Response to Guildford Consultation Draft Local Plan September NOTE: The Guildford Society response to the 2014 Consultation comprised 10 parts.

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1 Draft Guildford borough Local Plan: strategy and sites July 2014 Consultation under Regulation 18 of the Town and Country Planning (Local Planning) (England) Regulations 2012 Response to Guildford Consultation Draft Local Plan September 2014 NOTE: The Guildford Society response to the 2014 Consultation comprised 10 parts. The full 991-page response can be found at: _lpresponse_final-full.pdf In this comparison the sections on Sites and on Local Super Output Areas are referred to. These can be found on Julian Lyon s whiteboard site: A link to the documents can be found here: The files (that can be viewed or downloaded from the GuildfordPlan.com site) are: Site by Site Analysis _Site-by-Site_Response_FINAL and Guildford Society Analysis of Middle and Lower Super Output Areas _LandUses-MSOA-LSOA_FINAL PART 1 Guildford Town Centre Guildford Urban Area Guildford borough Proposed Submission Local Plan: strategy and sites June 2016 Consultation under Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulations

2 THE KEY TO INTERPRETING THE LSOA CHARTS IS: The longer the cone, the more deprived, and the rings are in deciles (in other words, the inner ring is the least deprived 10% nationally and the outer ring is the most deprived 10% of LSOAs nationally) Planning for sites This section identifies land required over the period to 2031 to deliver the scale of growth and development set out in the previous chapters of this document. SPECIFIC SITE ALLOCATIONS GUILDFORD SOCIETY RESPONSE Sept 2014 Site Allocation Policies Introduction The purpose of these site policies is to allocate land for a range of uses to support the vision and objectives of the Local Plan. The policies consider sites within the whole of the borough, and allocate 2

3 The role of this section of the Local Plan: strategy and sites document is to establish the principle that a suitable form of development can be located on a particular site, and to give that / those use(s) greater weight in determining planning applications and appeals on the site in question. However, it does not give permission to any particular proposal; this will still need to be achieved through the planning application process. The intention is to provide developers, service providers, the Council and residents with some certainty about what sites will be developed in the future and for what purpose. The allocation of a site does not necessarily mean that it will be developed straight away, although one of the intentions is to allocate sites which have the potential to enable development to take place without undue delay. As part of the evidence gathering, we asked developers, agents, landowners, parish councils and local residents to put forward sites that they wanted to be considered as potential allocations. We have considered these suggestions as we have prepared evidence base documents such as the SHLAA and ELA. The Local Plan Issues and Options consultation document included a summary and map of each potential development option at the time. At the time of consultation, some assessment of sites had been carried out (including that done in the SHLAA and ELA), but no decisions regarding site allocations had been made. The process for formulating policies and selecting sites is complex and has involved many considerations. The most important of these are: Evidence Base: All the development sites identified in this section are supported by an up to date, relevant and proportionate evidence base in accordance with the requirements of the National Planning Policy Framework (NPPF), the National Planning Policy Guidance (NPPG) and the Town and Country Planning (England) Regulations The key studies in the evidence base include the Green Belt and Countryside Study, Strategic Housing Land Availability Assessment (SHLAA), the Employment Land Assessment (ELA), the Viability Assessment, the Infrastructure Delivery Plan, the Options Growth Scenarios Transport Assessment Report, the Habitats Regulations Assessment (HRA) Planning for Sites The preamble to the schedule of sites is contained in two pages entitled: 'Planning for sites'. This section notes that All the development sites identified in this section are supported by an up to date, relevant and proportionate evidence base... [in compliance with NPPF] and that The key studies in the base include... [various documents], listing: Green Belt and Countryside Study which exists Strategic Housing Land Availability Assessment which exists Employment Land Assessment which exists The Viability Assessment which may refer to the Guildford Borough Council Affordable Housing Viability Update Study Final Report (October 2011) and which is referenced as 'Key Evidence' on page 39 of the Draft Local Plan. The inconsistency of naming of these documents is unhelpful, especially as there is an item 'Development Viability' in 'Future research' in Appendix C Infrastructure Delivery Plan - to be produced -see Policy 17 and 'Future research' in Appendix C Options Growth Scenarios Transport Assessment Report which exists Habitats Regulations Assessment which is included in 'Future research' in Appendix C but which is also the subject of a co-terminus consultation expiring on 22nd September Strategic Flood Risk Assessment - to be produced - see 'Future research' in Appendix C It could also have included: Reference to the infrastructure schedules of Appendix B Several other items from the list in 'Future Research' in Appendix C especially: Green infrastructure (including open space and outdoor recreation assessment) - this is likely to require land Retail Needs Assessment update Traveller Strategic Housing Market Assessment West Surrey Strategic Housing Market Assessment land for development including for housing, employment, retail and infrastructure (including allotments). Each policy lists the land uses that are acceptable on the identified land, alongside specific requirements and opportunities for future development proposals. Each site is identified on a corresponding map, and is also shown on the Local Plan proposals maps (appendix H). Detailed information about the infrastructure required to support specific development proposals is listed in the Infrastructure Schedule (appendix C), with the Land Availability Assessment (LAA) also providing further information about the deliverability of sites and potential timescales. Phasing of sites across the plan period is not proposed in the site policies. Large strategic development sites are encouraged to progress seeking planning permission for development proposals, given the length of time delivery of large sites and supporting infrastructure can take. Equally, smaller site allocations are encouraged to progress development proposals, to help provide housing in the earlier stages of the plan period. Where allocated sites have been identified as likely to deliver in the later years of the plan period due to constraints (as referenced in the LAA), if these are resolved sooner, development proposals are encouraged. All site allocations require planning permission prior to development. Allocating these sites does not grant planning permission for development, however, it does identify the principle of development and uses. Key Evidence NPPF Land Availability Assessment Green Belt and Countryside Study Strategic Flood Risk Assessment Surface Water Management Plan/ Study 3

4 and the Strategic Flood Risk Assessment (SFRA). The development sites seem to be generally consistent with the SHLAA. The Guildford Society has not checked in detail the list of sites in the ELA against the Draft Local Plan. Sustainability Appraisal: This site allocations section and its preparation meet the requirements of the Strategic Environmental Assessment (SEA) Directive. The policies and sites identified in the plan are being appraised against sustainability objectives on an iterative basis. These iterations identify how emerging policies and allocations may help to achieve the relevant social, environmental and economic objectives. Duty to Co-operate: The Duty to Co-operate Statement, which forms part of the evidence base to the plan, demonstrates how the Council has co-operated effectively. Public Consultation: We are committed to involving the public in the decision-making process. In the preparation of this plan, we needed to balance its responsibility to involve the public in decision-making with its duty above all else, to plan positively for sustainable development. We have undertaken a considerable amount of public engagement and have taken on board the representations made during the plan preparation where appropriate. This is set out in the Statement of Consultation, which forms part of the evidence base. Each of the following sites are site allocations, and are numbered for reference. For each site, the allocated land use is identified. This section also includes information about safeguarded land. Some of this is safeguarded land in order to meet longer-term development needs stretching well beyond the plan period. This safeguarded land is not allocated for development at the present time. Safeguarding this land will help ensure that Green Belt boundaries do not need to be altered during the next plan period. Other land is safeguarded to provide for future transport infrastructure within the plan period. There is no equivalent source document or Site Assessment in respect of Cemeteries, Allotments and SANG and there are generally no sites separately identified for other infrastructure. We are unclear as to what happens if the Infrastructure Delivery Plan identifies a need for sites allocated in the Draft Local Plan for other uses. It is also worthy of note that the 'Planning for Sites' section should set out clearly the treatment of sites for which there is a planning application and sites with outline or full planning permission as we cannot readily tell whether their treatment is consistent. For example, the schedule includes 1 and 2 Station View (currently under construction) but not the Waitrose site (also currently under construction), the Aldi site or the Boxgrove roundabout site. The decision to ignore windfall sites is, in our view, misguided. It has been a consistent part of the history of planning in Surrey (at least since the mid 1960 s) that windfall sites have continued to provide a very significant contribution to housing provision. Over the relatively recent past in Guildford, windfall sites have included: Stoughton Barracks, Boxgrove Gardens (former Ministry of Agriculture Fisheries and Food establishment), the old Odeon Cinema, permissions granted at the Fire Station site, continuing conversions of commercial property (e.g. Quarry Street), the former Surrey Advertiser building in Martyr Road, houses at the top of The Mount, dwellings on land forming part of school playing fields (e.g. Horseshoe Lane West) and many small-scale infill sites and redevelopments (e.g. New Inn Lane at Burpham). The Guildford Society is concerned that, on the one hand windfall has been omitted, but on the other hand, sites such as 31, 33 and 36 for example (which may historically have come forward as windfall sites) can only be brought forward if suitable alternative locations are found and no such provision is made in the Draft Plan. These points serve to demonstrate many of the shortcomings of the Draft Local Plan which is full of inconsistencies and is difficult to 4

