Draft Issues and Options Consultation Documents

Guildford Borough Council has prepared the following documents for approval by the Executive Committee at its meeting on 5th September:

Executive Committee Report:  20130905_Issues-Options_ExecCttee

This report includes reference to background papers as follows:



The Strategic Housing Market Assessment has not yet been made available but is a crucial document for determining demand.

The other document not in the Evidence Base is the Thames Basin Special Protection Area Avoidance Strategy (which expires in 2014)  provided here for ease of reference:
GBC-ThamesBasinSPA-AvoidanceStrategy and the GBC-ThamesBasinSPA-AvoidanceStrategy_Document

Index Page of Draft Consultation Document:  20130905_Issues-Options_ExecCttee_Index

Draft Consultation Document:  20130905_Issues-Options_ExecCttee_Consultation  (4Mb)

Draft Inventory of Sites for Consultation:  20130905_Issues-Options_ExecCttee_Consultation-SITES (28Mb)

Draft Consultation Questionnaire:  20130905_Issues-Options_ExecCttee_Consultation-Questionnaire

These documents (unless rejected by the Executive) will form the basis of the ISSUES & OPTIONS Consultation in October 2013.

Employment Land Assessment Commentary


This post looks at the Employment Land Assessment and aims to place it (and my responses to it) in the context of other parts of the Evidence Base.

As an overriding view, this document does not purport to be a strategy document for employment land – it aims to spell out the need for employment growth based on assumed population growth and it identifies where employment land is today and where more land needs to be provided to meet demand.

My main issue with this is that it is an organic approach to a situation that has been failing for many years, where a radical and ambitious approach is required.  Failing areas such as Walnut Tree Close and Woodbridge Meadows may well be better served as a new residential quarter, whereas, properly connected, these businesses may have greater success in the other established business centres or even a new centre in the Borough.

On page 12 of the Report there is an assessment (Table 1) of the effectiveness of the Employment Policies in the 2003 Local Plan:

  • Policy E1 FAILED
  • Policy E2 Some Success
  • Policy E4 FAILED
  • Policy RE15 Some success at BTRE Vokes, FAILURE at Peasmarsh

This should be the clearest possible indicator that organic solutions will probably be insufficient.

Corporate Real Estate Executives for major companies have taken Guildford off the list of destinations for headquarters or significant operations due to two main longstanding issues:


The Local Plan gives us a perfect opportunity to rebalance the policy environment and marketing Guildford as OPEN TO BUSINESSES

Guildford Urban Area has three principal employment centres:

  1. Town Centre (Friary & St Nicholas Ward) – 23.5% of the employment floor area accommodating 31.4% of the employees*
  2. University & Research park (Onslow Ward) – 25.7% and 39.6%
  3. Slyfield (Stoke Ward) – 26.6% and 12.7%

(figures from Table 2, p19)

* approximately 12% of the Town Centre Floor Space was noted in the ELA (Table 49) as available on the market in July 2013

Each of these areas has major constraints to business and enterprise growth –

Town Centre has major congestion issues throughout but especially in the Walnut Tree Close – Woodbridge Meadows corridor (325,000 square feet of space accommodating 511 employees).  Here the traffic congestion is so bad that it can take over an hour at peak times to get out onto the local road network.  Unsurprisingly, business have taken opportunities of lease expiries and break options to relocate – typically away from Guildford.

University & Research Park is also blighted by traffic congestion but mainly as a result of strategic failures of the A3.  Again, reports of 45 minutes to an hour to leave the research park area put a great strain on an otherwise exemplary business environment for high-technology companies (knowledge industries).

Slyfield has more industrial property than offices but relies on good quality logistics links to major highways.  Traffic is once a gain an issue here – a link to the A3 would be a partial solution but there also needs to be a much better public transport link from early morning to mid/late evening to ensure that employees can get to Slyfield for shift work and non-standard hours.

Each of these locations can be resolved with careful and wider-reaching planning – a Master Plan for the wider town centre; a Master Plan for the University Quarter (including the proposed or potential westward extension of the town); a Slyfield Master Plan to include potential expansion both northwards and southwards (as noted in the SHLAA and my commentary on Jacobs Well in particular).

These Master Plans should enable communication between themselves to ensure they do not preclude each other’s solutions but they should form Area Action Plans and be brought forward with the Local Plan as Development Plan Documents.

Above all, the Employment Strategy needs to be bolder than envisioned in the ELA – and the Economic Strategy needs to be more defined than the ‘Economic Vision’ document forming part of the Evidence Base.

One final point in the introduction to my response:  There needs to be a strong policy decision taken as soon as possible to establish how Guildford Borough Council will handle applications under the new General Development Order regulations that will allow conversion of office buildings to residential. This is a key issue when considering the propensity to attract businesses to Guildford and to provide enough jobs for a growing local population.  Whilst this is referred to in 2.3 (p13), there is no clear direction offered or recommendation made.  Guildford Borough Council could make such a statement and reinforce it through the Planning Committee pending the production and adoption of the Local Plan so as to avoid any undesirable or uncontrolled erosion of the commercial footprint.

Introduction (p7)


At 1.1 the ELA states that it “assesses how much employment land we are likely to need within Guildford Borough to 2031.”

Stage One – Taking Stock (p9)

This section begins with a Policy Context – looking at National, County and Local Authority policies.

At 2.1.5 the Report cites Paragraph 161 of the NPPF which explains the need to assess the “needs for land or floor space for ECONOMIC DEVELOPMENT” and the need to asses the “existing and future supply of land…to meet the identified needs.”

Neither the Economic Strategy nor the ELA seeks to identify an ambitious target for growth by attracting specific industries or sectors to Guildford.  It seems only the University has such a strategy and its strategic Business Plan is not taken into account in the ELA or as an informative document in the Evidence Base.  This should be addressed in the Evidence Base (whilst it is currently under development) so as to ensure that Guildford is capable of attracting and retaining businesses to be located in the town or its major business areas or elsewhere in the Borough.

Stage One does not give any indication of the prize to be won by Guildford Borough Council of being able to keep a large portion of incremental business rate growth – which could go a long way towards bringing about the infrastructure improvements we need in order to attract and retain businesses.  THERE IS, IT SEEMS, A VIRTUOUS CIRCLE WHICH HAS BEEN IGNORED IN THE ELA.

At 2.1.9 the five bullet points in the Economic Strategy (2013-2031) are set out, namely, Leadership, Infrastructure, Enterprise, Innovation, and Skils & Employment.

It is unfortunate that the Economic Strategy does not specifically focus on ATTRACTING businesses to relocate to Guildford to replace those lost whilst the infrastructure and housing problems were getting progressively worse.

At the footnote (2) to 2.2.1 (p11) the definition of ‘deliverable’ should be consistent with other definitions and uses of the same word across the Evidence Base.

At 2.4.4 the Report refers to the Enterprise M3 (EM3) Strategy for Growth document (final document published April 2013).

The suite of documents is available below:

From these there are some clearly emphasised comments:

  • “The Enterprise M3 area is an important economy and a successful economy against a range of indicators, and a place where businesses have wanted to locate and grow.”
  • “The March 2013 announcement by the Defence Secretary concerning the Basing Plan and the restructuring of army bases will result in a £100m boost for Aldershot with new bases and accommodation for troops returning from bases in Germany.”
  • “In 2013 there is more than 800,000 square metres of vacant industrial and office space which could, if full, house 50-70,000 jobs.”

There are some clearly identified issues set out in the Introduction:

  • It is a high cost location for businesses and their employees (it is ranked 8th out of 48 localities in respect of cost base – based on research by Local Futures).
  • The growth of the labour force is not keeping pace with the potential growth of business, especially as there is significant out-commuting to London (the area is only ranked 39th out of 48 localities in respect of the growth of the labour force);
  • Although improvements to transport have improved accessibility to Heathrow, uncertainty over the longer term plans for London’s airports will inevitably impact on the investment and location decisions of businesses;
  • There are growing problems of unreliable transport connections by road and rail with increased congestion and journey times on some routes;
  • There is a need for essential investments in infrastructure and the built environment, to meet the needs of local businesses, adapt to climate change and create a low carbon economy;
  • The innovation infrastructure is stretched and would need to expand if growth ambitions were to be met – occupancy rates at Surrey Research Park are already 95%;
  • There is a shortage of larger (25 hectare plus) sites – only two across the Enterprise M3 area.  This may prevent the relocation of major businesses and discourage sizeable inward investment projects;
  • In situ business growth is constrained for land and planning reasons. Some larger businesses have not always had close relationships with local public sector partners to help remove constraints to growth (including in situ expansion, tailored skills programmes and collaborations with research agencies);
  • Provision and take-up of reliable and high speed broadband has been a major issue reported by rural businesses in the Enterprise M3 area;
  • In aggregate terms there is not a problem with the stock of office and industrial floorspace, much of it high quality. Market demand has been weak but there are other factors determining demand including high rentals. Some of the vacant space should be considered for other uses to avoid surplus property having a detrimental impact on local services and market perceptions of the area.

