There are 27 core policies, then a further 57 policies defining actual sites.

If you intend to respond. remember to comment on the Policy statement in the blue box. If there a words that you think should be added, removed or changed in the Policy statement box, say what you would like and why.

If you responded to the previous consultation, that is immaterial, please respond again.

As the last round of consultation, YOU DO NOT NEED TO FILL IN AN ON_LINE QUESTIONNAIRE; PAPER QUESTIONNAIRES ARE AVAILABLE. IF YOU WISH, YOU CAN WRITE A LETTER BUT BE SPECIFIC AS TO WHAT POLICY YOU ARE REFERRING AND TO WHAT QUESTION IN THE QUESTIONNAIRE YOUR COMMENT RELATES. IF YOU ARE WRITING TO OBJECT TO SPECIFIC POLICIES OR SITES, PLEASE MAKE SURE YOU START EACH WITH "I OBJECT" AND THEN STATE YOUR REASONS OTHERWISE YOUR RESPONSE WILL BE COUNTED AS NEITHER FOR NOR AGAINST AND IN SOME CASES WILL BE POSITIVELY REGARDED AS IN FAVOUR.

To view each policy and the NAG interpretation of these policies please click on the chosen item from the menu list to the right. 

Strategic

Policy S1: Presumption in favour of sustainable development
Policy S2: Planning for the borough - our spatial development strategy

Housing

Policy H1: Homes for all
Policy H2: Affordable Homes
Policy H3: Rural Exception Homes

Protecting

Policy P1: Surrey Hills Area of Outstanding Natural Beauty (AONB)
Policy P2: Green Belt
Policy P3: Countryside
Policy P4: Flood Risk
Policy P5: Thames Basin Heaths Special Protection Area

Economy

Policy E1: Meeting employment needs
Policy E2: Locations of new employment floorspace
Policy E3: Maintaining employment capacity and improving employment floorspace
Policy E4: Surrey Research Park
Policy E5: Rural Economy
Policy E6: The leisure and visitor experience
Policy E7: Guildford Town Centre
Policy E8: District and Local Centres
Policy E9: Local Centres

Design

Policy D1: Making better places
Policy D2: Sustainable design, construction and energy
Policy D3: Historic environment
Policy D4: Development in urban areas and inset villages

Infrastructure & Delivery

Policy I1: Infrastructure and delivery
Policy I2: Supporting the Department for Transport’s “Road Investment Strategy”
Policy I3: Sustainable transport for new developments
Policy I4: Green and blue infrastructure


 

Strategic

Policy S1: Presumption in favour of sustainable development

When considering development proposals we will take a positive approach that reflects the presumption in favour of sustainable development contained in the National Planning Policy Framework. We will work proactively with applicants jointly to find solutions that mean that proposals can be approved wherever possible, and to secure development that improves the economic, social and environmental conditions in the area.
Planning applications that accord with the policies in this Local Plan (and, where relevant, with policies in adopted neighbourhood plans) will be approved without delay, unless material considerations indicate otherwise.
Where there are no policies relevant to the application or relevant policies are out of date at
the time of making the decision, then the Council will grant permission unless material considerations indicate otherwise, taking into account whether:
  • Any adverse impacts of granting permission would significantly and demonstrably outweigh the benefits, when assessed against the policies in the National Planning Policy Framework taken as a whole; or
  • Specific policies in that Framework indicate that development should be restricted.

Response: Object

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.


Policy S2: Planning for the borough – our spatial development strategy

During the plan period (2013-33), we will make provision for 13,860 new homes, 37,200 – 47,200 sq m of office and research and development (B1a and b) floorspace and 4.7 – 5.3 hectares of industrial (B1c, B2 and B8) employment land to help meet the needs for new homes, support the economy and supply 3,200 additional B class jobs.

The delivery of homes is expected to increase over the plan period, reflective of timescales associated with the delivery of strategic sites and infrastructure. The housing target each year is as set out below, however, this is not a ceiling, and earlier delivery of allocated sites will be supported where appropriate, subject to infrastructure provision.

We will identify 43 permanent pitches for Gypsies and Travellers and 6 permanent plots for Travelling Show people within Guildford borough between 2012 and 2017. Between 2017 and 2027 an additional 30 pitches and 2 plots will be permitted or any new target as identified within an updated Traveller Accommodation Assessment.

Annual Housing Target

Year Housing
Number
Year Housing
Number
2018/2019 500 2026/2027 700
2019/2020 550 2027/2028 700
2020/2021 600 2028/2029 785
2021/2022 600 2029/2030 790
2022/2023 700 2030/2031 790
2023/2024 700 2031/2032 790
2024/2025 700 2032/2033 790
2025/2026 700    

Response: Object

13,860 homes are proposed. This number has not been scrutinised by councillors despite repeated requests for debate. The assumptions and calculations underlying the model are hidden. It is not reasonable to produce unsubstantiated numbers in order to justify major structural change in a widely protected area (89% Green Belt, 44% AONB, approx. 75% protected by SPA). It is inappropriate to allocate this housing number, either over the plan period OR across projected sites, when the number itself is unsubstantiated. External consultants and members of the public have provided detailed criticisms of the model. IF the housing number were substantially lower, and only met housing need, there would be no need to build on Green Belt or open countryside. The number of homes proposed, plus existing planning permission, plus expected “windfall” sites, exceeds 13,860. Guildford residents would not accept building homes on open countryside to meet Woking’s designated “need” but this seems to be implied.


Housing

Policy H1: Homes for all

Housing Mix 

New residential development is required to deliver a wide choice of homes to meet a range of accommodation needs as set out in the latest Strategic Housing Market Assessment. New development should provide a mix of housing tenures, types and sizes appropriate to the site size, characteristics and location.

Development that results in the net loss of housing or specialist housing, including sites allocated for housing within the Local Plan will not be permitted.

Density 

New residential development is required to make the most efficient use of land whilst responding to local character, context and distinctiveness. Residential densities will vary dependent upon the local area context and character and the sustainability of the location. Higher density development will be supported in Guildford town centre.

Specialist housing 

We will support the provision of well designed specialist forms of accommodation in appropriate sustainable locations, taking into account local housing needs.

Students

We expect 60 per cent of the University of Surrey eligible student population (full time equivalent) to be provided with student bedspaces and accommodation on campus.

Travellers

We will identify sufficient sites for Travellers’ accommodation needs as set out in the latest Traveller Accommodation Assessment. These sites will be for a mix of tenures and provided on a number of small sites and as part of larger development sites to help create sustainable and mixed communities. New sites must have adequate utility services and amenity space, space for related business activities where appropriate, safe vehicular access, turning space and parking and be in areas with reasonable access to schools, health services and local services.

Sites should not significantly impact on the visual amenity and local character of the area or adversely affect an environmentally sensitive location.