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10 23: The Plaza, Portsmouth Road [122 homes] Site address The Plaza (land between Portsmouth Road and Bury Street), Guildford, GU2 4DH Guildford Town Centre Friary and St Nicolas LSOA GUILDFORD TOWN CENTRE POLICY A1: The Plaza, Portsmouth Road, Guildford [70 homes] Guildford 016B 10

11 Site Maps: Area of significant relative multiple deprivation; Major issues with the living environment particularly outdoors IS THE ALLOCATION ACCEPTABLE? NO, NOT ENTIRELY YES from the perspective of the use. Concerned about the density and the proposed height that this suggests the development will be and its consequent visual impact on the views from the High Street. The site is within the most deprived 20% of LSOAs in the Country for outdoor environment, Description Ownership Area (size) Existing use Guildford Town Centre Friary and St Nicolas Private landowner 0.38 ha Vacant LAA reference Site 134 Key considerations Close proximity to Listed Buildings Within the Millmead and Portsmouth Road Conservation Area Views on the skyline from the Conservation Area Flood risk (a small part of the site is within flood zone 2 medium risk) NEEDS QUALITY PUBLIC REALM to help mitigate the poor external environment locally, as highlighted by the Multiple Deprivation indices COMMENTS The Guildford Society is unhappy with the proposed density for an island site (122 houses on 0.38Ha exceeds 321dpH). Although there are few people (if anyone) who like the view of the two residential towers on the opposite side of Portsmouth Road, this is no reason to seek to build another tall building on this site either to mask or to complement the existing buildings. The Guildford Society would like to understand the assumptions made by Guildford borough Council in its proposed housing provision. 11

12 Ownership Private ownership the land is currently for sale Area (size) 0.38 ha Existing use Vacant last occupied by office buildings How was the site identified? SHLAA (site 134) Considerations Within Guildford Town Centre On the edge of the Core shopping area Within a Conservation Area 12

13 Flood zone 1 (low risk), with small areas on flood zone 2 (medium risk) and flood zone 3 (high risk) on the east side site boundary History of flooding on part of the site Close proximity to Grade II listed buildings on the east side of the site Within 400m to 5km of the Thames Basin Heaths SPA, where the impact of development can be avoided Area of High Archaeological Potential Corridor of the River Wey Risk of contamination Previously developed land Allocation Timescales Opportunities /commentary There is a current planning permission for offices (B1a) on this site (ref: 06/P/01430, 10/P/00803). Housing (C3) 1 5 years This is a previously developed site in Guildford Town Centre close to the railway station and bus station that could deliver new homes (including affordable homes) to help meet the identified need. The development could likely consist of flats, and would need to take account of the close proximity of listed buildings, and potential flood risk. At least 40% of the new homes provided will be affordable homes. The current planning permission for offices could be implemented before it expires in

14 LSOA 25: Land at Bedford Road, Guildford [NOTE this is different from POLICY A2 (right) inasmuch as this excludes the cinema but there is some common land area (see maps)] [120 homes] Site address Bedford Road surface car park, Old Orleans Site maps: restaurant and 20 Bedford Road, Guildford Guildford Town Centre Friary and St Nicolas POLICY A2: Guildford Cinema, Bedford Road, Guildford [0 homes] Area of significant relative multiple deprivation; Guildford 015A Major issues with the living environment particularly outdoors where this LSOA scores in the most deprived 2.5% in the country Areas such as this require a strong focus on their public realm and need to make a contribution towards resolving legacy issues. Is the Allocation Acceptable? NO object to offices this should be housing above commercial around a public square Support pedestrian improvements between railway and town HOUSING is desirable subject to suitable mitigation strategy for flood incidents. There is potential on this site to raise the public realm up above semi-basement parking with commercial uses below residential. NEEDS QUALITY PUBLIC REALM to help mitigate the poor external environment locally, as highlighted by the Multiple Deprivation indices Description Ownership Area (size) Existing use Guildford Town Centre Friary and St Nicolas Guildford Borough Council is the freehold landowner 0.8 ha Cinema (D2), food and drink (A3) and protected open space LAA reference Site 2229 Key considerations High flood risk Public open space Proximity to conservation area and listed buildings 14

15 Ownership Bedford Road surface car park Guildford Borough Council Old Orleans restaurant Guildford Borough Council owns the freehold, and the site is on a long lease to a third party 20 Bedford Road private ownership Area (size) 0.81 ha Existing use Surface car parking (68 short stay spaces and 35 contract spaces), 20 lock up garages, 15

16 auctioneer s building, offices and vacant restaurant. How was the site identified? SHLAA (sites 173, 524 and 2103) Considerations Within the Town Centre Located on the edge of the core shopping area Flood zone 2 and flood zone 3 (medium to high risk), history of flooding Within 400m to 5km of the Thames Basin Heaths SPA, where the impact of development can be avoided Conservation area Previously developed land Risk of contamination Corridor of the River Wey Local Plan (2003) allocated site (policy GT1) for mixed or the following uses; residential, hotel, offices, retail, cultural, leisure, entertainment. Allocation Offices (B1a) and/or housing (C3) with restaurants and cafes (A3) Timescales Opportunities /commentary 6 10 years There is an opportunity for improvements to the riverside and to pedestrian routes between the station and shopping area. A new town plaza environment could be created here, with the benefit of the riverside, cafes, places of work and leisure facilities (cinema). Residential use would be suitable here apart from on ground floors due to flood risk. At least 40% of any new homes provided will be affordable homes. This site would also be a prime location for modern offices, as it is exceptionally well located next to the station. Offices here could provide a headquarters premises for a large employer. 16

17 37 Land between Farnham Road and the Mount [70 homes] Site address Site Maps: Land between Farnham Road and the Mount, alongside the multi storey car park, Guildford Guildford Town Centre Friary and St Nicolas POLICY A3: Land between Farnham Road and the Mount, Guildford [70 homes] Description Ownership Area (size) Existing use Guildford Town Centre Friary and St Nicolas Network Rail 0.64 ha Old quarry and signal box LAA reference Site 2181 Key considerations Vehicular access Close proximity to Guildford railway station Site shape and topography Setting of listed buildings on The Mount Character of the Conservation Area Impact of development on trees Potential contamination Noise impacts, due to proximity to railway lines 17

18 Ownership Network Rail Area (size) 0.64 ha Existing use Old quarry and signal box How was the site identified? SHLAA (site 2181) Considerations Guildford Town Centre Within 400m to 5km of the Thames Basin Heaths SPA, where the impact of development can be avoided 18

19 Allocation Timescales Opportunities /commentary Flood zone 1 (low risk) Area of High Archaeological Potential Partly previously developed land Conservation area Trees on site Housing (C3) 6 10 years There are constraints to development that would need to be addressed as part of a development proposal, particularly in reference to any trees on site and the impact of development on the conservation area. This site is a sustainable location for residential development, with close proximity to the railway station, bus station and shops. At least 40 45% of new homes provided will be affordable homes. 31 BT Telephone Exchange, Leapale Road, Guildford [100 homes] Site address Land between Leapale Lane and Leapale Road, Guildford, GU1 4BD Guildford Town Centre Friary and St Nicolas LSOA POLICY A4: Telephone Exchange, Leapale Road, Guildford [100 homes] Area of significant relative multiple deprivation; Guildford 013C Major issues with the living environment particularly outdoors Description Guildford Town Centre Friary and St Nicolas Ownership BT Area (size) 0.6 ha Existing use Telephone exchange (sui generis) LAA reference Site

20 Site Maps: Is the Allocation Acceptable? YES This property is, however, unlikely to be available for development and, whilst allocated from a spatial planning perspective, this must be seen as potential windfall rather than as a core part of the planned supply. Comments Development of this site needs to be part of a town centre master plan (see comments on Town Centre). Key considerations Heavily developed site, lacking any landscaping or green space On a pedestrian route from North Street to a town centre supermarket 20

