Our Residents Association lies between two arterial routes into the centre of Guildford. We are relatively central, with many residents able to walk when going about their business. Housing is a mixture of Victorian, Edwardian and more modern family houses, some with larger gardens, and of flats and conversions. Our neighbourhood regularly reaches a state of gridlock due to two local schools.

  We are particularly keen to draw the Committee's attention to the need for safeguards to retain local character within towns and ensure change is for the better. We suggest that because policy has been largely driven by the desires to avoid urban sprawl and to provide housing, the need for the flexibility to respect the character of each town may not have been given sufficient attention. It would be unfortunate if the legitimate desire for an "urban renaissance" in practice destroyed the qualities that make urban living good in many neighbourhoods.

  Our Association has a reputation for taking a wider community focus.

—  We have actively supported the local campaign to resist urban expansion into the Green Belt around Guildford even though we are a town centre association and do not abut the Green Belt.

—  We appreciate the need to increase the availability of affordable housing. (We have resisted a major shopping centre expansion saying we need central small housing units instead.)

—  We encourage initiatives to reduce car use.

—  We do not oppose the principle of increasing the density of development in urban areas.

  However, when it comes to putting higher urban densities into practice, we are deeply concerned that the tools and powers needed to deliver this without harming the environment and quality of life in our towns are not in place. We fear that a highly prescriptive and centralised approach will prevent Local Authorities from being able to increase housing densities in a manner consistent with the character of a particular town or city.

  Already, in the light of the drive to increase urban densities as set out in PPG3, our neighbourhood is changing significantly. Supplementary Planning Guidance that has been relied upon to shape change in our area has been withdrawn with no Design Guidance in place to succeed it. We are left with no planning vision for our neighbourhood at all. The face of our community is being determined by the quirks of where developers can buy plots and make the highest returns by intensifying most. The precedents are being set before any locally accountable consultation has taken place on what type or style of high-density development is most appropriate in our town and each neighbourhood.

  Our submission addresses the Committee's specific questions, focusing on the issue of protecting urban character and also on the housing allocation proposed for Guildford.

THE OVERALL SCALE OF HOUSEBUILDING REQUIRED

  The increased housing allocation for Surrey has not been based on an assessment of need and alternative means of meeting any proven need. Nor has it been based on any assessment of capacity or a strategic environmental impact assessment. We find the overall focus on growth in the South East disturbing and totally at odds with Sustainable Development and social and economic equity.

ARE THE PROPOSALS LIKELY TO SIGNIFICANTLY REDUCE HOUSE PRICES

  The proposals are not likely to reduce house process in Guildford. Homes are built in the name of a local need. In practice people with London salaries and often the profits from London property sales move in to take up much of any new housing (including smaller units), keeping prices in Guildford high. The instruments the Government is relying on to provide more affordable housing for local people are too blunt. Most of the new homes proposed for Guildford will sell at prices bolstered by the London market and the increased population will add to the pressure for services and congestion and increase the need for key workers who will still be squeezed out of the local market.

THE GEOGRAPHICAL DISTRIBUTION OF NEW HOUSING, INCLUDING PLANS TO CONCENTRATE DEVELOPMENT

  The proposal by Surrey County Council to concentrate so much of Surrey's allocation in the Guilford area appears to be based on two troubling factors:

(i)  The relative power base of Councillors in various parts of the county.

(ii)  The argument that areas closer to London have already been ruined by town cramming and Green Belt fragmentation, so it is necessary to move on and do the same to the next zone out from London.

  The Draft Surrey Spatial Strategy would result in about a 24% increase in the population of Guildford. The scale of the changes proposed was not even made explicit. Inadequate thought has been given to the social and planning implications of such a radical increase in Guildford, which already suffers from strained services and terrible congestion. Geography is a vital factor because Guildford is confined to a small gap in the Downs, constrained by the Surrey Hills and the flood plain of the River Wey. A fundamental principle of Sustainable Development is the need to recognise that there are limits to growth.

  We are not resistant to change but the scale of expansion in Guildford proposed by Surrey's Spatial Strategy could not be accommodated by sustainable redevelopment of the existing town. The challenge would need to be shared among the county's settlements. Equally the housing stock is needed across the county. What good does it do someone in Addlestone if the housing reserve there is removed and housing is built instead in Guildford?

WHETHER THE PROPOSALS WILL PROMOTE HIGH QUALITY SUSTAINABLE COMMUNITIES WHILST AVOIDING POORLY DESIGNED URBAN SPRAWL

We ask the Committee to give attention not just to the dangers of poor quality urban sprawl but also to poor quality urban infill and cramming

  We fear that the density policy is being applied in too prescriptive a way. Only by giving greater discretion over application to Local Authorities can sufficient account be taken of how density changes would impact in practice on very diverse towns. (See final section)

PROPOSALS FOR NEW MILLENNIUM VILLAGES

  Although we do not advocate it, we would prefer to see a new self-reliant settlement in Surrey, built using the best available environmentally friendly practices, than inappropriate over-expansion of Guildford. However, if the Government persists with its higher housing figures, new settlements could be more acceptable than over expansion and inappropriate cramming of existing congested towns. More environmentally friendly approaches to materials, transport, drainage, energy and heating could be designed in from the start and for the whole community.

  Our preference would be for some appropriate redevelopment throughout the county to increase the proportion of smaller and more affordable housing stock, especially in schemes where the scale of the plot allows for good design. This is with the very strong proviso that the Borough Council has the power and freedom to determine the location, scale and character appropriate for any new higher density schemes to ensure they add to rather than harm the character of towns such as Guildford and of existing neighbourhoods within each town.

