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St. Mary’s Wharf/Debenhams


Planning Scrutiny Group, Guildford, Surrey 


Planning reference number 21/P/02232

St. Mary’s Wharf/Debenhams

Demolition of existing building and erection of two buildings comprising residential accommodation (Use Class C3), retail floorspace (Use Class E) and cinema (Sui Generis), erection of a retail pavilion (Use Class E), together with car and cycle parking, plant and all highways, landscaping and other associated works. | Debenhams, Millbrook, Guildford, GU1 3UU

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. Air Pollution: The block is planned in an area of high air pollution which falls under the AQMA for GBC. Unsafe levels of toxic air have been recorded in the area - at more than twice the maximum WHO safe levels, and the St Mary’s Wharf site is next to a road with high volumes of traffic marked for monitoring. Residents should not be exposed to high levels of air pollution until a plan has been put in place to mitigate this situation.

2. Urban habitat: The climate and ecological crises include a global biodiversity crisis. The UK is one of the most denatured countries globally, and Guildford has already lost a lot of greenbelt, along with valuable wildlife habitats. The NPPF aims for a net gain to biodiversity - yet despite GBC declaring a climate emergency, we note that seven trees are set to be lost, and others are at risk from root disturbance. There is no SANG planned, even though the recommendation for this density of residents would be an area of 2-4 hectares. 

3. Habitability: The plans show two very large buildings close together with a high density of residences. We feel that the resulting low light levels for residences facing the commercial building, as well as the limited space, both internal and external, make it unsuitable for a good level of residential amenity. The commercial building plans would be a better fit of the two proposals.  We feel that there is a lost opportunity to make the most of the space, and improve sustainability, with co-living spaces.

4. Transport: The use of e-bikes is likely to become more and more popular over the lifetime of the building, opening up the use of heavier cargo-laiden bicycles, yet only 15 spaces are provided for larger bicycles, and these larger bikes will not fit in the lift to access the cycle storage areas in the basement. Cycling among disabled people is popular - however, there are only three cycle parking spaces where a person can transfer from a wheelchair to a parked bicycle. The lack of cycling infrastructure near to the site is a huge barrier to cycling. It is vital that the development financially supports community infrastructure via a section 106 agreement. Additionally, there is no provision for car club spaces. A development of this size should promote car sharing via a car club rather than providing private car parking for those who happened to be first to move in.

5. Flooding: The Site is in an area of very high flood risk which is extremely likely to worsen with climate change. The evidence provided to calculate the new lower flood risk rating is questionable.


1.0 Green space and urban design


Climate change adaptation must be an essential part of the planning process for any new building or development, with the UK climate 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.


1.1 Site designation


It is good to see a brownfield site being used rather than a greenfield or greenbelt site.


1.2 Building footprint


The report states that approximately 2-4 hectares of recreational green space would be required for the 200+ new residents moving into this site. At present, the building footprint covers the majority of the site - therefore a missed opportunity for onsite recreation space, at the very least. 


We also note there are no plans for a SANG, with the reason given:


“The Proposed Development does not have this space available and therefore SANGs tariff payment and Strategic Access Management and Monitoring (SAMM) tariff payment will be required to offset recreational impacts.”


If there is no space available for recreation, then is this a suitable site for more residential units? Secondly, there is a suggestion that a payment will offset the impacts - has this been quantified? 


With no SANG proposed, local ecosystems will be further stressed. For example, very close by, there is the site on Portsmouth Road which could form some part of the SANG, and yet there are also plans to build on it (Guildford Plaza), rather than the desperately needed provide outdoor space for the ever increasing town centre residential population, and vital urban habitat for wildlife. 




The report concludes  “it is considered that the Proposed Development will comply with relevant legislation and planning policy, contributing to no net loss in biodiversity on-site.”


From the report, we understand that at least  seven trees will be felled, and soil will be disturbed, potentially affecting more. 


  • Given the ecological emergency, we should be aiming for a gain at this site, not a loss. Also the NPPF aims for a biodiversity net gain. 


The pocket park


At present some small area has been allocated to a “pocket” park - aptly described since it is smaller than the existing paved area in front of Debenhams.


  • Since Guildford has not opened any new park space while development has continued at a rapid pace, we would suggest that this public park area be made at least twice as big.

  • To mitigate slightly the noise and particulate pollution from the passing traffic, we would also suggest that mature shrubs/bushes are planted to create a green barrier from the road, and that the building is set back 6-7 metres from the road side. 


