NPPF Changes Consultation 2015

Increasing Residential Density Around Hubs

Question 3.

Do you agree with the Government’s definition of commuter hub? If not, what changes do you consider are required?

There is no size threshold set for a ‘commuter hub’ in the consultation document in terms of population size or number of dwellings. Our experience in Guildford borough is that planners will attempt to set local development criteria that force small communities to become large communities simply because they have frequent presence of inter-urban bus services passing through them and/or they contain a small rural station.  These routes might be there due to public subsidy or historical accident.

We are concerned that rural ‘commuter hubs’ in the Green Belt surrounded by small rural communities based in the Green Belt encourage inward journeys by car to reach the transport interchange. This leads to rural congestion, inappropriate speeding on D class and unclassified roads and a reduction of safety for cyclists and pedestrians on such routes. Levels of automotive pollutants rise and threaten health of children and older adults in rural communities. If there is such a thing as ‘sustainable development’, this is not it.

Rail and bus service frequency in dispersed rural areas is not fixed as many depend on local authority subsidy. Train and bus operators can have their operations subsidised by local authorities to provide more frequent services at peak times. This should not be an opportunity for LPAs to manipulate the number and service frequency in order to claim a rural village with a number of rail and bus services qualifies as a ‘commuter hub’. Our experience in Guildford borough is that this was done in the creation of a now-debunked Settlement Hierarchy evidence document submitted at the commencement of the Local Plan process. Subsequent actions by Surrey County Council to reduce their budget is seeing bus route subsidies withdrawn and low use rural routes being withdrawn from rural settlements in the Green Belt that previously had the route presence and frequency used to inflate their suitability for development.

Railway stations in Green Belt villages used by local commuters do not make the village a ‘commuter hub’, made ripe for housing development by revision of Green Belt boundaries during the Local Plan process.

  • We propose a viability test for rural rail and bus services emanating from a rural settlement that might be proposed by an LPA as a potential ‘commuter hub’. The viability test shall evaluate solely the routes of train and bus operators that operate without public subsidy. The evaluation shall be based on the number of passenger miles of those routes with a threshold set at an average of 50 passenger miles per user. Such routes, where average passenger miles per user fall below this threshold, shall be regarded as not contributing to a ‘commuter hub’ status.
  • We propose the exclusion of routes that are sustained by public subsidy as they are effectively a social service and should not be considered in the evaluation of what forms a ‘commuter hub’.
  • We propose the removal of any frequency of service test as this is easily manipulated through public subsidy of operators.
  • We propose a test for rural settlements that might be proposed as ‘commuter hubs’ by LPAs based on either the number of residential dwellings or local population. We propose a starter threshold of 1,500 residential dwellings or a starter threshold of a population of 2,500 residents.


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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