Agenda item

The draft Local Plan Development Management Policies (LPDMP) and the Draft Parking Supplementary Planning Document (SPD) 2021 were before the Joint Executive Advisory Board (EAB) for consideration.  The Planning Policy Lead gave a brief introductory presentation that identified which current policies, Development Plan Documents (DPDs) and SPDs in the 2003 Local Plan would be replaced by planned policies in the LPDMP.  The key stages in preparing the LPDMP document included research; preparation of issues and options; consultations; submission to the Secretary of State; independent examination by an Inspector; publication of the Inspector’s report and acceptance of the main modifications prior to adoption.  The EAB was advised of the timings associated with these stages and it was anticipated that these would culminate in the LPDMP being ready for adoption in Spring 2023.  The document would assist with the determination of planning applications and its two key themes related to protecting the environment and to securing high design standards.

 

Following the presentation, the EAB discussed the draft Local Plan documents on a chapter by chapter basis and made the ensuing comments for forwarding to the Executive.

 

Housing Chapter

 

Policy H4: Housing Density

 

·             EAB members repeatedly expressed the view that Policy H4 should be retained.

·             Further guidance in the form of a Local Residential Design Guide, Borough Character Study, Design Codes and various SPDs was sought.  It was clarified that SPDs would be developed when the LPDMP was adopted to elaborate on the policies.

 

Policy H5: Housing Extensions and Alterations including Annexes

 

·             A related Character Study and Green Belt SPD were required in this area.

·             Proportionality was raised as an issue requiring consideration, particularly in the Green Belt, due to the risk that homes could be extended and altered in an out of character manner in terms of size, scale, mass and height, with taller homes dwarfing smaller homes.  Using 1968 rather than 1948 as a measurement starting point was suggested.

·             Permitted Development Rights needed to be controlled, where possible, with a view to enabling rational extensions in the Green Belt and related guidance should be included in the Reasoned Justification section.

·             There was a need to differentiate between Green Belt, Countryside and Urban areas (as was the case with 2003 H8 and H9 Policies).

·             The provision of greater clarity in Policy D9 was sought.

 

Policy H6: Housing Conversion and Sub-division

 

·             There was a request to transfer the specific elements (character, proportion, amenity space, adequate parking) from Policy H7 back to Policy H6.

·             Sub-division of infill properties was seen as an issue and it was felt that it would be beneficial to cross-reference and strengthen wording in relevant Policies to prevent it.

·             There was a need for a Houses in Multiple Occupation SPD to provide guidance in respect of property conversions and sub-divisions in order to prevent loss of family homes and negative impact on the character and amenities of affected areas.

·             It was requested that this Policy be expanded to secure an element of affordable housing as part of the conversion of retail premises and offices to residential units.

 

Policy H7: Review Mechanisms

 

·             Whilst a review mechanism was welcomed in relation to affordable housing viability, it was requested that the Policy be expanded to include the use of viability assessments in other areas involving financial commitments such as housing mix and infrastructure requirements to justify departure from policies.  The viability review mechanism must ensure that developers could not leave the construction of the affordable element of a development late and at risk from being reduced or removed from schemes.

·             Although the Government defined the methodology of viability studies, it was beneficial to outline the Council’s related expectations in the Policy.

·             There was a need to ensure that Terms of Reference for affordable housing did not conflict with those in the Local Plan.

·             The creation of a social housing pot, such as that for Strategic Access Management and Monitoring (SAMM) / Suitable Alternative Natural Green Space (SANG) contributions, was suggested as a means towards funding the provision of affordable housing.

 

Policy H8: First Homes

 

·             This Policy was supported and it was suggested that the text of the Policy be broadened to cover future definitions of affordable housing in the event that Government policy or definitions changed.

·             With regard to exception sites, it was requested that policy wording be clarified to explain what would constitute an exception site in and out of the Green Belt.

·             First time buyer programmes must not reduce available stock for affordable housing.

 

Economy Chapter

 

Policy E11: Equine-Related Development

 

·             The EAB agreed that the definition of this Policy should be widened from equine-related development to include development associated with all animals.