Traveller accommodation should be provided on development sites of 500 homes or more whilst there remains an identified need. For 500 to 999 homes two pitches or plots should be provided, for 1,000 to 1,499 homes four pitches or plots, for 1,500 to 1,999 homes six pitches or plots and for 2,000 or more homes eight pitches or plots..

Houses in multiple occupation 

Proposals for houses in multiple occupation that require planning permission will be supported only where the balance of housing types and character of the immediate locality would not be adversely affected and there is sufficient amenity space available.

Response: Object

The housing mix is based on the assumptions set out in the Strategic Housing Market Assessment (SHMA) which has not been scrutinised or evaluated and so we must object overall. We support high density development in the urban area. Student accommodation should provided for 100% of new students and more than 60% of existing students, which would free up suitable family accommodation in the urban area. Guildford borough has already a higher proportion of traveller sites than most comparable boroughs and this should be taken into account when evaluating need for travellers.


Policy H2: Affordable homes

As well as providing and managing affordable homes ourselves, the Council will work with registered providers, developers and landowners to increase the number of affordable homes in the borough toward meeting identified needs.
These affordable homes will be provided:
  • on sites providing five or more homes, or sites of 0.17 ha or more regardless of the number of homes. At least 40 per cent of the homes on these sites must be affordable homes; and
  • on developments providing solely affordable housing either on public sector-owned land or developments by registered providers.

The tenure and size of affordable homes provided on each qualifying site must contribute, to the Council’s satisfaction, towards meeting the mix of affordable housing needs identified in the Strategic Housing Market Assessment 2015, or subsequent affordable housing needs evidence. This currently includes a tenure split of at least 70% rented, with the remainder being other forms of affordable housing. Affordable rent must be no more than the maximum level set out in our most recent housing guidance or strategy. Developers will be expected to provide land for affordable homes at nil value.

We will not grant planning permission for development that would result in the net loss of any affordable homes that have been built, that were secured by planning obligation or condition.

Response: Object

“Affordable” homes, under national definitions, means homes which are sold or rented at 80% of market value. Even at 70% rented this means that these homes will not be cheap, and starter homes will not be made available for local people. There is a viability clause (4.2.40) which means that in practice this could be unenforceable. We would be losing countryside for no local benefit.


Policy H3: Rural exception homes

Small affordable housing developments, including pitches for travellers will be permitted to meet identified local housing needs provided that:
  • the site adjoins or is closely related to, and in safe and easy walking distance of a defined or a non-defined rural settlement, and
  • the number, size and tenure of homes would be appropriate to meet, or to contribute to meeting, the identified local affordable housing needs, and the homes are all secured as affordable homes in perpetuity.

 Response: Object

This is a Trojan horse policy. It says that homes can be built anywhere near a settlement of any form (this includes agricultural land and the AONB). These homes could be homes for people with a village connection, but they could be for anyone on the Guildford borough housing list. To make the housing viable, or to improve the “mix” this can include “market” housing (i.e. normal commercial development). This policy means building anywhere, and ignoring all historic planning restrictions.


Protection

Policy P1: The Surrey Hills Area of Outstanding Natural Beauty (AONB )


The Surrey Hills Area of Outstanding Natural Beauty (AONB) will be conserved and enhanced to maximise its special landscape qualities and protect it from inappropriate development. All proposals will be considered against whether they:
  • conserve and/or enhance the setting and views of the AONB
  • conserve wildlife, historic objects or natural phenomena within it
  • promote its enjoyment by the community and visitors to the area
  • support the rural economy of the Surrey Hills area
  • provide or maintain public access to the AONB

Development proposals will also be assessed against the provisions of the current Surrey Hills AONB Management Plan.

Whilst the AONB designation does not preclude specific types of development in the Surrey Hills and proposals will be assessed on their individual merits, there will be a presumption against major development in the AONB in accordance with the NPPF. Exceptions may only be made for proposals that meet both criteria specified in paragraph 116 of the NPPF.

The AGLV will be retained until such time as there has been a review of the AONB boundary. Proposals within the AGLV will be required to demonstrate that they would not result in harm to the AONB or the distinctive character of the AGLV itself.

Response: Object 

This policy is much weaker than previous protection. It is dependent on the Surrey Hills Management Plan. Note that this welcomes housing development. The Surrey Hills needs much more substantial protection. Even major (undefined) development in the AONB would be permitted if exceptional (undefined) circumstances could be demonstrated.


Policy P2: Green Belt

We will continue to protect the Metropolitan Green Belt, as shown on the proposals map, against inappropriate development. In accordance with national planning policy, the construction of new development will be considered inappropriate and will not be permitted unless very special circumstances can be demonstrated.
Certain forms of development are not considered to be inappropriate. Proposals will be permitted where they are consistent with the exceptions listed in national planning policy and, where relevant, also meet the following criteria:

Extensions or alterations

The extension or alteration of a building provided that it would not result in disproportionate additions over and above the size of the original building.

Replacement buildings

The replacement of a building, provided the new building:

  • would be in the same use, and
  • is not materially larger than the one it replaces, and
  • is sited on or close to the position of the existing building.
Limited infilling

Limited infilling within the identified settlement boundaries of the following villages:
Albury, Compton, East Clandon, East Horsley (south), Gomshall, Holmbury St Mary, Peaslake, Pirbright, Puttenham, Shere, West Clandon and Worplesdon.

Limited infilling may also be appropriate outside the inset or identified settlement boundaries, and in the following villages, where it can be demonstrated that the site is as a matter of fact on the ground within the village:
Artington, Eashing, Farley Green, Fox Corner, Hurtmore, Ockham, Seale, Shackleford, The Sands, Wanborough and Wisley.

Response: Object 

This policy is much weaker than previous protection. It is dependent on the Surrey Hills Management Plan. Note that this welcomes housing development. The Surrey Hills needs much more substantial protection. Even major (undefined) development in the AONB would be permitted if exceptional (undefined) circumstances could be demonstrated.


Policy P3: Countryside

Within the area of countryside, as shown on the Policies Map, development will only be permitted provided it:
  • requires a countryside location or where a rural location can be justified, and
  • is proportionate to the nature and scale of the site, its setting and countryside location, and
  • does not lead to greater physical or visual coalescence between the Ash and Tongham urban area and Aldershot.

Response: Object 

This seems more protective – as a policy – than the proposals for the AONB and the Green Belt which is anomalous. Note - we are not in favour of building on this area. We think that the brownfield areas within the urban area are sufficient to meet all reasonable housing targets. There should be no need to build on any green fields if brownfield (previously developed) land is used efficiently. (That does not mean garden-grabbing!). However, we do not think this area justifies stronger policy protection than any other part of the borough. This policy refers to the area of countryside near Ash and Tongham (see paragraph 4.3.28). The fact that the current and previous Council Leaders represent this area should not give It preferential status: “we will seek to limit any development in the countryside unless it can be demonstrated that it is necessary in that location”. Green Belt and AONB areas should – by definition - have higher levels of protection than non-Green Belt areas, which is not the case with this policy.


