Vision and Ambition

GGG Response

Vision and Ambition

The vision is to build 693 dwellings a year, an inflated housing target, produced by using a “black box” model that takes no account of anomalies in the ONS statistics for the borough that underpin this model.  One such anomaly is the increase in the number of university students during the base years used to generate ONS population projections.  Consultants used by GBC ignored this, so the housing target is far in excess of the needs of residents.  This housing target will result in the borough’s permanent resident population increasing at 4.5 times the rate of population increase during the period 2001 to 2011, as measured by the censuses in these years.  Given the existing strain on infrastructure in the borough the “vision” in this plan will create a nightmare for existing residents.  

The only ambition in this plan is to build on a scale across the borough never before seen, driven by the ambition to “roll back the green belt”.  There is no regeneration programme for urban areas of Guildford, and instead of using the Local Plan as an opportunity for redevelopment within Guildford’s deprived areas, the focus is on large developments outside Guildford, mostly in green belt.  The plan has nothing for low paid workers in Guildford, and very little for young people who wish to live in the town.  It is a plan to benefit developers, not residents; a plan rooted in the past, but without learning lessons from the past.  

There are many contradictions within this Local Plan, and a few of examples of these are given below:

  • The plan proposes a major increase in traditional “bricks and mortar” retail in the town centre, as well as an expansion in warehousing and distribution.  Workers in these sectors tend to be among the lowest paid, at or just above the minimum wage.   The plan places an emphasis on the provision of “affordable” housing, but those on the minimum wage cannot afford “affordable” housing, it is a misnomer.  Workers in these sectors need social housing, but there are no plans for a significant expansion in Guildford’s social housing.  
  • As well as an increase in town centre retail, etc it is proposed to locate new employment sites in or close to the urban area of Guildford.  Only 20% of the housing proposed is to be within the town, with the remainder outside Guildford town.  This means that if employers take up the buildings in the centre of the town (this is a big if, as in surveys many employers complain about congestion) workers in these employment centres will have to live outside the town.  Inevitably this means they will rely on cars and vans to get to their place of work.  This is not sustainable, Guildford already has a problem with congestion and air pollution.  
  • The rate of growth (averaging more than 693 dwellings a year to 2031) means if employment is to be provided locally (for about 1,200 new adult residents a year) Guildford’s economy would have to expand at a rate well above anything seen in the recent past, and be sustained at this rate for 16 years – a period when history indicates there will be at least two national/international economic downturns.  This sustained growth would be unprecedented.  Without an expansion in local employment, Guildford will become a dormitory town for workers commuting long distances to other areas.  This is not sustainable.  
  • The delivery of housing is entirely in the hands of private companies that currently enjoy record profits due to their control of the delivery of new homes.  These companies will simply not build if anything has a major impact on their profitability, be it a global economic downturn or a local oversupply of housing, whatever.  Similarly, much of the infrastructure required has to be built by private companies, over which GBC have no powers.  In effect, GBC are proposing a Local Plan over which they have minimal control.  They have no powers to force the delivery of their targets in that plan.  This means the plan is an exercise in fantasy, but a fantasy that blights the lives of thousands of people, especially those who live close to proposed development areas.  

These examples serve to illustrate inconsistencies within the plan.  Other specific points addressing the declared “Vision and Ambition” are detailed below.  

Spatial Vision

A plan that will increase car journeys as much as this one will, especially in an area that already suffers from heavy congestion with associated high levels of air pollution, could not be described as a “vision”.  It is more of a nightmare than a vision.  The Metropolitan Green Belt was established to prevent the urban sprawl that has blighted many countries, such as the USA, but the goal of this plan is to set aside the protection offered by the Green Belt, and to create urban sprawl, with large extensions to the urban area of Guildford and the creation of urban areas in the countryside.

