Save Hogs Back

Save Hogs Back

Every photograph featured was taken at Blackwell Farm and every field

shown will be built on if the proposals go ahead

“the vision from its windy heights is one of the widest and most gracious of all visions of woods and fields and hills”

Eric Parker, 1908

Save Hogs Back Page 2

Save Hogs Back

The Hogs Back at Blackwell and Manor farms has been put forward as a strategic develop-ment site by Guildford Borough Council (GBC) in its draft Local Plan1 and the University of Surrey (UniS) has unveiled its accompa-nying plans to build 3,000 homes, spreading across 265 hectares of the Green Belt.

If these plans are realised, a third of the land forming the northern slopes of the Hogs Back between Guildford and Farnham would become urbanised, and nationally important views blighted for miles along this ancient ridge.

The proposed development area is vast and will increase the footprint of Guildford town by almost 15 per cent. An expansion on this scale, and the erosion of the borough’s dramatic rural backdrop, will change its character and setting forever. It will no longer be a place where hundreds of residents can easily access the countryside, and its historic centre will be lost among urban sprawl. Large swathes of beautiful countryside will be cov-ered in roads and houses, and views to and from an Area of Outstanding Natural Beauty (AONB) will be blighted.

The surrounding villages of Comp-

1 The draft Local Plan is for 2,250 homes (with 139 ha removed from Green Belt – not including additional SANG).

ton, Puttenham, Wood Street and Wanborough will also suffer as the rural landscape separating them from Guildford is swallowed up in housing estates and more traffic enters the already congested road network on the west side of town.

But surely this has all been taken into consideration and this site has been determined as a good place to build? It appears not.

The site is flanked by an AONB to the south, Broadstreet Common (an SNCI) to the north, ancient woodland and open countryside to the east, and ancient woodland and a scheduled ancient monument to the west. It also provides important rural views of the Cathedral.

The land itself is working farmland, containing areas of high grade agricultural land, which provides food to the region and boosts the economy. It is rich in wildlife and biodiversity, and supports four bird species of principal importance. It is crossed by public rights of way and contains medieval hedgerows, ponds and historic parkland. Much of the land is classified as an area of great landscape value (AGLV) or AONB. The entire land area is in Green Belt and fulfils all of the Green Belt purposes effectively.

Despite these features, GBC has earmarked this site for potential de-velopment, so why should the Hogs Back be saved?

“All the world in a few square miles. Chalk pits and blue butterflies on the Hog’s Back. And at the foot of the hill, suddenly, the sand; hard, yellow sand with those queer caves … And the fine grey sand on which the heather of Puttenham Common grows … And the enormous sloping meadows round Compton and the thick dark woods. And the lakes, and the heaths, the Scotch firs at Cutt Mill. The forests at Shackleford. There was everything. Do you remember how we enjoyed it all?” (Aldous Huxley, Antic Hay, 1923)

“Upon the whole it was an excellent journey and very thoroughly enjoyed by me; the weather was delightful the greatest part of the day ... I never saw the country from the Hogsback so advanta-geously.” (Jane Austen, May 20, 1813)

“From this town of Guilford [sic], the road to Farnham is very remark-able, for it runs along west from Guilford, upon the ridge of a high chalky hill... from this hill is a prospect either way, so far that ’tis surprising; and one sees to the north, or north west over the great black desert, called Bagshot-Heath, mentioned above, one way, and the other way south east into Sussex, almost to the South Downs, and west to an unbounded length, the horizon only restrain-ing the eyes ...” (Daniel Defoe, 1724-27)

Why save the Hogs Back? The Hogs Back is a chalk ridge forming part of the North Downs, which runs east to west through Surrey. For cen-turies it has formed part of the great highway across the south of England stretching from Salisbury Plain to Dover.

Guildford grew up in a gap in the North Downs at the crossing point of the River Wey. The Hogs Back (formerly Guildown) forms the backdrop to Guildford. Manor Farm and Blackwell Farm are on its northern slopes. Half of the proposed development site is above the 90m contour. Guild-ford’s Cathedral, by comparison, sits on the top of Stag Hill, which is just 78m AOD.

The heritage argument

Farms and hamlets across the former Down Place estate have a rich history, which dates back to ancient times. This history would be buried beneath executive homes, garages, super-markets and tarmac.

Published by Save Hogs Back and CPRE.For further information please contact:

[email protected]

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Records show that King John spent Christmas at Manor Farm with “uncommon splendour and magnificence” in 1200; Edward III spent Christmas there in 1337, 1340 and 1347; Edward IV stayed in 1479 and 1482; and Henry VIII in 1546. It is also believed that Elizabeth I visited on several occasions

Our “heritage assets” should not be something this generation can choose to destroy and the NPPF puts a duty on local authorities to protect them:

“Local planning authorities should set out in their Local Plan a positive strategy for the conservation and enjoyment of the historic environ-ment, including heritage assets most at risk through neglect, decay or other threats.” — NPPF 12, 126

The choice to put forward Blackwell Farm into GBC’s draft local plan appears to have no regard to this duty as:

Guildford would lose…... historic views from the Hogs Back. Blackwell, Manor, and Chalk Pit farms form part of the slopes of the Hogs Back – the steep chalk ridge that provide a dramatic back-drop to the town, and which can be seen from many points across the borough, including the High Street. The road along the ridge is ancient – its raised position offering pan-oramic views across open country-side, which have remained unspoilt for thousands of years.

Guildford would lose…... the only remaining corner of the Royal Palace and Park of Guildford, created in 1154 by Henry II as a deer park and an important part of Guildford’s history for more than 500 years. The Park was one of the biggest in England. It covered 1,620 acres, with a circumference of seven and a half miles, and adjoined Windsor Great Forest.

