Core Strategy Consultation April 2009
Below are WBDRA comments on this latest GBC Consultation.
We don't think it will have attracted much of a response as (a) it is an immensely lengthy document of over 130 pages and (b) most of the key terms are not defined and (c) the demographic numbers on which it seems to be based are 6 years old and do not obviously allow for serious changes inflicted by the 2008/9 Recession.
These are a personalised set of comments by some WBDRA Committee members - regular readers and other WBDRA members may not endorse or support some of the views expressed.
Items & Policies not commented on are issues beyond the WBDRA remit.
Dear Core Strategy Team
We have reviewed and considered this document and have provided comments below on matters which fall within the WBDRA remit.
Our comments on the document generally are:
(1) it is not an easy document to read & understand
(2) the online reporting method is far too complex and enormously time consuming
(3) too many terms are undefined (eg Affordable Home, Town Centre etc)
(4) there are serious flaws in the data on which certain key assumptions are based
Specifically our comments on the points of interest to WBDRA are as follows:
Profile & Key Issues 2.2
- Makes assumptions about the growth of the number of people working in the Borough. The predicted figure of 85,100 in 2010 cannot be correct when considered in 2009 as it was based on assumptions published in the 2003 Local Plan. It makes no allowance for the Recession which started late 2008 and will be ongoing well into 2009. If anything, the number of economically active people will have dropped dramatically by the end of 2009. The Office of National Statistics gives a figure of 78,000 in 2008 whereas the Annual Population Survey gives 68,900 for 2008. The figures on which Housing & Infrastructure requirements are based need revisiting and reassessing with some urgency.
- Why is the affordability of private homes close to places of work suddenly a concern? Guildford is essentially a London commuter town and anyone who can cycle or walk to work is lucky indeed. For millions of others in the Home Counties, there is no option but to head into London.
Profile & Key Issues 2.4
- Makes a statement about lack of affordable housing contributing to Skills Shortages. Before plans are initiated to concrete over the Borough, what are exactly are these Skills Shortages? Numbers & types of occupations? And how will the current Recession affect any such statistics?
Profile & Key Issues 2.9
- Makes a statement about high levels of housing need. On what evidence is this based and what type of housing does it refer to?
Vision for Guildford Borough to 2026
- Makes a statement about Housing which will "include more affordable homes". Has anyone ever thought to define what an affordable home actually is in monetary terms? A house costing £375,000 is affordable by many peoples’ standards in Guildford, even more so at the £275,000 level.
Area Visions 5.0
- Makes a statement about the town centre being described in the Draft SE Plan as a "Centre for Significant change". What exactly is meant by the Town Centre? Does this mean the area in an ellipse around the High St & North St (in which case why Redevelopment?) or does it mean the Urban Area which includes all the immediate suburbs or does it include the whole borough which includes Worplesdon, Stoughton, Merrow, East Horsley for example? The statement is not defined and is too vague on which to comment constructively or on which to base any hard plans.
- Makes a statement about “Guildford town” - what exactly is meant by this? Again lack of a proper definition effectively removes the opportunity for sensible comment. What exactly is the “growth of infrastructure” referred to – piped services? lighting? roads? parking?
- Refers to Housing Needs and again to undefined "affordable housing". Has Guildford Borough ever thought to question its management of the Social Housing Stock it already has? For example, there are numerous instances of elderly folk living on their own in 3-bed family Council Houses where once there was a family? Should we not be encouraging them to downsize? Have we ever thought of means-testing the 3 & sometimes 4 income families who live in this so-called "Social Housing"? All this housing could be available to key workers by proper management & more rigorous monitoring.
- Talks about robust flood risk reduction. Where is the evidence of any activity geared towards that objective? Every time we have a downpour many of the main thoroughfares are flooded simply because the sewerage/drainage system cannot cope. There are residential areas around the Borough where gardens are permanently wet – irrespective of weather conditions. Moreover, by allowing garden grabbing house building and extensions, the natural rainwater run-off is seriously impaired and the rain water just runs into someone else’s property. Guildford is on a flood plain and the present drainage infrastructure is woefully inadequate. Without some immediate measures to start improving it, all additional House building is going to cause tremendous problems for rainwater run-off for much of the Borough.
