GBC Policy

Policy D4: Development in urban areas and inset villages 

Planning permission for new development in the urban areas of Guildford, and Ash and Tongham, and inset villages will be granted provided that it: 

• ensures that the layout, scale, form, massing, height of buildings and structures, and materials relate to the site context and its surroundings 
• respects and compliments the existing grain and street pattern of the area 
• conserves locally and nationally important heritage assets and conserves or enhances their settings, has no unacceptable effect on the amenities enjoyed by the occupants of buildings in terms of privacy, noise, vibration, pollution, dust, smell and access to sunlight and daylight. 

In addition to the above, proposals for new development within inset village areas will have particular regard to: 

• the distinctive settlement pattern of the village and the important relationship between the built development and the surrounding landscape; 
• important views of the village from the surrounding landscape; 
• views within the village of local landmarks.

GGG Response

Summary

There are effectively two separate parts to this policy, both are flawed, and in the case on insetting, fatally flawed.  In the case of urban development there are numerous flaws, including:

• The plan envisages that 40% of homes built will be affordable, but this does not provide any accommodation for low paid workers, for example, those on the minimum wage, who cannot afford to buy “affordable” homes, nor can they pay the  so-called “affordable” rent.  There is a need for some expansion in social housing, especially in urban areas, where there is a greater concentration of low paid workers such as those employed in the retail, warehousing and distribution sectors.  
• The number of homes planned in the urban area is too low – there is a need for regeneration in some areas, but this is ignored and instead the plan concentrates on building homes on green field sites, which does not meet the needs for housing within the town, especially with the centre.  This is not a sustainable policy as building outside the town has a disproportionate effect on road traffic.
• The plan envisages a large expansion of the traditional “bricks and mortar” retail sector, but this is a sector in long term decline.

Urban development

There is a fundamental flaw in the draft Local Plan, in that there are not enough dwellings planned in urban areas, in particular, Guildford town centre.  This is where the demand for affordable homes is most acute, a fact which is recognised in much of the draft Local Plan.  Yet the plan then envisages that most dwellings will be built outside the urban area, so there is no continuity in the plan – if the demand for affordable homes is most acute within the town, then is where these dwellings should be built.  There are sites available, for example, various sites in Woodbridge Meadows, Walnut Tree Close (including the area around the station) and North Street.  Yet the focus in these areas is to provide a very limited number of dwellings, with the emphasis on additional retail space and more commercial premises.  Given the profound changes in traditional retail, this is not a sustainable policy.  There have been many examples of bankruptcies amongst traditional retailers, the most recent examples being BHS and Austin Reed, and previously Woolworths, Comet, etc.  The British Retail Consortium forecast that by 2020 up to one third of those now employed in traditional retail could lose their jobs, due to a combination of the move to the internet and higher costs, from business rates and increases in the minimum wage.  Recent figures show that online sales are still growing quickly, with more than 13% of total retail sales now made over the internet.  Nor does an expansion in traditional retail chime with the objective of attracting highly paid jobs to the area – the majority of jobs in retail are low paid, with zero hours contracts and usually a pay rate based on the minimum wage.  So any expansion in traditional bricks and mortar retail would create a greater demand for affordable and social housing – exactly the reverse of what is needed. 

Even the major grocery retail chains have been affected by changes in retail habits – Tesco, Sainsburys, Morrisons, etc are closing some stores, with no major large stores planned.  Banks and other financial institutions are still closing some branches, so changes in town centres still have some way to go – but none of these changes are recognised in the draft Local Plan, which envisages no limit to traditional retail. 

There is another reason why the retail sector is unlikely to exhibit long term growth, and this is consumer debt, which has reached a level that the Bank of England have said could contribute to economic stability.  This is likely to have a greater destabilising effect in the event of an economic downturn – and there will certainly be at least two of these during the life of the Local Plan.  Retail spending simply cannot be maintained indefinitely at its current rate, and to plan for a large increase in consumer spending is irresponsible.