Hence Guildford has areas named “Stag Hill” and “The Chase”. Deer still roam freely across the fields and woodland of Manor, Blackwell, Chalk Pit and Wildfield farms.

Medieval moatPartridge Field in Manor Farm is the last undeveloped section of the royal deer park. It provides a rural setting adjacent to the medieval moat, which once encircled the royal hunting lodge (a Scheduled Ancient Monument (SAM)).

Although the University says it has a conservation strategy for the SAM, the moat has been neglected under its ownership and there has been no attempt to open up the site to the public. Furthermore, three sides of the moat are now over-looked by University development. If Partridge Field is developed, the SAM will be fully surrounded and lost among urban sprawl.

Artist’s impression of how the Royal Manor would have looked2

2 Adapted from illustration by Boris Fijalkowski, reproduced in Helen Chapman Davies’ Book Guildford’s Hidden History

Guildford would lose…... one of the South East’s rare model farms. In 1859, architect and diarist Henry Peak designed Blackwell Farm in the new industrial form that was popular among large-scale landowners and farmers. The model farm was unusual for this part of the country and attracted consider-able attention at the time. Peak also designed Guildford Castle Gardens, Wyke School and the Fire Station in North Street.

Since being owned by UniS, Black-well Farm buildings have been boarded up and fallen into disre-pair.

Guildford would lose…... historic parkland associated with Capability Brown – Blackwell Farm has many and various stately trees – the remnants of parkland once belonging to Down Place.

Although there has been a house on the site for nine centuries (Down Place was the main manor of Compton at the time of the Domes-day survey), it was during the 18th century that most of the landscap-ing took place, and it is believed that landscape architect Capability Brown had a hand in this.

Guildford would lose…... strategic views and viewpoints to the grade II*-listed Cathedral. Blackwell and Manor farms provide the only remaining views where it rises from an entirely rural setting. Development here would adversely affect these significant views.


Save Hogs Back

“Manor Farm is the last remaining undeveloped corner of the Royal Palace and Park of Guildford, created in 1154 by Henry II ... Deer still roam freely across the fields and woodlands of Manor and Blackwell farms”

A journey through time - documented travellers on the Hogs Back

Worshippers travelling to Stonehenge

Phoenician, Greek and Gaul traders with Cor-nish tin, lead and furs

Julius Caesar on his way to London

King Alfred the Great, who was abducted here in 1035 by Earl Godwin

William the Conqueror on his way to Winchester

Pilgrims, including Hen-ry II, walking to Thomas à Becket’s shrine in Can-

terbury.

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“The fields across Blackwell Farm are bounded by hedgerows ... Most of the ancient hedgerows at Manor Park have been ripped out”

Eighteenth century parkland at Down Place estate covers much of the area proposed for devel-opment


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Spindle found on Blackwell and Manor farms dates hedgerows as more than 600 years old

Going, going ...“I thought it would last my time –The sense that, beyond the town,There would always be fields and farms,Where the village louts could climbSuch trees as were not cut down ...

And that will be England gone,The shadows, the meadows, the lanes,The guildhalls, the carved choirs.There’ll be books; it will linger onIn galleries; but all that remainsFor us will be concrete and tyres.”

Larkin wrote this poem in 1972. The title “Going, going ...” refers to the landscape of England, which he saw being fast eroded by devel-opment.

Much of what Larkin feared has happened, but in Guildford – which has been protected by the Green Belt and its AONB designations – the countryside “beyond the town” has survived, and Blackwell Farm is one area where Larkin’s “shadows”, “meadows” and “lanes” still exist.

But what we are losing is not just the “fields and farms”, but an im-portant part of Guildford’s character – a sense that countryside is within reach – not a park or other urban landscaping, but real countryside,

with medieval hedgerows, ponds and woodland, and all the wildlife that goes with it.

And the impacts of this loss of countryside will be far-reaching...

There will be an impact on ancient woodlandThe University land on the Hogs back includes two areas of ancient woodland. And these are truly ancient – land that has remained as woodland since the last ice age, 12,000 years ago.

These won’t be built on under the proposals, but both will be harmed, especially the woodland on the western side at Strawberry Grove and Manor Copse, which would be completely encircled by roads and houses. The woodland is home to many rare plants and animals, and these would not survive in an urban area. Rare bird species, such as nightingales and night jars, used to live at Strawberry Grove, but these have disappeared in the last ten years after most of Manor Farm was taken out of Green Belt.

There will be an impact on hedgerowsThe fields across at Blackwell Farm are bounded by hedgerows, some

dating back to medieval times. Many of these will be threatened. Most of the ancient hedgerows at Manor Park have been ripped out. This is despite the Hedgerow Regu-lations (1997) statement that, “The circumstances in which removal of an important hedgerow is allowed to proceed are likely to be exceptional. But a local planning authority might consider that the wider public inter-est was best served by the removal of a hedgerow.” Was the wider public interest served by the removal of these hedgerows?

There will be an impact on the AONB’s dark skiesThe University is proposing to build a £10m roundabout at the top of the Hogs Back to provide access to its new town3. The planner (Terence O’Rourke) has confirmed that this would have to be lit up at night. Because of its elevated position, the new roundabout would cause light pollution for miles around.

“Night light in Guildford is a pressing problem. In the year 2000, Surrey had a light night intensity equivalent to 80% of that emitted from Greater London.” 4

3 UniS presentation to the Guildford Society, February 18, 20144 Letter from Gillian Hein, CPRE Planning Officer to Carol Humphrey, August 19, 2004

Why save the Hogs Back? The environmental argument

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There will be an impact on Guildford’s air qualityGuildford is a “gap town”, located in a valley at a point where the River Wey cuts through the North Downs. This creates problems in terms of traffic, which is forced through the gap from all directions, and, of course, the NO2 emissions, which this traffic generates. In June 2013, Guildford’s air quality database indicated that two central Guildford sites were very near, or exceeding, 40 micrograms/m3 NO2 – the average annual limit allowed by the EU Air Quality Directive – and that this trend was rising. Ground level ozone is frequently seen in urban areas in summer5.