THE BALANCE OF NEW DEVELOPMENT BETWEEN HOUSING FOR SALE AND SOCIAL HOUSING

  The only mechanism for affordable housing being offered locally is to allow development of market homes on land that should not be developed (Green Belt) in order to get a small proportion of more affordable housing. It should not be necessary to build on inappropriate land. Also, in reality, "affordable housing" schemes provided under planning gain deals seem to increase the demand for service workers (who can't afford housing) more than they increase provision of key worker housing.

  If rigorously assessed housing need is for a particular type or size of property, and development in a particular location has been proven to be the best option, Councils should be able to ensure plans specify the nature of development required. These decisions should be taken by Local Government and be based on local community plans.

  We ask for our Council to be able to invest the money it received from council house sales on new affordable and environmentally friendly housing. We are shocked that this money has sat in the bank for so long and could now be spent elsewhere in the country rather then being used to tackle enormous local housing pressures.

  We also suggest that the Council is given the power to create a new reserve of Council Houses, which would be available as such in perpetuity. To avoid a dependency culture, we suggest tenants should be able to pay into a housing fund scheme that would enable them to gain a foothold in the private housing sector once they had saved up enough. The home they lived in while they were saving would remain the property of the Council. Unless the finances and the home are "decoupled", affordable housing needs constantly replenishing in a way that cannot be sustained.

THE EXTENT TO WHICH DECISIONS RELATING TO HOUSING, INCLUDING NUMBERS, TENURE AND DENSITY, SHOULD BE TAKEN BY CENTRAL AND LOCAL GOVERNMENT

  We are very worried that decisions on how to increase urban densities are being taken out of local hands by Government. In Guildford, GOSE is advocating a blanket approach wishing to apply the "30 to 50 dwelling to the hectare guidance" to any site over 0.1 of a hectare. It is denying the Council the option to decide how it achieves increased densities. For example, the Council might decide that it would be more environmentally acceptable to work to lower densities in some streets, neighbourhoods or even plots to retain the character of an area. Equally densities might be very high in some innovative larger schemes designed from scratch with high-density ideas in mind.

  Examples such as Bath are often cited to show that high-density urban design can be beautiful and desirable. It seems very relevant that you need a significant size of plot to achieve this kind of effect. You wouldn't get the same effect by sticking two/four Bath houses on every plot that came available between existing houses in Guildford! We suspect that it will often be easier to come up with attractive high density designs on a blank canvas than to slot developments into a townscape that was designed with different objectives in mind.

  Local evidence suggest that local authorities do not have the necessary freedom or policies in place to determine circumstances in which densities might best be increased by

(a)  scattering higher density schemes throughout a neighbourhood as commercial opportunities arise or

(b)  focusing higher densities in specific areas.

  We fear that the Government's prescriptive approach will deny local authorities the flexibility to respect the varying character of their local urban environment.

  There is currently no vision for a higher density Guildford.

  Will roads with terrace/compact houses remain unaffected because occupation is in too many hands and individual plots are too small or do we want lots of upstairs/downstairs flat conversions?

  Will roads with larger houses be the focus for redevelopment because individual plots offer commercial returns?

  Will all streets have a mix of flats and family houses if culs-de-sac are out of favour? Will some roads/neighbourhoods retain larger family houses while others become predominantly flats, thereby reducing overlooking problems and retaining the integrity of design of a few areas with character features?

  Will flat redevelopment be focused along bigger roads making the approaches into Guildford appear significantly more urban and high rise?

  Is there any scope for retaining the green character of much of Guildford by developing in a very innovative way at very high density at a few bigger sites? Would the Council have the power to achieve this?

  We await answers as to how these questions are to be considered but in the meantime, in practice, things are being decided by where developers are buying plots for redevelopment in Guildford.

  Councils need a streamlined, yet consultative, system for updating the relevant parts of their Local Plans to take account of the new thinking on increasing densities. Otherwise, Councils and communities will be powerless to shape the early applications that will set the precedents for higher density development.

  We also suggest Government Guidance is needed to make it clear that developers and councils should find ways of increasing the densities overall without destroying the character of well established neighbourhoods that are a greatly valued legacy and often embrace mature trees. We hope that it could clarify that, in advocating higher densities in towns, Government is not advocating "cramming" that harms the character of urban communities. It would be useful if a quality rider could be made whenever Government urges increasing urban densities such as "in a way that respects and enhances the character of towns and cities".

  We submit that it is not "sustainable development"

—  to allow crammed infill to harm residential areas that we inherit from previous generations and that are highly valued for their design, architecture, landscaping and greenery;

—  to work to the same development density in every town or in every part of every town. Some have a more high-rise, cosmopolitan character. Others have a more open, almost more rural character;

—  to advocate blanket density polices that do not allow local authorities to ensure change values the natural and built environment in each neighbourhood.

  The Government has said it will call in applications where the density is not high enough. We ask whether the safeguards are equally in place to ensure Local Authorities can refuse high-density development where this would harm the character of a neighbourhood. Will the appeal system be so preoccupied with density that planning authorities will be fearful of making judgements whether a high-density proposal is appropriate in specific circumstances?

  Has any work been done to assess whether inappropriate higher density development is likely to be more readily resisted in villages than in towns resulting in retention of more larger family houses with gardens in villages than in towns? Over time, what would the consequences of such a trend be for the socio-economic distribution of the population between town and country? (cf. experience of new towns like Hemel Hempstead.)

  We hope that the Committee can facilitate speedy refinement of the way higher density guidance is applied. Failure to do so would result in irreversible harm to the best of our urban heritage and fritter away rather than build on many of the successes of our planning system.

8 November 2002