Guildford Borough Local Plan: Issues and Options Consultation Response by Guildford Residents’ Associations

Guildford Residents’ Associations comprises 29 Residents Associations (24 with c2,800 membership households, 5 with c2,800 households) and 4 Parish Councils (with over 2,800 households). For more information see the Guildford Residents’ Associations (GRA) website at: http://www.guildfordresidents.co.uk

We each have our local special interests. We all share common aspirations and have come together to speak with one voice.

Abbotswood RA Central Crescent, Abbotswood RA Ltd, Beechcroft Drive RA, Burpham Community Association, Bicknell Close RA, Burrows Cross Area RA, Chantry View RA, Clandon Society, Cranley Road Area RA, Downsedge RA, Fairlands Community Association, Ganghill RA, Holy Trinity Amenity Group, Jacob’s Well RA, Joseph’s Road Stoke RA, Merrow RA, Normandy Action Group, Ockham & Hatchford RA, Onslow Village RA, Perry Hill RA, Ripley Society, Rookwood Court RA, Shalford Conservation Society, St. Catherine's Village Association, Tyting Society, Westborough Broadacres & District RA, Weyfield RA, Weymount Neighbourhood Group, Wood Street Village Association. Also supported by Compton, Clandon, Ripley and Worplesdon Parish Councils.

Our vision is for all residents to enjoy a good quality of life in a healthy, enriching environment within caring communities. Achieving this requires Guildford to o cherish its market town legacy, garden suburbs and downland setting, and o encourage innovative, balanced and sustainable development of its high added value economy, building on Guildford’s current strengths and correcting its weaknesses.

We came together to agree our Aspirations for Guildford (see answer to Question 41). We distilled these into the following five Priorities for the Local Plan:

Economy: To provide jobs for our children and support the economy…nurture a robust mix of knowledge-based, high technology and creative enterprises with strong links to the University and Research Park. Avoid over expansion of retail space given technology-driven change.

Distinctiveness and Character: To shape change for the better…assess all development to ensure it:  respects and enhances the valued historic and green character, setting, roofscape and views,  contributes to creating distinctive, cohesive communities, and  makes wise use of land.

Countryside and Open Space: To underpin our economy and quality of life…cherish our attractive countryside and river corridor, gardens, natural open spaces, “green edges” and “green approaches”. These will become more important as the town grows. New, natural, open spaces will be required.

Housing: To provide homes to meet the needs of Guildford…taking account of travel patterns, capacity and the influence of London, agree a judicious balance of planned sites such as Slyfield, town centre redevelopment, investment for communities such as Park Barn, sensitive use of sites within garden suburbs and villages and carefully planned settlement extensions. Adequate provision should be made on campus for student housing.

Traffic and Parking: To deliver essential infrastructure…make growth conditional on phased investment in:

 a new bridge across the railway/river,  a central bus interchange that provides full connectivity to all sides of Guildford to unify the town,  sensitively designed spaces for residents to park their cars  improved connections to the A3 to take traffic away from the town centre,  a strategy for taking through traffic out of the town, including an A3 tunnel, and  a transport network that makes cars unnecessary for getting into and about Guildford, including from airports. Work to five year delivery phases for major projects. Ensure consents are in place in readiness to bid for any capital

infrastructure investment funding made available to boost the economy. 1

In this response: GRA response = black text Selected extracts from consultation = coloured text

Issue: Understanding the Borough of Guildford

This section provides a snapshot of the area: • where Guildford borough is, its people, its places and the routes that connect them • what is good about the area that we may need or want to protect, enhance or promote • the problems that could worsen if left unchecked and things that might get in the way of dealing with these.

GRA Response: The snap shot does not adequately capture the distinguishing features that differentiate Guildford from elsewhere. We need an improved draft that will enable an inspector assessing our draft plan to be aware of what we value and that will support us all in developing appropriate policies.

In particular, we need to convey:  the positive consequences and challenges of being a gap town  the valued features that give distinctive character to our towns and villages and also support our economy  the very notable extent of inward and outward commuting – about half of working residents commute out, and about half of the workforce commutes in.

This is not about describing constraints to be resistant to change. It is about conveying the extent to which we will need to be highly innovative in the way we use scarce land. It is also about establishing that we cannot do it all and will need to make informed choices as to priorities.

Our residents’ assessment of the borough, from our Aspirations for Guildford document, is set out on page 4. We have highlighted the aspects of our borough we consider that the consultation’s assessment of strengths and weaknesses in Appendix B fails to describe adequately. We make the following additional comments on the draft assessment of Guildford:

We have a large and growing population, estimated to reach 152,426 by 2030 (CLG projections, 2010) We don’t have enough affordable homes - taking into account past under supply of 829 homes, there is an estimated annual need of 1194 affordable homes (SHMA, 2009) Housing supply is not meeting the local economy’s needs or demand for people (staff). The annual average need for affordable homes in Guildford borough 2009-2031 is 1066 (SHMA, 2009). The population and housing figures suggest certainty that is unwarranted when you look at the questions regarding their reliability in the evidence (How Many New Homes?). Housing need should be considered alongside provision of sustainable transport. More affordable and less expensive commuting for those who do not live in Guildford could be as important as provision of new homes.

We need more family homes in the area to help to retain families and to keep to a minimum commuting into the borough. This is something you’ve told us you need (SHMA 2009) The need for new homes to meet the needs of Guildford is not questioned but the suggestion these are needed to reduce commuting strays into policy without presenting a full picture. It takes 2

no account of the very large numbers who live in Guildford and commute out to work. When about 46% of the resident workforce commutes out and about 48% of Guildford’s workforce commutes in, promoting sustainable transport may emerge as a more appropriate strategy than an unattainable objective of keeping commuting to a minimum. It cannot be assumed building new homes will change this mix.

There is limited public sector funding available to plan and deliver transport infrastructure and improvements More significant than the lack of public sector funding has been a collective failure to tackle infrastructure challenges, work up schemes and get them “spade ready”. Only now is this starting to change. Given the contribution of Guildford to the national economy, we should be promoting a phased programme of infrastructure investment. We could have been ready with more ambitious schemes for the first tranche of Local Enterprise Partnership funding or applied for national infrastructure project funding.

The borough has no up to date Local Plan to plan for the number and location of new homes, jobs and other development Just as significant, and worthy of separate mention, is the absence of an approved Infrastructure Delivery Plan to support the Local Plan. Due to important changes in how contributions are secured, it will be much more difficult to secure contributions towards infrastructure between April 2015 and when we have not only a Local Plan but also a Delivery Plan and approved charging schedule in place. (See comments on Question 16.)

We have unique and important natural and man-made environments including natural habitats of European importance and nationally recognised landscapes (Like the Surrey Hills) and listed buildings The environment section omits:  The vibrant and distinctive historic High Street, that includes mainstream retailers not only boutiques, which relies on a collective commitment to sensitive planning to retain its character.

 The benefits to the economy and to well-being of the Surrey Hills Area of Outstanding Natural Beauty. It is both visible and within easy walking distance from the town centre.

 The River Wey, that runs through the heart of the town and merits a mention, yet is so often ignored. Much more should be made of this asset and access opened up.

 The importance of views and roofscapes.

 The soft, green edges along approach roads and around the edge of settlements that are a valued, distinctive feature of Guildford. This is currently supported by a “greening our approaches” policy.

 The attractive transitions and clean distinctions between town centre and suburb, and between suburb and countryside that are a notable feature. Guildford has largely avoided ribbons of high density redevelopment spreading along roads from the centre into surrounding residential areas, has remarkably little degraded countryside edge and few instances of high density suburban development that abut harshly against the countryside. This has important implications for the boundary of potential new developments such as at Slyfield.

Our important natural and man-made environments limit the opportunities for where we can plan for sustainable development in the future, increasing development pressures on local biodiversity and geodiversity They also create opportunities, underpin our economic success and contribute to well being.

Some places in our area are liable to flood, including some open land near to the Guildford, Ash/Tongham urban areas. There is potential for greater flood risk to people and property as a result of lots of small scale developments taking place 3

Unlike many places of comparable size, Guildford still benefits from water meadows that serve as functioning floodplain thereby avoiding worse flooding within built up areas than would otherwise be expected. There are also fewer developments that severely obstruct the floodplain than in towns such as Oxford. The value of a relatively unobstructed floodplain should continue to be borne in mind when decisions are taken on the location and design of any future development.

Extract from Residents’ Associations’ agreed Aspirations for Guildford:

Geography:

It must be recognised that there are natural limits to the growth that Guildford can accommodate. It is a gap town nestled in the Surrey Hills Area of Outstanding Natural Beauty with a narrow floodplain created by the Wey. Restricted roads converge in the town centre to cross the Downs. It is encircled by Metropolitan Green Belt. Also, it must be acknowledged that demand for homes in Guildford from families migrating out from London and elsewhere is unlikely ever to be met. All this represents a real challenge for Guildford.

Guildford benefits from its:

o Resource of enterprising residents with a strong commitment and sense of belonging to Guildford

o High tech and high added value economy and research park o University with strategic plans to expand medical and veterinary areas and develop distance learning o Foundation Trust hospital o Tourist potential and access to airports and London o Location in the Surrey Hills AONB with magnificent views and unspoiled countryside within walking distance of the town centre o Residential character of pleasant suburban and conservation areas o Scenic historic High Street with alleyways, views and the river providing a unique shopping experience o Variety of open spaces with individual character and green approaches into town o Good schools, sports, arts and leisure facilities, cathedral and historic buildings

In recent years Guildford has not developed as hoped: o Traffic congestion is a problem for businesses and residents. o The gyratory prevents best use of the river frontage and hampers links between the railway and shops. o Development has turned its back on the river and blocked pedestrian access along the riverside. o The A3 and railway divide the town hindering access to the university, research park and hospital. o Development at Slyfield is impeded by road capacity. o The A3 causes noise pollution from Burpham to Onslow and beyond, including Compton. o Ad hoc development fails to consider cumulative impact or contribute adequately to already strained infrastructure, a problem fuelled by a piecemeal approach to the sale of publicly owned assets. o Overdevelopment of sites, unrealistic attempts to design out rather than manage the car, loss of green features and over-reliance on retail expansion have undermined confidence within the community. o Poorly designed buildings increasingly dominate, eroding the sense of place. o Ribbon development and brash buildings are diminishing the character of the approaches. o Our streets deter walking and, in particular, cycling.

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Issue: Do we have the evidence we need?

Appendix C:  Affordable Housing Viability Study and updates (2008, 2009 and 2011)  Annual Monitoring Report 2012/13 (2013)  Employment Land Assessment (2013)  Equalities Impact Assessment screening (2013)  Flood Risk Reduction Measures guidance (2010)  Green Belt and Countryside Study (2009-13) (further volume commissioned)  Guildford Town Centre Development Study (2010)  Guildford Borough Preliminary Growth Scenarios Transport Assessment Report (August 2013)  Guildford Town Centre Sustainable Energy Study (2007)  Housing Needs Assessment (2013)  Habitat Regulations Assessment (HRA) Screening (2013)  How many new homes? (2013)  Infrastructure Baseline (2013)  Initial Sustainability Appraisal (2013)  Landscape Character Assessment (2007)  Local Housing Needs Surveys - Albury,Normandy,Pirbright,Ripley,Shackleford,Send,Shalford,Shere,Worplesdon  PPG17 Open space, sport and recreation audit (2006)  Retail and Leisure Needs Study (2011)  Settlement Hierarchy and Profiles (2013)  Sites of Nature Conservation Importance (SNCIs)  Strategic Housing Land Availability Assessment (SHLAA) (2013)  Strategic Housing Market Assessment (SHMA) (2009, 2010 update) (update commissioned)  Strategic Flood Risk Assessment SFRA (2009)  Sustainability Appraisal Scoping Report (2013)  Thames Basin Heaths Special Protection Area Avoidance Strategy 2009-2014 (2010)  Town centre vitality and viability report  Traveller Accommodation Assessment (2012)

GRA Response:

Our response to Questions 2 is at the end of our response.

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Issue: How do we want the Borough to develop?

Economic objectives:  Recognise and support innovation and our contribution as a world leader in higher education, health, high technology and knowledge- based industries  Provide excellent broadband communications as standard in all new developments  Provide for and support economic growth in environmentally sustainable and accessible locations  Support and expand the diversity of our business base  Support and expand the economic vitality of our rural areas  Keep and enhance the vitality and viability of our town, district and local shopping centres, with Guildford remaining a quality town with a vibrant, cosmopolitan town centre

Environmental objectives:  Require new developments to be of the highest quality design, have a positive relationship with their surroundings and contribute towards making environmentally sustainable places  Where appropriate require new developments to take account of the historic environment so that they contribute to protecting and enhancing our heritage  Protect, maintain and enhance our valued landscapes, green spaces and habitats within and around our urban areas and villages, particularly where of European or national significance  Enhance the connectivity of our urban areas, open spaces and wildlife habitats  Require high levels of sustainable construction including incorporating energy efficiency measures  Minimise local carbon emissions, maintain good air quality and promote sustainable management of our waste

Society objectives:  Provide a choice of homes to meet the identified needs of our communities and to support long term economic growth  Support communities in developing their neighbourhood plans  Maximise the efficient use of our existing infrastructure and secure extra infrastructure that we need to support new development  Provide a vibrant culture with theatres, venues and restaurants, with a choice of leisure, cultural and sporting facilities for everyone  Support Guildford’s role as a thriving student town Support cohesive neighbourhoods, encourage social enterprise and volunteering, and maintain viable community facilities  Help to reduce relative disparities in health and education attainment  Achieve a transport system balanced in favour of sustainable transport modes to give people a real choice about how they travel and which restrains the growth of vehicular traffic and congestion whilst supporting the improvement of walking and cycling facilities  Provide good access to open spaces and the countryside from our urban areas and villages

GRA Response:

Economic objectives:

Change to - Provide for and support balanced and sustainable economic growth in environmentally appropriate and accessible locations.

Add - Support and expand the diversity of our business base recognising, and planning positively to manage, the limitations to geographical enlargement of the town.

Change to – Keep and enhance the vitality and viability of our town, district and local shopping centres, with Guildford remaining a quality town with a vibrant, distinctive town centre. Add - Ensure retail and office buildings are designed to be flexible to cope with fast- changing needs and avoid over expansion of floor space given changing work practices and

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electronic shopping.

Add – Favour use of scarce land resources to support a balanced and sustainable Guildford economy rather than to provide dormitory housing for London.