One main part of the Strategy is:

Infrastructure and Place: Many of the constraints on business growth concern infrastructure – road and rail ‘bottlenecks’ causing congestion and slow/unreliable journey times, limitations on the capacity of the rail network, a shortage of housing for local workers, differential supply of reliable high speed broadband, access and capacity issues in relation to Heathrow and Gatwick airports. These are current problems that will worsen without investment.

The strategic actions include:

4.  Promote inward investment – especially in key sectors (2015-2020: work with property industry and local authorities to promote availability of industrial and commercial space)

5.  Develop visitor economy, with a focus on business tourism

6.  Drive innovation in all that we do, fostering a culture of entrepreneurship combined with driving business growth in niche sectors such as aerospace/space, cyber security, digital economy and pharmaceuticals (target: Strengthen the innovation brand and develop an average of 30 new businesses involved in knowledge networks per year.

7.  Increase supply of labour, especially high level skills capacity

9.  Establish an effective housing development strategy channelling investment, using a new Housing Investment Board (Targets: Boost level of housing completion year on year; Increase affordability of housing; Support housing in proximity of key economic centres/infrastructure; Support conversion of unused office space to housing.

10. Address congestion, along with road, rail and air bottlenecks (Target: Prioritisation of funding and the overseeing of the delivery of major local transport schemes).


Much of the character of the Borough’s economy is left to Appendix B (p80).  Of note in the highlights at 2.5 to 2.7 are:

  • The assessment of job numbers and job creations are five years out of date (2002 to 2008).  This refers to the 2009 Guildford Economic Study and not to the most recent Economic Strategy Report. The Evidence Base should be Up to Date and Integrated (NPPF)
  • At 2.6.1 the Report refers to a local business survey conducted in 2008.  This is, once again five years out of date and circumstances are fundamentally different now. The Evidence Base should be Up to Date and Integrated (NPPF).
  • At 2.7 the Report refers to eighteen sites identified as strategic employment sites. These are listed in Appendix T (p150) and characterised in Appendix U (from p155).  There is no attempt to consider any linkages between employment sites and, by and large, the information is superficial rather than strategic.

Stage Two – Estimating Future Employment Land Requirements

This section considers three approaches to estimate demand:

  • Employee Demand
  • Employee Supply
  • Projections of Past Take-up of Employment and Economic Development Land

Approach 1 – Employee Demand

The Report uses an “average estimate of floor space per employee” to calculate the amount of employment floor space that will be needed.  From my professional experience, this is a rather blunt instrument with which to carry out exploratory surgery.

New ways of working (referred to in the Report as “Smart Working”) are actually making projected demand rather difficult to estimate.  In some business sectors, corporate real estate executives are targeting ratios like one desk per two or more employees for offices;  at the same time, retailers adopting a click and collect or home delivery service are typically employing more people in the same footprint.

On the other hand, a major trend towards self-storage facilities means that only very few people are employed in a fairly substantial facility.

At 3.3 (Employee Demand Forecast 1: Economic Downturn Forecast) the forecast was recorded as having been made in Spring 2010 – three years ago and five years before the Local Plan is expected to come into force.  The forecast only covers the period to 2026 and so the officers have applied a projection for the balance of five years.

These analyses are spelt out in Table 3 – 2031 Forecast Adjustments (p24) in which an assessment of employment numbers is made and then applied to a 2009 baseline of typical space use density, leading to a total from Table 4 – Extra Floor Space and Land Required 2006 to 2031 (p25) which actually only estimates additional floorspace and not land take.

This summary of 36,000 square metres of net floor space required (which seems a very low number for a 25-year period under any circumstances) is not translated into the amount of land erquired to accommodate it in this scenario.

3.3.16 says: “We hope the majority of the [General Industrial] land will be re-used for [Business] or [Storage and Distribution] but if the location is totally unsuitable it may be released for other uses such as residential“.  It seems odd to have a statement of hope rather than prediction or assertion in a Report such as this.

At 3.4 (Employee Demand Forecast 2: Strong Economy Forecast) the figures were drawn from a 2008 forecast by Experian – even further out of date from the commencement of the Local Plan.  This forecast, ranging from 2007 to 2017 has been projected by officers to run through to 2031 (140% longer than the original range).

According to this approach, the net additional floorspace required (again no land requirement estimate is provided) is 164,000 square metres – a 24.22% increase in the current floor areas summarised in Table 2 (p19).

At 3.5 (Employee Demand Forecast 3: Mid-range Forecast) officers have derived a mid-range forecast which, for most figures with some rounding, seems to be a mathematical average rather than a mid-range economic forecast.

According to this approach the requirement is 99,000 square metres of space and, yet again, no reference to the likely land requirement to accommodate this requirement over the Plan period.

Approach 2 – Employee Supply Based Forecasts

The principal high level comment to make about this approach is that, whilst it considers the propensity and likelihood for new residents to commute to other employment centres (especially London) it fails to take into account major growth areas such as Aldershot (which is receiving large numbers of troops returning from Germany – with their families including, potentially, working wives).  Appendix Q does show data from the 2001 Census and the 2011 Census data is not yet available.

Furthermore, the Retail Demand Study (Roger Tym & Partners) suggests that there is latent demand by 2021 for more than 60,000 square metres of town centre retail space.  This will absorb some of the employees [but has not been modelled in this Report.]

It may well be that this section of the evidence base will need to be thoroughly reassessed in 2014 upon publication of the 2011 census data to understand the current origins and destinations of economically active members of the community, and having regard to Economic Impact Assessments prepared as part of applications for planning permission for the North Street development.

Figures taken from The Office of National Statistics (ONS) – particularly at Tables 10 and 11 do not take account of the gradual increase of the state pension age being introduced over the life of the Local Plan.  This will inevitably increase the number of people of working age and should be factored into a demand-side study such as this.

At Table 15 – Employee Supply Forecast – Extra Floor Space Required 2010 to 2031 – a figure of floor space per worker for the various sectors is set out.  This is interesting inasmuch as it suggests that the current space use allocations will subsist for the next twenty years or so – property industry evidence shows that some sectors are trending down (notably offices which shows the largest supply) and some are flat or increasing.  What is not clear is what assumptions should be made to accommodate and attract the types of businesses set out in the EM3 strategy – notably, aerospace/space, cyber security, digital economy and pharmaceuticals.

Approach 3 – Comparing Forecasts Against Past Commercial Floor Space Take Up

Generally the content of this section is logical – there must be some question as to how much store should be set by previous organic growth versus a strategic plan to grow.

At 3.8.10 there is a section on B8 (Warehousing) demand for which has varied considerably between 1998-2004 and 2005-2008.  The key question is whether there is any means by which to assess likely future growth (or inhibit it if other employment growth is preferred) or whether the Local Plan will need to be sufficiently flexible to accommodate it if necessary.  It should be noted that the growth of internet shopping means that regional distribution centres are likely to be in greater demand rather than less.

Factors Impacting upon New Job Creation and the Need for Additional Floor Space

The trends considered are Off-shoring and Home-Shoring.  There is a further trend of Near-Shoring (although for our purposes since Guildford is a high-cost centre, it is likely this will operate in similar fashion to off-shoring.

The key consideration for Guildford is that it is likely to attract the residual (head office or similar) functions with a higher value-add.  One potential issue for this will be that Guildford will find it difficult to provide relatively unskilled white collar jobs – the typical activities that tend to be off-shored.  A major analysis should be undertaken to establish how to either up-skill young workers or to attract a wider range of businesses despite the higher underlying costs of living and being in Guildford.

There is little current evidence to show that trends in home-working are either permanent or lead to reduced floor area in the long term.  It is clear that home-working (or perhaps hub-working – explained below) have the propensity to reduce space use.  Some of the older office stock may well not lend itself to the type of flexibility required for home-working to lead to structural space reduction – for example, older network cabling, poor layouts, etc., can be a major constraint for businesses wishing to do more with less space.

Hub-working is a new trend for individuals to gather in a working environment (more formal than the ‘Starbucks’ office) and, whilst it uses space, this could be provided in community facilities across the Borough rather than in established business centres.

Stage 3 – Comparing the Forecasts with Past trends for Employment Land

Figure 7 (p47) maps the trend lines modelled in the three approaches above for Offices:


The ELA Report correctly identifies the vision in the Guildford Borough Economic Strategy (2013-2031) for Guildford to have “world class businesses with capacity to expand…” and “an evolving and vibrant economy”.