Building 3,000 houses across 265 hectares of the Hogs Back will make matters worse:

i) another 6,000 cars will enter the road network on the west side of Guildford, increasing congestion (and emissions) along the A3 and A31 where these two roads intersect the town.

ii) Guildford’s “green lung” (on the slopes of the Hogs Back) will be removed. In the UK, the prevailing winds are from the West. The open farmland to the west of Guildford allows clean air to be blown into the town. If this area is urbanised, CO2 emissions and other pollutants will replace this clean air.

5 http://www.gefweb.org.uk/GEF%20newsletter%20Mar%2013.pdf

There will be an impact on wildlifeSir David Attenborough has warned that British Wildlife is in grave peril: “Fifty per cent of the hedgehog population has gone in 25 years; 90% of the wildlife meadows have disappeared in 100 years; 60% of all wildlife is diminishing and in danger, with 10% doomed to disappear in the next decades.”6

The Hogs Back is the only place in South East England where there is steep, north-facing chalk down. The South Downs and Chiltern Downs are south facing and the North Downs slope is gentle to the east of Guildford all the way to Dover. This means that the Hogs Back contains many rare and interest-ing plants, supporting all kinds of wildlife.

At Blackwell Farm there are deer, foxes, rabbits and snakes (adders, grass snakes and slow worms). There are badgers, bats, stoats, weasels and field mice. There are buzzards, kestrels, owls, pheasants and woodpeckers. There are also skylarks, yellowhammers, lapwings, linnets and little owls, all of which are endangered.

6 RSPB Conference for Nature, Lon-don, 3 September 2014

Blackwell birdsHundreds of bird species are present here, including some that are now rarities in the wider British countryside, having declined by more than half their original numbers in a 25-year period. The skylark, yellowhammer and linnet (once hunted almost to extinction by the Victorians for their fashion of keeping song birds) have all been present for the past 10 years.

These birds have been joined over the previous two summers by the lapwing, demonstrating that the farm is clearly of principal impor-tance for all these declining species.

All four species noted above have some of the highest conservation requirements laid down in law as birds of Principal Importance for the Conservation of Biodiversity. However, they are by no means alone in their choice of Blackwell Farm as home – they share it with more than 50 other bird species, including swifts, which travel 6,000 miles from central and southern Africa to use site as a key feeding ground. Many of these birds are sensitive to disturbance and would not cope with construction work or with urbanisation. Furthermore, and contrary to what some assume, many would not find new homes due to the fact that alternative habitats may not exist, are too far away, or are already occupied at full capacity.

The overall net decline in wildlife we continue to see in the UK is due to many localised assaults; a constant chipping away of our natural capital. Developing a site that clearly has such a high wildlife value would be compounding the national declining wildlife diversity problem.

One of the resident yellowham-mers (a Species of Principal Im-portance for the Conservation of Biodiversity) filmed at Blackwell Farm this March

A family of kestrels enjoying the view over Blackwell Farm

Wild orchids in ancient woodland at Blackwell Farm


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“90% of the wildlife meadows have dis-appeared in 100 years; 60% of all wild-life is diminishing and in danger with 10% doomed to disappear in the next decades” Sir David Attenborough

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62

3.1 The Nature and Profile of the Guildford Business Environment

This sub-section examines the nature and profile of Guildford’s local business environment. As part of this sub-section the report uses information from recent surveys of local businesses to identify what factors make Guildford a good or bad place for business. This information is useful as it can be used to inform any future economic development strategies.

3.1.1 The importance of the local business environment

The local business environment within which firms operate is a significant factor in determining the success and vitality of a local economy. It is made up of a number of constituent elements encompassing both the public and private sector. Aspects which may impact upon businesses include direct factors such as the cost and availability of business premises as well as more indirect factors such as the cost and availability of housing.

The local business environment is significant because whilst it may serve to encourage and facilitate business growth and economic development, it may also hinder and discourage growth. The importance of the local business environment for the Guildford Borough economy is the effect that it may have upon its ability to meet its potential for current and future growth. As Figure 3.1.1 indicates there are a number of factors that may impinge upon the Borough’s ability to realise its potential for growth. In particular these factors may impact upon the following aspects of economic growth:

• TheabilityoftheBorougheconomytoattractnewfirmsand inward investment into Guildford

• TheBorough’sabilitytoretainexistingfirmswithinthelocal economy

• Theabilityoflocalfirmstofullyrealisetheirpotentialforgrowth.

A survey of businesses undertaken by Guildford Borough Council in 200832askedanumberofquestionsthatprovideindications of the satisfaction or otherwise of Guildford firms with the local business environment. Businesses were asked what factors made Guildford a good place in which to do business and what factors made the Borough a poor place in which to do business.

Figure 3.1.1 shows those factors that were considered to be a strength. The most important factors identified were related to Guildford’s location with firms specifying good roadandrailconnections(68percentand56percentrespectively)andproximitytoLondon(54percent).Thesefactors are pertinent given Guildford’s designation as a transporthubintheSouthEastRegionalStrategy.Theothermain strength identified is the Borough’s environment with 58 per cent of firms identifying Guildford as an attractive place for people to live and work. What is also noticeable is that very few firms identified local business support networks or the Borough Council as positive factors.

Firms were also asked what factors made the Borough a weak placeinwhichtodobusiness.Theresponsestothisquestionwere more definite with almost two-thirds of firms stating that traffic congestion within the Borough and a lack of affordable housing were seen as local weaknesses. In addition 29percentoffirmsreportedthatplanningconstraintsheldback business, 13 per cent said that their workforce was inappropriately skilled and another 12 per cent stated that the Borough Council was not friendly to business.