Add – Support the contribution of Guildford’s green and historic character and beautiful, accessible countryside towards the economic attractiveness of the borough. (“Pleasant surroundings” helped Guildford through the recession)

Environmental objectives:

Add – Require new developments to be of the highest quality design, have a positive relationship with their surroundings and contribute towards local character and making environmentally sustainable places. Add – Protect, maintain and enhance our valued landscapes, green spaces and habitats within and around our urban areas and villages, particularly where of European or national significance or they contribute to the distinctiveness of Guildford

Change – Minimise local carbon emissions, achieve and maintain good air quality and noise pollution levels, promote sustainable management of our waste and water, and increase resilience to flood risk.

Add – Require new residential developments to provide well designed spaces for vehicles to reduce the dominance of parked cars on streets. (This recognises car use, not car ownership, is discouraged.)

Society objectives:

Change to – Provide a suitable mix of homes to meet the identified needs of Guildford supporting balanced and sustainable economic growth. Add – Provide easy and affordable access to the workplace for the significant numbers who work in Guildford and live elsewhere. (This need will not diminish regardless of the number of new homes)

Add – Maximise the efficient use of our existing infrastructure and secure extra infrastructure that we need both to support new development and overcome under provision.

Add – Reduce through traffic by putting the A3 in a tunnel and improving junctions to serve the town.

Add – Improve connectivity within the town by providing a central bus interchange with links in every direction and a new bridge over the railway.

Change to – Enable residents, businesses and students to get the most out of being a University and higher education town.

Add – Support excellence in health and educational provision and help to reduce relative disparities in health and education attainment.

Add – Retain short stay town centre car parks. (To support under-represented convenience retailing)

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Planning for the homes we need

Issues: How many new homes? The right mix and density of homes

Options:  When planning new homes we could set a specific mix and density of homes for the different areas within the borough  We could generally seek lower or similar densities than we do now and so use more land to deliver the development we need  We could seek higher densities and use less land  We could take a more flexible approach and assess each site on a case by case basis having regard to the character of the surrounding area and the sustainability of the location

GRA response: The missing question – how many new homes?

It is not acceptable to propose that the number of new homes in the draft plan will be determined by members after this consultation has closed and without providing any mechanism for the public to engage in the decision making process until the formal Draft Plan consultation. We require a balanced mix of homes to meet Guildford’s needs. The number should take account of local housing need, affordability, capacity and deliverability, the needs of Guildford’s economy, and travel patterns. Making a provision for affordable housing to meet Guildford’s needs is common ground.

Various housing need assessments accompany the consultation. Some are based on future projections of historical population trends. They assume a population growth rate for Guildford above the national average. There are about 630 more births than deaths a year and average household size has increased to 2.42. In recent years, the numbers moving into Guildford from other parts of the country have been almost cancelled out by those moving out from Guildford to other parts of the UK. We are informed that it is largely international net migration that accounts for recent population growth in Guildford, in part due to a fall in international emigration. However, this category is very poorly understood. Growth predictions for net international migration vary by a factor of three between studies and include a big category

called “other”.

With an estimated 35,060 (47.7% of the workforce of 73,489 in 2008) expected to travel into the borough to work, and about 32,072 (45.5% of the working population of 70,490 in 2008) travelling out, sustainable transport is always going to be a critical part of the approach to sustainable planning for Guildford. Even if many new homes are built, travel in and out of Guildford will continue to be a notable feature of the borough. Significant numbers will continue to move to Guildford with a view to commuting out to work. In addition, many who move to Guildford to work in the borough will remain when their place of work changes from Guildford to elsewhere.

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Housing figures being suggested based on the needs of Guildford’s economy assume homes built in the borough will be for local employees. This cannot be assumed. Only affordable housing can be targeted at local need. It is a trait of Guildford that a very significant proportion of market housing will be bought or rented by people who work elsewhere, either initially or over time. You may need to build in the order of 29,000 homes to make a significant impression on the numbers who currently commute into Guildford. This takes no account of future growth. This compares with a current figure of 54,000 households in the borough.

Hence, we suggest an appropriate housing figure should allow for travel to work patterns, and consider opportunities to improve the sustainability of inward commuting and availability of appropriate housing land. In practice, delivery over the last 12 years has been an average of 312 homes a year. We consider there is a very strong evidence based case for saying:  local need should be given priority over providing dormitory housing for those who commute out,  investment in sustainable transport should be a priority, and  housing growth at a level much above 300 homes per year would be unsustainable and harm the character of our constrained gap town. (Woking has an approved minimum target of 292 dwellings a year.)

Growing international demand needs to be better understood. For example, it is unclear how many international migrants are commuting out from Guildford to work elsewhere.

Density: The Council should produce a data base with the density of development in different communities across Guildford, including recent developments, to inform decisions on appropriate density rather than work to target figures such as 40 dwellings per hectare. The Plan should set out a framework of indicative housing density ranges for different areas coupled with a very clear policy that appropriate density, building height and ratio of hard to soft surfaces should be decided on a case by case basis according to the character of the surrounding area. Access to public transport should be taken into account, as one factor among several, when considering appropriate density and parking requirements. However, inappropriately high density that harms character would be unacceptable and unsustainable regardless of whether a location is close to a bus stop or railway station. It is very unlikely that any development above 4 or 5 storeys would be acceptable in any location in Guildford given the importance of the topography and of views into and from the town. Lower densities of 20-30 dwellings per hectare may be appropriate to retain character in some parts of garden suburbs and villages. 30-40 dwellings per hectare will often be an appropriate range, with building height confined to 2 -3 storeys. High density and taller buildings should be avoided around the edge of built areas to continue the approach of soft green edges that are a valued feature of Guildford. Attractive higher density redevelopment to enhance Park Barn and support the needs of the Hospital and Research Park would be preferable to nearby green field development on the Hog’s Back. The use of blanket densities of 30 and 40 dwellings per hectare in evidence documents (eg Green Belt and Countryside Study and Strategic Housing Land Availability Assessment) is inappropriate and should be revised. 9

Issue: Affordable homes

Options:  Reduce the threshold for the provision of affordable homes as part of a development scheme to five homes (gross)  Have no policy threshold, so all new housing developments would contribute  Where on site provision is impractical, we could take a financial contribution instead to allow us to provide affordable homes elsewhere in the borough

GRA response:

Greater clarity is required as to the range of housing needs that will be met by various approaches to affordable housing provision.

The threshold at which affordable housing should be provided should be changed to six homes for a trial period of five years and the effect of this approach assessed. The major contribution from schemes for five homes and fewer would be to contribute to infrastructure and, in particular, transport projects. In villages with fewer than 3,000 inhabitants, the threshold should be three.

A policy of no threshold and a requirement for contributions where on site provision is impractical raises three concerns:  It would require pooled contributions that would not be possible between April 2015 and approval of a Community Infrastructure Levy charging schedule. (See Question 16)  Guildford would need to be confident it could provide appropriate sites and deliver. Experience with collecting funds for Suitable Alternative Natural Greenspace, public open space and play areas, and other Section 106 provision has not been good. The Council opted for other forms of development on land it had earmarked for significant affordable housing provision. eg Civic and Bellerby Theatre sites.  There needs to be realism as to how many contributions are feasible. We will expect developers to contribute to infrastructure, including significant transport investment.

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Options:  Increase the proportion of homes that we require developers to provide as affordable housing to 40 per cent  Keep the proportion of homes we require developers to provide as affordable housing as 35 per cent  In addition to market housing developments we could require developments of other types of housing such as off-campus purpose-built student housing and care homes to provide a proportion of affordable homes

GRA Response:

The proportion of affordable homes should be made 1 in 3. This should be reviewed after five years.

If the threshold at which this proportion of affordable housing is required is lowered, from fifteen to six, and to three in villages with fewer than 3,000 inhabitants, this should increase provision of affordable homes. If the percentage were changed as well, this could put at risk the potential to secure contributions for other needs. Expanding on the answer to Question 5, developers would also be expected to:  contribute towards significant transport and other infrastructure  pay towards Suitable Alternative Natural Greenspace,  provide well designed buildings using quality materials and working to exacting new standards, and  in some cases, to decontaminate land or re-house/buy out existing owners.

We need to ensure investment in quality housing on planned sites in Guildford remains viable and commercially attractive.

The requirement to contribute should apply to homes for the elderly, which rely on key workers, and to off-campus student accommodation.

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Options:  Introduce greater flexibility in the size and location of rural exception sites making sure that rural exception housing schemes relate well in size to the nearest community  Include wording in a policy on rural exception housing relating to the price paid for land for rural exception housing  We could allow for limited market housing to be provided on rural exception sites provided that the overall amount of affordable housing provided is increased

GRA Response:

It is essential that any rural exception schemes relate well not only in terms of their size but also their impact on the landscape, wildlife and the distinctive local character of a village.

Greater clarity is required on the link between the Green Belt and Countryside Study and a rural exception sites policy. There is a risk the identification of ”potential development areas” will force rural exception housing onto less acceptable sites. If the least harmful sites have been identified as “potential development areas”, the likelihood of acquiring these plots more cheaply for affordable housing (on the basis that the land would not otherwise be developed) is diminished. An owner may anticipate development in this, or a subsequent, plan period. Also, if the consultants undertaking the Green Belt and Countryside Study followed their remit correctly, any land outside “potential development area” is likely to be less appropriate for development due to landscape impact or sustainability issues.

If Guildford has an up to date Local Plan with appropriate allocated sites and affordable housing policies, there should be little need for an exception policy in practice. It should instead be possible to meet local, village-based need for affordable housing as part of an integrated approach on small sensitively located, allocated sites. Setting a lower threshold for affordable housing provision in small villages as proposed in answer to questions 6 and 7 should assist in meeting local needs and make the provision of market housing on exception sites unnecessary.

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Issue: Homes for travellers

Options:  Provide pitches/plots within towns and villages where sites are suitable, available and viable  Provide rural exception sites for affordable accommodation for travellers in the Green Belt as an exception to Green Belt policy  Provide sites on land classed as Countryside Beyond the Green Belt  Provide pitches/plots on previously developed land in the countryside (including in the Green Belt)  Where suitable, make permanent the existing temporary planning permissions for pitches/plots  Encourage small scale private pitches in the countryside (including in the Green Belt)  Provide new sites (primarily public pitches) in the countryside (including in Green Belt)  Set a site size threshold and a proportion of traveller pitches/plots for large housing developments

GRA Response:

Government policy is very clear that “Inappropriate development is harmful to the Green Belt and should not be approved, except in very special circumstances. Traveller sites (temporary or permanent) in the Green Belt are inappropriate development.” This has recently been reinforced by the Planning Minister in a letter to Guildford’s MP in which he expresses concern that Inspectors have not always given the Green Belt “sufficient protection that was the policy intent of Ministers”. Guidance is also clear that any boundary review to meet an identified need for a traveller site should be “an exceptional limited alteration” in “exceptional circumstances”, “to meet a specific identified need” and “specifically allocated in the development plan as a traveller site only”.

It is recognised that the borough is required to provide sites “through the plan-making process and not in response to a planning application”. This contrasts with recent local experience of decisions regarding Gypsy, traveller and travelling showpeople pitches being taken by the Planning Inspectorate. Inspectors have acknowledged the damage of such sites to the 'openness' of the surrounding Green Belt but have allowed 'very special circumstances' to prevail

It is noted that Surrey has a high number of public sites compared with other

parts of the country. The 2011 census shows Surrey has the fifth highest ratio of traveller capacity to households in the South East.

In 2010, Guildford had the second highest number of sites in Surrey. According to the 2011 census, it also has the second highest proportion of travellers relative to households compared with other Surrey local authorities.

Within Guildford, sites and pitches in 2010 were concentrated in Worplesdon, Normandy, Ash South and Tongham, and Effingham

The process for identifying need for pitches should be transparent and equitable and take account of the ratio of pitches relative to households across the country and county.

Gypsy, traveller and travelling showpeople sites should be chosen to minimise impact on the landscape, wildlife, the floodplain and the settled community. Sites should be small scale, with a maximum of 10 pitches, again in order to reduce impact, and managed by Guildford Borough

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Council to regulate occupancy and monitor and enforce compliance with planning and impact requirements. The increasing size of mobile homes and vehicles is leading to requests for easy road access by the traveller community and, also, reinforces the need for limits to the number of pitches on each site to counter the increasing impact from larger pitch size.

The Plan should include policies that prevent hard standing created for traveller sites becoming a justification for future permanent housing development.

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Issues: Ageing population and vulnerable members of our community Homes for students, low paid workers and young working people

Options:  Plan for more Lifetime Homes, suitable for disabled residents and capable of being adapted to meet the needs of residents as their life needs change over time  Encourage the development of more retirement homes and specialist homes that help people to live independently, but have facilities or support available when they need them  Encourage the development of retirement communities that comprise of different types of housing and care facilities in a single location  Encourage the development of smaller homes in suitable locations for people who wish to ‘downsize’ from larger properties  Plan for new purpose built student accommodation or flats either on or off relevant campuses  Support appropriately designed new build or building conversions to houses in multiple occupations with the flexibility to meet the housing needs of students, low paid workers or young adults

GRA Response:

Homes for the Elderly:

More homes designed to appeal to older residents are required to release family houses. A range of pleasant options should be made available with a view to enticing older residents out of family homes with gardens far sooner than is currently the case. This market should be much broader than people who “can no longer cope with” their family home.

All options should be at higher density than bungalows. These homes should be of character and where possible provide access to an agreeable aspect or view. Some should provide a shared maintained garden and possibly a raised vegetable patch. Entertainment suites for guests, low maintenance, somewhere to park the car, provision for pets and good social facilities should be considerations.

New residential properties for the elderly and vulnerable should include telemonitoring capability. Provision of faster broadband in Surrey will permit this and make residents less reliant on distances to medical centres.

On Campus Homes for Students:

Residents attach great importance to provision of accommodation for university students on campus wherever possible to free up homes. It is of concern that the university has consent for campus accommodation that has not been built and that is has applied to develop the veterinary school on the site of a proposed accommodation block. Over 2,000 university students are estimated to live in private rented homes within the town. This outdated figure is considered an underestimate and would increase with the opening of a medical, veterinary and business school. This represents a large number of more affordable homes that could potentially be made available to the wider community.

As we make clear in our aspirations, we strongly support fostering greater integration of the town and university to enrich both. However, we do not have the land availability in Guildford to offer up great swathes of our housing stock to students. We note that other further education facilities

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have less land available. However, accommodation provision should be part of any redevelopment plans and not just involve green field sites.