A contributor to the nightmare vision is the ongoing lack of investment in infrastructure, which will be exacerbated by this plan.  In terms of infrastructure, the Surrey County Council Infrastructure Plan estimated that the borough would need investment totalling £2.5 billion, based on the provision of about 9,300 dwellings through the period of the plan.  GBC plan for at least 13,860 dwellings, most of them outside the urban areas of Guildford and so infrastructure needs will be higher than estimated.  Of the £2.5 billion, SCC estimated that £2 billion would be available from various sources, leaving a shortfall of £0.5 billion.  In an address to a council meeting, Mike Murray, speaking on behalf of Wisley Property Investments estimated that the developments outlined in the Local Plan would raise £100 million for infrastructure investment.  This leaves an obvious shortfall of £400 million – but in fact the shortfall will be much greater than this, due to the housing target in the Local Plan being about 50% higher than in the Surrey County Council estimate, and because of probable changes to the Community Infrastructure Levy.  This means that the borough cannot possibly meet its infrastructure needs, which is not recognised in the infrastructure plan that forms part of the evidence base of this Local Plan.  

Another contributor to the nightmare vision is the lack of recognition of the air quality problem in some areas of the borough.  That there is an air quality issue is illustrated by nitrogen dioxide (NO2) concentrations that are higher than the legal maximum.  One of the proposed development sites is close to one of the “official” NO2 measuring stations, at Wisley, and this reveals that nitrogen dioxide concentrations have been higher than the legal maximum of an annual average of 40µg/m3 for several years.  Other measurements have been made in villages that have roads that serve the A3 and have high traffic levels, and these have shown concentrations well in excess of the legal maximum concentrations, to the extent that one village has formally requested that their village be designated as an air quality management area.  This has not been put into effect, and the whole issue of air quality has been entirely ignored in the Local Plan, specifically in the spatial vision.  The spatial “vision” proposed in this plan is the reverse of that recommended by the Institute for Air Quality Management, who said “The pattern of land use determines the need for travel, which is in turn a major influence on transport related emissions.  Decisions made on the allocation of land use will dictate future emissions, as many people and businesses will make significant use of road transport for journeys between places that form part of their daily lives.”   

This has not been recognised in the spatial planning within this plan, which proposes that a large majority of new dwellings should be in rural areas, some considerable distance from the urban centre and employment centres.  It is a plan that could have been written specifically to increase journeys by road.  

This report (Land_Use Planning & Development Control: Planning for Air Quality, April 2015) also suggested that 

“Ideally, air quality should be a prime consideration for long term planning, so that land is used and allocated in ways that minimise emissions and that reduce the exposure of people to air pollution, so that land is used and allocated in ways that minimise emissions and that reduce the exposure of people to air pollution.”  

This has not been part of spatial planning, but it should have been, even though there is no statutory requirement to do so.  However, there is a statutory requirement to declare an air quality management area (AQMA) in areas that are known to have high pollution levels, but this has not been done.  The spatial planning in this draft plan will expose more people to air pollution.  Instead of what is proposed, more housing developments should be within Guildford town, which could be achieved by recognising that an expansion in retail and warehousing and distribution is not sustainable, and the land set aside in the town centre for these used instead to provide housing.  GBC should also have used the local plan to set targets for air quality planning, with proposals to reduce noxious emissions, for example, through the use of LPG fuelled public service vehicles, as is happening in other areas, such as Birmingham.  This has not been done; there is no proposal to tackle existing air pollution or to alleviate the pollution caused by adding approximately 30,000 cars and vans to those already in use within the borough.  This is the approximate number of vehicles that the proposed housing additions would bring.  

There are many areas where the text within the “spatial vision” section does not accord with reality, and a few examples are given below:

The opening text of the Spatial Vision reads 

“The Local Plan: strategy and sites makes provision to meet the identified growth needs of the borough in terms of housing, employment and retail and leisure.  This is achieved by maintaining the extent and function of the Green Belt in such a way as to protect the existing character of the borough through maintaining the clear distinction between urban and rural areas and safeguarding the natural built and historic environment”.  

If this were what is planned, there would be little room for complaint.  In fact, the clear distinction between urban and rural areas will be very considerably blurred with large holes punched into the Green Belt.  More than 6% of the Green Belt will lose that designation.  