Figure 3.1.1 – Factors Making the Borough Good for Business

Source: Guildford Borough Council Business Survey 2008

33A postal survey was carried out by Guildford Borough Council. The survey was focused on users of B-class space and a total of 153 responses were received

Guildford Economic Development Study 2009 – Evidence Base

Section Three – The Guildford Business Environment 88

3.1 The Nature and Profile of the Guildford Business Environment

This sub-section examines the nature and profile of Guildford’s local business environment. As part of this sub-section the report uses information from recent surveys of local businesses to identify what factors make Guildford a good or bad place for business. This information is useful as it can be used to inform any future economic development strategies.

3.1.1 The importance of the local business environment

The local business environment within which firms operate is a significant factor in determining the success and vitality of a local economy. It is made up of a number of constituent elementsencompassing both the public and private sector. Aspects which may impact upon businesses include direct factors such as the cost and availability of business premises as well as more indirect factors such as the cost and availability of housing.

The local business environment is significant because whilst it may serve to encourage and facilitate business growth and economic development, it may also hinder and discourage growth. The importance of the local business environment for the Guildford Borough economy is the effect that itmay have upon its ability to meet its potential for current and future growth. As Figure 3.1.1 indicates there are a number of factors that may impinge upon the Borough’s ability to realise its potential for growth. In particular these factors may impact upon the following aspects of economic growth:

• The ability of the Borough economy to attract new firms and inward investment into Guildford;• The Borough’s ability to retain existing firms within the local economy;• The ability of local firms to fully realise their potential for growth.

A survey of businesses undertaken by Guildford Borough Council in 200832

36%

68%56%

27%

54%

27%

12% 14%

58%

20%

0%0%

10%20%30%40%50%60%70%80%

Good quality local

workforce

Good rail connections

Good road connections

Good air connections

Proxim

ity to London/m

ajor centres

Good opportunities for local inter-trading

Good business support

available

Business friendly

Borough C

ouncil

Attractive environm

ent

Good local business

networks

Other

asked a number of questions that provide indications of the satisfaction or otherwise of Guildford firms with the local business environment. Businesses were asked what factors made Guildford a good place in which to do business and what factors made the Borough a poor place in which to do business.

Figure 3.1.1 – Factors Making the Borough Good for Business

32 A postal survey was carried out by Guildford Borough Council. The survey was focused on users of B-class space and a total of 153 responses were received

Section Three The Guildford Business Environment

Guildford is the top performing, non-metropolitan borough in the UK 7and it is in everyone’s interests for the borough to retain this position and for its growth to continue.

So what should we do to make Guildford stronger and to attract the best companies and the best people? The Guildford Borough Council 2009 Economic Develop-ment Study states that top of the list for bringing companies to the borough is its rail links, closely fol-lowed by its attractive environment,

7 Guildford Economic Strategy 2013-2031

Why save the Hogs Back? The economic argument

Factors making Guildford Borough Good For Business – from Guild-ford Economic Development Study 2009 (Source data from GBC Business Survey 2008)

“I feel that the proposed erosion of the Surrey Green Belt and the ‘ur-banisation’ of the surrounding villag-es will make Guildford a significantly less-attractive location for businesses (like SSTL) that are reliant on high-ly-skilled staff, who value and seek a quality environment. The Council’s assessment of the demand numbers and scale of development proposed in their plan appears to me to be greatly over-estimated. With the increasing mobility of such businesses, such a major development around Guild-ford might prove to be self-defeating.

“In my opinion the Hogs Back, the lands either side of it and the villages therein, comprise a national treasure that absolutely must not be lost forever.” – Sir Martin Sweet-ing, Group Executive Chairman, Surrey Satellite Technology Ltd (SSTL)

The Economic Development Study points to other threats: the cost of housing and traffic problems. It is unclear how GBCs draft local plan will tackle these effectively either.

House pricesEdge Analytics, which is advis-ing GBC on its SHMA has stated: “Whilst it is evident that Guildford Borough has a particularly acute affordability issue, it is less clear how an upwards adjustment to housing provision would manifest itself as an improvement to the affordability position.”

It is also apparent that house prices in Guildford are driven largely by the borough’s proximity to London

and an outflow of workers seeking better value-for-money homes in attractive locations within the com-muter belt: “Guildford is inextricably linked to the London markets where buyers look to move down the A3 corridor for lifestyle and schools.”9

In the year to 2013, 55,000 people moved out of London to other parts of the South East.10

The message is that we aren’t going to reduce the price of new executive homes - the very prop-erties the University is planning to build. What is needed is a mix of residential types that suit the projected demographic of younger professional people living on their own or as couples. What Guildford needs are flats close to the urban centre in easy reach of workplaces, transport links and leisure facilities. Guildford also needs “affordable” (ie social) housing and it’s easy for developers to integrate these homes and apartments into attractive schemes, which will help regenerate the parts of Guildford most in need.

TrafficA business survey carried out by Guildford Borough Council in 2008 found that the main reasons given for businesses moving out of the borough – aside from the cost of property – were transport and con-gestion. Traffic problems are also cited as a deterrent to businesses 9 - Mark Jamieson, Chairman of Strutt and Parker Central Region, Guildford in Guildford Property Market Update, spring 201410 Evening Standard, June 26, 2014

which ranks higher than proximity to London and higher than its air links. This is supported by the Uni-versity of Surrey:

“Many of the most influential people choose to live among Surrey’s beautiful green hills, so you could be rubbing shoulders with major players right here in the restaurants of Guildford.”8

It is clear that we should build on these strengths (not over them!). Top businessmen are concerned about the risk to Guildford businesses from over development:

8 University of Surrey Website

setting up in Guildford.

