Guildford Parish Forum Summary of Parish Council & Residents' Association Responses The consultation for Guildford's Local Plan ended in September 2014. It is understood that approximately 20,000 responses were received from 7,000 people (just over 2,600 were to the questionnaire). GBC have published interim findings, as there are clear messages that appear repeatedly. In- depth analysis will not be available for some time, so I have carried out a very basic analysis of Parish Council (PC) and Residents' Association (RA) responses to gauge how these compare to overall comments and to see the level of agreement or disagreement the various policies and comments produced. I have no software for this exercise and have not accounted for every detail of each response. There are difficulties in analyzing the results, as they are not clear- cut. In simple terms, (which is how I have conducted this) there were options to object, support or comment on policies. In reality, many responses were a mixture of all three. Some supported, but included many objections, others objected but then supported in part. There were multiple options for responding which included; a short questionnaire, individual policies, sites, (including maps, 's and safeguarded land), evidence base documents and compliance with NPPF. There was also a consultation on the town vision, habitats regulations assessment and sustainability appraisal and should that not have been quite enough to contend with, three areas (East Horsley, West Horsley and Puttenham) were involved in neighbourhood plans. 1 List of Policies are on page 13 1
In conjunction with the formal process, comments made via email or letter or at workshops were also included. Of the 20,000 comments received, the 618 (*top line comments) received from Parish Councils and Residents Associations are relatively small, in proportion. Clear patterns can be drawn from this brief analysis due to repetition of comments and a parallel between these comments and those drawn up by Guildford Borough Council in way of an interim summary. The similarities between comments made leave me to believe that the Parish Council and Residents' Association responses reflected the opinions of residents they represented. Within RA's some represented a small area and local views whilst others, such as Guildford's Residents' Association (GRA) had representation from across the borough. Twenty- one out of twenty- three Parish Councils responded, the exceptions were Tongham and Puttenham (who were finalizing a neighbourhood plan during this period). Twenty three Residents' Associations and Community Associations also took part. Had all respondents commented on all nineteen policies 855 comments would have been made. The actual number of comments on the 19 policies was 393 for whilst half the respondents commented on the majority of policies, some were more selective. Some policies gained more response than others. The following policies received the most comments; Policy 2 Spatial Strategy, with most comments being about the housing number. Policy 10 Greenbelt and Countryside, with most comments being firmly against development (particularly if fulfilling a growth agenda rather than local need) Policy 17 Infrastructure - congestion and sustainable networks must be implemented before further growth can be considered. Policy 9 Villages & brown field. Most objected to insetting / removal of villages from greenbelt. Burpham RA being the sole supporter. There was support for optimizing use of brown field sites before inclusion of Greenfield / belt. Policy details can be found on page 13. * top- line comment refers to direct response ie a clear objection or agreement. This excludes the many comments made within the text of each response 2
The Parish Councils responded to more policy questions than Residents' Associations. It is worth noting that more Residents' Associations responded to policy 15 (Guildford Town Centre) than Parish Councils. As many of the Resident's Associations are urban based compared to only two Parish Councils (one of whom did not respond), the results below are therefore not surprising. Other policy responses were in line with expectations from rural / urban mix. I.e. there was a greater response to policy 5 (rural exception) and policy 19 (green and blue infrastructure). Object / Support or Comment It is clear that the vast majority objected to most policies. Some were almost unanimously unpopular. Policies advocating improvement (to life styles, town or landscape) gained some support, i.e. policy 6 - making better places, 8 - AONB, 4 - affordable homes, 12 - historic environment and 19 - green and blue infrastructure. Comments were tempered by concerns over the housing figure and lack of any visible constraints. The policies receiving the largest number of responses also received the largest number of negative responses. These were connected with the housing number, the greenbelt and infrastructure. Policies 6 (making better places), 8 (AONB) and 19 (green and blue infrastructure) received more support than objections. Support for the AONB policy (8) might have been higher but for the addition of the word 'public' to AONB protection, meaning that protection of AONB would be restricted to public views only as opposed to the general protection afforded beyond Surrey. The vast majority of respondents wanted to see AONB and greenbelt firmly protected. 3
