Guildford Plaza response
Planning Scrutiny Group,
14 - 16 Friary Street
Planning reference number 21/P/01811
Construction of co-living accommodation (Sui Generis) with associated communal facilities, basement parking, landscaping and groundworks | Guildford Plaza (former Burymead House), Portsmouth Road, Guildford, GU2 4DH
Extinction Rebellion Guildford Planning Scrutiny Group is a group of volunteers with the aim of contributing positively to planning applications to help prevent climate breakdown. We come from different areas of Guildford from a broad range of backgrounds from design, to civil engineering. Our aim is to ensure that all new development puts the ecological and climate emergency - and by extension wellbeing of the people, front and centre of the planning process.
Overall, we object to this development. Our main objections are the following. Further recommendations are highlighted in the main body of our letter.
1. Energy generation - solar power: This site has ample unshaded roof space, much of which is already at a reasonable angle and orientation for solar panels as per the current plans. There is no reason provided for not installing solar PV panels, which in an otherwise relatively energy-efficient building could provide a significant amount of the development’s total demand, as well as lowering bills for residents.
2. Habitability - air pollution and heat: Windows will need to be permanently closed due to the high level of air pollution in this area as alluded to in the documents submitted. It will be near impossible to provide efficient natural ventilation if this is the case, as residents will be unable to open windows so as to create a through-draught. There is also no shading to windows, risking a common feature of modern apartments in that they will be uncomfortably hot during summer and increase the need for air conditioning, will increase the demand for electricity.
3. Active travel: We welcome the emphasis on active travel, and the lack of car parking spaces for private cars, but the cycle storage provision is woefully inadequate at 151 spaces when the accepted requirement is 1.5 spaces per double room i.e 452 spaces. It is not clear if there will be storage provided for private bicycles / larger cargo bikes / bikes with trailers / tricycles / adapted bicycles. We are also concerned that the route into town is very unsuitable for cyclists - the gyratory is almost never used by cyclists. Improvements to cycling infrastructure should be contributed to by this development.
4. Habitat for wildlife: The development site is classed as brownfield land, but it is ecologically classed as Open Mosaic Habitat, and as such is of importance in the context of the biodiversity crisis. The site provides a habitat for wildlife within 5km of SSSI sites. It is already recognised that brownfield can have a high ecological value - and that will be reflected with a change to the law in 2023 which will require brownfield sites to be aiding biodiversity. More consideration of how to increase the biodiversity of this site can also tie in to providing more non-paved outdoor space for residents.
1.0 Green space and urban design
1.1 Site designation
It is good to see a brownfield site being used rather than a greenfield or greenbelt site. However, as noted by Natural England, the application could have potential significant effects on Whitmoor Common SSSI and/or wildlife corridors locally.
The ecological appraisal report states that this site is ‘Priority Habitat Open Mosaic Habitat on previously developed land’, and that it ‘constitutes an important ecological feature of value at the site to local level’.
As such, this site should be considered an important habitat that must be preserved and improved upon as much as possible.
Climate change adaptation must be an essential part of the planning process for any new building or development, with UK climate and weather set to become more like southern Europe in the next 30-40 years. During heatwaves, poorly-designed residential blocks have been at best uncomfortable, and at worst dangerously overheated. Green infrastructure, as well as other natural features can help lower urban environments by a considerable amount (https://theconversation.com/after-another-hot-summer-here-are-6-ways-to-cool-our-cities-in-future-110817). We would encourage the council planning department and committee to understand urban centres as urban heat islands (UHIs), which further add to ambient temperatures. Research has found that urban spaces without green infrastructure can be up to 20°C higher because of the effect of high thermal mass concrete, etc.
While we note that there are green spaces planned, we’d like to add the following recommendations:
Living walls can also help provide insulation and cooling, whether relatively high-tech (shrubbery frames, etc) or low-tech (moss walls), and reduce some forms of air pollution.
Lighter-coloured pathways can significantly cool the surrounding areas.