Guildford’s draft Local Plan offers no firm infrastructure plans to resolve existing congestion and its proposals to increase housing by 652 units a year, which will equate to about 1,500 cars, will only make the situation worse. Over the next 30 years, we could see another 40,000 cars on Guildford’s roads. This level of population growth, without supporting infrastructure to free up traffic movement, will not boost Guildford’s economy, it will strangle it.

TourismTourism is important in the borough’s economy. It employs 7,400 people (nine per cent of the borough employers)11 and generates more than 200 million for local businesses12. Guildford borough’s attractive countryside, leisure opportunities on the river, and heritage all help to attract visitors. According to Visit England, there are more visitors to the countryside in the South East than to the coast, with more people likely to walk in the countryside (45 per cent) com-pared to the coast (25 per cent)13.

Two factors are key to maintaining and growing the borough’s tourism economy: protecting its landscape heritage from over-development and improving its transport infrastructure. The west 11 What is tourism worth? Visit England12 Tourism South East, 201213 Inbound tourism to Britain Na-tions and Regions, September 2013


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“The proposed erosion of the Surrey green belt and the ‘urbanisation’ of the surrounding villages will make Guildford a significantly less-attractive location for businesses (like SSTL) that are reliant on highly-skilled staff, who value and seek a quality environment”

Sir Martin Sweeting, Group Exec Chairman, SSTL

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side of Guildford has a number of tourist attractions: Watts Gallery, Limnerslease, Loseley House and Greyfriars Vineyard. These will not be enhanced by housing estates and traffic jams.

A better option for Blackwell Farm would be to create a city farm in the historic model farm buildings for school children and the local community. This would help preserve buildings which are being allowed to fall into disrepair and make use of Blackwell House, which has stood empty for more than 18 months. It would also open up Blackwell Farm to the public as promised at the last local plan.

AgricultureWith the UK population expected to reach 71.4m by 2030 from 62.6m in 201214, we clearly need to provide more homes, but we also need to balance this with the need to retain agricultural land to feed our growing population. According to a report by Cambridge University, the UK faces a potential shortfall of two million hectares of land for food by 203015. The report states that new residential and commercial devel-opments, transport infrastructure, and recreational space are making the UK more dependent on imports and worsening our existing food, animal feed and drink trade deficit of £18.6bn.

14 The Best Use of UK Agricultur-al Land, Andrew Montague-Fuller, Cambridge Institute for Sustainability Leadership (CISL)15 Ibid.

“Complacency is a genuine risk to future UK food security. If we want our food production and supply sys-tems to be secure, Government and food producers must plan to meet the impacts of climate change, popula-tion growth and increasing global demand for food.” – Anne McIn-tosh, Chair of Environment, Food and Rural Affairs Committee16.

Every field concreted over will be another field of food to be import-ed and developing high-grade and versatile agricultural land (grades 2-3a), such as that found on the University estate17, is against gov-ernment policy.

The NPPF states that there is a pre-sumption in favour of sustainable development and true sustainable development can only be achieved if it contributes to staple food pro-vision for all. The 105 hectares of arable fields at Blackwell and Manor farms that have been put forward for development in the draft Local Plan would produce enough wheat for 2.4 million loaves of bread – an entire year’s supply (one loaf a week) for a third of the borough’s population.

16 See http://www.parliament.uk/business/committees/com-mittees-a-z/commons-select/environment-food-and-rural-af-fairs-committee/news/food-security-re-port-substantive/17 30% of the proposed development site (excluding the steep slopes of the AONB) is grade 2-3a, the rest of the farmland is grade 3b

Employment land useGuildford is home to a number of knowledge-based companies in the Research Park and in the town, which are closer to transport links and other facilities.

The existing low-density Research Park (owned and operated by the University) provides just 65,000 m2 of office space on 27 hectares of land. There is scope to use this land more efficiently by building addi-tional office space on the surface car parks, and by introducing mixed-use development across the site (so the area can be used for 24 hours a day, rather than just during office hours).

Building at the same plot-ratio as the approved Master Plan for Man-or Park would provide six times the office accommodation on the Research Park than exists at present.

Whilst the University of Surrey will argue it is much cheaper to build further accommodation for employment land-use on Black-well Farm, it would be much less sustainable.

What are we to believe?“The University has no plans for the development of its adjoining land at Blackwell Farm. In partnership with the Borough Coun-cil, the University intends to explore how the woodland and ad-joining land at Blackwell Farm could be opened up to the public for informal recreation and link to existing areas of open space.” Surrey Matters, University of Surrey Magazine, January 1998


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“arable fields at Blackwell Farm ... would produce enough wheat for 2.4 million loaves of bread”

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Why save the Hogs Back? The planning argumentGreen Belt “The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open …” — NPPF 9, 79

The entire land area on Blackwell and Manor farms that GBC has put forward in the local plan is in Green Belt. This area is vast (139 hectares). To put this in context, this is more land than was taken out of Green Belt across the whole of England in the 12 months to March 201218 and the University is pushing to develop a further 126 hectares.

The land fulfils each and every purpose of Green Belt and does so powerfully. The movement of the Green Belt boundary is not justifi-able, because:

i) 64 hectares of adjacent Universi-ty-owned land was removed from Green Belt in 2003 and the NPPF precludes frequent changes to the Green Belt, stating that, when es-tablishing Green Belt boundaries in their Local Plans, “authorities should consider the Green belt boundaries having regard to the intended perma-18 “Green Belt Loosened”, Catherine Early, Planning Resource www.plannin-gresource.co.uk/article/1208363/green-belt-loosened

What are we to believe?“There should be a presumption against frequent changes affecting the approved Green Belt. UniS does not advocate ‘frequent changes’ and fully supports the Borough Council’s proposal in 99U1 to exclude all of the land it requires for its long term expansion.” — Tim Hancock, of Terence O’Rourke plc for the University, 2003