As a very high priority we need:  better data to confirm the number of homes used by university students that could be released for wider use  a strategy for delivering on campus student provision  a robust policy to promote this.

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Planning for the economy and jobs

Issue: Supporting our tourism, arts and cultural facilities

Options:  Develop a cultural strategy that helps to define and promote culture/cultural facilities  Direct development of new facilities including hotels towards those areas where there is a lack of provision  Direct new development towards those areas where most people live  Promote the borough as a destination for eco tourism  Promote the borough as a destination for business tourism including the provision of hotels  Promote the borough as a location for films and develop tourist facilities to support this

GRA Response: This is a weak section in part reflecting the failure to appreciate the positive links between:

 Guildford’s green and historical character,  the rich cultural life of the borough and  the economy. A rethink is required to ensure we develop in ways that protect the qualities that underpin our economic success. With care, the sectors of our economy that rely on the environmental and cultural attributes of our borough can thrive and increase significantly alongside growth in our knowledge based, high technology sectors. At present, we are not poised to achieve this. The tourism and cultural sector of our economy is being treated as “assorted odds and ends” tagged on to the mainstream economy and there is a perception that to expand our mainstream economy we need to overcome constraints and expand. We should treat Guildford’s culture and environment as the foundation of a strategy for the benefit of residents, visitors and the economy. We should consider both what we currently enjoy and what we want for the future. If we can get this right, we will:  sustain the well being of the community,  build a strong visitor economy,  and also support our high technology, knowledge based economy.

It is very enlightening to talk to dynamic post doctoral academics on the cusp of moving into business to exploit the commercial potential of their ideas. The environmental character and cultural richness of a place forms a critical part of their decision on where to locate.

We should make much more of the opportunities provided by:

 the River Wey that runs through the town and opens out into attractive water meadows – neglected

 the Surrey Hills Area of Outstanding Natural Beauty, landscape status equivalent to a National Park – disregarded and threatened

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 the distinctive character of our communities, countryside and open spaces – threatened

 the integration and use of our historical buildings as part of the fabric of the borough – threatened

 the diverse range of cultural and sporting venues - GLive welcome (especially upper High Street location), Academy of Contemporary Music welcome (especially use of town centre buildings), cinema area neglected, theatres welcome, many small character facilities threatened (especially by redevelopment for housing), various sporting facilities welcome (Spectrum needs investment) An integrated strategy for “Guildford’s culture and environment: heritage and aspirations” should be developed. A joined up approach would help sustain the visitor economy (including eco, heritage, entertainment, retail, social, rural, sport and business tourism), ensure we develop in a way that protects our critical assets and also support niche markets such as the film industry.

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Issues: Supply and location of offices and industrial buildings Lack of suitable office and industrial buildings Supporting our rural economy

Options:  Plan to provide enough employment land only to meet the expected employment needs of existing and new residents  Plan to provide enough employment land to meet the expected employment needs of existing and new residents and commuters  Plan to provide extra employment land to meet the expected demand from a growth in business activity  Plan to provide for additional employment land as a priority, to pursue high levels of growth  Plan to protect our strategic employment sites as defined in the Employment Land Assessment  Plan to redevelop and intensify the use of existing sites  Plan new employment throughout the borough  Plan new sites in rural areas that re-use rural buildings for employment use  Meet the need for higher quality flexible space by planning for the refurbishment of existing office and industrial floor space  Meet the need for higher quality flexible space and larger units through expanding existing business parks to provide new, high quality offices and industrial space  Meet the need for higher quality flexible space and larger units by planning to provide new, high quality offices and industrial space as part of any urban extension  Meet the need for head quarter office buildings of substantial size and high quality  Meet the need for higher quality space and larger units by creating new high quality industrial and office space outside of the urban areas, potentially opening a new business park in the countryside  Support economic growth in rural areas  Balance protecting agricultural land and supporting economic growth  Encourage tourism related development in the rural areas to support the rural economy

GRA Response: Guildford should promote balanced and sustainable economic development and businesses should contribute to the “attractive surroundings” that play a critical part in our economic success.

We should plan for the economic opportunities of the future, taking full account of significant changes brought about by e-commerce, creative industries, new technology, medical advances and home working. It is important to recognise significant changes in the nature of retailing, the qualities that attract high technology, medical and creative businesses and the shift to use of virtual links for business.

We should invest in our knowledge based, high technology economy. This will provide well paid, creative jobs and generate the money needed for investment in Guildford.

We need to distinguish between wanting to increase the added value of the economy and physical expansion, especially given the scarcity of land in Guildford. Guildford is not the place for space hungry businesses.

We should target high added value small and medium sized enterprises rather than the headquarters of larger corporations.

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The needs of Guildford’s economy should be an important consideration when we plan for new homes. However, in view of constraints on capacity in a gap town and the phenomenal level of commuting, we need to “decouple” economic growth and housing. Limited space for housing in the borough means investment in easy, affordable and more sustainable transport for those who travel into Guildford to work is a very high priority. This will be more sustainable than building homes on the scale required to have even a marginal impact on reducing journeys.

It is not commuting but congestion and the lack of appropriate public transport options that are the main problems for local employers. Commuting could be turned into a critical part of the solution in a constrained gap town. The priority for sustainable development should be to invest in infrastructure to provide environmentally acceptable and affordable ways for people to travel in and out of Guildford to work - see answer to Questions 14 and 15. This should be funded through the value added to the economy, including contributions to business rates.

By far the biggest category of inward commuters

is people from Waverley (7824).

Given the price of homes in Waverly, a significant part of this group is likely to be people choosing a more rural lifestyle rather than people who are priced out of Guildford.

More commute to than from Rushmoor.

We note that according to the Office for National Statistics, the current employment rate for the borough is less than 69%, down from an average of 73.2% in 2012, which in turn was down from 80.1% in 2011. Traditionally Guildford has had a higher employment rate than both the South East and England as a whole. According to current statistics this is no longer the case. The current employment rate for the South East is stable at about 74% and England at 71%. Across England the employment rate is slowly increasing and for this ratio to be falling in Guildford borough is of concern and should be understood. It reinforces the importance of using up to date data to inform the plan and the need to include a risk analysis and acknowledge uncertainty.

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We caution against over expansion of retail floor space and question the wisdom of the proposed massive increase in area, notwithstanding a current trend for retailers to concentrate on a smaller number of large retail centres. We should diversify use of the town centre.

Far more rigorous analysis of the future contribution of the retail sector to Guildford’s economy is required for several reasons:

 Before decisions are taken on significant retail expansion within a North Street redevelopment, the

likely effect on the Upper High Street, Tunsgate, the Debenhams site and the High Street itself should be better understood.

 Premises no longer required for retail use could be an important potential source of business and residential sites. The Employment Land Assessment should consider this. We note that in the base report (Working Futures) which informs the Employment Land Assessment, all scenarios predict an increase in retail employment in Guildford Borough by 2031 of about 1,150. This is an increase of 11% above the employment level in 2006. We question the validity of this assumption. For example, in its 2013 report, the Centre for Retail Research forecasts that 11% of retail outlets in the South East will close by 2018. Their forecast is that retail will continue to decline beyond 2018. As a rough indication, if 11% of retail outlets close in the borough by 2018, this could release in the order of 2.6 ha of floor space (assuming average unit size) for other uses or redevelopment.

 A forecast increase in internet shopping is used to predict additional employment from warehousing and distribution facilities locating in the borough. The likelihood of provision of warehousing and distribution centres in the borough is debateable. Warehousing and distribution for internet shopping is a low margin business. Given the scale of distribution networks, how likely is it that this type of

operation will choose to locate in a high cost environment where land is at a premium and with serious traffic congestion?

We should pursue an imaginative approach to how the town centre, Research Park/ University/ Hospital area, Slyfield and other business sites can be enhanced to support and attract innovation and enterprise. There should be more integration between these areas, including bringing business meetings into the town centre and creating space for innovative problem solving projects on Slyfield (eg for future equivalents of the team that cracked the problem of how to clean up oil spills using self propelled craft by coming together in a building made available). Transport links should support integration. It would be undesirable for business parks to become divorced from the town centre and only accessed via the A3.

The spaces we create for innovative enterprises should be attractive, respect our green and historical assets, provide underground parking wherever possible and, more generally, make greater provision for their traffic and parking impact.

We should retain small scattered business estates hidden within communities. We should protect space within communities for small businesses such as printers. There is a limit to how many business units should be converted to residential and the business relocated to Slyfield. We need sufficient space on Slyfield for housing if this to become a diverse and integrated part of the town.

There needs to be far greater understanding of the significant proportion of employment that is in rural areas. There is potential for technology to make this an ever more sustainable option and the growth in home working reduces the need for businesses premises. However, there are concerns that businesses unrelated to the land are using adapted farm buildings because of more relaxed planning, and that the countryside will become urbanised. Small, sensitively-located sites for appropriate rural businesses are required. In the Area of Outstanding Natural Beauty, the statutory purposes of conserving and enhancing the landscape and scenic beauty should prevail and shape the economy. 21

An area that merits attention is the land along the river corridor of Walnut Tree Close and Woodbridge Meadows. It lacks identity. It includes business estates that are attracting some retail development of a kind that could draw trade from the town centre, a trend that should be resisted. Consents have been given for large office redevelopments and also for high density, high rise housing. Parts of the area are at significant flood risk not just from the Wey overtopping but also due to rapid surface water runoff. A comprehensive supplementary planning document is needed for this whole area. The National Planning Policy Framework would favour business over residential use in vulnerable parts of this area (sequential test). Whatever the appropriate mix of homes and businesses, the area should be greatly enhanced to provide:  a strong sense of identity that makes much more of the Wey Navigation  continuous riverside access  sustainable drainage and channels rather than raised riverside car parks that add to flood risk and detract from amenity  a building line set back from the waterside and  a limit of 4 to 5 storeys at most, fewer by existing homes and the river.

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Issue: Supporting our local centres, district centres, and Guildford town centre

Option:  To produce a Town Centre Supplementary Planning Document following adoption of the Local Plan

GRA Response:

Guildford is in a vulnerable position with the prospect of significant town centre change and redevelopment taking place with neither an up to date plan nor an up to date planning brief in place. We are dismayed that this Local Plan Issues and Options consultation is not being used as an opportunity to consider critical issues that need to be addressed urgently to provide a coherent publicly supported strategic plan for the town centre. Hence we are using this consultation to set out some of our key aspirations. We also suggest we cannot wait until adoption of the Local Plan to produce a new Town Centre Supplementary Planning Document. We propose that a draft should be produced in parallel with the Local Plan consultation even if for legal reasons it cannot be adopted until later.

The absence of a town centre plan also hampers effort to identify how many homes should be planned for the town centre. It is not possible to determine whether we need to develop in Green Belt countryside without a better understanding of options for planning a significant increase in the number of homes in our town. This is a critical issue.

A Town Centre Plan

Residents do not want Guildford to become just like any other town. Our scenic, historic High Street, with alleyways, views onto Area of Outstanding Natural Beauty and potential river setting, provides a unique shopping experience. That distinctiveness has great commercial value. The High Street remains vibrant in part because enormous effort goes to ensuring it adapts to retail needs while retaining character. We must guard equally against loss of character and marginalisation as a boutique area if the major retail focus is moved towards the north side of North Street. Impact on the viability of the High Street should be an important consideration in assessing any proposals for town centre development.

Great care is needed to ensure that North Street is developed in keeping with the character of the High Street rather than as a “could be anywhere” shopping mall. We would like North Street to be enhanced in a way that it too enjoys great views and provides a variety of well designed shop fronts that follow

the rise of the land. The aim should be to create such an attractive mix of outstanding new buildings

with enduring appeal and retained original buildings, that North Street becomes as worthy of protection

in the future as the High Street is today.

It is essential to avoid overexpansion of retail floor space given the rise of electronic shopping, notwithstanding the trend that retailers are reportedly concentrating in a smaller number of larger centres. (See answer to Question 11) We should keep a range of short stay car parks, including some surface car parks, to support convenience shopping and plan innovatively to enable people to collect from shops items ordered electronically. Otherwise pressure for out of centre locations will increasingly draw custom from the High Street.

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We should retain public rights of way along streets in town centre developments creating new quarters rather than “shopping centres”.

We must be realistic about the extent of pedestrianisation that will be appropriate beyond the High Street. We do not support full pedestrianisation of North Street because this would cause unacceptable congestion on York Road and other surrounding residential roads. Perhaps the bottom section of North Street only could be a “shared space” with buses and pedestrians. Roads converge in the centre of the town to get across the gap in the downs and Guildford does not have sufficient road capacity to divert traffic around the centre.

Providing space for a very attractive and central, state of the art bus interchange with connections to all parts of Guildford will be essential to reduce car dependency for journeys to the town centre and to transform attitudes to public transport. We need pick up and drop off points near all key facilities and links to the railway station.

We should consider impact on the roofscape when development is proposed and respect topography by resisting inappropriately tall and bulky buildings. We would welcome more housing in the town centre in mixed developments but this should not be achieved by adding extensive level areas on top of buildings and destroying the stepped character of the area. Views onto the town centre are being destroyed by large buildings with ugly rooflines that ignore Guildford’s gap town setting.

We welcome the proposal for more restaurants and cafes. The area around the cinema has the potential to create a very attractive restaurant quarter around a square opening onto the river, perhaps with a small marina. Appropriate flood water storage and resilience measures should be integrated into the design

More generally, we should integrate the river more fully into the High Street We should retain and open up views to the river at Millbrook. Care needs to be taken to enhance the centre of Guildford in ways that do not just extend the current gyratory congestion outwards into surrounding residential communities.

Major development has also been proposed for the station area of Guildford. A Town Centre Supplementary Plan needs to be in place before any application is prepared. This should provide for:  access to the river,  an attractive pedestrian link to the town centre  excellent bus services and pick up and collection arrangements on both sides of the station  no buildings above four to five storeys  land safeguarded for another road bridge over the railway  provision for a future Heathrow rail link

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Options:  Retain the current hierarchy of town, district and local centres with the exception of upgrading Ripley from a local to a district centre  Redefine Guildford town centre’s boundary to that now shown on Figure B

GRA Response: The consultation considers local centres in villages. These should be sensitive to the character of each village and, where appropriate, AONB purposes.

Within the “Guildford urban area”, we also want to defend the diversity and identity of local centres by encouraging small local shops and a range of appropriate community cultural and leisure facilities. There is a concern that the consultation appears to treat communities outside the town centre as part of a homogeneous urban area. Proposals should draw on evidence in a Guildford Residential Character Areas study. (See answer to Question 2)

The Plan needs to provide a strategy for ensuring local centres are not swamped by large new supermarkets. A framework to guide local application of the “sequential test” in Guildford will be essential. (This is a national policy designed to give priority to town centres rather than large out of town retail centres.)