Waterways and/or water features can be integrated into this urban setting to help mitigate particulate air pollution, provide cooling in the heat of the summer, and also help support wildlife as a source of water.
1.3 Trees and Wildlife - ecological value
Through providing shade, retaining water and directly absorbing heat, trees help reduce the UHI effect. They can also help mitigate air pollution, improve mental and physical health, prevent flooding, improve air quality, significantly increase local biodiversity, improve property values, and more (https://doi.org/10.1002/ppp3.39).
We recognise that the site plans include the planting of nine new trees. If possible, we would also like to see more attention and detail paid to the possibility of planting hedges and other lower level vegetation, particularly to screen the site from nearby roads and provide habitats for small birds. The value of scrubland to local biodiversity is increasingly being recognised, but has not been taken into account in this application, with the existing scrub labelled ecologically low-value seemingly by default.
We would like more detail as to the replacement planting that will be undertaken in place of the existing trees and scrub which will be cut down, and would encourage saving at all costs the vegetation that is already there. While these may be given the definition of ‘low-value’ in construction terms, a visit to the site, as well as the ecological appraisal report, makes plain that the existing vegetation supports a wealth of life and a variety of species.
We would like assurances that the replacement planting will be of significantly greater scale than that lost, and that this planting will be maintained and supported to maturity.
There is only one existing mature tree on the site; a walnut tree (tree1). It has low ’bat roosting potential’ but is still an asset visually and ecologically. It was not removed when the site was cleared for a previously consented development, so why can efforts not be made to retain it for this development? The space available to bring trees into the development is limited because there is so much building and associated soakaway crate drainage where large growing trees would not be suitable.
Every effort should be made to preserve the asset, tree1. It is in a conservation area after all.
Could a micro-forest be considered?
The ecological appraisal report states that species using the site ‘are not a material planning consideration and the loss of potential opportunities for these species to the proposals is of negligible significance’. These species include Fox Vulpes vulpes, Woodpigeon Columba palumbus, Blue Tit Parus caeruleus, Goldfinch Carduelis carduelis, and Magpie Pica pica, along with other fauna including ‘non-priority’ species of mammals and invertebrates.
We disagree with the idea that any part of a functioning ecosystem is of ‘negligible significance’, particularly given the findings that UK wildlife populations have plummeted by an average of 60% since 1970. We need to take every opportunity to nurture and improve biodiversity in all settings, rather than taking an ‘island conservation’ approach.
‘EE2 - Bat Boxes’ states; ‘A number of bat boxes will be incorporated within the proposed development. The provision of bat boxes will provide new roosting opportunities for bats in the area, such as Soprano Pipistrelle, a national Priority Species. A number of integrated bat boxes / roost features should be incorporated into the new build. So as to maximise their potential use, the bat boxes should ideally be situated as high up as possible and sited facing a south-easterly, southerly or south-westerly direction, such that they are exposed to the sun for part of the day. The precise number and locations of boxes / roost features should be determined by a competent ecologist, post-planning once the relevant final development design details have been approved.’
We would like to see more detail as to the number and siting of bat boxes during the planning stage, rather than after approval.
Wood piles are welcome - but how will the development not disturb the wildlife these will house? We would also caution as to starting building work with biota as an afterthought, particularly given where this type of thinking can lead - for example, the disgraceful root cutting of two established oak trees in nearby Stoke Park which were ultimately felled.
We note that the majority of the landscaping on site looks to be paving, etc, rather than grass or other vegetation.
In light of the climate and ecological crisis, we would like to see more green areas, which would also help with flood mitigation. This could be a mixture of wildlife focussed habitats (e.g ponds, reeds, scrub, hedging etc) and areas for leisure - lawns, trees, benches.
Is there the potential to provide areas for residents to grow their own vegetables or plants?
2.0 Sustainable Living
2.1 Lifestyle and wellbeing
Co-living is a good use of the space available and has additional social benefits.
