Policy P2: Green Belt

GBC Policy

Policy P2: Green Belt

We will continue to protect the Metropolitan Green Belt, as shown on the proposals map, against inappropriate development. In accordance with national planning policy, the construction of new development will be considered inappropriate and will not be permitted unless very special circumstances can be demonstrated.

Certain forms of development are not considered to be inappropriate. Proposals will be permitted where they are consistent with the exceptions listed in national planning policy and, where relevant, also meet the following criteria:

Extensions or alterations

The extension or alteration of a building provided that it would not result in disproportionate additions over and above the size of the original building.

Replacement buildings

The replacement of a building, provided the new building:

  •     would be in the same use, and
  •     is not materially larger than the one it replaces, and
  •     is sited on or close to the position of the existing building.

Limited infilling

Limited infilling within the identified settlement boundaries of the following villages:

Albury, Compton, East Clandon, East Horsley (south), Gomshall, Holmbury St Mary, Peaslake, Pirbright, Puttenham, Shere, West Clandon and Worplesdon.

Limited infilling may also be appropriate outside the inset or identified settlement boundaries, and in the following villages, where it can be demonstrated that the site is as a matter of fact on the ground within the village:

Artington, Eashing, Farley Green, Fox Corner, Hurtmore, Ockham, Seale, Shackleford, The Sands, Wanborough and Wisley.

GGG Response

Summary

We OBJECT to this policy. This policy is much weaker than previous protection. It is dependent on the Surrey Hills Management Plan. Note that this welcomes housing development. The Surrey Hills needs much more substantial protection. Even major (undefined) development in the AONB would be permitted if exceptional (undefined) circumstances could be demonstrated.

Detailed response

This policy is tepid in support of the Metropolitan Green Belt even though it constitutes 89% of the borough and should be the cornerstone of all local planning policy. It is precious beyond the short-term demands of the present Government’s policy or a 15-year local plan.  As noted under Policy S1 above, it is a solemn legacy to future generations – an asset and amenity that belongs as much to Londoners and the wider nation as to the people who live in it.  It is not the Council’s to give away, and once it is gone it is gone forever.

Any policy on the Green Belt should start with a fair assessment of its value.  The Green Belt is not just empty space but is an inhabited, working environment that safeguards a certain stock of natural capital.  Building on it involves high opportunity costs, including an irreversible loss of:

  • Agricultural production
  • Rural leisure and tourism amenities
  • Water catchment
  • Flood control
  • Biodiversity
  • Natural heritage
  • A carbon sink for air pollution
  • Room for public facilities such as parks and burial grounds
  • Profitable film locations (e.g. Shere)
  • Future economic potential such as mineral extraction (even fracking)
  • Natural beauty, landmarks, open space, rural views and sight lines
  • Benefits to public health and wellbeing, physical and psychological (as well expressed in the NPPF) 

As a matter of law, morality and national and local policy, these assets should be protected in perpetuity, but Policy P2 seeks to justify excessive development in supposedly protected areas.  This is in breach of party manifesto commitments and contrary to previous responses to public consultation.  

It is disreputable to argue, as the Council does, that the plan would involve the loss of “only” 1.6% of the borough’s Green Belt.  Leaving aside the reliability of that statistic, the NPPF does not set an “acceptable” percentage.  No-one argues that we should sell 1.6% of British Museum artefacts in order to build houses.

I am not opposed to appropriate development in the Green Belt and recently supported a major planning application in my own village.  But I fail to see why a system of fair burden-sharing of new development cannot be applied to the borough’s existing settlements in proportion to their size.  This would minimise the strain on infrastructure and maximise the chances of retaining the character of each settlement through gradual growth.  It is reasonable to ask urban Guildford, with x times the population of semi-rural East Horsley for instance, to accommodate x times the number of new homes over the plan period.  Parish councils could be asked, and would no doubt be willing, to propose where their quota of houses should go.  Most rural residents are reasonable people who, if not alienated by top-down planners, will support realistic numbers of new houses in their neighbourhoods. Unfortunately, this democratic, bottom-up approach has not been attempted.  

Instead, while developers flip and land-bank urban sites as a financial speculation, this plan will dump most new development on greenfield sites where building costs are lower, covering the Green Belt with dozens of housing estates few residents want.  8,086 new houses are planned for the Green Belt but only 1,135 for Guildford urban area.  This is disruptive, socially inequitable and unnecessary.  It will not only destroy countryside but will also delay and disincentivise much-needed urban regeneration.  The remarkable revival and repopulation of central London shows that building dormitory satellite settlements is an out-of-date approach to planning.

I particularly protest at the “insetting” of 14 villages from the Green Belt, and at “infilling” 12 Green Belt villages.  I am deeply disturbed that settlement boundaries are to be hugely extended in many villages and that infilling is also proposed outside the settlement boundaries of 11 further villages.  Many Guildford villages are “leggy” in outline, reflecting the effect of ribbon development (often along just one side of existing roads) permitted between the Wars.  It is all too easy to square off boundaries by including countryside bounded on only one or two sides by existing development, claiming it contributes nothing to the “openness” of the Green Belt, a term which neither the plan nor the NPPF defines.  The NPPF’s other 4 tests of Green Belt status, including the prevention of urban sprawl, are ignored.  Effectively, this policy makes all villages within the Green Belt vulnerable to large blocks of new development and seems almost hellbent on securing the rejection of the plan as a whole. 

I believe this policy is based on a flawed Green Belt and Countryside Study that, according to one Conservative Councillor, was irregularly commissioned by Council officers without the authority of Councillors.   To “inset” two-thirds of the borough’s rural villages on the grounds that they no longer contribute to the purposes of the Green Belt is extreme and inherently implausible, given the borough’s location on the edge of Metropolitan London.  I cannot see how such extensive areas fail to contribute to the purposes of the Green Belt under the NPPF, although they would quickly defeat them if the proposed “insetting” and boundary extensions go ahead.  This policy is wildly disproportionate in terms of any foreseeable development need and has caused tidal waves of opposition from residents.  It flies in the face of NPPF paragraph 17’s aim of “empowering local people to shape their surroundings” and other NPPF provisions.   

The policy states that “the general extent of the Green Belt has been retained.”  This is a misrepresentation.   


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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