21 Ownership Private Area (size) 0.6 ha Existing use Telephone exchange (sui generis) How was the site identified? SHLAA (site 230) Considerations Guildford Town Centre Flood zone 1 (low risk) Within 400m to 5km of the Thames Basin 21

22 Allocation Timescales Opportunities /commentary Heaths SPA, where the impact of development can be avoided Previously developed land Housing (C3) and/or offices (B1a) years and beyond This is a large potential development site within the town centre that could significantly contribute towards future housing supply, including affordable homes or provide new modern offices. If new homes are provided, at least 40% will be affordable homes. 29 Jewsons, Walnut Tree Close [112 homes] Site address Jewsons, Walnut Tree Close, Guildford, GU1 4UB Guildford Town Centre Friary and St Nicolas LSOA POLICY A5: Jewsons, Walnut Tree Close, Guildford [125 homes] Area of significant relative multiple deprivation; Guildford 015A Major issues with the living environment particularly outdoors where this LSOA scores in the most deprived 2.5% in the country Areas such as this require a strong focus on their public realm and need to make a contribution towards resolving legacy issues. Description Ownership Area (size) Existing use Guildford Town Centre Friary and St Nicolas Private 0.64 ha Buildings merchant (sui generis) LAA reference Site 1107 Key considerations Heavily developed site, lacking any landscaping or green space 22

23 Site Maps: Sustainable Movement Corridor Potential contamination Is the Allocation Acceptable? NO NOT ENTIRELY The Guildford Society broadly supports the Guildford Vision Group proposal for a comprehensive development of a new residential quarter in this area, addressing many of the environmental issues highlighted in the Multiple Deprivation Indices. Comments This site must accommodate a new or improved Yorkie s bridge over the railway to facilitate the proposed GTAMS solution land needs to be reserved for this purpose in the Local Plan. Development of this site needs to be part of a town centre and/or Walnut Tree Close master plan There needs to be strong consideration of access if Walnut Tree Close is to be cut in two. The proposed density at dph seems reasonable if part of a comprehensive development. There will be the need to provide alternative employment land. 23

24 Ownership Private ownership Area (size) 0.73 ha Existing use Buildings merchant (sui generis) How was the site identified? SHLAA (site 1107) Considerations Guildford Town Centre Flood zone 1 (low risk) Within 400m to 5km of the Thames Basin Heaths SPA, where the impact of 24

25 Allocation Timescales Opportunities /commentary development can be avoided Corridor of the River Wey Previously developed land Local Plan 2003 Policy M7: Access from Walnut Tree Close to the Railway Station. Site allocation 122 continues to safeguard land for a route section of a new sustainable movement corridor, providing an attractive, landscaped priority pathway for pedestrians, cyclists and buses. The Guildford Town and Approaches Movement Study Strategy Report (Arup, April 2014) sets out the concept and identifies a potential route. Housing (C3) and/or office (B1a) 6 10 years There is an opportunity to provide new homes, including many affordable homes (at least 40% affordable homes), in this sustainable location close to the station. There is potential to incorporate some commercial office as part of a residential led mixed use scheme. Site allocation 122 safeguards land for a route section of a new sustainable movement corridor, providing an attractive, landscaped priority pathway for pedestrians, cyclists and buses. The Guildford Town and Approaches Movement Study Strategy Report (Arup, April 2014) sets out the concept and identifies a potential route. 20 North Street regeneration site [NOTE this is different from POLICY A6 (right) inasmuch as this excludes the Friary Centre but includes Leapale Road Car Park (see maps)] [0 homes] Site address Land bounded by North Street, Onslow Street and Leapale Road, Guildford, Surrey, GU1 Guildford Town Centre POLICY A6: North Street redevelopment, Guildford [200 homes] 25

26 Site Maps: Friary and St Nicolas LSOA Area of significant relative multiple deprivation; Guildford 013C Major issues with the living environment particularly outdoors (see the Guildford Society Land Uses report annexed to this submission) IS ALLOCATION ACCEPTABLE? NO, NOT ENTIRELY MAINLY YES but we object to bringing forward this development without a settled overarching master plan. ALLOCATION SHOULD NOT RULE OUT RESIDENTIAL USE WOULD OBJECT to loss of bus station without a suitable replacement NEEDS QUALITY PUBLIC REALM to help mitigate the poor external environment locally, as highlighted by the Multiple Deprivation indices Description Ownership Guildford Town Centre Friary and St Nicolas Mixed ownership. Guildford Borough Council owns the freehold, and M&G has a long leasehold over much of the site. 26

27 COMMENTS Area (size) 3.47 ha Acceptable use but concerned about justification for amount of Existing use retail proposed the Evidence Base is too old, given the rapid changes in the face of town centre retail, and we are concerned that this needs to be delivered carefully so as not to adversely affect the viability and vitality of the iconic High Street. Residential should be considered if practicable but we would object to residential merely forming a top slice of development. Any integration of residential must create a vibrant living community in the town centre. Development of this site needs to be part of a town centre master plan (see comments on Town Centre). Must have an overriding strategy for a bus station/ interchange for the town centre. In the absence of a suitable viable alternative, the bus station should remain within this site. Retail (comparison), residential flats, restaurants and cafes, offices, bus station, surface car parks, basement car park and servicing, and vacant land LAA reference Site 205 Key considerations Design, vitality and connectivity Maintaining suitable bus interchange facilities in Guildford town centre Listed building at 17 North Street, Guildford Adjacent to Town Centre Conservation area Potential to include land to the east of the identified site, subject to ownership Flood risk Ownership Area (size) Existing use How was the site identified? Guildford Borough Council and private landowner 2.52 ha Surface car parks (short stay), multi storey car park, bar, housing, shops, bank, offices, Citizen s Advice Bureau There is a long standing ambition to redevelop this land. In 2004, planning permission was 27

28 granted for a comprehensive mixed use redevelopment to provide up to a maximum of 170 residential units, shops (Class A1), professional and financial units (Class A2), restaurants and cafes (Class A3), community space (Class D1), replacement bus station, a public square, residential car parking, servicing, plant, the refurbishment of existing Friary Centre and ancillary works. The length of this permission was extended, but has since expired. Considerations Within Guildford Town Centre Most of the site is within the core shopping area Low probability of flooding Includes a Grade II listed building at 17 North Street Not within a conservation area although North Street frontage is opposite the Guildford Town Centre Conservation Area Area of High Archaeological Potential Within 400m to 5km of the Thames Basin Heaths SPA, where the impact of development can be avoided Previously developed land Allocation Retail (A1) with assembly and leisure (D2), restaurants and cafes (A3), non residential institutions (D1), multi storey car park Timescales Opportunities /commentary 6 10 years This is one of the largest development opportunities within Guildford Town Centre s core shopping area. It is a key site for regeneration, improvements to North Street, and the extension of the main shopping area. The primary use of this land will be retail (A1), with other complementary uses. 28

29 24 Land and buildings at Guildford railway station [NOTE this is different from POLICY A7 (right) inasmuch as this includes the land to the west of the station (POLICY A8 (below)) (see maps)] [450 homes] Site address Site Maps: Land at Station View and Station Approach, and to the east of Guildford Park Road, either side of the railway lines, Guildford, GU1 4JY Guildford Town Centre Friary and St Nicolas LSOA POLICY A7: Land and buildings at Guildford railway station, Guildford [350 homes] Area of significant relative multiple deprivation; Guildford 015A Major issues with the living environment particularly outdoors where this LSOA scores in the most deprived 2.5% in the country Areas such as this require a strong focus on their public realm and need to make a contribution towards resolving legacy issues. Is the Allocation Acceptable? NO, NOT ENTIRELY BROADLY ACCEPT THE USES but concern about potential overdevelopment of the site and urge caution. The site is within the most deprived 2.5% of LSOAs in the Country for outdoor environment, NEEDS QUALITY PUBLIC REALM to help mitigate the poor external environment locally, as highlighted by the Multiple Deprivation indices This is a site which Allies & Morrison has shown could provide clear views from the town to the Cathedral, and development height could threaten this. 29

