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GRA RESPONSE Guildford Proposed Submissi[...]

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GRA RESPONSE Guildford Proposed Submissi[...] Guildford Proposed Submission Local Plan: Strategy and Sites 2016 Consultation Response from Guildford Residents Association 18 July 2016 Please note this response includes 4 Appendices one of which is a separate document: “A Review of the West Surrey SHMA as it relates to the Objectively Assessed Housing Needs of Guildford” GGRRAA Guildford Residents Association comprises 26 Residents groups and 4 Parish Councils who support the GRA's statement of residents "Aspirations for Guildford". Our vision is for all Guildford residents to enjoy a good quality of life in a healthy, enriching environment within caring communities. Achieving this requires Guildford to: cherish its market town legacy, garden suburbs and downland setting, encourage innovative, sustainable development of its high added value economy, building on Guildford’s current strengths and correcting its weaknesses. 1 Question 1: The evidence base and submission documents GRA Comment: Key parts of the evidence are missing, flawed or based on withheld assumptions. The Strategic Housing Market Assessment overstates housing need, the Green Belt and Countryside Study uses a flawed approach and the Transport evidence is too late and incomplete to be relied upon to inform the Plan. Strategic Housing Market Assessment The “objectively assessed need” figure of 693 homes a year is too high. A professional review by NMSS (see Appendix 1) has concluded that, even basing the calculations on a period of stronger economic and student growth, the housing need figure should be revised down to 510 homes a year. It also advises the SHMA method should be changed to consider student housing need separately due to the distorting effect of students on the overall Objectively Assessed Need (OAN) forecast. The current SHMA inflates the proposed housing figure due to failure to correct for errors in the historical data for international migration flows, issues with the way it considers students and affordability, and flaws in the method for estimating the number of homes needed to support job growth. The SHMA needs to be revised, and the proposals based upon it reconsidered, before the Plan can be viewed as ready for submission to an Inspector. In addition, an immediate start should be made on calculating student requirements separately using a consultant with appropriate expertise. It is probable this exercise will reduce the OAN. Revision of the SHMA to take account of the consequences of the vote to leave the European Union has been proposed by a number of consultees and the Council leader. The NMSS SHMA Review makes an important contribution to the way ahead in several respects by showing that: even with a relatively strong pre ‘Brexit uncertainty’ economy, and using a stronger trend period than the one used by GLHearn for migration flows within the UK, the GLHearn OAN figure was too high. simply making a few post ‘Brexit uncertainty’ adjustments to economic and demographic need, as currently calculated by GLHearn, would not be 2 an adequate response because their approach to the economic data is flawed and they have not corrected for large errors in the historical data on international migration, student flows should be better understood and separated out to avoid distortion of the forecasts and, especially given the significance of flows of international students in Guildford, separate modelling of the student population will become more significant in future. NMSS has advised that the new projections issued on 12 July 2016 should make little difference in Guildford as the household formation rates on which they are based are not significantly different from the 2012-based set. It is most disappointing that demographic and economic model assumptions have been withheld by GLHearn so that the whole process cannot be cross checked. This means the OAN taken from their SHMA cannot be substantiated. Green Belt and Countryside Study This does not value appropriately the “fundamental aim” of Metropolitan Green Belt or look strategically at options for developing instead in major settlements beyond the Green Belt. The way Green Belt is parcelled up and scored is invalid: serving 2 Green Belt functions well is as legitimate as serving 3 to 5 functions. The Green Belt sensitivity analysis is not a valid basis for informing decisions. Eg It could be argued the sweep of open countryside rising up Gosden Hill, as you approach Guildford along the A3, is highly prized. So too is the role of Green Belt in preventing urban sprawl towards the Hog’s Back. Proposed removal from the Green Belt of a number of relatively small sites where development of an exceptional nature has taken place, plus adjoining land, has lost sight of the scale at which Green Belt is effective. Assessment of which villages to take out of the Green Belt does not adequately consider that villages contribute to the openness of the Green Belt as seen from surrounding AONB. Transport Evidence