Policy I1: Infrastructure and delivery
Policy I1: Infrastructure and delivery
To support delivery of this Local Plan, infrastructure needed to support development should be provided and available when first needed to serve the occupants and users of the development. This will be secured by planning obligation, planning condition, or from other infrastructure funding, including the Community Infrastructure Levy. Where the timely provision of necessary supporting infrastructure is not secured, development may be phased to reflect infrastructure delivery, or will be refused.
The key infrastructure needed to support the delivery of this Plan is provided in the Infrastructure Schedule at Appendix C. The Local Plan also includes land allocated for infrastructure. This infrastructure is listed at Appendix C. The non-site specific and more general infrastructure requirements are set out in the Planning Contributions Supplementary Planning Document (SPD) 2011, which will be updated as required.
Through the Community Infrastructure Levy (CIL) we will collect financial contributions from most new build developments in the borough. We will use CIL receipts towards providing infrastructure to support development, and will facilitate the spending of up to one quarter of CIL receipts originating from each Parish and from Guildford town, on local priorities to support development.
In allocating developer infrastructure contributions, we will prioritise Thames Basin Heath Special Protection Area mitigation and avoidance in order to ensure that we meet our legal responsibilities.
We OBJECT to this policy as it stands. Various aspects of Infrastructure are acknowledged as congested, inadequate for the existing population and not able to accommodate much growth. However, greenfield sites – requiring heavy infrastructure investment – are targeted in order to generate CIL income for the council. This is not sensible. The current draft CIL scale also encourages development on greenfield sites rather than brownfield.
The methodology commissioned by the Council to assess traffic and the corresponding roads infrastructure needs is inadequate for the purpose of the Local Plan and identifies only the tip of the iceberg in terms of existing congestion. Looking at local traffic situations around the Borough it becomes clear that the schemes proposed will not solve congestion and the local road network has not been given sufficient consideration. Under the growth proposed some locations would require highway schemes that involve demolition of property and road-widening in residential areas to solve the resultant congestion. Even the A3 improvements are not guaranteed to take place but they are being used to justify removing large areas from the Green Belt before detailed traffic assessments have taken place. These detailed investigations are being deferred until the planning application stage and will be left to developers to prepare. If a site then proves to be unsustainable its Green Belt protection will have been lost for no reason and unsuitable development will take place by a more insidious process.
With regard to SANG provision, GBC has demonstrated that it has no genuine interest in conserving and enhancing biodiversity and clearly regards the Thames Basin Heaths SPA as an obstacle to be overcome rather than a valued asset. This is underlined at the end of the Policy wording which indicates that the council is more interested in meeting its legal responsibilities than actually protecting wildlife. GBC is failing to take account of existing biodiversity at sites selected for SANG provision.
Some infrastructure, as identified in Figure 1 of the draft IDP- is within the control and remit of Guildford Borough Council – they have some influence in relation to planning – but much is under the control, and is the fiscal responsibility of, Surrey County Council or Highways England.
It is not realistic to assume that car use can effectively be replaced for all or even many users. Those who are disabled or infirm cannot easily substitute car journeys with bike travel: the elderly; the disabled; those caring for young children (particularly uncertain bike users and those with multiple children to care for); those wishing to use cars for supermarket or other bulky shopping; those who wish to commute to work and have no facilities for showering or changing on arrival; those who have lengthy and tiring commutes at present, for which the car is the final (short) element of a long journey (for those commuting into London from outside Guildford, a daily 3 hour commute is typical; this cannot realistically be extended by extensive cycling). All these factors mean that the replacement of the car with cycle use is likely to be overstated by many studies, particularly given narrow roads which do not allow effective or safe bike lanes.
Funding is not the only - nor the main - obstacle to improving infrastructure within the borough, and this seems not to be recognized. Guildford is a gap town, set in a bowl within the Surrey Hills Area of Outstanding Natural Beauty to the south of the borough, and with large sections of the borough affected by the Thames Basin Heath Special Protection Area to the north. There is a ribbon through the middle of the borough which contains rail and road links to London, but is already heavily congested, is Green Belt, AONB, SPA or more than one of the above. Very little of the borough is available for extensive development of infrastructure or any building. Do we really want solutions that involve driving new roads through our remaining countryside – including the AONB – at huge cost in financial and environmental terms. Such solutions may be the only ones left when the inadequacies of this proposed Local Plan are realised after the event.