1.3 Temperature


Climate change adaptation must be an essential part of the planning process for any new building or development. Green infrastructure, as well as other natural features can help lower urban environments considerably ( 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 is a small amount of green space planned, we would 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 surrounding areas compared to darker-coloured pathways. 

  • The building should aim to regulate temperature using passive systems wherever possible - saving emissions, cutting fuel bills, and ensuring maximum habitability for residents.

  • High thermal value building materials should be used to provide the best insulation possible. 

  • Flats should be dual aspect to provide a through draft. 


1.4 Trees and Wildlife 


The ecological report states:


“the area of site alongside the river is artificial in nature with metal piling and concrete sides, making it impossible for burrowing and thus unsuitable for otters or water vole. Further the frequent level of disturbance caused by the existing footpaths that run along both sides of the river and the street-lighting that accompanies them is likely to render this area of the River Wey highly unsuitable for otter and water vole.”


We are disappointed that the report does not aim to improve on the current situation in terms of being wildlife-friendly. We feel that there is scope for improvement in terms of the river ecology, along this stretch of river. The water vole has almost gone extinct, and so every effort must be made to make habitat available. 


We also note the risk to wildlife that does live in Wey Valley Meadows area 

“The Proposed Development, by way of working adjacent to the River Wey has the potential to cause pollution incidents which may affect the nearby designated sites such as Wey Valley Meadows, and otter and water vole that live in the River Wey.” There needs to be a rigorous plan in place to protect local ecosystems - will there be ecologists on site during the process?


Bird nesting sites


The report states: 


“Given the existing building has measures in place to deter nesting birds, via spike

strips and wires, the only potential location that could be used are the open areas of the flat roof. Given the exposed position here and lack of any evidence of historic nesting, it is considered likely there is a very low risk of encountering them within the development area.”


Our understanding is that the existing building will be demolished - and therefore those spikes will presumably be also eliminated. Is this not an opportunity for the developers to integrate some potential nesting sites?


We also are concerned that there is talk of “pest control” when referring to wild animals. We face an ecological emergency, and should not be poisoning animals. 




Seven trees will be cut down if this plan goes ahead, including the cherry in front of the building, sycamores and alders. Sycamore trees can live to hundreds of years, and grow to 30m in height. Replacing such a tree will be impossible - saplings take time to grow and establish their roots. Can the plans be modified to save some of the existing trees?


The plans show a very large footprint of the building and hard- landscaped areas could pose a threat to tree roots if extreme care is not taken. The report recognises that the machinery “may damage” soil structure and tree roots - again we would ask that every provision is taken to make sure that this is not the case (6.11).


In Stoke Park, a building was constructed within 3m of two ancient oak trees, leading to the roots being severed and the trees ultimately having to be cut down for public safety. We would like to ensure that the root systems of the vegetation in the area won’t be affected. Looking at the plan, trees 11, 22, 23, and 24 are very close to the building boundary - we strongly suggest that the building be made smaller or sited further from these trees to allow for more root space, and green space generally around the building. 


2.0 Sustainable Living

2.1 Lifestyle and wellbeing

We note the inclusion of a very small amount of shared space in the building, but this appears to be essentially ‘waiting areas’ for visitors. Given the social and environmental benefits of shared space, we wonder whether more communal areas could be provided - along the lines of those planned for Guildford Plaza. This could include cooking or clothes washing/drying facilities, for example.

2.2 Ventilation

Most flats in the planned development have only one aspect, which is generally not sufficient to provide adequate natural ventilation; through ventilation is much more efficient. Additionally, residents will likely be unable to open their windows due to the high levels of air (and noise) pollution in the surrounding area.

  • Can provision be made for natural ventilation at a building scale to prevent the need for air conditioning, which is energy intensive? 

2.3 Transport and travel

On average, a third of a Surrey resident’s carbon footprint is generated from car use, and overall, transport makes up almost half of all of Surrey’s emissions. As such, reducing cars and car use is critical to emissions targets. Guildford Borough Council has declared a Climate Emergency, and every effort possible must be made to address this. 

2.3.1 Walking

We welcome the opening up of the riverside and the pocket park. These will be invaluable amenities for the public to use. 

The plans include removing the existing guard railing along Millbrook.

  • Will this encourage vehicles to park illegally on the pavement, or to use the pavement for drop off/pickups?

  • Will removing the guard railing make it less safe for pedestrians?

  • These railings are currently used to support flowers in planters during spring and summer. While we believe these flowers are sterile and therefore of little value to local biodiversity, they could easily be replaced by plants to benefit local pollinators and other wildlife. If railings are removed, is there a plan to replace these planters?

