1.  INTRODUCTION

  The evidence I am submitting is from a Surrey perspective and refers particularly to the Guildford and Woking Districts.

  CPRE Surrey objected strongly during the public consultation process to both the first draft Surrey Structure Plan (which has now been withdrawn) and the subsequent draft Surrey Spatial Strategy, which took account of the Government housing allocation for the county of 35,400 during the period 2001 to 2016. Both of these documents were published earlier this year by the Surrey County Council (SCC).

  The draft Surrey Spatial Strategy proposed that three new communities of 2000 houses each be built on Green Belt land to the NW and NE of Guildford and to the South of Woking. This was the only Green Belt land to be taken for housing in Surrey. Both Guildford Green Belt sites had been proposed for development in the past and turned down for a range of good reasons, which are still applicable. These earlier planning decisions were the subject of Appeals, which were discussed following Inquiries.

  Both Guildford and Woking would also be allocated under the Strategy a "baseline housing distribution" of 2,150 and 2,350 houses respectively, presumably to be located on previously developed urban land and building sites.

  In addition, a further 7,000 houses were maintained as a "reserve" by Surrey County Council for eventual allocation across the county, again presumably including both Guildford and Woking.

  This meant that Guildford's housing total would be in excess of 6,150 houses and Woking's 4,350. We can assume, therefore, that the population increase for the two towns would be in excess of 20,000 and at least 300 hectares of Green Belt land lost.

  In determining their housing provision, SCC does not seem to have taken account of the 3,500 single unit accommodation, which is to be built for the use of students and teaching staff on the new second campus of the University of Surrey, which involves a further loss of over 60 hectares of Green Belt countryside.

  Further Green Belt erosion will inevitably result when the Highway Agency announces its proposals for improvements to the A3, and related Park & Ride provisions are made for Guildford.

  The impact of proposed development on such a scale would be enormous on the quality of life of Guildford and Woking residents, on the character and sense of place of the two towns, and on the sensitive countryside between them. It will increase traffic congestion dramatically, and will add to the burden on the already stressed medical, educational, social, and transport infrastructure.

  Both Guildford and Woking Councils have told SCC that they must think again, and this they have undertaken to do. A new draft Structure Plan is expected to be made public by the end of the month.

  In the meantime, Guildford Borough Council (GBC) has had its Local Plan held up by the Government Office for the South East (GOSE), which is insisting that a clause must be included which requires the strict application of a minimum housing density for development of 30 houses per hectare on sites above 0.2 hectares. This goes beyond PPG3 which only calls for this density rule to apply to sites of 0.4 hectares. The GBC will meet to decide how to react to this proposal on 5 November.

  CPRE Surrey deplores the over promotion of land-hungry economic growth and commercial and business expansion for Guildford and West Surrey, a process in which the SCC has played a significant role. CPRE Surrey recognises that the SCC has been under a great deal of pressure from a number of business-orientated organisations in this respect. It is this encouragement of market forces, which is generating unsustainable housing demand, which either leads to erosion of the Green Belt or some degree of town cramming. CPRE argues that there is a capacity limit beyond which the environmental and social cost to the community of further economic expansion is too great. The question before us is what value do we place on the heritage and character of our West Surrey towns and the beautiful countryside around them. CPRE wishes to enhance and protect the town and country environment and landscape rather than see it damaged and destroyed by the urban sprawl and linear development, which was so characteristic of much of Surrey's housing growth before the Green Belt was introduced.

2.  HOUSE BUILDING, HOUSE PRICES, & AFFORDABLE HOUSING

  An article in the Surrey Advertiser of 11 October states that first time buyers in Guildford have to pay £130,000 to £160,000 for a one bedroom flat. Similar accommodation in Godalming costs £120,000 to £140,000, in Cranleigh £125,00, in Haslemere £115,000, and in Woking around £130,000. Surrey villages can be even more expensive with Shere at £160,000 to £170,000.

  However, The Times of 1 November suggest that price rises may be past their peak in the South East as the economy cools down. With fewer buyers chasing more houses, price rises could flatten out in some areas and even fall on more expensive larger properties. There is some evidence in Surrey of cutbacks in staff and postponement of office building projects which suggests that a slowdown may be taking place. There is traditionally also less activity during the winter months.

  The reasons for these high prices are the attractive location of West Surrey with its proximity to London, Gatwick, and Heathrow, the development of local employment through business, higher education, and other commercial expansion, the ready availability of cheap mortgages and interest rates, the appeal of living in semi-rural countryside with all the advantages of urban lifestyle, the "second home syndrome," the "buy-to-rent phenomenum," the attractions of investing in property at a time when the stock market and other sectors are highly insecure, and finally the movement of people to Surrey because of its prosperity and numerous job opportunities in comparison to other parts of the country.

  A number of other specific factors will affect the Guildford housing market in the near future such as the huge expansion of the University of Surrey, a project included in the Guildford Borough Local Plan, which as mentioned earlier is now at the final stage of adoption seeking approval by GOSE. Even with a second campus provided with accommodation for some of the extra students and teaching staff, this development will lead to the demand for cheaper housing to increase significantly as University growth creates additional lower paid jobs for support staff, in a town where there is virtually no unemployment, and employers are desperately seeking to fill these kinds of vacancy already.

