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.
THE OTHER KEY ELEMENT FOR CONSIDERATION HERE IS THAT THIS IS LAND THAT WAS EARMARKED FOR FUTURE UNIVERSITY EXPANSION AND COULD BE A CRITICAL COMPONENT OF GROWTH (EG., OF THE RESEARCH PARK). IT SHOULD NOT, NECESSARILY BE BROUGHT FORWARD AS A MAJOR HOUSING SITE.
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.
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.
ONE AREA OF OMISSION SEEMS TO BE THE FAILURE TO IDENTIFY A SITE FOR A NEW SETTLEMENT (SUCH AS WISLEY AIRFIELD) IN THE SHLAA, AND THIS SHOULD BE ADDRESSED FOR CONSIDERATION UNDER THE ISSUES AND OPTIONS CONSULTATION.
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||–|
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.
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.
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.
NO REFERENCE HAS BEEN MADE TO THE POTENTIAL TO SITE RESIDENTIAL USES AS PART OF THE NORTH STREET DEVELOPMENT AND THE INTENDED RESIDENTIAL UNITS ON THE BELLERBY SITE (AS PART OF THE SUPERMARKET DEVELOPMENT) HAVE ALSO APPARENTLY BEEN OMITTED.
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.