Appropriate locations for supermarkets should be identified in the Local Plan rather than opportunistically as has happened recently. We anticipate supermarkets being promoted as part of development proposals to assist with funding.

The Plan should also take account of retail areas such as Ladymead and Woodbridge Meadows where retailing of a kind traditionally located around the High Street is emerging. These areas should specialise in the retailing of bulky goods you are likely to need a vehicle to collect.

Town Centre Boundary (Figure B)

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We support a tightly drawn town centre boundary. We should retain the green, residential character of routes connecting the town centre to other business areas. We welcome the clear distinction between the town centre and the residential character of adjoining suburban areas. We also agree with excluding the business park areas to the northern end of Walnut Tree Close.

We ask for South Hill, Warwick's Bench and Castle Hill to be removed from the town centre boundary. These are residential roads with houses of great character and Warwick's Bench serves as an approach road into Guildford. The Residential Design Guide and Landscape Character Assessment would support their removal.

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Planning for access and transport

Issue: Balancing development with traffic and congestion

Options:  Focus new development that will generate significant movement in locations where the need to travel will be minimised and the use of sustainable transport modes can be maximised, including locations which can be made highly accessible by passenger transport (including by park and ride services) and are served by cycle and pedestrian routes  Expect all developments that generate significant amounts of movement to provide a long-term travel plan, identifying the movements the development will generate and how these would be managed to deliver sustainable transport outcomes  Continue to identify and bring forward further park and ride facilities, particularly along the northern and eastern approaches to Guildford town  Require new developments to make use of or contribute financially towards improvements to passenger transport services (including park and ride services) and improved access for cyclists and pedestrians  Set aside more road space on the main approaches into Guildford town centre to improve routes for pedestrians, cyclists and buses

GRA Response:

 Land is scarce in Guildford.  An extremely large number of people commute into and from Guildford for work.  No matter how many homes we build, we will not change that pattern.  Relatively narrow roads converge in the town centre and come together to pass through the downs.  Investment in transport has been inadequate.

Given these factors, transport investment is essential to support existing development and without it new development should not be considered. Indeed, development should be conditional on delivery of an ambitious phased investment strategy. In the words of the Guildford Economic Development Study, “Transport infrastructure underpins economic performance through connectivity – linking business to business and people to employment opportunities””

Given the constraints on land availability, it is unlikely to be possible to choose between locations for development based on minimising travel. It will be more realistic to provide transport options that are as sustainable as possible where land is available. It may be necessary to rule out some locations due to unacceptable congestion, at least until improved transport solutions are in place.

We strongly oppose the approach that proximity to transport trumps other factors when considering new development. Impact on character can be just as important in terms of sustainable development. For example, being close to a bus stop or railway station does not make high density development that harms character acceptable. “Distance from facilities” is used inappropriately, as a surrogate for sustainability, throughout the consultation documents. This, along with the relative neglect of impact on character, could distort decisions on development location and density. (See answer to Question 2)

No further significant town centre development should be allowed that will increase traffic on the gyratory and feeder roads until a transport strategy is in place. The need for that strategy is urgent. We must ensure that any development that occurs before the new plan is adopted, at sites such as Bellerby Theatre, is compatible with transport capacity, does not jeopardise future plans and contributes to transport and parking solutions. 27

We attach great importance to all new business and residential development making contributions to transport infrastructure, at first through individual contributions to packages of work, then as soon as possible using Community Infrastructure Levy. (See our answers to Questions 4, 5, 6, 11 and 16) We would support:  Improved access to Slyfield and a bus service from a park and ride.  the proposal for a new railway station on the existing railway line at Park Barn. This would help serve the local community, where we propose redevelopment to enhance the area, and also the University, Research Park and Hospital. The consultation options make no mention of additional highway capacity even though the evidence points to a need for this. We note that Enterprise M3 included the Guildford gyratory scheme in its provisional list of schemes put forward to the Department for Transport in July 2013 for funding in the period 2015/16 to 2018/19. The estimated cost stated in the application is £3.8m which is expected to come from a grant from Enterprise M3 and also from the ‘Community Infrastructure Levy and Section 106 match funding’.

We would like to the see the following suite of transport investments taken forward in a phased delivery programme that is broken down into a series of five year investment phases:

Projects should be made ready to bid for national money and will need to be packaged into delivery chunks so all developers can pay for their part. A mix of developer contributions, business rate receipts, Enterprise M3 Partnership funding and partner contributions should be used and, where appropriate, a bid made for national infrastructure funding based on value added to the economy.

 A new bridge across the railway/river to unify the town. There are too few links between the north side and High Street side for a town the size of Guildford. Without tackling this capacity issue, congestion on all routes converging in central Guildford will be inevitable.  A state of the art central bus interchange, with full connectivity to all sides of Guildford, to integrate the town and make a car less necessary for getting about. The buses and the interchange

should be very attractively designed to challenge perceptions and reach new markets. Far more imagination needs to go into the timing and routes of journeys to entice more of us out of our cars. Links to railways stations should be provided. (Attitudes to recycling have been transformed in recent years. A comparable shift in attitudes to the use of buses and the services provided is required.)  Provision of improved sustainable transport to reduce reliance on a car for getting to work.

Employers should contribute to a fully integrated bus service with excellent links between railway stations and places of work. More park and ride as part of the mix of provision to support those who travel into Guildford to work. Parking should be underground where appropriate and contributions made by developers and employers.  A Heathrow rail link should be planned and any necessary land safeguarded.  Improved A3 junctions to serve the town. They should be designed with a longer term plan for the A3 in mind and to minimise negative impacts on surrounding areas.  A feasibility study and business case for an A3 tunnel through Guildford, with land safeguarded. If feasible and cost beneficial, this option should be pursued determinedly. A further by pass would have unacceptable consequences. A tunnel would free up land within Guildford and a central part of the old route could provide capacity for local sustainable transport. An early priority for the study would be to establish the most feasible route and land requirements. If a tunnel entrance in Gosden Hill would be a favoured route, the necessary land should be safeguarded. Land would need to be safeguarded for an entry on the north side too and construction sites planned. It is assumed three lane capacity would be necessary.

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We await the report of the GBC commissioned Guildford Town and Approaches Movement Study which includes consideration of A3 options and looks ahead to 2050. We also note that in October GBC’s Corporate Plan included a statement of intent to ‘investigate options for a Guildford A3 tunnel, together with innovative solutions for public transport...., improving our park and ride network and the feasibility of a heliport. Cycle super highways and the expansion of pedestrian access will be considered as a priority for the town centre’. Outcomes by 2016 include a viable long term solution for the A3.

Residents welcome the serious consideration that is being given to an A3 tunnel. We need to plan short term options to tie in with longer term plans, as well as to safeguard sites.

Careful phasing of delivery will be required given the time major infrastructure projects take to deliver and the costs involved. Balancing development with congestion will be a real challenge.

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Issues: Minimising the impact of traffic congestion on our communities Promoting alternative ways of moving around the borough Working with our partners

Options:  Explore opportunities to improve connections within Guildford town centre  Explore the opportunities to improve connections between the town centre and the wider town, including to neighbourhoods and destinations to the north and west of the A3 corridor  Improve our communities’ experience of catching buses into and from Guildford town centre by increasing effi ciency and coordination of services  Improve our communities’ experience of changing between bus and train services in Guildford town centre by increasing effi ciency and coordination and provide new places for people to access rail services  Use opportunities through the design of new developments and the negotiation of planning contributions to improve cycling and walking routes in our urban areas, villages, hamlets and rural areas  Use opportunities through the design of new developments and the negotiation of planning contributions to improve bus and community transport services, in our urban areas, villages, hamlets and rural areas  Continue working with our partners to address transport related issues

GRA Response:

 School buses should be promoted to help alleviate morning peak congestion. In recent years, various school buses have been cut. (Eg Pegasus, Guildford High School)

 Cycle lanes need to be rethought and made much safer. Where possible, wider split pavements should be considered in preference to cycle lanes in the road.

 As part of a strategy to reduce traffic speeds, pollution, congestion and accidents, the 50mph speed limit should be extended along the A3 throughout the entire town and low noise tarmac used on Guildford’s A roads.

 Provision of car parks should not be overlooked. We are very keen to see car parks retained, especially short term surface car parks to support convenience shopping. In October the GBC Executive adopted The Guildford Town Centre Parking Strategic Review which recommended the retention and development of key car parks. Car parks should be considered on a case by case basis depending on location, access, type of use, impact on views, flood risk and ground conditions. Far greater consideration should be given to underground parking.

 We ask for a more sophisticated approach to managing the car which distinguishes between ownership and use. We support discouraging avoidable car use by promoting attractive alternatives but seek a rethink on policies that have left us with streets crammed with parked cars, facilities lacking essential parking and car parks earmarked for redevelopment.

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Planning for infrastructure and services

Issue: Infrastructure and service provision

Option:  Continue to work with infrastructure providers to ensure that they plan for necessary infrastructure, taking into account the proposed amount and locations of development to be planned across the borough within the plan period

GRA Response:

We welcome the proposal to produce a living draft Infrastructure Delivery Plan (IDP) to provide for any essential additional infrastructure required to support development in the draft Local Plan.

Residents have been calling for:  a strategy for delivering infrastructure as an essential prerequisite for future growth.  all developers to contribute towards much needed new infrastructure for Guildford and not just towards short term measures.  long term aspirations to be broken down into more manageable delivery phases in order to prevent larger infrastructure schemes being forever deferred.  a more ambitious and robust approach.

We are concerned that, because Guilford is so far behind with producing a Local Plan and accompanying Infrastructure Delivery Plan, we will miss out on being able to charge developers a Community Infrastructure Levy to contribute towards essential infrastructure. The problem is made more pressing by the fact that, from April 2015, it will no longer be possible to charge developer contributions if more than five contributions have been pooled for that purpose since 2010.

We hope that Guildford will move quickly to:  keep to a minimum the period when GBC can neither pool contributions nor charge Community infrastructure Levy  sub-divide infrastructure works into discrete projects of relevance to each development.  identify any sites that need safeguarding to prevent development that would impede subsequent construction of critical infrastructure (eg road bridge over railway, space for rail link to Heathrow, cross Guildford road link and A3 tunnel entrances and constructions and assembly sites).

Strategic vision is needed to address the factors impeding the sustainable development of Guildford’s high added value economy and safeguard the quality of life for residents. Guildford needs to tackle the significant challenges it faces rather than allow ever more piecemeal development without adequate assessment of cumulative impact or contributions to necessary investment. Guildford is one of the most competitive non-metropolitan centres in the UK. It contributed a gross value added of £3,830 million to the economy in 2007. If success is to be sustained, Guildford merits a greater share of national infrastructure investment.

We also need to a far more forward looking approach to water supply, sewerage provision, landfill remediation and flood risk management. We deny ourselves win-win opportunities by failing to bring forward investments, such as at Slyfield.

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Planning for the environment

Issue: Green open spaces and habitats

Options:  Ensure that all development proposals identify positive measures to protect and improve biodiversity  Enhance the value and biodiversity of waterways  Expect new development to provide additional open space or to improve existing spaces, or an equivalent financial contribution to include provision for ongoing maintenance  Expect new development to contribute to the borough’s network of green open spaces and links between these  Take a flexible approach to the loss of open space that is assessed as poor quality, where there is a surplus of open space  Require developers of large developments to provide their own Suitable Alternative Natural Green space (SANG)  Continue to work to deliver the expanded and new SANG sites set out in the Council’s Thames Basin Heaths SPA Strategy  Identify further new SANG in suitable locations

GRA Response: We must preserve our attractive, accessible countryside, gardens, allotments and natural open spaces. The green character of the edges of Guildford, and of its approach roads, should be retained. We should make the green corridor along the river much more of a feature and protect views throughout the borough. New developments should contribute to creating distinctive places and a sense of community, not “could be anywhere” estates. They should provide well designed spaces for vehicles to reduce the dominance of parked cars on streets. As we state in our Aspirations document supported by 35 organisations:

Protect & enhance our countryside & open spaces within the town

Residents attach great importance to an attractive patchwork of green open spaces within local communities and to the natural beauty of the countryside that envelops the town.

This means:

o Stopping the incursion of urban features and out of character development in the countryside and protecting the Green Belt and countryside edge. o Enhancing the wildlife value and unique landscape qualities of the countryside around, and open spaces within, the town. o Providing outdoor locations where families can enjoy recreational activity in peaceful surroundings. o Making the river much more of a focus as a wildlife corridor, for recreation and as a feature of the town centre with pedestrian access along each bank. o Ensuring Council owned farms retain their rural character in perpetuity and are managed to enhance their landscape, wildlife and amenity value and to prevent harmful development around the edges of the town.

Actions:

1. Protect the designated countryside around Guildford, in particular the Green Belt and Surrey Hills Area of Outstanding Natural Beauty (AONB), and support the Area of Great Landscape Value becoming AONB.

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2. Protect green Public Open Spaces and their individual characters in the Local Plan. Resist turning natural, unspoilt countryside, such as Chantry Wood and Tyting Farm, into urban parks in the name of attracting visitors away from the vulnerable Thames Basin heathland wildlife areas.

3. Ensure any ‘Suitable Alternative Natural Greenspaces’ provide genuinely new opportunities for informal recreation in newly created areas of high potential wildlife value rather than simply a rebranding of areas already enjoyed by residents for their natural beauty.

4. Ensure the amenity value and distinctive character of open land owned by GBC is fully recognised and enhanced by appropriate management. Protect such land against harmful development (eg Stoke Park), noise pollution (eg Riverside) and insensitive management (eg flailing of trees and shrubs on the ancient trackway of Green Lane or the addition of urbanising clutter on the Chantries, Pewley Down and Tyting Farm). Review the management of each site to avoid further inappropriate interventions.

5. Secure the future of the valued qualities of Council owned farms, including Burpham Court and Tyting Farms, for the benefit of the community in perpetuity and ensure their management is resilient to anticipated changes in stewardship payments.

6. Retain current allotment sites for community benefit.

7. Designate adequate green space, allotments and public footpaths in new developments so they provide public benefit in perpetuity and are not lost within the curtilage of properties over time or developed.

