Housing
Policy H4: Housing Density
Preferred option to housing densityThe aim of this policy is to enable appropriate residential densities in high quality design-led schemes by having a policy that requires:1) Maximising the optimal use of land by building homes at the most appropriate density taking into account: a) the site size, characteristics and location, b) the urban grain of the area and appropriate building forms and sizes for the site, and c) the context and local character of the area. 2) Higher density development in the Town Centre, strategic sites or within 500 metres of existing or planned transport interchanges, unless there are strong reasons why it would be inappropriate. Justification for the choice of options and selection of preferred optionReasons the options were selectedA number of options have been considered to enable a comparison between them in terms of their ability to meet legislative requirements, Relevant Objectives from LPSS and the highlighted planning issues specific to Guildford borough.Reasons for selecting the preferred option in light of the other optionsSome of the alternative options are less specific to Guildford borough as they rely on generic guidance within the NPPF or PPG, or on the broader strategic Local Plan policies. The NPPF and PPG set out a range of considerations and tools that can assist in establishing appropriate densities on a site or in a particular area, such as accessibility, characterisation and design studies, environmental and infrastructure assessments and site viability. This is considered preferable to setting minimum density ranges for specific locations (the Town Centre, strategic sites or within 500 metres of existing or planned transport interchanges). To set out minimum density ranges is considered to be restrictive and complicated to ascertain and will limit the flexibility that is often needed when determining a planning application. The Council’s preferred option requires the optimal use of land by building homes at the most appropriate density. It is considered the most appropriate approach for Guildford. To apply prescriptive density ranges would restrict the flexibility to take all the site constraints and considerations into account. Sites within Guildford can often have their own challenges, such as the topography of the site, being partially within the flood plain or the impact on views which are crucial to the character and setting of the town centre. Flexibility is needed to ensure the right development can take place. Whilst seeking the optimum use of the land there also needs to be flexibility to ensure that a well-balanced range of housing can come forward to meet Guildford’s housing needs. When considering the relevant issues and options for housing density in Guildford, the Council’s preferred approach is to enable well-designed housing at an appropriate density. There will be a presumption for higher density development in the Town Centre. In the Town Centre there are more limited opportunities for development, yet it is a sustainable location so housing density needs to be optimised. There will also be a presumption for higher density development on strategic sites and within 500 metres of existing or planned transport interchanges. This is because the size of strategic sites will enable thoughtfully designed higher densities, and being in close proximity to transport interchanges enables opportunities to optimise densities on sustainable sites. The results of the assessment suggest that the preferred option provides a greater amount of guidance and flexibility specific to Guildford borough to help meet the relevant Local Plan objectives. |
Question 1: Do you agree with the preferred option to address housing density in Guildford?
Do you have any other comments or suggestions?
Response: Normandy Action Group disagree
While this wording is based on the National Planning Policy Framework (NPPF) – which is binding - this policy fails to recognise that development in rural areas, with inadequate transport and other infrastructure, cannot cope with the proposed scale of development. It is unsustainable. This should represent an absolute constraint on development.
Comments & Suggestions
The proposed approach to density lacks any ability to ensure that the density of a proposed development is appropriate given the environmental, landscape, character and sustainability constraints and/or opportunities of individual sites. This has resulted in high density housing being built in ‘edge of village’ settings in relatively low sustainability. In Flexford this has contributed to the development of affordable housing to address the Borough general need in Beech Lane, capping over land that had previously acted as a proxy SuDS resulting in flooding of properties not previously inundated and only resolved via the local Flood Forum after resistance to the necessary investment from GBC.
NAG supports the requirement to ensure that the development capacity of sites should avoid the necessary further release of Green Belt land. However, this must not be at the expense of the amenity of local residents (see above) and the character of the surrounding area.
The second part of the preferred option for housing density states that the policy will require:
Higher Density development in the Town Centre, strategic sites or within 500 metres of existing or planned transport interchanges, unless there are strong reasons why it would be inappropriate.
The listed transport interchanges include the existing outlying stations of Ash, Ash Vale, North Camp and Horsley, in addition to the proposed stations at Guildford East (Merrow) and Guildford West (Park Barn).
NAG does not consider that a distance of 500 metres from such transport interchanges would be suitable for high density development. For smaller settlements like Normandy and Flexford a distance of 500m would be outside the settlement boundary and totally inappropriate for high density housing and in many instances this buffer would include areas of low density housing and in many circumstances this would include large areas of existing unallocated Green Belt land.
The wording of the policy regarding the proximity to transport interchanges should be reviewed to ensure that the policy is appropriate for the individual circumstances of existing settlements.
In addition to transport interchanges, many of the new large sites in the Local Plan are areas of former Green Belt land with significant constraints, not least that of landscape or character impact.






