Agenda item

To receive a presentation in respect of the review of the Guildford Borough Local Plan.

The Lead Councillor for Planning, Environment and Climate Change introduced this presentation item and explained the Guildford Borough Local Plan: Part 1 Strategy and Sites (LPSS) 2019 review process.  It was emphasised that this five yearly statutory review process was a separate and distinct exercise from updating and changing a Local Plan.  There was a requirement for local planning authorities to review their Local Plans on a five yearly cycle and, in the event that the review found that the Local Plan required updating, that procedure would be pursued.  The Local Plan review was a technical exercise conducted by Council officers guided by the Planning Advisory Service (PAS) and followed a statutory approach.  The outcome of the review would be reported to the Executive and then to the Council to obtain a decision in respect of whether an update of the Local Plan was required.  In the event it was determined that an update was necessary, the Council would decide what form the update would take and which particular aspects of the Local Plan needed updating.  Such a decision was likely to be reached in mid to late Spring 2024 as the five year anniversary of the adoption of the Local Plan fell in April 2024.  The Lead Councillor and the Executive welcomed any questions and comments from councillors in respect of the Local Plan review process.

Members of the Planning Policy Team presented the item.  The presentation highlighted:

·           The context, scope and next steps of the Local Plan review.

·           The necessity for the Council to review the Local Plan by 25 April 2024.

·           Addressing the question of whether the Local Plan required updating with reference to the National Planning Policy Framework (NPPF).

·           The stages of the review process, the outcome of which would not change the Local Plan.

·           Considering the changing context in a proportionate manner with regard to national policy and changing circumstances e.g. housing need / delivery, economic changes that may impact viability, and new social, environmental or economic priorities.

·           Officers’ use of the PAS matrix for the review which featured review factors and a Local Plan Toolkit review assessment.

·           The Local Plan remained part of the Council’s Development Plan giving primary consideration in determining development applications in the Borough and attaching due weight to relevant policies in existing plans consistently with the NPPF.

·           The possibility of new national legislation and policy weighing in favour of an update of the Local Plan, consisting of:

-         the New Levelling Up and Regeneration Act

-         new NPPF and National Development Management Policies to follow the Act

-         updates to National Guidance

·           Monitoring by officers of national developments in respect of Planning Reform.  Although these were unlikely to have any implications for the review, they presented a challenging uncertainty in terms of a firm view regarding the scope of a potential future Local Plan update.

·           The findings of the review would be reported to the Executive on 25 January 2024 and then to full Council on 21 February 2024.  The report would address internal engagement with the cross party Planning Policy Board and the Joint Executive Advisory Board, external engagement limited to Duty to Co-operate bodies, and a technical assessment.

The JEAB was advised that, although the existing Local Plan had been adopted in 2019, it had been prepared on the basis of the 2012 NPPF under transitional arrangements allowed under the 2018 NPPF.  Subsequent NPPFs had been introduced in 2021 and 2023 without a significant impact on the Local Plan.

Housing need was an area of particular area of interest as the Local Plan had been prepared under the old system of calculating housing need leading to an annual allocation of 562 homes.  Under the 2018 NPPF system, which sought to introduce a simplified standard methodology which included an affordability uplift component, this number would rise to the requirement for 779 new homes per year in the Borough.  The Government had indicated that the standard methodology calculation would be amended in Spring 2024 and the related final figure was anticipated to equate to an increase over the current 562 figure.  A new figure could only be challenged, or successfully implemented, as part of the Local Plan examination process based on evidence.  In the event that a Local Plan was over five years old and found to be in need of updating, the NPPF stipulated that the standard methodology be utilised to calculate the five year housing supply figure.

Other planning legislation changes of possibly more significance included the introduction of Use Class Order E which placed retail and office into the same use class whereas they had been in separate use classes previously.  In addition, there had been some changes to allow retail and office uses to change to residential use in certain circumstances under permitted development rights, which impacted on employment policies in the Local Plan.  The most significant changes would lead to alterations to the plan making system.  A further factor with implications for the Local Plan related to the fundamental changes in circumstances which had occurred during the past five years since its adoption which altered the planning context, including Covid, the cost of living crisis, inflation and higher interest rates which all had implications for the economy, construction and viability whilst impacting on the type of employment land required pointing to the need for an update of the Local Plan.

With regard to social, environmental or economic priorities, climate change and biodiversity were highlighted as areas of increasing importance to both local and central government.  As part of the preparation of the Local Plan: Part 2 Development Management Policies, the opportunity had been taken to strengthen these policy areas.  As this resulted in a gap in terms of e.g. biodiversity net gain in the current LPSS, an update of the document would enable such priorities to be reconsidered.

It was noted that the Government was embarking on a significant programme of planning reform with a view to introducing a simpler and more rapid and predictable planning system and this was reflected in the forthcoming new and secondary legislation.

The following points arose from ensuing questions, comments and discussion:

1.            It was most likely that the Local Plan would require updating owing to the introduction of forthcoming primary and secondary legislation combined with changes to the housing need calculation and the economic context.  Sustainability together with environmental and heritage protection were also factors to be taken into consideration.

2.            Whilst the public would have ample opportunity to respond to consultation associated with any proposed update to the Local Plan, related communications should seek to manage expectations around development sites and the housing need figure.  Communications issued to date had placed an emphasis on the difference between a review and an update of the Local Plan and further thought was being given to improving and expanding methods of communication and engagement.

3.            There was a possibility that an update of the Local Plan could lead to changes to the Greenbelt boundaries to include some sites which had been excluded from the Greenbelt in the current version of the Local Plan.  The introduction of different categories of land designation was also possible.

4.            Measures to promote biodiversity and tackle climate change were expected to hold increasing weight in future planning policy.

5.            The Council’s current planning policy framework was robust and would remain valid and in place pending the implementation of an updated Local Plan.