Response to Guildford Consultation Draft Local Plan · 15.09.2014 · Response to Guildford Consultation Draft Local Plan (September 2014) Exec 18. The Town Centre Vision consultation,

Response to Guildford

Consultation Draft

Local Plan

September 2014

Response to Guildford Consultation Draft Local Plan (September 2014)

Guildford Society Response to Consultation Draft Local Plan (draft4a) Summary Exec 1. The Guildford Society response comprises nine parts:

Exec 1.1. Answers to Questionnaire in the format provided by Guildford Borough Council (contained in the body of this response)

Exec 1.2. Policy-by-Policy comments on the Consultation Draft Local Plan (‘the Draft Plan’) (contained in the body of this response)

Exec 1.3. Schedule of specific responses to a selection of the site-specific policies (contained in Annex 1 of this response)

Exec 1.4. The Guildford Society LSOA Land Uses and Statistics Report (Contained in Annex 6 of this response)

Exec 1.5. Paper on the discrepancies between the SHLAA and the Draft Plan (contained in Appendix 1 of this response)

Exec 1.6. Copy of Guildford Vision Group response to the Sustainability Appraisal (22nd January 2013) (contained in Annex 2 of this response)

Exec 1.7. Copy of Response to Issues and Options Consultation (29th November 2013) (contained in Annex 3 of this response)

Exec 1.8. Copy of Response to the Draft SHMA (20th February 2014) and Population Analysis since which time no meaningful amended SHMA has been forthcoming (‘the Draft SHMA’) (contained in Annexes 4 and 5 of this response)

Exec 1.9. A suite of Position Papers prepared (and as yet unpublished) by the Design & Heritage Group of the Guildford Society (contained in Appendix 2 of this response)

Exec 1.10. A summary of the background and constitution of the Guildford Society (contained in Appendix 3 of this response)

Exec 2. The Guildford Society in our response to the Consultation on the Draft Local Plan which runs from 1st July to 22nd September 2014 (‘the Consultation’) have set out to be objective and, whilst there are clearly areas of grave concern, positive and constructive.

Exec 3. The Society is particularly concerned, however, that the Local Development Scheme does not provide for further material engagement after the

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Consultation – the next stage simply being to comment on the soundness of the Draft Plan.

Exec 4. The Draft Plan is currently not sound for the reasons provided in our response among others, and so there are many elements of the Draft Plan which we would expect to change significantly and substantially between the Consultation and the pre-submission draft.

Exec 5. The Guildford Society does not agree, for example, that a Local Plan should pre-date its adoption by as much as five years, a quarter of its nominal life, and that much of the evidence is of a similar age. This is particularly troubling in the context of the current draft because we are currently operating on the basis of a housing target of 322 dwellings per year, but we will be deemed to have a shortfall prior to adoption for five years from 2011 to 2016 against a plan target of 652 dwellings per year – an effective administrative deficit of 330 dwellings per year amounting to a total administrative shortfall of 1,650 homes before we even begin to implement the new plan.

Exec 6. The Vision for the borough in the Draft Plan are simply not cohesive or exciting enough and need to be reworded to ensure the strategic objectives flow from the vision and that the plan is constructed to deliver it:

Exec 7. The Guildford Society has suggested a rewording of the Vision as follows: Exec 7.1. Guildford in 2031 will be a sustainable town and borough which: Exec 7.2. Is a great place in which to be - to live, to visit, to work, to shop

and to study; Exec 7.3. Sits comfortably within its green belt surroundings, protected from

uncontrolled expansion; Exec 7.4. Has substantially improved traffic, transport, technical, physical,

educational and health infrastructure; fit for the mid-century and supporting life, work and play in and around the town and borough;

Exec 7.5. Allows excellent development that respects its context, heritage, arts and cultural diversity;

Exec 7.6. Has a thriving economy centred around knowledge businesses and other established sectors as well as attracting new forward-looking businesses;

Exec 7.7. Has village communities which are able to accommodate organic growth;

Exec 7.8. Has a town centre and district centres that function exceptionally well;

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Exec 7.9. Provides effectively for those who are less well-off through affordable housing, ample employment and leisure activities;

Exec 8. The construction of the Local Plan is cumbersome in two particular ways: Exec 8.1. Having two separate documents (Strategy & Sites and Delivering

Development) will make the interpretation of each of the policies difficult. In this consultation, however, the absence of the Delivering Development draft makes the evaluation of spatial policies particularly difficult.

Exec 8.2. The policies in the Strategy & Sites draft do not seem to be in a logical sequence and it is difficult to establish from the document how it will all work in practice.

Exec 9. The Key Facts section is a hotchpotch of data, information and narrative. This would benefit from a much more rigorous and complete summary and it would be helpful to reflect on this section at the end of the document to identify what changes we might expect when the plan is implemented.

Exec 10. The lack of consistency and the absence of impact assessment mean that a subsection like ‘Pockets of Deprivation’ and its single paragraph (2.4) refer to general relative comparisons at county and national level rather than picking out specific Local Super Output Areas (‘LSOAs’) where specific problems are particularly in need of resolution. There are no policies which explicitly set out to deal with resolving pockets of specific and particular relative deprivation.

Exec 11. The Guildford Society, as an annex to its response, has gathered some of the detailed data for all of the 84 LSOAs in the borough, and has highlighted particular issues. This analysis shows that some aspects of some of our borough’s LSOAs score in the most deprived 2.5% if all LSOAs in England.

Exec 12. At 2.6 the Draft Plan notes that “We do have a skills shortage in some sectors” but fails to note that we have a resource of young people with low/no skills as highlighted by the LSOA study. The Draft Plan should provide for both ends of the spectrum.

Exec 13. The section on Housing refers to the SHLAA and the Draft SHMA. The SHLAA and the Local Plan are not wholly consistent (we have included a summary of the inconsistencies at Appendix 1) and the noted shortcomings of the SHMA have not yet been resolved and make it difficult for us to fully respond to this consultation.

Exec 14. The Guildford Society makes its submission in this document on the basis that many of our findings may have to be adjusted as and when documents

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promised or provided as contended drafts are eventually provided. We would expect to have the right to make further representations in due course.

Exec 15. The section in Key Facts dealing with Infrastructure (a single paragraph 2.15) is woeful, of little benefit and contains no empirical facts.

Exec 16. This response includes policy-by-policy comments both in direct response to Consultation Question 6 and in a separate section in this representation

Exec 17. Appendix B – Infrastructure Schedule – is generally underwhelming and includes a significant proportion of measures which should already have been completed prior to adoption of the Local Plan. Exec 17.1. [summary of comments from GSoc Transport Group?] Exec 17.2. The Guildford Society specifically and categorically objects to the

proposal at 5.1.2 (New Junction with the A31 Hog’s Back) and wishes to see that wording deleted from the schedule.

Exec 17.3. At 5.1.4 the proposed Park & Ride on Blackwell Farm – if a business case can even be proven which, given the current usage of the Onslow Park & Ride, may not be positive – should link up with the proposed new rail station (5.1.5) rather than rely on road transport alone. No hard landscaping including Park & Ride should be constructed above the 90m contour due to the adverse impact on the landscape and setting for the Area of Outstanding Natural Beauty.

Exec 17.4. At 6.1.2, the proposed alterations to the A3 should be to provide for four-way all-movement access serving both Gosden Hill and Slyfield.

Exec 17.5. The SANG at 6.2.6 could occupy the entire land identified in the GBCS as Potential Development Area C2 on which the Guildford Society does not support any form of development.

Exec 17.6. At 7.1.1 the development of Wisley must include the conversion of the partial junction on the A3 at Ockham to a four-way all-movement junction which should also be configured to provide a dedicated access to RHS Wisley Gardens (to avoid traffic having to use the M25 junction as a turnaround) and should also enable the junctions between M25 and Ockham to be closed.

Exec 17.7. At 8.1.1 and 8.1.2, these proposed interventions should be thought through again as part of the proposals for a larger expansion of Slyfield set out in this representation.

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Exec 18. The Town Centre Vision consultation, also taking place at the same time, is welcomed by The Guildford Society. The response is due on the same date and there will inevitably be some crossover between the two responses. Exec 18.1. The Guildford Society’s response to the Town Centre Vision

Questionnaire is appended below at Vision-1 on page 101 Exec 19. [to be continued] Exec 20. Missing from the list of development sites in the Draft Plan are:

Exec 20.1. Tunsgate Square; and Exec 20.2. University Manor Farm development area

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Contents Guildford Society Response to Consultation Draft Local Plan (draft4) ........................................................................ 2

Summary ................................................................................................................................................................... 2

Contents ................................................................................................................................................................... 7

Questionnaire Responses ............................................................................................................................................. 8

Questions about procedure ...................................................................................................................................... 8

Policy-by-Policy Analysis ............................................................................................................................................. 36

Infrastructure Schedule – Appendix B .................................................................................................................... 94

Responses to Town Centre Vision Consultation ....................................................................................................... 101

List of Appendices ..................................................................................................................................................... 102

List of Annexes .......................................................................................................................................................... 102

Appendix 1 – SHLAA Analysis.................................................................................................................................... 103

Executive Summary .............................................................................................................................................. 103

1. Purpose of this Note ......................................................................................................................................... 103

2. Locations ........................................................................................................................................................... 103

3. Delivery between 2015 and 2031 ..................................................................................................................... 104

4. Planning for sites .............................................................................................................................................. 106

5. The SHLAAs ....................................................................................................................................................... 108

6. May 2014 SHLAA ............................................................................................................................................... 109

7. June 2014 SHLAA .............................................................................................................................................. 110

8. Summary ........................................................................................................................................................... 112

Appendix 2 – The Guildford Society Design & Heritage Position Papers ................................................................. 113

Background to position papers prepared by the Guildford Society ..................................................................... 114

Good design - eight points to help ensure good design and future heritage creation – a position paper by the Guildford Society .................................................................................................................................................. 116

Preserving and enhancing the approaches to Central Guildford – a position paper by the Guildford Society ... 118

Preserving and enhancing Guildford’s historic High Street – a position paper by the Guildford Society ............ 120

Preserving and enhancing Guildford’s residential heritage – a position paper by the Guildford Society ........... 123

Enhancing Guildford’s riverside – a position paper by the Guildford Society ...................................................... 125

Preserving Guildford’s vistas, roofscapes and skyline – a position paper by the Guildford Society .................... 127

Appendix 3 – The Guildford Society: Background and Purpose ............................................................................... 130

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Questionnaire Responses Questions about procedure Question 1: The evidence base

All Local Authorities should prepare a Local Plan for their areas. The draft Local Plan: strategy and sites document sets out how we can direct and manage development across the borough up to 2031, making provision for homes and employment and environmental assets. It is based on up-to-date evidence.

Evidence contributing to the preparation of the draft Local Plan: strategy and sites, is listed in Appendix C.

Do you agree that the evidence used for the draft Local Plan: strategy and sites is adequate, up-to-date and relevant?

Response: NO

Comments: Q1.1. The Guildford Society responded in great detail to the Issues and Options

Consultation and it is disappointing to note that few of our comments have been reflected in either the current evidence base or the Draft Plan.

Q1.2. Aside from specific policies in the Draft Plan, we have a particular concern over the completeness of the documentation and evidence referred to in the Draft Plan. One such key example is the Infrastructure Delivery Plan (‘IDP’) which has not yet been published: Q1. 2.1. The IDP is referred to in paragraph 4.11, Key Evidence for Policy 11,

Policy 17 and the following paragraph 4.208, and is listed as “Future Research” on page 145.

Q1. 2.2. The Guildford Society is adamant that, were a fully-scoped Infrastructure Delivery Plan in place prior to the final draft of the Consultation Draft Local Plan, there may have been many more references to it – not least in Policies 15 and 18 (Town Centre and Green and Blue infrastructure) – and more interaction with it in policy 17 (Infrastructure).

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Q1. 2.3. The IDP is referred to as part of the Evidence Base for the Site Specific policies in the section ‘Planning for Sites’ – described as a ‘key study’.

Q1. 2.4. The Guildford Society notes that Guildford Borough Council is not in control of large parts of its infrastructure, and that it relies on others to provide relevant and competent supporting information and planning.

Q1. 2.5. We also note that it has been the intention of Surrey County Council to prepare a new Local Transport Strategy for Guildford, but that this has been delayed to allow Surrey County Council to examine submissions on the Draft Plan. No pre-submission draft plan can be settled based on this consultation and the subsequent issue of key documents which would have a material impact on the responses given to this exercise.

Q1. 2.6. The A3 suffers major traffic problems – the spill-over from which causes gridlock in Guildford town centre and on many local roads. The A3 is managed by the Highways Agency (‘HA’), whose relevant strategy document (M25-Solent route-based strategy evidence report – April 2014) was not included in the evidence base and, whilst acknowledging that capacity on the A3 around Guildford is a key challenge, it makes clear that the HA has no current plans to resolve this constraint.

Q1. 2.7. Furthermore, EM3 (the Local Enterprise Partnership covering the Guildford area) has identified in its Economic Plan (2014-2020) – covering only part of the Local plan Period – three schemes which it will not be funding but which are critical to the overall success of the growth package: Q1. 2.7.1 A3-M25 Wisley Interchange Q1. 2.7.2 Guildford A3 Strategic Improvements Q1. 2.7.3 North Downs Major Investment Programme

Q1. 2.8. EM3 also identifies (but funding has not been assured) a strategic package for the A3 in North-East Guildford, and new railway halts at Merrow and Park Barn.

Q1. 2.9. The HA and EM3 strategic comments, coupled with the lack of any funding commitment, means that the infrastructure – already heavily overloaded – is a real and meaningful constraint on development

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unless resolved. This should be acknowledged and its impact fully assessed on the face of the Draft Plan – it is not.

Q1.3. We are annexing a further copy of the response to the Issues and Options Consultation for reference and to highlight that the provisions of The Town and Country Planning (Local Planning) (England) Regulations 2012: PART 6 - Preparation of a local plan - Regulation 18 (‘Regulation 18’) have not been observed in the preparation of the Draft Plan.

Q1.4. In summary, we have particular concerns in respect of: Q1. 4.1. The Infrastructure Baseline Report

Q1. 4.1.1 This does not provide any scope to conclude what capacity there is for Guildford to expand, what constraints are surmountable and which ones would be economically impractical to overcome.

Q1. 4.1.2 The shortcomings of this Report are intensified by the failure to prepare an Infrastructure Delivery Plan alongside the Draft Plan.

Q1. 4.1.3 Specifically, at 2.1.18 it says that the Highways Agency has no plans for the A3; this is totally unacceptable in the context of the scale of development proposed in the Draft Plan coupled with the scale of development occurring in Rushmoor, planned in Waverley and likely to take place along the A3 axis further south;

Q1. 4.1.4 Although 2.1.22 summarises the dire situation on both local and main road networks, few of these are addressed in the Draft plan and yet these are a severe constraint on development. Surrey County Council’s current policy (2.2.30) is that new infrastructure will only be considered where there is a strong business case or where there are gaps in the network – The Guildford Society contends that Guildford has substantial ‘gaps’ due to historic low investment levels.

Q1. 4.1.5 Whilst 2.2.26 notes that three infrastructure schemes will happen in 2014-15 there is no indication these will be carried out.

Q1. 4.1.6 The entire Infrastructure Baseline needs to be updated to include items shown in Appendix B which are shown to be in progress or committed. This could be achieved

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by way of an overlay rather than a new baseline document BUT other refinements need to be made as The Guildford Society identified in its response to the Issues and Options Consultation.

Q1. 4.2. The Green Belt & Countryside Report (‘GBCS’) Q1. 4.2.1 Whilst it can be argued that the GBCS sets out to identify

which parts of the Green belt are critical to the functions of the Green Belt (NPPF Section 9: Especially Paragraph 80), it rather perversely leads to a conclusion (particularly in the case of Blackwell Farm) that subsequent Local Plans would seek to expand the urban area westwards until almost reaching Wanborough.

Q1. 4.2.2 As such, the GBCS fails NPPF 83: “authorities should consider the Green Belt boundaries having regard to their intended permanence in the long term, so that they should be capable of enduring beyond the plan period”.

Q1. 4.2.3 The Draft Plan should have approached sustainable development from the opposite approach – where is the most practical place for development? – and then tested this against the GBCS.

Q1. 4.2.4 This might lead one to the conclusion, from a practical perspective, that extending Slyfield as far as Jacobs Well could provide a combination of sustainable transport and consolidated expansion of employment areas. The GBCS would then have suggested it would be inappropriate to develop the 200m strip of land between Slyfield and Jacobs Well.

Q1. 4.2.5 The challenge for the Local Plan would then be to establish the balance of benefit and harm, to understand what mitigation strategy should be employed and to draft policies accordingly.

Q1. 4.2.6 The methodology applied by Pegasus is in any event questionable for the purposes for which Guildford Borough Council has applied it.

Q1. 4.3. The Settlement Profiles Report

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Q1. 4.3.1 The responses provided by Parish Councils inform a substantial part of the Settlement Hierarchy forming the basis for the spatial planning of the Borough.

Q1. 4.3.2 No such consultation was carried out for the entire Guildford Urban Area (which, unlike the remainder of the Borough, has no lower tier of representation). This could easily have been achieved by sending out a similar questionnaire to the various Residents Associations.

Q1. 4.3.3 As a result, the Report is poor and fails to take account of the granular characteristics of the Guildford Urban Area neighbourhoods.

Q1. 4.4. Retail & Leisure Report Q1. 4.4.1 Although updated in 2011, this evidence is based on

2004/2005 data collected for the original report in 2006. Q1. 4.4.2 The nature of the retail sector has changed dramatically

– even since 2011 – and the report does not emphasise sufficiently the increasing component of retailing which is the leisure experience.

Q1. 4.4.3 The town centre absolutely has to become (during the Plan Period) the beating leisure heart around which the future of town centre retail can thrive.

Q1.5. Furthermore, the Draft SHMA is not generally considered to be a reliable document and has so far failed to take account of the revised Sub-Regional Population Projections (published 29th May 2014 by the Office for National Statistics) which show a reduction by one third in the rate of population growth between 2011 and 2021, and a slowing of growth annually thereafter. All of the Guildford Society analysis points to the draft adopted figure being unnecessarily high – with all of the development consequences that entails.

Q1.6. We are, therefore, annexing a further copy of the response to the Draft SHMA for reference and to highlight that the provisions of Regulation 18 have not been observed in the preparation of the Draft Plan.

Q1.7. The Draft Plan differs from the SHLAA in a number of ways, none of which has been explained. Despite the apparent comprehensiveness of the SHLAA and the decision (which we disagree with) to ignore an allowance for windfall sites, the SHLAA misses some key sites and sectors – notably the University land above its 2.4Ha or so surface car parks on the Stag Hill campus backing onto the railway line and the only partly developed Manor Farm campus.

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Q1.8. The treatment of student housing in supply and demand seems to be inconsistent and understated. This needs to be explicitly addressed and the University’s strategy for the Plan Period needs to be taken into account.

Q1.9. Finally, the NPPF calls for an integrated approach to employment and housing (and, by implication, Infrastructure). We see this as a triangle of links whereby the objective need for each should be assessed according to the impact upon the others:

Q1.10. The Objective Assessment of Housing Need would give rise to a need to provide sufficient jobs and/or a planned or forecast increase in the economy (taking account of any background changes to working patterns) would give rise to a need to provide sufficient housing that workers could afford. Each or both of these would lead to a need to address infrastructure (both as an enabler and also to mitigate the impact of growth).

Q1.11. The Draft Plan gives no indication of how these aspects work together and, consequently, how Guildford Borough Council has arrived at its target figures.

Q1.12. The Draft Plan refers to the Infrastructure Delivery Plan – a key component of a joined up plan – which has not yet been prepared (or at least released). This is a major failure which, for the purposes of this exercise, demonstrates that the Section 18 Consultation is not sound, and that any Local Plan based on this consultation, as the last substantive opportunity to influence the content and site allocations in the Draft Plan, must also be found unsound.

Q1.13. Taking all of these points together, it is absolutely plain to the Guildford Society that the Evidence Base is not adequate to support the proposed policies in the Draft Plan. Nor any policies in any future Local Plan.

Question 2: National policy and guidance Local Plans are required to be in line with the National Planning Policy Framework (NPPF) and the National Planning Policy Guidance (NPPG).

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To the best of your knowledge, do you think that the draft Local Plan: strategy and sites is consistent with national policy and guidance?

Response: NO

Comments: Q2.1. NPPF (and, indeed Policy 1 of the Draft Plan) establishes a presumption in

favour of sustainable development but it also requires plan makers to take account of local circumstances and constraints.

Q2.2. The shortcomings in the Evidence Base make it very difficult to understand and test whether any particular development is sustainable or not. Q2. 2.1. There is no clear indication that the housing target (based on a

combination of an Objective Assessment of Housing need – flawed –and local constraints – not obviously assessed) could be found sound;

Q2. 2.2. There is no Infrastructure Delivery Plan and, as noted in our response to question 1 above, there is no funding assured to resolve the critical infrastructure deficits, let alone objective technical assessments of new infrastructure to support new developments;

Q2. 2.3. There is, consequently no clear indication that any of the development proposed would be sustainable and, notwithstanding that not developing would also be unsustainable, the Draft Plan (as drafted) is fundamentally flawed in practical and policy terms.

Q2.3. The list of sites proposed for allocation cannot readily be tested against the Evidence Base to understand whether development of them would be sustainable (or the circumstances under which they might be sustainable).

Q2.4. This shows a fundamental deviation from the underlying principles of NPPF. Q2.5. Furthermore, the number and scale of proposed removal of land from the

Green Belt is not explicitly explained by reference to ‘Exceptional Circumstances’. The Guildford Society recognises the fundamental difficulty for the Council. In citing its exceptional circumstances as a blanket treatment, it could open the door for any site in the Green Belt and Area of Outstanding Natural Beauty to be brought forward for development in the meantime.

Q2.6. On the other hand, the Guildford Society does not comprehend the merits for insetting individual sites as and for themselves. The Council will need to justify each on its own exceptional circumstances, and many of these are immaterial to the extent they will present problems for the Council to explain and defend its treatment of each. The Guildford Society does not think this approach is

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consistent with NPPF 84 and considers there are no exceptional circumstances to remove individual sites from the Green Belt.

Q2.7. The approach to housing and employment targets (and, by implication, infrastructure) is not shown to be integrated and, the Guildford Society would argue, can be shown to be disintegrated. This is out of step with NPPF 158 and its preceding policy NPPF 157. Q2. 7.1. The Draft Plan housing target is 652 homes per year. Q2. 7.2. The Employment Land Assessment is based on a projection of figures

from Experian’s 2010 forecast of economic growth. Q2. 7.3. Edge Analytics noted that the Experian forecast would give rise to an

average need for homes at 392 dwellings per year (260 homes per year fewer than the Draft Plan housing target).

Q2. 7.4. GL Hearn adopted a different Experian forecast with double the amount of economic growth and arrived at a required (employment-led) number of homes per year of 570.

Q2. 7.5. The land allocation in the Employment Land Assessment is made on the basis of the Experian forecast leading to 392 homes, and would clearly be inadequate for a housing number as high as 570, let alone 652.

Q2.8. Therefore, the housing and employment strategies appear to be out of step with one another.

Q2.9. The infrastructure deficit (widely reported in the Borough’s Economic Strategy and in the 2009 Economic Report) must be addressed in order for the employment growth to take place AND to accommodate the additional households proposed.

Q2.10. This argument and others are spelt out in greater detail in the Policy by Policy assessment which follows this section of the Guildford Society response.