The plan calls for a very large, high density development at Wisley, close to the boundary of the borough, in what is currently open countryside in the Green Belt.  Another large development is planned at Garlick’s Arch, less than 3km south on the A3, and within another 3 km another at Gosden Hill Farm, all of which are in the Green Belt.  When considering the view from the A3 the current appearance of open countryside from the junction with the M25 to Guildford along the A3 will be lost, replaced by two large developments in open countryside and a large extension to the urban area of Guildford, extending into the countryside.  Thus the extent of the Green Belt will not be protected.

Two of the villages to be removed from the Green Belt are East Horsley and West Horsley, with a total of 363 ha (3.6 km2) to be removed from the Green Belt.  The justification for insetting of villages is given in Policy D4, and this is to increase housing density within villages.  From some of the plans given in the Local Plan showing proposed sites it is clear that it is expected that the provision of a number of development sites and the insetting of these villages is designed to lead to the coalescence of villages, such as East and West Horsley, and Normandy and Flexford.  As the housing layout and style in these villages is an open pattern of development, they both make a contribution to the openness of the Green Belt, and this will be lost because the housing density for the developments proposed (averaging approximately 18 dwellings/ha) is considerably higher than the average density in these settlements.  

It is not clear why new Green Belt will be created in and around Ash and Tongham to prevent Ash and Tongham merging with the village of Ash Green, when the result of removing East and West Horsley from the Green Belt together with together with several new development sites will be their coalescence.  If it was important to prevent existing villages from merging then both East and West Horsley would remain in the Green Belt, and proposed developments would be smaller, in proportion to the existing villages.  

Similar considerations apply to the settlements of Flexford and Normandy.  The area to be inset is approximately 134 ha (1.3 km2) including a very large 67 ha development site, located between the two settlements.  This will result in the coalescence of the settlements of Normandy and Flexford.  As both make an important contribution to the openness of the Green Belt, they should not be inset, and this development site is inappropriate development in the Green Belt.  Again, if it is important to prevent existing settlements of Ash and Tongham merging with Ash Green, then similar considerations should apply to these settlements, especially given that they are in the Green Belt, whereas Ash and Tongham are not.  

The Spatial Vision goes on to say 

“The plan provides for the delivery of 13,860 homes by 2033.  The preferred location for this development is existing brownfield sites.  Over 2,800 units are proposed in the urban areas to take advantage of the existing infrastructure and services, reduce the need to travel and offer alternatives modes of transport to the private car.”  

Or, to put it another way: 11,060 homes are proposed on sites which cannot take advantage of the existing infrastructure and services, which will increase the need to travel and which cannot offer alternatives modes of transport to the private car.  

The low proportion of housing within the urban centre is because there is so much emphasis on providing employment sites within the urban area, for example, by expanding retail premises, etc but not enough on using these sites for housing – to take advantage of the benefits defined in the above quotation.  There is no emphasis on using land in the urban area efficiently, for example, by replacing existing land hungry surface car parks with multiple level car parks, thus freeing up land for housing development.  A few employment centres have multi-level car parks and this should be encouraged in other centres, and all new employment centres should be required to have multi- level car parks, ideally with several levels underground.  Steps such as this would increase the availability of brownfield land within the urban area, and permit higher levels of housing provision.  Another step would be to encourage the University of Surrey to do the same, to be more efficient in their land use, and to house a much higher proportion of students within the university campus – as they previously agreed to do.  There is adequate space for this within the existing campus, especially if surface car parks were replaced by multi-level car parks.  This would free up many houses within Guildford which would then be available to residents, either to rent or purchase.  

The Spatial Vision refers to the need to the economy and steps planned to support local employers.  However, one of the major issues that employers have with Guildford is severe traffic congestion, and this is not addressed adequately in the plan, and the Spatial Policy outlined will make it much worse.  As stated above, a very considerable shortfall in funds required for infrastructure has been highlighted by Surrey County Council.  Proposals for many of the changes to local roads are light on detail, and the funds suggested as being required (which in fact are unlikely to be available) fall well short of what is actually necessary to effect an improvement in congestion.  