Generally comments were critical although respondents had made every effort to be as constructive as possible when they were able. Generally, the findings were in line with the summary given by Cllr. Mansbridge in December 2014. Key points Housing number too high & lack of clarity as to how the figure was reached Must differentiate between need and demand Disingenuous to refer to external / economic demands as need Demonstrate robust analysis and development of brownfield before considering greenfield / greenbelt Data used in evidence base must be accurate (population, economic, migration and immigration) Weak infrastructure, traffic congestion and most commented on the need to retain greenbelt Great concern about insetting villages Great concern about possible subjectivity of 'very special circumstances' permitting removal of greenbelt / boundary revision Plans shown to some Parish Councils did not resemble those put forward by GBC Why are areas legally protected by EU law relating to SPA / SSSI/ SAC/ AONB included? Incomplete / vague/ non- specific policies Car parks should be subterranean and multi- storey rather than ground level (to optimize use of brownfield sites) The emphasis on economic need is too great in comparison to that placed on the rural economy & conservation Timing of meetings / deadlines gave rise to maximum inconvenience (school holidays, short notice) Lack of support for large strategic sites with highest number of objections for Blackwell Farm Lack of inclusivity for those not IT literate Flooding from the river is acknowledged but little heed paid to surface flooding Greater weight should be given to Parish Councils & Residents Associations and less to those with vested interests Consultant who are also property developers / managers cannot be truly independent and should not be used Subjectivity of the scoring system for greenbelt function apparent as two studies completed by two different agents within 14 months produced different results. The low scores produced in the most recent document, support developers plans Greater provision needs to be made for elderly Inclusion of known errors Bias towards greenbelt development Objections to additional greenbelt destination at Ash considerably outweighed support as it fulfills fewer greenbelt functions than land proposed for removal. Allies & Morrison plan for Town Centre Vision had greater support than GBC's The need for an impact assessment - assess combined affect and cost of new proposals Amendments in documents were not tracked or highlighted, as agreed Disagreement with points made in the introduction, eg. 'we have sought to select sites carefully and in a way which does not overburden any single area of our borough and ensure that the right infrastructure is in place Many could not agree with this due to the level of development proposed in greenbelt and high percentage growth in specific areas Use of the term 'where viable' should be removed (affordable housing policy) 4
Supplementary questionnaire Fewer Parish Councils and Resident's Associations answered the questionnaire than the series of questions on policies. The questions that most groups were unable to support were the evidence base (1) and the overall vision (4). There was also general disapproval of the sustainability argument; the habitats assessment and many felt the plan did not follow the guidance set out in the NPPF (national planning policy framework). There was very little support overall with Ash Parish Council being the most supportive. 5
Strategic Sites There are three strategic sites, these are Gosden Hill (site 59), Blackwell Farm (site 60) and Wisley (site 66). The greatest number of objections from both Parish Councils and Residents' Associations, was to Blackwell Farm. There was very little difference in opinion between Gosden Hill and Wisley and no support for the any of the sites. It is also worth noting that most submissions represented views from their immediate locality. Some did submit views on the wider borough, submissions from societies and campaign groups were not included in this report. The results include answers to the site questions for 59, 60 and 66. Opinions given within text of other parts of the submission will not have been included here. 6
SPECIFIC SITES (excluding strategic sites) In the main comments about specific sites were made by those local to the site. Exceptions were: 61 - Land north of Keens Lane Worplesdon 62 - Land at Liddington Hall Worplesdon 64 - Land at Gunners Farm & Bullens Hill Farm Worplesdon 65 - Land north of Salt Box Road Worplesdon 77 - Land to the south of Clandon station Clandon 96 - Four Acres Stable Normandy 102 - Land north of Tangley Place Worplesdon All of the above received a slightly larger number of objections. Comments / objections were also raised to the following; MAPS Ash, Clandon, Effingham, Normandy & Flexford, Send, Worplesdon and Chilworth (suitable alternative natural green space areas) Effingham Common, Ockham, Blackwell Farm, Backside Common, Stringers Common. SAFEGUARDED LAND Fairlands, Normandy, Flexford and Send Marsh, land adjoining Fairlands. In contrast the following received support; 48 Slyfield regeneration proramme (SARP) Guildford Urban 104 Land at Westborough for Allotments Westborough 105 Land to the rear of Jacobs Well for allotments Jacobs Well The actual break down of comments to individual sites is listed from page 8-13. CONCLUSION There is a general lack of support, because the need for the level of growth proposed has not been adequately proven and without a full impact assessment, it is not possible to determine the real benefits or cost of implementation. [Financial and social costs and impact on infrastructure] Where regeneration is needed, benefits are understood and it is in these areas where support was given. The plan put forward combined local need with wider economic demand. Given our proximity to London, this demand cannot be satiated and there are concerns that attempts to do so will have a devastating impact on Guildford, as we know it. There is no support for the strategic sites and widespread objection to the proposal at Blackwell Farm in particular. There was considerable frustration that the consultation had gone ahead without first correcting known errors and shortcomings and without fully explaining the housing figure. The plan should differentiate clearly between that which is needed to fulfil local need and that which is desirable for additional growth. 7