Question 3: Sustainability Appraisal and Habitats Regulations Assessment As part of the preparation of the draft Local Plan: strategy and sites, we carried out a Sustainability Appraisal and Habitats Regulations Assessment which considered the likely significant effects that the draft Local Plan: strategy and sites may have on environmental, economic and social factors in the borough, including European Designated Habitats.

Having looked at the Sustainability Appraisal and Habitats Regulations Assessment do you agree with:

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a) the Sustainability Appraisal of the draft Local Plan: strategy and sites? Response: NO

Comments: Q3a.1. There is no indication that any of the points made in response to the

Sustainability Appraisal consultation (made by the Guildford Vision Group (‘GVG’) on 23rd January 2013) have been taken into account.

Q3a.2. Whilst GVG is not the same as the Guildford Society, GVG was formed by the Guildford Society and others to press for the master planning of the Town Centre and the resolution of longstanding traffic congestion.

Q3a.3. By incorporating it into this representation, the GVG response should be seen also as part of the base for the Guildford Society representations. The Guildford Society hereby endorses that submission as if it were its own.

b) the Habitats Regulations Appraisal of the draft Local Plan: strategy and sites?

Response: NO

Comments: Q3b.1. The Thames Basin Special Protection Area (‘SPA’) has not been expressly

strategized in the Draft Plan and yet it is a fundamental constraint on development beyond the legitimate controls of the Council.

Q3b.2. The only part of the Borough that is not within 10km of a SPA is within the Surrey Hills Area of outstanding Natural Beauty.

Q3b.3. This needs to be amplified as a constraint upon development and there needs to be a separate strategy for the fulfilment both of the NPPF objective to meet objectively assessed need, and also of the EU in its sponsorship of SPAs.

Q3b.4. The Guildford Society finds it very difficult to reconcile the fact that there are three co-terminus consultations on very important issues, one of which is the Habitat Regulations Assessment 2014.

Q3b.5. URS Screening Opinion 2013: Q3b. 5.1. At paragraph 36 (Water Quality) notes that “research carried out by

the Environment Agency has indicated that future sewage treatment capacity at Guildford sewage treatment works can be rendered adequate to deal with projected growth, at least to 2026 given

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relatively small capital cost and will therefore not have an adverse effect upon receiving waters”.

Q3b. 5.2. This statement is contrary to the emerging plans to change the sewage works at Slyfield to enable development under the Slyfield Area Regeneration Project (‘SARP’) that releases Site Number 48 – see our site specific response – which do not explicitly accommodate the capacity until 2031 (viz. the entirety of the Draft Local Plan Period).

Q3b. 5.3. Paragraph 4.2 (Features of European Interest) refers to bird counts which are 15 years out of date. There is no indication as to whether the SPA is working in its objective to protect the species and whether such protection has led to increased populations of protected birds.

Q3b. 5.4. The SPA policy has such restrictions on an already highly constrained land supply that it must be beholden on the European Union to provide such updated information as will ensure the protection measures are proportionate and up-to-date.

Q3b. 5.5. The Precautionary Principle of the European Commission puts a heavy burden on the Borough to the extent that SANG contributions as a part of development levies (whether contained in Community Infrastructure Levy or some additional charge) will inevitably make Affordable Housing less viable as a part of new development and there is a considerable risk that the Local Plan targets will not be met. The Council must seek assistance from Central Government and/or the European Union to reconcile: Q3b. 5.5.1 Its need to provide ever greater number so of homes in a

constrained borough; Q3b. 5.5.2 The need to provide a considerable proportion of

affordable homes in any development; and Q3b. 5.5.3 The need to pay towards allocating scarce land towards

protection zones and SANGS for the protection of ground-nesting birds.

Q3b. 5.6. In any event, this is a material constraint which is outside the control of the Council and which must restrict development.

Q3b. 5.7. This concept must also have specific regard to the requirements and principles of NPPF 83 – to the extent that the Local Plan should ensure that development opportunities would be safeguarded to ensure the [Green Belt] boundaries would not need to be redrawn at

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the next Local Plan: boundaries “should be capable of enduring beyond the plan period”.

Q3b. 5.8. The constraints including SPAs are shown below:

Q3b.6. The URS Draft Local Plan HRA report highlights that Green Belt developments and village insetting could have a detrimental effect on the SPAs due to increased road journeys and local emissions. URS recommend additional policy wording to protect against harmful developments. Whilst The Guildford Society supports this suggestion, the pre-allocation site screening should have taken this into account and URS should have been able to review detailed data rather than leave a risk that an allocation may not be sound.

Q3b.7. The URS report also notes that the scale of development for both housing and employment purposes (including specifically in the town centre) would tend to increase road journeys and would have an adverse pollution impact within 200m of the centre of local roads. There is no reference to such impact or potential restrictions as part of the Infrastructure Baseline report. It is not clear what (if any) impact this concern may have on policies.

Q3b.8. URS’s analysis of individual site allocations (at Section 5 of its report) is bland and broadly unhelpful inasmuch as all development is given broadly similar comment to the effect that it might cause harm to the SPA if not mitigated. The Council needs to insist on a better quality of response for any of the larger sites – say for more than 100 homes – in order to ensure the targets in the Local Plan can actually be met in practice.

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Q3b.9. The higher quality of response is particularly important where there is a proposed realignment of the Green Belt boundaries. The realignment must not only satisfy the ‘Exceptional Circumstances’ test; it must also demonstrate it can achieve what it sets out to do.

Q3b.10. The URS summary (at 7. Conclusions) makes a number of comments which will need to be incorporated into the Pre-Submission Draft Local Plan. This sets a series of land-hungry requirements in train and, having regard to the overall area of the borough, some form of spatial impact assessment should be conducted to enable us to understand the effect on the already heavily constrained borough’s supply of development sites.

Question 4: The vision The draft Local Plan: strategy and sites vision statement should be both aspirational and achievable and set out the kind of borough we will strive to become by 2031. It should also identify objectives that we will meet in order to achieve the vision. The vision for the draft Local Plan has been developed from a range of locally specific strategies and through consultations and feedback from stakeholders.

a) Do you think the vision of the draft Local Plan: strategy and sites depicts the borough that communities would want to be living and working in by 2031?

Response: NO

Comments: Q4a.1. Whilst several parts of the Vision are sensible and appropriate in principle, the

Vision itself is hardly visionary. Q4a.2. The Guildford Society, in its Draft Alternative Local Plan annexed to this

response, has set out a more comprehensive and forward looking, aspirational vision: Q4a. 2.1. Guildford in 2031 will be a sustainable town and borough which:

Q4a. 2.1.1 is a great place in which to be - to live, to visit, to work, to shop and to study;

Q4a. 2.1.2 sits comfortably within its green belt surroundings, protected from uncontrolled expansion;

Q4a. 2.1.3 has substantially improved traffic, transport, technical, physical, educational and health infrastructure; fit for the

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mid-century and supporting life, work and play in and around the town and borough;

Q4a. 2.1.4 allows excellent development that respects its context, heritage, arts and cultural diversity;

Q4a. 2.1.5 has a thriving economy centred around knowledge businesses and other established sectors as well as attracting new forward-looking businesses;

Q4a. 2.1.6 has village communities which are able to accommodate organic growth;

Q4a. 2.1.7 has a town centre and district centres that function exceptionally well;

Q4a. 2.1.8 provides effectively for those who are less well-off through social and affordable housing, ample employment and leisure activities;

Q4a.3. There also needs to be a clear set of Strategic Objectives, and not merely the headings from the Corporate Plan with a little detail (see below).

b) Do you think the ambitions, issues and strategic objectives of the draft Local Plan: strategy and sites are representative of the issues the borough faces and the things that we will need to achieve to meet our vision for 2031?

Response: NO

Comments: Q4b.1. Once again this comes back to the first question. In the absence of a high

quality Evidence Base, it is almost impossible to establish a set of comprehensive plan-led objectives to resolve issues which the Evidence Base has failed to highlight and where the Evidence Base cannot readily point to solutions.

c) Is there anything you think should be included? Response: YES/NO

Comments: Q4c.1. The absence of a clear strategy for the University campuses (Stag Hill and

Manor Farm) seem to us to be an error of omission, given the importance of

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the University to the town and borough (and vice versa), and having regard to the policies and allocations of related sites and their respective challenges: Q4c. 1.1. The proposed policy for the University to house 60% of FTE students

on its own land is nothing more than a statement of intent without clear analysis showing what capacity exists for development on the two campuses (both for increasing student numbers and accommodating them).

Q4c. 1.2. The University has in the past published its strategic plans: 2000 Strategy: http://portal.surrey.ac.uk:7778/portal/page?_pageid=764,134803&_dad=portal&_schema=PORTAL 2009 Strategy: http://www.surrey.ac.uk/about/corporate/documents/university_of_surrey_plan_2009-10.pdf 2009-2019 Estates Strategy: https://www.google.co.uk/url?sa=t&rct=j&q=&esrc=s&source=web&cd=2&cad=rja&uact=8&ved=0CCkQFjAB&url=http%3A%2F%2Fportal.surrey.ac.uk%2Fpls%2Fportal%2Furl%2FITEM%2FB8FF309C0CE7501FE0440003BA296BDE&ei=WDwRVN_LMoKfygOPuIEw&usg=AFQjCNFYc-e9q5vCZCDGQl2vhwjuSuNGDg&sig2=iHWC9ifPMy-UTPwFm8TqUw&bvm=bv.74894050,d.bGQ (all accessed 11th September 7.15am)

Q4c. 1.3. In the Estates Strategy at 10.5.2 the document notes: “The Estate Strategy is broadly consistent with the content of the Stag Hill Development Brief which is out of date. The University is planning to complete an overall development master plan for Stag Hill and Manor Park.”

Q4c. 1.4. An updated strategy needs to be forthcoming from the University – at least in outline form – or the overall master plan or Development Brief need to be properly referenced in the Local Plan to ensure (on a two-way basis) that infrastructure is suitable and that proper account is taken when proposing other schemes – in this case, probably, Blackwell Farm (Site 60).

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http://portal.surrey.ac.uk:7778/portal/page?_pageid=764,134803&_dad=portal&_schema=PORTAL

http://portal.surrey.ac.uk:7778/portal/page?_pageid=764,134803&_dad=portal&_schema=PORTAL

http://www.surrey.ac.uk/about/corporate/documents/university_of_surrey_plan_2009-10.pdf

http://www.surrey.ac.uk/about/corporate/documents/university_of_surrey_plan_2009-10.pdf

https://www.google.co.uk/url?sa=t&rct=j&q=&esrc=s&source=web&cd=2&cad=rja&uact=8&ved=0CCkQFjAB&url=http%3A%2F%2Fportal.surrey.ac.uk%2Fpls%2Fportal%2Furl%2FITEM%2FB8FF309C0CE7501FE0440003BA296BDE&ei=WDwRVN_LMoKfygOPuIEw&usg=AFQjCNFYc-e9q5vCZCDGQl2vhwjuSuNGDg&sig2=iHWC9ifPMy-UTPwFm8TqUw&bvm=bv.74894050,d.bGQ







Question 5: The Key Diagram The Key Diagram is a representation of the draft Local Plan: strategy and sites. It provides a broad indication of how the borough will develop over the lifetime of the plan.1

a) Do you think that the Key Diagram is representative of the key aspects of the draft Local Plan: strategy and sites?

Response: YES

Comments: Q5a.1. Although broadly representative, the diagram is confusing and should perhaps

be shown as two distinct key diagrams (see (b) below).

b) Is there anything missing or is there a way to make the Key Diagram clearer?

Response: YES

Comments: Q5b.1. The diagram could be shown in two distinct parts:

Q5b. 1.1. The existing constraints and area designations Q5b. 1.2. The proposed policies

Q5b.2. In our comments on the Infrastructure Baseline we identified that it would be helpful to identify capacity of different types of infrastructure and a third plan might provide this with traffic light coding to show where there is a reasonable amount of capacity (green), where the infrastructure is nearing capacity (yellow), and where it is already at or exceeding capacity (red).

Q5b.3. This would help to frame policies in specific areas that ensure there are adequate contributions or CIL allocations towards the creation of additional capacity. It would also go a long way towards explaining why some larger-scale developments would be desirable to deliver the required level of infrastructure, where piecemeal development on a small scale cannot.

1 Please note: The Key Diagram is not intended to identify specific sites or street names which can be seen on the individual settlement maps in Appendix G.

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Question 6: The content - paragraphs, policies and site allocations Which paragraph, policy or site allocation of the draft Local Plan: strategy and sites document do you wish to make comment on and do you wish to support or object and/or comment?

A separate response should be completed for each individual paragraph/policy/site you are making comment on. Please state your comments fully and clearly and your reasons for supporting/ objecting to this paragraph/policy/site.

Please indicate what changes i.e. wording, alternative site/boundary, you feel should be made.

Q6.1. The Guildford Society responses in the table below are to be taken as part only of the representations for each respective policy.

Q6.2. The Section below entitled ‘Policy by Policy Analysis’ should also be read as part of our response to this question.

Q6.3. The Annex below entitled ‘Site by Site Analysis’ should also be read as part of our response to this question.

Paragraph number/Policy number/Site allocation number or any other aspect:

Support/Object Comments

Policy 1: Presumption in favour of Sustainable Development

Support the Principle but Object to it in the context of a poor Evidence Base

The Evidence Base is inadequate to support such a presumption as it is not possible to determine what development would be sustainable. Equally, the lack of integration between housing, employment and infrastructure needs is at best unhelpful in this regard. See P-1 below

Policy 2: Borough-wide Strategy

Object to the strategy as premature

The figures being used in this draft policy are not settled and, consequently, the borough-wide strategy is a moving target.

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Again the lack of integration is a major concern, and the Draft SHMA is not fit for purpose. There are unexplained inconsistencies between the SHLAA and the Draft Plan. There seems to be some justification for looking towards the Green Belt for site allocations (possibly more for future plans than for this one) but the supporting data is conflicting and inadequate. See P-2 below

Policy 3: Homes for All

Support the Principle but Object to various details

The principle of the policy seems to be one of inclusivity. The failure to look to explicitly solve some of the major causes of relative deprivation is troubling. The Guildford Society would like to see some form of impact assessment of proposed allocations on relative deprivation, as well as some positive policies designed to overcome some of the extreme deprivation scores. The Local Plan needs to make specific numerical reference to student homes and ensure we plan properly both for the students and their institutions, and also for current and aspiring

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residents and their communities. See P-3 below

Policy 4: Affordable Homes

Support the Principle but Object to it in the context of an absence of proof of its viability

The principle is commendable, the execution is a hostage to fortune. The Council is unable to demonstrate consistent achievement of 30% affordable under the current Local Plan (2003) let alone 40-45% under the Draft Plan. Viability will be key (having taken into account CIL and other contributions) and there needs to be a robust test that does not allow a developer to commit a price to a landowner that then allows it to plead non-viability and results in a reduction in affordable housing provision. See P-4 below

Policy 5: Rural Exception Homes

Support the Principle

The viability provisions in the draft policy are too lax See P-5 below

Policy 6: Making Better Places

Support the Principle but Object to the vagueness of the Draft Policy

The Guildford Society believes the Council should embrace the provisions of NPPF 62 by establishing a Design Review Panel and we would like to be part of that process. See P-6 below

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Policy 7: Sustainable Design, Construction & Energy


The principle is accepted, the weakness of language is not. The policy needs to be more emphatic and needs to lead to better behaviours rather than avoidance strategies. See P-7 below

Policy 8: Surrey Hills AONB


The Guildford Society supports this policy and requests that it be strengthened by ensuring there is a strong presumption against development. See P-8 below

Policy 9: Villages and Previously Developed Sites

Understand the challenge but Object to the Policy

The weaknesses in the Settlement Profiles Report make the draft policy ineffective and lead to conclusions which are not wholly supported by the evidence. See P-9 below

Policy 10: Green Belt & Countryside

Understand the challenge but Object to the Policy

The Guildford Society does not fundamentally disagree with the need periodically to review Green belt boundaries but it has major issues with the Green belt and Countryside Report, the approach to insetting and the notion that some land is safeguarded but by no means sufficient for much more than one Local Plan Period. The SHLAA and GBCS seem to have concluded that there is a limit on the extent to which land can be made available for development (all other things

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being equal). This allocation of land needs to last us for 40 years of need rather than 20 years of the current Draft Plan. Whilst there may need to be incursions on the scale proposed, this cannot be a one-off raid on the Green Belt for this Local Plan which will inevitably be followed by a similar raid next time around. That would be contrary to the Green belt provisions in NPPF. See P-10 below

Policy 11: Ash & Tongham Strategic Location for Growth


This is broadly beyond the Guildford Society’s remit but we do note that the area of Rushmoor immediately adjacent to this area is particularly deprived by comparison to much of the Ash & Tongham area. See P-11 below

Policy 12: Historic Environment


The policy wording is weak and unhelpful but the principle is important and we support it. Guildford’s history and heritage assets are key success factors and must be nurtured alongside the other objectives in the Local Plan. See P-12 below

Policy 13: Economic Development

Support the Principle but Object to the

The Guildford Society is concerned that the ambition in the Economic Strategy is not

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vagueness of the Draft Policy

sufficiently reflected in the Draft Plan and is not well provided for in the Employment Land Assesment. See P-13 below

Policy 14: The Leisure and Visitor Experience


Once again the policy is written more like an aspiration or plea. This needs to be much more definitive and convey the authority as befits this important aspect of the current and particularly the future well-being of the town. See P-14 below

Policy 15: Guildford Town Centre

Support the Principle but there needs to be more reserving of land for comprehensive development

The Guildford Society supports the Allies & Morrison vision as expanded by the Guildford Vision Group proposals. Land will need to be explicitly reserved in the Plan and the Council will need to take a pro-active role in bringing forward major regeneration of neglected and underused areas. This response should be supplemented by reference to P-15 below and also by reference to our response to the Town Centre Vision consultation, reproduced at Vision-1 to Vision-7 below. The specific reference to ‘people above traffic’ is all very well but no mention is made of

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what to do with traffic, including freight. The scale of work required to clear the town centre of traffic so as to allow larger-scale pedestrian prioritisation will be far in excess of any contribution from CIL and firm plans need to be developed to ensure the town centre has the capacity that will be demanded by the proposed levels of development.

Policy 16: District and Local Centres


The Guildford Society expressed its concerns about the weakness of the Settlement Profiles Report in our response to the Issues and Options consultation. The lack of granularity within the Guildford Urban Area means that this policy is inadequate for the neighbourhood centres within the Guildford Urban Area and no account is taken of the spatial policies which can help to correct areas of relative deprivation by good urban planning. See P-16 below

Policy 17: Infrastructure and Delivery

Object to the policy as premature and incomplete

The Guildford Society is highly concerned that the consultation was launched before a draft Infrastructure Delivery Plan has been published. As a result we see major shortfalls in both current

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infrastructure (and the Infrastructure Baseline, whilst a good start, is inadequate in this regard) and in the proposed provision in Appendix B. See P-17 below

Policy 18: Sustainable Transport for New Developments


Whilst the principle is acceptable, the policy is weak and needs considerable improvement if this is to be more than just a pipe-dream. See P-18 below

Policy 19: Green and Blue Infrastructure


The principle, yet again, is acceptable but the vagueness of the policy drafting means it could apply to any town with a river running through it. We need to see a much more robust policy environment, building on the vision and strategic objectives, to ensure this policy is fit for purpose and that it conforms to expectations under the NPPF. There should be a reserved, safeguarded strip along both sides of the river to ensure that a long term continuous riverside walk can be implemented to give everyone access along the length of the Wey through our borough. See P-19 below

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SITE ALLOCATIONS See Separate Schedule

There are key omissions in respect of this section of the Draft Local Plan: Tunsgate Square – initial public consultations have taken place with a view to redevelopment of the property and the proposed mix and quantum of uses should be taken into consideration when evaluating, for example, Site 20. University Campuses (Stag Hill and Manor Farm) – with approved plans and latent development potential – particularly by ensuring new developments make use of the airspace above current surface car parking and that consented developments are included in the SHLAA and ELA. Land assembly sites as noted by the Guildford Vision Group Land reservations for key infrastructure.

Question 7: Any other comments Do you have any other comments that have not been covered by the previous questions?

Response: YES

Comments: Q7.1. Please see all attachments to this submission.

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Q7.2. The Draft Plan is not very clearly related to Guildford and its borough. The Guildford Society is concerned that such a ‘generic’ plan cannot be adequate for a town and borough with the characteristics, heritage, constraints and challenges that we have. Q7. 2.1. not all of the land reservations required for infrastructure have been

identified; Q7. 2.2. the very specific issues faced by Guildford and its borough were

identified either in the original documentation or the mass of responses received to the Issues and Options consultation. This appears to have largely been disregarded or ignored;

Q7. 2.3. the Guildford Society has attached to this response our position papers relating to specific aspects of our town and borough and we aim to see that the policies protect and enhance the critical elements that make Guildford special, whilst acknowledging that there must be development;

Q7.3. Appendix D lists superseded Policies. There seems to be no reference to it in the main text of the Plan. Q7. 3.1. All appendices should be properly referenced within the main text. It

is not referred to in para 1.1 which mentions the 'delivering development' second part of the Plan (the initial letters should presumably be capitalised to ensure that the user understands this to be a specific reference – viz. “Delivering Development”), and 'delivering development' is not in the Glossary of Appendix A although 'Local Plan Strategy and Sites' is.

Q7. 3.2. All referencing needs to be checked as a matter of course. Q7. 3.3. The Guildford Society considers if of paramount importance that

good policies in the 2003 Plan are carried over into the new Plan. It is essential to check that:

(a) the new Plan really does cover the good parts of the 2003 policies which it claims to supersede; and

(b) 'delivering development' will save all the good parts of all the remaining policies.

The Guildford Society recommends that Appendix D should have a preamble which makes these points very clear.

Q7. 3.4. By way of example:

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Q7. 3.4.1 The last exercise of this kind was the 'Core Strategy Further Options Consultation' of March 2009, to which the Guildford Society responded at length.

Q7. 3.4.2 'Annex 1' of the Consultation was 'Saved Policies'. It listed all the saved local policies to be replaced by the Core Strategy.

Q7. 3.4.3 We have checked this against the Appendix D list. The Appendix D list is satisfactory in this respect.

Q7. 3.4.4 2003 Policies R2, R3 and R4 were in the Consultation list for the Core Strategy, but it would be reasonable for them to be saved in 'delivering development'.

Q7. 3.4.5 The Consultation for the Core Strategy then listed all the Policies 'to be reviewed later by the GDF'. These are the ones for 'delivering development'.

Q7. 3.4.6 A third list gave 'Polices that were not saved for future use' (H1, H10, S1, RE7, HE11, GT4, U1).

Q7. 3.4.7 The three lists gave complete coverage of all the 2003 Policies.

Q7. 3.4.8 The Guildford Society recommends that Appendix D should include the two latter lists.

Q7. 3.5. The Guildford Society has taken a general look at the variances in policy and where they seem to be covered in the Draft Plan: Q7. 3.5.1 Policy 2 more than covers H1 Q7. 3.5.2 Policy 3 covers H7 (HMO part), H10 (deleted), H13 & H14 Q7. 3.5.3 Policy 4 covers H11 except for the last paragraph -

benefit to be preserved for successors Q7. 3.5.4 Policy 5 covers H12 but without most of the specific

conditions Q7. 3.5.5 Policy 6 does not cover G1(5), and, of critical importance

to the Guildford Society for the protection of views in G5(6), does not include the specific criteria of G5(1). This is all left to 'detailed design policy' - see 4.72. This must be covered somewhere (presumably in 'delivering development').