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The analysis of Green Belt in paragraph 6.5 of the consultation is wholly inadequate as a basis for review of Metropolitan Green Belt around Guildford. The consultation text does not set the scene reflecting the policy that “Green Belt boundaries should only be altered in exceptional circumstances”. A far more strategic assessment is required, especially given the recent letter from the Planning Minister that “unmet need alone“ is unlikely to justify housing development in Green Belt. A case for exceptional circumstances has not been made in the documentation and evidence. We await the results of the forthcoming Strategic Housing Market Assessment. The absence of a strategic vision for key potential redevelopment areas makes it harder to establish the scope for meeting the needs of the borough by redevelopment of a range of town centre and other critical sites.

Across the Surrey Hills AONB, from Chalk Pit Lane towards Bookham and London (Roland McKinney)

Little consideration appears to be given to the Surrey Hills Area of Outstanding Natural Beauty and its importance in shaping decisions on the location of development. Countryside and villages in the Area of Outstanding Natural Beauty should be given the highest status of landscape protection in line with legislation. There should be no major development in the AONB. (There is no exceptional public interest that would justify overriding this.) Indeed, there should be no development in the AONB unless this serves the purpose of designation, associated statutory duties and is consistent with conserving and enhancing natural beauty. The importance of protecting views into and out from the AONB should also be considered, a principle dating back to the 1947 Hobhouse Report.

It would seem logical for AONB candidate areas, identified in the 2007 Review of the Area of Great Landscape Value and more recent Landscape Character Assessment, to be given a high level of protection from development. 34

Issue: Built environment

Options:  Identify locations in the borough which have strong local distinctiveness and require new developments to conform to that local style, whilst allowing more innovative design in all other areas  Identify opportunities to improve connections within and beyond the town centre, including links to the River Wey, the University of Surrey and railway station  Plan for improvements to existing, and provision of new, well-designed public spaces in Guildford town centre, in Ash and Tongham, in our villages and other strategic growth schemes as part of any major new development

GRA Response: To shape change for the better and protect distinctiveness, we should ask the following three questions of any new development:

 Will it respect and enhance the valued historic and green character, setting, roofscape and views?  Will it contribute to creating distinctive, cohesive communities?  Will it make wise use of land?

At present, the Plan risks focusing on distance to facilities at the expense of community and character.

We do not support the split proposed in the consultation between conforming to distinctive character or being innovative. Regardless of where development is proposed, and whether it is traditional or modern, it should have a sense of place and enhance the character of an area. Residents are dismayed at the recent spate of applications where developers have been told in pre application discussion to “go for modern”. This advice is inadequate. Be it traditional or modern, a building should be appropriate for its setting. We do not want Guildford to lose its identity.

As we state in our Aspirations document supported by 35 organisations:

Value the green & historic character of Guildford

Whilst planning for new homes in areas where they can be accommodated without harm to character, equally we must work to maintain and improve the character and green aspect of our established residential areas and town centre by: o Preventing ‘garden grabbing’ and loss of trees and hedges. o Stopping congested streets being treated as car parks because building plots are overdeveloped. o Creating green spaces in housing schemes and providing adequate space for cars so that greenery is not subsequently lost by occupants to make space for vehicles. o Ensuring new buildings have character, use materials that will age well, are designed to stand the test of time and respect and enhance our heritage.

o Avoiding the bulk and height of buildings obscuring the contours of our gap town. o Protecting views from, into and within the town, retaining and creating valued landmark buildings. o Requiring the scale and form of existing buildings, which harm views, block riverside access or are discordant with topography, to be revised when redevelopment occurs.

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o Taking special care to protect tree screens, rural landscape features and large spaces between developments at the boundary between town and country. o Ensuring the approaches to Guildford are lined by trees not high-rise buildings or stark flood lit car parks. o Promoting green areas and large trees as ever more important in making Guildford a comfortable place to live. o Resisting light pollution and obtrusive moving images and signs, especially in historic and residential areas. o Leaving space for water in squares, meadows and ponds to avoid flooding of homes, businesses and roads.

ACTIONS

1. Update and make full use of the Residential Design Guide and Landscape Character Assessment. 2. Strengthen the protection of Guildford’s Victorian and Edwardian heritage such as Victorian schools, London Road railway station, period houses and villas. 3. Ensure new developments and extensions allow for adequate, well landscaped off-street parking and encourage underground parking where appropriate. 4. Open up the riverside keeping it a green area and set back any building line to create a continuous

path along each bank as redevelopment opportunities arise. 5. Retain and establish squares and water meadows to accommodate flood water and reinstate a more natural alignment of the Wey around Slyfield when the landfill site is remediated. 6. Take cumulative impacts into consideration when development is proposed.

Town Centre:

7. Consider impact on the roofscape when development is proposed and respect topography by resisting inappropriately tall and bulky buildings (eg retain and open up views to the river at Millbrook). 8. Protect valued landmarks and views in planning briefs and applications (eg safeguard the views from Bright Hill and of the Mount from the town centre). 9. Promote replacement of buildings of poor design or that block views or riverside access. At the end of their economic life, revise footprint, height and massing as necessary to achieve character in keeping with surroundings. 10. Promote quality of design in character with surroundings and resist large signs, screens and unsubtle lights. 11. Retain public rights of way along streets in any town centre developments creating new quarters rather than “shopping centres”. 12. Ensure proposed major developments (eg railway station, Bellerby Theatre site, Cathedral, St Nicholas car park and Bedford Road sites) are of a scale and character that fit well with the historical buildings, topography and skyline of Guildford. Assessment of cumulative impact and compatibility with, and contribution to, Guildford’s strategic vision will be essential. Traffic, parking, provision of green space and use of materials that will age well are important considerations.

Garden Suburbs and Villages:

13. Protect the suburbs and villages from the imposition of housing densities that harm neighbourhood or village character and from the development of overly bulky and high houses with adverse impacts on green character and views 14. Implement measures to protect the wooded nature of Guildford including making earlier, more effective use of Tree Preservation Orders and preventing developments that crowd out trees. 15. Introduce a new policy to ensure development that borders the countryside and designated green space is of appropriate scale and rural character and well screened. Treating sites around the periphery of settlements as “urban area” does not achieve this.

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We are supportive of enhancing links between the town centre and other areas including to the railway station and University/ Cathedral/ Hospital/ Research Park area. We do not want to create ribbons of town centre redevelopment running into surrounding residential areas. An attractive, valued feature of Guildford is that you have green and attractive residential roads leading into the town centre (greening the approaches policy) and clean distinctions between town centre and suburb, and between suburb and countryside.

The Wey corridor benefits from a mix of inspirational management (such as the water meadows of South Guildford by Shalford Park) and highly insensitive development (such as buildings and roads that block off access, protrude into the natural channel and turn their backs to the river). Making more of the river should involve expanding the green corridor by moving back development not encouraging a string of raised car parks and high rise buildings along the water’s edge adding to flood risk and further impeding access. A more natural alignment of the river should be reinstated when the landfill is remediated at Slyfield (and a minor no net difference change made to the Green Belt boundary).

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Issue: Climate change and sustainability

Options:  Require consequential improvements to existing buildings when applicants apply for planning permission, unless the improvements are not viable  Develop a renewable energy strategy that identifies suitable sites for renewable energy and promotes the development of CHP networks  Introduce a more stringent standard where viable for water use in new homes, requiring water saving measures and a per person consumption target lower than 105 litres per day

GRA Response: We should distinguish between:  measures needed to make us more resilient to the extremes of water shortage and extreme rainfall and  steps we need to take to reduce our harmful impact on the environment.

Resilience:

We should treat the Wey floodplain as an asset that reduces flood risk to property and also encourage more flood resilient design and layout of homes and public space. Sustainable drainage systems, including permeable paving, should be encouraged. This is especially important given the rapid runoff that can flow down streets from the downs and overwhelm lower lying areas. Redevelopment presents important opportunities for improved layout and the policies in the National Planning Policy Framework, including the sequential test, should be rigorously applied. We should be mindful of why certain spaces have been left undeveloped over the years; we could pay a high price for inappropriate development.

Sustainability:

Reuse and recycling of materials should continue to be a high priority. Measures to promote energy efficiency and renewable energy, and reduced water and energy use are welcome as long as the policy allows for a flexible approach that takes account of all aspects of sustainability. Viability should not be the only caveat. There has to be openness about the trade off between different sustainable development objectives. A fine building or green area may be considered an “irreplaceable asset” and, where that is the case, it would be unsustainable to harm it.

Eg A solar or wind power measure might destroy the character of a valued distinctive building or an area of great natural beauty and would not always be the most sustainable option. Eg A corkscrew water power facility may cause disproportionate harm to wildlife. Eg Combined heat and power requires a joined up approach to all environmental impacts, including emissions. It is not sustainable if it involves burning materials that should be reused.

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Planning for our town and villages

Issue: Settlement hierarchy

Settlement Hierarchy Urban Area: Guildford urban area, Ash and Tongham urban area Semi Urban Village: East Horsley Large Village: Normandy and Flexford, Fairlands, Pirbright, Wood Street Village, Ripley, Send, Send Marsh/Burntcommon,

Shalford, Chilworth

Medium Village: West Horsley (North and South), Worplesdon, Effingham, Jacobs Well Small Village: Peasmarsh, Shere, Peaslake, Compton, Gomshall, West Clandon (North and South), Puttenham, Albury, Ash Green Hamlets: East Clandon, Ockham, Seal and The Sands, Holmbury St Mary, Wanborough, Shackleford, Wisley, Wyke, Eashing, Farley Green, Hurtmore, Littleton/Artington, Fox Corner

Options:  Use the settlement hierarchy to judge the appropriateness of developments  Use other research to help judge the appropriateness of developments

GRA Response: The Settlement Hierarchy does not provide a basis for determining the housing needs of each settlement and its capacity to accommodate development in a sustainable way. Landscape quality can be a more significant factor than settlement size. There should be no major development in the Area of Outstanding Natural Beauty, either at the edge of the urban area or associated with villages. Even very minor housing development should only be considered if based on the sustainable needs of a particular village within the AONB, designed to be fully compatible with the statutory purpose of the designation and very sensitively located. in view of the recognised landscape quality, land in the suggested potential development areas at Chinthurst, Shalford, and to the eastern end of Chilworth should be protected from inappropriate development.

As stated in relation to Question 2, characterising settlements and their access to services and transport is useful but ranking villages according to misnamed “sustainability” and functional scores with weightings does not provide a basis for directing growth. The objective is identifying future capacity for sustainable growth, while respecting limits, not turning larger villages into small towns.

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Issue: Villages in the Green Belt

Options:  Use the recommendations set out in volume four of the Green Belt & Countryside Study to identify new settlement boundaries for some villages to remove them from the Green Belt

GRA Response: Overall the Green Belt and Countryside Study is so flawed that it cannot be relied upon as sound evidence. (See answer to Questions 2) It is noted that Volume IV was commissioned, and the number of villages studied expanded, due to the introduction of the National Planning Policy Framework. This changed the criteria for determining whether a village should be taken out of the Green Belt (inset). Both Volumes III and IV of the Green Belt and Countryside Study provide some useful data on each of the villages studied. However, the analysis undertaken to consider whether villages should be inset is unsound and draws conclusions that need testing:

 There is a flaw in the methodology. The National Planning Policy Framework states: o “If it is necessary to prevent development in a village primarily because of the important contribution which the open character of the village makes to the openness of the Green Belt, the village should be included in the Green Belt.” o “When defining boundaries, local authorities should: … define boundaries clearly, using physical features that are readily recognisable and likely to be permanent.” The first (see paragraph 86) sets out the test of whether a village should be inset. The second (see paragraph 85) sets out considerations for when defining a boundary. The Pegasus study combines the two processes and scores the presence/absence of permanent physical features to define a boundary as a criterion for determining whether a village contributes to the openness of the Green Belt. This criterion should not determine whether a village is inset.

 There is inevitably a limit to what can be achieved through site survey, aerial imagery and Ordnance Survey mapping. The locations of woodlands, hedgerows, tree belts, and highway and railway infrastructure surrounding each village were mapped as possible boundary features rather than as determinants of openness. Rights of way, such as footpaths, and amenity space should be considered from which the open character of a village or its contribution to the openness of the Green Belt might be appreciated. Given the topography of Guildford, views onto villages can be of great importance and need to be taken into account.

 The way trees and topography were considered is of concern. The study assumes a village surrounded by trees does not contribute to the openness of the Green Belt but concedes surrounding woodland could be appreciated from within an open village. “Open” in a Green Belt context relates to absence of development. Woodland is a highly valued Green Belt land use. Guildford borough has a policy of encouraging soft green edges to settlements which contributes to the open character of the Green Belt and softens the impact of settlements. A village that adjoins woodland can contribute greatly to the openness of the Green Belt even if the appreciation of the contribution of the village is at shorter range and more distant views are more screened. Seasonality also needs to be considered.

 The overall scale of a village should be considered. A compact small village may contribute to the openness of the Green Belt as much as a larger more linear village. 40

 The way density is taken into account needs careful consideration. Inclusion of higher density development within a village should not necessarily lead to a conclusion that a village fails to contribute to the openness of the Green Belt. Some higher density housing makes a very positive contribution and does not detract from an overall impression of openness. Also, suggesting inclusion of some higher density homes within a village detracts from Green Belt function will discourage sensitive provision of affordable housing.

We encourage Guildford Borough Council to invite detailed scrutiny of each village assessment and test the Pegasus proposals against local community knowledge. In a by no means exhaustive list, we suggest that the proposals to take Gomshall, Normandy, Send, Shere and Wood Street out of the Green Belt are reconsidered given the important contribution of these villages to the openness of the Green Belt and the valued vantage points into and from Green Belt woodland. We suggest the proposals to remove Effingham, Gomshall, Normandy, Shalford, Shere and Wood Street from the Green Belt are reconsidered on the basis that presence of physical boundary features does not determine whether a village contributes to the openness of the Green Belt. Smaller, more compact villages should be reconsidered. We are certain local knowledge will identify further considerations. Getting insetting decisions right is critically important, not only for the integrity of the Green Belt countryside, including its villages, but also because local authorities are required to:

 “consider the consequences for sustainable development of channelling development o towards urban areas inside the Green Belt boundary, o towards towns and villages inset within the Green Belt or o towards locations beyond the outer Green Belt boundary”. o  “take account of the need to promote sustainable patterns of development”, and

 “when defining boundaries, … ensure consistency with the Local Plan strategy for meeting identified requirements for sustainable development”.