30 Comments: Description Development of this site needs to be part of a town centre master Guildford Town Centre plan (see comments on Town Centre). Friary and St Nicolas The development needs to serve both sides of the town, Ownership Network Rail accommodating a bridge over the river and railway, pedestrian Area (size) 2.2 ha access to the town centre and a bus interchange/stops. Existing use The Guildford Society supports the principle of Allies and Morrison vision of station plaza especially in view of the shortage of quality public realm in the area (see LSOA details). Car parking provision required on both sides of the railway station and surface car parking should be resisted. Nothing should prevent the introduction of rail link to Heathrow We would prefer the development height to be broadly in scale with current buildings. Development if delivered in phases should be masterplanned to ensure the whole development works comprehensively Railway station, including offices and retailing, and associated car and cycle parking LAA reference Site 1171 Key considerations Sustainable Movement Corridor The replacement of Walnut Bridge to reinforce the alternative pedestrian route, and provide a route for cyclists, from the station to town centre away from Bridge Street Potential contamination Heritage and conservation Flood risk (a small part of the site is within flood zone 2 medium risk) Ownership Area (size) Existing use The site is owned by Network Rail. It is one of seven key strategic sites under contract with Solum Regeneration, the joint venture company set up between Network Rail and Kier Property during ha Railway station, transport infrastructure, surface car park (including long stay / commuter parking and parking for adjacent 30

31 How was the site identified? Ranger House), taxi rank, small scale retail and cafes SHLAA (site 171), Local Plan (2003) allocated site (policy GT8) for comprehensive mixed development Considerations Located on the edge of the core shopping area Within the Town Centre Flood zone 1 (low risk), part flood zone 2 (medium risk) Within 400m to 5km of the Thames Basin Heaths SPA where the impact Allocation Timescales Opportunities /commentary of development can be avoided Previously developed land Risk of contamination Corridor of the River Wey Local Plan 2003 Policy M7: Access from Walnut Tree Close to the Railway Station. Site allocation 122 continues to safeguard land for a route section of a new sustainable movement corridor, providing an attractive, landscaped priority pathway for pedestrians, cyclists and buses. The Guildford Town and Approaches Movement Study Strategy Report (Arup, April 2014) sets out the concept and identifies a potential route. Improved transport and interchange facilities to include existing levels of car parking, Housing (C3) and hotel (C1) and office (B1a) with restaurants and cafes (A3) and/or assembly and leisure (D2) and/or retail (A1) 6 10 years This is a very sustainable location for new development. The site can provide a mix of uses, including new homes of which at least 40% will be affordable homes. The primary use 31

32 will be housing (C3), offices (B1a) and hotel (C1) with some smaller scale uses (A3, D2 and A1). Site allocation 122 safeguards land for a route section of a new sustainable movement corridor, providing an attractive, landscaped priority pathway for pedestrians, cyclists and buses. The Guildford Town and Approaches Movement Study Strategy Report (Arup, April 2014) sets out the concept and identifies a potential route. INCLUDED IN 24 ABOVE INCLUDED IN 24 ABOVE POLICY A8: Land west of Guildford railway station, Guildford Park Road, Guildford [0 homes] Description Ownership Area (size) Existing use Guildford Town Centre Friary and St Nicholas Guildford Borough Council 1.02 ha Surface car park, footbridge access to the train station, Network Rail operational 32

33 buildings, vehicular access to Farnham Road car park, railway sidings LAA reference Site 2332 Key considerations Noise (proximity to railway lines) Potential contamination and remediation 33

34 LSOA 30: 77 to 83 Walnut Tree Close, Guildford [34 homes] Site address Site Maps: 77 to 83 Walnut Tree Close, Guildford, GU1 4UQ Guildford Town Centre Friary and St Nicolas POLICY A9: 77 to 83 Walnut Tree Close, Guildford [0 homes] Area of significant relative multiple deprivation; Guildford 015A Major issues with the living environment particularly outdoors where this LSOA scores in the most deprived 2.5% in the country Areas such as this require a strong focus on their public realm and need to make a contribution towards resolving legacy issues. Is the Allocation Acceptable? NO The Guildford Society broadly supports the Guildford Vision Group proposal for a comprehensive development of a new residential quarter in this area, addressing many of the environmental issues highlighted in the Multiple Deprivation Indices. Comments: Development of this site needs to be part of a town centre and/or Walnut Tree Close master plan Description Ownership Area (size) Existing use Guildford Town Centre Friary and St Nicolas Private 0.37 ha Office (B1a), light industrial (B1c) and warehouses (B8) LAA reference Site 8 Key considerations Corridor of the River Wey Flood risk Previously developed land close to Guildford railway station 34

35 There needs to be strong consideration of access if Walnut Tree Close is to be cut in two. Initial proposals by the Guildford Vision Group show the river banks as being suited to a linear riverside park as part of a comprehensive regeneration of this area. This is an important riverside site and provides exceptional scope to provide excellent public open space currently deficient per the LSOA data. Any development on this site must be strategically designed to manage flood water and flooding. (See Green Blue Infrastructure response) NB EA objection to 13/P/ In the absence of a master plan under the terms of NPPF there should be a presumption against development Ownership Private Area (size) 0.37 ha Existing use Offices (B1a) and warehouses (B8) How was the site identified? SHLAA (site 8) Considerations Guildford Town Centre 35

36 Allocation Timescales Opportunities /commentary Corridor of the River Wey History of flooding Flood zone 3 (high risk) Within 400m to 5km of the Thames Basin Heaths SPA, where the impact of development can be avoided Previously developed land Housing (C3) and offices (B1a), or Offices (B1a) and storage and distribution (B8), or Offices (B1a) 6 10 years Walnut Tree Close is an area of likely change over the plan period. Redevelopment here would help to improve the character of this area, however, any proposal must address the risk of flooding, and ensure that development does not increase flood risk and takes all available opportunities to reduce flood risk on site and elsewhere. If new homes are provided, at least 40% will be affordable homes. NOT IN THE 2014 DRAFT AS A SPECIFIC SITE (ALTHOUGH THE SUSTAINABLE MOVEMENT CORRIDOR WAS REFERRED TO SEVERAL TIMES) POLICY A10: Land for Sustainable Movement Corridor Town Centre Phase 2, off Walnut Tree Close, Guildford [0 homes] Description Guildford Town Centre 36

37 Friary and St Nicolas Ownership Part private and part unregistered Area (size) 0.3 ha Existing use Buildings merchant (sui generis) and access road to Yorkie s Bridge LAA reference N/A Key considerations Sustainable Movement Corridor Potential contamination 37

38 27 Guildford Park Car Park [110 homes] Site address Land between the railway lines and Guildford Park Avenue, Guildford Guildford Town Centre Onslow LSOA POLICY A11: Guildford Park Car Park, Guildford Park Road, Guildford [160 homes] 38

39 Site Maps: Area of relative multiple deprivation; Guildford 015C Issues with the living environment particularly outdoors and in particular for old person deprivation where this LSOA scores in the most deprived 20% in the country. Is the Allocation Acceptable? NO The housing use is acceptable but there is a need for public realm and education. The car parking should be developed elsewhere and this site replanned as part of the town centre master plan to enable the new road proposals as suggested by the Guildford Vision Group. THERE WILL BE URGENT NEED FOR A PRIMARY SCHOOL IN THIS AREA TO SERVE EXISTING AND NEW HOMES Comments: This site must accommodate a new bridge over the river and railway to displace traffic from the town centre and riverside Description Ownership Area (size) Existing use Guildford Town Centre Onslow Guildford Borough Council 2.12 ha Surface car park and garages LAA reference Site 178 Key considerations Noise (proximity to railway lines) Potential contamination and remediation 39

40 Whilst this is important land for residential development, there also needs to be land identified and allocated for community (education). We have suggested that the site numbered 37 (Land between Farnham Road and The Mount) would lend itself better to use as a multi-storey car park. This could allow the entirety of the Guildford park Car Park site to be public realm, housing and a primary school. Care needs to be taken in determining development densities as well as the need for great public realm and attractive connections between the town centre and the University and Cathedral. Allocation and development of this site needs to be part of a town centre master plan Ownership Area (size) Existing use Guildford Borough Council 1.97 ha How was the site identified? SHLAA (site 178) Considerations Surface car park (400 long stay spaces) and garages (118) 40