Q7. 3.5.6 Policy 7 covers much more than G1(9) and (10) Q7. 3.5.7 Policy 8 covers RE5 & RE6

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Q7. 3.5.8 Policy 9 covers RE3 and RE7. It covers RE7 with more named sites but fewer specifics, especially height.

Q7. 3.5.9 Policy 10 the wording is looser than that of RE1, RE2, and especially the specifics of RE4, and RE8. The Guildford Society has not had the resources to fully evaluate this and set out specific issues and examples.

Q7. 3.5.10 Policy 12 - historic environment - presumably left to 'delivering development'

Q7. 3.5.11 Policy 13 covers E1, E2 but not E3 - loss of employment land. It covers E1, but not E5 - homeworking

Q7. 3.5.12 Policy 14 omits some of the specifics of T1 and T3, especially the protection of neighbours which the Guildford Society considers to be an important control. It omits T5 - conversion to B&B etc.

Q7. 3.5.13 Policy 15 covers S2 but the threshold is lowered from 2,500 to 1,000 sq m.

Q7. 3.5.14 Policy 16 is far more flexible than policies S8 and S9, District and Local Shopping Centres. Policies S4 to S7 are irrelevant to Policy 16 because they cover primary, secondary and tertiary and specialist shopping areas in the town centre. They are not covered by Policy 15. They need to be covered somewhere.

Q7. 3.5.15 Policy 17 more than covers G6. The 2003 Plan did not have infrastructure as a main heading.

Q7. 3.5.16 Policy 18 does not specifically cover M1 - town centre parking provision. It does not give sufficient prominence to buses, and does not cover the priority requirement of M4. It should do so. It does cover G12, G1(1) and G1(2).

Q7. 3.5.17 Policy 19: G11 was for the Wey and Navigations and nothing else. Although para 4.231 is headed Wey Navigation there is no mention within the Policy itself. Policy 19 just talks about 'blue infrastructure'. The Guildford Society considers that the Wey and Navigations should have specific mention within a policy. R1 is not expressly covered.

Q7. 3.5.18 One further point on Policy 19 is that the whole draft Plan pays too little attention to land for sport and

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recreation (especially for young people). This needs to be part of the planning obligations and needs to be taken into account in viability assessments.

Q7.4. The Guildford Society transport Group has recommended several additional desirable objectives for the Local Plan as follows: Q7. 4.1. Divert cross-town traffic to enable the conversion of Bridge Street

and Onslow Street into avenues of shared space. (Buses, taxis, cyclists & pedestrians and limited local traffic and access to car parks).

Q7. 4.2. This will support one section of the proposed Sustainable Movement Corridor (SMC)

Q7. 4.3. A good bus interchange, centrally located with corresponding bus routing plan.

Q7. 4.4. New dedicated cycle routes such as the A3 crossing at the Wooden Bridge.

Q7. 4.5. Consider driverless flexible vehicle services for the Sustainable Movement Corridor(s) to provide comprehensive Sustainable Urban Movement.

Q7.5. Guildford’s Local Plan needs some fundamental redrafting in order to be truly representative of the town and borough, the future aspirations and the specific proposals.

Q7.6. The Guildford Society’s submission, taken as a whole, aims to include constructive proposals to achieve this.

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Policy-by-Policy Analysis This part of the document provides more information than the summary response in the Questionnaire responses.

P-1. Presumption in Favour of Sustainable Development

P-1.1. This policy is taken in its entirety from the NPPG. P-1.2. The presumption itself is a reasonable concept taken as a whole with

the remainder of the NPPF. P-1.3. The Guildford Society has two primary problems with this Policy as it

stands in the Draft Plan: P-1.4. Firstly, the Evidence Base is not good enough to provide a framework

for testing sustainability, and the Sustainability Appraisal (‘SA’) has flaws identified in response to the SA consultation. P-1.4.1. The constraints are not clearly set out and are not

identified as restrictions by default (subject to the various tests required by NPPF);

P-1.4.2. The infrastructure restrictions (notably the severe deficits in historic infrastructure provision) are not articulated;

P-1.4.3. The various designations of international, national, regional and local land use restrictions (such as SPAs, AONB, Green Belt, Sites of Special Scientific Interest, Areas of Great Landscape Value (subject to any future redesignation) and Conservation Areas) are not highlighted in the context of Policy 1. The Guildford Society considers that to be a mistake.

P-1.4.4. Other environmental factors such as contaminated land are not specifically highlighted. Also absent are sites already designated under other local strategies (such as under [Minerals and Waste] strategies).

P-1.4.5. The nature of the recent flooding and the need to avoid key areas for development to ensure appropriate protection against flooding highlights the need to make reference to this restriction here.

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P-1.5. Secondly, the text in the Monitoring Indicators section of Policy 1 fail to recognise the combined influences on each other of housing, employment and infrastructure.

P-1.6. The Evidence Base as it relates to each of these three critical components should be kept under regular review in addition to the developments and infrastructure completed in each year of the Plan.

P-2. Borough-Wide Strategy

P-2.1. The absence of a demonstrable and cohesive link between HOUSING and EMPLOYMENT and the required INFRASTRUCTURE means that this policy (and the Plan in general as drafted) does not stand up to scrutiny and does not comply with the express and implicit terms of the NPPF. P-2.1.1. The Draft SHMA contains baseline figures which are not

based on the most up-to-date statistics. P-2.1.2. The Employment Land Assessment is out of step with the

growth assumptions in the Draft SHMA. P-2.1.3. The Infrastructure Baseline is not fit for purpose as it does

not demonstrate the current capacity, nor the steps required to facilitate development without disproportionate harm. Furthermore there was no Infrastructure Delivery Plan available alongside the Draft Plan to enable any rational assessment.

P-2.2. The Guildford Society believes the figures are wrong and strongly objects to the absence of cohesion in this policy and the Draft Plan in general.

P-2.3. Care must be taken to ensure, when estimating housing need, to use demographic need as a starting point before taking account of other factors such as market signals, employment and economic trends and affordable housing need. By not using the most current data, the Draft SHMA is nowhere near fit for purpose.

P-2.4. It is our contention that a restatement of these figures and the integration of the housing, economic and infrastructure strategies will necessitate a fresh consultation (for a minimum of six weeks) in order to allow the community to reflect on clearly explained likely impacts.

P-2.5. The evident (long-term) infrastructure constraints, coupled with the legal restrictions in land use (including, but not limited to SPAs, SSIs,

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AONBs and Green Belt) are a very material constraint on development and should be taken into account in the setting of a housing target.

P-2.6. Guildford Borough Council is a second tier authority with little actual control over the built infrastructure, and still less over international, national and regional designations of land. We strongly believe the Draft Plan should be suitably constrained in its expected and planned delivery of development UNLESS and UNTIL the strictures of those designations and the strait-jacket of infrastructure deficit can be relaxed.

P-2.7. The SHLAA identifies 6,837 units that can be expected to be deliverable within the legal constraints (all excluding the Green Belt Boundary realignments) - notwithstanding those will provide their own local infrastructure issues (341.85 dwellings per year).

P-2.8. The Draft Local Plan identifies 6,191 units on the same basis (309.55 dwellings per year).

P-2.9. The ELA identifies employment land capable of meeting a Compound Annual Growth figure of 0.7% (taking the Experian figure to 2026 and projecting at the same rate to 2031 to reflect the local plan period.

P-2.10. The How Many New Homes? Option 5 employed an Experian 2010 growth projection assuming that the number of new homes required over the plan period would be 7,160 to 8,520 (358 to 426 dwellings per year – average 392). Its employment figure averages out at 0.39% annual growth in employment (and 0.24% if we take the economically active labour supply figure).

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P-2.11. It could be argued that a combination of people working longer and a strong tradition of in-commuting should ensure that the employment development can be made viable without requiring quite such an increase in dwellings.

P-2.12. The Draft SHMA sees GL Hearn take a different growth rate from Experian and suppose that 570 dwellings per year would be required to meet the needs of the economy.

P-2.13. Even at the lowest levels of presumed growth, the numbers of dwellings required for the economy EXCEED the number of available sites without some realignment of the Green Belt Boundary (see P-2.7 and P-2.8 above).

P-2.14. Furthermore, the National Planning Policy Framework requires the Green Belt Boundary to be permanent and defensible, and requires us to make sufficient land available for subsequent plan periods.

P-2.15. The realignment of the Green Belt requires a much more insightful process and a specific debate rather than overtaking other vital components of the Local Plan.

P-2.16. The borough and Guildford itself are situated on good rail links and close to the A3 trunk road which encourage commuting both inbound and outbound. The housing market cannot be seen in isolation and restrictions in the housing supply are not wholly responsible for decisions of Guildford employees to commute from the wider catchment area – in exactly the same way as it would be perverse to assume that the reason people commute from Guildford to work in London is entirely due to the shortage of housing in London.

P-2.17. The inbound and outbound commuting and through traffic put a substantial burden on the local infrastructure and a lack of investment over several decades has led to a major infrastructure deficit.

P-2.18. The infrastructure deficit has not been shown to be surmountable through the Draft Local Plan – especially in the absence of the Infrastructure Delivery Plan – and resolution of infrastructure shortfall is not entirely within the control of Guildford Borough Council.

P-2.19. It makes absolute sense, therefore, to constrain the Draft Plan at this stage with a commitment to an early review which could enable

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more growth based on the extent to which other agencies have committed to relax or remove specific constraints.

P-2.20. The provision of safeguarded land is, in our opinion, insufficient to ensure that there is enough land made available for growth not only in the current plan period but for the foreseeable future.

P-2.21. We would contend that the total housing provision for this Plan Period and the next should be identified in this Draft Plan but with strong protections and safeguards to ensure the future sites are not arbitrarily brought forward earlier.

P-2.22. PLEASE SEE ALSO THE APPENDIX TO THIS DOCUMENT ANALYSING INCONSISTENCIES IN THE SHLAA

P-3. Homes for All

P-3.1. The Guildford Society understands the 'inclusive' nature of a title such as "Homes for All", but notes this is a somewhat generic heading that is not defined clearly enough in the ensuing verbiage.

P-3.2. The concept of Homes for All could loosely be taken to mean 'meeting all DEMAND' where, to all intents and purposes, demand in Guildford is limited only to the extent excessive development does not do irreparable harm to the town and borough.

P-3.3. NEED, however, is a different matter. P-3.4. Although data on a Lower Super Output Area basis is readily

available, this does not seem to have been taken into account in settling the policies for the borough and specific areas.

P-3.5. The LSOA Deprivation Indices highlight specific challenges for particular areas in such topics as: P-3.5.1. Multiple Deprivation Index (overall Deprivation); P-3.5.2. Income; P-3.5.3. Employment; P-3.5.4. Health & Disability; P-3.5.5. Education Skills and Training; P-3.5.6. Barriers to housing and Services; P-3.5.7. Crime; P-3.5.8. Living Environment;

P-3.6. Each of these categories is then subdivided into ‘subdomains’ (data is available at http://data.gov.uk/dataset/index-of-multiple-deprivation and makes interesting reading in the context of local area characteristics).

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http://data.gov.uk/dataset/index-of-multiple-deprivation


P-3.6.1. Park Barn (E01030497 or Guildford 012D) features just inside the most deprived quarter of LSOAs in the country under the Multiple Deprivation Index – the only LSOA in the Borough to do so. When the subdomains are investigated, this area falls in the most deprived 2.5% in the country for children and young people’s Education, Skills and Training – clearly a major focus for attention (easy though it may be to allocate sole responsibility to Surrey County Council). The Local Plan should be aspirational enough to provide whatever solutions spatial planning can offer.

P-3.6.2. By contrast, the Wanborough & Seale area (E01030471 or Guildford 017A) features just inside the least deprived quarter of LSOAs in the country under the Multiple Deprivation Index, yet, when the subdomains are investigated, this area falls within the most deprived 1.3% LSOAs in the country for geographical barriers to housing and services. This (and the other three LSOAs in the most deprived 3% in this category) should warrant attention in the Local Plan.

P-3.6.3. Walnut Tree Close and Station area (E01030452 Guildford 015A) and the York Road, Artillery Road, Haydon Place section of the town centre (E01030451 Guildford 013C) are within the least deprived third and the most deprived 40% respectively under the Multiple Deprivation Index and yet, in terms of Outdoors Living Environment, they are both in the most deprived 3% in the country – absolutely essential to address this in the Local Plan.

P-3.7. The absence of critical data overall and character assessments of settlements across the borough and neighbourhoods within the Guildford Urban Area means that opportunities have been missed to use spatial planning to contribute to solutions which:

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P-3.7.1. address the most serious areas and elements of relative deprivation

P-3.7.2. increase density in some locations, and in so doing, solve local issues

P-3.7.3. ensure development enhances local areas P-3.7.4. prevent overdevelopment of particularly sensitive areas P-3.7.5. help ensure the viability of local services whilst respecting

the quality of local environments P-3.8. Density and building heights – for example, along the River Wey to

the north of the town centre – could, through careful master planning, deliver substantial numbers of homes whilst leaving the key views to and from the north-downs relatively unaffected.

P-3.9. In other areas, however, height and mass would have a major and detrimental impact on long distance views and on street-scenes.

P-3.10. The Evidence Base does not logically separate the areas for protection from the areas of opportunity and, consequently, neither does the Draft Plan. The Guildford Society is concerned that this leaves too much to chance (we recognise that although there may be policies in the Development Control Local Plan to deal with these concerns, the first draft of that document has not yet been published).

P-3.11. It is, therefore, not clear that the areas for which development is proposed are actually the same as the areas of need. No attempt has been made to designate challenging areas for special treatment and regeneration.

P-3.12. Density P-3.12.1. There are no character assessments that indicate the

existing densities in any particular area. P-3.12.2. The Guildford Society has analysed the LSOA data which

gives an indication of the densities in a wider area but there needs to be more direction to understand where densities should be preserved at more or less current levels and where (if anywhere) these might be increased through good design.

P-3.12.3. Density could be used as a force for good in some areas where there is relatively low density development but little

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public realm and where social or environmental and deprivation issues are prevalent.

P-3.12.4. Take, for example, Park Barn (LSOA: Guildford 012D) which is the only borough LSOA in the most deprive quartile in England. Here, P-3.12.4.1. The average built density is 30.5 dwellings per

Hectare but the average dwelling footprint is only 43.16 square metres.

P-3.12.4.2. The two most frequently occurring average council tax bands are D and G.

P-3.12.4.3. The peak of population is in the range 15 to 29 years.

P-3.12.4.4. Just under 75% of the homes are rented and almost 60% of all homes are social rented.

P-3.12.4.5. More than 1/3 of properties have at least one spare room and yet just under on in ten properties are considered overcrowded.

P-3.12.4.6. The deprivation profile of the LSOA is shown below:

P-3.12.4.7. Education and skills among young people are shown as particular areas of deprivation and it

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is reasonable to deduce that too few facilities and amenities are available for young people who make up a high proportion of the population (29.97% of the population is 19 or below).

P-3.12.4.8. In such cases it may be appropriate to look toward substantial regeneration to provide homes of the right sizes with great public realm and a good provision of youth facilities for gathering, training and recreation.

P-3.12.4.9. Making this happen may bring with it an increase in density to, say, 40dpH – increasing the supply of housing from 629 to, say. 750 to 800 but with substantial environmental improvements.

P-3.12.5. On the other hand, the scope to enable some increase in height and massing in specified areas whilst protecting key views and characteristics of other areas can only be properly managed by assigning specific density targets to specific areas.

P-3.12.6. It may be that this type of development control mechanism is to be included in the ‘Delivering Development’ Local Plan in due course. It is unfortunate that document is not available to allow us to understand the limitations or opportunities that may have been taken into account but are not expressed in the ‘Strategy and Sites’ Local Plan.

P-3.12.7. We note that Scott Brownrigg were tasked with sense-checking the planning assumptions in the SHLAA. We are unable to audit the auditors as the core information was not provided.

P-3.12.8. The Guildford Society would, on balance, support a Height and Density Development Plan Document alongside the Local plan to guide developers and the community towards a sustainable pattern of development which enhances and protects the borough.

P-3.12.9. The Guildford Society wishes to have specific mention in the Policy to the effect that ‘the practice of developing

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new, free-0standing residential property within existing gardens (so-called ‘garden-grabbing’) where such development would result in a materially higher plot density than that for the surrounding area, and where suitable frontage and access onto adopted highways is not available, will be discouraged.

P-3.13. Students P-3.13.1. The Guildford Society is appreciative of the proposed

restriction of university accommodation to amount not exceeding 40% off-campus.

P-3.13.2. The scarcity of land in our area mean that even at 40% of the University Full-Time-Equivalent students plus the students at University of Law, the Academy of Contemporary Music, Italia Conti, Performance Preparation Academy, and any other further education establishments, there will be large numbers of dwellings unavailable to the market or for affordable homes.

P-3.13.3. The student policy must be a coherent one which enables the learning sector to thrive but which ensures there is no detrimental effect on the wider community.

P-3.13.4. To this end, a clear and unambiguous policy for Homes in Multiple Occupation (‘HMOs’) must be included in the Local Plan. The conversion of homes into HMOs has been envisaged but the management of existing HMOs has not. There must be a limit or some similar control on numbers (whether by reference to percentages of housing stock in any particular given area or by absolute numbers) and this must be capable of being managed through the planning system.

P-3.13.5. Census data and empty homes data arising from the census give a misleading picture – the student population are counted in their non-term-time residence and this leads to high levels of notionally empty properties in the town centre: P-3.13.5.1. Guildford 015A (Walnut Tree Close, Station

and lower Farnham Road (north side)) shows 10.03% vacancy;

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P-3.13.5.2. Guildford 013C (North and South of the Western end of York Road) shows 10.74% vacancy;

P-3.13.6. These two areas are also areas where the outdoors environment are in the most deprived 3% in the country.

P-3.13.7. There needs to be some positive intervention through the planning system to systematically reduce the numbers of HMOs in these areas.

P-3.13.8. Furthermore, the policy needs to take account of students who will inevitably be housed off-campus. The remaining student accommodation must be distributed across the urban area to avoid the creation of student ‘ghettos’ in order to foster and encourage a sense of community and the development of a society that includes both students and permanent residents.

P-3.14. The Guildford Society accepts that suitable accommodation needs to be provided for Travellers.

P-3.15. The Guildford Society does not have a sense from the Local Plan as to how the Council will approach any viability test, nor the sequential approach to any concessions that might be made. P-3.15.1. If the Local Plan is to be predictable and defensible, there

must be a clear hierarchy of need and a settled approach to determining the viability of any development in the context of CIL, Affordable Housing levies and in terms of other design and content provisions in this Local Plan when seen against the provisions of Policy 1 (Presumption in favour of Sustainable Development)

P-4. Affordable Homes

P-4.1. The concept and aspirations of this Policy are understood and commendable. The mechanism for delivery and its viability are absent, however.

P-4.2. As a general background to affordability of housing in Guildford Borough, as distinct from surrounding authority areas, The Guildford Society has reviewed government data which shows median house prices as a multiple of median earnings from 1997 to 2013 (the data can be viewed at

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https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/321015/Chart_576.pdf: P-4.2.1. 1997:

P-4.2.2. 1998:

P-4.2.3. 1999:

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https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/321015/Chart_576.pdf

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/321015/Chart_576.pdf


P-4.2.4. 2000:

P-4.2.5. 2001:

P-4.2.6. 2002:

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P-4.2.7. 2003:

P-4.2.8. 2004:

P-4.2.9. 2005:

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P-4.2.10. 2006:

P-4.2.11. 2007:

P-4.2.12. 2008:

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P-4.2.13. 2009:

P-4.2.14. 2010:

P-4.2.15. 2011:

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P-4.2.16. 2012:

P-4.2.17. 2013:

P-4.2.18. This set of charts shows that many of our surrounding local authority areas (notably Waverley, where median house prices have exceeded median income by more than ten times in ten of the past eleven years) have a larger affordability gap than Guildford (two of the past eleven years).

P-4.2.19. The Guildford Society believes this should not make us complacent but we do need to view these data in the appropriate context.

P-4.2.20. Within the Borough, in the Lower Super Output Areas, there are pockets of deprivation where access to housing and services is particularly challenging.

P-4.2.21. The Affordable Homes policy should ensure that a much more rigorous test (if not an absolute number applied

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without question) is applied in those areas where the Housing and Barrier to Services Domain score is within the most deprived quartile in the country. P-4.2.21.1. Guildford 001A P-4.2.21.2. Guildford 001B P-4.2.21.3. Guildford 002A P-4.2.21.4. Guildford 002B (top decile) P-4.2.21.5. Guildford 003B P-4.2.21.6. Guildford 003C P-4.2.21.7. Guildford 003F P-4.2.21.8. Guildford 004D P-4.2.21.9. Guildford 005C P-4.2.21.10. Guildford 006B P-4.2.21.11. Guildford 006C P-4.2.21.12. Guildford 017A (top decile) P-4.2.21.13. Guildford 017B P-4.2.21.14. Guildford 017C (top decile) P-4.2.21.15. Guildford 018A (top decile) P-4.2.21.16. Guildford 018C

P-4.2.22. In 2007-8 fiscal year, the average estimated proportion of families in poverty in the Guildford Borough Middle Super output Areas was:

Approximate Percentage of

Households Below 60% of the Median

Income; (after housing costs)

E02006344 Guildford 001 11.4E02006345 Guildford 002 10.0E02006346 Guildford 003 8.9E02006347 Guildford 004 10.5E02006348 Guildford 005 14.4E02006349 Guildford 006 13.4E02006350 Guildford 007 24.0E02006351 Guildford 008 12.0E02006352 Guildford 009 16.6E02006353 Guildford 010 19.0E02006354 Guildford 011 9.1E02006355 Guildford 012 25.1E02006356 Guildford 013 12.9E02006357 Guildford 014 13.6E02006358 Guildford 015 14.2E02006359 Guildford 016 10.7E02006360 Guildford 017 13.2E02006361 Guildford 018 11.0

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P-4.2.23. Guildford 007 covers the Bellfields and Slyfield areas:

P-4.2.24. Guildford 012 covers the Park Barn area including Dennisville and Ashenden and part of Westborough, along with the Manor Farm campus of the University.

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P-4.2.25. The data are not particularly focussed and it is worth noting that some parts of these two MSOAs already have some LSOAs with relatively high levels of social rented housing: P-4.2.25.1. Guildford 007A 28.73% P-4.2.25.2. Guildford 007B 24.02% P-4.2.25.3. Guildford 007C 52.82% P-4.2.25.4. Guildford 007D 29.03% P-4.2.25.5. Guildford 012A 8.49% P-4.2.25.6. Guildford 012B 38.35% P-4.2.25.7. Guildford 012C 47.54% P-4.2.25.8. Guildford 012D 59.94%

P-4.2.26. The weekly rents of Council housing has on average risen by 4.18% per year since 1998/99.

P-4.3. The affordability of affordable housing is by no means assured for those in the greatest poverty and Government policies aimed at encouraging those on housing benefit with more bedrooms than required to downsize have led to further (penalty) charges.

P-4.4. Affordable housing is NOT the same as social housing. P-4.5. Many key workers struggle to find accommodation in Guildford and

are forced to commute – some service sector workers commute from as far away as Portsmouth.

P-4.6. It is possible for lower paid staff to commute into Guildford from more affordable centres due to the availability of public transport, and a more viable solution may be to improve public transport links

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rather than to expect to house everyone who may wish to live in Guildford – the difference between DEMAND and NEED.

P-4.7. Clearly a cohesive and viable strategy for affordable housing is required.