The Local Plan includes the provision of additional sites and premises to meet employment needs across the borough, as well as 120 houses per year for new workers for new employers in the borough.  However, the rosy picture painted in the employment report by the authors AECOM does not adequately reflect the actual condition of the local economy.  The strength of the local economy as painted in the Employment Land Assessment Report (Guildford Borough Employment Land Assessment Report, AECOM, September 2015) was exaggerated through the careful selection of supporting statistics.  As an example, in the section with the heading Policy and Socio-Economics (page 1) the increase in employment within the borough was given as 4.1% during the period 2010 - 2013.  This was a period when Guildford was still emerging from a recession, and so employment growth was strong, but not typical of a full business cycle.  Employment growth over a longer period should have been given, to give a more accurate picture of the local economy.  Using NOMIS statistics the number of residents employed in 2005 averaged 68,000 and this had increased to an average of 68,500 in 2015, so that the growth in employment over this 10 year period was less than 1%.   Note too that the average employment in 2015 was considerably lower than peak employment reached in 2007, when it was 74,400.  According to NOMIS statistics there has been very considerable variations in the number of residents employed and this is not captured by the Employment Land Assessment report.  Although the NOMIS statistics refer to employment by residents of the borough rather than jobs within the borough (a similar time series for these is not readily available), jobs available locally should be reflected in the employment of residents.  In fact, NOMIS statistics also reveal that the average weekly pay of residents in the borough is significantly higher (6% in 2015) than pay for those employed within the borough, suggesting the local economy is weaker than neighbouring economies.  Residents commute outside the borough to get higher pay.  

It is simply astonishing that the Local Plan suggests that jobs can be created over a 15 year period at a rate well in excess of anything that Guildford has seen in the past.  It is simply a nonsense to add an additional 120 houses so that additional workers will come to the borough.  The housing target of a minimum of 693 per year will result in an additional adult population of about 1,200 potential employees per year, and the local economy will not be able to supply employment for these people.  Historical employment data provides no evidence that over a 15 year period an additional 18,000 jobs will be created within the borough, given that the number of residents in employment increased by only 0.7% in the 10 years from 2005 to 2015.  Consequently, a large majority of new residents will be forced to commute out of the borough to find employment, adding enormously to traffic congestion and air pollution.  

There are many other instances of selective use of statistics in the Employment Land Assessment Report, far too many to elaborate on.  As the report concludes there is a need for additional land for employment premises, and because a large part of this land set aside for employment is within Guildford town, it is worth commenting on a few more instances of the use of statistics.  This is because this land should be used for housing within the town, which is where the need for housing is, not in the countryside beyond the town.  In Section 6.6 of this report2, an explanation of employment forecasts were given.  Data was used by AECOM from 3 separate forecasting organisations for employment growth between 2015 to 2033, namely 

  • Cambridge Econometrics
  • Experian
  • Oxford Economics

These forecasts exhibited a very wide range – in the case of office employment the range was 0.55% to 1.18% per annum, so the highest forecast was 2.1 times the lowest.  This may be acceptable in a short range forecast, but is wholly unacceptable for long range use.  Similarly, the forecast for employment in the industrial/storage category ranged from 0.58% to 1.14%, so in this case the highest forecast was 2.0 times the lowest.  Again, this range should be unacceptable for use in long range forecasts.  These individual forecasts were averaged by AECOM to provide a number used to project the requirement for floor space for these respective employment categories.  In this case, with forecasts from various sources exhibiting such a wide range, averaging is not appropriate.  As an example of the dangers of averaging consider a human with half of their body in a deep freeze, at about -25°C, and the other half in an oven at 100°C.  Their average temperature would be 37.5°C – an ideal body temperature, but that would be irrelevant because they would be dead.  Averaging must take account of the range, etc and this has not been done.  In fact, the variation given in these separate forecasts indicate that the quality of the forecasts is very debateable, given that they are all for the same variable, and over an extended period of time each forecast would result in a very different outcome.  