The vehicle entrance and exit to the Site do not give priority to pedestrians and they will have to wait at each kerb. Sightlines are not ideal, and with drivers going up/down ramps, there is a clear risk to safety for pedestrians and cyclists at entrances/exits.

  • We recommend footpath/cycle paths being at a continuous level slightly elevated from the road in line with the pavement, so vehicles have to go up and over them. This is done throughout cities with excellent walking and cycling infrastructure in the Netherlands and elsewhere, showing drivers that pedestrians and cyclists have priority and naturally reducing car speeds.

2.3.2 Cycling

Resident cycle storage

Section 6.2.7 of the Design and Access statement states that 10% of cycle spaces are provided as Sheffield stands for recumbent cycles and those unable to utilise tiered racks. With electric bikes on the increase, the number of larger cargo bicycles is likely to increase considerably over the lifetime of the building. Considering larger bicycles take up twice the width of standard bicycles, there are actually only 15 spaces that can be used by larger bicycles (6%) with 4% of spaces unable to be used.


  • 25% of provided cycle spaces should be for larger cargo bikes/bikes with trailers/tricycles/adapted bicycles. 


Cycling among disabled people is almost as popular as among non-disabled people, with 17% of able bodied people cycling regularly and 12% of disabled people. Cycling is easier than walking for ¾ of disabled cyclists, however there only appears to be 3 cycle parking spaces where someone can transfer to a bicycle from a wheelchair or where they can manoeuvre a recumbent bicycle into a parking spot while remaining in the saddle.


  • More cycle stands with 1.2m space alongside to be provided.


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. 


  • 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.

  • Provide personal lockers in the cycle store area for cycle helmets, shoes and cycle gear. The number of lockers should be the same as the number of cycle parking spaces.


We note the Transport Assessment says a cycle repair stand will be incorporated within the public realm.


  • It would be prudent to provide a cycle repair stand and shared use bicycle pump within each of the three cycle stores.


Section 6.2.6 of the Design and Access Statement says a bicycle repair station will be located within each of the 3 cycle stores.


  • There is some confusion as to how many, and where the bicycle repair stations will be located.


A cycle hire scheme could also be popular in a development like this.


  • Cycle hire scheme to be investigated


Visitor cycle parking


14 public visitor cycle spaces are provided. This is insufficient for 215 dwellings plus retail space, plus being the destination of the Guildford to Godalming Greenway.

  • 30 additional spaces to be provided.

  • Cycle parking to be covered

Cycle network


It would be helpful if a segregated cycle route could go through the site and continue on the proposed/hoped for bridge connecting to the back of the Yvonne Arnaud and on to the river path. Such a bridge would be well used and appreciated.

There are currently no cycle lanes or cycle tracks surrounding the development. The literature relies on the Guildford to Godalming Greenway which is still at consultation stage. 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 shown in the literature is pedestrian only during the daytime. Cycling south there are no cycle lanes or cycle tracks along Millbrook. This lack of infrastructure is a huge barrier to cycling as a method of sustainable travel from the development. The statement “The development is conveniently located in terms of cycle accessibility with several local facilities and amenities accessible by cycle using the network of cycle routes and roads in the vicinity of the Site.” (ref 3.2.2 Transport Assessment) is incorrect.

  • Local cycling infrastructure is desperately needed. Development to financially support community infrastructure via a section 106 agreement.

Guildford to Godalming Greenway

The Guildford to Godalming Greenway plans currently show a segregated cycle lane along Millbrook alongside the site in place of one lane of traffic. This will encourage cycling, with the Site being at the end of this greenway.

  • Additional cycle spaces should be provided for public use. Cycle spaces should be covered.

  • Cycle lane in front of entrance and exit to the Site to be on a continuous higher level, so vehicles entering/exiting the site have to go up and over the hump. This gives clear priority to cyclists.

Using the space within the highway boundary (see area shaded yellow in snapshot below) to build the ramps (hatched in red), will prevent the area being used for cycle infrastructure in the future. This area may be needed for additional cycle spaces, or for cycle lanes following the installation of the Guildford to Godalming Greenway.

  • Ramps to be moved out of highway boundary.


Access to cycle storage

Access to the basement for cyclists is either via a lift or via a signal controlled one-way ramp. 

  • Will the signal control on the ramps give sufficient time for cyclists with heavy loads/trailers or children cycling to travel up the ramp?

The entry movement for the signal controlled ramp will have priority over vehicles egressing from the basement.

  • How will cyclists be detected?

We note that as well as the ramp, there will be a lift down to the basement level, sized to accommodate bicycles up to 2m in length.