Policy P4: Flood Risk

Flood zones in Guildford borough are defined based on definitions contained within national planning practice guidance and the Council’s Strategic Flood Risk Assessment (Level 1) .

Development in areas at risk of flooding as identified on the latest Environment Agency flood risk maps and the Council’s Strategic Flood Risk Assessment, including the ‘developed’ flood zone 3b (functional floodplain), will be permitted provided that:

  1. the vulnerability of the proposed use is appropriate for the level of flood risk on the site;
  2. the proposal passes the sequential and exception test (where required) as outlined in the NPPF and Government guidance;
  3. a site–specific flood risk assessment demonstrates that the development will be safe, including the access and egress, without increasing flooding elsewhere, and where possible, will reduce flood risk overall;
  4. the scheme incorporates flood protection, flood resilience and resistance measures appropriate to the character and biodiversity of the area and the specific requirements of the site;
  5. when relevant, appropriate flood warning and evacuation plans are in place and approved; and
  6. site drainage systems are appropriately designed taking account of storm events.

Development proposals in the ‘developed’ flood zone 3b will also only be approved where the footprint of the proposed building(s) is not greater than that of the existing building(s). Proposals within these areas should facilitate greater floodwater storage.

With the exception of the provision of essential infrastructure, ‘undeveloped’ flood zone 3b will be safeguarded for flood management purposes.

All development proposals will be required to demonstrate that they will not result in an increase in surface water run-off and should have regard to appropriate mitigation measures identified in the Guildford Surface Water Management Plan or Ash Surface Water Study. Priority will be given to incorporating SuDs (Sustainable Drainage Systems) to manage surface water drainage, unless it can be demonstrated that they are not appropriate. Where SuDs are provided, arrangements must be put in place for their management and maintenance over their full lifetime.

Development within Groundwater Source Protection Zones will only be permitted provided that it has no adverse impact on the quality of the groundwater source and it does not put at risk the ability to maintain a public water supply.

Response: Object 

There are aspects of this policy which are acceptable; it is sensible to protect groundwater source protection zones, provided that the maps are accurate. However, urban development on hardstanding does not create increased flood risk, especially where there is the capacity for improved flood resistance measures to be included in the design. Sites such as the Arriva bus depot, on the River Wey bank, are potential high value brownfield land which may not be used for housing because of this policy. The footprint of existing buildings should not be the limit of future development, but the extent of existing hard standing. Tarmac and concrete do not act as functional floodplain, but some land with hard standing close to the river, within the town centre and within easy walking distance of the train station, provides an exciting opportunity for real urban regeneration which could protect the surrounding countryside.


Policy P5: Thames Basin Heaths Special Protection Area

Permission will not be granted for development proposals unless it can be demonstrated that doing so would not give rise to adverse effects on the ecological integrity of the Thames Basin Heaths
Special Protection Area (SPA), whether alone or in combination with other development. Where one or more adverse effects on the SPA are likely, measures to avoid and mitigate these effects must be delivered and secured in perpetuity. These measures must be agreed with Natural England.

The following principles apply:
  • There is an “exclusion zone” set at 400m linear distance from the SPA boundary. Permission will not be granted for development that results in a net increase in residential units within this zone. Proposals for other types of development within this zone must undertake Appropriate Assessment to demonstrate that they will not harm the integrity of the SPA.
  • There is a “zone of influence” between 400m and 5km linear distance from the SPA boundary. Where net new residential development is proposed within the zone of influence, mitigation measures must be delivered prior to occupation of new dwellings and in perpetuity. Measures must be based on a combination of Strategic Access Management and Monitoring (SAMM) and the provision, improvement and/or maintenance of Suitable Alternative Natural Greenspace (SANG).
  • Residential development of at least 50 net new dwellings that falls between five and seven kilometres from the SPA may be required to provide mitigation measures. This will be assessed on a case-by-case basis and agreed with Natural England.

SANGs

The following principles apply to the provision of SANG.

  • A minimum of 8 hectares of SANG land (after discounting to account for current access and capacity) should be provided per 1,000 new occupants.
  • Developments must fall within the catchment of the SANG that provides mitigation, except developments of fewer than 10 net new residential units.
  • The Council will collect developer contributions towards mitigation measures, including SANG (unless bespoke SANG mitigation is provided) and SAMM.
  • Developments may secure or provide bespoke SANG. Proposals for new SANGs will not be acceptable unless approved by Natural England. Large developments may be required to provide bespoke SANG mitigation.

Where further evidence demonstrates that the integrity of the SPA can be protected using different linear thresholds or with alternative mitigation measures (including standards of SANG provision different to those set out in this policy) these must be agreed with Natural England.

Response: Object 

This policy is weak. The mitigation (cash compensation) offered for development in the special protection area is so small and negligible as to be meaningless. SANG (Suitable Alternative Natural Greenspace) is not beneficial; the sites identified or targeted are already green space. To create SANG is just using agricultural or wooded land as recreation land in order to justify building on other green spaces. There is no actual increase in environmental protection; it is a policy designed to permit building on otherwise protected areas. SANG – in part used to prevent dogs and cats attacking nesting birds - must ensure that it is not using land which is adjacent to the special protection areas.


Economy

Policy E1: Meeting employment needs

The provision of 3,200 additional B class (see glossary) jobs to 2033 will be supported. In order to deliver these, land will be allocated for a net gain of between 37,000 and 47,000 sq m of floorspace for B1a and B1b uses and between 4.7 and 5.3ha land for B1c, B2 and B8 use class floor space to ensure an adequate supply of land is available for employment purposes. This will provide a range and choice of employment floor space over the plan period and accommodate the predicted future growth in economic development required for Guildford’s economy to develop and increase.

  Lower range

Upper range

Office and Research & Development floorspace (B1a and B1b) 37,200 sq m 47,200 sq m
Industrial land (B1c, B2 and B8) 4.7 ha 5.3 ha

The Plan aims to ensure sustainable employment development patterns, promote smart growth (see glossary) and business competitiveness, and allow for flexibility to cater for the changing
needs of the economy.
We will:

  • support the retention, creation and development of small local business by encouraging a range of types and sizes of new premises including incubator units, managed workspace and serviced office accommodation
  • support the provision of essential ancillary employment facilities close to places of employment
  • support rural economic development opportunities,
  • support proposals which come forward to redevelop outmoded employment floor space and cater for modern business needs.

B Class Uses
Strategic Employment Sites

The seventeen designated sites that together make up the borough’s current core supply of employment land will be protected as Strategic Employment Sites and changes of use from employment to non-employment uses resisted. The retention, intensification and employment based regeneration of these sites is encouraged. The Strategic Employment Sites are:

Office (B1a) and Research & Development (B1b) Strategic Employment Sites

  • Guildford Town Centre employment core
  • Surrey Research Park (extended)
  • Guildford Business Park
  • London Square, Cross Lane
  • 57 and Liongate Ladymead
  • The Pirbright Institute.

