Policy S2: Planning for the borough – our spatial development strategy

GBC Policy

Policy S2: Planning for the borough – our spatial development strategy

During the plan period (2013-33), we will make provision for 13,860 new homes, 37,200 – 47,200 sq m of office and research and development (B1a and b) floorspace and 4.7 – 5.3 hectares of industrial (B1c, B2 and B8) employment land to help meet the needs for new homes, support the economy and supply 3,200 additional B class jobs.

The delivery of homes is expected to increase over the plan period, reflective of timescales associated with the delivery of strategic sites and infrastructure. The housing target each year is as set out below, however, this is not a ceiling, and earlier delivery of allocated sites will be supported where appropriate, subject to infrastructure provision.

We will identify 43 permanent pitches for Gypsies and Travellers and 6 permanent plots for Travelling Show people within Guildford borough between 2012 and 2017. Between 2017 and 2027 an additional 30 pitches and 2 plots will be permitted or any new target as identified within an updated Traveller Accommodation Assessment.

Annual Housing Target

Year Housing
Number
Year Housing
Number
2018/2019 500 2026/2027 700
2019/2020 550 2027/2028 700
2020/2021 600 2028/2029 785
2021/2022 600 2029/2030 790
2022/2023 700 2030/2031 790
2023/2024 700 2031/2032 790
2024/2025 700 2032/2033 790
2025/2026 700    

GGG Response

Summary

We OBJECT to this policy.

13,860 homes are proposed. This number has not been scrutinised by councillors despite repeated requests for debate. The assumptions and calculations underlying the model are hidden. It is not reasonable to produce unsubstantiated numbers in order to justify major structural change in a widely protected area (89% Green Belt, 44% AONB, approx. 75% protected by SPA). It is inappropriate to allocate this housing number, either over the plan period OR across projected sites, when the number itself is unsubstantiated. External consultants and members of the public have provided detailed criticisms of the model. IF the housing number were substantially lower, and only met housing need, there would be no need to build on Green Belt or open countryside. The number of homes proposed, plus existing planning permission, plus expected “windfall” sites, exceeds 13,860. Guildford residents would not accept building homes on open countryside to meet Woking’s designated “need” but this seems to be implied.

Detailed response

We have 5 objections to the proposal to build 13,860 new homes: 

  1. The number is based on pre-Brexit data for economic and population growth, including migration.  These now need to be revised downwards, possibly quite seriously. 
  2. The number is based on an arbitrary Housing Market Area (HMA): the “West Surrey” tri-borough area of Guildford, Woking and Waverley.  An HMA should be an area within which a majority of people live, work, shop or study.  On any commonsense view, “West Surrey” is much too small.  Half of Guildford borough’s residents work elsewhere, and half who work here live outside the borough.  A short, half-hour commute puts the borough within reach of Surbiton to the North, Haslemere to the South, Reigate to the East and Basingstoke to the West; but all lie well outside “West Surrey”.  Puzzlingly, the adjacent district of Rushmoor, minutes from Guildford town centre, is outside the HMA.  It is no justification to say that the tri-borough area has been used in the past, or that a similar approach is used elsewhere; unlike (say) Carlisle, Norwich or Shrewsbury, Guildford is in the London commuter belt and part of a far wider and more complex housing market.
    These concerns have been raised since 2014 but the Council has failed to seek better market data.  There was no public consultation on the SHMA and Councillors were not allowed to scrutinise it.  The absence of a ready alternative, however, does not make “West Surrey” reliable.  The area is artificial, and so therefore are the housing numbers derived from it.  For instance, by juxtaposing Guilford with Woking it appears that Guildford residents are being asked to build homes on open countryside to meet its bigger, urban neighbour’s “need”.  Guildford wants to build 7 sites of over 500 units, compared with only 4 across Surrey’s 10 other districts, and 26 sites over 100 units, compared with 53 across the rest of the county.  This distribution is unbalanced. 
  3. The figure of 13,860 new homes is unsubstantiated.  It has not been scrutinised by Councillors despite repeated requests for debate.  The assumptions and calculations underlying the model are hidden, protected by a claim to intellectual property by commercial sub-contractor used in preparing the SHMA.   The Council say we should trust the contractors’ model because it is used by a large number of other local authorities.  Wide usage, however, does not confer objectivity.  Guildford’s OAN would fail the basic transparency test even if the methodology used were a universally admired ‘gold standard’.  But it is not: it belongs to consultants whose website openly proclaim their pro-development agenda,  leading to reasonable suspicion that the figures are inflated. External experts and members of the public have provided detailed critiques of the model.  Its most fatal flaw, however, is that it has not been disclosed – not even to the authors of the plan, who have taken it on trust.  This is irrational and unsound.
  4. The status of the 13,860 figure is ambiguous. The plan fails to set a Housing Target of new homes to be built, or explain how this relates to the “Objectively Assessed Number” (OAN) for housing need.  Elsewhere, the Council have said that the two are identical because the OAN is “deliverable” and is by definition objective and cannot be contradicted.   But they also say that infrastructure or other constraints may in due course affect deliverability.  In contravention of the NPPF, the plan fails to address these.  In addition, the number of homes proposed, plus existing planning permission, plus expected “windfall” sites, exceeds the total of 13,860.  So how many homes (taking account of these adjustments) do the Council want built?  The plan does not say.  Without this figure it is hard to see how can anything else be planned.  This undermines the validity of the whole consultation.  It is unreasonable to ask the public to approve a “plan” that fails to propose a target number that takes all the standard constraints and adjustments realistically into account, leaving the Council to set one without further consultation.  Even if the OAN were not flawed, it is at best only a baseline figure and should not be passed off as a policy proposal.
  5. It is unreasonable to embark on a radical transformation of the borough on the basis of an unclear housing target.  Most of Guildford borough is highly protected from development (89% Green Belt, 44% AONB and about 75% protected by SPA). Whether or not increasing the number of dwellings by up to a quarter is desirable, it would be a major and irreversible change, arguably turning a largely rural borough into a mainly urban or suburban one like Woking.  The scale of the housing number increases the onus for it to be seen to be sound.  A substantially lower number, on the other hand, would remove the need to build on Green Belt or open countryside, and instantly meet the single biggest public objection to the plan as a whole.


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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