P-4.8. Recent applications and proposals for developments in Guildford appear to be challenging the viability of providing 30% affordable homes in line with the current (2003) Local Plan. Once CIL is introduced and a 40% threshold is applied (subject to viability), and taking into account the current infrastructure deficit for which CIL is not intended to be used, this policy is likely to fail to deliver the required level of development of affordable homes.

P-4.9. To ensure the delivery of affordable homes the Council may be better placed to ask the Government if it can levy a surcharge on Council Taxes at, say an average of £100 per home per year with the greatest burden falling on the highest bands, and for the proceeds (around £5.5m per year) to be hypothecated for the express purpose of the Council building affordable homes.

P-4.10. In the meantime, to the extent the higher target for dwellings per year is predicated upon closing the affordability gap, it will be essential that it can be shown to actually deliver as proposed. We do not expect this to be the case without direct intervention.

P-4.11. The Guildford Society is not convinced that the good intent of this policy will, as drafted, result in any significant increase in the affordability of homes and OBJECTS to the policy as drafted.

P-4.12. As regards the specific policy drafting in any event, we consider an additional point should be added after the fourth bullet to the effect that [these affordable homes will be provided] through conversion of long-term vacant retail, office or industrial property or by bringing back into use flats located above retail properties.

P-5. Rural Exception Homes

P-5.1. Although this policy has no particular direct relevance to the Guildford Society, we are concerned that this is another example of a good principle spoilt by slack controls – the viability test to hold the developers to account for providing affordable homes in the countryside is simply too weak.

P-6. Making Better Places

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P-6.1. We applaud the intention but do not believe the Draft Plan sufficiently embraces NPPF Paragraph 62, and strongly assert that the Council needs to establish a Design Review Panel (‘the Panel’) with full statutory consultee status. The Guildford Society is happy to form the nucleus of the panel and fully recognises that it is not the purpose of the Panel to frustrate or prevent development but to uphold the principles of place-making and great design.

P-6.2. Some of the wording needs to be tightened up in the supporting text. For example, in 4.71 we think we should be creating “great places for people to live in, work in, study in, visit and otherwise use.”

P-6.3. The Policy itself could, as noted by our Design & Heritage group, be reworded along the following lines: P-6.3.1. POLICY 6: Making better places

P-6.3.1.1. We require all new developments, whether individual buildings or large-scale development schemes, to achieve high quality design and enhance the environment in which they are set. This will be achieved by: • Master-planning all major developments of

an area of greater than […] • Develop with imagination and style,

reflecting our position as a regional centre and County town while ensuring that new development has due regard to existing architectural styles, urban grain and where relevant, Guildford’s county town architectural vernacular;

• Preserve existing skylines and sightlines, with roof-sited plant on new developments being architecturally clad; and

• mplementing and constituting an independent design panel to review and make recommendations about planned major buildings.

P-6.3.1.2. Large scale residential developments (20 or more dwellings or 0.5 hectares or more),

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informed by the Guildford design principles must: • provide a harmonious, integrated mix of

uses that fosters a sense of community and contributes to the creation of inclusive communities that provide the facilities and services needed by them;

• provides places for communities to meet and interact, such as play and recreation and other public spaces in large developments;

• are provided with adequate vehicular and public transport links

• give priority to plan positively for non-car based modes of transport;

• are designed to facilitate and promote walking as a means of transport, providing a high quality environment for pedestrians. Where possible residential areas should allow short walking distances to amenities; and

• provide convenient and safe routes through the development and to nearby areas for cyclists.

P-6.3.1.3. All developments will: • promote and reinforce local distinctiveness

to create a sense of place. Innovative architecture will be encouraged and supported in the appropriate context;

• be expected to have regard to and perform well against Building for Life criteria;

• be expected to use art and materials of a nature appropriate to their setting;

• take account of the context in which they are sited.

P-6.3.2. The Guildford Society are unsure that the criteria for a major development are appropriate and emphasise,

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therefore, that the reference to context needs to be strong enough to ensure such developments do fit well into their surroundings.

P-7. Sustainable Design, Construction & Energy

P-7.1. Again, the Guildford Society embraces the principles espoused in the policy but we require more emphatic language.

P-7.2. The statement of “our ambition” is the planning equivalent of the lawyers’ “agreement to agree” which is barely worth the paper it is printed on.

P-7.3. There needs to be clarity of targets and a clear understanding of what third party involvement needs to be secured (eg., infrastructure providers).

P-7.4. The Council could help in this process by building a knowledge bank of research and consultants’ reports identifying what is possible in the borough and what can broadly be ruled out. For example, ground permeability studies might enable the installation of more Sustainable Urban Drainage Solutions (‘SUDS’).

P-7.5. The policy also needs to have some regard to pressures to site wind turbines and solar farms in our area and there must be some planning guidance or presumption against such installations unless they can be shown to have minimal visual impact on key views.

P-7.6. Water attenuation and rainwater harvesting is to be encouraged to both reduce flood risk and to enable our scarce water supplies to go further.

P-7.7. Where possible otherwise, new development should drain to soakaways and land drains rather than add to the pressure on surface water drains.

P-8. Surrey Hills AONB

P-8.1. The protection of the AONB is paramount and should amount to (and be articulated as) a presumption against development in the strongest possible terms.

P-8.2. The context and views into and from the AONB should be afforded similar controls and there should be a presumption against any major new traffic junctions in the AONB where they would be required to be lit and/or where they and their associated roads would visually impact the AONB or its setting.

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P-8.3. The Guildford Society broadly supports the principle of the policy and, whilst it would benefit from some tighter wording, we do not see a need to add further comments here.

P-9. Villages and Major Previously Developed Sites

P-9.1. The weakness of the Settlement Profiles Report and the Green Belt and Countryside Report are particularly challenging in the context of this draft policy. Furthermore, the inadequacies of the infrastructure baseline and the absence of an Infrastructure Delivery Plan, are major impediments to the strategy for villages and previously developed sites.

P-9.2. The settlements and communities need to be intrinsically sustainable communities and the focus should be on sustainability rather than on whether the settlement is washed over by the green belt or inset. NPPF has clear guidelines and it is by no means clear that these have been followed.

P-9.3. The Guildford Society is keen to ensure that the character of the borough remains broadly intact whilst recognising that, AONB aside, no area can be substantially immune from development.

P-9.4. The proposed insetting of settlements seems to us to be illogical and poorly thought out. The Guildford Society is not opposed to insetting in principle but considers that many rural settlements and villages have functioned well for fifty years or so whilst being washed over by the Green Belt.

P-9.5. The redrawing of Green belt boundaries (see also P-10 below) will require the Council to demonstrate ‘Exceptional Circumstances’ and there is no clear sense that, in most villages, such exceptional circumstances exist, if any.

P-9.6. The Guildford Society is not well positioned to get engaged in specifying the appropriate treatment for villages and insetting and, in all case as far as we are aware, these are covered by Parish Councils who can best respond.

P-9.7. The Guildford Society does, however, have serious concerns about the content and quality of the Settlement Profiles Report and believes that this and the flawed Green belt and Countryside Report, and the paucity of real information on rural infrastructure in the Infrastructure Baseline do not seem to place the Council well in terms

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of making the case for insetting in any particular case and risks poor decision-making in and under the Draft Local Plan.

P-10. Green Belt and Countryside

P-10.1. Successive Communities and Local Government communications have made it clear that the Green Belt does not have to be redrawn and that it for Local Authorities to choose whether to review their Green Belt Boundaries.

P-10.2. This guidance came out too late for Guildford Borough Council but the Council had already decided to review the Green Belt by its appointment of Pegasus in 2009 (well before NPPF was introduced in 2012) due to a shortage of land identified as part of the South East Regional Plan exercise.

P-10.3. The Council having decided to review our Green Belt boundaries, we recognise that the Guildford Society must consider this policy in that light.

P-10.4. The apparent intention of the Green Belt policy is, therefore, broadly correct but its interpretation in the allocation of sites and the proposed realignment referred to at 4.123 is a largely incoherent and an unnecessarily blunt instrument.

P-10.5. The policy, therefore, misses the point it tries to make and proliferates a number of seemingly unnecessary ‘nibbles’ to the green belt boundary, resulting in an illogical and, in places, completely indefensible and non-permanent boundary. It is, in the opinion of the Guildford Society, in contravention of the principles and policies of NPPF.

P-10.6. The Guildford Society is not fundamentally or philosophically against the realignment of the Green Belt boundaries as an occasional EXCEPTION and under exceptional circumstances, but it fully supports and endorses the NPPF requirement for the boundary to be permanent.

P-10.7. We should note that a significant number of our members are opposed to the use of Green Belt land for development and that this ensures that our approach is both cautious and expects a strong burden of proof of both the necessity and of the exceptional circumstances outweighing the harm to the Green Belt.

P-10.8. Furthermore, NPPF requires land to be identified and allocated well beyond the Plan Period and the Guildford Society considers this must

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mean that we either have to make available sufficient land for development for more than one plan period or we have to recognise the constraints of the AONB, SPAs, SSIs and Green Belt for what they are (notwithstanding additional constraints of the historic infrastructure deficit) and allocate our available space between two plan periods.

P-10.9. Constrained Plan P-10.9.1. The SHLAA identifies scope for 15,629 residential units over

the Draft Plan Period (notwithstanding that the Guildford Society objects to some of the proposed site allocations) which, divided between two plan periods and assuming the legal constraints remain firmly intact would suggest that Guildford can only provide around 400 per year for the foreseeable future (in the spirit of NPPF Paragraph 181: “a final position where plans are in place to provide the land and infrastructure necessary to support current and projected future levels of development”.

P-10.10. Assuming Green Belt Realignment P-10.10.1. The Guildford Society recognises (and has received

general – but not universal – acceptance from those attending our series of talks on the emerging Local Plan) that the level of provision of development under a fully constrained plan would most probably be insufficient to allow Guildford to function properly.

P-10.10.2. The boundaries of Guildford Urban Area, if redrawn, need to ensure that new extensions are provided with or very close to local amenities and facilities, and need to have wholly defensible permanent boundaries. The development of such sites must not so adversely affect the openness of the Green belt and cause such harm as to outweigh the presumed and actual benefits.

P-10.11. Brownfield First P-10.11.1. The Guildford Society is advocating a Brownfield First

principle should apply – not meaning specifically that Green Belt can only be developed once every piece of brown field land has been developed but that strategic priority must be given to the good use of previously used land such that the

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necessity for incursions into the Green belt can be reduced or eliminated over the Plan Period.

P-10.11.2. As part of the Brownfield First strategy, we are actively supporting the Guildford Vision Group concept of a complete rethink of the River Wey corridor to the north of the town centre.

P-10.12. River Wey Corridor (north of the town centre) P-10.12.1. As noted above (in the response to 3. Homes for All), the

area around the station and in Walnut tree Close is one of the most deprived 2.5% of LSOAs in the country for outdoor environment.

Guildford 015A (Walnut Tree Close and Station)

P-10.12.2. The principles we are applying to this example – which might apply on their merits respectively to other brownfield areas – are that: P-10.12.2.1. The replacement of like-for-like business space

on the edge of town (or elsewhere in a suitable business location) would require a broadly similar if not slightly smaller overall footprint than is currently provided;

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P-10.12.2.2. The provision of housing towards or on the urban fringe would be at a density of, say, 40 dwellings per Hectare;

P-10.12.2.3. The development of such key land – even allowing for a linear riverside park – could provide high quality living environments with a density in excess of 100dpH (assuming height and massing issues can be overcome), even allowing for a semi-basement parking area which can be designed to accommodate flood water in extreme flooding events;

P-10.12.2.4. A master planned and Council-promoted development would enable a coherent development, maximising land uses and would ensure delivery in a way the multiple private ownerships could not achieve;

P-10.12.2.5. More homes could be provided on less land overall by targeting the regeneration of such sites which the data tells us are in urgent need of regeneration;

P-10.12.2.6. The provision of a linear riverside park (preferably on both sides of the river, extending a green-blue corridor from the National Trust’s Dapdune Wharf site all the way into the town centre) would help provide some dramatic improvements to the outdoors environment and the air quality around the existing housing in Walnut Tree Close and around the station.

P-10.12.3. It is our judgement, therefore, that efficient use of land (both brownfield and greenfield) in this case, would suggest the displacement of uses from Walnut Tree Close which would need to be made available elsewhere, and that the optimal location may be as part of an expansion of the Slyfield Industrial Estate (‘Slyfield Estate’).

P-10.13. Slyfield Estate

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P-10.13.1. The land between Slyfield Estate and Jacobs Well is part of the Green Belt and a 200m strip is considered by the GBCS report as fulfilling an important green belt function – avoiding coalescence, among others. By creating a strip of bunded woodland between the extension and Jacobs Well, the protection zone between the two areas could be preserved – albeit narrower – or a strategic decision could be taken to move the boundary of the Guildford Urban Area outwards to the northern limits of Jacobs Well.

P-10.13.2. The Green belt boundaries (redrawn) could be made to be defensible and permanent and the exceptional circumstances in this case would include enabling the urban regeneration of an area of partial relative deprivation in the town centre and the resolution of traffic and transport issues both locally and within the town.

P-10.13.3. More importantly, the expansion of Slyfield Estate would P-10.13.3.1. Benefit from the creation of a park & ride at

Slyfied (probably served off Clay Lane) and linking to the proposed GTAMS ‘Golden Thread’ public transport, pedestrian and cycle way to the town centre and station;

P-10.13.3.2. Require a much better access to and from the A3 to reduce pressure on the A320, probably taking the form of a four-way junction – for which additional land would need to be reserved for infrastructure developments in the Green Belt;

P-10.13.3.3. Need to include some general amenities for convenience shopping and cafés/ restaurants;

P-10.13.4. This infrastructure improvement would enable some development to the north of Burpham.

P-10.14. Gosden Hill Farm P-10.14.1. Although the proposed Green Belt release is for Potential

Development Areas C1 and C2 in the Green Belt and Countryside Report, the Guildford Society highly values the openness of the Green Belt comprising PDA C2 when

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viewed towards Guildford to the left of the A3 Southbound carriageway.

P-10.14.2. Development on the downslopes towards the A3 would cause unjustifiable harm to the openness of the Green Belt and should be resisted.

P-10.14.3. On the other hand, the Guildford Society does not have an objection in principle to the eastern half of the site (south of the line of trees marking the ridge) being developed for housing, access being improved by the introduction of a Merrow/Burpham station on the railway.

P-10.14.4. The permanent demarcation of the Green Belt between the open downslopes (described above) and the part of the site for development should be by way of a strip of bunded woodland along the ridgeline. This and the woodland to the north of the site would protect the Green Belt boundary as a permanent feature and, on the proviso that exceptional circumstances can be demonstrated, the Guildford Society would support the realignment and release of green belt (as noted herein) either for this Draft Plan or the next.

P-10.14.5. Development should not take place unless or until the all-direction A3 junction has been installed AND once there has been a firm undertaking to provide the new railway station.

P-10.15. Blackwell Farm P-10.15.1. This Draft Plan is not to concern itself with the past

performance (or failures) of the University to fulfil its development promises – the failure of which is partly responsible for the shortfall in housing in recent years. It must, however, consider the likelihood of a site allocated in the Draft Plan actually being available for development.

P-10.15.2. On balance, the economics of the proposed allocation probably mean it will be brought forward if the quantum of housing offset by the planning obligations remains viable.

P-10.15.3. The Guildford Society does not object in principle to urban extensions where suitable. In this case, however, we recognise that the existing ancient woodland and the Area

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of Outstanding Natural Beauty represent defensible and permanent boundaries for the Green Belt.

P-10.15.4. The proposed realignment of the Green Belt (and especially the University’s current proposals which extend further into the Green Belt) is troubling on a number of counts: P-10.15.4.1. The rationale in the GBCS report – if replicated

at the next Local Plan process – would lead to further urban expansion beyond that currently proposed. The landscape is open across the reach of the hillside below the Hog’s Back – with the partial exception of Wildfield Copse – from the Guildford Urban Area all the way to Flexford. The logical defensible boundary is in its current position.

P-10.15.4.2. The development proposes access via a grade-separated junction on the A31 along the peak of the Hog’s Back, within the AONB and requiring 24-hour lighting. This would be an unacceptable intrusion and must be treated as part of the harm such a realignment of Green Belt boundaries would cause.

P-10.15.4.3. The precedent of protection of the AONB land has not been favourable in the Manor Farm area where the construction of the most recent Park & Ride facility was delivered.

P-10.15.5. In terms of the development proposed, the Guildford Society strongly supports the development of enhanced knowledge-based industries around the existing world-class cluster at the Surrey Research Park.

P-10.15.6. Furthermore, we are concerned (as noted above) that there has been insufficient attention to providing suitable up-skilling and employment opportunities for the residents in the Park Barn area – in which the LSOAs score particularly badly.

P-10.15.7. The area of the proposed site north of the dividing line (hatched yellow below) between LSOA Guildford 005E and

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Guildford 017C should, in our view, be available substantially for employment uses in this plan and the next. We would prefer to see a woodland link between Wildfield Copse and Strawberry Copse and for that to be the boundary of the Green Belt – made defensible and permanent by such planting.

P-10.15.8. In the event that a larger area is demonstrated to be appropriate for removal from the Green Belt (meeting all of the tests in the NPPF and the benefits demonstrably outweighing the harm) and notwithstanding the concerns about development proposals per se in this location, any

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realignment of the Green Belt must involve the creation of a permanent (but natural) boundary on the Western edge.

P-10.15.9. Development must be limited to the extent an absolute preclusion of development above the 90m Above Ordnance Datum (‘AOD’) contour line and a limit in building height of no greater than 95m AOD anywhere on site and a restriction of, say, three stories to any building on the site.

P-10.16. Wisley Airfield P-10.16.1. The proposed development at Wisley is particularly

troubling – not because it is development in the Green Belt, but because of the scale of development.

P-10.16.2. The Guildford Society considers the proposed development to be either too small or too large: P-10.16.2.1. Too small to be self-contained and to avoid

unacceptable impact on local amenities and facilities and on the local roads.

P-10.16.2.2. Too large to sit alongside the existing communities without becoming a cuckoo in the nest.

P-10.16.3. The site is previously developed land in the Green Belt. P-10.16.4. The site is very close to the Thames Basis Special

Protection Area. P-10.16.5. The site, whilst relatively open to Ockham village, is not

particularly open to the wider views – although by no means invisible.

P-10.16.6. This is a site where there is a presumption against development in the Green belt except under Very Special Circumstances (for an applicant) or Exceptional Circumstances (for Guildford Borough Council to redraw the Green Belt boundaries to inset it) and where the benefits can be demonstrated to outweigh the harm to the Green Belt.

P-10.16.7. The Guildford Society recognises that if the case for the quantum of housing can be proven, if a constrained Local Plan would not be found sound and if we are unable to persuade our neighbouring authorities to take our excess housing need, then the housing would have to go

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somewhere and previously developed land would be preferable to virgin Green Belt.

P-10.16.8. We accept that this is not a popular position for us to take but it seems appropriate under the circumstances and given the land could be brought forward in the early part of the plan period post adoption, whilst brownfield alternatives are likely to come forward much more slowly.

P-10.16.9. In the case of Wisley, there needs to be a very high cost to the developers of ensuring the development does not adversely affect the viability and vitality of the surrounding centres and encouraging them to put in place permanent mechanisms for connecting the communities.

P-10.17. Overall, however, the Guildford Society is adamant that the Green Belt is a precious resource that cannot be (or is at least highly unlikely to be) replaced. Any decision to redraw the boundaries must be taken with a heavy heart and from a perspective of caution.

P-10.18. The Guildford Society has little specific to add to the proposal to extend the Green Belt towards Ash South and Tongham except that – assuming the Exceptional Circumstances argument is strong – this seems like a sensible proposal to avoid the circumstances where Ash and Tongham become the development area by default rather than of choice.

P-11. Ash & Tongham Strategic Location for Growth

P-11.1. The deprivation indices show that care needs to be taken in this area. There is a major area of relative multiple deprivation just across the boundary in Rushmoor and the urban area of Ash South & Tongham has expanded, in part at least, because the area is beyond the restrictive controls of the Green Belt.

P-11.2. Broadly, this area is beyond the Guildford Society’s area of specific interest, but it would seem sensible to apply a level of control to development in the area to ensure the planning policies and spatial allocations are consistent with strategies to resolve specific deprivation issues.

P-12. Historic Environment

P-12.1. The Guildford Society objects to this policy. The prematurity of this policy in the light of an absence of key documents is outweighed only

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by the timidity of the language and the promises as yet unfulfilled in the text of the policy itself (“we intend to review…”; “we are in the process of…”; and “we will further develop our strategy…”).

P-12.2. The historic environment is key to Guildford’s success, and it is very much within the scope of The Guildford Society’s remit to seek to ensure the protection and enhancement of key assets, key views, key and places.

P-12.3. The Guildford Society also wishes to ensure that the context, surroundings and environment are protected to ensure that the integrity of Guildford as a Gap Town is preserved.

P-12.4. The Design and Heritage Group within the Guildford Society has established a series of position papers, much of the content of which could and should form the basis for the policies in this Draft Local Plan and its companion Development Control Local Plan.

P-12.5. The Guildford Society is concerned that so much of the background information that would enable us to take a view on the suitability or otherwise of this Policy is yet to be produced.

P-12.6. The Guildford Society has made reference internally to a desire to compile and maintain a map of heritage assets, but it has no budget to complete the same. The Council could, in the context of this Local Plan, and given the reference at 4.139 to the section of the sister Plan (‘Delivering Development’), the first draft of which we have not yet had sight of, we feel there is an opportunity to combine the policy aspirations of the Council with the heritage aspirations of the Guildford Society.

P-12.7. Within the body of the Policy itself, we would suggest some additions: P-12.7.1. In the first paragraph: “…The borough has many rich and

varied heritage assets including the Historic High Street, listed buildings, conservation areas, homes and their gardens, scheduled monuments, historic park and gardens, the River Wey and its valley, the Surrey Hills AONB, key views and viewing points, and areas of archaeological value and potential”.

P-12.7.2. At the end of the second paragraph we believe a further sentence should be added: “Where a designated or undesignated heritage asset is redeveloped (for whatever

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reason), new buildings or extensions should be of a similarly high architectural standard as the original asset.”

P-12.8. Paragraph 4.137 notes that there is a proposed series of Conservation Area Appraisals. The Guildford Society believes that this should also include a commitment on the part of the Council to consult with local communities to ensure that these appraisals have documented aspects of character of importance to residents.

P-13. Economic Development

P-13.1. The Draft Local Plan does not list as part of its Evidence Base the Draft Economic Strategy 2013, despite referring to it at 4.144.

P-13.2. At 4.145 the Economic Strategy Vison is repeated, including for “Guildford to be a town and borough with strong infrastructure” along with other key objectives.

P-13.3. The Guildford Society is concerned that the ambition in the Economic Strategy is not sufficiently reflected in the Draft Local Plan and is not well provided for in the Employment Land Assessment.

P-13.4. The further key objective to attract “world class businesses with capacity to expand and deliver growth” is conflicted by the piecemeal proposed provision of employment space in areas where major companies would not necessarily wish to be located.

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P-13.5. The driver to provide employment (as demonstrated by the proposed monitoring indicator ‘number of employee jobs’) should be replaced by a more meaningful integrated indicator between housing, employment, skills and income.

P-13.6. Given the very specific ambitions, therefore, it is disappointing that, whilst the policy is spatially explicit in broad terms, it does not set out explicitly to prioritise or deliver an increase in Gross Value Add (GVA) from the allocation of scarce resources.

