Caught up in the final rush

A neighbour kindly sent me a copy of their considered response to the consultation on Guildford Borough Council’s draft Local Plan and a very trenchant document it is.  This is the “real” consultation, where residents’ responses will go forward with the rest of the much-criticised ‘evidence base’ to the planning inspector who examines in public the submitted plan next May (2015), not the sham consultation last year, used by the council to draw the sting of those motivated to respond and then manipulate the evidence base where politically convenient.  Now, residents’ comments really do matter.  If you write, you have the right to request being heard at the examination in public and put your points personally and directly to the planning inspector.

My neighbour had read the 19 policies in the draft document, picked out the Site Policies relevant to Normandy and Flexford, gone back to the ‘evidence base’ documents referenced in the policy notes, taken the trouble to re-read all 207 paragraphs the National Policy Planning Framework, noted the letters of ministerial guidance issued by the various incumbents of the planning portfolios over the last 18 months and also taken the trouble to be aware of the decisions flowing through the courts that modify interpretation of the NPPF.  This is the dedication being shown again by thousands of incensed residents that believe this council has been and is being secretive, misleading and duplicitous in the development and presentation of this plan.

When faced with a council where the lead councillor for the Local Plan process has had to step down from the Executive Committee of the council as a result of being arrested, bailed and appearing in court, facing seven charges variously reported in the press as including forgery, fraud by false representation, obtaining monetary advantage by deception and wilfully pretending to be a barrister; where the Head of Planning came back from holiday in August, sat down at her desk and promptly resigned; and where the deputy leader of the council’s Executive Committee has resigned recently “due to pressure of increased work commitments outside the council”, residents cannot be blamed for expressing deep dissatisfaction with the governance of the borough and the management of the Local Plan process.  Something is rotten in this borough.

What did my neighbour write in his letter to the council planning department, outlining his rejection to the potential ‘concreting over’ of Normandy and Flexford? Perhaps you would like to read for yourself…

“Dear Planning Department

I am writing in response to Guildford Borough Council (GBC)‘s public consultation on the Draft Local Plan: strategy and sites 2014, and to register my strong objections to a number of its proposals. These are partly about the assumptions underlying the Draft Plan itself, and partly about the impact of GBC’s proposals on Normandy and Flexford.

On the overall Plan I find it deeply disappointing that GBC has not listened to the many authoritative voices questioning the rationale for an annual new housing figure of 652, as expressed in Policy 2. Given that the Office of National Statistics has issued revised data and corrections to the Guildford numbers it is astonishing that consultation is going ahead on the basis of the original assumptions. This figure drives everything else in the Plan and makes it impossible to have a proper public debate about its contents. In turn it renders worthless much of the so-called ‘evidence base’; for example the brief for the ‘Green Belt and Countryside Study’ (GBCS) is skewed in favour of finding reasons to build on the Green Belt on the basis of this inflated housing requirement.

In this respect GBC seems determined to ignore the repeated statements from Ministers concerning the importance of the Green Belt: the fact that exceptional circumstances are required for changes to Green Belt boundaries, that unmet housing need is not such a circumstance, and that the existence of the Green Belt constitutes a reason for not meeting housing need – even where this has been objectively assessed. A recent example of this is the letter of 18 June 2014 from Nick Boles MP – who was at the time Planning Minister – to Sir Paul Beresford MP, which has been widely circulated and which is very clear indeed on these points.

Thus much of the emphasis in the draft Plan is on ‘insetting’ within the Green Belt villages that are currently ‘washed over’ by it. While some of the proposed extensions to the settlement boundaries might on the surface appear reasonable, in the case of Normandy and Flexford it is hard to have any confidence that this move does not simply represent the thin end of the wedge, given the cavalier rejection in the draft Plan of the ‘openness’ of the area and its contribution to the openness of the Green Belt, and the concurrent proposals for so-called ‘safeguarded land’, the use of which would fundamentally change the character of the area. It is to these proposals, made under Policies 9 and 10, that I wish to voice the strongest possible objection.