The flawed identification of “potential development areas” in the Green Belt and Countryside Study has undermined confidence in the process of determining which villages should be given Green Belt boundaries. It is unclear how any village land proposed for removal from the Green Belt will be protected from inappropriate development, especially in the period when Guildford will have to rely on a dated Local Plan. In the new Plan, how would policies to protect character in villages be strengthened where Green Belt status is no longer the policy relied upon to shape decisions? How will the soft, green edges to villages be retained?

Issue: Ash Green

Options:  Include Ash Green within the urban area - Ash Green would be linked to the urban area by land identified in research (GBCS potential development areas K9, K8 and K6 north)  Define a boundary for the settlement of Ash Green so that it becomes an identified settlement within the rural area

GRA Response: No comment

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Cross boundary issues Issue: Duty to cooperate

Options:  Continue working actively and constructively with our partners to address cross boundary issues

GRA Response: Given the constraints of being: . a gap town . surrounded by Green Belt, . located in the Surrey Hills AONB, . adjoined by Special Protection Area, and . relied upon by 8,000 commuters to London, we would expect Guildford Borough Council to explore the potential for housing need to be met by surrounding boroughs under the duty to cooperate. We are surprised that Guildford advised Woking that it would not be asking its neighbour to assist with providing homes to support housing needs. Guildford claimed, in advance of the evidence, it expected to be able to meet its housing needs.

Is the potential to increase the number of homes in Rushmoor for people who commute into Guildford being fully investigated?

It will be important to cooperate with Surrey County Council (as Lead Local Flood Authority) and other Risk Management Authorities, such as Thames Water, regarding flood risk management. A coordinated approach to management along the Wey will be required.

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Planning for sites and spatial options

Issue: Spatial options - where new homes would go and when

villages Redevelop appropriate spaces and buildings in our towns and villages: This would involve converting existing buildings and providing new buildings within the existing urban areas of Guildford, Ash and Tongham, and within the existing boundaries of our villages, to provide new homes and other buildings. These kinds of sites are often, but not always, land that has been developed before (previously developed land). Our research in the SHLAA tells us that continued development in these areas could provide 3,302 homes in the years 2015-2031.

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Use land on the edge of villages to provide affordable housing for local need: This option involves building new affordable homes on land outside of but closely related to the existing boundaries of villages, to provide affordable homes. These are known as rural exception housing schemes as they are allowed as exceptions to the normal planning policies that discourage new homes being built in the countryside. Local communities sometimes suggest opportunities for schemes like this after a survey has identified housing need in their parish. We cannot permit rural exception sites of this kind around the urban areas of Guildford, and Ash and Tongham. Our research in the SHLAA tells us that we could achieve 160 homes on rural exception sites in the years 2015-2031.

Reuse previously developed land in the countryside: Previously developed land (defined in the NPPF) which is or was occupied by a permanent structure, including the curtilage of the developed land (although it should not be assumed that the whole of the curtilage should be developed) and any associated fi xed surface infrastructure in the countryside that has potential for appropriate redevelopment to help meet future development needs. Our research in the SHLAA tells us that we could achieve 269 homes on previously developed land in the countryside in the years 2015-2031.

Use countryside land in the west of the borough: We could provide development by extending the existing urban area of Ash and Tongham into the countryside to help to meet our housing, employment and infrastructure needs. (Extension(s) to the Guildford urban area is another option that is explained below). This could provide new neighbourhood(s) within reach of existing transport links, shops, schools and health care, as well as bringing new or improved services and facilities that may also benefit surrounding existing residents. Our research in the SHLAA tells us that we could achieve at least 2,004 homes on some of this land. However, we could consider using more of this land to provide approximately 4,556 homes in the years 2015- 2031.

Use countryside in the centre of the borough by extending Guildford town’s boundaries: We could extend the existing urban area of Guildford into land currently designated as Green Belt to provide new neighbourhood(s) to meet some of the development that the borough needs in the future. Development in locations like this could integrate well with the existing facilities and services in Guildford town, whilst providing new infrastructure which may also benefit surrounding existing residents. Our research in the SHLAA tells us that we could achieve approximately 1,782 homes if we provide one new neighbourhood or 3,564 homes if we provide two new neighbourhoods in the years 2015-2031.

Use countryside to expand around villages: We could expand our villages by developing some of the countryside that adjoins their existing boundaries. Providing new homes and business space can help to support the rural economy including local services within a community. Our research in the SHLAA tells us that we could achieve 2,510 homes on using countryside around villages in the years 2015-2031.

Significantly expand an existing village: We could expand a village that has good range of services including transport links as we plan for new development through the Local Plan. We estimate that this could provide approximately 4,920 homes in the years 2015 - 2031 based on the same assumptions towards density and capacity and considerations of availability as the Green Belt and Countryside Study used.

Create a new village: We could create a new village. This would mean building a new settlement with homes, employment, and supporting infrastructure. As it would be a stand alone settlement, it would require a scale of development that could provide the facilities and services to support itself. This includes jobs, shops, community facilities and leisure opportunities to reduce the likelihood that it becomes a dormitory area from which residents need to commute. We estimate that this could provide approximately 2,175 homes in the years 2015-2031 based on the same assumptions towards density, capacity and availability as the Green Belt and Countryside Study

GRA Response:  The potential for freeing up homes in the town currently used by university students, who could be relocated to new and redeveloped campus accommodation, should be given very high priority as a potential quick win. This should be accompanied by a strategy to strengthen links between the university and the town which are valued.

 Attractive, higher density redevelopment to enhance and invest in Park Barn should be another priority and major focus. This would provide homes close to the Hospital and Research Park and would be preferable to any nearby green field housing development. 44

 In the absence of an up to date town centre plan, the potential for well planned, sustainable development within the town centre has not been objectively assessed.

 Development designed to entice more elderly residents out of their family homes earlier should also be a priority strategy. This is a structural adjustment that could make a significant contribution to freeing up housing stock.

 Failure to bring forward investment costing tens of millions at Slyfield is blocking an investment worth hundreds of millions, including hundreds of new homes. This should be brought forward as a matter of urgency.

 It would be totally wrong to put major development in the nationally protected Surrey Hills Area of Outstanding Natural Beauty.

 The intention to protect Green Belt has been restated to Guildford’s MP by the Planning Minister who wrote “unmet need alone“ is unlikely to justify housing development in Green Belt. The boundary should only be changed under exceptional circumstances which this consultation does not explore at a strategic level. It is deeply regrettable that a flawed Green Belt and Countryside Study has undermined confidence in a crucial and sensitive debate on how Guildford should develop. All of the options proposed in the potential housing examples (consultation pie charts) include 3,362 homes from redevelopment in towns and villages. That suggests a certainty that is unwarranted and that needs testing against improved density assumptions and the car parking strategy that retains much needed car parks. (See answers to Question 4, 15, 17, 18, 20 and 21)

In the potential housing examples, two different options to “use countryside in the centre of the borough by extending Guildford town’s boundaries” are presented. o One option assumes 3,564 homes are built by extending Guildford towards the Hog’s Back (at Manor Farm which is partly in the AONB and Blackwell Farm) and beyond Burpham (Gosden Hill and Nuthill Farm) o Another option assumes 2,510 homes are built by extending Guildford along Merrow Down (Burwood Farm which is entirely in the AONB) and beyond Burpham (Nuthill Farm).

 Both options assume 40 dwellings per hectare which we question. (See density comments in answer to Question 4)  Proposing Area of Outstanding Natural Beauty in potential housing examples suggests a troubling disregard for the designation.  Proposing building on AONB in the smallest potential housing example also undermines the reassurance given that potential development areas in the AONB were only included as options of last resort.

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Issue: Site options

Guildford town centre: North Street regeneration site, Portsmouth Road surface car park, 1 & 2 Station View, The Plaza, Portsmouth Road, Land and Buildings at Guildford Railway Station, Bedford Road surface car park, Bright Hill car park, Guildford Park car park, Buildings at Chertsey Street, Jewsons, Walnut Tree Close, Guildford urban area: Middleton industrial Estate excl. Lexicon House, Cathedral Hill & Guildford Industrial Estates, Land at Guildford Cathedral, Land at Walnut Tree Close, Merrow Depot, Merrow Lane, Guildford Fire Station, Ladymead, Former Pond Meadow School, Westborough, Guildford College, Stoke Road, Slyfield Area Regeneration Project Ash and Tongham; Lyssons Avenue/Station Road East, Ash Vale, (urban area) Enterprise Industrial Estate, Station Road West, Ash Vale Villages: Ramada Hotel, Guildford Road, East Horsley Previously developed land: Mount Browne (Surrey Police HQ) Sandy Lane, Land around Merrist Wood College, (countryside) Worplesdon, RHS Wisley, Wisley, Bisley Camp, Bisley, Brookwood

GRA Response:

It is of concern that housing numbers are being established for sites in critical town centre areas that do not yet have an up to date Supplementary Planning Document to guide estimation of appropriate, sustainable housing numbers. Overarching Town Centre, Wey Corridor and Slyfield strategies are urgently required plus more detailed planning briefs for North Street, the Railway Station, Bedford Road and Walnut Tree Close areas. What density, height and layout assumptions are being made to identify numbers? (See answers to Questions 4, 11, 12 and 18 including in relation to density, use of car parks and land around North Street, Guildford railway station, Bedford Road surface car park, Bright Hill car park, Walnut Tree Close, Ladymead and Slyfield area.)

Great care needs to be taken in the approach to areas liable to flood. Advice on residential use being less appropriate in high risk areas should be heeded in the layout of mixed use developments.

Any station redevelopment should take account of the fact that peak rail use is forecast to grow by 24 per cent between 2010 and 2031. We need to retain space for a fully functional railway station with links to bus services to the north and south sides of the track. Air track and railway bridge land requirements should be safeguarded.

There should be no reduction in car park availability in the town.

Mount Browne is in the Area of Outstanding Natural Beauty. The present development is incompatible with the statutory purpose of the AONB and this should be upper most in any consideration of future use if this site is no longer required by the police. The purpose of an Area of Outstanding Natural Beauty is not only to conserve but also to enhance natural beauty in terms of landscape and scenic beauty. As the site is previously developed land, change of use of the existing buildings to residential could not be refused. However, if redevelopment is proposed, this should be of a kind that establishes use compatible with the purpose of designation. There should be no increase in overall footprint, no intensification of use and the opportunity should be taken to explore a changed layout that enhances the landscape of the Surrey Hills, perhaps creating a village that befits the designated area.

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Issue: Land around Ash and Tongham (including countryside)

 Grange Road, Tongham (A31/A331)  Land at Kingston House, Poyle Road, Tongham  Land to the east of White Lane, Ash Green  Land to the south of Hazel Road, Ash Green  Land south of Ash Lodge Drive  Land near The Briars, South Lane & Grange Road  Land to the south and east of Guildford Road  Land to the north west of Ash Green Road

GRA Response:

There is a risk of over-developing Ash and Tongham because they are not within the Green Belt. The plan should provide for Ash and Tongham to retain their identities and not merge them into a larger urban area with Aldershot.

Issue: New Green Belt land

In Ash and Tongham, new Green Belt could prevent new development getting too close to the AONB and could prevent Tongham merging with Ash Green. Our GBCS has identified two areas that could help to achieve this if they became Green Belt: • land to the east of Manor Farm, referred to in the GBCS as land parcel K3, and • land around Poyle Farm referred to in the GBCS as part of land parcel K5.

GRA Response:

There is a good case for extending the Green Belt boundary such that Ash and Tongham are afforded a greater degree of protection from integration into an expanding Aldershot. When the Metropolitan Green Belt was designated, it was intended that development would jump the protected area and be directed instead to appropriate locations beyond. It was not foreseen that development would become concentrated on small settlements in countryside in a ring around the Green Belt boundary. The proposed Green Belt extensions would help to retain the openness of countryside made vulnerable as a result of the Metropolitan Green Belt and assist in preventing coalescence. We consider the test of exceptional circumstances, which must be satisfied in order to justify extending the Green Belt, is met.

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Issue: Land surrounding Guildford urban area

Land to the north east of Guildford - this is land at Gosden Hill Farm, Merrow Lane Primarily new homes, with other uses including retirement/care homes, offi ces, supermarket, food and drink, leisure and community uses Land to the south west of Guildford - this is land at Blackwell Farm, Hogs Back Primarily new homes, with other uses including retirement/care homes, offi ces, supermarket, food and drink, leisure and community uses Land at Gunners Farm and Bullens Hill Farm - this is land to the west of Jacobs Well and south of Salt Box Road Industrial uses and warehouses Land north of Salt Box Road and west of the railway line, Whitmoor Common – north of Salt Box Road Industrial uses or Park and Ride

Our research (GBCS) identifies more potential land close to Guildford, but it may not be suitable for development: • land to the south east of Guildford (this is land to the south of Warren Road) - this land is in the AONB • land to the east of Guildford - this is a golf course and a small part of it is in the AONB • land to the north of Guildford (this is land at Tangley Place Farm) - a large part of this land is too close to the Thames Basin Heaths Special Protection Area to be suitable for new homes. Our research (ELA) suggests that the land could be suitable for industrial uses but only if the roads were improved to support the increased transport that would result from this change of use. The site may be better suited to a Park and Ride (see later section).

GRA Response: Having countryside with the highest landscape status in England that you can walk to in minutes from the High Street, business areas and many homes is an economic, social and environmental asset we can ill afford to harm. The consultative documents show inadequate regard for the Surrey Hills AONB, give little more than lip service to policies designed to protect AONB and fail to apply the logic behind those policies. There is no case in any of the evidence for developing on AONB land and any such land should be ruled out from the list above. We are required not only to conserve but also to enhance such areas. We concur with the suggestion that land to the east and south east of Guildford in the AONB would not be suitable for development and note that these areas are considered unsuitable for development, due to constraints, in the Strategic Housing Land Availability Assessment. Given the requirement for an evidence based approach, we would expect any proposals for development on land surrounding Guildford urban area to avoid development in, or harmful impact upon, the Area of Outstanding Natural Beauty.

 According to the National Planning Policy Framework, “great weight should be given to conserving landscape and scenic beauty in [the Surrey Hills AONB], which have the highest status of protection in relation to landscape and scenic beauty”.

 Such is the importance attached to protecting the beauty of the Surrey Hills that “major development” is only allowed in [the AONB] in exceptional circumstances. It must be proven to be in the public and national interest and that there is no practicable alternative. If development is essential, the detrimental effects

on the environment must be minimised. (Silkin Test 1949, National Planning Policy Framework paragraph 116)

 As far back as 1947, the Hobhouse Report established that views into and out from the designated area matter. The 2012 National Planning Policy Framework reinforces that valued landscapes should be enhanced and protected.