P-13.7. The vision and ambition for economic development in the Draft Local Plan needs to more explicit in its definition of the types of business being targeted and why the sites allocated should be suitable for the targeted sectors.

P-13.8. The Guildford Society supports in principle a policy which sets out to achieve more jobs in the creative, knowledge and high technology sectors but does not, sadly, see this policy as delivering either the conditions for attracting such investment nor the spatial solutions.

P-13.9. The traditional industries still require support and provide valuable employment. Where large facilities employ few people, these should be discouraged and some measure of employment density and GVA should be targeted through the policy.

P-13.10. Equally, given some of the challenges in the Borough in terms of skills, income and employment, it would surely have been important to have targeted measures to solve known issues.

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Areas of Relative Deprivation – Employment (2010)

Areas of Relative Deprivation – Education, Skills and Training (2010)

P-13.11. The scarcity of land in the Borough means that we need to be explicitly cautious to avoid attracting businesses employing few

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people on large areas of land at the expense of higher value-adding businesses and SMEs.

P-13.12. The list of sites and areas in the Policy does not include the proposed site allocation (Site 55 – ‘Tongham Triangle’) unless it is referred to here as “Land at Grange Farm, Tongham”, and neither is it specifically included under Policy 11.

P-13.13. The list in the policy excludes Walnut Tree Close (notably in terms of the protection of strategic employment sites and retention and intensification of employment) but does not suggest where existing businesses might go, and it includes Woodbridge Meadows.

P-13.13.1. The Guildford Society is recommending the comprehensive development of both Walnut Tree Close and Woodbridge Meadows for housing and the displacement of businesses to a larger than planned expansion of the Slyfield Industrial Estate.

P-13.13.2. This proposal would see most businesses displaced from that area – although it will be important to identify local solutions to ensure that businesses supporting or relying on interaction with the town centre are not driven out to unviable locations.

P-13.13.3. See our comments in the site-by-site analysis

P-13.14. This policy fails to capitalise on the Industry Clusters already in the town and borough and fails also to protect them and enable them to grow – please note the entire section on page 05 of the Economic Strategy 2013.

P-13.15. Slyfield Industrial Estate has a good critical mass of employment – mostly providing a contrast in terms of business types to the Surrey Research Park. Both are essential to the economy of the town and borough. The scope to make Slyfield more accessible and also to accommodate more employment space should be a clear plan priority and the Guildford Society considers this needs to include:

P-13.15.1. A larger than planned northern expansion for ‘B’ uses;

P-13.15.2. A four-way junction at Burpham on the A3;

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P-13.15.3. Improvements to Clay Lane (as per Draft Local Plan);

P-13.15.4. A clear bunded woodland separation from Jacobs Well;

P-13.15.5. A new Park & Ride facility for workers and shoppers;

P-13.15.6. A new SANG area to comply with SPA rules;

P-13.15.7. Public Transport corridor linking to the town centre;

P-13.15.8. Ancillary facilities for convenience and hospitality;

P-13.16. Blackwell Farm – as noted at P-10.15 above – is an essential part of the long term success of the internationally-recognised and economically significant Surrey Research Park. Sufficient land needs to be safeguarded long beyond the end of the current Local Plan to ensure that there are no severe spatial constraints which might lead the entire park to fail in due course.

P-13.17. Retail Employment

P-13.17.1. The proposed retail expansion in the town centre is not mentioned as part of the Economic Development policy and surrounding paragraphs.

P-13.17.2. We will refer to this again as part of our response to both the Leisure and the Town Centre policies (Policies 14 & 15 respectively).

P-13.17.3. In the meantime, however, there is a series of conundrums as to whether the employment numbers have included or excluded new retail jobs (say, circa 1,150 as noted in ‘Working Futures’) and whether the affordable housing projections have taken into account the likelihood of many of these new shop workers being on wages not significantly higher than the Minimum Wage.

P-13.17.4. The impact on affordable housing numbers on the one hand and employment land requirements on the other are substantial and significant in the context of the Draft Local Plan.

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P-13.18. Although the Rural Economy is mentioned in the policy, this is merely as a policy undertaking to “support rural economic development opportunities”.

P-13.19. Given the significant proportion of the borough’s population living in rural areas, this needs to be addressed. The 2013 Economic Strategy noted that:

“A third of borough residents live in a rural area, and the rural wards account for 25 per cent of all employment in the borough. In addition to farming, food and tourism the range of jobs and businesses is extensive including shops, workshops, distribution, ICT, childcare and education, residential homes, manufacturing, property, corporate headquarters and offices. Internet business and working from home is increasing. This shows the diversity of the borough’s rural economy and stakeholders support the view that all forms of business can be appropriate in the countryside, and that small rural businesses should be supported to remain in rural areas as they start to expand where possible, as this plays a crucial role in the development of the rural economy.” (our emphasis)

P-13.20. The Local plan will need to be more positive and enabling, and it should take its lead from the Council’s own economic strategy.

P-13.21. Equally, care must be taken to ensure that rural jobs are not provided in such a way as to urbanise the rural areas by stealth or neglect.

P-13.22. Furthermore, and of PARAMOUNT IMPORTANCE, the infrastructure (especially transportation and traffic) is already failing as noted in the 2013 Economic Strategy and needs urgent attention in order to facilitate any further development:

“Traffic congestion in the town centre and on the gyratory in particular is considered to be one of the town’s main weaknesses.”

P-14. The Leisure and Visitor Experience

P-14.1. The policy needs to begin not by supplication but by emphasis: “We expect the provision…” should be replaced by “A key factor in the success of our town and borough is a high quality visitor experience.

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As a consequence, we will protect and enhance the contribution that tourism, arts, cultural heritage and sport make to our quality of life…”

P-14.2. “Historical and heritage sites” needs to be added into paragraph 4.162 to reflect the fact that not all heritage assets are in the town centre.

P-14.3. The policy also needs to focus on the High Street, the River and other heritage assets missing from the list in paragraph 4.163 and 4.164 to ensure that the viability and vitality of these is preserved and the context, setting, views in and out are protected and enhanced. 4.164 needs to include the Surrey Hills AONB.

P-14.4. The policy is written in such an underwhelming way that it is hard to see that this will ensure a focus on those things that make Guildford so attractive.

P-14.5. The Guildford Society (notwithstanding that we would prefer to see a newly drafted positive policy) considers that:

P-14.5.1. The first bullet in policy 14 should have appended to it “…character of the area including sustaining the Spectrum and Surrey Sports Park as pre-eminent regional sorting venues.”

P-14.5.2. We would add two new bullets to the end of the list:

P-14.5.2.1. “Supporting the provision of new and improved information at heritage sites that improves their understanding by vistors, including the provision of blue ‘heritage’ plaques on buildings and additional photo interpretation boards.”

P-14.5.2.2. “supporting the provision of new and improved child/family oriented facilities in both urban and rural areas including outdoor and indoor play areas, gymborees, farm parks and performances.”

P-14.6. Furthermore, the leisure experience will increasingly be critical to the commercial viability of the town centre over the coming years, when

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the increase in internet sales will mean that the leisure aspects of shopping will become so much more important.

P-14.7. It will be of paramount importance, therefore, that the proposed retail development of Site 20 (North Street) complements and enhances the High Street rather than diverting people from it and leading to its long term demise.

P-14.8. The connections and links between University, Cathedral, station, riverside, High Street, castle, G-Live and other key locations need to be planned and (where necessary and appropriate) land reserved in the Local Plan to ensure the visitor experience is cohesive and attractive.

P-14.9. The Guildford Society is pleased at references to the rural visitors and would encourage the Council to ensure that conservation areas and picturesque scenes are protected and enhanced.

P-15. Guildford Town Centre

P-15.1. Paragraph 4.173 focuses on the two linear features (River Wey and High Street) which are – or could be – attractive features. It does not highlight two other linear features which are far less beneficial for the town – the railway and Onslow Street.

P-15.2. The Guildford Society has been encouraged by the recognition of the environmental challenges and the approach the Council has taken to the town centre in recent weeks and months.

P-15.3. The Vision in the Draft Plan needs rewriting to reflect the principles arising from the Allies & Morrison visioning exercise.

P-15.4. The Town Centre Policy itself is insufficient to enable or to ensure delivery of a stellar town over the plan period and needs completely rewriting.

P-15.5. The initial part of the policy sets as the main focus the delivery of 50,000 sqm of retail space which is justified by an outdated Retail Study for which much of the data was gathered between 2004 and 2006.

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P-15.6. The general bullet list of features to be encouraged and facilitated seems appropriate but the policy is somewhat unwieldy and the key components are either missing or understated.

P-15.7. The Guildford Society would like to see:

P-15.7.1. The complete reorganisation of the town centre to reduce (or preferably eliminate) the impact of vehicular traffic on the town centre, the riverside and town centre connectivity.

P-15.7.2. The promotion of larger packages of sites for regeneration such as:

P-15.7.2.1. A Water Quarter between Friary Street and Park Street including a market square at the bottom of North Street and incorporating the Electric Theatre and buildings fronting the southern side of Bridge Street;

P-15.7.2.2. The Station Quarter including the land from the railway tunnel to the proposed Guildford Vision Group bridge and from the River Wey to Guildford Park Road;

P-15.7.2.3. The Bedford Road Quarter incorporating the north side of Bridge Street and the Odeon Cinema;

P-15.7.2.4. A Riverside (West) Residential Quarter encompassing Walnut Tree Close from the Guildford Vision Group proposed bridge to the Clandon line railway viaduct and Guildford Park Car Park;

P-15.7.2.5. A Riverside (East) Residential Quarter including the law courts and police station and extending as far as the Woodbridge Road cricket ground;

P-15.7.2.6. A Riverside (North) Residential Quarter bounded by the Clandon line rail viaduct, the

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Waterloo Line main railway, Ladymead and the River;

P-15.7.3. These areas could be comprehensively regenerated and could provide substantial new quarters designed to provide exemplary environments for residents and visitors, great public realm and go some way towards resolving some of the issues highlighted by the Multiple Deprivation Indices.

P-15.7.4. Two strong threads should run through all aspects of the town centre and immediate surrounds:

P-15.7.4.1. Opening up the river to leisure on both sides throughout its length through the town centre. This will involve the creation of a linear riverside park and comprehensive flood protection;

P-15.7.4.2. Removing most traffic from all town centre areas (aspiring to limit traffic from the eastern end of the Upper High Street; the entire length of the High Street from Abbots Hospital to Millbrook; Quarry Street from the High Street to Castle Street; North Street; the entire area bounded by Park Street, Bridge Street and Onslow Street; Onslow Street itself and Chertsey Street).

P-15.7.5. Land needs to be reserved in the Local Plan and safeguarded from piecemeal development. A clear statement of intent needs to be expressed by which the Council would seek to assemble sites and ensure the delivery of developments and the regeneration of whole areas.

P-15.7.6. By regenerating these areas comprehensively it should be possible to maximise development whilst delivering major environmental improvements and fostering the kind of visitor experience noted in Policy 14.

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P-15.7.7. The town centre needs to be regarded as a key piece of infrastructure for the borough and for the region.

P-15.7.8. We support the Allies & Morrison vision but with the amendment proposed by the Guildford Vision Group whereby a new bridge takes traffic away from Onslow Street and the gyratory system.

P-15.7.9. We strongly support a wide-ranging pedestrian priority zone with spaces shared with buses but not everyday traffic.

P-15.7.10. The Policy needs to include an assertive statement in defence of the High Street, such as:

P-15.7.10.1. “We will preserve the existing character of the High Street, including continuing to place limitations on the size and character of shop fronts, and conserving its connecting gates and granite setts and York stone paving.”

P-15.7.11. The combination of regenerating key underused assets and preserving our heritage will ensure Guildford is a most attractive town and visitor attractor for the foreseeable future – the core infrastructure for a thriving borough.

P-16. District and Local Centres

P-16.1. The principal weakness in this policy (arising directly from one of the major failings of the Evidence Base) is the poor understanding of and inadequate planning for the Guildford Urban Area, its neighbourhoods and communities.

P-16.2. Consequently, Policy 16 does nothing to help deliver solutions to recognised problems (such as those highlighted in the Indices of Multiple Deprivation).

P-16.3. Some of the village and neighbourhood centres are failing due to competition from elsewhere or from an unsustainable shortfall in local population.

P-16.4. There are some good examples of neighbourhood shopping but this should not be seen as the norm.

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P-16.5. In an area such as Park Barn where there is considerable relative deprivation, the local centres could provide additional facilities for young people, some business start-up space and some training facilities.

P-16.6. The second paragraph of Policy 16, therefore, needs to be expanded to ensure that the centres should “meet changing retail, leisure, social and community needs, habits and practices over the plan period.”

P-16.7. One specific area requiring careful planning and approach over the Local Plan period is the Ladymead retail zone where many of the retail units benefit from Open A1 Retail Use, meaning that they could become substantial competition for the town centre and, more particularly for surrounding district centres.

P-16.8. Supermarket uses should be resisted in most areas, following a strict application of the sequential test and requiring a robust economic impact assessment having regard to the effect such uses would have on all district and village centres within the expected catchment area. It would be helpful to identify suitable sites but in the absence of specific allocations, there must be adequate controls.

P-17. Infrastructure and Delivery

P-17.1. The Guildford Society is highly disappointed that the Infrastructure Delivery Plan (‘IDP’) was not available to us as part of the Local Plan consultation.

P-17.2. Infrastructure is such a key constraint for development in the borough and especially in the town that NO REALISTIC ASSESSMENT OF THE FEASIBILITY OF PROPOSED DEVELOPMENT SITES COULD BE MADE.

P-17.3. Despite the lack of IDP the Guildford Society has attempted to provide an objective response to the Consultation Draft Local Plan.

P-17.4. The Guildford Society, however, wishes to reserve the ability to review all of its responses when the IDP is published and will press for a further period of consultation ahead of the restrictions to soundness alone in the pre-submission consultation.

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P-17.5. The Infrastructure Baseline lists many shortcomings, congestion problems, etc., but is by no means a comprehensive nor exhaustive list.

P-17.6. Surrey County Council has reiterated its policy to encourage modal shift with additional road capacity to be built only where a strong business case exists or where there are gaps in the network.

P-17.7. The Transport Group of the Guildford Society highlight that towns of Guildford’s size typically have a ring road to keep through traffic out of the town; Guildford does not – a gap exists between West Clandon and Compton and, whilst a by-pass would be very expensive and potentially damaging to the AONB, a local tunnel running south to north-east through Guildford’s chalk might be a possibility.

P-17.8. Other measures should, therefore, be fully examined. In the absence of a ring road, the A3 effectively has to bear double the load and is already compromised due in part at least to the 100m climb between the river and the cut through the Hog’s Back as it passes the Onslow area.

P-17.9. The A3 carries substantial traffic:

P-17.10. Whilst these data from the Highways Agency show the overall volume of traffic on the A3 has not changed much, the sense is that traffic at peak times is heavier and that many drivers divert from the

Annual Average Daily Traffic flows for A3 through Guildford

Road Link Description

Direction Southbound Northbound Southbound Northbound Southbound Northbound2003 29,727 29,890 40,015 39,996 41,376 40,3762004 30,654 30,436 41,017 40,524 41,961 41,2452005 30,513 30,550 40,446 40,053 41,455 41,0702006 30,158 30,902 39,210 40,679 41,513 41,4592007 30,328 30,868 39,468 40,820 41,717 41,5182008 29,551 30,328 39,562 40,237 40,971 40,9382009 29,680 30,424 39,637 39,855 40,875 40,5272010 29,141 29,653 38,967 39,406 40,079 40,0192011 30,075 49,684 39,665 40,299 41,085 41,0312012 30,081 33,728 39,655 40,312 41,141 40,9902013 29,944 30,873 39,768 40,543 41,193 41,379

A3 between A320 and A322



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A3 through the town centre and other local roads to avoid peak hours congestion.

P-17.11. From Surrey County Council, the following data shows the traffic pattern on a single day on the A3 in 2013 between Burpham and the Stoke Road junction:

P-17.12. Assuming similar numbers of cars on the Cathedral to Farnham Road junction (two lanes), the capacity of the road at various speeds and assuming the Highway Code stopping distances are adhered to on average:

A3 (19th April 2013) Traffic Count

From To North South07:00 08:00 3,616 3,347 08:00 09:00 2,977 3,607 09:00 10:00 2,581 2,395 10:00 11:00 2,582 2,511 11:00 12:00 2,500 2,427 12:00 13:00 2,432 2,193 13:00 14:00 2,361 2,519 14:00 15:00 2,910 2,556 15:00 16:00 3,111 2,793 16:00 17:00 3,658 3,718 17:00 18:00 3,827 3,394 18:00 19:00 2,767 2,869

A320 to A3100Time

Road Speeds and Vehicle Capacity

Speedmph 1-lane 2-lanes 3-lanes70 1,109 2,218 3,32760 1,231 2,462 3,69350 1,379 2,758 4,13740 1,561 3,122 4,68330 1,714 3,428 5,14220 1,882 3,764 5,646

cars /km

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P-17.13. This would show that the A3 can only accommodate the volume of traffic at peak hours at 20mph on the two-lane stretches, a real pinch-point for through traffic past Guildford.

P-17.14. In the town centre, the problem is no less severe but the environmental impact is much greater. The through traffic occupies prime river frontage and often crosses the river not once but twice in the same journey. The legs between the traffic signals are very short (perhaps ten cars or so in most places) leading to congestion between signal changes.

P-17.15. Guildford Vision Group has modelled traffic data collected on 11th June 2011 by Sky High Traffic Surveys – data collected by Automated Number Plate Recognition as an origins and destination survey around the one-way system.

P-17.16. Based on current traffic conditions (2011), and mapped in increasing intensity of red colours, the data shows the following levels of peak hour traffic:

P-17.17. The traffic conditions were multiplied up (assuming a direct linear relationship which will almost certainly not exist in practice) to give an indication of what the same traffic origins and destination would look like in 2026 based on a pro-rated increase of 652 homes per year.

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P-17.18. The traffic, in this case, is restricted by the cumulative workings of the traffic signals rather than just the capacity of the road and, given the peak traffic is almost at gridlock and that there may be a substantial increase in traffic (by around a quarter), there needs to be substantial intervention in the town centre before any significant development can take place.

P-17.19. The Guildford Society supports the principle of trying to encourage modal shift but believes it is unlikely to make much difference to through traffic and that to anticipate that it might be a panacea would risk destroying the economy not only of the centre of Guildford but in the borough and the region.

P-17.20. Reference to SPDs and CIL in the text has no particular substance behind it and trying to interpret and understand the policy consequences is akin to crystal-ball-gazing.

P-17.21. Reference is made to deficiencies highlighted in the 2013 Infrastructure Baseline, but no solutions are provided.

P-17.22. No land is safeguarded for possible diversion of traffic from the town centre, the allocations made in Appendix B being quite inadequate for town centre relief.

P-17.23. Paragraph 4.196 should read: “The timely provision of suitable, adequate infrastructure is key to the continuing and future success of the borough. It is critical to the borough’s economic future and also to the well-being of the borough’s population, taking full account of future development.”

P-17.24. In paragraph 4.201 the phrase: “Many infrastructure providers work to statutory requirements and . . . short-term planning cycles” is avoiding the issue. Surrey County Council and/or the Highways Agency have long term options and opportunities.

P-17.25. Where at 4.202 there is the statement: “Some additional capacity MAY be created by… behavioural changes” (our emphasis), this must be more pejorative. It is essential that measures ARE put in place to encourage this. Is this, perhaps, meant to be covered by “demand management strategies” in the second paragraph of the Policy?

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P-17.26. The statements at 4.203, 4.204 and 4.205 are incompatible with statements elsewhere. For example, Policy 18 1.c provides for development of existing cycle routes, 4.211 is contrary, and the preamble to Appendix B specifically states that CIL can be used for improvements to existing infrastructure.

P-17.27. The paragraph 4.206 suggests that somehow developers will be able to provide “unacceptable development” if the cost of “mitigating measures” makes the project unviable!

P-17.28. Appendix B should include the “critical” infrastructure to support the first five years of the plan development but very little if any ‘critical infrastructure’ is specifically identified.

P-17.28.1. Appendix B sets out a description of a number of projects which the Council intends to investigate but all of these projects are still in the formulation stage or have yet to be studied or, importantly, have no committed funding. For example:-

P-17.28.2. the development of proposals for the Gyratory (item 1.1.1) is a ‘scheme to be developed’ (taking into account the outcomes of origin-destination travel surveys…in May 2014, etc). It has a cost which is ‘yet to be determined’ and has ‘no committed funding’;

P-17.28.3. the review and update of traffic control in Guildford town centre through the Local Sustainable Transport Fund (item 1.1.5) ‘will commence in 2014/15’ at a cost ‘to be determined’;

P-17.28.4. Appendix B states that a “Sustainable movement corridor will (be created to) provide an attractive, landscaped priority pathway for pedestrians, cyclists and buses…” (item 2.1.1). Reference is made to the Arup report which “…sets out the concept and identifies a potential route”.

P-17.28.5. Paragraph 4.217 states that the route of this sustainable movement corridor will be protected from development. This project, whilst listed as part of the ‘critical

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infrastructure’, is ‘presently promoted by Guildford Borough Council as distinct from the County Council as highway authority; it has a cost ‘yet to be determined’; and there is ‘no committed funding’.

P-17.28.6. Furthermore, aside from reserving a short section to the west of Walnut Tree Close (Site Allocation No. 122) (a section which, in any event, will be unnecessary if Walnut Tree Close is severed – which, as it stands, the Guildford Society does not support – no other part of the route is identified in the Plan.

P-17.28.7. Without the definition of the whole of the route as a site allocation there is no way:

P-17.28.7.1. of the public assessing its impact on property (thus giving land owners affected by the route a chance to object),

P-17.28.7.2. of assessing the impact of the proposal on the built-up fabric of the town, or

P-17.28.7.3. of the Council being able to reserve and protect the route from development when planning applications for redevelopment are received in order to ensure that, at some stage, the corridor could be constructed.

P-17.28.8. Some members of the Guildford Society have been advised that the route is likely to follow the existing road network.

P-17.28.9. To the extent existing roads are envisaged to be used to create this “attractive, landscaped priority pathway for pedestrians, cyclists and buses”, how will the town deal with the motor traffic which will be displaced?

P-17.28.10. Item 2.1.1 refers to a “Sustainable Transport Package” to provide “a package of enhanced public transport (Quality Bus Corridors), walking and cycling infrastructure to support access to major employment site in Guildford”.

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But, here again, the timing is ‘to be determined’ and there is ‘no committed funding”.

P-17.28.11. Section 6.1.4 refers to a new rail station at Merrow. This is a proposal which has been identified over many years and has already been the subject of a feasibility study. It disappointing that the wording in the Local Plan is so cautious. It states:-

“The business case for the new railway station is to be tested. This will include consideration of the costs of construction, ongoing operational costs of the site and the associated rail services.”

P-17.28.12. The Guildford Society contends that with 2,000 houses proposed for the adjacent Gosden Hill Farm; with a new secondary school proposed at West Clandon (close to the rail station and planned to meet the needs arising from major housing developments on the east side of the Borough) and with the enormous benefits which a rail station would bring to the existing residential areas of Burpham and Merrow, the Plan must be more positive in its comments.

P-17.28.13. Other relatively minor items are listed in Appendix B, - for example a “Wayfinding signage system” for the town centre and the wider area, “the redesign of pedestrian crossing facilities at the junction of Chertsey Street and North Street”, and “a setts management strategy for the High Street”.

P-17.28.14. Much of the content of the schedule in Appendix B is for completion within the plan period but before the plan is likely to be adopted and this should be noted.