Volume 4 of the GBCS, section 13.16, acknowledges the requirement of the National Planning Policy Framework (NPPF), paragraph 86, that ‘if the open character of the village makes an important contribution to the openness of the Green Belt, the village should remain washed over by the Green Belt’. However the GBCS then continues (section 13.17) to offer its own interpretation of what constitutes an ‘important contribution’ to openness: ‘if such land is then physically enclosed to a significant degree by topography and/or vegetation there would be little opportunity to observe the land in question, and little opportunity to perceive how such land could significantly contribute to openness in Green Belt terms, thus limiting its opportunity to contribute to the openness of the area to any significant degree or attach any sense of importance.’

This convoluted argument is then applied in Volume 5 of the GBCS to the case of the proposed ‘Potential Major Development Area’ (PMDA) H12-A that occupies the entire space between Normandy and Flexford, consisting at present of productive agricultural land. This envisages a ‘Major Village Expansion’, with a development of an extra 1,083 dwellings, giving a potential population growth of 2,599. This would take the population of Normandy/Flexford from its current 1,784 to a new total of 4,383. It is claimed this area has ‘defensible boundaries’ and that ‘a major expansion… would not significantly affect the openness of the wider Green Belt at this location within the Borough.’ There follows a long and contrived list of justifications in support of this claim, including the astonishing statement: ‘Opportunities to appreciate the openness of the PMDA at H12-A are generally restricted between Normandy and Flexford’.

This is complete nonsense. It assumes that these opportunities only present themselves to people who drive cars along the roads, as opposed to those who walk the public footpaths – in this case the one between Westwood Lane and Glaziers Lane that traverses one of the most rural landscapes in this part of the Borough, with a rich natural flora and fauna that most certainly does contribute to the openness of the Green Belt as per para 86 of the NPPF. It is also ludicrous to claim that the vista from Westwood Lane – or indeed looking down on the area from the Surrey Hills AONB on the Hog’s Back – would not be adversely affected by the construction of an estate of over 1000 new houses. (The study is also silent on the impact on houses to the South of Pussey’s Copse that back on to the fields, one of which happens to be ours.) The idea that the loss of this wonderfully open space could somehow be compensated by the creation of the artificially constructed ‘suitable natural alternative greenspace (SANG)’ sites that also feature prominently in GBC’s proposals is laughable: destroying green fields and designating much less attractive areas as ‘suitable alternatives’ is just a cynical way of justifying inappropriate development.

The result of this proposal would be to join up Normandy and Flexford and destroy the current openness of the area. This is completely at variance with national policy. It rests on a sophistical analysis that appears to have been produced with the sole purpose of justifying the proposal, rather than as part of an objective appraisal: a case of deciding on the policy and then manufacturing the ‘evidence’ to support it rather than basing policy on objective and impartial evidence. The prospect of an increase in 70% in the number of houses in Normandy and Flexford, and of the consequent strain on an already overburdened infrastructure, is also glossed over in the most superficial way in the study. All in all this piece of ‘evidence’ is totally lacking in credibility and should not form the basis of any rational plan.

Furthermore, although the Orwellian term ‘safeguarded land’ suggests some degree of protection, in fact it means exactly the opposite: this land will be removed from the Green Belt immediately and forever. Although it is claimed that it is merely ‘safeguarded’ for future development, i.e. not to be developed within the forthcoming Plan period, section 4.115 of the Plan document makes clear that: ‘This land will also ensure that we have the flexibility to meet our current development needs should any of our strategic sites not come forward as envisaged over the plan period.’ In other words, Normandy and Flexford have been selected as a strategic overspill for any failures to deliver ‘development’ elsewhere in the Borough. Unsurprisingly, I find that completely unacceptable.

For all these reasons I object in general to the assumptions underpinning the draft Plan (Policy 2) and specifically to the proposal to ‘inset’ Normandy and Flexford within the Green Belt and to ‘safeguard’ site H12-A for future development (policies 9 and 10). I hope a more realistic and honest appraisal of the evidence will be undertaken and that the rural character of our neighbourhood will be preserved rather than sacrificed on the altar of so-called ‘development’.”


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