Council wants to spread housing shortfall over more than five years
Cllr Mansbridge says: “All councils with high proportions of green belt or areas of outstanding natural beauty (AONB) are struggling with the impact of the National Planning Policy Framework (NPPF) and the supporting planning practice guidance. Guildford, with 89% green belt and acute infrastructure constraints compounded over decades, finds itself in a uniquely sensitive position given its inability to meet its suggested housing need without encroaching significantly on its existing green belt.
“We are therefore taking the government at its word and have decided to adopt a policy approach which will exclude all development in the green belt, unless it can be demonstrated that the list of constraints in the revised planning practice guidance (including green belt, AONB, flood risk, green space and heritage) can be overcome. We are now undertaking a rigorous reassessment of the potential adverse impacts on each site to assess where these impacts will ‘significantly and demonstrably’ outweigh the benefits of meeting housing need, using the existing evidence base and comprehensive constraints, in the wake of a highly charged public consultation.
“One of our greatest challenges in preparing our draft Local Plan has been to accommodate the accrued backlog of housing since the start of our plan period in the first five years of the plan, as directed by planning practice guidance. However, we are aware that some inspectors are taking a different approach based on local circumstances, such as at Gravesham Borough Council, where the backlog was apportioned over the whole plan period.
“If we could justify such a consistent approach in Guildford borough, this would enable us to phase our development sites more appropriately, including brownfield sites that have a longer lead in time, and thereby potentially minimising the reliance on green belt sites. This also allows time to address the current deficits in infrastructure and plan properly for any potential future development. Reducing the scale of the immediate five year housing land supply requirement could also potentially minimise the risk of ‘planning by appeal’ rather than through the democratic process.
“We have something of a perfect storm – Guildford is a vibrant retail and business centre with full occupancy and very few vacant sites. At the same time, the housing need has grown substantially. The government is also placing greater emphasis on the need for our Local Plan to align with the growth agenda set out by our Local Enterprise Partnership, Enterprise M3. It is simply not possible to meet the full backlog arising from the increased housing number in the first five years – other than by releasing green belt land, which could irrevocably damage Guildford’s character.
“Therefore we are asking the Secretary of State to make representations jointly to ministers to permit Guildford’s housing shortfall to be met over the full period of the plan. If we can frame a delivery trajectory over the full plan period we can produce a better plan with less impact on the urban and town environments, and on the green belt.
“We believe that our local circumstances are both unique and exceptional, and we urge the Secretary of State to consider making the strongest representations on our behalf, and that of all our residents in the borough of Guildford, so that our future Local Plan is seen by all as being entirely constructive.”