The ELA, however, sets its recommended provision at between the medium and high levels in Approach One above, rather than look at the previous provision as a target. It does, however, state that the policy will be monitored and the ELA updated on a three-yearly basis.

I would recommend that the provision should be capable of providing more than the target based upon demand but not less than the lower threshold.  this should enable tired old buildings and locations to be eliminated and relocated without companies having to leave the area to transform and grow.

It is worth highlighting that the likely incremental Business Rate receipts to Guildford Borough Council from an increase in office floor area of 65,000 to 110,000 square metres would be in the region of £8m to £12m per year by 2031.  This could provide a good revenue from which to fund infrastructure improvements.

Figure 8 (p49) shows a similar analysis of Industrial floor space, but on this chart the demand and trend are declining.


There is a considerable gap between the trend line and the employee forecast lines and, despite the downward trend and forecast, the ELA is recommending a modest increase in industrial floor space by 20,000 square metres over the Local Plan period.  I think this is appropriate and, even more desirable, it is to Guildford’s benefit if the quality of the supply were to be substantially improved.

Once again, the ELA recognises the remarks in the Guildford Economic Strategy, and this time looks to provide scope for a greater amount of space than trend or forecast to help realise the goals of that strategy.

Figure 9 (p52) shows an analysis of Distribution and Storage floor space.


Even more so than for Industrial space, there is a major disparity between the historic trend line and the employee demand lines.  This is the third of three charts which has historic trend above employee demand and this would tend to suggest that the employee demand is either underestimated or that Guildford’s economy is close to saturation point.

Given the comments about the regional economy and targets for growth, it is reasonable to deduce that the employee demand figures are simply wrong.

The ELA does at least conclude that the target floorspace should be between the trend and demand forecasts at 40,000 -70,000 square metres.

Baseline Floor Space Requirements

The ELA Report deduces that the total floor space to be provided needs to be between a range of 105,000 square metres (10.5 Hectares) to 200,000 square metres (20.0 Hectares).

I have modelled the totals for the three property types below, together with the ELA recommended range:


Clearly, the upper limit of the ELA recommendation does not provide sufficient space to maintain trend and, for a Local Plan relying on or promoting growth, this seems to be a weakness in the Evidence Base.  There should be a t least enough total space to meet the previous trends and Land Allocation strategies should ensure good quality, connected space is provided to set Guildford’s businesses at or above regional and national norms.

Below I have reproduced the Press Statement issued by Guildford Borough Council on release of the ELA:

Employment land study makes case for economic growth

Today, we have released a study into how much land we need to provide local jobs in the future. The Employment Land Assessment has found there is currently not enough employment land to meet future growth needs in our borough.

The research is one in a series of evidence-based documents that will support the development of the Local Plan for our borough. Together, the documents look into the availability of land for housing and business growth over the next 20 years.

“This evidence will help us understand how we can protect local jobs in the coming years and attract new jobs to the area,” says Cllr Monika Juneja, Lead Councillor for Planning and Governance.

“The new Local Plan must protect existing major employment sites. It also needs to ensure employers have a degree of choice and flexibility when looking for new premises to ensure they can operate efficiently.

“If we don’t provide enough space for future growth, existing businesses could move out of the borough and new businesses may not be able to establish themselves,” she added. “We need to make sure existing small local companies, emerging businesses and large companies are able to invest in our community.

“We don’t want people to have to leave the borough to find jobs – we want to preserve the vibrant, thriving economic life of our borough, now and in the future.”

The ELA, in failing to recommend the provision of employment land at even the same rate as previous trend, far from ‘making the case for Economic Growth’ seems to limit the propensity for Guildford to grow through the Plan period.  This does not seem to be the panacea suggested in the press statement.

Meeting the Need for Additional Floor Space

There is regular reference in the Report to the poor quality of much of the existing employment accommodation and this is rightly remarked on in 4.6.3 in the context of a shortage of Grade A Office Space in the Borough “which is needed to attract inward investment in the borough and meet goal (sic) to ‘ensure that Guildford borough will be the top-performing economy in Surrey in the years up to 2031 and beyond’ (Guildford Borough Economic Strategy 2013-2031)“.

This section of the report examines vacant premises as at July 2013 and unimplemented planning permissions as at January 2013.  It puts these into the following table (Table 28)


This shows a total available supply that, based on historic trends would run out in 2020 and, at the ELA assessment of High Demand, would run out in 2022 (as shown below).


The analysis in this section of the ELA does not account for any businesses who might be attracted to Guildford if the strategies likely to be adopted in the Local Plan are successful in terms of resolving the long-standing issues identified in the Economic Strategy, namely, traffic congestion and housing affordable to workers.

This all seems to show that there will be a substantial shortfall through the Plan Period.

Having arrived at an “Absolute Maximum” supply level of 135,600 sqm by a combination of the figures above and by the more efficient use of the existing buildings, the report then goes through a Reality Check at 4.10.  This revises the figure down to 74,300 sqm.

At this level of supply we will have run out of available space between 2017 (trend) and 2019 (high) as shown below:


The ELA then goes into Stage Four – Meeting the needs medium to long

There is a minor discrepancy between 4.10.9 (which notes there are seven potential additional sites) and 5.1.8 and Table 32 which both say eight.

NOTE; In my comments on the SHLAA and the SPR, I noted that we should consider a more extensive increase in Slyfield.  This taken with the Onslow/Shalford ward extension at Blackwell Farm (H1 and H2 of the GBCS) should be able to accommodate the level of commercial space required.

The ELA concludes on page 69 that for 2013 to 2031 we should make a provision of between 105,000 and 200,000 sqm of office/industrial/warehousing space, further concluding that:

“6.1.5 If we do not protect our existing major employment sites from alternative development proposals: the borough may increasingly have a dormitory role with increasing levels of (net) out-commuting, there may be a reduction in available local job opportunities for local residents which is particularly important for those who are less well qualified to travel outside the borough for employment, locally grown businesses may be forced to locate and/or relocate outside the borough as a result of lack of choice and availability of sites and premises.

6.1.6 We believe the new Local Plan needs to strongly protect its locally strategic employment sites identified in figure 3 (p14) and table 2 (p15). This would comply with the National Planning Policy Framework (paragraph 21) which states councils should
“set criteria, or identify strategic sites, for local and inward investment to match the strategy and to meet anticipated needs over the plan period”.
Loss of these sites to alternative uses runs the risk of constraining employment growth, limiting economic diversification and fuelling a significant imbalance between the size of the resident workforce and the number of locally available jobs.”

There are 23 appendices to the Report and most of these have not been carefully reviewed in this commentary.

Appendix B – Employment and Industrial Characteristics Review of Guildford

On page 81 the ELA refers to a July 2010 Lambert Smith Hampton office report but reports 2012 take-up.

On page 82 the Lambert Smith Hampton data on Industrial and Distribution is from March 2011 and includes the comment “The general shortage of industrial land could herald the return of speculative development in late 2011/early 2012.” This clearly did not happen and must call into question the accuracy of the remaining data and any assumptions formed on the basis thereof.

On page 83 Figure 1 shows the Regional property Markets in the South East from a CBRE market study of 2007 – well out of date.

On page 84 Lambert Smith Hampton’s office report from page 81 is duplicated – and again at page 149

On page 85 the LSH industrial and distribution report from page 82 is duplicated and again at page 149.

On page 134 the 2007 CBRE figure from page 83 is repeated.


Wearing my Corporate Real Estate hat, there is no indication from the ELA that Guildford is open to attracting major new business, and this needs to be properly discussed in the Issues and options consultation.  If we wish to attract larger businesses and be once again a focus for headquarters as well as having a thriving small and medium sized business sector, we will absolutely need to be bolder with our numbers and strategy, taking more of a leaf out to the EM3 book and setting an objective to compete with all other regional centres.  This, however, needs to be done in a sensitive and well-thought way to avoid having a surfeit of empty space and a failing market such as Bracknell is suffering from in the present market.


This commentary is a first look at some of the sites being advanced for the Strategic Housing Land Availability Assessment.

Noting my comments on the SHLAA document itself, I am beginning this site specific review with the Green belt sites identified.

It is worth pointing out that inclusion in the SHLAA does not imply planning would be granted and the Report does not make that sufficiently clear.

Land Currently in the Green Belt

Beginning on page 284 of the SHLAA:

Site Ref 46: Green Belt and Countryside Report land parcels C1 and C2

Identified in the South East Regional Plan in 2009 as a target area for release of Green Belt Land.