When developed, the new employment site at Gosden Hill Farm will be treated as a Strategic Employment Site.

Industrial (B1c, B2 and B8) Strategic Employment Sites

  • Slyfield Industrial Estate
  • North and south of Lysons Avenue, Ash Vale
  • Riverway, Astolat, Weyvern at Peasmarsh
  • Cathedral Hill Industrial Estate
  • Guildford Industrial Estate, Deacon Field
  • Woodbridge Meadows
  • Midleton Road Industrial Estate
  • Merrow Lane (incl Perram Works, Bridge Park, Merrow Business Centre, SCC depot)
  • The Guildway, Portsmouth Road
  • Quadrum Park, Peasmarsh
  • Woodbridge Park, Woodbridge Road
  • Henley Business Park, Normandy

When developed, the new employment site at Garlick’s Arch, Send Marsh/Burnt Common, will be treated as a Strategic Employment Site.

Locally Significant Employment Sites

The Locally Significant Employment Sites will be protected and within these sites changes of use to non-employment uses resisted. The retention and regeneration of these sites is encouraged and intensification where possible will be considered to be appropriate.

The Locally Significant Employment Sites include all sites which meet the definitions set out below and include:

  • 31 Chertsey Street and 1-7 Stoke Road, Guildford
  • Andrew House, College Road, College House (89 and 91), Stoke House, Leapale House and Bell Court, Guildford
  • 65 Woodbridge Road, Guildford
  • The Pines Trading Estate, Broad Street
  • Send Business Centre, Tannery House, Tannery Lane, Send
  • Grange Court, Tongham
  • The Courtyard, Wisley

The Strategic Employment Sites and the Locally Significant Employment Sites are shown on the borough Policies Map.

Response: Object 

We object because

  • the evidence base is unreliable
  • there is unclear differentiation between B class uses
  • only high added-value business uses are desirable, not low grade, low employment warehousing which is land hungry
  • industrial and commercial businesses must be concentrated in the urban area, or existing business parks (eg Slyfield) not in the rural environment which the infrastructure is unable to support
  • the rural environment must support micro or high tech businesses, agricultural industries, and tourism, and these sectors must not be damaged by general industrial development which is inappropriate

 Policy E2: Locations of new employment floorspace

Proposals for new office and research and development (use Class B1a and B1b) floorspace will be directed first to Guildford town centre, then sequentially to:

  • locations within 500m of a public transport interchange,
  • Office and Research & Development Strategic Employment Sites unless the proposed floorspace is limited in scale (less than 200 sq m or 25% of the existing office/R&D floorspace whichever is the lower) and/or ancillary to the primary use of the site OR the proposed floorspace meets the criteria set out in policy E4 and is appropriate to be located on Surrey Research Park.

Where net additional floorspace exceeding 200 sq m or 25% of the existing office/R&D floorspace is proposed (whichever is the lower) in the redevelopment or extension of a building in locations other than those set out above, it will need to be demonstrated that there are:

  • no sites available in the locations set out above
  • there is a demonstrated need, and
  • the site is or will be made accessible by sustainable modes of transport.

The expansion of existing offices in locations outside town centres and Strategic Employment Sites should be limited and any development not limited in scale is to be directed to sequentially preferable locations.

Industrial, warehousing and storage:
Proposals for new industrial, warehousing and storage (use Class B1c, B2 and B8) floorspace will be directed to the Industrial Strategic Employment Sites.

All B class development:
Proposals for the development of new B class uses will be encouraged and provision for small business units (less than 50sq m), suitable for start-ups and SME will be encouraged.

Proposals, particularly those of over 5,000 sq m, will be encouraged to provide childcare facilities on or close to the site.

Response: Object 

We are of the opinion that all new office and research and development (use Class B1a and B1b) floor space should be within Guildford town centre. We do not support the policy of expanding the Research Park onto Blackwell Farm and we do not believe there are exceptional circumstances to justify incursion into this permanent and high quality area of Green Belt


 Policy E3: Maintaining employment capacity and improving employment floorspace

In order to sustain and enhance employment capacity (including land, floorspace and/or jobs):

  • employment floorspace will be protected and the loss strongly resisted on the Strategic Employment Sites, which are defined in policy E1. Change of use will only be acceptable if evidence is provided of active and comprehensive marketing of the site for its current use (offices, research and development or industrial) for a continuous period of at least two years
  • employment floorspace will be protected and the loss resisted on the Locally Significant Employment Sites, which are defined in policy E1. Change of use will only be acceptable if evidence is provided of active and comprehensive marketing of the site for its current use (offices, research and development or industrial) for a continuous period of at least 18 months
  • employment floorspace will be protected in line with latest needs assessment and the loss be resisted outside designated employment sites. Change of use will only be acceptable if evidence is provided of active and comprehensive marketing of the site for its current use (offices, research and development or industrial) for a continuous period of at least 12 months.

Once the period of comprehensive and active marketing is achieved, any other suitable employment use should be considered before change of use to residential or other use will be permitted.

The redevelopment of outmoded employment floorspace will be permitted to cater for modern business needs. The provision of improved ICT infrastructure will be encouraged in refurbished and redeveloped sites.

Response: Object 

We do not support the policy of resisting change of use from B1a to residential because it flies in the face of positive property market solutions for the regeneration of brownfield land and is contrary to current government policy which has recently been reaffirmed and permits a change of use from B1a (offices) to C3 (residential).


Policy E4: Surrey Research Park

The existing 28 hectare Surrey Research Park and the proposed extension will be protected for business use comprising offices, research, development and design activities, in any science, including social science, falling within Use Classes B1 (a), (b) and (c) of the Town and Country Planning (use Classes) Order 1987 (as amended), that is complementary to the activities of the University of Surrey. Development in accordance with the above will be supported.

It is expected that the new extension will provide a variety of sizes of unit including some small units (between 15 – 80 sq m) in order to meet the needs of start-up companies.

Where any proposals for development are submitted which do not meet the criteria set out above, the onus will be on the applicant to demonstrate:

  • the need for such proposals in this location
  • the economic benefits to the local and wider economy
  • the proposals are well designed and landscaped to complement and enhance the existing Research Park setting,
  • the proposed use would complement the overall functioning of the Research Park.

Response: Object 

We support the maintenance of research, development and design activities, in any science, including social science, that is complementary to the activities of the University of Surrey at the Surrey Research Park. We do not believe that there is a need to expand the Research Park into a larger Business Park. We believe that the planning policy going forward for the Surrey Research Park should be to maintain and enhance the integrity of its research base allowing for the economic value add to the local economy of knowledge and technology transfer from the University. B1b (should be the primary use class for the Research Park and that applications for B1a should be resisted due to the danger of dilution of the core purpose and reputation of the park. We do not believe the inclusion of B1c uses is appropriate or necessary.