“It is quite clear that the Green Belt is going to have to be reviewed.” —Tim Hancock, Terence O’Rourke, Presentation to Guildford Society, February 18, 2014

What are we to believe?“The provision of on-campus accommodation for over 60% of students is a benefit of very substantial significance. On-campus accommodation is cheaper than renting in the private sector and students are closer to the University’s facilities. Other benefits include a subsequent reduction in housing demand in Guildford, further enhanced by the release of University land at Hazel Farm for general housing provision.” — UniS Manor Park Non Technical Summary (para 19/20), November 2002

“ Not all students wish to live in University accommodation, preferring instead to enjoy different aspects of community life ...” — letter by Greg Melly, Vice President for Enterprise and Growth, UniS, July 25, 2014

nence in the long term so they should be capable of enduring beyond the plan period.” — NPPF 9, 83;

ii) opportunities exist for providing homes and employment land in more appropriate and more sus-tainable sites, which provide better access to town, have less impact on traffic, have less impact on the environment and actively help to regenerate brownfield sites; and

iii) “Paragraph 14 of the NPPF clearly states that, Local Plans should meet objectively assessed needs, unless specific policies in this Framework indicate development should be restricted; these policies include the Green Belt and AONB.”19 GBC has not made any attempt to consider applying such constraints and has not explored in detail any 19 Letter from Nick Boles to Sir Paul Beresford, 18 June, 2014

joined-up approaches to providing employment land across the region, dismissing off-hand such ideas on the basis that “we don’t want Guild-ford to be a dormitory town”.

AONB “Great weight should be given to conserving landscape and scenic beauty in National Parks, the Broads and Areas of Outstand-ing Natural Beauty, which have the highest status of protection in relation to landscape and scenic beauty.” — NPPF 11, 115

The entire land parcel across Blackwell Farm and Manor Farm is beautiful and there are parts with AONB and AGLV designation. The entire land area was put forward as a recommended evaluation area as part of the ongoing AONB bound-ary review, although it is unclear whether this land area has been fully assessed to date.

Every field across the site can be seen from different points along the Hogs Back ridge, from Flexford in


Extent of development on Manor Farm - 1999

Extension of Green Belt on Manor Farm - 2003

Development including H1 and H2 from draft Local Plan - 2014

Extent of University’s proposed development

Going west - encroachment along the Hogs Back

Royal SurreyCounty Hospital

Manor Park

Guildford

Blackwell FarmDeveloper (UniS) proposal

2003 Today

Tomorrow?

Draft Local Plan 2014

Local Plan 2003

Wood Street Village

Village of Compton

Satellite imagery - Google Earth

Save Hogs Back

Yellow area shows the extent of the University of Surrey’s proposed housing development. The area indicated as Manor Farm was removed from Green Belt in 2003 to allow for University expansion

the west to The Mount in the east, and so they form the views out of the AONB. They also form the views into the AONB from Cathe-dral Hill, from the emerging Manor Park Sports Centre, from the train when travelling on the Guildford to Reading line, and from the public footpaths and bridleways which cross the site. It is worth noting that the Government has, in its March 2014 National Planning Practice Guidance on Natural Environment – Landscape, emphasised the im-portance of protecting the setting of AONBs. This affects proposals on land outside an AONB that might adversely affect its setting.

The setting today for the AONB is very beautiful and is largely enjoyed

by the public on foot, bike or on horseback, or from the train. If the planned development goes ahead, then this will be seen by thousands of people in cars entering and leaving the housing estate - but the setting and views of the AONB that they would experience would be in marked contrast to those enjoyed by people today.

Regeneration of brown-field land “Planning policies and decisions should encourage the effective use of land by re-using land that has been previously developed (brownfield land), provided that it is not of high environmental value.” — NPPF 11, 111

If the University is allowed to build on Blackwell Farm, there would be no incentive for it to develop its brownfield land more efficiently and there would be no incentive for it to make better use of more than 17 hectares of farmland, which it has turned into surface-level car parks over the last 50 years.

The World Wildlife Fund’s new Living Planet Centre in Woking was built over existing surface car parks; and St Joseph’s Church in Guildford (completed in 1984) has a car park at its lowest level. These are good examples of what can be achieved.

Unimplemented permis-sionsThe NPPG states that councils should consider the delivery record of developers or landowners, in-cluding a history of unimplemented permissions.

The University has a poor record of delivery. It had outline planning permission for more than 5,000 student and staff residences, but still has 3,395 of these to build. Despite building just 30 out of 300 staff homes on Manor Park and with no intention to build the remainder within the next five years, it is ask-ing to build 300 more on Blackwell Farm.

The “exceptional circumstance” by which Manor Park was taken out of Green Belt in 2003 was to build student residences and to relieve pressure on the local housing sup-ply. Despite the University commit-ment to housing 60% of its full-time students on campus,20 it still only plans to accommodate 42%21.

This figure has fluctuated between 38% and 44% as student numbers have varied.

It would seem appropriate that the local plan policy imposes an abso-lute cap on the number of students living off-campus and a figure of 1,500 students (approx 85%, of the population) would be a good target. 20 University Manor Farm 2003 De-velopment Brief (Section 5.2)21 UniS 2009 to 2019 Estates Plan (section 5.5.2), the University sets an internal target of 42%.

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“139 hectares [at Blackwell Farm] is more land than was taken out of Green Belt across the whole of England in the 12 months to March 2012”


Save Hogs Back

Blackwell and Manor farms provide the only remaining views of the Cathedral where it rises from an entirely rural setting, which should be protected in line with NPPF 12, 126. The ancient woodland visible on the left forms part of the Green Belt boundary and screens the development on Manor Park and the Research Park beyond.