This has been produced very late and is incomplete and untested to the extent that the Plan is not ready for a Regulation 19 consultation. It is emerging that the Strategic Highway Assessment shows there will be congestion, even with all the highway schemes in the Plan. Many questions remain unanswered. We assume various inconsistencies are 3 errors (eg 1000 homes on Slyfield generating no extra traffic). More information is needed to understand how much congestion will occur, and where. This has not been provided in time to inform Plan proposals or responses. The analysis points out problems across the network and does not support the claim that the highways network can accommodate the additional demand arising from the Plan. The available evidence shows that the Sustainable Movement Corridor is in a preliminary stage of development. The information provided indicates that it cannot achieve its intended objectives along much of its route due to narrow roads and pinch points. The original concept has had to be diluted and impact on other routes, demand and an economic business case are required. The very concept of a single linear route as appropriate for Guildford is unproven. Evidence on bus travel is fundamentally compromised because no clear and workable location for a bus interchange is proposed. No information has been provided on the demand for and capacity of rail services. The main line to London is already extremely busy in peak periods. Information about the town centre as regards traffic, buses and parking is lacking in the Plan. The Plan does not address the traffic issues in the town centre. The Council has announced its intention of implementing the Town Centre Master Plan which includes making better use of the asset of the river. We submit that the Plan should include the protection of a route for a new bridge connecting the east and west parts of the town across the railway to maintain accessibility and to provide greater resilience in this key part of the road network. For more detail refer to Appendix 2. [Please Note: Additional transport information has been requested which it was not possible for Guildford BC and Surrey CC to provide in time for this submission. A list of the relevant questions has been submitted. GRA wishes to reserve the right to follow up aspects of this submission where lack of transport information (data or model assumptions) or absence of clarification leads to gaps or errors in analysis and observations.] Guildford Retail and Leisure Study This is an improvement but the credibility of the case for massively expanding retail space is undermined by trends in retailing and by the repeated failure to implement the North Street development. The economic 4 value of the green and historic character of Guildford is not adequately considered. Air Quality and Noise NO2 emissions need careful monitoring in view of some sites being close to limits, revised estimates of premature deaths, issues with vehicle emission controls and misplaced optimism regarding congestion. Traffic noise from the A3 should also be reported. 5 Question 2: Legal Compliance GRA Comment: The Plan preparation process has had inadequate regard for national policy which attaches “great importance” to the “openness” and “permanence” of Green Belt. The test of “exceptional circumstances” that might justify allocating Green Belt land for development in a Local Plan has not been rigorously and transparently applied at a strategic level. The Sustainability Appraisal seems to have lost sight of the concept of Sustainable Development as described in the National Planning Policy Framework to the extent that we question whether it complies with the requirement. Green Belt It is unacceptable to treat Green Belt as a readily available source of development land during Plan preparation, notwithstanding that this is the time when any boundary review deemed necessary takes place. Any such review should be mindful of the “great importance”, “openness” and “permanence” of Green Belt and take a long term perspective towards this planning mechanism. The Mayor of London intends to respect London’s Green Belt boundary. The test of “exceptional circumstances” that might justify allocating Green Belt land for development in a Local Plan has not been rigorously and transparently applied at a strategic level. Releasing Green Belt to fund infrastructure (eg “support delivery of A3 junction upgrades” or “facilitate delivery of new strategic infrastructure including a rail station, park and ride and a secondary school”) or to fully meet exaggerated need does not pass this test. Nor does building on open, previously-developed Green Belt. Opportunities to channel development towards locations beyond the outer Green Belt boundary, linked to sustainable transport and the duty to cooperate, have not been adequately considered at a strategic level. This assessment should involve more than just looking at a small area of countryside within the borough immediately beyond the Green Belt boundary, or indeed the rather meaningless Housing Market Area.
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