Policy E5: Rural Economy

In order to support economic growth in rural areas, which will create jobs and prosperity, a positive approach to sustainable new development will be taken in Guildford borough. To promote a strong rural economy:

  • the sustainable growth and expansion of all types of business and enterprise in rural areas will be supported, through conversion of existing buildings and provision of well designed
    new buildings of appropriate scale, provided they are in accordance with green belt policy and other policies in the plan
  • the development and diversification of agricultural and other land-based rural businesses will be supported, and
  • the retention and development of local services and community facilities in our inset and identified villages, such as local shops, meeting places, sports venues, cultural buildings, public houses and places of worship, which respect the character of the countryside, will be supported.

The Council will work with our partners at Surrey County Council and the Enterprise M3 LEP to support and improve the provision of internet services where needed in rural areas and enhance digital inclusion in such areas. This will help to retain and promote services and types of business, including traditional agriculture, and help to create more sustainable villages.

To support the rural economy, national policy is more flexible, allowing small-scale development for main town centre uses (see glossary) without applying the sequential approach. The sequential approach will not be applied to applications for small scale rural offices or other small scale rural development.

Response: Object 

Use of rural areas for town centre uses without applying the sequential approach is against the principles of localism which mean that local people should be consulted – and heeded (not ignored!). Villages need protecting both in terms of design and in terms of scale. Previous
commitments to improved high-speed broadband and mobile phone coverage have now been diluted, despite general support. This is disregarding the responses from the previous consultation.


Policy E6: The leisure and visitor experience

We will continue to develop a high quality visitor experience to increase the contribution that tourism, arts, cultural heritage and sport make to our quality of life and social and cultural well-being. To achieve this we will support:

  • the provision of new and enhanced leisure and visitor attractions, including arts and cultural facilities, in accordance with the sequential test outlined in the NPPF for main town centre uses
  • the provision of new and improved accommodation and conference facilities for tourist and business visitors in accordance with the sequential test
  • sustainable rural tourism and leisure developments that benefit businesses, communities and visitors in rural areas as long as they respect the size, character and function of their
    setting and comply with national green belt policy. This support extends to the re-use of suitable rural buildings for visitor accommodation and other small-scale rural development
    proposing less than 100sq m of additional floorspace
  • proposals which promote greater use of the River Wey as a leisure and recreational resource.

To protect the vitality and viability of our town, district and local centres, proposals for new leisure space which exceed 500sq m and are located outside of these areas, as designated on the Policies Map, will be required to submit an impact assessment. All new and
enhanced leisure and visitor attractions and facilities should preserve the borough’s special heritage and natural features.

The loss of existing visitor, leisure and cultural attractions, including arts and entertainment facilities, hotels and indoor sports venues, will be strongly resisted unless replacement facilities of an equivalent or better standard and provision are proposed in a location equally
accessible to the facility’s current catchment area. Alternatively, robust evidence must be provided that demonstrates that the facility causes significant detriment to the amenity of the locality or that:

  • there is no longer a need for the existing facility or an alternative leisure or visitor use; and
  • the existing use is unviable and its retention has been fully explored (including through marketing the facility for alternative leisure or visitor use for a continued period of at least 18 months).

Response: Object 

Tourism and visitors do not depend on new visitor “attractions”. Overdevelopment of countryside is a risk. Surrounded by the natural beauty of the Surrey Hills, Guildford is distinguished as an historic county town. The historic part of the town should be exploited to the full creating a real sense of vibrancy and atmosphere. This should be linked to the attractions of the Museum, the Castle, the Wey and the historic High Street including its views of the Hogs Back. Guildford would be wise to model itself on other historic towns like Bath, Chester and York. The economic impact would create big advantages for both the leisure and the niche speciality retail sectors in the town Guildford the historic “Gateway to the Surrey Hills” has far more potential than Guildford being a stereotypical centre found anywhere around London. The countryside can offer high quality tourism – including cycling, National Trust sites, open countryside and cultural events including theatre and opera – which is lucrative. This is not recognised fully.


Policy E7: Guildford Town Centre

By 2033, Guildford town centre will have:
• a new retail-led, mixed-use development of 45,000 sq m (gross) of additional comparison goods floorspace on the North Street regeneration site within its primary shopping area.
• developments of other town centre uses that contribute to the liveliness of the town centre including food and drink, more gyms and cinema screens;
• approximately 1,172 new homes, particularly on upper floors as part of mixed use developments;
• more varied uses during the evening and night-time, including along the riverside, with residents and visitors feeling safe;
• active use of the riverside and the river;
• more effective routes within and across the town centre for pedestrians and cyclists
• new public squares and other informal meeting areas.

Retail and leisure proposals over 500sq m (gross) located outside of Guildford town centre, local or district centres, and where the site is not allocated in this Plan, must be supported by a retail impact assessment.

Within the Primary Shopping Frontage as defined on the Policies Map proposals for change of use of existing ground floor shops (Class A1) to other uses will not be permitted.

Within the Secondary Shopping Frontage defined on the Policies Map, planning permission for the change of use of ground floor shops (Class A1) to Class A2, A3 or A4 will be permitted where all the following criteria are met:

  • the additional uses result in no more than two permitted ground floor non-retail uses adjacent to each other; and
  • the additional use results in no more than one third of this section of the defined street level frontage (as defined in Appendix B) in permitted non-A1 Use Class; and
  • the use does not result in loss of amenity in terms of noise, disturbance, smell, litter or traffic generation; and
  • the proposed use will not be detrimental to the shopping function or character of the town centre.

Exceptionally loss of shopping area uses (Class A) at ground floor level will be permitted, subject to the above criteria, where the proposed use is appropriate to a town centre shopping frontage.

Proposals for new food takeaways within 500m of schools will not be accepted because of the potential negative impact on the health of school children.

Response: Object 

There should be much more residential use of the town centre. There is limited need for further retail, which will disadvantage existing retailers as well as using valuable land inefficiently. Existing niche retailers should be supported, but this does not mean further retail expansion which could be counterproductive. There is an urgent need for a brownfield register and to focus on brownfield redevelopment before considering development outside the existing urban area. CIL strategy must promote brownfield redevelopment. . Guildford should strive for high quality definition making it a great centre for people to live in and visit. It would be a great mistake if Guildford were to opt for large impersonal department stores and dull high street chain stores at the expense of exploiting its uniqueness and character which would afford greater benefits.


Policy E8: District and Local Centres

We will support the role of District Centres as the focus for communities in the surrounding areas in providing for everyday shopping and service needs as well as for some more specialist needs. Proposals for residential use of upper floors add to the liveliness of centres, and will be considered positively.

The following areas, as shown on the Policies Map, are designated as District Centres. For each, the Primary Shopping Area is the boundary of that Centre:

  1. Wharf Road, Ash
  2. Station Parade, East Horsley
  3. Ripley.

In order to strengthen the liveliness and economic resilience of the borough’s District Centres, retail developments consistent with the scale and function of that centre will be supported. Where no suitable sites are available, sites on the edge of designated centres will be considered. We will not apply this sequential approach to proposals for town centre uses of less than 100sq m (gross) in rural areas.

