university campus than living in a shared house.  In addition, a large proportion of people who lived in HMO’s within Guildford town were actually young professionals. 

·         Concern that if a tunnel was built to improve access into Guildford, it would be built in green belt land and the implications for associated planning applications.

·         If we take sites out of the plan did they have to be relocated elsewhere?


The Leader of the Council thanked the Board for the issues raised and responded to specific questions. 


The Board discussed the following issues but did not accept them as recommendations to the Executive:


·         A review of the Strategic Housing Market Assessment (SHMA) figures.


·         Concern had been raised in relation to the over provision of land allocated in the Proposed Submission Local Plan in relation to Objectively Assessed Need (OAN) figure.  The Leader of the Council confirmed that this was required to ensure we could meet OAN by enabling Guildford Borough Council to have flexibility.  If there were a surplus in terms of numbers that was primarily because there was an expectation that some of the sites would not be delivered during the plan period.  Therefore, there was a slight surplus in relation to the overall number but did not expect that in reality the number would be exceeded.  Neighbouring authorities such as Waverley would not be entitled to count delivery from any of Guildford Borough Council’s surplus land towards their housing supply. 


·         Concern about the distribution of development across the borough in particular the Horsley’s and Ash South and Tongham.  Concern about the inclusion of site allocation A41. 


·         The Executive to re-consider the target set in relation to the number of students to be accommodated in student accommodation on the University of Surrey Campus from 60% to 80-90%. 


·         The Executive to consider the safeguarding of tunnel entrances on the A3.



The Board endorsed the following proposals as supported by the Leader of Council:


·         to review the naming of particular ‘pockets of deprivation’, as currently used to describe some wards.


·         to support the proposal to monitor the effect of future planning applications on local communities, in particular the increase in the number of Houses in Multiple Occupation (HMO’s).


·         to commend the planning policy team for their prodigious hard work in the production of the proposed submission Local plan: Strategy and Sites.


In addition, the Board


RESOLVED: that the Executive, at their meeting on 11 May 2016, took into account the following recommendations in relation to the proposed submission Local Plan: Strategy and Sites:


1.    To consider the Board’s overwhelming concern about the lack of adequate infrastructure to support planned development particularly in its rural areas.  Sufficient infrastructure should be delivered when needed to support the cumulative impact of development in the future, in particular for sites that are too small to provide their own infrastructure directly themselves, but which cumulatively would have an impact.  


2.    To give assurance and guarantee that infrastructure improvements would be delivered in time to support planned growth. 


3.    To consider reviewing the methodology employed in the Green Belt and Countryside Study, specifically in relation to deciding between, low, medium and high sensitivity areas.  This would ensure that it was defensible when examined by the Secretary of State.


4.    To support the strongest worded affordable housing policy we can have within the remit of sustainable development.


5.    To safeguard green spaces and green approaches in Guildford Town and its surrounding countryside so to enhance the quality of life for all. 


6.    To review whether a higher windfall assumption is justified.


Supporting documents: