Policy I4: Green and blue infrastructure

GBC Policy

Policy I4: Green and blue infrastructure

Biodiversity

The Council will conserve and enhance biodiversity and will seek opportunities for habitat restoration and creation, particularly within and adjacent to Biodiversity Opportunity Areas (BOAs). The Council will produce a Green and Blue Infrastructure Supplementary Planning Document (SPD) setting out how this approach will be implemented.

Proposals for development must demonstrate how they will deliver appropriate net gains in biodiversity. Where proposals fall within or adjacent to a BOA, biodiversity measures should support that BOA’s objectives. The SPD will set out guidance on how this can be achieved.

The designated sites in the following hierarchy are shown on the Policies Map or as subsequently updated:

  • European sites: Special Protection Areas (SPA) and Special Areas of Conservation (SAC)
  • National sites: Sites of Special Scientific Interest (SSSI)
  • Local sites: Sites of Nature Conservation Importance (SNCI) and Local Nature Reserves.

Permission will not be granted for development proposals unless it can be demonstrated that doing so would not give rise to adverse effects on the integrity of European sites, whether alone or in combination with other development. Any development with a potential impact on SPA or SAC sites will be subject to a Habitats Regulations Assessment.

Development will not be permitted within or adjacent to national sites unless it can be shown that doing so would not be harmful to the nature conservation interests of the site. Permission will not be granted for proposals that are likely to materially harm the nature conservation interests of local sites unless clear justification is provided that the need for development clearly outweighs the impact on biodiversity.

Blue infrastructure

Waterways will be protected and enhanced. Development proposals that are likely to have an impact on waterways, including the River Wey catchment, must demonstrate how they will support the implementation of the Water Framework Directive and have followed guidance from the Environment Agency and Natural England on implementation of the Wey Catchment Plan and flood risk management.

Open space

Open space (encompassing all open space within urban areas, land designated as Open Space on the Policies Map and all land and water that provides opportunities for recreation and sport) will be protected from development in accordance with the NPPF.

GGG Response

Summary

Response type: OBJECT  

The Policy shows concern for conserving and enhancing biodiversity, which is welcome. We also note and welcome the intention to extend the principle beyond Biodiversity Opportunity Areas. However the current plan to build on large areas of countryside and to inset villages will have the opposite effect. The Policy appears therefore to be a box-ticking exercise with no real teeth to it. 

There is no mention of the value of wildlife gardening to biodiversity or the important role that larger gardens play in a village setting. 

There is no mention of the impact of the plan on food production, or monitoring the loss of agricultural land. 

“The natural world, its biodiversity and its constituent ecosystems are critically important to our wellbeing and economic prosperity, but are consistently undervalued in conventional economic analyses and decision-making” (Biodiversity 2020 page 11)

“As a public authority in England you have a duty to have regard to conserving biodiversity as part of your policy or decision making.” (Government Planning Guidance)

Part of the problem is that “Biodiversity benefits are unpriced” and so not valued by those who look only at the more obvious and simplistic economic benefits.

We have some concerns that “enhancing” the River Wey in the town centre will avoid using the available brownfield land around Walnut Tree Close and Slyfield for urban regeneration and sustainable housing that could otherwise be used.

Why should the Walnut Tree Close/Woodbridge Meadows industrial area not be regenerated from bus garages, urban car parks and empty factories to offer sustainable, well designed, urban homes which are medium height, and can meet almost all of Guildford’s real housing needs?

Detailed response:

The policy on Green and Blue infrastructure is broadly supported with an important and major caveat; and if disregarded this should count as an objection.

However, it is noted that the largest areas of industrial brownfield land within the borough are near to or adjacent to the River Wey, particularly in the Walnut Tree Close area and in the Slyfield industrial area.

These areas could support much more housing than the relatively small numbers indicated in the policy on the town centre, under a town centre regeneration scheme.  This would have huge benefits for the community as a whole since relatively run down areas would be subject to regeneration, the river banks would be cleaner and more attractive.

It is vitally important for the town as a whole that the run-down Walnut Tree Close area is used for well-designed housing, as indicated by the Mastervision document first draft compiled by Allies and Morrison.  John Rigg of Savills and Guildford Vision Group indicated  to the Scrutiny Committee of GBC that initial commercial projections indicated that the Walnut Tree Close area alone could provide 4000 homes. This is significantly in excess of the current GBC proposals.  Both Allies & Morrison and GVG initially indicated that they believed that this site could be available for regeneration within the critical 5 year window required for the local plan.  It is therefore essential that nothing in this policy should jeopardise anything that could lead to the Walnut Tree Close area being a regeneration zone.

As has been noted elsewhere, for reasons that are not altogether clear but appear to be connected to central government direction and a desire to maximize the Community Infrastructure Levy, there is an aggressive desire to push development on to the Green Belt at all costs, ignoring or eliminating for other reasons sites which could be used in the town for residential purposes. This has informed recent planning decisions (both the Aldi site and the Waitrose site were originally zoned for residential purposes and were eminently suitable for this) and this bias seems to be informing the Local Plan.