 

Protecting Chapter

 

Policy P6/7: Biodiversity in New Developments

 

·             Bring forward Green and Blue Infrastructure and Green Belt SPDs to support the protecting policies.

·             Add a sentence to ensure that existing wildlife corridors are protected.

·             Change the number of houses where net increase was applicable from 25+ to 4+.

·             It was requested that a policy be introduced to prevent specifically the use of chemicals for site clearance prior to sowing.  Alternatives were being sought.

 

Policy P8/P9: Protecting Important Habitats and Species

 

·             Ancient Woodland should not be included in SANG measurement and should be ring fenced for protection.

·             Ancient and significant hedgerow protection should be included in this Policy together with a reference to the Hedgerow Regulations 1997.

·             Support was expressed for a blanket Tree Preservation Order in respect of all trees over a certain size.

 

Policy P11: Air Quality and Air Quality Management Areas (AQMAs)

 

·             Clause 1 of this Policy should state that development proposals must have regard to the need to improve air quality and reduce the effects of poor air quality.

·             Although the possibility of introducing a Borough wide AQMA focusing on the A3 corridor was raised, there was a view that AQMAs were ineffective in improving air quality.  However, as there was an opinion that an increase in the number of electric vehicles could gradually assist with the improvement of air quality in the future, it was requested that the Council develop a policy to actively promote the installation of charging points in new build properties to encourage and facilitate the use of electric vehicles.

·             As the wording of this Policy was considered to be ambiguous in terms of granting planning permission in respect of new developments with garaging and driveways owing to their likely contribution to air pollution, it was suggested that the wording was reviewed.

·             In view of the expiry of the Council’s Air Quality Strategy next year and limited officer resources to progress this matter, it was suggested that an EAB task group could be established to support the officer team to deliver a new strategy.

 

Policy P13: Sustainable Surface Water Management

 

·             The words ‘expected to’ and ‘likely’ should be deleted from this Policy in recognition that climate change was already occurring.

·             There was a need to address construction water run-off in the Policy.

 

General Point

 

·             All Policies featured in this Chapter could be strengthened by increased interlinking.

 

Design Chapter

 

Policy D4: Achieving High Quality Design and Respecting Local Distinctiveness

·             The Council’s Residential Design Guide (2004) required updating.

·             A  Borough Character Study should be brought forward in this regard.

·             Local Design Codes needed to be introduced.

 

Policy D5: Protection of Amenity and Provisions of Amenity Space

 

·             There was a need for a net increase in open space rather than a loss.

·             Introduction of a standard for external space per dwelling, similar to current internal space standards, to include private amenity space, separation distances and delivery spaces was welcomed.

·             There was a requirement to ensure new developments had sufficient amenity spaces.

 

Policy D8: Public Realm

·             The addition of pocket parks to the public realm was sought.

Policy D9: Residential Infill

 

·             Owing to related concerns, a written response to explain the difference between limited infilling in the villages and infill development was offered by Councillor Jan Harwood and accepted.

·             As key concerns and issues were not addressed, the possibility of establishing an Infilling Task Group to consider this matter in depth and deliver solutions was considered.

·             A requirement for a Design Guide and Design Codes in this respect was identified.

 

Policy D10: Noise Impacts

 

·             Remedies and enforcement of this Policy was queried.

·             The issue of noise pollution stemming from the A3 trunk road should be considered alongside associated air quality issues.  It was requested that the Policy be diligently enforced.

 

Policy D10a: Light Impacts

 

·             The issue of light impacts needed to extend beyond the Area of Outstanding Natural Beauty (AONB) and include general rural areas.

·             Point 6 in the Policy needed to cover the whole of the AONB and other sensitive and rural areas supported by Neighbourhood Plans.

 

Policy D11: River Wey Corridor

 

·             The need for a Borough Character Study in this regard was identified.

·             The tightening of wording to ensure that developments reflected the landscape setting of the river was sought.

 

Policy D12: Sustainable and Low Impact Development

 

·             The suggestion that the Climate Change Board review these types of development prior to the Regulation 19 consultation was agreed.