41 Within the Town Centre Flood zone 1 (low risk) Within 400m to 5km of the Thames Basin Heaths SPA, where the impact of development can be avoided Previously developed land Allocation Timescales Opportunities /commentary Housing (C3) and parking 1 5 years There is an opportunity to provide new homes, including many affordable homes (at least 40% of the new homes provided will be affordable homes), in this sustainable location close to the station, whilst continuing to provide public parking. 26 Bright Hill surface car park and Adult Education Centre [NOTE this is different from POLICY A12 (right) inasmuch as this includes Adult Education Centre and Robin hood Pub (see maps)] [77 homes] Site address Land between Bright Hill/Harvey Road and Sydenham Road, Guildford, GU1 3RX Guildford Town Centre Holy Trinity LSOA POLICY A12: Bright Hill Car Park, Sydenham Road, Guildford [60 homes] Area of significant relative multiple deprivation; Guildford 013E Description Ownership Area (size) Existing use LAA reference Site 174 Key considerations Visually prominent elevated site Guildford Town Centre Holy Trinity Guildford Borough Council 0.47 ha Temporary car park 41

42 Site Maps: Major issues with the living environment particularly outdoors where this LSOA scores in the most deprived 5% in the country Is the Allocation Acceptable? NO, NOT ENTIRELY Whilst the land would appear to lend itself to car parking inset into the hillside and residential development above, the allocation of 77 units is not explained. The Guildford Society is concerned about the proposed loss of education space and no reference is made to the future of the attractive former school buildings on the site of the Adult Education Centre which gives Sydenham and Harvey Roads a lot of their character. Comments: Need to see retention of education facility on this site. Appears to be scope to provide car parking cut into the hill and greater residential numbers. Care will need to be taken with views into and out of the site Views Conservation area Quantity of public parking Setting of locally listed buildings 42

43 Ownership Area (size) Existing use Guildford Borough Council and Surrey County Council 0.88 ha Surface car park (short stay 121 spaces) and education (D1) How was the site identified? SHLAA (site 174 and 88) 43

44 Considerations Within the Town Centre Located on the edge of the core shopping area Flood zone 1 (low risk) Within 400m to 5km of the Thames Basin Heaths SPA, where the impact of development can be avoided Conservation area Area of High Archeological Potential Previously developed land Topography varied levels on the site Locally listed building (Adult Education Centre) Local Plan policy H2 Housing Proposal (Bright Hill Car Park) Allocation Timescales Opportunities /commentary Residential (C3) and public car parking years Combined, these sites provide a potential development opportunity that can provide new homes within the town centre and retain public parking to support this side of the Town Centre. To achieve this, whilst retaining views from this location of the town and cathedral, may require the loss of the locally listed building. This would be considered as part of a potential development proposal. At least 40% of the new homes provided will be affordable homes. 44

45 Sites omitted from 2016 Draft that featured in the 2014 Consultation Draft 21: Portsmouth Road Surface Car Park [0 homes] 22: 1 and 2 Station View [177 homes (under construction)] 28: York house, Chertsey Street [20 homes] 32: Buryfields House [28 homes] 33: Guildford Crown Court [94 homes] 34: Debenhams [150 homes] 35: Dolphin House, North Street [44 homes] 36: Guildford Borough Council offices, Millmead [52 homes] 38: Guildford Library, North Street [18 homes] 39: Bus depot, Leas Road [50 homes] 40: Guildford Methodist Church [25 homes (in progress)] 41: Pembroke House, Mary Road [26 homes] 42: Riverside Business Park, Walnut Tree Close [60 homes] 50 Kernal Court, Walnut Tree Close, Guildford [136 homes] Site address Kernal Court, Walnut Tree Close, Guildford, GU1 4UD Guildford Urban Area Friary and St Nicolas LSOA Guildford Urban Area POLICY A13: Kernal Court, Walnut Tree Close, Guildford [100 homes] 45

46 Site Maps: Area of significant relative multiple deprivation; Guildford 015A Major issues with the living environment particularly outdoors where this LSOA scores in the most deprived 2.5% in the country Areas such as this require a strong focus on their public realm and need to make a contribution towards resolving legacy issues. Is the Allocation Acceptable? NO NOT ENTIRELY The Guildford Society broadly supports the Guildford Vision Group proposal for a comprehensive development of a new residential quarter in this area, addressing many of the environmental issues highlighted in the Multiple Deprivation Indices. Comments: Development of this site needs to be part of a town centre and/or Walnut Tree Close master plan There needs to be strong consideration of access if Walnut Tree Close is to be cut in two. Description Ownership Area (size) Existing use Guildford Urban Area Friary and St Nicolas Private 0.55 ha Warehouse (B8) and industrial (B1c) LAA reference Site 2183 Key considerations This area of Guildford is currently changing in character from primarily industrial to residential (including student accommodation), through a series of planning permissions on individual sites Proximity to the Corridor of the River Wey Flood risk in this area. Although the site is outside of the modelled flood extents for flood zone 2 and 3 (medium and high risk of fluvial flooding), land in relative close proximity to this site is within flood zone 2 and 3 46

47 The proposed density at 247dpH may be reasonable if part of a comprehensive development but, as an isolated development, seems too high bearing in mind the substantial issues with outdoor environment this is also completely different from the density suggested in the Local Plan for the near adjacent site 29. There will be the need to provide alternative employment land. Ownership Private Area (size) 0.55 ha Existing use Warehouse (B8) and industrial (B1c) How was the site identified? SHLAA (site 2183) Considerations Guildford Urban Area History of flooding Flood zone 1 (low risk) and part flood 47

48 Allocation Timescales Opportunities /commentary zone 2 (medium risk) to the north east of the site Within 400m to 5km of the Thames Basin Heaths SPA, where the impact of development can be avoided Previously developed land Corridor of the River Wey Housing (C3) and/or student accommodation and/or offices (B1a) 1 5 years Walnut Tree Close is an area of likely change over the plan period. Redevelopment here would help to improve the character of this area, however, any proposal must address the risk of flooding, and ensure that development does not increase flood risk and takes all available opportunities to reduce flood risk on site and elsewhere. At least 40% of any new homes provided will be affordable homes. 52 Wey Corner, Walnut Tree Close, Guildford [35 homes] Site address Wey Corner, Walnut Tree Close, Guildford, GU1 4TT Guildford Urban Area Friary and St Nicolas LSOA POLICY A14: Wey Corner, Walnut Tree Close, Guildford [35 homes] Description Guildford Urban Area Friary and St Nicolas 48

49 Site Maps: Guildford 015A Ownership Private Area (size) 0.38 ha Area of significant relative multiple deprivation; Existing use Major issues with the living environment particularly outdoors where this LSOA scores in the most deprived 2.5% in the country Areas such as this require a strong focus on their public realm and need to make a contribution towards resolving legacy issues. Is the Allocation Acceptable? NO Distribution (B8) is not a suitable use in this area The Guildford Society broadly supports the Guildford Vision Group proposal for a comprehensive development of a new residential quarter in this area, addressing many of the environmental issues highlighted in the Multiple Deprivation Indices. SITE BETWEEN 42 & 52 NOT EVEN IDENTIFIED ON THE PLAN should provide a direct pedestrian & cycle route from Yorkie s bridge to the tow path (potential link to Dapdune Wharf) Comments: Development of this site needs to be part of a town centre and/or Walnut Tree Close master plan There needs to be strong consideration of access if Walnut Tree Close is to be cut in two. Initial proposals by the Guildford Vision Group show the river banks as being suited to a linear riverside park as part of a comprehensive regeneration of this area. This is an important riverside site and provides exceptional scope to provide excellent public open space currently deficient per the LSOA data. Any development on this site must be strategically designed to manage flood water and flooding. (See Green Blue Infrastructure response) NB EA objection to 13/P/ In the absence of a master plan under the terms of NPPF there should be a presumption against development Trade sales (a sui generis use) with a storage and distribution use (Class B8) and business use (B1) LAA reference Site 2226 Key considerations Proximity to the River Wey Corridor of the River Wey Flood risk 49

50 Ownership Private Area (size) 0.38 ha Existing use Storage and distribution (B8) How was the site identified? SHLAA (2226) Considerations Guildford Urban Area Corridor of the River Wey Within 400m to 5km of the Thames 50

51 Allocation Timescales Opportunities /commentary Basin Heaths SPA, where the impact of development can be avoided Flood zone 2 (medium risk) and flood zone 3 (high risk) History of flooding Previously developed land Housing (C3) and/or offices (B1a) or storage and distribution (B8) 6 10 years Walnut Tree Close is an area of likely change over the plan period. Redevelopment here would help to improve the character of this area, however, any proposal must address the risk of flooding, and ensure that development does not increase flood risk and takes all available opportunities to reduce flood risk on site and elsewhere. If new homes are provided, at least 40% will be affordable homes. 51