As a result, it is important that the desire for Green and Blue infrastructure does not become an excuse for preventing regeneration of Walnut Tree Close.  It is noted that the Council has stated that “The Council is keen to protect the watercourses from inappropriate development that would spoil their character”. The bus station adjacent to the River Wey, and the empty car parks associated with empty factory space, are hardly attractive development – well designed mid height (3-4 storey) apartment blocks would be a great improvement to the river corridor, offer major scope for sustainable regeneration, and would prevent the need for any incursion into the Green Belt to meet reasonable housing needs.

That regeneration zone would be highly sustainable, because it would be within 1 mile of the railway station, adjacent to the A3, and would eliminate an area of huge congestion in the town because if the industrial sites were replaced by housing then the residents would commute by train or walk to work rather than having to drive in to an industrial estate.  

It certainly does not seem appropriate to create substantial new parkland on current hard standing.  The protections to which this policy refers largely describe existing open space, which is of great importance.   But to determine not to utilize brownfield land for residential use at an appropriate density in order to force building on to the Green Belt would seem to be in contradiction of the principles of use of the Green Belt applied in the Gallaher Homes v Solihull court of appeal case, where the hierarchy of use is clearly defined, with urban brownfield required to be used as a first option.

So there is some considerable support for the residential element of this policy, with the note that this should be explicitly amended to permit construction of a regeneration zone on the brownfield areas surrounding the river in the middle of the town, and that this should not be held up pending yet more transport studies (Guildford’s track record on brownfield utilisation is poor), but should be implemented with immediate effect.

It is not clear what form the “parkland” along the River Wey will take but the images available in the Town Centre MasterPlan suggest  mown grass similar to the area around Millmead. This misses an opportunity to enhance biodiversity and enable town centre residents to engage with wildlife. Engagement with wildlife should mean much more than throwing bread at ducks and chasing pigeons. To achieve a wildlife corridor through Guildford, that can also benefit  the health and well-being of residents living close by, the green space retained beside the river should be managed with the needs of wildlife in mind.

Responses to policy notes:

4.6.33 Villages are generally permeable to wildlife. The lower density of housing and presence of gardens (especially larger gardens) provides a corridor for movement across the residential area. Insetting of villages and the relaxation of planning restrictions in the Green Belt implied by Policy P2 will lead to infilling, “garden grabbing” and consequent loss of biodiversity. It will replace connections and corridors between habitats with barriers and lead to further fragmentation of our natural infrastructure. 

4.6.34 In the past Guildford Borough Council recognised the role that wildlife gardening and management of parks and open spaces for wildlife could play in enhancing biodiversity. There seems to have been a shift away from this. These aspects should be recognised in the Plan as well as the importance of BOAs and although 4.6.35 goes part way towards this we have yet to see the GISPD.

4.6.36 This is long overdue and should include the way that our lanes are managed. The current approach is unsympathetic, sometimes damaging tree roots and scarce native plants. It seems to be oriented towards encouraging faster traffic rather than recognising the traffic-calming effects of natural vegetation (See the original Quiet Lanes Initiative) – management of open spaces and lanes

We await the Countryside Vision with interest.

4.6.37 It appears  that Policy I5 has been omitted.(We think this meansP5 – more evidence of slapdash work)

4.6.38 We agree with this statement but public access is frequently damaging to biodiversity – the more obvious examples being dogs out of control in the vicinity of ground-nesting birds and trampling of grassland habitats. Public open space must be protected for the reasons given but wildlife needs undisturbed (or at least less disturbed) space too if it is to thrive.

Responses to definitions:

This section starts with a definition that is not a proper definition and is followed by statements that are not definitions at all, apart from the last  – suggesting that this part of the document has not been thought through or checked.

4.6.42 “Biodiversity creation and/or enhancement” is not a definition – it requires definition.

Do you mean that you will create new species or encourage them to evolve ? Or do you mean that you will increase the number of species living in the Borough, or the population of each species, or both?

The points made are aspirational that have no enforcement to back them.

We support the use of green roofs and walls.

However, building on the countryside and increasing the population by such a large amount will not help vulnerable species. It will put added pressure on remaining habitats and increase light and air pollution, degrading the ability of the borough to support wildlife.

4.6.43 Arrangements with developers have no guarantee of success or longevity. They involve partial mitigation and overall loss of the original biodiversity interest of a site.

4.6.44 This appears  to be saying that you will deliberately put playing fields, sports facilities and other leisure activities in BOAs – but these are land uses that reduce biodiversity!

4.6.45 Our understanding of SANG is that it is intended to reduce pressure on Special Protection Areas by providing an alternative area for people to walk their dogs – and hope that  they do not prefer to use the SPA.  In other words they are intended to attract the type of user that is damaging to vulnerable species such as ground-nesting birds. In the desperation to find SANG land Guildford Borough Council are making use of existing open space that will not attract people away from the SPA and you are ignoring the impact on existing wildlife. For example – GBC decided to include the towpath in the Parsonage Meadows SANG as a way of also facilitating a cycle route. Encouraging cyclists and dog-walkers to use the same narrow path will not encourage dog-walkers to use it rather than the SPA. At Effingham Common GBC plan to designate an important area for wildlife and ground-nesting Skylarks.  GBC is riding roughshod over  the opinions of the Commoners and local residents. GBC used to put up signage warning dog-walkers not to disturb the Skylarks during the nesting season – but these signs were not put up until well into the nesting season this year and only then after complaints and harassment of Skylarks by out-of-control dogs.

In allocating sites as SANG, GBC has ignored the requirement to consider existing biodiversity and clearly have little or any knowledge or understanding of the issue. The issues relating to Russell Place Farm have been pointed out by a qualified Biologist (see article in The Guildford Dragon by Chris Venables, Many invertebrates are dependent on the dung of grazing animals and this aspect of our countryside is being steadily driven out of our Borough).

4.6.46 We welcome this acknowledgement of the damaging effects of the proposed building developments. This also has relevance to the manner in which the green spaces next to the River Wey are managed.

4.6.47 We welcome the proposals but are concerned that these may be no more than good intentions. How will GBC ensure that they are carried out fully – and paid for by the developer?

Reasoned Justification:

4.6.50 As the emerging strategy for Surrey and the GISPD are not yet available the plan should not be proposing sites that will jeopardise them. The implication is that this aspect of the plan is not being taken seriously and will carry no weight in site selection despite the guidance in the NPPF.

4.6.51 In fact some GBC contract mowing and lane management is not in line with a strategy that is meant to protect biodiversity. Examples – damage to tree roots and unsympathetic treatment of roadside vegetation (that includes orchid species) in Chalk Lane – southern end of Kingston Meadow in East Horsley is now mown flat rather than left to grow as a meadow through the Spring and Summer as it used to be (so no more day-flying Burnet moths).

KEY EVIDENCE

Guildford Borough Policy Statements are statements – not evidence.

Additional evidence should include:

Existing SNCI surveys, including those that took place in 2004-2007.

Biodiversity evidence emerging from Neighbourhood Plans.

Evidence obtained by requests to local naturalists and natural history societies including those with a specialist interest.

MONITORING

Simply maintaining open space will not be enough for a significantly enlarged population.

Providing more open space to meet existing shortfalls or the needs of a much larger population will reduce the area of land currently in food production or providing wildlife habitat.

SANG delivery is harming existing biodiversity

It is not clear how you will measure a change in biodiversity just by looking at planning applications. “Net gains in biodiversity provided by development” is a contradiction in  terms. There may well be a few examples in England where low density housing has been combined with manufactured habitat at the expense of loss of agricultural land with no surrounding habitat damage - but we see no evidence of that in the Local Plan.  Even when a housing development replaces agricultural land it increases pressure on the surrounding countryside. A simple example is where houses border woodland and residents dump their garden rubbish (and often worse) over the garden fence.  Increased leisure use on nearby countryside also has an adverse effect on biodiversity.

There is no guarantee that mitigations listed in an application will be carried out and their effectiveness is not guaranteed either. GBC would need to carry out follow-up ecological surveys on all sites. Who would pay for these ? Are there enough consultants to carry out the work in sufficient detail ? What aspects of biodiversity will be measured? 

How frequently are surveys by Natural England intended to take place ? How will GBC ensure that NE carry them out ? A baseline  of existing surveys against which changes will be monitored should be included within the plan and it must  be comprehensive for  monitoring  to be effective. 

How frequently will SNCI surveys be carried out ? At what expense ? The last survey published in 2007 made recommendations for an increase in the size of the Wisley Airfield SNCI and stated that this should be taken into account for planning purposes. This was overridden  in the recent planning inspector’s report and the Local Plan includes this particular SNCI as a building site. This is clearly a case of hypocrisy and suggests that the Council has no genuine intention to maintain biodiversity let alone enhance it.

We believe that a survey of SNCIs is currently taking place but that it is limited in scope to the previously known sites. This prevents other sites, where genuine biodiversity enhancement has taken place (often as a result of volunteer community effort), from being recognised in this way. While every stone is being turned over in the quest to find green space to build on, no genuine effort is being made to identify biodiversity hotspots that may have been overlooked in the past. In other words the approach being taken is one that intends to make no net gain, and possibly even reduce, sites of nature conservation interest – in contradiction to the stated aims.

If an existing SNCI (or one proposed on grounds of biodiversity but not formally accepted in a Local Plan) is found to be in poor condition the action taken should be to bring it back into good condition – not to remove its status and build on it.


2017 Guildford Local Plan

Guildford’s NEW local Plan has just opened for consultation. PLEASE RESPOND before 24th July 2017.  GGG has published its responses to Local Plan Policies here 


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