Retail and leisure proposals over 500sq m (gross) located outside of a local or district centre, and where the site is not allocated in the local plan must be supported by an impact assessment.

Proposals for new food takeaways within 500m of schools will not be accepted because of the potential negative impact on the health of school children.

Within the District Centres shown on the Policies Map, proposals for change of use of a ground floor shop (Use Class A1) to use for financial and professional services (Use Class A2) and/or food and drink (Use Class A3/A4/A5) will be permitted where all of the following criteria are met:

  • the proposal results in no more than two adjacent non-retail uses
  • the proposal results in no more than one-third of defined ground floor frontage units in permitted non-retail uses
  • the proposal will not result in loss of amenity in terms of noise, smell, litter or traffic generation, and
  • the proposal will not prejudice the character and appearance of the district centre and its immediate environment.

Exceptionally loss of shopping area uses (Class A) at ground floor level will be permitted, subject
to the above criteria, where the proposed use is appropriate to a District Centre.

Response: Part Object, Part Support

We think it is appropriate that these three district centres should support development consistent with the scale and function of the local centre. We think it is appropriate not to approve planning applications for main town centre uses over 100 sq m outside district centres – although this policy could and should be more clearly articulated. We do NOT support consideration of sites on the edge of district centres for town centre uses.


Policy E9: Local Centres

We will support the role of Local Centres as the focus for local communities in providing for everyday shopping and service needs. Proposals for residential use of upper floors add to the liveliness of centres, and will be considered positively.

The following areas, as shown on the Policies Map, are designated as Local Centres. For each, the Primary Shopping Area is the boundary of that Centre:

The 14 urban Local Centres are:

  • Aldershot Road, Westborough
  • Collingwood Crescent, Boxgrove
  • Kingpost Parade, London Road, Burpham
  • Epsom Road, Merrow
  • Kingfisher Drive, Merrow
  • Madrid Road, Guildford Park
  • Southway, Park Barn
  • Stoughton Road, Bellfields
  • The Square, Onslow Village
  • Woodbridge Hill, Guildford
  • Woodbridge Road, Guildford
  • Worplesdon Road, Stoughton
  • Ash Vale Parade, Ash
  • The Street, Tongham.

The six rural Local Centres are:

  • Bishopsmead Parade, East Horsley
  • Effingham
  • Fairlands
  • Send
  • Shalford
  • Shere.

In order to strengthen the liveliness and economic resilience of the borough’s Local Centres, retail developments consistent with the scale and function of that centre will be supported. Where no suitable sites are available, sites on the edge of designated centres will be considered. We will not apply this sequential approach to proposals for town centre uses of less than 100sq m (gross) in rural areas.

Retail and leisure development proposals over 500sq m (gross) which are not located in a local or district centre, and where the site is not allocated for the proposed use must be supported by an
impact assessment.

Proposals for new food takeaways within 500m of schools will not be accepted because of the potential negative impact on the health of school children.

Within the Local Centres shown on the Policies Map, proposals for change of use of a ground floor shop (Use Class A1) to use for financial and professional services (Use Class A2) and/or food and
drink (Use Class A3/A4/A5) will be permitted where all of the following criteria have been met:

  • the proposal will not result in a concentration of such uses that would be harmful to the local shopping centre's vitality and viability; and
  • the proposal will not result in loss of amenity in terms of noise, smell, litter or traffic generation; and
  • the proposal will not prejudice the character and appearance of the local centre and its immediate environment.

Exceptionally loss of town centre uses (Use Class A) at ground floor level will be permitted, subject to the above criteria, where the proposed use is appropriate to a Local Centre.

To ensure that people living and working in rural areas can access everyday goods and services, we will resist the loss of rural shops and service units that provide for everyday needs (within Use Class A) within rural areas but outside of Local and District Centres, unless a minimum of 12 months marketing for that Use Class is demonstrated.

Response: Object 

We do not think that retail development adjacent to the 6 rural centres is appropriate, nor sites on the edge of designated centres.


Design

Policy D1: Making better places

We require all new developments to achieve high quality design and enhance the environment in which they are set.

Residential developments of 25 or more dwellings must:

  • provide a harmonious, integrated mix of uses, where appropriate, that fosters a sense of community and contributes to inclusive communities that provide the facilities and services needed by them
  • provide places for communities to meet and interact, such as play and recreation and other public spaces
  • be designed to facilitate and promote walking, providing a high quality environment for pedestrians, and where possible allowing short walking distances to amenities
  • create places that are easy to get to and through, foster active lifestyles, are easy to understand and navigate, and feel safe during the day and night, and
  • provide convenient and safe routes through the development and to nearby areas for pedestrians and cyclists.

All developments will:

  • respond meaningfully and sensitively to the site, its characteristics and constraints, and the layout, grain, massing and height of surrounding buildings
  • be laid out to make the best use of the natural features such as trees and hedges and levels, and enhance views into and out of the site
  • promote and reinforce local distinctiveness to create a sense of place, with innovative architecture encouraged and supported in the appropriate context
  • be expected to have regard to and perform positively against Building for Life 12 criteria, and
  • be expected to use art and materials of a nature appropriate to their setting.

Response: Part Support, Part Object 

We support the emphasis on views, natural features, local distinctiveness, and layout of surrounding buildings. There is no reference to vernacular or historic design guidelines, even in Conservation Areas and we object to the absence of this from this policy. Most of the borough, especially the rural areas, have vernacular design guidelines which are available to give suggestions as to appropriate design. These should have mandatory planning force. The monitoring of this policy is inappropriate. Why should this policy result in a reduction of the number of appeals for poor design – should it not result in better designed buildings?


Policy D2: Sustainable design, construction and energy

Sustainable development

Proposals for zero carbon development are strongly supported. Proposals for development, including refurbishment, conversion and extensions to existing buildings, must set out in a sustainability statement how they will deliver:

  • sustainable design and construction practice including (where applicable):
    • the efficient use of mineral resources and the incorporation of a proportion of recycled and/or secondary aggregates
    • waste minimisation and reusing material derived from excavation and demolition
    • the use of materials both in terms of embodied carbon and energy efficiency
    • landform, layout, building orientation, massing and landscaping,
  • the lowest level of carbon emissions (direct and embodied) that is achievable,
  • the highest levels of energy and water efficiency that are achievable and
  • measures that enable sustainable lifestyles for building occupants wherever opportunities to do so are identified.

When meeting these requirements, the energy and waste hierarchies should be followed except where it can be demonstrated that greater sustainability can be achieved by utilising measures
further down the hierarchy. The Sustainable Design and Construction Supplementary Planning Document (SPD) sets out guidance on appropriate standards and practice.

Climate Change Adaptation

Developments should be fit for purpose and remain so into the future. Development proposals must set out in a sustainability statement how they have incorporated adaptations for a changing
climate and changing weather patterns in order to avoid increased vulnerability and offer high levels of resilience to the full range of expected impacts.