52 43 Land at Guildford Cathedral, Guildford [168 homes] Site address Site Plans: Land at Guildford Cathedral, Alresford Road, Guildford, GU2 7TN Guildford Urban Area Onslow LSOA POLICY A15: Land at Guildford Cathedral, Alresford Road, Guildford [100 homes] Area of relative multiple deprivation; Guildford 015C Issues with the living environment particularly outdoors and in particular for old person deprivation where this LSOA scores in the most deprived 20% in the country. Is the Allocation Acceptable? UNCERTAIN of the viability and suitability of this site for housing particularly in the numbers suggested. The distant views of the Cathedral must not be affected by development. Given the poor overall score in terms of outdoor environment in the wider area, it is important to ensure that, as part of the proposed development, the remaining green spaces around the Cathedral are preserved in perpetuity. Development heights should not be such as to obscure the base of the Cathedral and a skirt of green from key vantage points. Description Ownership Area (size) Existing use Guildford Urban Area Onslow Guildford Cathedral 3.28 ha Open space and residential properties LAA reference Site 50 Key considerations The setting of the grade II* Listed Building, on approaches and access Views, particularly from the setting of town centre Conservation Areas and listed buildings Impact of scale, heights and form of development Impact of any development on green mound and silhouette of the Cathedral both day and night time from wide surrounding area Loss of open space Surrounding urban context 52

53 Comments: Intuitively, this is a site which should remain undeveloped. The Guildford Society is very conscious of the Dean & Chapter s aspirations to help preserve the Grade 1 Listed Cathedral without having the type of endowment income available to older Cathedrals. This may constitute very special circumstances but not to the extent any amount of harm is acceptable. In any event, this site should include the provision or safeguarding of a route for a public walkway (integrated with the Guildford Park Car Park site) from the station and town centre to the Cathedral as none currently exists. The OS data shows the Cathedral is at 78m Above Ordnance Datum (AOD) Views from, say, the top of Poltimore Road/Irwin Road are from an AOD height of ca.80m, views from the town centre and other key vantage points are from much lower (eg.,the specially made cut through the Chantry woods (ca 50m AOD) and must be maintained. There are also important views from Merrow Downs, Pewley Hill and the Hog s Back Ownership Dean and chapter of Guildford Cathedral Area (size) 3.28 ha Existing use Open space How was the site identified? SHLAA (site 50) Considerations Guildford Urban Area 53

54 Allocation Timescales Opportunities /commentary Flood zone 1 (low risk) Within 400m to 5km of the Thames Basin Heaths SPA, where the impact of development can be avoided Protected Open Space Adjoining a Grade II Listed Building Housing (C3) 1 5 years Not in 2014 Draft Site Allocation Redevelopment here will provide new homes (including at least 40 45% affordable homes) and help support the future of Guildford s Cathedral. Development of this site will need to be sensitively carried out in view of the settings of a Grade II Listed Building, and consideration of the level of provision of Protected Open Space in the area. POLICY A16: Land between Gill Avenue and Rosalind Franklin Close, Guildford [450 homes] Description Ownership Area (size) Existing use Guildford Urban Area Onslow Royal Surrey County Hospital 2.36 ha Residential (C3) 54

55 LAA reference Site 2331 Key considerations Accessibility for emergency vehicles Making efficient use of the site There are 389 existing properties on this site 55

56 Not in 2014 Draft Site Allocation POLICY A17: Land south of Royal Surrey County Hospital, Rosalind Franklin Close, Guildford [0 homes hospital-related development] Description Ownership Area (size) Existing use Guildford Urban Area Onslow Royal Surrey County Hospital 1.3 ha Temporary car park for hospital use LAA reference Site 131 Key considerations Usage of temporary car park Impact on local road network 56

57 57

58 47 Guildford College, Stoke Road, Guildford [NOTE this is different from POLICY A18 (right) inasmuch as this includes the entire Guildford College site (see maps)] [0 homes Education Uses] Site address Site maps: Guildford College, Stoke Road, Guildford, GU1 1EZ Guildford Urban Area Christchurch LSOA POLICY A18: Land at Guildford College, Guildford [100 homes] Guildford 013A Outdoor environment and access to housing are the two notable elements of relative deprivation in this LSOA. Despite this, more than half of the households fall within Band D for Council Tax. Just under 50% of homes are family households, but more than 55% are flats or maisonettes. Is the Allocation Acceptable? YES Comments: The Guildford Society is keen to support the excellent work of the Guildford College. It does, however, have some concerns about the impact of intensification of the use of the site without parameters there is, for example, a clear desire and need to preserve openness on the edge of Stoke Park and green spaces adjacent to Stoke Road, one of the approach roads to Guildford Town Centre. Description Ownership Area (size) Existing use Guildford Urban Area Christchurch Guildford College 0.7 ha Education (D1) LAA reference Site 2323 Key considerations Close proximity to Stoke Park Boundary treatments backing onto Stoke Park Impact of development on setting of listed buildings, parkland setting and views Lido Road area setting of locally listed building and listed war memorial on green island Protected Open Space 58

59 Ownership Area (size) Existing use How was the site identified? Considerations Guildford College 4.8 ha Education (D1) and associated uses Local Plan issues and options consultation Guildford Urban Area Flood zone 1 (low risk) Within 400m to 5km of the Thames 59

60 Allocation Timescales Opportunities /commentary Basin Heaths SPA, where the impact of development can be avoided Previously developed land Some land is protected open space Education (D1) and associated uses During the plan period There are opportunities to provide an intensified education use on this site, to enable the college to meet its future needs. 51 Former car showroom, Aldershot Road, Guildford [38 homes] Site address Former car showroom (Tony Purslow Site Maps: Limited), Aldershot Road, GU2 8BX Guildford Urban Area Westborough LSOA POLICY A19: Land at Westway, off Aldershot Road, Guildford [38 homes] Guildford 009B This LSOA scores poorly for education and skills among young people). Almost 40% comprises social rented housing The site borders Guildford 012D which is the only LSOA in the Borough whose Index of Multiple Deprivation overall places it in the poorest 25% in the Country: Description Guildford Urban Area Westborough Ownership The land is for sale Area (size) 0.56 ha Existing use Temporary private car park LAA reference Site 34 Key considerations With regards to rights and easements, an area at the entrance of the site has full and free passage and running of services, the right to pass and re-pass and the right to park a maximum of six motor vehicles in the allocated parking spaces, as long as the allotments are in use. A design of a development scheme needs to take this into account 60

61 Is the Allocation Acceptable? YES Providing that proper regard is had to contributing towards the resolution of local deprivation issues. Consideration should also be given to opportunities to provide training and skilling for young people Comments: The Guildford Society has no particular specific comments in respect of this site Ownership Private Area (size) 0.47 ha Existing use Temporary private car park How was the site identified? SHLAA (site 34) Considerations Guildford Urban Area Flood zone 1 (low risk) Within 400m to 5km of the Thames Basin Heaths SPA, where the impact 61

62 Allocation Timescales Opportunities/ Commentary of development can be avoided Risk of contamination Previously developed land Housing and/or specialist housing (C3) 6 10 years This is a vacant site that is in a sustainable location for new homes. At least 40% of any new homes provided will be affordable homes. 46 Former Pond Meadow School, Guildford [20 homes] Site address Site Maps: Former Pond Meadow School, Pond Meadow, Guildford, GU2 8LG Guildford Urban Area Westborough LSOA POLICY A20: Former Pond Meadow School, Pond Meadow, Guildford [0 homes] Guildford 012C This LSOA scores particularly high in terms of deprivation for young persons education (poorest 2.5% in the country) and skills (poorest 10% in the country) and for young persons deprivation (poorest quartile). Clearly there is a need for spatial planning in this area to improve the prospects for young people and training for those of working age. Description Ownership Area (size) Existing use Guildford Urban Area Westborough Surrey County Council 0.6 ha Vacant school buildings (D1) LAA reference 1584 Key considerations Community benefit Vacant site Protected open space 62

63 Is the Allocation Acceptable? PROBABLY, YES but see Comments Comments: The deprivation scores for the surrounding area (dating back to 2010) highlight a need for training and education facilities. Perhaps it would be possible to work with the Independent Schools, The County Education Authority, the University and Guildford College to establish whether there is scope to develop a vocational training centre perhaps even for building trades to support the amount of housing proposed in the Draft Local Plan. Attention should be given to such needs when determining applications and assessing the level of contributions for CIL, affordable homes and residual s106 agreements. Ownership Surrey County Council Area (size) 0.6 ha Existing use Vacant school buildings (D1) How was the site identified? SHLAA (site 1584) Considerations Guildford Urban Area Flood zone 1 (low risk) Within 400m to 5km of the Thames 63