2.2 Transport and travel
The site has excellent opportunities to benefit from sustainable transport - for example, nearby train and bus stations, convenient bus services and being close enough to the town centre for residents to cycle or walk.
We support the lack of private car parking space which will encourage active travel. It is realistic to expect a significant number of residents to want and/or need to travel by bicycle because of this.
However, 151 cycle parking spaces is simply not enough storage space in the cycle store to readily enable this. 452 spaces will be required (accepted requirement is 1.5 bicycle spaces per double room (ref https://www.london.gov.uk/sites/default/files/london_plan_evidence_base_-_cycle_parking.pdf). 25% of these spaces should be for larger cargo bikes/bikes with trailers/tricycles/adapted bicycles.
We support the idea of a cycle hire scheme as well as private bicycle storage.
Can this be set up at the outset rather than being an aspiration for the future?
How will theft of bicycles (including electric bikes) be prevented? Electric bikes have been stolen from secure parking areas where all residents of a building have access to a cycle store. Therefore will there be a security camera and will the times and ID of keycard entries be logged? A greater number of cycle enclosures could improve security.
Consider providing bicycle lockers for more expensive bicycles.
The number of lockers in the cycle store area for cycle helmets, shoes and cycle gear, should be the same as the number of cycle parking spaces.
Consider providing a shared use bicycle pump, and bicycle stand for maintenance work in the cycle storage area.
Section 6.5 of the Design and access statement states there will be 12 visitor cycle parking spaces on the lower courtyard, but only four are visible on the plan.
The 20m long ramp with gradient of 1:8 will be quite strenuous for a heavily laden cargo bike or bike with trailer.
Could the cycle storage be moved to road level?
There are currently no cycle lane or cycle tracks surrounding the development. Cycling to the north there is no safe way to cycle across the one way system/gyratory. The recommended cycle route east and up the high street described in the literature is pedestrian only during the daytime. Cycling south there are no cycle lanes or cycle tracks along Portsmouth road. Several amenities are mentioned in the literature as being conveniently situated for cycling, such as Waitrose 5 minutes by bicycle, but there is no safe cycle route there without negotiating the four lanes of the gyratory. This lack of infrastructure is a huge barrier to cycling as a method of sustainable travel from the development. The statement “It is considered that there is a good level of high-quality pedestrian and cycling infrastructure surrounding the site providing access to a range of key services and amenities.” (ref 5.7.1 Transport Assessment) is incorrect.
Local cycling infrastructure is desperately needed. Development to financially support community infrastructure.
The Transport Assessment takes the Travel to Work dataset from the 2011 Census for residents in the local ward, and adjusts these due to the car free nature of the development to give the following proposed travel mode shares: Walking 38%, Cycling 4%, Public Transport 56%, Car 2%. Surely the figure for cycling is still far too low and has not been adjusted?
Proposed travel mode shares to be challenged, particularly cycling at 4%, and impact on/lack of local cycling infrastructure subsequently reviewed.
We support the decision to minimise car ownership in this town centre site with excellent active travel and public transport connections.
Is providing just two car club spaces sufficient for 301 double bedroom studios?
We note that there will be electric car charging points at some car parking spaces.
We believe every parking space should be equipped with electric charging facilities. Given the lifespan of this development, and the inevitability of a shift to electric vehicles, all cars parked on site will require electric charging long before the end of life of the development. Installation now will be significantly cheaper than retrofitting after construction, and will visually demonstrate a further commitment to less polluting travel above that which has already been undertaken.
The current bus stop is on a relatively steep hill. Drivers will often hold vehicles on the clutch before over-revving as they move off again rather than applying the handbrake and shifting into neutral gear when waiting behind a bus. This generates significantly more emissions and exhaust fumes than drivers idling behind a stopped bus on a level road.
The scheme would therefore benefit from the bus stop being set back from the road to allow passengers to get on and off without holding up traffic.
The scheme would benefit from a taxi drop-off space to the side of Portsmouth Road as there is currently no safe area for taxis to stop.