Suggests 300 homes towards the 1-5 year target (although it later describes this as “the possibility of some first phase completions occurring in the first five years”) and a further 1,331 homes in the 6-10 year window.

The site is 88.83 Hectares (that is 219.5 acres) of mostly ‘moderate’ agricultural land.

There will no doubt be some serious questions here from local residents but perhaps the biggest challenge is to understand how these sites have been assessed in the Green Belt and Countryside Report which has led to them being brought forward from the Green Belt for development as a priority.


These images show the designation of the site(s) in the GBCS Report alongside an aerial photo from Google Maps.

Below is the extract from the SHLAA:


The GBCS Report Appendices to Volume 2 include two files:



For parcel C1 (Gosden Hill Farm) the walking routes seem to disregard the presence of woodland which was part of Merrow Common.  The GBCS Report (Volume 2) notes for C1 that “Woodland to the south west of the land parcel between Merrow Lane and Gosden Hill Road is designated as an SNCI“.  In what way is it appropriate to consider a direct route as below for the purposes of calculating the sustainability score?  What should the score be in reality if the route were drawn to circumvent the Merrow Common woodland?:


I am aware of more detailed concerns about these particular sites (not least that distance to the nearest A road shows a walking route to the 6-lane dualled A3 (see below), and that the cultural facility measured in the Report actually closed in 2009).


Clearly some careful re-examination of the fact-based assessment needs to be done before these sites can be compared with other sites in the Evidence Base.


Site Ref 311 (part): Green Belt and Countryside Report land parcels H1 and H2

The first thought I had when I read this entry was “why on earth is this land in Shalford Ward?” – see Ward Boundaries below:


Suggests 300 homes towards the 1-5 year target (although it later describes this as “the possibility of some first phase completions occurring in the first five years”) and a further 1,633 homes in the 6-10 year window.

The site is 139.68 Hectares (that is 345.2 acres) of mostly ‘moderate’ agricultural land.

There will no doubt be some serious questions here from local residents – most if not all of whom will live in the adjoining Onslow Ward.

Part of the site is in an Area of Outstanding Natural Beauty and Area of Great Landscape Value – this part should have been screened out of consideration before assessment within the Green Belt and Countryside Report.

The Green Belt and Countryside Report plan is shown below with an aerial photo from Google Maps:


Below is the extract from the SHLAA:


The GBCS Report Appendices to Volume 2 include two files:



For parcel H2 the walking routes seem to disregard the presence of woodland (Strawberry Grove and Manor Copse).  The GBCS Report (Volume 2) notes for H2 that “Strawberry Grove and Manor Copse located to the east of the land parcel are designated as Ancient Woodland.  This designation also applies to a tree belt which extends from the north of Strawberry Grove to the railway line“.  In what way is it appropriate to consider a direct route as below for the purposes of calculating the sustainability score?  What should the score be in reality if the route were drawn to circumvent the Ancient Woodland?


The walking route on the above example is between the centre of parcel H2 to the nearest town or district centre.  The route shown goes to Guildford Town centre when Wood Street Village, Park Barn and Onslow Village all have district centres nearer than the Centre of Guildford.  Perhaps this aberration is due to the failure of the Settlement Profile Report to consider the Guildford Urban Area as a collection of neighbourhoods around the Town Centre.



Site Ref 2014: Green Belt and Countryside Report land parcels H8-A and H8-B

These parcels relate to land to the south and west of Fairlands, and should be taken in the context of Site Ref 311 (part) described above.


These two areas taken together represent a substantial incursion into the Green belt to the West of Guildford which, whilst they may be appropriate in isolation, should ask the question whether there is a likely future coalescence and whether there should be a more detailed study of the area to identify the merits or harm in extension of Guildford from Park Barn to Fairlands and Wood Street Village, together with suitable infrastructure and facilities to serve a new neighbourhood.

The proposed Fairlands expansion is 27.66 Hectares (63.8 acres) and is planned with an average density of 30 dph (dwellings per Hectare) as against the 40 dph applied to the urban extension.  There is no reference in the Settlements Profile Report to the current density of Fairlands and, for this to be a village extension and to be in character with the existing settlement, surely some analysis should have been done at Settlement level to inform a supply-side study such as this.

Thinking Bigger…

In Volume III of the Green Belt and Countryside Report a further area is identified for removal from the Green Belt:


If it is appropriate to extend Fairlands on parcels H8A and H8B, then why not consider a more ambitious expansion that could link better with facilities and transport routes by creating a critical mass and by planning on a larger scale:


The orange areas would amount to around 100 Hectares (or, say, 250 acres) and could provide in the region of, say, 1,500 homes.

Links from the orange land (H8C and the southern section of H8) to H2 (which could then provide the university and research park extensions – employment – and could support local amenities) would suggest that a comprehensive urban expansion in this area could bring major benefits to the town.  Equally these could link into the proposed new Park Barn Station (or, better still, some form of transit system linking the university, hospital, park & ride and these new settlement areas to the town)


The above image showing a potential Docklands Light Railway type system is included simply to illustrate how these could be connected communities and could take local traffic off the roads (including the various shuttle bus services currently running from the station to the Research park and to Guildford Business Park) and solving some of the university’s connectivity issues across its two campuses.

The thinking behind this is that, if a major realignment of the Green Belt is required, it should be defensible and should accommodate sustainable development.  A driverless train service like the Docklands Light Railway could run, say, three or four pairs of carriages around the loop and not be constrained by hours of operation in the way current bus services are.  this means commuting to and from employment areas should be easier and it should also support the evening economy in town as well as hospital visiting.


Jacobs Well and Slyfield and Site 245

Missing from the Housing Land Availability Assessment (due to the way the land was scored in the Green Belt and Countryside Report) is the potential to redraw the Guildford Urban Area Boundary around the north side of Jacobs Well.  This is not a recommendation for implementation but seems to be a perfectly logical possible alternative to expansion in other areas which should be considered.

A new Urban Area Boundary would be defensible and the increase in housing where jobs are located and where intensification of employment uses is considered in the Employment Land Assessment seems to accord with the requirements of sustainability – notwithstanding that it requires the swallowing up of an existing settlement into Guildford Urban Area.


Parts of Parcel B3 and Parcel B2 could be excluded from Green Belt and developed in such a way that the area could have stronger transportation links to Guildford – ensuring that the area as a business area and residential quarter is less reliant upon car travel and that journey times are more predictable.

In the plan below (introduced as an example and thought-starter rather than as a proposal) the yellow area is Site Ref 245 in the Strategic Housing Land Availability Assessment.  The orange areas are currently not included as potential sites for development in the Green Belt, I have suggested potential for a Park & Ride on the lower part of the site with access to and from the A3 at Burpham (catering for Guildford-bound traffic from the A3 north) with connections between Slyfield and Clay Lane (blue dashes) and a potential Park & Ride bus route joining the A320 close to its junction with the A3.  This assumes that the scale of development would be such as to enable infrastructure and services in this way.  I have assumed a green buffer along the river for both flood protection and environmental reasons.  I would reiterate, I have included this as a means of identifying choices of places and ways to amend the green Belt boundary and to allow development that can be made to be sustainable, deliverable and to ensure future defensible boundaries.


As a broad assessment, I would consider this could accommodate an additional 1,000 to 1,500 homes and some additional employment areas to meet or go towards the needs identified in the Employment Land Assessment.  This could perhaps be achieved earlier than the 11-15 year timescale suggested in the SHLAA for Site 245.

Placing a Park & Ride that could be accessible from both the Woking Road (A320) and the A3 could mean that the existing Park & Ride at Spectrum could be used for another purpose – potentially for housing development or for some other purpose.

Furthermore, this might be a more appropriate once-and-for-all redrawing of the Green belt Boundary than carving out the area of A4 (Whitmoor Common) and A1 (Stringers Common).

Site 245 is 41 Hectares (101.3 Acres) and is currently an industrial estate and sewage works.  It is proposed for 1,000 homes in years 11-15.

There is a specific area master-planning group (SARP which stands for something like Slyfield Area Regeneration Partnership) that has been established to bring forward this site.  This would seem to be a suitable site for housing as long as the river corridor is protected and if the site can be properly linked to established residential districts and associated services and facilities.  Once again there is no specific regard to settlements within the Guildford Urban Area and so no assessment in the Evidence Base can be directly applied and cross-referenced with this proposal.


Other Green Belt areas included in the SHLAA are village extensions that can properly be assessed by the Parish councils and/or residents’ groups, and they affect the Guildford Urban Area only to the extent that a failure to find sufficient rural sites will place a greater burden on the urban area.


Countryside Outside the Green Belt

In general, it is not my intention to focus on the urban area of Ash South and Tongham.