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In considering land outside the AONB, the sensitive transition between town and country is a valued feature of Guildford that helps the economy. Roads leading into Guildford, including the A3, have green approaches. We should not destroy countryside to which the public enjoys easy access within walking distance, only to create inferior Greenspace to which people are required to drive. A preferred route for an A3 tunnel, any entrance or assembly land and the land required for improved A3 junctions should be identified before further consideration of housing sites.

More prominence should be given to avoiding harm to ancient woodland, an irreplaceable habitat we are required to protect under the Biodiversity Convention.

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Issue: Land surrounding villages

 Land to the north of West Horsley, west of West Horsley, adjoining Tannery Lane, Send, west and south west of Fairlands, west of Westwood Lane, Normandy, east of Westwood Lane, Normandy, south east of Hunts Hill Farm, Normandy, near Anchor Copse, Normandy, north of Flexford, east of Flexford, west of Flexford, west of Ripley, west of Chilworth adjoining New Road, east of Chilworth adjoining Dorking Road, east of Shalford adjoining Chinthurst Lane, west of West Horsley, east of Shere Road, West Horsely, north of Send Marsh, north east of Send Marsh, north of the centre of Send Marsh, around Burnt Common warehouse, London Road, extension of Peasmarsh Industrial Estate, Old Portsmouth Road and land near Effingham Common Road, Lower Road and Water Lane, Effingham

GRA Response:

At what point does a “semi urban village” become an “urban area”? Taking villages out of the Green Belt and expanding significantly would make a significant impact on the integrity of the Metropolitan Green Belt to the south west of London. It will also increase traffic congestion on roads into Guildford.

A strategic debate is required. This cannot be achieved by the process currently in place. We are extremely disappointed that the flawed Green Belt and Countryside Study is hampering meaningful discussion on important matters and undermining confidence among the community. We consider both the proposals regarding which villages should be removed from the Green Belt (inset) and the identification of potential development areas to be unsound. (See answers to Questions 2 and 21) 50

Land around villages within the AONB (Puttenham, Compton, Albury, Shere, Gomshall, Peaslake and Holmbury St Mary) has not been assessed for their development potential as part of the GBCS. Further work is needed as there may be opportunities for small scale growth in the AONB that would not harm the high landscape quality of this area. Some villages in neighbouring boroughs are close to our boundary. We could talk to our neighbouring councils and explore the potential of extending these villages, using land that is in our borough. Possible places where we could consider this are on the edges of Old Woking, Milford, Farncombe, Bramley and Godalming.

GRA Response:

We would not welcome more work using the methodology applied in the Green Belt and Countryside Study to assess potential development areas around villages within the Area of Outstanding Natural Beauty. However, we were under the impression Guildford Borough Council is already commissioning work on AONB villages.

Extreme care should be taken to ensure any such assessment is of a very different nature, based on AONB purposes and the needs of AONB villages in compliance with those purposes. This should not be approached from the perspective of overriding the statutory purpose of the AONB. The label “potential development area” should not be used in any assessment.

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Issue: Significant expansion of existing villages

 land between Flexford and Normandy could possibly provide 2,700 new homes, along with other uses  land around Send and Send Marsh could possibly provide 2,220 new homes, along with other uses.

GRA Response:

We are under the impression this work is being commissioned. If so, the methodology should be reviewed to avoid flaws in earlier studies. A process should be set in place for strategic discussion when the report is available.

Flood risk is an issue around Send and Send Marsh.

Issue: A new settlement

A new settlement here could be approximately 167 hectares in size. This new settlement could provide at least 2,175 new homes along with other uses. Whilst acknowledging that this land has been developed before there are potential limitations to any future development of this land: • any new residents would be reliant on the private car in the absence of public transport connections • the land is close to the M25 and A3 junction and may increase the number of vehicles using these busy roads on a daily basis • part of the land is within 400 metres of the Thames Basin Heaths Special Protection Area, where new homes cannot be allowed so this radically affects the amount of land that could be developed for housing • a new settlement here would absorb the hamlet of Ockham • part of the land has planning permission for a large composting facility.

GRA Response:

Again we had understood this work is already being commissioned. If so, the methodology should be reviewed to avoid flaws in earlier studies. Again, a process should be set in place for strategic discussion when the report is available.

Proximity to part of the Thames Basin Heaths Special Protection Area is an issue for residential use.

Issue: Traveller and travelling showpeople sites

See answer to Question 8

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Issue: Land for Park and Ride sites

The possible sites previously suggested in Worplesdon remain options for a future Park and Ride service:  Land at Worplesdon Road, north of Tangley Place  Land at Tangley Place Farm  Land at Keens Lane  Land at Liddington Hall, Aldershot Road  Land at Westborough Allotments, Woodside Road  Land near Jacobs Well Village Hall  Land between Glaziers Lane and Strawberry Farm, Normandy

GRA Response:

We support further well located Park and Ride facilities. However, as can be seen from our answer to Question 14, they should only be considered as part of a mix of provision to support those who travel in to work. Greater priority should be given to improved and affordable, sustainable transport to reduce reliance on a car for getting to work. Park and Ride provision should form part of a fully integrated bus service with excellent links between railway stations and places of work. Services should link with appropriate key employment sites, such as Slyfield, not just the town centre. Park and Ride car parks have a significant harmful effect on the character of the countryside or townscape, often at sensitive sites near the edge of the town, and can detract from important views. These factors should all be taken into account when locations are considered and the potential for underground parking should be explored.

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Issue: Suitable Alternative Natural Green space (SANG)

The government’s advisers, Natural England, consider the overall effects of additional homes up to five kilometres from an SPA boundary can be avoided by providing Suitable Alternative Natural Green space (SANG), managing access to the SPA itself, monitoring the SPA's condition and through habitat management. Whilst we have enough identified SANG across the borough as a whole to meet our potential future needs, Natural England and our strategy require that developments of ten or more homes must be within five kilometres of a functioning SANG (we can assign developments of less than ten homes to any SANG in the borough).

GRA Response:

To date very little Suitable Alternative Natural Greenspace has provided new opportunities for informal recreation in newly created areas of high potential wildlife value. Sites have mostly involved rebranding and manicuring of areas already enjoyed by residents for their natural beauty, including enlargement of car parks. The effectiveness of the policy should be reviewed. We would welcome the opportunity for greater engagement in identifying appropriate new Suitable Alternative Natural Greenspace to deflect pressure from protected lowland heath bird habitat around Guildford. Reinstatement of chalk grassland habitat for amenity benefit, on land currently ploughed or improved (ie. fertilised and sprayed for more intensive grazing) might be considered. How Burpham Court Farm is managed will be of great interest to residents. We would be keen to avoid further intrusive urban features in established areas of natural beauty.

SANG should certainly be provided as part of any new development and could potentially be an integrated part of Sustainable Drainage Systems on some sites, which will be required from April 2014.

Issue: Land for burials and cremations

 Land north of Guildford This land is identified as a potential development area in our research (GBCS land parcel J3).  Land to the east of Tongham, near to Aldershot crematoria Our research (GBCS) records this land is within land parcel K3.  Large scale developments on the edge of Guildford. When we plan large new developments, we will consider whether burial ground is suitable as part of a mixed-use development. GRA Response: No comment

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Issue: Allotments

 Land at Westborough allotments, Guildford (Woodside Road). There is land next to the current allotments that is identified for affordable homes and open space (by the Local Plan 2003).  Land near Jacobs Well village hall. The land is being considered for allotment use by the land owner and the local parish council  Large scale developments. We can ask for new allotments to be provided on land that is identified for large-scale future development

GRA Response:

We very strongly support retention of current allotment sites for community benefit, including at Westborough, near Jacobs Well and provision in new developments.

Issue: Open space

GRA Response:

We support “Local Green Space” being designated as follows:

 Two fields on the northern flank of Pewley Down to enlarge the current wildlife and amenity area, as proposed by Holy Trinity Amenity Group.

 The small Snicket on Epsom Road that was cleared by a speculative developer, as proposed by Friends of The Snicket.

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Making it happen

Issue: Other issues?

GRA Response:

We look to Guildford Borough Council to develop a financial plan to accompany the draft Local Plan with financial scenarios and a risk register included. We suggest this is based on three five year phases: o 2015-20 o 2021-25 o 2026-31

Issue: Detailed policies

GRA Response:

As is clear from our answer to Question 18, residents attach very high priority to shaping change for the better to protect and enhance the green and historic character of our town, suburbs, business parks, villages and countryside. We want to be innovative and to retain and nurture a strong sense of identity and distinctiveness.

To achieve this we need:

 development control policies that support character and sense of place. This should be seen as central to the Plan rather than as a secondary matter largely made redundant by the National Planning Policy Framework.

 to revise the Sustainability Criteria against which the emerging Local Plan is being judged. At present the sustainability criteria and indicators fail to monitor whether policies in the Plan will protect and enhance the valued, distinctive character of the borough even though this objective is an important part of sustainable development. (refer to East Guildford Residents’ Association’s submission on Sustainability Appraisal Scoping Report)

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Issue: Implementation and monitoring

Our ongoing infrastructure planning research will help to support the Community Infrastructure Levy (CIL) charging schedule, which will be subject to independent examination before it is adopted. We are currently aiming to adopt the CIL at the same time as we adopt the Local Plan Strategy and Sites. An up to date plan is needed to base the CIL rate(s) on. We must draw up a CIL charging schedule based on the gap we identify in infrastructure funding, once we have taken into account all other funding sources.

From 6 April 2014, [now 2015] we will be restricted on the number of planning obligations we can pool towards any one piece of infrastructure. This means that from that date we may not collect and pool contributions from developments to provide Special Protection Area (SPA) mitigation. Consequently, from that date we will be unable to approve homes in SPA affected areas (unless developments provide their own SANG) until we can fund appropriate mitigation through CIL.

GRA Response:

This will not only affect provision of Suitable Alternative Natural Greenspace. It will also affect contributions to other infrastructure. We look to Guildford Borough Council to produce a strategy to demonstrate that provision of wider infrastructure and securing of contributions will not be put at risk by delay in getting an approved Community Infrastructure Levy Charging Schedule.

Contributions to safeguarding Special Protection Areas are highlighted because the issue affects several authorities and development cannot proceed without funding for mitigation. The worry is that GBC will be less effective in securing contributions for other infrastructure, in the absence of a Levy, but the development will proceed regardless.

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Any other views?

Issue: Other matters

GRA Response:

We include as part of our response our Aspirations for Guildford document which has the support of the following organisations:

Abbotswood RA Central Crescent, Abbotswood RA Ltd, Beechcroft Drive RA, Burpham Community Association, Bicknell Close RA, Burrows Cross Area RA, Chantry View RA, Clandon Society, Cranley Road Area RA, Downsedge RA, Fairlands Community Association, Ganghill RA, Holy Trinity Amenity Group, Jacob’s Well RA, Joseph’s Road Stoke RA, Merrow RA, Normandy Action Group, Ockham & Hatchford RA, Onslow Village RA, Perry Hill RA, Ripley Society, Rookwood Court RA, Shalford Conservation Society, St. Catherine's Village Association, Tyting Society, Westborough Broadacres & District RA, Weyfield RA, Weymount Neighbourhood Group, Wood Street Village Association. Compton, Clandon, Ripley and Worplesdon Parish Councils.

Also supported by CPRE and the Guildford Society.

Many sections have been incorporated into our response to the issues and options consultation. We include the full document in view of the significant consensus it represents and the importance of the Local Plan as a way of achieving these aspirations. We draw attention to the first three pages which convey our ambition to work constructively with the Council and other partners to address the significant challenges we face.

Guildford Residents’ Associations welcome the steps that have been taken by Councillors in a genuine attempt to improve dialogue with the community. We note the number of issues in our Aspirations document that are being taken forward, as well as the hiccoughs along the way.

If Guildford is to benefit from balanced and sustainable development, we need a much clearer sense of four elements:  How much development?  Where?  What kind? - including type and character/height/density  What infrastructure is needed to support this? We trust our response provides a steer on our approach to all four elements.

We very much hope that in the critical next stage, before publication of the Draft Plan, we can have positive and honest discussion with our Councillors and with planners on how to achieve the best outcome for Guildford. We face some significant challenges and great progress is being made in addressing issues that have been set aside for too long. We are not saying no to change. We do want to be confident any change will be for the better and that we will avoid losing what makes Guildford special along the way. We also want to come up with solutions that are appropriate for the needs of a gap town that is extraordinarily interconnected. We look forward to dialogue.

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Issue: Do we have the evidence we need?

GRA Response: An inspector will assess whether the plan is sound relative to the evidence base. Hence, we attach great significance to omissions and to flawed methodology in studies purporting to be objective evidence. Below we suggest evidence required and set out key concerns with certain studies.

Omissions:

Residential Density Database

We propose evidence on existing densities in different areas is required in order to inform a policy of providing appropriate indicative density ranges for different parts of the borough.

Please refer to comments on Question 4.

Guildford Residential Character Areas

Evidence is required to capture the character of residential areas in Guildford. This could

readily be drawn from the Residential Design Guide character areas. This should be used to help inform the Plan. The town should not be treated as an amorphous “urban area”. It is important to identify the differing suburban and central residential areas if Guildford is to remain distinctive and benefit from a sense of community. Green edges and approaches are a valued quality to be captured. A sound plan will need to be able to respect the features of suburban and conservation areas that are valued and make improvements where there are failings.

Overlooked:

Surrey Hills Area of Outstanding Natural Beauty Plan

The Management Plan should be used to inform the Guildford Plan. The AONB is an asset and is currently being undervalued and largely seen as a constraint. How many town centres and research parks benefit from such close proximity to one of the finest landscapes in England?

Underused:

Landscape Character Assessment

Far more use should be made of this critical piece of evidence. Guildford is to be congratulated for being ahead of many others in having compiled this invaluable resource. It should enable

more informed debate and ensure, wherever possible, change respects valued landscape characteristics.

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Evidence Issues:

Green Belt & Countryside Study:

The brief for volumes I to III was to identify “realistic sustainable location(s) for green field release.” The criteria and assessment are so flawed these volumes are unsound and cannot be relied upon as a basis for decisions.

Scoring system - This loses any meaningful link with the overall purpose of Green Belt or the value of specific sites.