We are pleased to see that this proposal uses significant passive measures of reducing energy demand, such as good air tightness, high u-value materials and orientations based on daylight. If GSHP is deemed not suitable for this site then the installation of ASHP is an acceptable compromise, given that there is no large-scale district heating network in the local area.
However, we cannot see why neither PV panels for generating electricity, nor solar hot water panels, have not been adopted for this site. It is accepted that these panels compete for the same amount of roof space, and that solar thermal technology may not be the best fit for this type of development. Why then, if the Energy Statement specifically states that ‘solar PV would likely offer greater CO2 emission reductions with the same area’, has there been a decision not to adopt solar PV?
In E.1.4, unlike in all other sections in E.1 Low and Zero Carbon Technologies, there is no reason given not to adopt PV solar panels to significantly lower the CO2 emissions of this site.
We call on the developers to reverse this decision and generate what could be a significant amount of the electricity used to run this development - particularly given the reduced energy demand achieved through materiality and other methods - on site and in a low-carbon manner.
2.3.1 Domestic energy use
The provision of shared cooking and leisure facilities is very welcome.
We would like to see fully electric kitchens installed if possible, and for all kitchen and other appliances to be maximum-rated for efficiency. This can be noted in sales publicity for potential purchasers as both an environmental positive and also a way to reduce bills.
There appear to be no areas for drying clothes naturally. Tumble dryers are the least energy-efficient way to dry textiles.
Is there the potential to provide spaces to hang-dry clothes?
Most studios have only one window which is generally not sufficient to provide adequate natural ventilation; through ventilation is much more efficient. Can additional natural ventilation be built in through the communal areas to prevent the need for air conditioning, which is energy intensive?
3.0 Water, Flooding and Drainage
3.1 Foul Drains
There are unknowns about local sewers and the suitability for connection from the site. It is being assumed that connection for half the site will be to a sewer which is higher than the planned basement floor. This would then require a pumping system with emergency storage, which would be significantly less efficient.
We hope that alternatives can be found that maximise the use of gravity systems over pumps.
Calculations for foul flows are made on single occupancy of 301 studios. All the studios show double beds and so it must be assumed that two people may live in a studio. This would increase the flow in the foul sewers.
The assumption that the flow from the office block previously on the site would be similar to a residence of 301 studios does not sound feasible, even with newer water saving fittings. For example, 301+ people may all use the shower and toilet within the same short period of time each morning in a residence, whereas the people in the offices would not do that.
3.2 Surface Water
The site is mainly Grade 1, low flooding risk, but to the east side, there is an area of grade 2, medium risk where the site is 80m from the River Wey. It is the Wey and rising groundwater (medium risk) that are the main risks. The area has a history of flooding and there are flooding levels marked on the north side of nearby St Nicolas church showing flood water levels in previous years. The entrance to the basement is vulnerable as it is located in the area most at risk; it is surprising that it was located here and not in a less vulnerable spot. Also, the flood protecting mound at the entrance will mean that car headlights will disturb the residents opposite at 5-11 Bury Street as cars drive over it.
Run off from a new development must not be greater than the run off from the original greenfield. Guildford Borough Council does not approve of the discharge levels (17.5l/s.) and Thames Water does not approve of the level of storm water discharge into public sewers. Additional measures will be needed to meet the requirements.
The presence of a ’highly sensitive and vulnerable aquifer’ beneath the site is an additional problem for infiltration of surface water and considerable care must be taken during the construction process to ensure water sources are not polluted.
The large areas of soakaway crates on both podiums is a concern for future maintenance of the buildings, as they will not support the weight of heavy vehicles. The sustainability requirements are that the building should have ‘functional adaptability‘ and be able to be extended or have major refurbishments in the future.
The presence of critical sewers and mains nearby make the site additionally challenging, as they could be damaged, especially if piling is used, and this risks sewage pollution entering the river.
The basement is potentially below the ground water level. Use of pumps to remove surface water within the basement is not considered to be sustainable.