On the other hand, from the pages of the Surrey Advertiser (9th August) there is a public outcry about a planning application for 400 houses on land that forms part of Sites 45 and 33 (SHLAA p262).  this does not bode well for a process whereby a far larger urban extension (or series of extensions) is proposed.

Set out below is the summary of sites from SHLAA.

Site Ref GBCS Ref Ward Area (Ha) TOTAL Houses 0-5 Houses 6-10 Houses 11-15
45, 33 K7 Ash South & Tongham              42.00               685                              685                                –                                  –
1450 Ash South & Tongham                0.11                    2                                  2                                –                                  –
51, 21, 2004, 57, 11, 10, 2005 K9 Ash Wharf and Ash South & Tongham              13.15               328                                 –                            328                                  –
36 K5 Ash South & Tongham                3.55                  35                                 –                               35                                  –
2000, 1163, 394 K2 Ash South & Tongham              18.56               464                                 –                            464                                  –
1211 K9 Ash South & Tongham                2.91                  75                                 –                               75                                  –
2001 K6 Ash South & Tongham                2.87                  71                                 –                               71                                  –
2002 K6 Ash South & Tongham                1.90                  62                                 –                               62                                  –
338, 2006 K8 Ash South & Tongham              11.20               242                                 –                            242                                  –
1451 Ash South & Tongham                0.50                    3                                 –                                 3                                  –
 TOTALS              96.75            1,967                              687                         1,280                                  –

The reliance on 687 units from this area in the years 0-5 is probably reasonable assuming planning permission is granted for the current application (400 units).  If not, there is a risk to the five year supply totals.

Identified Village Settlements

In general, development opportunities in the Identified Village Settlements (SHLAA p. 176 onwards) are village extensions that can properly be assessed by the Parish councils and/or residents’ groups, and they affect the Guildford Urban Area only to the extent that a failure to find sufficient rural sites will place a greater burden on the urban area.

Guildford Urban Area

As a general comment, many Guildford Borough Council-owned garage blocks are included for development.  These may provide amenities for neighbouring housing and, to the extent that residents currently park their cars in the garages, such development may lead to a greater problem of on-street parking – an issue that already causes some problems with residents in Guildford.

A few of the proposed housing sites in the Guildford Urban Area have been selected below for critical analysis or comment.

Site 50 – Land at Guildford Cathedral

The area of land shown (3.28 Hectares) does not adequately reflect the proposal making it very difficult to evaluate.


The Achievability Assessment suggests that this can be delivered within five years

Looking at the scale of housing opposite and superimposing this fronting onto the road, it should be possible to achieve around 25 family homes whilst respecting the upper slopes and protecting a similar area of hillside undeveloped to the west as on the opposite (university) side before the refectory car park.

Site 92 – Land Adjoining Boxgrove County Primary School

Given the stated shortfall in school places in the town centre, care will need to taken to ensure that this space will not be required for school expansion to meet the needs of an extension to the Guildford Urban Area.

Site 100 – Land on both sides of Walnut Tree Close (GU1 1TP)

This land is valuable residential land currently underused for commercial purposes.

Walnut Tree Close

The plan below shows park land alongside the River Wey (complementing the green area and National Trust site on the other side of the river.  The dark blue area (assumed to be around 2.5 Hectares of the 4.5 Hectare site identified) should be able to accommodate housing at a greater density – say around [175 dwellings per hectare, providing in the region of 400 homes].  The current alignment of Walnut Tree Close could be smoothed out to improve movement (dotted in red) and there is scope for a new railway and river crossing at around the point shown (narrowest part of the railway) which would help to remove traffic from Guildford town centre and to access the University and the Cathedral from a wider area of Guildford.

Walnut Tree Close_Development

The Employment Land Assessment indicates that this site currently has 20,000 square metres of floor space at relatively low levels of mass and density.

The SHLAA suggests that the time scale for development could be 6-10 years and this may be realistic if the buildings all fall vacant within the time scale – probably with a route reserved for the river/rail crossing and the realignment of Walnut Tree Close completed.

Businesses could be displaced to Slyfield as long as the transport infrastructure were to be improved for public transport access between the town centre (and station) and Slyfield.  The ELA suggests there are around 670 jobs located on the site but in reality this seems to be outdated as some of the buildings are already being demolished and others seem barely used.

This suggestion would see a much larger number of urban-living homes provided in an area badly in need of regeneration.  The fact that the development would back onto the railway should give scope for some development height and mass which might not be acceptable elsewhere.  parking should be at half-basement level to help raise the living accommodation clear of flood levels.

Site 136 – Merrow Depot

The area shown in the Employment Land Assessment includes the industrial estate fronting onto the through road part of Merrow Lane.

The SHLAA entry is restricted to the land owned by Surrey County Council.

This site is across the railway from Site 46 (C1 & C2) – see above – and there has been talk in the past of creating a new station at Merrow in about this position to serve any urban extension and the employment centred in Appendix U7 of the ELA.

Prior to development of either this or Site 46, there should be a full study of the combined effects of the developments and also any benefits of using all of this site for commercial purposes (or even community facilities that a development on the scale of Site 46 might require) centred around a new station.

Site 232 – Bus Depot, Leas Road, Guildford

The bus depot should be relocated to a business environment such as Slyfield.

It also seems to be worthwhile identifying an alternative site for Safeguard Coaches (Madrid Road) and regenerating their site for housing  – that site does not appear in the SHLAA.

For Site 232, the time frame may be optimistic given the presence of fuel tank(s) on the site and the potential need for remediation of the soil in a sensitive location.

Site 1584 – Former Pond Meadow School, Guildford

Given the stated shortfall in school places in the town centre, care will need to taken to ensure that this space will not be required for school expansion to meet the needs of the nearby extensions to the Guildford Urban Area.

Other sites in the Guildford Urban Area will attract specific comments from residents and neighbours and none of them seems to offer strategic opportunity or threat.

Missing Sites in the Guildford Urban Area

In addition to the Safeguard Coaches site at Madrid Road, there is also a former GSA building in Madrid Road that does not seem to be occupied and that could be suitable for development.  See below.


The principal site that goes unmentioned is the Farnham Road Hospital where there may be merit in relocating the hospital use to a site on or near to the Royal Surrey County Hospital and regenerating the site (including conversion of the significant building(s)) for new homes. See below. This includes the adjoining site (Site 129) shown in the Town Centre section of the SHLAA report as being available for development in 6 to 10 years.


Guildford Town Centre

The most odd finding in the Town centre section of the SHLAA Report is the disparity between dwellings per hectare across the range of sites without explanation.

Site 134, for example (Guildford Plaza) should be capable of a reasonable density – especially having regard to the scale of building that previously occupied this plot.  It is shown as accommodating only 37 dwellings per hectare although the site levels would probably allow underground parking and still to make good use of the frontages of the site.

Site 171, Guildford Railway Station shows 54 dwellings per hectare.  This is largely because the entire railway station is included in the site. In actual fact, the area for housing (including the station forecourt) is probably around 2 hectares and so the density is more like 190 dwellings per hectare.

Site 173, Bedford Road shows 83 dwellings per hectare, whereas Site 174, Bright Hill Car Park shows 106 dwellings per hectare.

Much greater clarity is required to establish on what basis the density figures were derived.

Site 171 – Guildford Mainline Station (aka SOLUM)

This site represents a linear development along each side of the railway station which, if implemented, would preclude future access for a new relief road across the railway.

A potential route for the road is shown at Site 100 (above) and would impact only the very end of the site. Other potential routes show a bridge closer to the station and great care should be exercised to understand the opportunities for wider infrastructure improvements as part of the Solum development.

Site 178 – Guildford Park Car Park and Site 1107 – Jewsons

The  plot designated Site 178 includes (at its north-east corner) a relatively new office building – never let – recently converted into student housing (shown in Navy Blue below)



This plan shows a possible route for a relief road (following on from Site 100 above).

On the other side of the railway is Site 1107, Jewsons which would probably be able to remain in situ (or ideally, to be brought forward for residential development irrespective of the alignment of the relief road as shown in Site 100 above.

Careful analysis should be carried out to establish that such development does not preclude the relieving of traffic in Guildford town centre and the creation of the first railway bridge crossing in the town centre for around 150 years.

Site 1422 – Dolphin House, North Street

The site line is probably drawn too tightly around this site whose opportunity would the wider regeneration of the top of North Street.  This could also include the red-lined area  and might provide a high quality town centre housing development (above retail) which properly respects both the houses in Martyr Road and Abbots Hospital.


Other Town centre Sites

Sites 1419 (Debenhams) and 1420 (Guildford Borough Council Offices) could each be characterised by their ability to possibly be relocated within a regeneration of North Street.  These should form part of a strategic study alongside the planning of the town centre regeneration and should be explored with an open mind.