BiodiversitySpecies of Principal Importance “Planning policies should… pro-mote the preservation, restoration and re-creation of priority habitats, ecological networks and the protec-tion and recovery of priority species populations, linked to national and local targets ...” — NPPF 11, 117

At least four Species of Principal Importance for the Purpose of Conserving Biodiversity are present at Blackwell Farm and at least three have been present for at least ten years. These include the yellowhammer, skylark, linnet and lapwing. Building on this site would, therefore, destroy a priority habitat.

The NPPF states that, “the pre-sumption in favour of sustainable development does not apply where development requiring appropriate assessment under the Birds or Hab-itats Directives is being considered, planned or determined” — NPPF 11,119. This applies to Blackwell and Manor farms in respect of the Species of Principal Importance for the Conservation of Biodiversity.

Ecological networks“The planning system should con-tribute to and enhance the natural and local environment by...mini-mising impacts on biodiversity and providing net gains in biodiversity where possible, contributing to the Government’s commitment to halt the overall decline in biodiversity, including by establishing coherent

ecological networks that are more resilient to current and future pres-sures” — NPPF 11, 109

It is now recognised that purely conserving wildlife in designated island reserves isn’t the right way to proceed and that wildlife needs to be protected through an intercon-nected landscape approach. With a falling proportion of Guildford borough in arable production, it is difficult to find a better example than Blackwell Farm for its land-scape and wildlife variety. This makes it a prime candidate site for targeted action for the recovery of priority species, as advocated in the NPPF.

Special Protection Areas (SPA) Blackwell and Manor farms are

within 400m-5km of the Thames Basin Heaths SPA. The Habitats Regulations Assessment notes that a large development at this site has the “potential for increased disturbance” of the SPA and “could contribute to reduced air quality through traffic movements”.

Suitable Alternative Natural Green Space (SANG)The ancient woodland at Man-or Copse/Strawberry Grove and Wildfield Copse is rich in wildlife. Manor Copse, in particular, is home to many rare plant species, includ-ing wild daffodils and pyramid or-chids. Its identification as a SANG is therefore incongruent with the NPPF’s policies on protecting and enhancing the natural environ-ment. The additional recreational

use that would result if the wood-land became a SANG would exert direct pressures on these sites, which are often fragile to human disturbance. It is also at odds with Natural England’s own guidance on selecting SANGS, which states that: “The identification of SANGS should seek to avoid sites of high nature conservation value, which are likely to be damaged by increased visitor numbers.”22

22 Natural England Guidelines for the creation of SANGS Introduction 12-06-08

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Road infrastructureThe road system on the west of Guildford can’t support develop-ment on this scale at Blackwell/Manor farms. Queues are a regu-lar feature at rush hour along the A31 and around the Royal Surrey County Hospital, and adding another 4,000-5,000 cars – which a 2,250-home development would bring – would cause even longer tailbacks and problems on the A3, as well as on arterial routes, such as the Egerton and Aldershot Roads and on the B3000 at Comp-ton and Puttenham.

Congestion in Guildford is caused by traffic movements east to west across the town, which cause tail-backs onto the A3 (and disruption

to movements north to south). The University is arguing that this would be mitigated by a link road between the A31 and Manor Park, but this would only benefit those travelling to, and from, the Research Park/Hospital/University from the west, and even this benefit would be lost once the new road was swamped by vehicles generated by the new estate.

Access at Manor ParkAccording to the current draft local plan, the only guaranteed access/egress for the proposed Blackwell/Manor farms development is via Manor Park, and this would mean another 5,000 cars crossing the Tesco roundabout.

The prospect of more traffic

crossing this busy junction was a concern for the Planning Inspector when giving permission to move back the Green Belt boundary at Manor Farm in 2003. His report stated that the University must “confine the increase in traffic generation from the Manor Farm site to no more than 5%”. However, the traffic figures put forward by the University in 2003, which were accepted by the Inspector (and which showed that the University development would put almost no new traffic demands on the local community) did not include projec-tions for the park and ride.

The University has not demon-strated that this 5% restriction to traffic (also cited in a Section 106 agreement under the 2003 Local Plan), hasn’t been breached. The conclusions of the traffic assess-ment carried out by PBA in June 2013 (accompanying a planning application for a car park at Manor

Park) are not valid as: 1) the traffic assessment was carried out outside peak term time; and 2) the decision has been made to disregard certain journeys from the final figures. If the University can’t demonstrate that a threshold is met now, then what will the situation be like when the University completes the planned development on Manor Park (with thousands of student and staff homes) and a further 3,000 houses, which it plans to build at Blackwell Farm?

Access at Beechcroft DriveBeechcroft Drive, off the A3, is not a junction that could safely sustain additional traffic.

Access at Down PlaceDown Place is a single-track road, which would have to be widened to allow access onto the A31– this would mean carving through AONB land and destroying trees that are centuries old and which

form part of the former Down Place parkland. It would also mean re-placing a weak bridge across the A3 slip road, causing traffic mayhem during construction works. The access point onto the A31 has poor visibility to the west, where the ridge rises.

Any new roundabout and road sys-tem connecting the A31 to Manor Park would take decades to design and deliver. (It took 10 years to complete the road widening at Gill Avenue.) In terms of road access, Blackwell Farm is not a sustainable development site.

DrainageThe Hogs Back acts as a soak-away to allow rainwater to naturally fill underground aquifers. However there are a number of springs flowing from the Hogs Back and the drainage systems are already inadequate with regular flooding already occurring in the area below

Why save the Hogs Back? The infrastructure argument


Save Hogs Back

Manor Farm on the Ashenden Estate and further west at Wood Street Village. These problems will be increased when the land is covered in brick and concrete. Although “suds” or reservoirs can mitigate flooding, these are not always effective and Fairlands has linked drainage problems and flooding to the Research Park’s construction.

RailwayNo economic viability study for a rail halt at Blackwell Farm has been undertaken by Network Rail, although a study was carried out in 1995 for a station further east (clos-er to the Research Park, Hospital and University). At that time the proposal was deemed not viable.