  • Lift to be sized to accommodate non-standard bicycles such as larger recumbent style (2.5m long), cargo bikes or bicycles with trailers (2.8m long). This is essential as cyclists with heavily laden bikes may struggle up the basement ramp and are more likely to want to use the lift.

The route from the lifts to the cycle storage area is not possible for larger bicycles. The bicycles will not make the 180 degree turns or get through the single doors. See image below.



  • Route from lifts to cycle storage areas to be direct and accessible for larger bicycles.

2.3.3 Cars

The basement has 76 car parking spaces allocated (up from an existing 57 spaces).  


While we support EV charging points for residents over no charging points, we must stress that simply switching out all combustion engine vehicles for EVs is not a solution to the climate and ecological  crisis. Every effort must be made to encourage active travel and public transport over private car use. EVs drive further destruction of ecosystems across the world, and continue the car paradigm which has been damaging to the environment and society. 


Surrey’s Vehicle and Cycle Parking Guidance (2018) recommends 20% of available residential car parking spaces should be fitted with a fast charge socket with a further 20% spaces with a power supply for future conversion. We are pleased to note that 80% of spaces will be provided with passive provision to allow for easy future conversion.


The nearby Plaza development, aside from disabled and service vehicle parking, proposes only car club parking spaces. St. Mary’s Wharf development proposes 76 car parking spaces, which is much less sustainable. The energy required to build a new car generates more than 17 tonnes of CO2e – almost as much as three years' worth of gas and electricity in the typical UK home, as well as the considerable environmental damage caused by mining for materials. If cars can be shared, this environmental footprint would be significantly reduced.


  • A development of this size should include car club spaces. The nearest car club space is currently a nine minute walk away in Martyr Road.

  • Could the number of spaces be reduced and only car club and disabled spaces provided?


Note the minimum number of car parking spaces required by Surrey’s Vehicle and Cycle Parking Guidance (2018) is zero.

2.3.4 Buses

The Site is close to Guildford bus station and there is a bus stop just south of the site, however bus prices are very high, and bus tickets cannot be used on rival bus operator buses on the same route.

  • GBC to investigate using some of the powers available in the Bus Services Act 2017 to run bus services in a similar manner to London, with GBC in control of ticket prices and better able to ensure routes are serviced frequently whether rural or urban.

Guildford lacks a bus route circulating the edge of town as currently all routes start and end at the bus station.

  • Circular bus route (away from town) to be investigated by GBC.

2.3.5 Trains

The Site is situated close to Guildford railway station with good opportunities for using train services.

2.3.5 Taxis

  • The scheme would benefit from a taxi drop-off space as there is currently no safe area for taxis to stop. 


2.3.6 Boats

Boats are shown adjacent to the site but there is no indication of mooring facilities such as bollards and rings. There is a large height drop to the river, so ladders or ramps would be needed by those arriving by boat to reach dry land.  


3.0 Water, Flooding and Drainage

3.1 Flooding

Without the Debenhams building, this site would be described as functional flood plain. It has always been prone to flooding and to the forces of the river.  Indeed it was timber washed from the Moons Timber Yard, on the site prior to Debenhams, that piled up in front of the old Town Bridge and led to the river bringing down the bridge in Feb 1900. 


There are no flood alleviation measures in place in the area and none are planned. 


The photograph in the Flood Risk Assessment 1 document (14 Oct 2021) Section 4.3.3 (see image below) shows the Debenhams building during the 2013 flood.  This photograph is used as evidence that the high water level is “below the top of the river wall and ground floor of the building”. There are cars in the Millmead car park and their number plates are clearly visible.  



Image extracted from St Mary’s Wharf Flood Risk Assessment section 4.3.3


However, there are other photographs of the same scene (see below) which show the cars with the water level at the bottom of their windscreens. ie at least 500mm higher than their number plates. Therefore the levels shown in the document are misleading and the distance between the flood and the ground floor was clearly less than in the document’s photo. Maximum flood height was actually reached in the early hours of the next day after the photo below from the Mirror was taken. 



Photo of cars in Millmead car park opposite Debenhams. Ref


The site has recently had its flooding designation changed from 3b (1 in 20yr risk) to 3a (1 in 100yr risk).  We can see what the rules are but they defy common sense and favour building over safety. The NPPF says to steer building to the areas of lowest flood risk.  The process has been gone through and we end up with one of the most high risk sites for flooding.  


  • Flood designation is based on flawed evidence. Flood designation should be reviewed.