P-17.28.15. The main issue for the Guildford Society is, however, that, desirable as these yet-to-be-finalised projects may be, the projects listed in Appendix B are insufficiently advanced to merit being identified as the “critical infrastructure” needed to support the scale of new development which is proposed in the Plan.

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P-17.29. Paragraph 4.202 of the Plan acknowledges that “Provision of new infrastructure raises issues of funding and delivery, and much existing infrastructure therefore has little spare capacity to cope with population growth and new housing development” and continues “Some additional capacity may however be created by bringing about behavioural changes, for example in how people travel”.

P-17.30. It seems clear that the Plan places undue optimism on the prospect of achieving additional capacity through behavioural change in the way people travel and, furthermore, that there is great uncertainty over the realisation of most of these infrastructure projects – notably the Sustainable Movement Corridor.

P-17.31. Against a background of great uncertainty and an absence of committed funding and a failure to safeguard or allocate suitable land for infrastructure where needed (as required by Policy 17), the Plan is seriously deficient on the key issue of infrastructure and fails to meet the requirements of NPPF Paragraph 177: “It is equally important to ensure that there is a reasonable prospect that planned infrastructure is deliverable in a timely fashion. To facilitate this, it is important that local planning authorities understand district-wide development costs at the time Local Plans are drawn up.”

P-17.32. This view may change upon publication of the promised Infrastructure Delivery Plan but the prospects are not looking good on the basis of the Draft Plan.

P-18. Sustainable Transport for New Developments

P-18.1. This policy is another example of an intuitively correct intention but a rhetorically poor and unemphatic text.

P-18.2. It is difficult to avoid the sense that splitting the Local Plan into the two component parts (Spatial Strategy and Delivery) had led to an excess of vagueness which we can only hope will be tightened up by development control policies.

P-18.3. Unfortunately, we have no option but to respond to the draft policies laid out before us.

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P-18.4. There is no clear indication that transport and traffic solutions are sustainable at current low levels of development, let alone at the levels envisaged by the Draft Local Plan.

P-18.5. No significant town centre development should be permitted unless and until the gyratory and other town centre traffic and transport issues have been resolved.

P-18.6. A new bus interchange and town centre network needs to be put in place – preferably with strong intermodal links between bus and train and with a more robust and longer hours provision of Park & Ride facilities on all sides of Guildford.

P-18.7. Proper highway modelling will be required before the Infrastructure Delivery Plan can be relied upon. This means that sustainable transport will be difficult to plan for in the short term.

P-18.8. The Guildford Town and Approaches Movement Study (‘GTAMS’) provides an insight into a potential solution but it is in no way ready to be considered as part of this Draft Local Plan in that it has no route (and no land designations) except a small part as it crosses Yorkies Bridge between the University and Walnut Tree Close (Site 122), despite Policy 18: 1g which requires the route to be safeguarded.

P-18.9. This is an expensive proposal without having taken into account the various developments in the Draft Local Plan. This needs a more thorough review to understand its likely patronage and methods to link the corridor to other areas.

P-18.10. Overall, there are good concepts, a shortage of worked up ideas and a complete dearth of data and spatial planning.

P-18.11. In greater detail, however:

P-18.11.1. Policy 18.1.d Covers ‘public and community transport’. It could be clearer if it spelt out what it concerns: for example ‘buses, taxis, trains’, etc.

P-18.11.2. For 18.1.g (in addition to our comments above), it should be noted that an engineering feasibility study is required to support any action taken. This also applies to paragraph 4.217)

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P-18.11.3. Policy 18.2 needs to take full account of the impact on Guildford of developments outside the borough such as Dunsfold or Cranleigh housing.

P-18.11.4. We note the content of Policy 18.3 and paragraph 4.221, but we are concerned that the requirement for small-scale developments to have to submit transport statements will add to the cost of and delays in the planning process. This is contrary to the Government's stated objective to improve and simplify the planning system.

P-18.11.5. We do not understand the reference in 4.217 (which we broadly support) to “subsequent studies”. What does this include?

P-18.11.6. The Guildford Society, through its Transport Committee commends paragraphs 4 .221 and 4.222 to the extent that Travel Plans will be required for all new developments, but asks whether parking could also be included in this analysis.

P-18.11.7. Monitoring indicators should include empirical results in respect of measureable improvements in air quality, accident rates, reduction in congestion and increase in modal shift from private car to public transport.

P-19. Green and Blue Infrastructure

P-19.1. There is so much essential green and blue infrastructure across the borough.

P-19.2. From the Department for Communities and Local Government Land Use Statistics (2005) the Borough comprises:

P-19.2.1. 270,931,390 square metres of land area of which:

P-19.2.1.1. Green Belt 240,400,000 sqm (88.73%)

P-19.2.1.2. Green Spaces 222,336,180 sqm (82.08%)

P-19.2.1.3. Water 2,669,280 sqm (0.99%)

P-19.2.2. Only 1.58% of the borough is covered by domestic buildings (or 11.21% including domestic gardens).

P-19.2.3. More than 3 times the area of water is covered by roads.

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P-19.3. Managing the Green Infrastructure is not the same as managing the entire Green Belt or the full amount of Green Spaces. The impact of the Thames Basin Special Protection Area which requires us to deliver Sustainable Alternative Natural Green spaces (SANGs) is such that the network of SANGs is a critical part of the Green Infrastructure.

P-19.4. The policy correctly identifies the landscape character as a key component of Green Infrastructure.

P-19.5. The Guildford Society recommends safeguarding land along both sides of the River Wey with the long term aim of providing pedestrian (and cycle) paths alongside the river and opening up a combination of rural parkland outside the centre and riverside active spaces in the town centre – perhaps with a similar feel to the South Bank in London between the Milennium Bridge and London Bridge.

P-19.6. [to be completed]

P-20. Site-by-Site Comments (See Separate Section forming an integral part of this Submission)

Infrastructure Schedule – Appendix B AppB-1. The comments in this section are drawn from the Transport Group of the

Guildford Society AppB-1.1. The Town centre Major Scheme at 1.1.1 cites three

influences, of which only the new Origins and Destination survey will help inform schemes for the relief of traffic congestion.

AppB-1.2. The Transport Group was also unsure why there was only one improvement in pedestrian access between the station and the town centre when so much more needs to be done (noting, for example, the Allies & Morrison and Guildford Vision Group aspirations.

AppB-1.3. The items at 1.1.3 to 1.1.5 are ongoing and should be included in the Infrastructure Baseline rather than Appendix B.

AppB-1.4. The Guildford Society is not aware of the circumstances that make the ‘improvements’ at Chertsey Street and North Street a priority. There are more urgent requirements for

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pedestrian crossing improvements such as High Street/Millbrook and Bridge Street/Onslow Street.

AppB-1.5. In respect of The Sustainable Movement Corridor: AppB-1.5.1. Site 122 is insufficient to deliver Section 1 of the

Sustainable Movement Corridor. AppB-1.5.2. The report by Arup suggests the concept but does

not identify a specific route (see also our response to Policy 18.1g above.

AppB-1.5.3. SECTION 1: If Site 122 is found to be appropriate, the remaining highway (Walnut Tree Close) should be capable of use for the residents rather than through traffic although The Guildford Society is unconvinced of the rationale for making the road into two cul-de-sacs and is not aware of any qualitative or quantitative data to support such a plan.

AppB-1.5.4. SECTION 2: This route needs to be identified – probably as part of the Blackwell Farm allocation if that allocation is deemed appropriate (Site 60) and as part of the allocations The Guildford Society has suggested for the University’s Manor Farm and Stag Hill campuses (see our Site-by-Site analysis).

AppB-1.5.5. SECTION 3: This involves Bridge Street and Onslow Street and cannot be delivered without diverting a large portion of the traffic currently using them.

AppB-1.5.6. The Guildford Society, in endorsing the Guildford Vision Group’s concept of pedestrian priority for much of the town centre, recognises that a kind of informal Sustainable Movement Corridor could exist across the town centre and the corridor could in due course be configured in a star shape to provide wider access from across the borough. This would make a much more meaningful long term modal shift but would probably require longer than a single plan period to deliver.

AppB-1.5.7. SECTION 4: Reference has been made to using Woodbridge Road which seems to be wishful

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thinking and no study has been reported that would identify the impact on traffic. The design of the North Street development (Site 20) has not been finalised and so there is no clarity as to how this link will take place. How will Ladymead accommodate the Sustainable Movement Corridor?

AppB-1.5.8. SECTION 5: This route needs to be identified – probably as part of the Blackwell Farm allocation if that allocation is deemed appropriate (Site 60) and as part of the allocations The Guildford Society has suggested for the University’s Manor Farm and Stag Hill campuses (see our Site-by-Site analysis).

AppB-1.5.9. SECTION 6: This section of the route seems to ignore topography on either side of the A3, the massive visual impact a so-called ‘land bridge’ would have, the river and integration into the Slyfield Area Regeneration Project (Site 48). The environmental impact of this section of the route needs careful consideration before the route itself is reserved.

AppB-1.6. Overall, it seems, the objective of improving routes and reducing journey times on public transport can only be achieved by the substantial reduction of current traffic volumes. This may prove to be a circular argument too far.

AppB-1.7. At item 2.1.2 (Sustainable Transport Package (bus and cycling)), the town centre corridors should be defined (or the comments made at AppB-1.5.6 should also apply here).

AppB-1.8. A fully rational bus routing system for the town centre must be planned, together with proper interchange facilities. This process needs to involve all stakeholders and must not be left to the whims of developers.

AppB-1.9. The items 2.1.3 and 2.1.4 (Cycle Routes and Bus Stops respectively) are ongoing and should be included in the Infrastructure Baseline rather than Appendix B.

AppB-1.10. Provision should be made for items 2.1.6 and 2.1.7 (Junction Improvements at A320 Woking Road junction with Jacobs Well Road and Jacobs Well junction with Clay

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Lane respectively) within the longer term project (8.1.2 Clay Lane Phase 2). In any event, money has already been raised and deployed to deal partly with 2.1.7.

AppB-1.11. Traffic reduction is required in connection with Item 2.1.8 (A25 Epsom Road, Merrow – Pedestrian Safety Improvements) to improve the areas around a cluster of local schools.

AppB-1.12. The Guildford Society does not understand why SECTION 4.1 omits all of the main routes into the town centre – particularly the A281 at Shalford, the A320 Woking Road, the A322 Worplesdon Road and the A3 between Burpham and the cathedral junction.

AppB-1.13. No assessment has been made in the Options Growth Scenarios Transport Assessment Report (‘OGSTAR’) of the impact of Scenario 2 on the Local Roads Network in the centre of Guildford. Existing constraints (although not an exhaustive list) are listed under 2.2 of the Infrastructure Baseline Report.

AppB-1.14. A further OGSTAR scenario should have considered the potential impact of a major development at Dunsfold.

AppB-1.15. There needs to be clarity as to whether the OGSTAR report considers the current and proposed developments in Rushmoor District and those being consulted on in Waverley Borough, and what the impact might be of more cross-town traffic and on the major arterial routes.

AppB-1.16. At 4.1.1, A3 junctions are listed separately but there needs to be an integrated assessment of the A3 and long-term solutions need to be identified.

AppB-1.17. The Guildford Society welcomes the intention at 4.1.2 to implement the long-awaited Park & Ride for northern Guildford. This representation suggests a Park & Ride as part of the Liddington Farm development (Site 62) and also at Slyfield (Site 63 and also the Clay Lane site) where there should be a link to an all-direction junction at Burpham.

AppB-1.18. The new zebra crossing at Shalford (4.1.5) has already been installed and so this should be removed from Appendix B.

AppB-1.19. BLACKWELL FARM (Site 60)

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AppB-1.19.1. IF, AND ONLY IF the allocation is deemed acceptable (see The Guildford Society response to Site 60 in the Site by Site Analysis), the Guildford Society Transport Group makes the following observations, which are brief since the scheme presented is only a preliminary sketch:

AppB-1.19.2. A future northern outer by-pass of the A3 would be precluded if the proposed site is fully developed, which would put all the onus for coping permanently with through traffic on the existing A3 with improvements that would possibly be inadequate in the long-term.

AppB-1.19.3. Access and egress by traffic: The assertion is made that a new road access to the A31 to west of Guildford would improve access to this part of the town and reduce traffic on the A3. This suggestion implies a major traffic route through the proposed large residential development which is likely to be unacceptable to the Guildford Society.

AppB-1.19.4. The A31 junction and access road indicated (5.1.2) may be essential to the development due to the inability of the present approach from the east (Gill Avenue) to take extra traffic. The combination of access to the new community and access to the University and Research Park facilities would be unacceptable without major alteration. As noted in response to Site 60, however, The Guildford Society would not support a major junction on the A31 involving grade separation, 24-hour lighting and a major adverse impact on the Area of Outstanding Natural Beauty.

AppB-1.19.5. If the combination of the unacceptable burden of traffic on the local roads and the unacceptable intervention of a junction in the AONB render this development unachievable or require it to be considerably scaled down then so be it.

AppB-1.19.6. Public transport:

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AppB-1.19.6.1. The new Rail Halt proposed seems to be in the wrong place, although its siting may be clear of gradients which might inhibit a station location at Park Barn/Egerton Road.

AppB-1.19.6.2. The Guildford Society considers that the optimum location would be near the Royal Surrey County Hospital or the Egerton Road Bridge. However, see AppB-1.19.6.4 below.

AppB-1.19.6.3. After a gap of well over 10 years since the last comparable study, there is a need for investigation of a Guildford alternative to conventional buses.

AppB-1.19.6.4. One notable possibility would be a Personal Rapid Transit (PRT) comprising driverless "cars" running on elevated tracks between multiple points, reducing conventional car usage and replacing a multiplicity of buses. Such a network could connect Guildford railway station, the University, the Cathedral, the Royal Surrey County Hospital, the Onslow park-and-ride, the Sports Park, Research Park and Manor Park residences and beyond.

AppB-1.19.6.5. It could be a thoroughly innovative and economic solution for shoppers, workers, students and hospital visitors. It could serve as a major link between East and West Guildford. A current precedent exists at Heathrow T5 in the form of the British system Ultra Global PRT.

AppB-1.19.7. The Guildford Society assumes the measures at 5.1.3 include closure of the access from Beechcroft Drive to the A3.

AppB-1.19.8. The reference to a 1,000 car park & ride at Blackwell Farm (5.1.4) is confusing given the new park & ride at Onslow nearby. Also, this is described as a park & ride for the A31 but this assumes the proposed A31 grade-separated junction is built. Please note our objection to that

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at AppB-1.19.4 above. Would this replace the existing Onslow park & ride?

AppB-1.19.9. Indeed, park & ride facilities are often sited close to new developments (see also 6.1.3). This risks losing sight of the rationale for park & ride which is to intercept traffic at the edge of town and to provide longer stay low cost parking, mainly for commuters. The reason for this tendency seems to be the availability of land.

AppB-1.19.10. There may be cases for parking with a shuttle service to specific high employment areas, but modified park & ride services at peak times could also do this.

AppB-1.19.11. Park & ride sites should, however, be selected for their location close to major approach roads.

AppB-1.19.12. The proposed new station (5.1.5) should not be seen as part of a Blackwell Farm development – the LSOA data for Park Barn demonstrates a clear need for access to employment, education and services even before Blackwell Farm is developed. See AppB-1.19.6.1 and AppB-1.19.6.2 for our comments about the proposed location of the station.

AppB-1.20. Slyfield regeneration (Site 48) AppB-1.20.1. The proposals at 8.1.1 and 8.1.2 are fundamentally

flawed. This road should take traffic between a new all-direction junction with the A3 and the A320 Woking road, relieving the congestion on the A3100 (London Road), A25 (Ladymead) and reducing traffic through the village at Jacob’s Well in addition to providing access to the Slyfield site. See also 2.1.6.

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Responses to Town Centre Vision Consultation

The Guildford Society welcomes the Town Centre Vision prepared by Allies & Morrison. We also strongly support the enhanced vision promoted by the Guildford Vision Group including the potential release of multiple major regeneration sites in the town centre, the displacement of traffic from the centre by construction of a new route from York Road to Farnham Road, and the wide-ranging introduction of pedestrian-priority areas.

The Guildford Society responds to the Guildford Town Centre Vision Questionnaire as follows:

Vision-1. What are your thoughts on the principle and approach for limiting the environmental impact of Guildford’s road network? Vision-1.1. …

Vision-2. What are your thoughts on the principle and approach for revealing the River Wey? Vision-2.1. …

Vision-3. What are your thoughts on the principle and approach for creating more people friendly streets and new public spaces? Vision-3.1. …

Vision-4. What are your thoughts on the principle and approach for creating a compact and well connected town with development that reflects Guildford’s historic street pattern? Vision-4.1. …

Vision-5. What are your thoughts on the principle and approach for providing new homes on underused sites in Guildford? Vision-5.1. …

Vision-6. What are your thoughts on the Vision’s approach to the Town Centre? Vision-6.1. …

Vision-7. Is there anything else you'd like to tell us? Vision-7.1. …

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List of Appendices

Appendix 1 – SHLAA Analysis Appendix 2 – The Guildford Society Position Papers

Appendix 3 – Summary of the background and constitution of The Guildford Society

List of Annexes

Annex 1 – Site-Specific responses to a selection of the site-specific policies Annex 2 – Copy of the Guildford Vision Group response to the Sustainability Appraisal

Consultation (22nd January 2013)

Annex 3 – Copy of The Guildford Society response to the Issues and Options Consultation (29th November 2013)

Annex 4 – Copy of The Guildford Society response to the Draft SHMA Consultation (20th February 2014)

Annex 5 – Copy of The Guildford Society paper on Population that accompanied the Draft-SHMA consultation response at Annex 4 (20th February 2014)

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Appendix 1 – SHLAA Analysis This Appendix reproduces a paper written by John Baylis for the Guildford Society Planning Group:

Executive Summary • The presentation of information on housing sites in the Draft Local Plan is confusing and difficult

to follow. It also seems to be at odds with the SHLAAs and needs to be resolved to ensure both that the Plan is capable of meeting its targets and also that the sites have been consistently assessed and properly included or excluded from the final version of the Local Plan.

• The Local Plan period is from 2011 to 2031, whereas some of the tables run from 2015. There should either be a consistent start date of 2015 or the completions of homes in each of the categories for the period from 2011 to date should be included together with a reasonable prediction of homes to be constructed in 2014-2015.

• The use of different groupings and nomenclature is unfortunate and needs to be addressed. • The totals of sites should be consistent for each grouping and should include a collective total for

the ‘small sites’ (including a clear definition of what constitutes a ‘small site’) to ensure the totals carry across accurately between documents.

• Numerical inconsistencies need to be cleared up (particularly at Ash and Tongham). • Assumptions made in the treatment of outstanding planning permissions should be explicit and

included within the Local Plan. • The last category in the June 2014 SHLAA (‘Land under Consideration’) should be explained and,

if not included in the Local Plan, the reasoning should be clarified. • To the extent the supply totals in the Local Plan (14,660) exceed the Local Plan housing target

(13,040) [even before allowing for completions between 2011 and 2015 (am I correct here, John?)] the rationale for oversupplying in the Local Plan need to be spelt out.

• We expect the SHMA figure to be reduced to reflect the adjustment by about a third in the ONS Population Projection (as published on 29th May 2014 when compared to the projections upon which the Draft SHMA was based).

• The various lists being treated as a list of sites which, if developed would meet objectively assessed need, it will be essential to establish the basis on which sites will be scored and will either remain in the list or be withdrawn from the Submission Draft of the Local Plan in due course.

• The Local Plan does not deal adequately with the (in places extreme) deficit in infrastructure, the absence or failings of which constrain development. This will need to be properly assessed for each of the development sites to be put forward in the final list.

1. Purpose of this Note This Note examines the way information on housing sites is presented in the GBC draft Local Plan July 2014. It checks for consistency and suggests ways of improving clarity and transparency. The findings are summarised in section 8.

2. Locations The GBC draft Local Plan July 2014 identifies sites for new homes over the Plan period. The sites are grouped into ‘Locations’ in paras 4.4 and 4.6 of the draft Plan (see page 25 of the draft Plan):

a. Guildford town centre

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Response to Guildford Consultation Draft Local Plan (September 2014) b. urban areas c. inset villages d. identified Green Belt villages e. countryside beyond the Green Belt f. urban extensions to Guildford and Ash and Tongham g. new settlement at the former Wisley airfield h. development around villages (including some expansion)

The labelling a. to h. is my own notation, introduced for ease of reference: it is not taken from the draft Plan.

3. Delivery between 2015 and 2031 In Policy 2 the Plan period is stated as being 2011 to 2031, during which 13,040 new homes will be provided (652 per year). However Table 1 of the draft Plan (‘Table 1’) sets out (inter alia) the net increase of new homes for the period 2015 to 2031.

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Unhelpfully, when compared to the ‘Locations’ above, the sites are grouped into Settlements. There is no site specific information at this stage. I have attempted at Figure 1 above to identify which locations fall into which settlement categories or vice versa.

I have then set out in Table A below the Settlements and the Homes (net increase) for each settlement as given in Table 1 using the cross-referencing in Figure 1.

The TOTAL in Table A is not given in Table 1, but as noted in para 4.12 of the Draft Local Plan it is greater than the number in Policy 2, though the time period 2015 to 2031 is shorter than 2011 to 2031.

There are some inconsistencies:

FIGURE 1: Comparison of Locations and Settlements

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A. Guildford town centreB. Guildford urban area (excluding town centre, including SlyfieldC. Ash and Tongham urban areasD. Inset villages and infill development within Green Belt VillagesE. Rural exception housingF. Previously developed land in the Green BeltG. Former Wisley airfield (Allocation 66)H. Urban extensions to GuildfordI. Around villages

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Response to Guildford Consultation Draft Local Plan (September 2014) • there appears to be no Settlement for Location (e) and no Location for Settlement F. • Para 4.12 refers one to Appendix G for site allocations. Appendix G is Maps. The reference

should be to Site Allocation Policies 20 to 125.

TABLE A: Settlements Settlement Location Homes

(net increase) A. Guildford town centre a 1,932 B. Guildford urban area (excluding town centre, Including Slyfield)

b (part) 2,285

C. Ash and Tongham urban areas b (part) 1,215 D. Inset villages and infill development within Green Belt villages

c & d 368

E. Rural exception housing Not specific 150 F. Previously developed land in the Green Belt ? 241 G. Former Wisley airfield (Allocation 66) g Up to 2,100 H. Urban extensions to Guildford f (part) 5,015 I. Around villages h 1,354 TOTAL Up to 14,660

The labelling A. to I. is my own notation, introduced for ease of reference: it is not taken from the draft Plan.

4. Planning for sites After page 84 of the draft Plan the pages are not numbered. The next page is headed ‘Planning for sites’. It states that the key studies for housing in the Plan’s evidence base include the GBCS and the SHLAAs. A six page schedule follows. The schedule lists the sites and numbers them 20 to 123. It gives the name of each site, the ‘Total number of homes’ for each site and the allocated uses for each site. This Note is concerned only with sites allocated in whole or part to housing. The sites are grouped under ‘Headings’ (my nomenclature) as set out in my Table B below

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TABLE B: Planning for Sites Heading Settlement Location Total number

of homes from schedule in draft Plan

Homes (net increase), From Table 1 in draft Plan

① Guildford town centre

A a. 1,939 1,932

② Guildford urban area

B b. (part) 1,500 2,285

③ Ash & Tongham urban area

C b. (part) 1,564 1,215

④ Within villages

D? c. and d. 70 368

⑤ Land around Guildford urban area

H f. (part) 5,015 5,015

⑥ New settlement

G g. Up to 2,100 Up to 2,100

⑦ Land around villages

I h. 1,588 1,354

⑧ Previously developed sites in the countryside

F ? 225 241

(rural exception housing – not in schedule)

E not specific 150 150

TOTAL Up to 14,151 Up to 14,660

The labelling ① to ⑧ is my own notation, introduced for ease of reference: it is not taken from the draft Plan.