The Library site (Site 1236) could be freed up by relocating the library into the North street development and, because of its position behind Guildford House, could be opened up as an enlarged pocket park, framing the important rear façade of Guildford House and creating an oasis of calm in the town centre.  This should also include the relocation of the employment centre offices to open up the Old Cloth Hall to views up North Street.



There will be many people who disagree with my comments and I am happy to hear all feedback.

The key observations are:

The SHLAA has not considered all options;

The SHLAA has relied on some of the flawed outcomes of the Green belt and Countryside Study;

The SHLAA should help to guide a long term vision of the various different parts of the town and Borough, and yet there is no real attention given to the settlements within the overall Settlement of Guildford Urban Area – for this the Settlement Profile Report is deficient.

In the Employment Land Assessment, there is not enough granular detail as to where employment might be provided, or what mixes are supposed, when considering residential use of part or all of employment land.

In the Infrastructure Baseline Report, there is a clear concern about the traffic congestion in the town centre and this should be addressed in the other reports even if to note that prior to any major development, a detailed assessment must be undertaken to avoid the preclusion of a long term solution to traffic or transportation deficiencies.

No guidance or recommendation is made as to the need or desirability to create a new settlement in the countryside (albeit three suggestions are floated briefly in the introduction.  It would have been useful to see some indication of the scale and numbers of units such development might accommodate and to ensure that new settlements would be discussed as part of the Issues and options Consultation in late 2013.

Employment Land Assessment

On 7th August the Employment Land Assessment was published on the Guildford Borough Council Evidence Base.

This document represents the penultimate piece of work to allocate or identify potential sites for development.

See previous comments on the Strategic Housing Land Availability Assessment here.

A commentary on the Employment Land Assessment will follow in the next several days.

Strategic Housing Land Availability Assessment

The Strategic Housing Land Availability Assessment has been published as part of the Guildford Borough Council Evidence Base and not as a consultation draft.  Weighing in at almost 400 pages this seems more daunting than the reality – many pages are made up of individual site assessments.

The first observation is that there is no estimated target number of housing units to provide over the plan period (although on page 5 there is reference to “our interim housing number is currently 322 homes a year“).

If we assume the Borough-wide housing need of 322 units, this would suggest the required number of housing sites to find over the fifteen years of the Local Plan would be 4,830 homes.  NPPF says that, for any five year period, Local Authorities must have identified their five year need plus 5% or 20% depending on their prior ability to satisfy housing need.

Figure one on page 9 shows that the number of housing units completed in 2008/9, 2009/10, 2010/11 and 2011/12 has remained resolutely below 250 units per year, suggesting that the 20% margin would apply to 5-year housing numbers.

Consequently, at any time during the plan period, Guildford Borough Council would need to have identified available and viable land for 1,932 dwellings for delivery within five years.

So, over the plan period, this suggests that housing need is 4,830 homes (fifteen years at, 322 units plus a floating allocation of 65 units to cover NPPF obligations).

The SHLAA identifies land for 11,799 new homes (no indication as to what percentage increase in new homes across the borough that would represent) and does not explain why the Report has seen fit to aim to provide around double the likely level of supply (for example, if there is a need to make up for several years of underdevelopment).

Any statement of need for housing should be kept under constant review as Local Plan policies emerge and as, say, employment land is identified so as to ensure that there is sufficient housing to accommodate the needs of employers and their staff.

The SHLAA was prepared in conjunction with the Employment Land Assesment (ELA) – published on 7th August – and the Strategic Housing Market Assessment (SHMA) – not yet published at the time of writing this review.

The tables 1-6 set out the results of the assessments for Guildford Town Centre, Guildford Urban Area, Western Urban Area, Identified Village Settlements, Rural Exception Sites and Previously Developed Land in the Green Belt respectively.

The figures from tables 1-6 should have been sub-totalled and the shortfall identified so that:

Years 1-5   631 units (required 1,675, hence shortfall 1,044 units)

Years 6-10   1,096 units (required 1,610, hence shortfall 514 units)

Years 11-15   1,896 units (required 1,610, hence surplus of 286 units)

The next stage would be to assess how many housing units could be brought forward from later periods to meet some or all of the shortfall.  Assuming the basis of the Report is sound and that all such units have been accelerated (not totally clear from the text), there would be a need to find the additional dwellings from Green Belt or Countryside beyond the Green Belt.

Table 7 identifies 724, 1,280 and 0 potential new homes for the three periods respectively from Land in the Countryside but Outside the Green Belt.

If implemented, these housing units would still leave a nominal shortfall in Years 1-5 of 320 (64 dwellings per year), a nominal surplus in years 6-10 by 766 (153 dwellings per year surplus) and years 11-15 are unaffected with a surplus of 286 units.


The main problem, however, is that the five year supply from Years 1-5 is insufficient to meet the requirements set out in NPPF without using land in the Green Belt.

Table 8 sets out the summary of assumed development on land assessed as suitable for housing that is currently in the Green Belt.

Table 8 shows Years 1-5 at 1,214 in the Green Belt as currently drawn (an oversupply of 894 units against the 322 homes target per year referred to above).  No justification is given as to why such oversupply should be provided;

At Years 6-10 table 8 suggests an additional 4,873 homes (on top of the surplus from tables 1-7), making a total surplus of 5,639 homes. Again no justification is given as to why such oversupply should be identified.

At Years 11-15 table 8 suggests 115 homes could be provided in the Green Belt, adding to the surplus of 286 from tables 1-7, totalling 401 homes above target level.

Further analysis of the various sites will follow although it is not expected that this analysis will be a thorough one for each plot proposed.

[to be continued…]

Green Belt and Countryside Study


(3rd August 2013)

The Green Belt and Countryside Study sets out to “determine appropriate Potential Development Areas (PDAs) for future housing and other growth requirements if suitable land cannot be identified within built-up areas.” The Summary document sets out to provide background to the instruction from Guildford Borough Council to Pegasus Planning Group – which evolved over several years – and to illustrate how the four component volumes of the evidence base relate to each other. The Study has assessed specific parcels of land in relation to Green Belt planning policy, sustainability criteria and environmental capacity to determine appropriate areas for future development within the Borough. The Study has examined land across the Borough within Volumes I, II, III and IV as follows:

Volume I – Summary, Introduction and Background to the Study

Section 1 provides a Non-technical Summary of the Study. Section 2 provides an Introduction, including an overview of the purpose and scope of the Study. Section 3 provides a Review of Previous Green Belt Studies, and an evaluation of methodologies undertaken for other districts. Section 4 provides a Planning Policy Review, and the planning context within which the Study has been undertaken. Section 5 outlines the Role and Purpose of the Green Belt within Guildford Borough. Section 6 outlines the Green Belt and Countryside Methodologies used for assessing land within the surroundings of urban areas and for villages across the Borough.

Volume II – Land surrounding the Urban Areas of Guildford, Ash and Tongham Section 7 details the Methodology for Assessing Green Belt and ‘Countryside beyond the Green Belt’ within the surroundings of Urban Areas at Guildford, Ash and Tongham. Section 8 outlines the Study Findings for assessing Green Belt and Countryside beyond the Green Belt surrounding the Urban Areas of Guildford, Ash and Tongham. Section 9 details the Conclusions for Volume II.

Volume III – Land surrounding Villages across the Borough Section 10 details the Methodology for Assessing Green Belt Land surrounding Villages across the Borough. Section 11 outlines the Study Findings for assessing Green Belt Land surrounding Villages across the Borough. Section 12 details the Conclusions for Volume III.

Volume IV – Insetting of villages from the Green Belt Section 13 details the Methodology for the Insetting of Villages and defining Green Belt boundaries within Guildford Borough. Section 14 outlines the Study Findings for assessing the Insetting of Villages and defining Green Belt boundaries within Guildford Borough. Section 15 details the Conclusions for Volume IV.


Volume I, apart from setting out a summary of findings at 1.11 to 1.48 does not really add anything to the remaining volumes. The assessment looks at how well specific parcels of land serve the purposes of the Green Belt (as defined within PPG2 and the NPPF) – and it would be helpful if those had been reproduced at 1.5. Following identification of the parcels of land they were scored based upon how well they meet the purposes of the Green Belt – including the ability to check the unrestricted sprawl of large built-up areas; the prevention of neighbouring towns from merging into one another; assistance in safeguarding the countryside from encroachment; and the preservation of the setting and special character of historic towns. A similar approach was adopted in assessing the land parcels around the Borough’s villages. At 1.7 the Report notes that the Green belt parcels are “assessed against sustainability criteria and environmental capacity” but the authors leave it for the reader to trawl through the remaining documents to try to identify the specific tests. The report identifies that 16 PDAs on the periphery of urban areas would be capable of accommodating approximately 9,800 dwellings.