64 Allocation Timescales Opportunities /commentary Basin Heaths SPA, where the impact of development can be avoided Previously developed land Partially protected open space Housing and/or specialist housing (C3) and/or student accommodation, and/or non residential institution (D1) including community facilities years This is a vacant site. Redevelopment here will provide new homes (including at least 40% affordable homes), and could also provide a community facility if required. 104 Land at Westborough allotments, Guildford [0 homes allotments] Site address Land at Westborough allotments, Woodside Road, Guildford Guildford Urban Area Westborough LSOA POLICY A21: Land at Westborough allotments, Guildford [0 homes] Description Guildford Urban Area Westborough Ownership Guildford Borough Council Area (size) 3 ha Existing use Open space and allotments LAA reference Site 176 Key considerations Protected open space Guildford 012D This is the only LSOA in the Borough whose Index of Multiple Deprivation overall places it in the poorest 25% in the Country. 64

65 Site Maps: Is the Allocation Acceptable? YES Comments: The previous allocation would have deprived the area of an important amenity. 65

66 Ownership Guildford Borough Council Area (size) 0.48 ha Existing use Open space and allotments How was the site identified? Local Plan (2003) Considerations Protected open space Within 400m 5km of a Special Protection Area Guildford urban area 66

67 Allocation Timescales Opportunities/ Commentary Local Plan (2003) policy H3 (Housing and open space) Allotments 1 5 years Although this site was allocated for housing and open space in the 2003 Local Plan (policy H3), housing development was not been pursued by the landowner (the Council) on this site, and it is widely known that the local residents would prefer for this site to be used for additional allotments rather than housing. Although there is a considerable need for housing, particularly in sustainable locations such as the urban areas, housing is not feasible on this site. Allotments are the preferred use of this site. 61 Land north of Keens Lane, Guildford [140 homes] Site address Land between Tangley Lane, Keens Lane, Worplesdon Road, Guildford Guildford Urban Area Worplesdon LSOA POLICY A22: Land north of Keens Lane, Guildford [140 homes] Description Guildford Urban Area Worplesdon 67

68 Site Maps: Guildford 005C This LSOA is in the most deprived 5% in the country for affordability of homes. 46% of homes in the LSOA are Band G or higher. Is the Allocation Acceptable? YES The Guildford Society recognizes the proposal to provide a Care Home on the part of the site within 400m of a Thames Basin Special Protection Area. The need to do so says more about the SPA regulations than good spatial planning and it will be essential to ensure that the Care Home use is appropriate in this location and not merely making use of an otherwise unusable part of the site. Comments: The Guildford Society generally supports suggested land use(s)/proposal. Due to the high level of unaffordability of homes in this area, it will essential to ensure the full provision of affordable homes as part of any development. Ownership Area (size) Existing use Private 5.25 ha Fields, grazing and stables LAA reference Site 126 Key considerations Impact of development on the Thames Basin Heaths SPA Setting of a listed building 68

69 Ownership Area (size) Existing use How was the site identified? Considerations Private 5.25 ha Fields, grazing and stables Green Belt and Countryside Study (part of potential development area J3) Currently Green Belt 69

70 Allocation Timescales Opportunities /commentary Partly within 400m of the Thames Basin Heaths SPA, partly within 400m to 5km of the Thames Basin Heaths SPA, where the impact of development can be avoided Flood zone 1 (low risk) Greenfield Interventions will be required which address the potential highway performance issues which could otherwise result from the development. Housing (C3) and care home (C2) 1 5 years This site could provide new homes (of which at least 45% will be affordable housing) and a care home (approximately 50 beds). The care home would be located in the area of the site within 400 metres of the Thames Basin Heath SPA. 65 Land north of Salt Box Road, Guildford [0 homes education] Site address Land north of Salt Box Road, west of the railway line, Guildford Guildford Urban Area Worplesdon LSOA POLICY A23: Land north of Salt Box Road, Guildford [0 homes] Description Ownership Area (size) Existing use Guildford Urban Area Worplesdon Private 7.88 ha Field 70

71 Site Maps: Guildford 005C This LSOA is in the most deprived 5% in the country for affordability of homes. 46% of homes in the LSOA are Band G or higher. Is the Allocation Acceptable? NO PROBABLY NOT Whilst The Guildford Society recognizes the need to provide a new secondary school, this needs to be in a location with excellent accessibility on various forms of transport. The location of a school in a clearing in the woods has not been shown to meet that criterion. NOTE: THE SCHOOL DOES NEED TO GO SOMEWHERE AND SOME EASILY ACCESSIBLE LAND IDENTIFIED FOR HOUSING ELSEWHERE MAY NEED TO BE SET ASIDE FOR EDUCATIONAL USE Comments: This use needs to be seriously and critically rethought. Spatial planning is not simply about identifying a space and seeking to fill it with a use for which no other site has been found. There is no indication from the Infrastructure Baseline as to what catchment the school would be expecting to serve and, indeed, whether it would entirely meet the need of the increased population in the proposed Guildford Urban Area extensions and infilling. The clearing in the woodlands should be preserved within the Green Belt. Failing that, the site may be suitable for business use annexed to Slyfield or even possibly for Traveller pitches. LAA reference Site 2018 Key considerations Impact of development on the Thames Basin Heaths SPA (the site is within 400m) Impact of development on the surrounding Site of Special Scientific Interest (SSSI) Provision of car parking 71

72 Ownership Private Area (size) 7.88 ha Existing use Field How was the site identified? Green Belt and Countryside Study (potential development area A4) Considerations Currently Green Belt Greenfield site Flood zone 1 (low risk) 72

73 Allocation Timescales Opportunities /commentary Within 400m of the Thames Basin Heaths SPA An Appropriate Assessment may be required at project level Site almost surrounded by Site of Special Scientific Interest (SSSI) Education (D1) secondary school of at least five forms of entry 6 11 years and years Potential for new secondary school to serve increased need in the western part of the borough Potential access to the site from where Grange Road meets Salt Box Road, with a possible new junction. 73

74 48 Slyfield Area Regeneration Project (SARP) [1,000 homes] Site address Site Maps: The sewage treatment works and land between Slyfield industrial estate and the A3, Guildford Guildford Urban Area Stoke LSOA POLICY A24: Slyfield Area Regeneration Project, Guildford [1,000 homes] Guildford 005F Whilst the LSOA data is not particularly relevant to the proposed allocation, it is worth noting that around 85% of homes in the LSOA are in Band F or above Is the Allocation Acceptable? YES BUT The Guildford Society broadly supports the emerging proposals floated by the Guildford Vision Group for a comprehensive extension of the Slyfield area to accommodate: Displaced businesses from Walnut Tree Close and Woodbridge Meadows Park & Ride SANG The expansion will require the four-way junction on the A3 (as noted at Site 59 above) Description Guildford Urban Area 74

75 See indicative plan below Stoke Ownership The land is owned principally by Guildford Borough Council and Thames Water with Surrey County Council having a minority interest. Area (size) 40 ha Existing use Sewage treatment works, former landfill site, Council depot, community hall and allotments LAA reference Site 245 Key considerations Allotments Flood Risk Design Green Infrastructure The plan above shows (in orange) the proposed expansion of Slyfield to the north, some of which is included in Site 48. Comments: The GBCS identified a 200m strip of land separating Jacobs Well from the Guildford Urban Area. The Guildford Society suggests that a permanent strip of bunded woodland could be created to demarcate the boundary, but that the remainder of the strip and the area above the areas of flood risk should be capable of significant expansion. A new four-way A3 junction and the proposed GTAMS golden thread bus, cycle and pedestrian link from Slyfield through the town centre and to the Surrey Research Park should enable a much more viable expansion of Slyfield and contribute to a modal shift to help reduce the number of cars on our roads. Ownership Area (size) Existing use How was the site identified? SHLAA (site 245) Surrey County Council, Thames Water and Guildford Borough Council 40 ha Sewage treatment works, former landfill site, Council depot and allotments 75