 

Policy D13: Climate Change Adaptation

 

·             The Climate Change Board should review this adaptation Policy before the Regulation 19 consultation took place.

 

Policy D14: Carbon Emissions from Buildings

 

·             It was agreed that the Climate Change Board review carbon emissions from buildings prior to the Regulation 19 consultation.

 

Policy D15: Renewable and Low Carbon Energy Developments

 

·             It was agreed that the Climate Change Board should also review Policies D12-15.

·             Urgency in language in paragraph 3.161 was needed to assert that Climate Change was currently happening.

·             Reversal of language such as “if possible” to compel the applicant to prove why sustainable measures were “impossible”, was requested.

·             Concern was expressed around the “biodiversity” definition if the Council continued to allow glyphosate usage.

·             Given the urgency of Climate Change, these policies were highlighted by various councillors as requiring strengthening, greater ambition and tighter definition.

·             More active promotion and requirement of policies was sought, e.g. requirements on electric vehicle parking in new homes.

·             Linkage should exist between Air Quality and Climate Change policies.

·             It was emphasised that the Climate Change Board needed to review this Policy before Regulation 19 consultation, as agreed.

 

Policy D18: Conservation Areas

 

The Conservation Area Character Appraisals should be brought forward and consideration be given to the appointment of a graduate resource to take the work forward.

 

Policy D20: Non-Designated Heritage Assets

 

·                  The last sentence of paragraph 5.355 of the draft Local Plan should be deleted as it was considered to be superfluous and discouraging.

·                  There was a need to strengthen the language in paragraph 3 (page 171 of the draft Local Plan document) and explain the mechanism for accepting suggestions for non-designated heritage assets nominated by other parties.

 

Infrastructure Chapter

 

Policy ID5: Protecting Open Space

 

·             This Policy needed to be strengthened and aligned with Policy D5: Protection of Amenity and Provision of Amenity Space to avoid the loss of open space and community facilities.

 

Policy ID6: Open Space in New Developments

 

·             There was a wish for current provision to be increased (reference comments on D5).

·             Concern regarding the long term management of open space, especially for affordable and shared ownership homes, was expressed.

 

Policy ID8: Community Facilities

 

·             Current provision needed to be increased (reference comments on D5).

·             A standard of delivery should be set.

 

Policy ID10: Achieving a Comprehensive Guildford Borough Cycle Network

 

·             It was felt that this Policy was weak and should place a greater emphasis on cycling and prioritise it to ensure delivery of cycleways catering for all types of cyclists by developers to achieve modal shift and use of the Sustainable Movement Corridor.  Further clarity was required in relation to what constituted an acceptable cycle route in terms of safety and speed limits etc.  There were concerns that many of the Borough’s roads were too narrow to accommodate both vehicles and cycles and therefore separate Borough-wide routes were required.  It was requested that the legibility of the map at Appendix A be improved through colour coding and designation of cycle routes prior to the Regulation 19 consultation.

 

Policy ID11: Parking Standards

 

·             The 2011 data should be updated on the release of 2021 Census information as a Main Modification.

·             As parking standards set out in this Policy related to local but not district centres, it was requested that the latter be added to the Policy.

·             The tables relating to public houses should be adjusted to treat them as restaurants for the purposes of parking provision as a retention measure.

 

Draft Parking SPD

 

Policy ID3: Sustainable Transport for New Developments

 

·             With regard to this Policy of the Local Plan Strategy and Sites document, on which this SPD provided policy guidance, concern was expressed that the low levels of off-street parking suggested was likely to lead to issues with parking on streets and pavements.  A practical approach to enforcement was required to prevent roads from becoming impassable.  A written response from a transport perspective would be circulated to the EAB by e-mail.

 

General Points

 

·             A Project Plan must be produced and resource allocated for the preparation of SPDs.

·             Monitoring Indicators needed to be broadened to include specific measures rather than rely on appeal outcomes.

 

Officers were thanked for the considerable time and effort they had invested in preparing the draft Local Plan documents to date.