Some of the characteristics set out in this Report should have found their way also into the Settlement Profile Report – the linkages between the documents should be much more formal and comprehensive.  Equally, the Infrastructure Baseline does not provide good interface with this document. It is not clear from Volume 1 whether the Report considered any new settlements rather than simply the land around existing ones.  Wisley Airfield might be one such area for consideration. At 3.9 the Summary refers to five purposes of the green belt designation (but omits them here); it then recites them as being in Section 9 of NPPF – they are:

  • To check the unrestricted sprawl of large built-up areas
  • To prevent neighbouring towns from merging into one another
  • To assist in safeguarding the countryside from encroachment
  • To preserve the setting and special character of historic towns
  • To assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

At 4.10 the Report quotes from a key element of NPPF (Paragraph 83): “Green belt boundaries should only be altered in exceptional circumstances, through the preparation or review of the Local plan.  The Framework comments that, at that time, authorities should consider the Green Belt boundaries having regard to their intended permanence in the long term, so that it would be capable of enduring beyond the plan period.” Other key paragraphs are recited in this section (NPPF Paragraphs 84, 85, 86, 99, 100, 115, 118, 132 and 156). Section 6 promises information about assessment methodology but does not actually deliver, relying on the reader to migrate to the relevant chapters of the other volumes.


  1. It does not seem appropriate to have applied different methodology to urban edge relative to villages.  The village approach seems a more sensible screening methodology; from that point, land ruled out due to environmental constraints (eg AONB) should have been eliminated prior to the “sustainability” assessment (which is itself flawed and works to a pre NPPF definition – reflecting the fact that much of this work was carried out before NPPF was introduced).  To have included figures for land parcels where the AONB designation would presume against development in not only flawed, but invites applications from land owners – and even from Guildford Borough Council, where they are the landowner as at South Warren Farm.  In the latter case, Surrey county Council and Guildford Borough Council have been custodians of South Warren Farm on behalf of residents in order to prevent development.  The AONB constraint is referred to for that site (Parcel E23) but only rather feebly and without ruling the parcel unsuitable for development.
  2. The areas in the Volume where there is a nearby Village (eg., Jacobs Well) are assessed against the village and not the urban area AND there is no particular effort to see if there is a major settlement that could be added within the green belt to reduce the need for realignment of the green belt around Guildford.


This volume sets out the scientific approach to the sites surrounding the Borough’s urban areas – Guildford and Tongham & Ash. There is a proper context to the work and there is no merit in summarising it here.  Questions and concerns are set out as they arise when page-turning through the document. The key map for this section is available here (20130730_GreenBelt-Vol1-App2_PotentialDevelopmentAreas) (65Mb) STAGE 1 – Compartmentalisation and sub-division of land into separate land parcels The consultants divided the surroundings of Guildford into segments separated by A Roads and railways – on the whole this is a sensible strategy when seen against the NPPF guidelines, and it is puzzling for example, therefore, why the mainline railway north of Guildford is not considered to be a zone boundary. The railway lines represent a more permanent and defensible zone boundary than the A Roads which could be bridged or junctions could be added where a new settlement or significant extension warrants it.

The zones are:

From A322 (Worplesdon Road) to A320 (Woking Road) is set as Zone A (and includes land on both sides of the mainline railway)


From A320 (Woking Road) to A3 including land north of A3 between A3 and Authority border with Woking Borough Council is set as Zone B.


From A3 to London Road Line Railway is set as Zone C.


From London Road Line Railway to A246 (Epsom Road) is set as Zone D.


From A246 (Epsom Road) to A281 (Shalford Road) is set as Zone E (and includes land on both sides of the Gatwick line railway).


From A281 (Shalford Road) to A31 until its junction with A3 and the to south of A3 is set as Zone F and includes A3100 (Portsmouth Road)


From A3 to A31 (Hog’s Back) is set as Zone G.


From A31 (Hog’s Back) to A323 (Aldershot Road) is set as Zone H and includes both sides of the Aldershot line railway).


From A323 (Aldershot Road) to A322 (Worplesdon Road) is set as Zone J.


The land outside the Green Belt surrounding Tongham & Ash is set as Zone K. From these Zones, the land was subdivided into parcels so that [to be continued…]


For each parcel of land a binary score (0 or 1) is applied to qualify the parcel according to each of the following four Green Belt purposes:

  1. To check the unrestricted sprawl of large built-up areas
  2. To prevent neighbouring towns from merging into one another
  3. To assist in safeguarding the countryside from encroachment
  4. To preserve the setting and special character of historic towns

There is no score made for the fifth NPPF definition of purpose, namely: To assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

It seems odd that, where there are areas of the Guildford Urban Area that need regeneration, that no urban expansion could be seen as assisting with the regeneration – for example, if the area in town at Walnut Tree Close and Woodbridge Meadows or William Road could become new residential quarters by moving uses towards Slyfield at Parcel B3.

Using the binary approach for Purpose 1 would see a parcel well away from an existing settlement scoring 0 (suggesting it might be suitable for development under Purpose 1) but an edge of settlement parcel would score 1 (tends against development) even though it may be a more sustainable site.

For Purpose 2 the measure is broadly appropriate but would exclude a parcel where there may be an appropriate choice to make whether to coalesce settlements (eg., Slyfield and Jacobs Well).

For Purpose 3 the measure is again broadly appropriate but this should again not be allowed to preclude a site where a valid once-and-for-all settlement extension is a plausible and pragmatic option.

Purpose 4 is a valid measure, assuming there is no development that could enhance the setting and character of the historic settlement (eg., development should not be permitted on the Hog’s Back that is visible from the high Street and forms part of the historic setting of Guildford).

At 7.16 the Report notes criteria against which the lowest scoring green belt parcels are assessed.  This includes the walking distance to the nearest Town or District Centre.  Since the District Centres are not identified in the Settlement Profile Report, this demonstrates a lack of integration of the evidence base.  Equally, some of the sustainability criteria are geographic facts, whereas some other categories could actually be created as part of a development.

At 7.21 the Report focuses very heavily on walking distances based on the Institution of Highways and Transportation (IHT) guidance (2000) but does not challenge the criteria, nor does it take any account of cycling routes and times.

At 7.24 the Report notes that railway stations are an essential facility in determining the sustainability of a land parcel.  There is no indication whether the suggested new stations at Park Barn and Merrow have been taken into account in assessing parcels in their particular areas (some sort of conditionality might need to apply but the current absence of the station might affect the deemed sustainability and rule out potential for development.

7.27 highlights an issue with the Thames Basin Heaths Special Protection Areas (SPA) in that sites that would otherwise be suitable for extension become undevelopable due to the SPA.  The current SPA runs to 2014 and, as part of the Local Plan process, Guildford should consider whether it needs to be amended so as not to frustrate the allocation of the most suitable extension sites.

The Report generally seems to only include facilities within Guildford Borough, whereas many of the settlements in the Borough are close to the boundaries with other Local Authorities.  Any cross-boundary facilities should be allowed to form part of the analysis for each parcel.

Indeed, a further issue is highlighted in Table 5.4 (pp14-17) where many of the criteria are measured against the Guildford Borough Local Plan Proposals Map (Adopted 2003).  These include some aspirations marked on the plan which do not appear to have been qualified as having been implemented.  Equally, other aspects like, say, cycle routes may exist that were not on the 2003 Proposals Plan.  Equally, there needs to be a robust process to upgrade this information against future proposals for plan areas and site allocations so as to ensure the data is fit for purpose in the context of the new emerging Local Plan.

Volume II – Section 8 – Study Findings

Selected comments are made here but a full look at the Report is essential for anyone with special interest or knowledge.  These comments are intended as GENERAL remarks to try to ensure that all potential sites can be compared and only the most suitable selected.

Section 8 – Stage 2 screening and Stage 3 sustainability assessment

B1 scores 3 and B3 scores 4 (excluding them from consideration as a suitable Green Belt site for development).


The infilling of the area between Slyfield and Jacobs Well may be desirable in the context of, say, better connections to the A3 and Burpham.  This could be designed so as to:

  • Help ensure the viability of the small parade of shops;
  • Local employment opportunities are already substantial at Slyfield and could be substantially increased in the new Local Plan;
  • Access to Guildford town centre is via a designated cycle route which could be accessed by a coalescence or extension.

Under the Consultants’ scoring method these parcels are omitted without detailed assessment at Stage 3, and yet parcel B8 (scoring 2) is included for Stage 3 assessment.