76 Considerations Allocation Guildford Urban Area Flood zone 1 (low risk) and flood zone 2 (medium risk). An initial flood risk assessment shows that none of the site falls within flood zone 3 Within 400m to 5km of the Thames Basin Heaths SPA, where the impact of development on the SPA can be avoided Previously developed land Corridor of the River Wey Protected open space (south west of site) Contaminated land (open landfill). Detailed studies have been undertaken and further work is ongoing. Allotments Community hall Adjacent to proposed strategic employment site Infrastructure requirements will include a Clay Lane Link Road, which could be delivered in two phases, which will connect to the Local Road Network Interventions will be required which address the potential highway performance issues which could otherwise result from the development. Housing (C3) and Traveller pitches (sui generis) Employment Offices (B1a), Research and development (B1b), Light industrial (B1c), general industrial (B2), storage and distribution (B8) A new council waste management 76

77 Timescales Opportunities /commentary depot (relocated on the site) Waste facilities the northern area of approximately 11ha is allocated in Surrey Waste Plan 2008 for nonthermal waste uses. A new sewage treatment works (relocated within the site) Upgraded primary school and financial contributions towards secondary school expansions A local retail centre years This is a strategic development site, providing opportunities for approximately 1,000 new homes and employments uses in the urban area. At least 40% of new homes provided will be affordable homes. A planning application for phase one of the Clay Lane Link Road is imminent. This will be within the area shown on site allocation

78 59 Gosden Hill Farm, Guildford [The site at Policy A25 includes an additional area of frontage onto the A3 when compared to 2014 site 59] [2,000 homes] Site address Land to the north east of Guildford, Site Maps: Merrow Lane, Merrow, Guildford Guildford urban area Burpham and Clandon and Horsley LSOA POLICY A25: Gosden Hill Farm, Merrow Lane, Guildford [2,000 homes] Guildford 008B and Guildford 001A 78

79 Guildford 008B Affordability is the most significant issue in this LSOA. Guildford 001A This is a large LSOA covering 5.7% of the Borough. 90% of the LSOA area is Green Space. The principal issue is the lack of affordability of housing where this LSOA ranks in the most deprived 5% in the country. Is the Allocation Acceptable? NO The Society does not support any development including P&R north of the east-west tree line dividing the site. Ownership Area (size) Existing use How was the site identified? Considerations Private 89 ha Farmland Green Belt and Countryside Study (potential development areas C1 and C2), SHLAA (site 46) Currently Green Belt, adjoining the This can be summarized by reference to the Green Belt & Countryside Report where development should NOT be permitted on PDA C2. Description Ownership Area (size) Existing use Guildford Urban Area Burpham and Clandon and Horsley Private 89 ha Farmland LAA reference Site 46 Key considerations Some Tree preservation orders on site Borders a Site of Nature Conservation Importance (SNCI) to the east of the site Part of this site has been designated as a 79

80 urban area strategic employment site and is Comments: Greenfield land expected to deliver a significant amount The Society does not support any development including P&R north Flood zone 1 (low risk) of employment uses. of the east-west tree line dividing the site. (GBCS Potential Within 400m and 5km of the Thames Burpham Neighbourhood plan Development Area C2) Basin Heaths SPA Some Tree preservation orders on site Development north of the line would impact adversely on the openness of the views on the approach to the town. Borders a Site of Nature Conservation Importance (SNCI) to There are substantial pluvial flooding issues that already affect the east of the site Burpham and the land at C2 often ponds at its lowest points in A very small strip of land at the north heavy rain. of the site bordering the A3 is good (classification 3a) agricultural land of which an even smaller area is very good (classification 2). The rest of the The development of any of this land needs to have improved overall access to and from the A3. There consequently needs to be a reservation of land and policy support in the Local Plan for a 4- way all-movement A3 junction. land is moderate agricultural land (grade 3b). Without improved access the impact on traffic in Burpham and on Part of site a strategic employment London Road will be severe and no development should be site permitted. Infrastructure requirements could Development of the southern half of the site should include a include a relocated A3 southbound railway station and the land should be reserved for that purpose off slip, a new A3 southbound on slip and connections to the Local Road Network. Interventions will be required which address the potential highway performance issues which could otherwise result from the development. The Infrastructure Delivery Schedule identifies the locations on the Local Highway Network and the Strategic Highway Network which could be expected to experience the most significant The openness of the site in the Green Belt fronting the A3 will be potential highway performance seriously harmed by development which will adversely affect the issues, in the absence of mitigating soft green edge of Guildford on the north side. interventions, from development of this site. Other supporting infrastructure must The Society strongly believes development of this portion of site 59 (C2 in the GBCS Report) should be resisted. be provided on the site, including a To the extent that the area designated C1 in the GBCS Report is not new two form entry primary school, viable or would cause irreconcilable issues in Burpham and having local retail centre, GPs surgery, regard to the emerging Neighbourhood Plan for Burpham the site 80

81 Allocation Timescales Opportunities /commentary community building, open space should not be allocated and the Green belt boundary left as it is including playgrounds, playing fields today. and allotments, Suitable Alternative The formation of a four-way junction (subject to Highways Agency Natural Green Space (SANG), a new confirmation and all technical due diligence) should be created so Park and Ride facility, a new rail as to give access to the Slyfield area and the A320 without station possibly partly on the site for adversely impacting the main population centre of Burpham, and so Merrow on the New Guildford Line. as to relieve traffic on both the A320 at Slyfield and on the London Reducing surface water flood risk, Road between Burpham and Guildford. potentially with balancing pond(s), on site Sustainable Urban Drainage System (SUDs) Appropriate assessment required at project level to consider impact on the Thames Basin Heath Special Protection Area (SPA). Housing (C3), Traveller pitches (sui generis), employment uses (B1a, B1b and B1c), Park and Ride, railway station, open space, education, local retail centre (A1, A2 and A3), community and health services buildings (D1). 1 5, 6 10 and years This is a strategic development site that can accommodate a mix of uses, primarily residential (up to 2000 homes, including at least 45% affordable homes, and eight Traveller pitches), creating a mixed sustainable community. Part of this site has been designated as a strategic employment site and is expected to deliver a significant amount of employment uses. Development could facilitate the delivery of a new Park and Ride facility on the site and a new rail station, possibly partly or wholly on the site, for Merrow on the New Guildford Line. 81

82 60 Blackwell Farm, Guildford [Reduced site area in Policy A26 relative to Site 60] [2,250 homes] Site address Site Maps: Land to the south west of Guildford, Blackwell Farm, Hogs Back, Guildford Guildford Urban Area Shalford, Worplesdon and Onslow LSOA POLICY A26: Blackwell Farm, Hogs Back, Guildford [1,800 homes] Guildford 005E Guildford 017C 82

83 Guildford 015B Guildford 005E: Low incomes, deprivation in education especially young persons deprivation. Ownership Area (size) Existing use How was the site identified? Private ha Farmland Green Belt and Countryside Study (potential development areas H1 and H2), SHLAA (part of site 311) Guildford 017C: General lack of access to housing where this LSOA is in the most deprived 3% in the country. Is the Allocation Acceptable? NO The allocation across the site is unacceptable. The site is part of the context for the neighbouring Area of Outstanding Beauty and this needs to be respected preferably with the renewal of the status of the upper slopes as an area of Great Landscape Value. The Guildford Society recommends that no development (including roads) should be carried out above the 90m contour and no development should project above 95m above ordnance datum (AOD) Description Ownership Area (size) Existing use Guildford Urban Area Shalford and Worplesdon Private 78 ha Farmland LAA reference Site 311 Key considerations AONB AGLV Access Surface water flood risk 83

84 Considerations Currently Green Belt, partially adjoining the urban area Greenfield land Flood zone 1 (low risk) Within 400m and 5km of the Thames Basin Heaths SPA Partially in an Area of Outstanding Natural Beauty and Area of Great Landscape Value The land is primarily moderate (classification 3b) agricultural land, with an area towards the centre of good agricultural land (classification 3a), and a very small area of very good agricultural land (classification 2) on the western side. Part of site strategic employment site Infrastructure requirements could include a new junction with the A31 Hog s Back and/or A3 trunk road and connections to the Local Road Network. Interventions will be required which address the potential highway performance issues which could otherwise result from the development. The Infrastructure Delivery Schedule identifies the locations on the Local Highway Network and the Strategic Highway Network which could be expected to experience the most significant potential highway performance issues, in the absence of mitigating interventions, from development of this site. Developer contributions could also be sought in respect of providing a new Park and Ride facility on the site and a new Park Barn/Surrey Research We would prefer to see the development restricted to within LSOA 005E as currently drawn. Guildford 005E Guildford 017C Approx 90m contour Guildford 0 84