The use of passive irrigation for the plantings is excellent. Green roofs and green walls would be even better and would absorb water as well as providing cooling and carbon storage.
It is likely that Environment Agency regulations regarding flows into the drainage system will be tightened again. Please bear this in mind as buildings should be designed to last at least 100 years.
4.1 Effects on surrounding properties
The document written by Eb7 is incomplete in that any change in light is measured in comparison to a ’previously consented development on the site’ and not from the current situation, nor even from the building that previously occupied the site. This means that negative changes to daylight and sunlight at nearby properties are shown as very small or zero and in some cases are deemed to be improved! At particular risk are the Alms Houses in Bury Street.
This does not give an accurate view of the damage that will be caused to the availability of daylight and sunlight to surrounding properties. A comparison must also be made to the current situation to enable a fair and accurate understanding of the impacts on light of this development for surrounding buildings and residents.
4.2 Daylight in the proposed development
The Building Research Establishment recommends that the ADF (average daylight factor) for rooms is 2% for kitchens, 1.5% for living areas and 1% for bedrooms. A value of 1.5% has been chosen here as an average for the studios. The studios, such as the Type 1, tend to be deep with natural light at one end and so artificial light will be required in the back areas, usually the kitchen areas, during the day. Even with this lower level being used, 19% of the studios fall below it and have less daylight than recommended.
This will affect resident wellbeing and require increased electricity use, and is unacceptable. Every effort should be made to ensure that all studios receive adequate natural light.
A proportion of the studios have balconies which will alleviate lack of daylight and provide an opportunity to be outside. However, in other site documents it is noted that the levels of air pollution on site may require residents to leave their windows closed permanently, suggesting that balconies will not be used, as is often visibly the case in modern blocks of flats with balconies.
Further, for all those who have no balcony, it is not clear if they can access the Living/Kitchen/Dining areas on their floor or if they will have to go downstairs to communal areas or outside to the limited outdoor space.
A reason given for the lack of daylight is that windows are being obscured by the balconies.
Surely it is possible to design a building where both can be present without detriment - for example, by staggering windows and balconies?
5.0 Air pollution
Air pollution from traffic has reached unsafe levels in Guildford Borough, particularly NO2. The centre is now part of an Air Quality Management Area. We would question therefore, adding housing to an area deemed to be of risk to human health. Residents must be able to open their windows and use their balconies, and an elaborate air filtration system and air con is energy intensive - something we want to avoid in an ecological crisis. It is also of no use when residents step outside for some (fresh) air.
Building works inevitably create a lot of dust - and we are concerned that this construction operation will add yet more dust, even if mitigation measures are in place - this is recognised in the ecological report.
‘Of the threats to the SPA and SSSI that are listed above, public access/disturbance and air pollution are of relevance to the proposed development and an assessment of the likely effects of each threat and any associated mitigation is provided below.’
We note that the air pollution report recognises that the site is within a high pollution area - and that the ground floor is particularly exposed.
Given this, we question the effectiveness of measures in the application to minimise the impacts of air pollution, and particularly whether residents will be able or even advised to use their balconies as provided. Further thought and attention should be paid into how best to ensure residents of this development and also neighbours can be protected from poor and worsening air quality.
What are the two rooms to the far north on the proposed lower ground floor plan for? There are rectangles with crosses within, in the rooms.
In an ideal world without the constraints of the housing crisis and the legal responsibility to provide housing, this would be an ideal spot for a public park, helping provide a nature corridor between the habitats to the north, south and west of Guildford and creating a large town centre natural space for people to enjoy. However, we recognise that there has been a reasonable effort to ensure this development is sustainable in terms of living plans, materiality, energy efficiency, and other areas.
However, we believe the above issues need to be addressed before the application can be supported. This application goes some way towards addressing issues including the climate crisis, having too many cars on our roads, and others - but given the length of time this development will be a feature of Guildford’s built environment, and the urgency of many of the issues at stake, it can and must be improved upon in the ways listed above