② includes Slyfield at 1,000 homes. ⑤ comprises Gosden Hill Farm (2,000), Blackwell Farm (2,250), Land north of Keens Lane (140) and Land at Liddington Hall (625).

As the Location (e) is missing from the Settlements list (see Table A)

The correspondence between ‘Headings’ and ‘Settlements’ is better than that between ‘Locations’ and ‘Settlements’, although the ordering is different. A single system of naming instead of the present three systems would make the Plan much more intelligible and transparent.

There is no Heading for E because rural exception housing is not site specific.

The ’Planning for sites’ text gives the end date as 2031 but not the start date (2011 or 2015?)

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Response to Guildford Consultation Draft Local Plan (September 2014) The schedule does not give totals for each Heading. The numbers in the table above were obtained by adding the ‘Total number of homes’ for each site under each heading. My arithmetic stands to be corrected.

The ‘Homes (net increase)’ figures are taken from the previous table and are therefore 2015 to 2031.

The schedule is followed by two-page entries for each of the sites. Each entry gives the area of the site and much other information, but not the ‘Total number of homes’ for the site. For that, one needs to go back to the schedule. Each entry does give the SHLAA reference number, and hence, via the schedule, the ‘Total number of homes’ for each site can be checked against the SHLAA.

The two Totals at the bottom of Table B are not very different (4%), but there are some significant differences in individual Totals, and these should be explained or corrected as the case may be.

5. The SHLAAs The next stage is to compare these figures with the SHLAAs. There are two relevant ones which have to be read in conjunction. Quoting from the GBC website:

“we published a partial update to the SHLAA in May 2014”

and

“we have prepared this full update of the SHLAA (June 2014). This SHLAA is a full update to the July 2013 document in terms of the total numbers, and incorporates the findings of the partial update (May 2014). However, this SHLAA does not replicate all the detailed site information sheets and should therefore be read alongside the partial update (May 2014). The additional information that is included in this full SHLAA update is previously developed land in the Green Belt, land in the Countryside beyond the Green Belt, rural exception sites, land currently in the Green Belt and land under consideration for inclusion in the village settlement boundary (inset from the Green Belt).”

It should be noted that the list in the above quoted paragraph does not correspond precisely with any of the previous three descriptors (Locations, Settlements and Headings). I will call them ‘Categories’.

A significant difference between the SHLAAs and the site entries in the draft Plan are that the SHLAAs contain all the identified sites, including the smaller ones. Comparisons show that sites with fewer than about 18 homes do not have two-page site entries in the draft Plan and therefore are not included in the schedule of sites. The draft Plan does not say what the exact cut off number is, and it appears to be slightly different for different Categories. It is very reasonable that the draft Plan should not contain the many smaller sites in the SHLAAs, but the draft Plan should state clearly the criteria for omission.

During a visit to 25 Swan Lane I was told that only ‘strategic’ sites are included in the draft Plan. However sites providing only 20 homes can hardly be strategic. The Key Diagram on page 18 of the draft Plan shows just four ‘Strategic Development Sites’: Blackwell Farm, Gosden Hill Farm, SARP and Wisley airfield.

Because the two SHLAAs are so recent one would expect the draft Plan to be in close accord with them. This will now be examined.

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6. May 2014 SHLAA This SHLAA has an ‘Index of sites’ for Categories:

• Guildford town centre (Settlement A) • Guildford urban area (Settlement B) • Western urban area (Ash and Tongham urban areas) (Settlement C) • Identified village settlements (Settlement D with a different name)

The SHLAA index can be compared with the Plan schedule, but the index entries, unlike the schedule, do not include the ‘Total number of homes’ for each site. One has to go back to the two-page entries for each site in the SHLAA, which do give the ‘Total net gain’ unlike the two-page entries in the Plan.

The totals under each heading, given below, exclude sites with planning permission which have homes outstanding for delivery within the Plan period. Summaries for each Category are given in the text of the SHLAA in tabular form, tables 2 to 5.

Guildford town centre: SHLAA index corresponds well with the schedule in the Plan. One site, 1 &2 Station View, 177 homes in Plan schedule, is not in SHLAA index because it has permission. Four sites in the schedule are classified as in the ‘Urban area’ in the SHLAA index. Sixteen small sites totalling 94 homes are not in the Plan schedule. The smallest site in the schedule has 18 homes, the largest not in the schedule has 12 homes. The total of all indexed sites is 1682: add 250 with permission makes a grand total 1,932 as given in Table 2 of the SHLAA and in accordance with Table 1 of the Plan.

Guildford urban area: SHLAA index entries correspond well. But ’land at Guildford cathedral’ is given as 168 homes in the Plan schedule, but only as 50 homes in the SHLAA index. One site, 2225, 28 homes in the SHLAA index is not in Plan. Forty four small sites totalling 183 homes are not in the Plan schedule. The smallest site in the schedule has 20 homes, the largest not in has 18 homes. The total of all the indexed sites is 1,872, add 403 with permission in Table 3 of the SHLAA and 10 special (see SHLAA) makes a grand total 2,285 in accordance with Table 1 of the Plan.

Ash and Tongham urban area: there are three sites in the Plan schedule, two of them totalling 64 homes as in the SHLAA index. The third site in the Plan schedule is 1,500 homes ‘Land in Ash and Tongham’, but it is not in the SHLAA index. Fourteen small sites totalling 95 homes are not in the Plan schedule. The total of all indexed sites is 159, compared with 150 in Table 4 of the SHLAA, add 34 with permission makes 184 which is at variance with the 1,215 in Table 1 of the Plan. The discrepancy is 1,031 homes. On the other hand the Plan schedule totals 1,564.

Identified village settlements: there are two sites in the Plan schedule totalling 70 homes in accordance with the SLHAA index. Thirty nine small sites totalling 204 homes are not in Plan schedule. The total of all indexed sites is 274 compared with 225 in Table 5 of the SLHAA, add 143 with permission makes 368 in accordance with Table 1 of the Plan.

Thus the SHLAA agrees with the draft Plan Table 1 except for Ash and Tongham and hence it seems the Table1 figures include the ‘small sites’ omitted from the Plan schedule. The discrepancies between A, B

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Response to Guildford Consultation Draft Local Plan (September 2014) and D and ①, ② and ④ are explained, provided there are no other large sites with permission and which therefore should have been included in the schedule.

If Table 1 is taken to be definitive, however, then there are a few discrepancies because the Table does not include the variations between the SHLAA index and the Plan schedule noted above. There appear to discrepancies within the SLHAA between the totals of indexed sites for the latter two Categories and the numbers given in the SHLAA Tables 4 and 5, as noted above.

7. June 2014 SHLAA The SHLAA has tables (3 to 6) for the four categories of the May 2014 SHLAA. There are some small changes in the numbers with permission resulting in slightly different totals:

• Guildford town centre: 1,929 instead of 1,932 • Guildford urban area: 2,294 instead of 2,285 • Ash and Tongham urban area: 183 instead of 184 • Identified village settlements: 383 instead of 368

It is not clear why the June numbers were not used in Table 1 of the Plan

The SHLAA then proceeds to consider the other Categories:

• Rural exception sites (Settlement E) • Previously developed land in the Green Belt (Settlement F) • Countryside beyond the Green Belt (no Settlement) • Land currently in the Green Belt (Settlements G, H and I) • Land under consideration for inclusion in the village settlement boundary (inset from the

Green Belt) (no Settlement)

Taking these in turn:

Rural exception sites: Ten new homes per year area are assumed giving the 150 total as in Table 1 of the Plan. This includes 24 homes which already have permission.

Previously developed land in the Green Belt: There are two sites in the Plan schedule totalling 225 homes in accordance with the SLHAA index. Eleven small sites totalling 111 homes are not in the Plan schedule, giving a total of 336 as in Table 8 of the SHLAA. This is at variance with the figure of 241 in Table 1 of the Plan. The two largest of the small sites not in the Plan schedule are for 25 and 22, indicating a higher cut off figure than used elsewhere. As regards homes with permission the SHLAA says ‘homes with planning permission on previously developed land in the Green Belt are counted in the section: land currently in the Green Belt.’

Countryside beyond the Green Belt: There is no corresponding Settlement and hence no direct comparison can be made between the SHLAA index and the Plan schedule. The index lists four sites: three of them, all in Ash Green, total 149 homes. The fourth is described as ‘Land to the east of Ash and Tongham’ with 844 homes making a total 993 compared with 992 in Table 9 of the SHLAA. The large site is described as a combination of many previous individual sites. In addition to the 844 it includes 557 homes

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Response to Guildford Consultation Draft Local Plan (September 2014) with permission. The total with permission given in Table 9 is 570, making the total for the Category 1,562 in Table 9. This is considerably greater than the discrepancy of 1,031 noted above for Ash and Tongham urban areas. (It is very close to the 1564 total of the Plan schedule but this is probably a coincidence.)

Land currently in the Green Belt: The numbers for homes for Wisley airfield and for the urban extensions to Guildford in the SHLAA index agree with those in the Plan schedule and in Table 1 of the Plan (settlements G & H). The total is 7,115 homes. The other entries in the index for this category total 1,455 which added to 7,115 gives 8570 as in Table 10 of the SHLAA. The Table gives 91 homes with permission making the overall total 8661 as given in the Table. There are no small sites in this Category. The entries for ‘Land around villages’ in the Plan schedule total 1,588 because the schedule includes two sites totalling 133 not in the index, both sites in Ash Green. These two appear in the index under ‘Countryside beyond the Green Belt’, so explaining part of the difference between the 1,562 and the 1,031 noted above. Table 1 of the Plan gives 1,354 for ‘Around villages’ (settlement I). This is inconsistent with the 1,455 in the index and 1588 in the Plan schedule.

Land under consideration for inclusion in the village settlement boundary (inset from the Green Belt): This category contains twelve sites, three larger ones of 35, 22 and 20 homes, and nine smaller ones totalling altogether 131 homes as in Table 11 of the SHLAA. None of these appear to be included anywhere in the Plan schedule or in Table 1 of the Plan.

Total: Table 12 of the SHLAA gives a total including permissions of 15,629 compared with the 14,660 of Table 1. The difference is quite substantial in terms of the over provision compared with the 13,040 Plan commitment. Comparing the two as in Table C below, about half of the difference of 969 arises from the assignments to Ash and Tongham. The remainder arises from the inconsistencies detailed above.

TABLE C: Comparison of SHLAAs with draft Plan

Category in June 2014 SHLAA Total homes, from SHLAAs

Equivalent Settlement in Draft Plan

Total homes from draft Plan

Difference

Guildford town centre 1,929 A 1,932 -3 Guildford urban area 2,294 B 2,285 +9 Ash and Tongham urban area 183 C 1,215 -1,032 Identified village settlements 383 D 368 +15 Rural exception sites 150 E 150 0 Previously developed land in the Green Belt

336 F 241 +95

Countryside beyond the Green Belt 1,562 None (C?) 0 +1,562 Land currently in the Green Belt 8,661 G, H, I 8,469 +192 Land under consideration for inclusion in the village settlement boundary (inset from the Green Belt

131 None 0 +131

TOTAL 15,629 14,660 969

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8. Summary The presentation of information on housing sites in the draft Plan is confusing and not transparent, especially when one tries to compare it with the evidence base (the SHLAAs). Anyone might become frustrated when trying to decipher it. This may well be because of the time pressures in producing the draft Plan, and Officers are probably conscious of the defects and intend to remedy them. Specifically:

1. There should be a single nomenclature for groups of sites, not three as at present, with a fourth in the SLHAAs. This would make the Plan much more intelligible and transparent

2. The Plan schedule should have an entry for ‘small sites’ for each group of sites (‘Guildford Town Centre’ etc): the entry should give the number of such sites in the group and the total number of homes from the small sites. For each group there should then be a ‘total homes’ entry for the whole group which should be identical to the corresponding number in Table 1 of the Plan. This would aid clarity and transparency enormously.

3. The cut-off criterion which controls whether a site is ‘small’ and is therefore omitted from the Plan site allocation policies should be stated explicitly and applied consistently.

4. The inconsistencies between the schedule in the Plan and the Table I entries as described in this Note would then be removed.

5. The several numerical discrepancies identified in section 7 above should also be addressed and wherever possible removed. Prime amongst these is the treatment of Tongham and Ash, where numbers appear to disagree by up to about 500 homes.

6. There should be more clarity on start date, 2011 or 2015, and the implications of using a different date (2015) for the housing numbers to that of the Plan commitment (2011) should be spelt out.

7. The treatment of ‘permissions’ in calculating homes should be explained in the Plan. 8. The treatment of ‘Land under consideration ….’, the last category in the June 2014 SHLAA (see

table above), should be clarified. Why is it not included in the Plan? 9. The extent to which the housing total should exceed the commitment of 13,040 should be stated

and justified in the Plan. The present total appears to be arbitrary in that it is, in principle, simply the total of SLHAA sites. There is no logical or other link between the SHLAA total and the Plan commitment, except that the SHLAA total needs to be greater than the Plan commitment. Thus there is no reason why the Plan total should be 14,660 and thus exceed the commitment by as much as 1,620. The Plan total should be lower and the Plan should exercise some judgement in stating which SHLAA sites are excess to requirements and are therefore not included, or are re-assigned as ‘Safeguarded land’. Indeed, because there is also Safeguarded land, there is no obvious reason why the Plan total should differ from the commitment of 13,040.

John Baylis

Secretary or the Guildford Society Planning Group

23.08.2014

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Appendix 2 – The Guildford Society Design & Heritage Position Papers

1. Overview 2. Good design - eight points to help ensure good design and

future heritage creation 3. Preserving and enhancing the approaches to Central

Guildford 4. Preserving and enhancing Guildford’s historic High Street 5. Preserving and enhancing Guildford’s residential heritage 6. Enhancing Guildford’s riverside 7. Preserving Guildford’s vistas, roofscapes and skyline


Background to position papers prepared by the Guildford Society Overview

The Guildford Society’s purpose includes:

• Conserving the best of Guildford and its environs; • Promoting high standards of planning and architecture to create a long term sustainable

community; and • Influencing the pace and type of development.

Its activities are focused on the town centre and significant issues in urban Guildford with parish councils safeguarding other areas of Guildford Borough.

The Society is broadly in favour of the development of The Town to ensure it continues to provide a great place to live, work and do business. However development pressures from a range of sources are significant:

• Commercial developers of all types of building; • Home owners seeking to extract value from their property by development; • The Council’s desire to re-develop parts of the town centre; • New businesses seeking to move to the Town; • The continuing success of the University; • Immigration to the South of England; and • New business opportunities.

If not properly controlled, such development will irreversibly damage the urban, natural and rural environment valued by citizens. Consequently this desire to develop needs to be balanced with the need to create a long term sustainable community, and preservation of Guildford’s heritage and culture, critical factors in The Town’s success over many years. Consequently the Society believes that it is vital that The Town’s heritage is conserved for the benefit of current and future generations and that this must be a vital consideration when evaluating regeneration and new development opportunities in the town centre and urban Guildford.

Our response

In response to these challenges, the Society has prepared a series of papers setting out its position on matters related to The Town’s heritage. These papers are deliberately aspirational and are intended to provide a basis for communicating consistently with stakeholders on the Local Plan, town planning and individual developments; they will be reviewed and revised periodically as required.

The desired overarching design principles are set out in the paper entitled “Good Design“; other papers provide information on the Society’s views on key heritage aspects of The Town.

The Society welcomes early discussion with home owners, developers, businesses and the Council when significant development is planned and this is intended to be facilitated by these papers.

While acknowledging the considerable work already performed by competent authorities in defining polices applicable to Guildford including GBC, SCC and NT, much of which the Society concurs with, there will always be certain matters which the Society either disagrees with or considers to be under ambitious. The Society’s position papers are not intended to be restatements of policies produced by others but are instead intended to represent the Society’s own independent views. The Society recognises that, on occasion, these positions may differ from those of other parties due to differing objectives but encourages those parties to actively engage with Society members on areas of difference.

To complement these position papers, the Society also intends in due course to develop a map of The Town highlighting districts, streets, groups of properties and selected buildings which it considers to be

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Response to Guildford Consultation Draft Local Plan (September 2014) of architectural, heritage or community value. It also intends to create a register of principal views of skyline and sightlines.

While in setting out its views proactively, the Society is keen to ensure its message is received by GBC in advance of bringing forward detailed local planning policy and by developers and residents prior to embarking on the development process.

The Society is also active in reviewing planning applications and on occasion engages in pre-application discussions with developers and councillors on major applications. Members of the Society’s Planning Group review all planning applications in Guildford town centre, and other applications in the Guildford urban area which it considers to have significant impact on the locality. As the Society’s adopted position on a number of facets of Guildford, the views set out in the Society’s position papers will form a key component of the Society’s responses to future planning applications.

Current position papers

Good design - eight points to help ensure good design and future heritage creation Preserving and enhancing the approaches to Central Guildford Preserving and enhancing Guildford’s historic High Street Preserving and enhancing Guildford’s residential heritage Enhancing Guildford’s riverside Preserving Guildford’s vistas, roofscapes and skyline

Glossary

The Society’s position papers make use of the following terms:

AONB Area of outstanding natural beauty Borough The Borough of Guildford GBC or Council Guildford Borough Council HGV Heavy goods vehicle NT National Trust SCC Surrey County Council Slyfield Slyfield Industrial Estate Society The Guildford Society (see http://www.guildfordsociety.org.uk/) SSSI Site of special scientific interest Town Urban Guildford University University of Surrey

September 2014

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http://www.guildfordsociety.org.uk/


Good design - eight points to help ensure good design and future heritage creation – a position paper by the Guildford Society It is undeniable that good design helps to build communities, creates a better quality of life, and makes places more comfortable for people to live, work and play in. It is the Society’s position that good design should be at the heart of ensuring that new developments and building refurbishments in the Borough respect its heritage and create buildings of quality and architectural merit to form the heritage of the future. This will enable today’s citizens of Guildford to hand on The Town to the next generation in a better state than we acquired it.

1. A good Town Centre Master Plan should include a comprehensive Design Guide. The results of such initiatives as the Farrell Review of Architecture and the Built Environment should be incorporated into the Design Guide as ‘best practice’ for driving forward good design. GBC should also ensure that this guide is publicly consulted on and widely communicated to citizens and the development community. It should also ensure that it is applied to all future developments in The Town so that new and refurbished buildings embrace the principles of good design and hence enhance and enrich Guildford’s commercial and aesthetic future.

A good design policy is only as good as the people that seek to apply it. Where a planning team does not have sufficient members that are fully qualified to design buildings, then its approach often defaults to one of setting simplistic guidelines to prevent the worst mistakes. This limits the opportunity for creating strong and innovative architectural solutions. As a consequence, to effectively implement a good design policy the Society will challenge GBC to commit to up-skilling its planning team.

2 The NPPF states that Local Authorities should have local design arrangements in place, and recommends setting up independent design review panels. Design Review is an independent and impartial evaluation by a panel of experts on the built environment with the skills necessary to appraise and offer observations leading to improvements. They do not attempt redesign. Their review gives planners confidence to encourage quality and innovation. It is independent, expert, multi-disciplinary, accountable, transparent, proportionate, timely, advisory, objective and accessible

Such panels are in place and used by certain neighbouring Authorities. The Society will liaise with appropriate professional bodies to bring forward proposals to assist GBC with establishing such a Design Review Panel and offer its services, on the basis of the Principles and Practice set out in the guidance document published by the Design Council (in association with CABE, the Landscape Institute, RTPI and RIBA) to meet the NPPF requirement.

3 Developers that embrace good design should be publicly rewarded. One way that this can be achieved is by substantially increasing the public awareness of design awards to both local and national levels including Guildford’s own Design Awards programme2 which promote and recognise successful projects and credit owners, architects and builders. Developers should also be actively

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Response to Guildford Consultation Draft Local Plan (September 2014) encouraged to think of themselves as “patrons of good architecture” and be made aware of the financial benefits accruing by creating effective and iconic buildings.

4 The GBC Design & Heritage Champion’s role should be clearly defined to enable them to play a critical and proactive role in planning pre-applications, acting as a truly independent and pro-active champion and as conduit of information with outside bodies.

5 GBC should develop and apply the concept of Permitted Development Rights to smaller projects so that owners are encouraged to consult an architect and invest in a well thought out design without the risk of the scheme not being granted planning permission. Owners are also reminded of the Society’s views on a wide range of development related matters which are set out in the Society’s position papers when considering a development.

6 For larger projects, responsibilities for ensuring good design should be clearly allocated across participants. The developer should be responsible for the financial viability and the architect for the design and for specification of materials. Clear articulation of the benefits to be derived from good design should be encouraged.

7 Primary responsibility for protecting the public interest both in respect of an individual building but its wider context within the public realm should lie with GBC’s planning team. One of their roles should be to protect the public where the developer may have little interest beyond short term financial profit and the architect exerts little influence, a situation which does not normally result in the creation of well-designed buildings. Specifically, planners should:

Apply their powers to ensure that sufficient open space is allocated in new developments. Ensure that the urban grain is distinctive and adds character to The Town. This includes

involvement in determining the scale of new streets, lanes, squares and other urban spaces to ensure that the urban grain is developed and enriched. Blandness in the grain, even more than the individual uses of the units, will result in a disappointing “anytown” character and fail to capitalise on the benefits of being a “gap town”.

Spot opportunities to make space that could be potentially helpful for public transport services notwithstanding that they do not have direct power to control traffic. Planners can however ensure space is allowed for off-road bicycle routes and in large new developments for drive-in-drive-out entrances for buses where these are appropriate.

Restrict the height of buildings so that they blend into the existing urban fabric. Given the height of existing buildings in the Town, building heights of more than four or five storeys will generally be unlikely to meet this principle.

8 Finally, to realise these aspirations, the general public and interested local bodies must all contribute if Guildford is to continue to conserve and create high quality and new heritage.

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Preserving and enhancing the approaches to Central Guildford – a position paper by the Guildford Society

Setting the Scene: A Brief Analysis

Guildford’s position as a ‘gap town’ has endowed it with a complex set of access roads and railways. The roads and railways leading directly into The Town centre are used to access different parts of the Borough as well as connecting to towns outside of Guildford. Although Guildford town centre is the destination for several thousand people every day, people also travel across the Borough to access the University/Research Park/Hospital zone, to work in the suburban office parks and nearby towns, or to attend schools throughout the Borough and beyond. Further, Guildford’s location means it also attracts significant through-traffic including cars and numerous HGVs. The need to cross the River Wey has resulted in many of these routes converging on the frequently grid-locked gyratory. The surfaces of many of these highways are no longer in good order.

The approach roads into the Borough of Guildford tend to be through greenbelt, agricultural land and villages which provide an attractive entrance into the Borough by road. Development in the late 19th century through the mid-20th century has meant that this network is now substantially fixed. Several of these roads are also cross-country ‘A’ roads with a single lane in each direction with only occasional dual carriageways. These factors limit the scope for expanding capacity and varying use.

Within the Borough, the road layouts of the various wards/neighbourhoods were developed in the late 19th century and were well established by the 1930s creating a network that is also fixed at the local level and inadequate for modern needs. The widths of roads in residential areas as well as along main ‘A’ roads are not fit for purpose today. However with adjacent land generally having been developed and in established ownership, there is little scope to change this today.