  It is interesting to note that Surrey was the only shire county in the South East to build more houses in 2001 than the RPG9 figure. Unfortunately, the houses built by developers have not been of the right type to meet existing need, being mainly 4 or 5 bedroom executive homes on which profitability is greatest. Small dwellings and affordable single unit accommodation have become increasingly scarce as a result. This situation has been made more severe as owner occupiers are investing heavily in extending their homes to make their properties larger and accordingly increase their value.

  Reliance on developers to provide plans for mixed development on major urban renaissance sites in Guildford has not worked as yet. The Guildford Borough Council has rightly decided not to allow planning applications to go forward for Phase 2 of the Friary development, and for sites at the Civic Hall, and the Railway Station unless they include mixed development with a major element of affordable accommodation.

  CPRE Surrey believes that the centre of the town should be a vital and vibrant heart of the community where people choose to live because attractive housing is available of good design, which is close to employment vacancies. The town centre should not be reserved exclusively for commercial and business development which is only alive during the daytime. Delays in developing the town centre over the years and the over-supply of office accommodation has exacerbated the Guildford housing shortage.

  CPRE Surrey supports PPG3 but believes that it needs to be implemented on a local basis with sensitivity in order to protect the high quality of the residential environment and the rural countryside. The strict application of a rule requiring a minimum density of 30 dwellings per hectare on sites above 0.2 hectares could be very damaging if applied mindlessly without due attention to conservation areas, town and village character, and sense of place. National guidance of this kind has to take account of local community opinion and knowledge. The loss of open space and green neighbourhoods, adjacent too settlement boundaries bordering the Green Belt and designated countryside such as the Surrey Hills Area of Outstanding Natural Beauty (AONB), would be highly regrettable. Attention has also to be given to county designations such as Areas of Great Landscape Value where one unwise development can ruin large tracts of open countryside and views from AONB land.

  We have been pressing the Guildford Borough Council to publish a Supplementary Planning Guidance which will help to ensure that officers work with PPG3 in a coherent way rather than interpreting it in a subjective or too inflexible manner. We also support the Countryside Agency initiative to encourage rural communities to adopt Village Plans, designed to encourage local involvement in decision making.

  One of the main issues to be faced in the threat to houses of character which add distinctiveness to a community neighbourhood but are not necessarily listed. Both PPG3 and the Surrey Design Guide recognise the need for townscape quality and neighbourhood character to be protected, but this is a matter for careful interpretation and judgement, which bitter experience suggests is not always present. Developers are inclined to pull down older properties dating back to 1900 and even earlier, and to replace them with high density housing which does not fit well with the surrounding neighbourhood and is of poor design sensitivity. There is a feeling in Guildford also that developers do not always fully honour the "gain" commitments they have made in terms of infrastructure provision (for example, the sites at St Luke's Hospital, and Queen Elizabeth Barracks).

  The SCC argues that their proposal to put 6,000 houses on Green Belt land between Guildford and Woking is the direct result of the Government's increased housing allocation to Surrey above the original SERPLAN proposal. The urban capacity study undertaken to date across Surrey has apparently been unable to discover sufficient brownfield sites to permit development without encroaching in this way onto greenfield sites. CPRE maintain that this study needs to be done much more rigorously, and we understand that this work is now being undertaken. The sequential approach to land use is for CPRE Surrey one of the most important aspects of PPG3.

  The SCC proposal to erode Green Belt land has the support of developers who favour the use of greenfield sites for house building. This change in the SCC approach is in direct conflict in our opinion with current national, regional, county, and borough policy. Unfortunately, SCC also continue to emphasise the need to rely on the developer to provide "gain" as a means of obtaining affordable housing. This means in practice that the developer will build at least two executive homes for each affordable house resulting in a totally unacceptable level of land-take from the countryside.

  CPRE argues that one of the major reasons for the current affordable housing shortage was the sell-off of Council homes. The policy of a "right to buy" is still in place. This has increased property ownership and because of the rise in house prices it has encouraged a far wider selection of the population to go for house acquisition as a means of wealth accumulation than previously, and depressed the number of those who would have formally rented property for their housing needs.

  CPRE Surrey urges the Government to allow the release of the funds held by Guildford Borough Council (approximately £30 million) which were made from Council house sales so that this money can be invested into affordable housing projects. Guildford Borough Council already owns an extensive amount of land at the town centre.

  CPRE Surrey also urges the Government to investigate what can be done to amend the current policy of selling off MOD, NHS, and other publicly owned land to obtain the maximum return as this leads to further executive home supply and impedes affordable housing provision.

3.  FORECASTING FOR THE COUNTY AND THE REGION

  CPRE Surrey believes that much of the forecasting which predicts economic expansion in the South East was prepared during a period of boom. It seemed to have a flavour of "predict and provide" about it, which we had believed was discredited as an approach. This, of course, influences the housing forecasts now being reviewed. We continue to favour a policy based around the concept of "plan, monitor, and manage".