In addition, the emphasis on these two employment categories is unwise as the total employment market is important – it is likely employment in some employment categories will fall, so if there is growth in any employment category it must serve to mop up unemployment as well as create new opportunities.  Finally, statistics given for actual changes within Guildford cover the period 2004 to 2012 – but this should be unacceptable for a report published in September 2015, data up to 2014 must have been available at the time of publication.  

A final example of the selective use of statistics is from section 6.11.2, in which the OPDM Employment Land Reviews Guidance Note is quoted.  This was used to provide a ratio of land to premises on that land, over one storey, so that the area required for industrial land could be calculated.  Quoted ratios ranged from 1:0.35 to 1:0.45 (ratio of land : premises) for manufacturing and from 1:0.40 to 1:0.60 for warehouse uses.  AECOM used the average of the median of these to provide a ratio used in producing forecasts for land requirements, namely 1:0.45.  However, using an average of the medians was inappropriate in Guildford – land costs are high in the borough, and a large part of the borough (89%) is designated green belt and so using this average ratio betrayed a lack of ambition to use land efficiently.  An ambitious goal would be to do better than the best, and this would be provided by using an average ratio slightly beyond the range given, for example, 1:0.60.  This could be achieved, for example, by ensuring that all car parking was provided by underground parking, beneath buildings, so that open space could be retained, and by building several storeys above ground where this is possible.  Surface car parking and single storey buildings are inefficient in their land use.  Using an average land to premises ratio, as AECOM did, showed a total lack of ambition to use land efficiently.  Using land efficiently would mean there would be no requirement for additional land to be set aside for employment purposes – and this land could be used instead for housing.  

Overall, the Employment Land Assessment displayed a selective use of statistics to give an inaccurate overoptimistic picture of the growth potential in local economy as well as displaying a complete lack of ambition to use land efficiently.  Consequently, its conclusions regarding land requirements for employment use should be disregarded.  

In the paragraphs devoted to transport, there is a statement 

“During the plan period Guildford will experience significant improvements to transport infrastructure including new stations at Guildford West (Park Barn) and Guildford East (Merrow).  

This is presented as a factual statement.  However, Network Rail has made no commitment to approval of these stations, despite having recently published a study that examines investment needs on this route up to 2043 (Wessex Route Study, Long Term Planning Process, Network Rail, August 2015).  In this study, the possibility of these new stations is mentioned, but only as a response to the consultation that preceded the publication of the report.  Details given of proposed projects that will be included in their next spending plans (to cover the period 2019 to 2024) include no provision of any description for these new stations, and in fact the emphasis is on increasing the number of trains per hour during peak periods.  Adding a further two stops would reduce the ability to add additional trains, and so goes against the need to increase capacity on the line by adding trains.  Thus it seems highly unlikely that these new stations would be provided within the time frame of this Local Plan, if ever.  In addition, it is clear from the Network Rail report that changes to platforms in Guildford Station will not be made in the next budget period (up to 2024) and that the inclusion of this project in the next budget period (after 2024) is dependent on further studies.  Similar timing constraints apply to the electrification of the North Downs Railway.  So the delivery of many of the infrastructure improvements, particularly the new stations, within the timeframe of the Local Plan is, at best, doubtful.  To present their provision as a certainty was simply dishonest.  

Finally, according to the Spatial Vision, the delivery of housing as described in the plan is predicated on the delivery of infrastructure, yet there is no monitoring system in place to ensure that infrastructure is delivered, with necessary services provided.  As an example, consider the need for GP services.  It is possible to build a doctor’s surgery, but there is a national shortage of GPs, so there are considerable problems in recruiting doctors needed to man existing surgeries.  Thus building premises are no guarantee that services will follow, even assuming funds are available.  No monitoring systems or programmes are described in this spatial vision and so one has to assume there are none in place to monitor this programme to ensure that services, as part of necessary infrastructure, are actually delivered.  No red lines for specific developments have been provided, so that it is clear exactly what infrastructure must be provided before a specific development can be started.  As no monitoring systems are in place, there is nothing in this vision to suggest that the promise made by Councillors, that infrastructure will be delivered before additional housing is built, will be honoured


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