This trend has continued into the 21st century with new roads within The Town generally being a single lane in each direction with inadequate space for car parking. This has contributed to the significant levels of congestion experienced by motorists during the rush hour when parked vehicles, often unloading goods, partially block a portion of a lane of traffic. In many roads near schools when one traffic lane is fully occupied by parked vehicles, dropping off or calling for children in the mornings and afternoons sometimes brings car movements to a standstill.

This paper’s purpose is not to set out the Society’s position on how this existing highway and rail networks should be changed; this is the work of the Society’s Transport Group. It does however set out the Society’s position on how those existing routes should be improved to provide a positive visual experience for residents and visitors when arriving and leaving The Town.

Improving and Enhancing the Approaches to Guildford

The Society’s position is that it is vital that the approach roads to Guildford make a positive statement about Guildford’s success, culture, heritage and aspirations for the future. In particular:

1. The major routes into and out of The Town should have an absence of pot holes. They should have a wearing course and structure that is durable and of a high standard. Variants should be progressively applied to all roads in the Borough. Surrey County Council’s five year £100 million “Better Roads Scheme” to relay the worst roads in the County, with resurfaced roads having a 10 year guarantee3 is a positive development.

3 Surrey Matters, Autumn 2013

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Response to Guildford Consultation Draft Local Plan (September 2014) 2. Major buildings on principal approach roads should be of high architectural merit. The impression

made by such buildings should be a consideration when granting planning permission for new development sites with the intention of creating landmark buildings. These should also have regard to the environment in which they are located, be kept in good order and minimise any impact on The Town’s skyline. Site hoardings should be kept to a minimum and be decorated to blend with their surroundings, including being painted with a representation of the obscured building as is done in historic towns across Europe; plain or advertising covered hoardings should be discouraged.

3. To provide positive first impressions of Guildford, the Society’s position is that approach road roundabouts and verges be greened and planted to a high standard. General advertising should not be permitted. However where a planting scheme has been sponsored, a modest board is acceptable, provided that it is of standard size and format, its contents are in good taste and it is maintained in good order. The planting rather than advertising must dominate.

4. Well designed signage suitable for all users should follow a clear hierarchy of needs and apply a consistent style which has been developed following public consultation. The extent of information and directional road signage should be useful to users without dominating the environment. Redundant road signage should be removed.

5. Improvements to the pedestrian experience in The Town should include renewal and upgrading of pavements, provision of small landscaped spaces and planters. There should be a presumption in favour of removal of pedestrian protection barriers except where a balanced risk assessment has established the need for retention on grounds of pedestrian safety. Where appropriate, footpaths should be opened to use by cyclists.

6. Street furniture should be well designed, suitably sited and apply consistent styles, developed in consultation with the public. There should be different ranges of street furniture (benches, planters, lighting and bins) for rural and urban locations. Street furniture should also include public art, particularly sculpture, reflecting The Town’s strong tradition in the arts.

7. In order to improve pedestrian links between the rail station and The Town there should be a pedestrian corridor including a river crossing from the vicinity of Guildford Station at Walnut Tree Close to Bedford Road or Onslow Street to serve people accessing The Town as well as Guildford College, businesses and residential areas to the north of York Road.

8. Measures to improve the Traffic flow within The Town should be smooth and include: a) Traffic light synchronisation and monitoring of traffic hot-spots with CCTV. b) Rules regarding loading and unloading of goods vehicles on roads, particularly prohibiting

stopping and unloading of trucks during peak hours on the gyratory.

9. Both rural and urban approach roads should be suitable for all road users. Wherever possible, cycle paths should be created using green verges and be separated from roads. Also cycle paths through open spaces, for example, adjacent to redundant rail lines provide an attractive and safe alternative and could link villages to The Town. Installation of adequate cycle lanes in urban areas is more difficult but where possible should be created both within existing roads as well as providing off-road paths. Safe space should also be made for pedestrians so they do not feel threatened by other road users.

10. Rail passengers arriving in Guildford should experience clean, modern station facilities. There should be well sign-posted, at-grade pedestrian access to all The Town’s key facilities and attractions as well as good interchange facilities for other transport modes.

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Preserving and enhancing Guildford’s historic High Street – a position paper by the Guildford Society

Overview

Guildford’s historic High Street provides the images by which the Borough is universally known. It is designated as The Town’s primary Conservation Area and contains several listed buildings. Its adequate care, conservation and vitality have been a priority to the Guildford Society since its re-formation in 1935, and to its predecessor, the Old Guildford Society4.

However it faces many pressures including: new shopping priorities; wear and tear; the impact of weather on services, surfaces and buildings; commercial demands; competition from proposed new developments; and competing demands for funding. These all present challenges to its survival.

Maintaining High Street premises as economically productive is the best way to ensure the long term preservation of its historic buildings. Consequently the Society’s position is to balance the desire to encourage the vitality and general liveliness of High Street while conserving the characteristics that have made it iconic. This includes encouraging smaller specialist traders to High Street and ts gates to create a balanced offer with major chains and “services” premises – banks, ‘phone shops etc; and working with masterplanners to make the High Street fully pedestrianised. We are also keen to avoid developments elsewhere making High Street premises economically unviable while High Street premises should be able to participate in a wider range of activity, for example the night time economy, markets and art.

Street paving

The granite setts make a major contribution to High Street’s character. They were laid over a century ago on a flexible sub-base adequate for horse-drawn traffic but were re-laid in the 20th century with a rigid construction which has proved incapable of bearing the load of heavier and faster vehicles of today. This has been exacerbated by inexpert re-laying following maintenance of buried services with lifted setts frequently mislaid and replaced with asphalt.

A similar situation applied to the footways/pavements of York stone paving slabs which have suffered from both heave from vehicles mounting the kerb and maintenance of buried services. The traditional cast-iron rainwater ducts across the pavements have been allowed to disintegrate with shallow concrete surface channels being considered.

The Society’s position is that:

11. Suitable specifications and method statements are developed and made mandatory for all relaying work including the currently planned relaying of the setts in High Street.

12. Matching replacements are sourced to cover any setts or York stone slabs lost.

13. Only craftspersons correctly trained in laying setts and York stone paving are employed to work on this key heritage asset.

14. A clearly designated officer with responsibility for oversight and checking should continue to be appointed, the findings of that oversight rigidly enforeced and all contractors be required to give notice of operations to that officer.

4 “What Makes Guildford High Street Special?” by Doug Scott, Nov. 2010

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Response to Guildford Consultation Draft Local Plan (September 2014) 15. A programme of systematic like-for-like replacement of the cast-iron rainwater channels across the

pavements is established (for example when shop fronts are renewed).

16. There is adequate funding and a committed budget to cover the above.

17. A weight limit be imposed on HGVs using High Street to protect setts and stone flags.

18. The iconic High Street be listed to match the buildings which benefit from this status or given “Scheduled” status by English Heritage.

Street furniture

The Society expects all street furniture5 and signage on High Street to be: appropriate to the character of its location; simple; consistent; and for all signage to be clear. This is particularly appropriate to The Town’s historic streets. The Society’s position is that:

1. A high standard of design, sensitive to location, for all items of street furniture.

2. Design and colour of bollards, bins and posts to be consistent.

3. Signs to be clear, informative, sensitively placed and unobtrusive.

4. An appropriate “heritage sensitive” barrier gate.

5. Utilitarian barriers which break the visual link with Town Bridge to be removed/replaced.

Shop fronts

Over the years the Society has done much to encourage good shop front design through its Design Awards. Many of the points made have been built into the Council’s own shop fronts policies. The Society’s position is that within the High Street conservation area:

1. Fascias should show good and appropriate design (both “retro” and clean modern), be in “traditional” colours and respect the architecture of the stories above.

2. Hanging signs should be no larger than (600x600mm); fascias and signs should not be illuminated.

3. Windows should not contain garish long-term posters.

Upper stories

High Street premises used for shops at street level frequently use the upper floors for storage or appear to leave them unoccupied. Windows are frequently blanked off or left uncleaned. None at present appear to be used for their original residential purpose, due to the difficulty of separate access. The Society wishes to encourage:

1. Proper maintenance, including window-cleaning, and removal of unsightly clutter.

2. Occupants to re-plan and open up “dead” windows.

3. Creative design by owners to allow uses including residential or small professional office and connecting adjoining premises together.

Street lighting

5 The Society defines street furniture to includes seats, benches, bollards, telephone connection boxes, lamp posts and floral posts, pedestrian signposts, historic plaques, parking restriction signs, significant sculptures (two currently) and the barrier gate to exclude vehicles at “pedestrian only” times.

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Response to Guildford Consultation Draft Local Plan (September 2014) Existing street lighting is appropriate to High Street with a range of replacement “heritage” posts and fittings being currently available which is generally acceptable. The Society will continue to monitor the appropriateness of lighting, applying the same standards as for street furniture. The Society is also keen to encourage good design for special displays such as Christmas lighting.

September 2014

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Preserving and enhancing Guildford’s residential heritage – a position paper by the Guildford Society Overview

Guildford is a historical commercial centre and major commuter hub. Its housing stock comprises a blend of dwellings from medieval to contemporary which when combined with its proximity to London makes it a highly desirable location in which to live. With continued inward immigration to the South East and ambitious plans by the University and GBC to make the Borough a technological hub, Guildford faces a significant challenge to balance increased demand for residential accommodation with the need to conserve the character that makes it an attractive place to live.

Preserving the character of The Town by retaining its existing housing stock

A significant proportion of Guildford’s historical housing stock has already been lost through poorly planned or insensitive development. The housing stock that remains makes a significant contribution to the character of The Town and includes what is regarded by some as a garden city (Onslow village), Edwardian mansions and Victorian terraces. The Society is committed to conserving The Town’s existing housing stock and retaining this intrinsic part of Guildford’s character.

A number of Guildford’s districts already enjoy some protection through the more onerous planning regime that accompanies designation as a conservation area. However, there are a significant number of other residential areas of Guildford which the Society considers to be of community or architectural value but which do not enjoy this same level of protection.

To prevent isolated out of character development, the Society is generally against demolition of existing single dwellings, instead preferring developers to focus on modernisation or conversion within the existing fabric of a building in order to preserve its exterior and interior architecture and provide it with new life. Such development should ensure that architectural styles and materials match those of existing contemporary buildings with materials selected and construction performed in accordance with the principles of sustainable construction6 and so as to ensure the new development achieves an Energy Performance Setting A rating. Further information is contained in the Society’s position paper on Good Design.

An alternative development strategy of which there have been numerous examples is the practice of –sub-dividing existing residential plots and development of additional dwellings, increasing densities. This has an adverse impact on local community by increasing plot densities, introducing new and often clashing architectural styles and compromising access. The Society considers the green spaces provided by gardens to be an important part of the character of a site which are also to be conserved. The Society considers that owners have a duty to the society in which they live to retain the character of their area. The Society will oppose sub-division where it considers the resultant development will cause aesthetic harm to the locality.

Strengthening communities through high quality development

The Society is however supportive of new development that enables the Town to continue to thrive and flourish in the 21st century. The requirements for such new properties would ordinarily be set out in a comprehensive master plan for Guildford. But in the absence of such a plan, we would expect the characteristics of such developments to include:

Being of a size and nature that meets the changing needs of The Town’s demographics; Being sensitive to and complimenting existing architectural styles prevalent in their locations; Built at a plot density in keeping with other contemporary local developments;

6 Strategy for Sustainable Construction published by HM Government, June 2008.

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Response to Guildford Consultation Draft Local Plan (September 2014) Built according to best practice in sustainable construction; and Creating a quality architectural legacy of benefit to current and future generations and that is of

equal or greater architectural merit than any existing building being replaced. Further information can be found in the Society’s position paper on Good Design.

To avoid unnecessary development of greenfield sites or the greenbelt, the Society believes new development should be sited within The Town whenever possible. This will rebuild a vital community in the heart of The Town, prevent destruction of other sites of value to residents and enable regeneration of existing industrial sites.

Further there has been a recent trend to convert retail premises for residential space. Providing such development takes place in accordance with the principles set out in this paper, the Society would be in favour providing that such conversion does not remove essential services from communities. With regard to Guildford’s historic High Street, the Society is in favour of bringing space above shops into residential use as this helps conserve the fabric of these historic buildings. However the Society is opposed to conversion of street-level retail premises for residential accommodation as this would damage the character of this Guildford landmark.

Where residential development does take place, it is important that this is well planned and makes provision for the necessary infrastructure to create thriving, accessible and sustainable new communities. This includes good transportation links, schools, retail leisure and open spaces which should be provided at the cost of the developer. The Society does not consider “gated communities” where security fences and gates seek to isolate and separate specific developments from the communities in which they are located to be consistent with the creation of strong, sustainable communities. The Society is similarly opposed to the creation of gated environments around existing dwellings or groups of houses.

Importantly, the Society has a presumption that where existing residential sites are developed, due regard should be given to the character and utility of the urban environment in which the new development is sited. This will enable green spaces (including gardens) to be retained. Equally, this should not be seen as encouraging high-rise development as this would also change the character of The Town and damage views of its surrounding countryside and existing skyline.

While this paper is focused on the Town, the Society would apply similar criteria when considering proposed residential development in the surrounding villages.

September 2014

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Enhancing Guildford’s riverside – a position paper by the Guildford Society Overview

The River Wey runs through the heart of Guildford. While in its outskirts the river provides green space, in the centre it has become hemmed in by buildings of disparate styles as poor planning decisions over many years have resulted in significant damage to this environment. Of particular concern is the preponderance from the second half of the 20th century of monolithic structures, brutalist architecture and ugly surface car parks. These provide an unpleasantly stark contrast with Guildford’s county town vernacular and the rural environment that the river provides in the heart of The Town, undermining its value to the community.

The National Trust owns the River Wey Navigations and is responsible for maintaining it as a working waterway. This affords a level of protection to the river itself and its adjacent towpaths and today is principally used by pleasure craft (rowing boats, canoes, narrow boats), walkers, cyclists and fishermen. However the river is also a major part of Guildford’s industrial heritage and is surrounded by a number of historic buildings which are variously in the ownership of GBC and private landowners and which should be conserved and protected from future redevelopment.

Further, the river is a rich source of pleasure to residents of Guildford, providing a green corridor in the heart of The Town. The adjacent Shalford Park and water meadows are critical for absorbing floodwaters and protecting the town centre from flooding while providing a haven for wildlife.

Society position

The Society’s focus is on the riverside between Ferry Lane and Stoke Mill. Its position is to recognize the distinct stretches of river - regenerating and preserving the built-up area in the town centre and conserving the rural areas of the river. Specifically:

4. There should be no further development between the River Wey and A281 from Ferry Lane to Guildford Rowing Club to preserve the rural environment that currently extends into the heart of The Town. This land should be preserved as part of the green belt to the south of Guildford and provision made to encourage wildlife and wildlife watching and so it can fulfill its historical role of absorbing flood waters and protecting the town centre.

Where redevelopment of existing properties on the west bank takes place, such development should be low-rise, have due regard to enhancing existing scenic views and existing architectural styles. In particular, there should be a presumption against large apartment-style developments in this part of The Town.

5. The developed area of the riverside from Guildford Rowing Club to Dapdune Wharf should be re-zoned for leisure use while conserving the existing heritage buildings and public open spaces in this area. A plan should be established for this area setting out a long term programme for its transformation. In particular:

This area could be a leisure destination for residents and visitors, creating new dining and drinking experiences and facilitating a “café society” that might become the pulsating heart of The Town. It should meet the tastes, needs and budgets of all ages and social groups and include landscaping, open spaces, sculpture (eg the Society’s “Bargeman”) and galleries to promote the arts, creating a focal point for culture and cultural events in The Town.

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Response to Guildford Consultation Draft Local Plan (September 2014) Many of the existing buildings in this area7 are part of the Borough’s industrial heritage and

should be conserved for predominantly leisure use. All new development in this area should be sympathetic to this heritage and its architectural style. Cities such as Birmingham and Manchester provide good examples of how this can be achieved.

Buildings that do not fit this template8 should be redeveloped as they approach the end of their lives and be replaced with more sensitive properties. In the interim period, owners should be encouraged to take steps to ensure that these buildings are less obtrusive and better blend in with the proposed use for this area. The Yvonne Arnaud Theatre has made some positive changes with its outside café in this respect.

Parking should be sited away from the riverside area and in particular existing surface car parks at Millbrook, Park Street and Bedford Road should be re-sited or built under ground, freeing up this land for more efficient use, for example leisure related-activity.

The environment should be re-landscaped, removing railings where possible and hiding unsightly bins that are currently visible and negatively impact the perceptions of visitors.

Interpretation boards should be located sensitively to explain the historic context of buildings.

6. The river between Dapdune Wharf and Stoke Mill already flows in an urban area. Sites in this area should be re-zoned for housing, with existing green sites preserved. For example Walnut Tree Close should become a new waterside community. This would enable the greenbelt to be protected while removing the existing unsightly industrial and commercial buildings from this stretch of river. Such development should not be high-rise in nature, but be flood resistant and sensitive to its riverside location; premises with river frontages should be well presented.

7. Wey Navigations infrastructure which is the responsibility of the National Trust should be well maintained to avoid negative perception of poorly maintained infrastructure by residents and visitors. Existing pedestrian bridges at the Yvonne Arnaud Theatre and Guildford Rowing Club should be replaced with permanent structures that are in keeping with other Wey Navigation infrastructure and provide stepless access.

8. Traffic infrastructure and in particular the gyratory has one of the most significant impacts on the riverside area. Detailed consideration of this is beyond the scope of this paper. However, where possible there should be a presumption in favour of minimising the impact on the riverside area of major highways that parallel or cross the river and priority given to pedestrians. The existing historical Town Bridge and Onslow Bridge should be re-integrated with the regenerated riverside area and colour schemes co-ordinated.

9. The riverside area should enjoy safe, attractive connections to key locations in The Town including the railway and bus stations, High Street, North Street, University and Castle. These should be greened and access provided for able bodied and disabled people at street level. Signposting should be clear, unobtrusive and in keeping with the character of the riverside area.

10. A continuous foot path including new bridges in contemporary or canal vernacular architectural style should be created along each side of the river from land already in public or National Trust ownership and from land provided as part of future development and regeneration opening up frontages to the river. Where residential properties back directly on to the tow path, walls (in bargate stone) or wooden fencing should be well maintained and consistent in style.

September 2014

7 Eg Rodboro Building, The Billings, Town Mill, Dapdune Wharf, Electric Theatre, Onslow Street quay, Treadwheel Crane. 8 Including Debenhams, Connaught House, Wey House and Friary Court.

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Preserving Guildford’s vistas, roofscapes and skyline – a position paper by the Guildford Society Overview

Guildford has been bestowed with a stunning natural location, located as it is in the heart of the North Downs in the River Wey Valley and this topography has created particularly fine sight lines. As the historical county town of Surrey, Guildford’s development has created a number of historic buildings of local and national significance that have created an iconic skyline. Together these have combined to form a key component of The Town’s heritage.

It is the Society’s position that these skylines and sight lines be protected for the benefit of current and future generations against damage by development in The Town. As it is impossible to list every sight line and skyline of heritage value in Guildford, developers should demonstrate that there is no significant impact on these by any proposed development.

Vistas within Guildford town centre

Guildford is frequently called a gap town “and probably owes its location to the existence of a gap in the North Downs where the River Wey is forded by a path commonly known as the ‘Pilgrims’ Way’” between Winchester and Canterbury9. It is also located on the coaching route between London and coastal towns such as Portsmouth, which was a catalyst for creating much of the iconic architecture in Guildford today.

On both sides of this river valley there are steep and significant hills, the Mount leading to the Hogs Back to the west, and Pewley Down (with the Castle at its base) and St Martha’s Hill to the east. Both sides of the valley are wooded and the existing trees are a significant component of these views and consequently require careful maintenance.

The principal sight lines which this has created are as follows:

Looking down from the top of the iconic High Street, across Town Bridge over the Wey to The Mount and the original Pilgrims Way green lane drovers’ road winding its way over the Hogs Back towards Winchester.

From The Mount one can look up the High Street with its granite setts, half-timbered and Georgian buildings and the exceptional 17th century Abbotts Hospital, Holy Trinity Church, 16th century Royal Grammar School which form a unique cluster of listed buildings with the Guildhall and John Aylwards’ clock projecting over the street.

From above Tunsgate Arch a short lane approaches the Castle Gardens and at its centre the splendid Norman Keep, an ancient monument from the 12th century.

From the Keep and its surrounding mount, the view South across the Surrey Hills is outstanding.

To the west of The Town, one looks across central Guildford towards Maufe’s 20th century Cathedral which towers over most other buildings in The Town.

Looking east from The Town across the Wey valley to the rear of the fine terrace of listed buildings on Quarry Street with the Castle behind and Semaphore Tower above.

9 Source: http://en.wikipedia.org/wiki/Guildford

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http://en.wikipedia.org/wiki/North_Downs

http://en.wikipedia.org/wiki/River_Wey

http://en.wikipedia.org/wiki/Ford_(crossing)

Response to Guildford Consultation Draft Local Plan (September 2014) The narrow lanes leading off on either side of the High Street such as Angel Gate which form part

of Guildford’s county town vernacular.

The rooflines formed by the listed buildings and more recent developments on High Street, Quarry Street and Chapel Street.

However the rooftops of many buildings are strewn with plant and radio transmitters and these should be suitably obscured by sensitive architecture whilst retaining functionality.

The skylines to the east and west heading south from the town centre are dominated by green hills which are peppered by individual homes of character built to a low plot density which were constructed principally in the first half of the 20th century. These have contributed to the characteristic appearance of these hills.

These views are considered to be key features of Guildford’s cultural, historical and natural heritage and should be secured in perpetuity.

Vistas in the Surrey Hills and Greenbelt

The Town’s location within the Surrey Hills provides many views both adjacent to The Town and further afield that are extraordinary. Much of the Surrey Hills and the North Downs are already protected as they are in the rural Greenbelt and are designated as AONBs and SSSIs.

Along the A248 between Shalford and Albury, spectacular views in all directions can be seen from and to the pinnacle of St. Martha’s Hill, with its 12th century church reputed to have served as a resting stop along the Pilgrim’s Way; this site also features several Neolithic and Megalithic artefacts some of which have been dated to 3500 BC.

The Hogs Back is a narrow elongated ridge that stretches from Guildford to Farnham. At a height of 154 metres above sea level it provides exceptional views:

To the north of the Borough’s towns and villages such as Normandy, Tongham and Ash and on clear days to London including Canary Wharf, The Gherkin and Heathrow Airport.

The views to the south of the Weald are unspoilt and much of this area has been designated as AONBs as well as SSSIs.

These views are considered to be key features of Guildford’s cultural, historical and natural heritage and should be secured in perpetuity.

September 2014

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Response to Guildford Consultation Draft Local Plan (September 2014) ANNEX – PHOTOGRAPHS OF KEY VISTAS

Vistas within Guildford town centre

Looking towards the West Hill from the High Street The same view a bit further up the hill at the Guildhall.

View of the Cathedral and the University site from West Guildford View from Bright Hill towards Guildford Cathedral Vistas in the Surrey Hills and greenbelt

View from the South looking up towards St. Martha’s Church

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Appendix 3 – The Guildford Society: Background and Purpose

[to be appended]

Documents

Response to Guildford Consultation Draft Local Plan · 15.09.2014 · Response to Guildford Consultation Draft Local Plan (September 2014) Exec 18. The Town Centre Vision consultation,