Renewable, low carbon and decentralised energy

The development of low and zero carbon and decentralised energy, including (C)CHP distribution networks, is strongly supported and encouraged.

All new developments must connect to (C)CHP distribution networks where they exist, or incorporate the necessary infrastructure for connection to future networks, unless it can be clearly demonstrated that doing so is not feasible or that utilising a different energy supply would be more sustainable.

Proposals for development within heat priority areas as shown on the Policies Map and all sufficiently large or intensive developments must demonstrate that heating and cooling technologies have been selected in accordance with the following heating and cooling hierarchy unless it can be clearly demonstrated that an alternative approach would be more sustainable:

  1. Connection to existing (C)CHP distribution networks
  2. Site wide renewable distribution networks including renewable (C)CHP
  3. Site wide gas-fired (C)CHP distribution networks
  4. Renewable communal heating networks
  5. Gas-fired communal heating networks
  6. Individual dwelling renewable heating
  7. Individual dwelling heating, with the exception of electric heating

All (C)CHP must be of a scale and operated to maximise the potential for carbon reduction.
Developments that do not connect to or implement (C)CHP or communal heating networks should be ‘connection-ready’.

Energy statements must be provided to demonstrate and quantify how development will comply with the energy requirements of this policy. Guildford Borough Council will work proactively with applicants on major developments to ensure these requirements can be met.

Carbon reduction

New buildings must achieve a reasonable reduction in the carbon emissions that remain after efficiency measures have been applied of at least 15 per cent. This should be achieved through the provision of appropriate on-site renewable and low carbon energy technologies. Proposals should set out how this will be achieved in an energy statement.

Response: Object 

The emphasis on energy and waste hierarchies and reduction of carbon emissions as part of building design are welcomed. However, the emphasis on CCHP (Combined Cooling Heating and Power) and communal heating networks seems curious – no such networks are currently locally available. There is an element of “Greenwashing” – the imposition of aspirational environmental targets while ignoring the simple fact that building dormitory towns is environmentally unsustainable. These all require increased car use and will lead to increased congestion and so air pollution and higher carbon dioxide emissions and a few solar panels on roofs will not compensate for the considerable environmental cost.


Policy D3: Historic environment

We will conserve and enhance the historic environment in a manner appropriate to its significance. We will support development of the highest design quality that will conserve and, where appropriate, enhance the special interest, character and significance of the borough’s heritage assets and their settings and make a positive contribution to local character and distinctiveness.

Heritage assets are an irreplaceable resource and works which would cause harm to the significance of a heritage asset, whether designated or non-designated, or its setting, will not be permitted without a clear justification to show that the public benefits of the proposal considerably outweigh any harm to the significance or special interest of the heritage asset in question.

Response: Part Object, Part Support

The policy appears reasonable. However, conserving and enhancing the historic environment may be damaged by supporting ancillary development. In historic locations (Chilworth Gunpowder Mills, the NT sites like Clandon Park or Hatchlands, Guildford Castle, Guildford Museum etc) this policy needs to have an overriding emphasis on protection rather than supporting development. The emphasis on supporting some development – in the context of an authority that has already set in place aggressive reviews of Guildford Museum and the Electric Theatre – should be viewed with some caution. The reasoned justification seems reasonable but it must be noted that it is the wording of the policy, rather than the associated explanation, that must be key.


Policy D4: Development in urban areas and inset villages

Planning permission for new development in the urban areas of Guildford, and Ash and Tongham, and inset villages will be granted provided that it:

  • ensures that the layout, scale, form, massing, height of buildings and structures, and materials relate to the site context and its surroundings
  • respects and compliments the existing grain and street pattern of the area
  • conserves locally and nationally important heritage assets and conserves or enhances their settings,
  • has no unacceptable effect on the amenities enjoyed by the occupants of buildings in terms of privacy, noise, vibration, pollution, dust, smell and access to sunlight and daylight.

In addition to the above, proposals for new development within inset village areas will have particular regard to:

  • the distinctive settlement pattern of the village and the important relationship between the built development and the surrounding landscape;
  • important views of the village from the surrounding landscape;
  • views within the village of local landmarks.

Response: Object 

There are effectively two separate parts to this policy, both are flawed, and in the case on insetting, fatally flawed. In the case of urban development there are numerous flaws, including:

  • The plan envisages that 40% of homes built will be affordable, but this does not provide any accommodation for low paid workers, for example, those on the minimum wage, who cannot afford to buy “affordable” homes, nor can they pay the so-called “affordable” rent. There is a need for some expansion in social housing, especially in urban areas, where there is a greater concentration of low paid workers such as those employed in the retail, warehousing and distribution sectors.
  • The number of homes planned in the urban area is too low – there is a need for regeneration in some areas, but this is ignored and instead the plan concentrates on building homes on green field sites, which does not meet the needs for housing within the town, especially with the centre. This is not a sustainable policy as building outside the town has a disproportionate effect on road traffic.
  • The plan envisages a large expansion of the traditional “bricks and mortar” retail sector, but this is a sector in long term decline.

Infrastructure and delivery

Policy I1: Infrastructure and delivery

To support delivery of this Local Plan, infrastructure needed to support development should be provided and available when first needed to serve the occupants and users of the development. This will be secured by planning obligation, planning condition, or from other infrastructure funding, including the Community Infrastructure Levy. Where the timely provision of necessary supporting infrastructure is not secured, development may be phased to reflect infrastructure delivery, or will be refused.

The key infrastructure needed to support the delivery of this Plan is provided in the Infrastructure Schedule at Appendix C. The Local Plan also includes land allocated for infrastructure. This infrastructure is listed at Appendix C. The non-site specific and more general infrastructure requirements are set out in the Planning Contributions Supplementary Planning Document (SPD) 2011, which will be updated as required.

Through the Community Infrastructure Levy (CIL) we will collect financial contributions from most new build developments in the borough. We will use CIL receipts towards providing infrastructure to support development, and will facilitate the spending of up to one quarter of CIL receipts originating from each Parish and from Guildford town, on local priorities to support development.

In allocating developer infrastructure contributions, we will prioritise Thames Basin Heath Special Protection Area mitigation and avoidance in order to ensure that we meet our legal responsibilities.

Response: Object 

Various aspects of Infrastructure are acknowledged as congested, inadequate for the existing population and not able to accommodate much growth. However, greenfield sites – requiring heavy infrastructure investment – are targeted in order to generate CIL income for the council. This is not sensible. The current draft CIL scale also encourages development on greenfield sites rather than brownfield.

The Council’s methodology assessing traffic and roads infrastructure needs is inadequate. It identifies only the tip of the iceberg in terms of existing congestion. Looking at local traffic situations around the Borough it becomes clear that the schemes proposed will not solve existing congestion and the local road network has not been given sufficient consideration. Some proposed locations would require highway schemes that involve demolition of property and road-widening in residential areas to solve the resultant congestion.