 It tries to score each separate land parcel in a tick box exercise that uses very narrow criteria and repeatedly misses the point of designation. An area that plays a crucial role in preventing settlements from merging and in restricting sprawl could score 2 and be treated as a candidate for development. There is no basis for suggesting the more criteria an area fulfils, the greater its contribution to the Metropolitan Green Belt.  Perversely, the study scores undeveloped Green Belt land as less important in stopping “encroachment”, and hence as less valuable and potentially more suitable for development. Yet a land parcel free from significant development has been more successful to date in preventing encroachment. Also, future encroachment may come from a farm that is undeveloped or from a farm that has associated development and has already encroached. The Coventry Green Belt study took the approach that areas free from development can play a crucial role in preventing encroachment into the countryside.  The Guildford study relies on land being next to a conservation area to determine whether it contributes to “the setting and special character” of a historic town. The Coventry study scored Meridan Gap as meeting this Green Belt criterion. The Guildford study could legitimately have taken account of AONB setting and of views to and from historical Guildford.  Different land parcels would have been taken forward for consideration as potential development areas had the approach in the Coventry Green Belt review been adopted. Sustainability - The study puts Green Belt close to settlements at risk by misrepresenting sustainability as “distance from facilities”.

 The summary report concedes “It was assumed that land adjoining the three main urban areas of Guildford, Ash and Tongham would offer the most sustainable locations for such development.”  The study brief clearly states that the agreed criteria for assessing sustainability of areas should include “opportunities for integration and securing infrastructure”, and also a “location’s contribution to the quality and value of landscape character in the borough”. The identification of potential development areas and rankings would have been very different if the consultant had, as specified, considered contribution to the quality and value of landscape character as part of sustainability.  As a result of erroneously treating landscape character as separate from sustainability, the study fails to consider harm to irreplaceable natural assets as inherently unsustainable. When it suggests major development on land parcel E23 in the AONB would be the 6th most sustainable housing option in the borough, this mostly reflects proximity to the town. Sustainability is a wider concept, as set out in the National Planning Policy Framework, and includes protecting irreplaceable, nationally valued AONB that benefits the town.  Concerned residents have been advised by GBC that “the Evidence with Land Availability is simply an audit which identifies the land we have available...it isn’t necessarily land that…we may want to build on...that would be sustainable for development, or…that would get through the planning process.” However, had the consultants fulfilled their brief, the evidence would have produced a list of the more sustainable options.

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Areas of Outstanding Natural Beauty - The study fails to apply policies designed to protect the Surrey Hills AONB which has the highest status of landscape protection, equivalent to a National Park.

 The study identifies land along Pewley and Merrow Downs in the Area of Outstanding Natural Beauty as “potential development areas” without applying the test for major development. This long standing test, which applies to National Parks and is now set out in Paragraph 116 of the National Planning Policy Framework, is much stronger than a requirement that land outside is assessed first. It requires exceptional circumstance that the Green Belt study would need to demonstrate before identifying a “potential development area”.  The study also fails to take adequate account of impact on the Area of Outstanding Natural Beauty on the Hog’s Back. The study suggests development on Manor Farm could be kept away from the part that is in the Area of Outstanding Beauty, which is about a fifth of parcel H1. However, it fails to consider the visual impact of major development on the scenic beauty of the Hog’s Back and, in particular, the potential demand for a road link on the designated part.  More attention should be given to impact on the adjoining Area of Outstanding Natural Beauty in the assessment of the potential development area along the Epson Road in Merrow (parcel E1).  A recent inspector’s letter, regarding the Waverley plan inquiry, is being put forward as a justification for identifying “potential development areas” in Area of Outstanding Natural Beauty. The inspector was concerned that local designations should not be treated as a basis for a blanket ban on development, even if some of the locally designated land might be upgraded to national status in future. He stressed that much more weight should be given to “national designations to which the Framework attaches particular importance”, such as Green Belt and Area of Outstanding Natural Beauty, as opposed to local designations. He specified that if the location of new development is to be influenced by local landscape designations, as Waverley proposed, then the purpose and nature of such designations should be justified by the evidence base.  AONB is a national designation. Natural England, not a Local Authority, designates Areas of Outstanding Natural Beauty. The purpose of the designation is both to conserve and enhance the natural beauty of our finest landscapes. The inspector’s letter essentially reinforces that AONB land should be given the highest status of protection in accordance with the National Planning Policy Framework. In the absence of exceptional circumstances, proposing major “potential development areas” in the AONB is unwarranted.  In the AONB, assessing the potential for identifying very small scale sites to meet the needs of villages, in a way that is consistent with conserving and enhancing the natural beauty of the landscape, might be appropriate. This would be consistent with the Waverley inspector’s letter. Inconsistent approach - The report adopts an inconsistent approach to assessing land parcels.

 The initial studies considered damaging development to expand the town and harm the purposes of the AONB but not whether there were any options to meet any possible needs of villages in a way that would be compatible with the statutory purpose of the AONB.  Some land parcels are ruled out due to environmental or access constraints but not others. A more strategic review of fulfilment of Metropolitan Green Belt purposes, informed by description of land parcels, would have been better. We propose GBC:  undertakes a strategic Green Belt assessment, retains the land parcel descriptions and disregards the scoring against four criteria as a basis for identifying potential development areas,  renames the so called sustainability assessment as a measure of “proximity to facilities” and  removes the label “potential development area” from any land in the Area of Outstanding Natural Beauty. The approach fails to give great weight to conserving landscape and scenic beauty, the requirements of the major development test are not met and the label itself promotes harm contrary to the statutory purpose of the AONB. 61

Insetting Volume IV of the Green Belt and Countryside Study is also flawed and should not be relied upon to determine which villages should be taken out of the Green Belt (inset).

 The methodology is flawed because it uses the presence or absence of permanent boundary features as a basis for deciding whether a village should be inset. Such features are a consideration when defining a boundary not a determinant of whether a boundary is required. Openness is the determining factor for insetting.

 A village set in trees can contribute to openness of the Green Belt and to near and distant views.

 A small compact village may contribute to openness. We propose GBC:  disregards the insetting scoring undertaken by Pegasus  reviews each assessment of whether to inset a village with each village community to draw upon local knowledge

Infrastructure Baseline:

Infrastructure investment has failed to keep up with current levels of development. In these circumstances, the Infrastructure Baseline should include more detail on deficiencies in existing provision and steps being taken to identify and promote schemes that address deficiencies, particularly in transport infrastructure. The lack of ambition is a concern.

This study needs to be more transparent where changes to infrastructure proposed are driven by the aspiration to redevelop sites. Library relocation, bus station relocation and use of car park sites for development are examples. Guildford already has a convenient, centrally located

library with potential to act as a community hub that, along with the Post Office, promotes footfall in the upper High Street and North Street.

Areas inadequately addressed include:  the failure of bus services to provide connectivity across the town at critical times and to connect to the railway station  the dangerous design and inadequacy of cycle routes  lack of integration of new developments, such as St Luke’s, due to poor pedestrian access and connectivity  shortage of short term off-street car parks and of well designed off-street resident parking  reliance on on-street parking making parked cars a negative feature of the town

 loss of parking spaces to development eg in the vicinity of GLive  failure to provide adequate new open space with developer contributions  the proportion of developer contributions that are required for Suitable Alternative Natural Greenspace, especially given questionable outcomes and negative consequences.  loss of convenience shopping in residential communities  disconnection from the County Council which is located outside the county and not in the county town

Omissions:

Guildford Adult Education Centre and Harvey Road Gallery, Sydenham Road, Guildford GuildfordInstitute, Town Lido. Centre Development Study

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Settlement Hierarchy and Profiles:

Characterising settlements and their access to services and transport is useful but ranking

villages according to misnamed “sustainability” and functional scores with weightings does not provide a basis for directing growth. The objective is identifying future capacity for sustainable growth, while respecting limits, not turning larger villages into small towns.

Guildford Borough Preliminary Growth Scenarios Transport Assessment Report

A study was commissioned from Surrey County Council called Guildford Borough Growth Scenarios Transport Assessment which reported in August 2013. This demonstrates that congestion will increase significantly in the Borough under the growth scenarios supplied by GBC for testing. Further work will be required with revised scenarios. The method compares scenarios with a do-minimum situation. This do-minimum has the same amount of traffic in the peak hours in 2031 as in the 2009 base year.

The validity of this assumption should be challenged. If this is because the network is already operating pretty much at capacity, the extent to which capacity will be exceeded should be considered.

Strategic Housing Market Assessment:

This is too dated. We await the new assessment.

Waverley, Woking and Guildford are too different to be grouped and do not form a single

Housing Market Area that reflects the key functional linkages between where people live and work.

Far better figures on student housing are required. Student numbers account for a sharp increase in the 19-24 age range and the impact of such very large numbers living in private rented accommodation should be better understood.

Given that it is estimated an increase in international immigration and decrease in emigration have had the most significant impact upon Guildford’s population in recent years, the effect on the housing market should be better understood. Is international migration masking migration

from London?

How many new homes?

Will the significant areas of uncertainty identified be followed up? Why is there such variation in estimates of net international migration? What is the significant variable described as “other”? What proportion of international migrants commute out of Guildford and how many migrate from London? How will the phenomenal level of commuting be factored in? How will the potential to provide campus accommodation for students be factored in? Why is the predicted growth in Guildford’s population higher than national predictions?

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Employment Land Assessment:

 Great care should be taken to base economic and employment forecasts on a full economic cycle and to follow through the full implications of changing technology on demand for land.

 The employment rate should be updated in view of recent falls.

 The commuting rate is of such significance this should be updated and the implications given more consideration.

 Building in the order of 8,000 new homes will not translate into homes for Guildford’s economy. More attention should be given to sustainable transport measures required to support inward and outward commuting.

 Retail floorspace and employment predictions should be revised.

 Assumptions regarding demand for warehousing and distribution should be reconsidered given constraints in Guildford.

 More consideration should be give to the economic value of the environmental, historical

and cultural richness of Guildford.

 A more rigorous assessment of all categories of existing business floorspace likely to be or become available should be undertaken.

Sustainability Appraisal Scoping Report

Insufficient attention is given to critical aspects of sustainable development:

Local character, distinctiveness and sense of place should be appraised These are qualities that add to well being and help to underpin economic success. If Guildford is to attract and retain skilled people who will drive the new and creative technologies of the future, we need to cherish the valued qualities of our various community areas as well as to create imaginative and inspiring new developments. This requires more than just attention to designated wildlife sites and listed buildings or conservation areas. It is about green approaches, garden suburbs, distinctive villages and soft edges between town and country, roofscapes and views, consideration for landscape and setting, quirky buildings and materials that age gracefully rather than becoming shabby. These qualities are under great pressure and have a value that needs to be captured in the Sustainability Appraisal. We do not want Guildford to become a clone town with no features to distinguish it from any number of places.

Use of previously developed land should involve sensitive site by site decisions on density Care needs to be taken to ensure valued residential character is not lost as a result of pressure to make efficient use of previously developed land. A balance needs to be struck between sustainability objectives. Higher density near transport will often, but not always, be a more sustainable option.

Outdated economic overview The economic analysis uses unrealistic outdated retail growth projections and pays inadequate attention to the exciting scope for attracting new high tech, medical and creative technologies. What will the impact of home working be? Can technology reduce demand for domestic and international travel? What of economic resilience?

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Should we be diversifying our town centre? What about linkages between business sites? What will be the impact of growth on established businesses and traffic?

The approach to vehicles, parking and traffic needs rethinking

It is not sustainable to try to design out the car by providing no space for vehicles on development sites and treating car parks as available for alternative use. This simply pushes cars onto residential streets and pavements, aggravates congestion and pollution, degrades the street scene, fuels loss of green space to hard standing in new developments and leads to surface water run-off issues. Half a space per flat is not a sustainable policy for a development in which each resident owns a whole car! The focus for the Sustainability Appraisal should be level of car use. Previous planning policies have got this wrong,

Making alternatives to the car attractive Sustainable development requires making alternatives available and attractive. The report does not do enough to promote provision for residents and businesses within Guildford. The report also focuses on reducing congestion. The objective should instead be increasing the proportion of non car journeys per resident and visitor.

Guildford is a split community Access and connectivity are issues. The A3 divides the town. This is not good for cohesion and inclusiveness. There is a need for additional crossings of the river and railway to unite the town and to reduce congestion and pollution. There is also a need for a clean, modern state of the art bus interchange to improve connectivity.

Our comment on the sustainability objectives are as follows:

Suggested amendments or additions in bold

Objective 7: To make the best use of previously developed land and existing buildings and encourage sustainable construction while also respecting the valued character, landscape features and views of adjoining areas.

This addition relates to safeguarding qualities that provide distinctiveness and sense of place. This concerns irreplaceable assets and pillars of economic and social wellbeing. This proposed addition is distinct from objective 10 and is needed to encourage site sensitive decisions and prevent inappropriate cramming in the name of sustainability

Objective 11: To reduce road congestion and pollution levels and promote sustainable alternatives to travel by car and lorry.

We should promote positive provision of alternatives and reduction in the need to use a car. We oppose an indicator that proposes fewer spaces for cars.

Objective 14: To reduce waste generation and disposal, and achieve the sustainable management of waste including reuse of resources.

This addition is needed to strengthen the case against combustion of waste which is less sustainable than

reuse of materials.

Objective 18: To provide for a forward looking, adaptable and resilient mix of commercial development opportunities to meet the needs of the economy

We suggest the additional text is required to achieve sustainable development in a time of great change and uncertainty as well as opportunity.

We ask for the following Sustainability Objectives to be added:

ADD: To develop a dynamic, diverse and knowledge-based economy, that excels in innovation, with higher value, lower impact activities

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This is critical. It can help steer Guildford away from over reliance on retail and challenge us all to ensure we are making imaginative provision to attract the businesses of the future.

ADD: To enable planned and phased provision of infrastructure and services including appropriate communications technology.

ADD: To adopt a long term and strategic approach to planning including, as necessary, phased delivery and readiness to tackle major challenges and inherited mistakes.

Sustainable development requires a longer perspective and making things better rather than handing on problems to the next generation. This should be captured in the objectives.

Strategic Housing Land Availability Assessment:

We welcome the exclusion of Area of Outstanding Natural Beauty from development options in this document.

Where constraints have been identified, the practice guidance suggests the SHLAA should consider what action would be needed to remove them. This SHLAA includes reference to possible actions that could be taken to overcome any identified constraints.

We suggest that for key potential redevelopment sites, such as Slyfield and Walnut Tree Close, far more decisive action plans are put in place to overcome constraints and drive delivery.

We propose major redevelopment to enhance Park Barn is pursued and on campus student accommodation is added.

A

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