Strategic Objectives – PC3
- Item PC3 talks of protecting environmental assets and green spaces to benefit quality of lives and biodiversity. And yet the Council has presided over one the worst periods of Garden Grabbing Housing Development and loss of Open Space to Housing we have known for years. Despite consultations about Site Allocations, valuable amenity spaces such as the Aldershot Road Allotment Site (aka Westborough Allotments Site) - one of the areas much valued and prized Open Spaces - remains under threat of Housing Development, despite massive local public support for keeping the whole site as Allotments.
Strategic Objectives - PC6
- This talks about ensuring provision of social, cultural and recreational facilities, this seems completely at odds with the present reality in Worplesdon & Westborough.
Strategic Objectives – EPE2
- Item EPE2 refers to making the best use of previously developed or under-used land. Where does that place the Aldershot Road Allotment Site? It is one of the most over-subscribed sites in the Borough, fully let with a waiting list of over 60 individuals. Once the whole site was Allotments so why not listen to what local people asked for in the Site Allocations Consultation and return the site to the 110-plot site which it always used to be. The waiting list situation for Allotment Sites is growing weekly according to Guildford Allotment Society - other boroughs in the UK have responded positively and quickly to such demands, GBC could easily do the same and without jeopardising any genuinely “affordable” housing plans.
- Policy CP1 - WBDRA fully endorses the view that previously developed land must be used prior to considering developing greenfield or undeveloped land such as commons and Allotment Sites.
- Policy CP2 talks about house building @ 422 houses per annum as per the South East Plan. Hang on a minute, didn't GBC tell us they were firmly opposed to this plan so why are we now proposing to go along with it?
- Policy CP5 refers to Infrastructure. It is needed NOW not after we've all caved in to the political nightmare of the South East Plan. The statement about "local infrastructure required to support the anticipated level of housing" is a nonsense. It hasn't happened yet with some very substantial developments in the Borough -so why should we suppose it will happen in the future? Roads are in appalling condition, traffic jams & congestion are routine daily problems and we have already mentioned the extreme inadequacy of the Piped Drainage Services.
- Policy CP9 mentions "inclusiveness" and opportunities for people to be involved in consultation - there is little point to such activity if nothing is going to happen as a result of those consultations and the Council just stalls or does what it wanted to do in the first place.
- Policy CP10 talks about homes for all. If the Borough Housing Department managed the local Social Housing stock with a bit more alacrity and business-like attention, many more temporary homes would suddenly appear for key workers and genuine people in need of social housing.
- Policy CP11 refers to Housing Density and Character. Sadly all too often in the past Planning Applications for Housing pass through without any public or committee scrutiny. If the Planning Officers were effective in their jobs, they would appreciate the actuality of Housing Density and local character of the applications they are charged with managing. How very few of them actually seem to know the areas involved. They should put aside the grandiose sales hype of developers narratives in Planning Applications and actually get out and see the impact such applications would have and talk to the neighbouring occupants. If there really is a will in the Council to apply principle of Optimised Density and character, more than 50% of recent Planning Applications which went out for local consultation would have been rejected at the application stage.
- Policy CP12 deals exclusively with Affordable Homes. Sadly no definition of an Affordable Home is supplied so does anyone actually know what an affordable home actually is? What does it or should it cost? The Policy mentions a mix of 60% social rented and 40% of other forms. This type of social engineering is simply untenable and the Queen Elizabeth park development is a prime example of mixed development failure. The whole business of Affordable Housing is really an absolute ill-defined muddle. Our Residents’ Association has vigorously opposed many Housing Conversion & Extension applications which on the face of it seem affordable or at least lower than average cost but in the end, the Planning Committee plays party politics and it all goes to Student Lets. The developers/landlords pay no Council Tax and just cause abject misery and stress in the neighbourhoods which were once quiet family house roads – roads where houses are now poorly maintained student accommodation awash with cars, noise and thoroughly unpleasant places to live. As long as Guildford is a University Town and the Council Planners fail to see developments for what they really are, there will always be a shortage of decent family housing and lower-cost housing too. The University has numerous empty spaces in its Halls of Residences - why are students discouraged by the high rents required by the University to live there and thereby encouraged to take up residence in the Borough’s much-needed lower cost Housing Stock?
Westborough, Broadacres & District Residents Association
tel: 0799 994 4601 (daytime only) 0781 219 3101 (evgs)
Page Last Updated - 18/04/2009