Planning Scrutiny Group, Guildford, Surrey
Planning reference number 21/P/02333 Cathedral
Demolition of existing Cathedral Close dwellings and erection of 124 no. residential units with associated engineering works, access, landscaping, parking and ancillary works | Land South and East of The Cathedral Church Of The Holy Spirit, Stag Hill, The Chase, Guildford, GU2 7UP
Overall, we object to this development. Our main objections are the following. Further recommendations are highlighted in the main body of our letter.
Energy: The UK has a legal commitment to carbon neutrality by 2050, and consequently gas boilers will be banned in new builds from 2025. This will put this development on the border between inefficient, polluting gas boilers and a requirement to install greener heating options. For the sake of residents (who will be stuck with high fuel bills which will only get higher as fossil fuels inexorably increase in price) and for the climate/environment, including future generations and our wildlife, these boilers should be replaced with efficient electric boilers or other green active technologies, or ideally designed out altogether in favour of insulation, thermal mass and/or heat pumps.
Flooding: There is a risk of flooding to properties downhill of the development from runoff, on- and off-site. The rejection of Grey Water use for flushing toilets should be reversed. The incomplete SUDS data must be completed. The loss of mature trees, and more hard landscaping will further worsen the run-off.
Transport: There is no safe cycle route to the station or into the town centre. The cycle storage, particularly for the private dwelling, is inadequate and woefully small. Cycle storage for the apartments to be at street level and directly accessible from the street.
Loss of trees - we note that 26 mature trees are to be cut down, under these proposals, and in total 70. Re-planting cannot match decades of growth and root systems. We would suggest building takes place on an alternative brownfield site which would not implicate a loss of biodiversity or habitat.
Air pollution: The housing proposal is in an area of unsafe levels of air pollution, very close to the A3. At present there are no proposals to address this.
1.0 Green space and urban design
1.1 Site designation
We are concerned that this housing development seems to be using up a significant portion of the little green space left in this densely built-up area of Guildford. We are also concerned that a lot of space is taken up with car parking spaces. We should be building on brownfield wherever possible, not greenfield.
1.2 Biodiversity and trees
26 mature trees are to be cut down, and in total 70 according to the report. We note that during construction there could also be some disruption to the root systems of other trees. While we are pleased to see a community orchard and other ‘replacement trees’ are planned, new trees are no replacement for an established tree ecologically.
The report notes “A parcel of deciduous woodland habitat of principal importance is present within the application site and could be impacted by the development through direct removal, destabilisation of tree roots and pollution”. Dense scrub vegetation is also found on this site, and is a valuable habitat for many species. The ecological report notes “Significant nesting bird potential was identified in buildings, woodland, scrub and scattered trees throughout the application site. Old bird nests were observed in trees on several occasions during the survey visit”. Similar reports are given for reptiles, including slow worms, and bats.
❖ More effort must be made to retain valuable habitats, particularly for species which are protected, endangered or threatened.
1.3 Subsidence risk
The water table is high. The underlying strata is London Clay which is non-porous and prone to causing subsidence, especially on steep slopes. If additional cost is incurred, such as in piling, to ensure stable properties, any consequent increase in cost is usually balanced by a reduction in affordable housing planned by the developer, which we also oppose.
1.4 Layout and building design
We note that a lot of the dwellings along the western parcel are houses of a detached or semi-detached nature. These houses will lack the potential for co-working, laundry space, etc that semi-detached and/or terraced properties offer. Terraces would also enable the same number of units to be built on a smaller footprint, along with additional benefits such as shared insulation through party walls, etc.
❖ We would suggest that the car parking area is in one place at the entrance to the development - and car club spaces are allocated. This would mean that the area was more pedestrian friendly and safer for children and wildlife - and reduce the need for access roads (more lost green space).
2.0 Sustainable Living
2.1 Lifestyle and wellbeing
Every effort should be made to ensure residents can live as sustainably as possible. This includes everything from providing active travel and public transport links through and to/from the site, to ensuring dwellings are powered and temperature-controlled passively and with green infrastructure, to retaining and replanting as many trees and green spaces as possible.