Policy indicates note an intention to pool Community Infrastructure Levy from most new build development and to use CIL receipts to assist in provision of infrastructure needed to support the delivery of the plan. As with other aspects of planning, there is a failure to recognize that out of town settlements in particular have particularly high requirements for additional new basic infrastructure in order to exist at all – roads, sewers, water provision, electricity, gas, telephone and broadband links will all need to be provided and in many cases the links to existing services will need to be upgraded before these can be implemented. The ability to divert funds from CIL to other uses will be inherently limited, not least that otherwise the proposed settlements will not be able to function. The Council strategy of taking CIL from new build in the Green Belt seems to be to pay for roads within the town centre, as indicated in the policy which notes that legislation prevents the use of planning obligations to fund existing infrastructure deficits.
In the reasoned justification, it is indicated that the council will be prepared to negotiate if an applicant claims that the the infrastructure requirements for their development make it unviable. This means that some developments will go ahead anyway and worsen the infrastructure deficit. The Policy claims that infrastructure needed “should” be provided and available when first needed but we have no confidence in the council enforcing this.
The absolute constraint on developmental capacity within the borough represented by the infrastructure limitations cannot be swept aside, but the council has ignored this and failed to apply a constraint on the housing number.
We are not convinced that the extent of existing traffic congestion has been fully recognised by the SCC transport assessment because the methodology employed waters down the level of traffic observed. This has knock-on effects when modelling the various development scenarios. The result is that the requirements identified (expensive though they may seem) are the tip of the iceberg. One of the easiest issues to understand is the use of average peak hour flows for the baseline data. SCC acknowledge that that this is “typically lower” (see Transport Assessment 4.13.4 but GBC prefer the averaging approach with some eloquent wording in their Headline network metrics (3.9). A much better solution would have been to collect reliable baseline data that allowed for the effects of queuing and modelled each hour (or a shorter time period). Such an approach would have cost more but GBC seem unwilling to go the extra mile for reliable evidence while being content to spend large sums of money on propaganda exercises such as their one-sided video. There are other more technical reasons why the transport assessment methodology fails to fully identify current and planned congestion.
Planned developments for Guildford and Waverley Boroughs were modelled together but growth for the rest of the UK was allowed for only using the DofT forecasts. As a result it is not clear whether adequate allowance has been made for significant developments planned for Woking and other neighbouring Boroughs. This represents an inconsistency in approach with the West Surrey SHMA.
Many of the results for the PM peak are missing (TA 4.1.11 states that “these can be set out in an addendum report at a later date”). We believe that those who need to travel on the roads in peak hours will be every bit as interested in their future journeys home as they are for going to work. Publication of the Transport Assessment was delayed until the start of the consultation period so perhaps the non-inclusion of many PM results was simply a result of running out of time.
The Model Development Validation Report does include some interesting baseline data that may be of interest to residents in terms of local knowledge of traffic.
We are not convinced that it would be practical or desirable to end up in a position where the only solution to traffic congestion is to build many more new roads as by-passes through the Surrey countryside, or turn existing roads into dual carriageways, or demolish buildings (some of which may be historic) in order to accommodate higher capacity junctions in built-up areas.
It is noted that the infrastructure Development Plan was developed using hotspots identified in “OGSTAR” (the previous Transport Assessment used for the 2014 consultation) as a starting point. (See Transport Topic Paper (5.56)). However, the site list used for OGSTAR was not even compatible with the former draft Local Plan let alone the current one. Despite this, the Key Evidence mentions the June 2016 TA but not OGSTAR.
Appendix C (Infrastructure Schedule) is lacking in detail concerning what work will actually be carried out for most of the Local Road Network projects and the cost estimates are clearly at the guesswork stage suggesting that these schemes have not been fully thought through or checked for viability. If more detail is available then why not provide it.
It is not clear whether CIL will be received in time to put the required infrastructure in place for each development – or what penalties will be applied for late payment.
The Monitoring Indicators rely entirely on annual CIL receipts and spending. Surely they should look at actual infrastructure delivery and any changes in its adequacy.