RED = Urban Blue = Land around Guildford Urban Parish Council Resident's Association Total 46 Former pond meadow school 48 Slyfield Area Regeneration Project (SARP 51 Former car showroom Aldershot 57 East Horsley countryside depot and BT telephone exchange, East Horsley 61 Land north of Keens Lane, Guildford 62 Land at Liddington Hall Guildford 63 Land north of Slyfield Industrial Estate 64 Land at Gunners Farm and Bullens Hill Farm 65 Land north of Salt Box Road, Guildford Object Support Object Support Object Support 1 2 3 1 2 3 2 2 1 4 5 1 4 5 2 3 5 2 3 5 8
Green - Land around villages 68 Land at Hornhatch Farm, Chilworth 69 Redevelopment Parish Council Resident's Association Total object support object support object support 2 2 of Howard of Effingham School & associated land, Effingham 72 Land near Horsley Railway Station, Ockham Road North, West Horsley 74 Land around Burnt Common warehouse, London Road, Send 75 Land at Tannery Lane, Send (including Clockbarn Nurseries 2 1 (com ment) 3 1 (comm ent) 76 Land to the east of Aldertons Farm, Send Marsh 1 2 (inc 1 comme nt) 9
Green - Land around villages Previously developed sites in the countryside (brownfield) Purple = Traveller pitches 77 Land to the south of Clandon station and north of Meadowlands, West Clandon 80 Land south of New Pond Road, adjoining Farncombe 81 Broadford Business Park, Shalford Object Support object support object support 2 1 3 2 2 82 Mount Browne, Guildford 89 Land at Home Farm, Effingham 90 Land at Wyke Avenue, Normandy 91 Land rear of Palm House Nurseries, Normandy 1 (local) 1 92 Land North of Green Lane 93 Valley Park Equestrian, East Shalford Lane, Shalford 95 Roundoak, White Hart Lane, Wood Street Village 2 2 2 10
Purple Travellers Pitches Grey Cemeteries Gold Allotments Parish Council Resident's Association Total 96 Four Acres Stable, Aldershot Road, Normandy 99 Garages at Wharf Lane, Send 100 Land at Cobbetts Close, Normandy 101 Whittles Drive, Aldershot Road, Normandy 102 Land at Worplesdon Road, north of Tangley Place 103 Land to the west of Normandy, east of Westwood Lane 104 Land at Westborough allotments, Guildford 105 Land rear of Jacobs Well village hall, Jacobs Well Object support object support object support 2 2 4 2 comm ent 1 2 3 2 4 6 1 3 4 11
109 110 112 113 116 119 SAFE GUARDED 121 SAFE GUARDED 123 SAFE GUARDED Blackwell Farm Broadstreet and Backside Common Russell Farm Place Stringers Common Former Wisley Airfield Effingham Common Land between Normandy and Flexford Clay Lane link road, Guildford Land to the east and south of Four Acre Stables Aldershot Road, Normandy Parish Council Resident's Association Total Object support object support Object support 1 3 1 4 1 2 1 3 4 2 12
Parish Council Resident's Association Total 118 SAFEGUARDED Land adjoining Fairlands, Guildford Object support Object support Object support 3 3 POLICIES 1 PRESUMPTION IN FAVOUR OF SUSTAINABLE DEVELOPMENT 2 SPATIAL DEVELOPMENT STRATEGY SCALE AND DISTRIBUTION OF DEVELOPMENT 3 HOMES FOR ALL 4 AFFORDABLE HOMES 5 RURAL EXCEPTION 6 MAKING BETTER PLACES 7 SUSTAINABLE DESIGN, CONSTRUCTION AND ENERGY 8 Surrey Hills Area of Outstanding Natural Beauty (AONB) 9 VILLAGES AND MAJOR PREVIOUSLY DEVELOPED SITES 10 GREEN BELT AND THE COUNTRYSIDE 11 ASH AND TONGHAM STRATEGIC LOCATION FOR GROWTH 12 HISTORIC ENVIRONMENT 13 ECONOMIC DEVELOPMENT 14 THE LEISURE AND VISITOR EXPERIENCE 15 GUILDFORD TOWN CENTRE 16 DISTRICT AND LOCAL CENTRES 17 INFRASTRUCTURE AND DELIVERY 18 SUSTAINABLE TRANSPORT FOR NEW DEVELOPMENTS 19 GREEN AND BLUE INFRASTRUCTURE 13
QUESTIONNAIRE Total number of responses in entire consultation 1 Evidence Base - Do you agree that the evidence used for the draft Local Plan: strategy and sites is adequate, up- to- date and relevant? 2 National policy & Guidance To the best of your knowledge, do you think that the draft Local Plan: strategy and sites is consistent with national policy and guidance? 284 263 3 Sustainability Appraisal and Habitats Regulations Assessment - Having looked at the Sustainability Appraisal and Habitats Regulations Assessment do you agree with: a b sites? the Sustainability Appraisal of the draft Local Plan: strategy and sites? the Habitats Regulations Appraisal of the draft Local Plan: strategy and 208 180 4 The Vision a Do you think the vision of the draft Local Plan: strategy and sites depicts the borough that communities would want to be living and working in by 2031? B Do you think the ambitions, issues and strategic objectives of the draft Local Plan: strategy and sites are representative of the issues the borough faces and the things that we will need to achieve to meet our vision for 2031? C Is there anything you think should be included? 5 The Key Diagram a Do you think that the Key Diagram is representative of the key aspects of the draft Local Plan: strategy and sites? B Is there anything missing or is there a way to make the Key Diagram clearer? 6 The content - paragraphs, policies and site allocations Question 6 of the paper version of this questionnaire asks you to make comments on particular paragraphs, policies or site allocations in the draft Local Plan. 261 216 180 180 145 7 Any other comments? 697 14