❖ All dwellings should take account of adequate natural light. 2.2 Transport and travel
To avoid conflict between pedestrians and cyclists, the two should not share the same path.
❖ Sustainable Transport Route to have segregated cycle and footpath.
❖ Connection to Yorkies Bridge to be approved by the university
Although there is good cycling infrastructure on the route to Tesco and Surrey Research park, this is only in one direction and there is no safe cycling route into town or to the railway station; cycling on Guildford Park Road is particularly problematic. It is not currently suitable for less-confident cyclists, let alone encouraging people who do not currently cycle to start.
The Design & Access Statement part 3 describes an existing enhanced cycling connection to the railway station which simply does not exist.
❖ Guildford Council to seek cycling infrastructure funding from development via section 106.
❖ Improvements for Guidford’s Sustainable Movement Corridor 2 (cycle route to Yorkies Bridge) to be brought forward.
Alresford Road and Ridgemount are the current natural choice for cyclists cycling towards the station. The addition of all the vehicles from the development linked to this road will reduce safety for cyclists and pedestrians on this route.
In the artist images within the Design & Access statement (see Figure 1), the shared pedestrian/cycle route appears to be cobbled which is uncomfortable and less safe to ride on, particularly in wet weather and on a slope. This will further disincentivise cycling and walking in favour of driving, particularly for new or less-confident cyclists.
Figure 1, image of cyclist on cobbled street ref Design and Access statement
❖ Shared pedestrian/cycle routes be smooth for comfortable, safe cycling.
To avoid conflict between pedestrians and cyclists, the two should ideally not share the same path.
❖ Sustainable Transport Route (dark solid orange, running east west in Figure 2) to have segregated cycle and footpath.
Figure 2, Connectivity image from Design and Access statement, part 6
❖ Connection to Yorkies Bridge in Figure 2 above to be approved by the university.
❖ A flatter circular route around the cathedral to be considered for the Sustainable Transport Route to avoid the steep hills at each end of the site.
The cycle storage for the apartments described in the Design & Access statement part 10 shows the blue spaces to have additional space suitable for oversized bikes (see figure 3) - however these spaces are the same size as all the other spaces, and are insufficient for oversized bikes.
Figure 3, cycle storage for apartments. Ref: Design & Access statement part 10
With numbers of electric bikes increasing, the number of larger cargo bicycles is similarly likely to increase considerably over the lifetime of the development, particularly given its location relative to local shops and the town centre (a quick cycle, but a significantly longer walk, particularly for those doing a weekly shop or with young children). Department for Transport’s LTN1/20 Cycle Infrastructure Design states that a cycle design vehicle should be 2.8m x 1.2m, and cycle infrastructure should be designed for this. The blue box drawn in
Figure 3 shows a cycle design vehicle. Clearly, the cycle storage as currently planned is not fit for purpose in this regard.
❖ Cycle storage to accommodate larger cargo bicycles.
❖ Cycle storage to provide lockers for helmets and bicycle equipment.
The cycle storage provision for the private houses (see Figure 4) requires lifting one bicycle over the handlebars of the other which may be difficult or impossible for some, and is certainly inconvenient for everyone. To promote cycling over car use it must be easier than taking the car. The cycle storage also does not provide storage for anything other than standard bikes. To take an example from countries with excellent cycle infrastructure and rates of cycling compared to driving, in the Netherlands the requirement is for lockable bicycle storage of at least 5 square metres.
Figure 4, cycle storage provision for private houses
❖ Cycle storage provision for private houses to be minimum 5 square metres to encourage cycling, and allow for oversized bicycles, trailers, adapted bicycles and cargo bicycles.
The cycle storage for blocks F, G, H, I, J and K is not at street level. It is not directly accessible from the street; this is a minimum requirement in the Netherlands, for comparison. For several of the blocks it is expected that bikes will be carried up or down stairs, and through four narrow doors, see Figure 5.
❖ Cycle storage to be at street level and directly accessible from the street.
Figure 5 Route from cycle storage to street level for Block I, ref Transport Assessment Appendix H
Guildford’s climate emergency declaration requires planning to “encourage car share schemes” - however, despite the large scale of the development, there are no spaces allocated for car share/car club schemes. The nearest car club space is at Bedford Road, an 18-minute walk away. Green space is lost to private car parking - in many cases, two spaces per dwelling.