The A3 improvements are not guaranteed to take place but they are being used to justify removing large areas from the Green Belt before detailed traffic assessments have taken place. These detailed investigations are being deferred until the planning application stage and will be left to developers to prepare. If a site then proves to be unsustainable its Green Belt protection will have been lost for no reason and unsuitable development will take place by a more insidious process.


Policy I2: Supporting the Department for Transport’s “Road Investment Strategy”

Guildford Borough Council is committed to working with Highways England to facilitate major, long-term improvements to the A3 trunk road and M25 motorway in terms of both capacity and safety, as mandated by the Department of Transport’s “Road Investment Strategy”. As such, proposal sites adjacent to the A3 and M25 and other large sites will need to take account of any emerging proposals by Highways England or any other licenced strategic highway authority appointed by the Secretary of State under the Infrastructure Act 2015

Response: Object 

This policy is concerned only with the strategic road network – the A3 and M25 for which the responsibility and decision making lies with Highways England. It is only reasonable that the council will work closely with Highways England to ensure that the Local Plan does not utilise land in a way that limit the scope for future improvements. However, the proposals for the A3 are undecided and the council has suggested a very expensive tunnel proposal that, even if HE decided to go ahead with it, is unlikely to be delivered until the end of the plan period. Less expensive alternative A3 improvements would not be delivered before implementation of the current draft Local Plan and would deliver a massive growth in traffic. The road improvements are likely to lead to massive disruption to traffic during the construction phase on top of an already overloaded road network. It would be folly to make matters worse by committing to a massive housing number and the only logical conclusion is that a very significant traffic constraint should be applied to the OAN for this Local Plan.


Policy I3: Sustainable transport for new developments

We will expect that new developments will contribute to the delivery of an integrated, accessible and safe transport system, balanced in favour of sustainable transport modes, to facilitate sustainable
development.

We will expect new development to:

  • provide high-quality, safe and direct routes within permeable layouts that strengthen, facilitate and encourage short distance trips by walking and cycling
  • provide secure, accessible and convenient cycle parking
  • protect, enhance and improve existing cycle and walking routes, to ensure the effectiveness and amenity of these routes
  • secure appropriate improvements to public and community transport, including infrastructure and park and ride requirements
  • provide off-street vehicle parking for both residential and non-residential developments at a level which reduces the likelihood of overspill parking on the public highway where there is a clear and compelling justification that it is necessary to manage the Local Road Network
  • within areas of on-street parking stress, as identified by the Vehicle Parking Supplementary Planning Document, planning permission for residential developments resulting in a net increase in housing will be subject to a planning obligation to require that future occupants will not be eligible for on-street
    residents parking permits
  • provide a Travel Plans where significant amounts of movement are generated
  • facilitate the use of ultra low emission vehicles
  • provide for the needs of people with disabilities by all modes of transport, wherever possible, and
  • contribute to the delivery of the route of the proposed Sustainable Movement Corridor in the town of Guildford where appropriate.

We will expect new developments to demonstrate adequate provision to mitigate the likely impacts, including cumulative impacts, of the proposal on both the safe operation and the performance of the Local Road Network and Strategic Road Network. This provision should include the mitigation of environmental impacts, such as noise and pollution, and impact on amenity and health. This will be achieved through direct improvements and/or Section 106 contributions and/or the Community Infrastructure Levy (CIL), to address impacts in the wider area including across the borough
boundary.

We will expect all applications for development that generate significant amounts of movement to be supported by a Transport Statement or Transport Assessment in accordance with the thresholds set out in the Council’s Local Validation List.

Response: Object 

We support the concept of sustainable transport but object on the grounds that the practicalities have not been properly considered, It is not sustainable to build dormitory towns and call them sustainable. Not everyone can cycle all the time. How can large developments outside the town centre maximise sustainable travel? This is a matter for the planning process- the further from the town centre, the less sustainable the development will be. Reliance on cycling discriminates against vulnerable members of the community. How can the disabled, those with small children, or the very old, or the infirm, or those who are ill, cycle outside the town in order to commute, or even inside the town? Only some people cycle –and Guildford has some steep hills, especially going out of town. Park and rides are slow – how can those with a 3 hour commute add 1 hour to their journey from using park and rides? The only sustainable mechanism for new developments is to have them in the town centre close to the railway and the main shopping links where a “hoppa bus” can provide satisfactory links for those who cannot walk or cycle. While we welcome the intention to encourage rail travel by adding two new stations (subject to negotiation with Network Rail) there could unintended consequences.


Policy I4: Green and blue infrastructure

Biodiversity

The Council will conserve and enhance biodiversity and will seek opportunities for habitat restoration and creation, particularly within and adjacent to Biodiversity Opportunity Areas (BOAs). The Council will produce a Green and Blue Infrastructure Supplementary Planning
Document (SPD) setting out how this approach will be implemented.

Proposals for development must demonstrate how they will deliver appropriate net gains in biodiversity. Where proposals fall within or adjacent to a BOA, biodiversity measures should support that BOA’s objectives. The SPD will set out guidance on how this can be achieved.

The designated sites in the following hierarchy are shown on the Policies Map or as subsequently updated:

  • European sites: Special Protection Areas (SPA) and Special Areas of Conservation (SAC)
  • National sites: Sites of Special Scientific Interest (SSSI)
  • Local sites: Sites of Nature Conservation Importance (SNCI) and Local Nature Reserves.

Permission will not be granted for development proposals unless it can be demonstrated that doing so would not give rise to adverse effects on the integrity of European sites, whether alone or in combination with other development. Any development with a potential impact on SPA or SAC sites will be subject to a Habitats Regulations Assessment.

Development will not be permitted within or adjacent to national sites unless it can be shown that doing so would not be harmful to the nature conservation interests of the site.

Permission will not be granted for proposals that are likely to materially harm the nature conservation interests of local sites unless clear justification is provided that the need for development clearly outweighs the impact on biodiversity.

Blue infrastructure

Waterways will be protected and enhanced. Development proposals that are likely to have an impact on waterways, including the River Wey catchment, must demonstrate how they will support the implementation of the Water Framework Directive and have followed guidance from the Environment Agency and Natural England on implementation of the Wey Catchment Plan and flood risk management.

Open space

Open space (encompassing all open space within urban areas, land designated as Open Space on the Policies Map and all land and water that provides opportunities for recreation and sport) will be protected from development in accordance with the NPPF.

Response: Object 

The Policy shows concern for conserving and enhancing biodiversity, which is welcome. We also note and welcome the intention to extend the principle beyond Biodiversity Opportunity Areas. However the current plan to build on large areas of countryside and to inset villages will have the opposite effect. The Policy appears therefore to be a box-ticking exercise with no real teeth to it. There is no mention of the value of wildlife gardening to biodiversity or the important role that larger gardens play in a village setting. There is no mention of the impact of the plan on food production, or monitoring the loss of agricultural land.

 

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