  Our understanding is that the SEERA Housing Advisory Group is at present preparing a monitoring study which will be published in November which will cover work being done on demographic and housing projections, land supply, housing availability and type, urban capacity studies, and affordable housing.

  Reviews of the 1996-based household projections have revealed that household formulation has been much lower than expected. It appears that Public Examination of RPG9 in June 1999 was correct in suggesting that forecasts of household formation were only broad indicators and should not be followed slavishly.

  It would seem wise, therefore, to check whether current forecasts are reliable now that the economy has slowed, especially as an analysis of up-to-date figures is expected from the Regional Assembly's Housing Advisory Group. It will also be possible to take account of new data from the 2001 census soon.

  For whatever reason, the forecast need for small dwellings, affordable housing, and single unit accommodation has not yet been met. On the other hand, the proportion of new large detached houses of four bedrooms or more has risen from 20% 10 years ago to 40% of the total housing supplied. In other words, the house building industry is not supplying what the cheaper market requires, but rather the sector which is most profitable for them to supply.

  It appears that there is a strong case for many planning issues to be reviewed on a Regional rather than a County basis. Questions relating to water, power, environment, waste and housing all cross boundaries. Problems relating to long distance commuting, Surrey's involvement with the through traffic of the "gateway to Europe," and its proximity to London also make County decision making difficult.

  When it comes to housing, it is common sense that what happens in Aldershot, Crawley, Croydon, Horsham, and the Southern suburbs of London will be of significant importance to Surrey's environment in terms of traffic congestion, pollution and a host of other factors. Building on neglected brownfield sites in South London may be a far more intelligent use of land than plundering the countryside for housing elsewhere. Developers will naturally press for the release of greenfield sites because it is cheaper for them to build there rather than on contaminated urban land, which nonetheless should have priority to be cleaned up before countryside is concreted over for ever. It is important to equalise the playing field as regards VAT to remove the discrimination in favour of new housing on greenfield sites.

  CPRE Surrey believes that the allocation of extra housing decreed by central government has been a divisive process for the SE counties and within Surrey itself as Councillors seek to defend their own patch. Community consultation has clearly shown that the residents of West Surrey are staunchly behind the Green Belt and that the failure of the SCC to recognise this has undermined their credibility in Guildford.

4.  NATIONAL CONSIDERATIONS

  CPRE Surrey is aware of the SEEDA involvement with the task of rejuvenating areas in the Region which have suffered from economic decline and social neglect. It is our view that this same approach should be followed on a National basis over the whole country. We fully support the proposals made in the CPRE report "Even Regions, Greener Growth" (published February 2002) which argues for a more balanced development across the UK to take pressure off the over-heating South East. We believe that it is necessary to encourage investment and economic growth for areas which are in need, and have the environmental capacity to accommodate it. We do not believe that the South East Region should be promoted and sold to the extent that its countryside, character, and distinctiveness is destroyed in the process by over development. We also wonder whether it is wise for Regions to compete for investment one against another when national policy objectives may require other priorities to be taken into account, which reach beyond market forces.

  It is our proposal that a full scale review is made of land owned and occupied by national government departments and agencies in Surrey to see whether it is essential that the various activities based in the county need to be there or whether they could be relocated to other areas of the country better able to accommodate them. In particular, it would be good to know when the MOD finally intends to publish its land use plans for the future.

5.  CONCLUSION

  CPRE believes that the proportion of homes which are vacant in Surrey is virtually nil. It would be useful to make a survey to see what office space is available in comparison. There is certainly plenty for rent in both Guildford and Woking.

  There has been much talk of "smart growth" from the business community and of future working from home. This implies that economic expansion is possible without occupying more land space. Measures could therefore be considered to discourage further office development and to consider change of use to provide more affordable single unit accommodation on land which becomes available of is under utilised for commercial and other employment.

  The emphasis on Guildford and Woking is unbalanced. Growth as envisaged in the draft Surrey Spatial Strategy would significantly alter the settlement pattern. It does not seem to take any account of other towns such as Leatherhead which are in decline and need renewal and rejuvenation.

  The cumulative effect of PPG3 in the Region needs to be monitored by SEERA. The information CPRE has at its disposal suggests that the average density on sits allocated in local plans for the SE is 21.4 dwellings per hectare. For those sites completed, the figure rises to 25.5 dwellings per hectare. Marginally higher still is the average for sites with planning permission at 26.3. This suggests that densities are increasing as a result of PPG3 as sites progress through the planning and development process. There is still, however, a very long way achieve PPG3 targets across Surrey. It would certainly be premature to sacrifice Green Belt countryside in the manner proposed by SCC in their draft Spatial Strategy at this stage.

  The challenge will be for local authorities to ensure that PPG3 is implemented in a sensitive manner so that Surrey towns like Guildford do not lose their character and distinctiveness. The opportunity is for good design and planning to enable higher density housing to be introduced of such high architectural quality that it enhances the town landscape as part of an urban renaissance and revitalisation, which provides affordable accommodation at the town centre, which is attractive to live in.

Tim Harrold

2 November 2002