❖ Allocate spaces for car share/car club scheme.
With the significant impact on the environment that all new building developments bring, the council should be doing everything in its power to ensure that all housing developments are as climate- and environment-friendly as possible. This applies not only during construction and immediate impact, but also on an ongoing basis during the lifespan of any development.
The UK has a legal commitment to carbon neutrality by 2050, and consequently gas boilers will be banned in new builds from 2025. This development will therefore be close to the cut-off point for this ban. It is shameful that the energy report for a new development of 124 residential units, to be completed only just before the 2025 deadline if at all, plans to install gas boilers. Even disregarding the climate, environmental and other impacts, the claim that gas boilers are the most cost-effective solution to the problem of heating fails to take into account alternative passive and active technologies for heating.
❖ Passive heat retention methods such as improved insulation and greater thermal mass to be instituted as a priority.
❖ Alternative active heating solutions to be considered, such as solar hot water - which can be implemented far more cheaply than gas boilers, while also avoiding all or almost all of the negative impacts of 124 new gas boilers.
The Sustainability Report claims that gas boilers can be decarbonised and ultimately be converted to run on 100% hydrogen. Firstly, unless these boilers are specifically hydrogen-ready boilers - significantly more expensive than standard gas boilers - this is incorrect. Secondly, there are major infrastructural and other problems with generating hydrogen and building the infrastructure required to transport and store it. Consequently, the idea that all homes will be heated with hydrogen in the short- or medium-term future is similarly incorrect. Additionally, ‘green hydrogen’ - produced using renewables, as opposed to ‘grey hydrogen’ produced using fossil fuels - will not reach commercial viability in the near future, and so the report’s insinuation that these boilers can be sustainable at some point is also incorrect.
Bearing in mind the UK’s legal commitment to carbon neutrality by 2050, not to mention the council’s stated ambition to minimise the climate, environmental, ecological and human impacts of increasing emissions and air pollution, the fact that the energy report dismisses the use of air source heat pumps is especially disappointing. This technology, along with electric boilers, may currently be more expensive per unit than gas boilers, but over their lifetime will be significantly cheaper to run and maintain, especially as gas boilers are rapidly replaced by these technologies. In a development of this size, there is also potential for district heating via ground source heat pump, which when applied across all 124 units plus possibly other local buildings (either immediately or in the future) would ultimately be more cost effective than individual gas boilers. Of course, any of these three technologies will be far more cost effective in any case than gas boilers in all but the shortest of short-term calculations - before even factoring in the costs of climate, environmental, ecological and human costs.
❖ Air source heat pumps, ground source heat pumps and electric boilers to be considered.
❖ Larger-scale district heating to be considered - particularly as the application refers specifically to a presumed lack of efficiency for 124 separate heat pumps.
Given the 2025 ban on gas boilers, along with inexorable increases in fossil fuel prices we will see in the coming years, installing gas boilers in this development will see residents burdened with high fuel bills which will only get higher still. The current energy crisis has brought into sharp relief once again the impact of fuel poverty on communities, even in our relatively rich area. The fact that Surrey has more older residents on average than many other counties is also important, given the surge of winter deaths and ‘heating or eating’ incidents we experience during every bout of cold weather. By contrast, implementing passive heat retention such as insulation and high thermal mass, coupled with energy-efficient and futureproof active heating such as solar hot water or heat pumps would not only reduce these incidences, but also save residents thousands of pounds on fuel bills - boosting property values and paying for any increased capital expenditure invested in these solutions.
The council should be insisting that all new developments use alternative heating methods well in advance of the 2025 cut-off point for new gas boilers.
❖ Therefore this development should not be approved until green passive and active heating methods are proposed. If the developer refuses to replace gas boilers with solutions that meet reasonable climate, environmental, ecological and human targets then the application should be rejected.
This development should seek to reduce energy use and carbon emissions from electricity usage, which would also reduce bills for residents.