C1 scores 1 and C2 scores 2 – C2 scoring higher because it  “prevents neighbouring settlements from merging”.


The land at C1 (Gosden Hill Farm) is proposed as development which would comprise establishing a new railway station on the London Road line at Merrow.  It seems very odd to suggest that C1 and C2 are qualitatively different in terms of preventing neighbouring settlements from merging.

E1 scores 1 and is, therefore, included as a land parcel for consideration.


In this instance, the creation of the Merrow Park & Ride seems to have raised the spectre of development by extending the settlement eastwards.

Part of the land parcel identified for potential development is within the Area of Outstanding Natural Beauty (AONB) and yet potential development does not seem to have been precluded by it (see ISSUES above).

Parcel E1 does not appear to be listed in the Strategic Housing Land Availability Assessment although it is recommended that the green belt boundary be redrawn to exclude E1.

E22 and E23 score 1 and 2 respectively DESPITE BOTH BEING DESIGNATED AS AONB.


The AONB is a designation which helps protect the character of Guildford’s surroundings and the Borough as a whole.  To have included figures for land parcels where the AONB designation would presume against development is not only flawed, but invites applications from land owners – and even from Guildford Borough Council, where they are the landowner as at South Warren Farm.  In the latter case, Surrey county Council and Guildford Borough Council have been custodians of South Warren Farm on behalf of residents in order to prevent development.  The AONB constraint is referred to for that site (Parcel E23) but only rather feebly and without ruling the parcel unsuitable for development.

Parcels E22 & E23 do not appear to be listed in the Strategic Housing Land Availability Assessment although it is recommended that the green belt boundary be redrawn to exclude them both.

E24 scores 2 and E25 scores 1 suggesting they should be considered for potential development – although clearly in the AONB – and, ironically, they would score higher if E22 and E23 were developed.


Clearly development should not be appropriate in this location as it represents a key element of the character of the east of Guildford Borough – this includes Tyting Farm for which specific plans are being advanced to preserve the landscape of this site owned by Guildford Borough Council.

All of Zone G is covered by AONB although 7 of 19 parcels would appear to satisfy the criteria for sustainability assessment.

H1 and H2 score 1 and H3 and H4 score 0.


The land at H1 and H2 are owned by the University of Surrey and may have been earmarked for University expansion – Research Park, Teaching Campus and/or Student Accommodation.  Part of H1 is in the AONB as is part of H3.

Infrastructure between the Onslow Village area and the town centre is fragile as is the A3 that runs past these sites.  Analysis of these areas must, therefore, take into account not only the presence of infrastructure but also its suitability for intensification of use.

If H1 and H2 were to be taken out of the green belt and brought forward for development, H3 and H4 would still, presumably, only score 1 each, suggesting an almost limitless westward sprawl along the north side of the Hog’s Back.  This may indicate some flaw in the binary scoring methodology.

Parcel J1 scores 3, J2 scores 1 and J3 scores 2.


It seems as though there is a clear split in J1 between the western half and the eastern half.  The eastern half could probably infill between Stoughton and Liddington New Road.

Plot J2 is a finger of green which, if J3 were developed, should probably remain as public amenity space and should be protected by the Local Plan rather than earmarked for potential development.

The land designated with the letter K surrounding Tongham and Ash seems to have been treated with different criteria to that around Guildford.

For example, K8 and K9 both scored 3 (which would rule them out for consideration around Guildford, and yet they are put forward for the sustainability test and are ranked 6th and 1st= respectively. This suggests that the methodology applied to one urban settlement or the other could be challenged and there is no obvious explanation in the report.

Section 8 – Stage 4 environmental capacity

There follows a summary of each parcel that the Report recommends is taken out of the Green Belt – omitting some parcels without specific explanation.

It should be noted that the use of coloured plans is prejudicial towards colour blind readers and care should be taken to ensure that no-one is excluded from reading and understanding the specific zoning and restrictions of the parcels of land.

Equally, the summary sheets could usefully set out the scores from the previous exercises in each table so as to place the overall context within the findings.

No specific comments have been made so far in relation to each parcel (other than have already been made above).

Section 8.6 – Recommended Revisions to Green Belt Boundaries Surrounding Urban Areas

The individual plot maps are slightly confusing where two almost adjacent parcels are affected, as the plans only show each successive part in the context of the existing boundary and not also in the context of the other proposed changes.  There does not seem to be an overall master plan in the report to show the cumulative impact of all of the recommendations.

Parcels E22 and E23 are both in an Area of Great Landscape Value and an Area of Outstanding Natural Beauty and should not be taken out of the green belt.

Far better that a significant new settlement in a less sensitive environment should be promoted and excluded from green belt ahead of areas that safeguard the character and appearance of the environs of our historic town.

Section 8.7 – Estimated Residential Development Capacity

The table of estimated capacity from urban encroachments on the green belt and countryside outside the green belt should note both the Areas of Great Landscape Value and should score as zero development on those parcels that fall into AGLV and AONB designations.  To do otherwise is to send a signal to developers that those sites might be capable of substantial development and might make planning policies that preclude development indefensible where those parcels have been removed from the green belt.

There should be a broad estimate of the number of residents that might be accommodated in the extension areas mooted and express that number as a percentage of the current Guildford Urban Area population and the Ash & Tongham population respectively.  At a rate of, say, 2.15 per household, there would be a 20% increase in Guildford urban population even before allowing for additional housing numbers on non-green-belt brownfield sites.  At teh same rate, Ash & Tongham would have a population increase of 30%.

VOLUME II – Conclusion

The conclusion does not comprise a recommendation and does not seek to eliminate the sites such as E22 and E23 where the existing countryside designations coupled with their current green belt status would suggest there is no justification for taking them out of the green belt.


This Volume III takes account of extensions or infilling in villages across the Borough. Each such village – unlike the Guildford Urban Area – has a Parish Council in addition to having Borough Councillors. As a result this review is not intended to be a comprehensive assessment of the rural settlements and their green belt surroundings.

It is worth reiterating two concerns from earlier –

  1. The methodology of screening sites for the villages should also have been used for the Guildford Urban Area;
  2. There is insufficient (if any) attention given to potential options to coalesce settlements with the urban areas to create a once-and-for-all extension without such extensive potential nibbling away of the Green Belt;

At 10.2 the Report notes that “if (the approach adopted for the urban settlements) was applied to the assessment of villages, a number of the villages, potentially including those which performed well in terms of environmental constraints and sustainability criteria, would not have been considered.” This is a clear indication of the inadequacy of the urban land approach.

At 10.7 the Report continues that “the (Potential Development Areas) surrounding villages were only considered to be viable if the purposes of the Green Belt would not be significantly compromised, and if the land parcels were not significantly constrained by environmental designations” which, if applied to the urban areas, would not have allowed the parcels E22 and E23 to be recommended for removal from the Green Belt.

Jacobs Well:

As previously noted, consideration should be given to expanding the Guildford Urban Area to meet Jacobs Well by infilling between Slyfield and Jacobs Well and A3.

This suggestion is to have regard to the ability to provide further housing around a key employment area, bring about sufficient critical mass for improved facilities and services, and to recognise that the North of Jacobs Well represents a long term defensible green belt boundary.

By using infill sites such as this might protect the Downs from development or removal from Green Belt (eg E22 and E23).

In general, the Report is too conservative in some areas (such as Ripley which has the facilities and services to support more development towards the A3, or Send and Send Marsh which could be coalesced whilst retaining the protection of their outer boundaries, etc) and fails to shine a spotlight on potential new settlements (such as at Wisley Airfield) as an alternative green belt solution rather than a comprehensive and broad brush realignment of the Green Belt across the Borough.

The schedule of potential development areas should include a measure of the percentage increase in the existing settlement that the PDA represents.

Equally, because the Settlement Profile Report (qv) does not set out the typical and variance of housing density in each settlement, there is no way to sense check the housing numbers postulated in the schedule. This is indicative of a wider concern about the Report, namely that it is too generic and does not provide enough guidance as to the merits of retaining the majority of the Green Belt in tact whilst carving out sufficient land for a new settlement that could be designed to be sustainable (as defined by the Report) and could be created with strong defensible green belt boundaries.


This section deals with the inserting or otherwise of villages and other settlements and I have not reviews this in detail because this should arise from the thorough review of Volume III and any amendments that may need to be made.

Further comments may be added to this site as fellow reviewers make their views known and, especially where others have more intimate knowledge of the various settlements than I do.

As a final note of caution, I am not advocating any specific development but am seeking to ensure there is a proper debate with alternatives and that some issues that have been omitted or underplayed are raised before a draft Local Plan is issued for consultation based on this evidence base.