Even in the unlikely event that Network Rail were to approve a scheme, it would be many years before the station was built and operational.

Has GBC assessed whether the Blackwell Farm site has the land area available for the 2,250 houses proposed? Once AONB/AGLV and the buffer zones to the ancient woodland (which URS recom-mends extending) are eliminated, along with land for proposed in-frastructure (roads, suds/reservoirs to prevent flooding, the school, GP surgery, supermarket, station, park-and-ride and other recreational space), the site is unlikely to accom-modate this number of homes.

The University has already indicat-ed that it does not intend to build the target of 45% affordable homes on the site1 and once infrastructure costs (building roads and reservoirs and potentially linking sewerage pipes to Slyfield) have been factored in, then it is likely to argue that it won’t be economically viable to build any.

Given the time frames involved in building the necessary road infra-structure, the site would be unlikely to provide any houses towards the five-year supply.

The question therefore arises: Is it worth the cost to the environment — carving a roundabout and road through the AONB, blighting views from the historic Hogs Back ridge, removing the only remaining rural

1 Discussion between Greg Melly and Beechcroft Drive Resident’s Association, 2014

view of the Cathedral, ruining the western gateway to Guildford and destroying a wealth of wildlife, for a few hundred homes?

Is it worth putting more vehicles on Guildford’s most congested roads and causing traffic mayhem during the building of a new junction on the A31?

Is it worth removing one of Guild-ford’s important economic assets – its landscape – and depriving future generations of their enjoyment of it?

Or does GBC plan to extend the de-velopment further along the Hogs Back in line with the UniS plans and create further harm to our environment and landscape?

The NPPF recommends the pre-selection of sites to make sure that they have the ability to deliver the most sustainable solution. Building over any part of Blackwell Farm would not be the most sustainable solution and the entire site should be removed from the next draft of the Local Plan. Councillors should also firmly reject any proposal to move the Green Belt boundary on the west of Guildford, just 10 years after it was last rolled back.

What are we to believe?“The University has made approach-es to Network Rail [regarding the station]” – Greg Melly, UniS Vice-President for Enterprise and Growth, University Stakeholders Meeting on May 19, 2014

“As far as we are aware, no discussions have been had between Network Rail and the University/Council about a station west of Guildford.” – Hannah Draper, Transparency Advisor, Network Rail, July 11, 2014

Will you get what you are promised? This single track road across

AONB provides the only road ac-cess to Blackwell Farm and would have to be widened to accommo-date 5,000 cars

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“The Hogs Back, the lands either side of it and the villages therein, comprise a national treasure that absolutely must not be lost forever”

Sir Martin Sweeting, Group Exec Chairman, SSTL

“UniS proposals for development to the west of Guildford undermine the nationally important coun-tryside of the Surrey Hills Area of Outstanding Natural Beauty and of Great Landscape Value. They disregard the permanence of the Metropolitan Green Belt and, with it, the rural environment that is such a key element of Guildford’s heritage. They harm the views to and from the Hogs Back, which is one of the best known features of the Surrey countryside, and cherished by residents and visitors alike. They involve the loss of valuable agricultural land and open views to the Cathedral and across unspoilt landscapes to the North.” Tim Harrold, chairman CPRE Surrey Guildford District;

Advisory Board Member of the Surrey Hills Partnership.

“We fully support the Save Hogs Back campaign. The multiple arguments against development of the Manor Farm and Blackwell Farm sites are overwhelming and we have a moral duty to protect the beautiful Hogs Back ridge from development for the benefit of future generations.”

James Henry, Chair Wanborough Parish Council

“Puttenham Parish Council has serious concerns about losing the north slope of the Hogs Back to large-scale development and feels that the spectacular panoramic view should be kept for genera-tions to come. The main B3000 road is at a standstill morning and evening, which causes congestion every day linking the A3 to the A31, and is unable to absorb the massive increase in movement. This would also lead to traffic cutting through the warren roads of Puttenham.”

John Green, Chair Puttenham PC.

“The scale of the proposal is staggering. It has to be seen to be believed. The impact on surrounding villages, as they become part of the urban landscape will be irreversible. It is widely accepted that severe traffic problems exist at the very point where the development is proposed and businesses in Guildford have cited this as being a key factor for moving away from Guildford. The impact on villages, as traffic takes alternative routes, is less well publicised, but is a serious problem now.”

Fiona Curtis, Chair Compton PC.

“Wood Street Village Association completely supports the Save Hogs Back Campaign and joins with it against the proposals to develop housing on Blackwell Farm and Manor Farm. This land is both AONB and land joining AONB, and is protected by the Metropolitan Green Belt, it is meeting all the purposes of those titles.” Neville Bryan, Chair Wood Street Village Association

“Worplesdon Parish Council strenuously objects to the proposal by the University of Surrey to develop Blackwell Farm, which would have a devastating impact on the Area of Outstanding Natural Beauty (AONB) from an aesthetic and environmental perspective. The loss of: working farmland, en-dangered species, ancient woodland, ancient chalk trackways, a Scheduled Ancient Monument, the Green Belt and panoramic views of the town, together with an increased risk of flooding in Wood Street Village and Fairlands, increased traffic congestion and loss of a vital wildlife corridor should not be allowed under any circumstances.” Worplesdon Parish Council

www.savehogsback.co.uk

Why save the Hogs Back?“Close proximity to green countryside of outstanding beauty and the open character of the villag-es around Guildford are unique and one of the major attractions for staff to the ‘high technology’ businesses in the area ... The Hogs Back, the lands either side of it and the villages therein, comprise a national treasure that absolutely must not be lost forever.”

Sir Martin Sweeting, Group Executive Chairman, Surrey Satellite Technology Ltd

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