❖ All appliances installed as standard in this development should be of the highest efficiency standards - eg. A+++ rating or equivalent.
We welcome the decision to install solar PV panels in this development. However, roof orientation for most roofs on site appears to be east-west, which means panels will not be positioned for optimum efficiency (south-facing) despite the massing plans for the development largely facilitating this as an option. It is uncertain from the report whether this has been taken into account when estimating the emissions savings, or whether this is based on a flat rate and will in fact perform below this level.
❖ Consider whether placement of solar panels could be optimised for more efficient electricity generation and therefore lower emissions and bills.
3.0 Water, Flooding and Drainage
3.1 Risk to Aquifer
The site is in a groundwater source protection zone. The aquifer is beneath the clay layer but RSK site investigations have shown that water is reached in some areas tested at just 0.8m below ground level. The aquifer could therefore be at risk of contamination during construction work.
❖ Measures to be put in place in the plan to protect the aquifer during construction.
3.2 Surface Water Runoff and Flooding
There is a drop of some 17.5m in the site. The land is lower on all sides of the development, except the Cathedral side, and which reduces the risk of flooding on the site itself. The site is Grade 1 (low risk of flooding).
However, there is a history of flooding from Cathedral site runoff in Ridgemount, Arlesford Road and Linwood areas, at the base of the hill. The Environment Agency map shows the natural route of the runoff is to the east of the Cathedral Cottages, then south through properties in Ridgemount and Lynwood.
Additional buildings and roads on the site will reduce the surface area for absorption and increase runoff. The permeable paving to be used does not have optimum performance because of the underlying non-porous clay. Removal of trees and plants will also remove their ability to store water. Currently, 91% of the site is permeable but the proposals result in only 76% being permeable.
Courts are increasingly recognising the role of neighbouring land use changes and new developments in causing flooding, and there is a considerable body of case law in relation to new developments causing flood damage to surrounding properties. Should nearby residents experience additional flooding during or following the construction of this development, there may be a legal case to answer for the developer and landowner.
❖ The proposal must detail how additional runoff water will be dealt with to prevent flooding of the site and roads and properties downhill beyond the site.
Increased intensity and frequency of precipitation in the UK through climate change is likely to lead to reduced infiltration and increased overland flow. The sustainable drainage system will be designed for what is currently defined as a ‘1-in-100 year event’. An extra 40% allowance for climate change is being added to the calculations, but this is no more than a ‘best guess’. Currently, records are being broken all the time as the impacts of climate change worsen. Given the significant increase in extreme weather events far less likely than ‘1-in-100 year events’, we believe these measures may not be enough.
❖ Choosing a safer site or substantially reducing the surface area changed from permeable to non-permeable would be far preferable.
The Building Regulations Part H21 require that the first choice of dealing with surface water should be soakaways or infiltration, but the clay ground prevents this. The next choice would be joining into a watercourse, but none exist nearby. The third, and least sustainable, is for the water to join the local surface water sewer. The flow to the sewer can be attenuated, preferably by above ground attenuation ponds and basins or above ground swales. There was said to be too little room for these on the site but some have now been squeezed in at the south of the site. The less sustainable alternative is below ground storage of the water, in crates or tanks. All the water from a 1-in-100 year climate change storm generated on site will be stored on site and discharged to the nearby surface water sewer. All of these surface water measure will require long term maintenance and funding.
❖ Is this the right site for a development of this type if the surface water cannot be dealt with on-site and in a sustainable way?
3.3 Grey water
Grey water use was considered for the site but was rejected because of extra cost and because clients would not like its appearance.
We are in a climate emergency and need to do everything we can to reduce waste of every kind. Using drinking-quality water for flushing toilets for cosmetic reasons is clearly absurd at the best of times, and particularly in a climate emergency when we should be aiming to reduce the impact of catastrophic climate change on future generations.
❖ The rejection of grey water use for flushing toilets should be reversed.
3.4 Incomplete SUDS information
SUDS (sustainable drainage systems) at Surrey County Council are not satisfied with the figures for runoff from the site and are thus not able to calculate the increased flood risk on- or off-site.
❖ The proposal should not be approved without full completion of runoff data - this is essential.