Measurements of the river height in floods in Guildford are given in the GBC Flood Investigation Report 2015 (see table below).  We know that 1968 (estimate 4.6m) flooded Debenhams. This report says the next flooding event is expected within 20 to 30 years’ time of 2013. The 2000 flood event is not mentioned in the Flood Risk Assessment 1 report despite the level being higher than in the 2013 flood.


Dec 2013 (see photos above)      3.72m

Dec 2012                                       2.51m 

Jan 2003                                       3.09m

Nov 2000                                      3.78m

Sept 1968 (estimated)                  4.6m 

Source: Section 19 Flood Investigation Report Guildford Borough 28 Oct 2015 


  • Flood designation should be reviewed.


We are getting bigger, more frequent and more serious extreme weather events taking place, and these will only continue to worsen. On our current trajectory, we will not come close to staying below 1.5 degrees of warming, or 2 degrees, or even 3 degrees. The extra climate change allowances for risk assessment are best guesses and therefore this Site is particularly at risk. 


  • Flood-proofing should be reconsidered with regards to likely impacts of climate change, and a more accurate flood designation.


The site (and its 3a 1 in 100 yr flood rating) is currently protected by the Debenhams concrete retainer walls and base slab, from 1967, which enclose the basement area. These are to be retained but are perforated by 11 drainage holes and an old underpass tunnel, which is leaking and has a pump. The walls must also withstand the demolition process and the building of two massive buildings, as well as the force of the river for 100yrs. An inner protective box has now been added to the plans, but the integrity of the outer walls still plays a crucial role.


  • Integrity of existing walls to be validated.


3.2 Surface drainage 


It is recommended that the flow from a site should not exceed the green field rate. This is not achievable on this site because the building dominates the site and there is not room for enough mitigation measures. When this is the case, the recommendations are changed to ‘do the best you can’! Blue crates are being used as attenuation in all available spaces, together with green and blue roofs.


The area of soakaway crates on the unbuilt areas, pocket park to the south, the strip to the west and public area to north 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 surface water will flow through five of the existing outflows in the old wall directly into the river. During high river levels, these are below the water and therefore water will back up the pipes. 


3.3 Foul drainage 


The foul drainage design is good, as it is gravity fed to nearby sewers instead of being pumped, although connection details are not yet known.  However in the event of severe rain and flood, the main sewers are likely to become surcharged and sewage will not be able to leave the site.  A holding tank is proposed but this would be full in 24hrs and leave residents in difficulty. Considering flooding events have happened on average every 5 years recently for several days, the holding tank volume is insufficient.

  • Holding tank size to be reviewed.


Grey and potentially contaminated drainage from the basement is to be treated and pumped up to the main sewers.  In times of flood this would not be able to be discharged either. 


3.4 Ground water 


There is potential for flooding from below ground level. 


3.5 Aquifers 


The site is in a Source Protection Zone which restricts activities which may pollute the source. There is high vulnerability from pollutants discharged at ground level. 

  • Great care must be taken during the construction process not to pollute the water source


3.6 Basement 


The basement is below the river level and most at risk of flooding.  Serious flooding will challenge the measures in place and could mean the plant and pumping facilities in the basement cease to function. 

  • Ensure all plant and equipment in the basement is protected from flooding


3.7 Exception test 


This test is to explain how the benefits to the community outweigh the flood risk and to explain how the development will be safe for its life. 


There are many benefits to the community but the flood risk is great.  Every possible method of protecting the property from flooding is being brought forward, including waterproofing walls, flood gates, raising the ground floor level by one metre and pumping.  The fact remains that this is a high risk site. 


4.0 Light

All buildings should aim to maximise natural lighting (bearing in mind natural or other solar shading as necessary to prevent overheating on hot days). This will not only minimise use of artificial lighting, but also has physical and mental health benefits.

Outdoor lighting should be sensitive so as not to disturb wildlife or sleep patterns. LED lights can be customised so that less blue light is emitted, which is particularly damaging to nocturnal creatures and also interrupts sleep patterns in humans. 

Movement sensors would be our preferred means of ensuring that lights are only on when necessary.

Lighter-coloured pathways would also minimise the intensity of light needed, and devices such as cats eyes could be used to help cyclists. 

4.1 Daylight in the proposed development

There are concerns, highlighted in the ecological report, as to the hours of sunlight on some of the inner areas of the building, particularly the part of the residential building that faces the commercial building. Those residents will get very little natural light due to the other building so close in front.  If there must be two buildings, we would suggest that there is a much bigger distance between the two, and that the commercial building be made much smaller to allow at least the upper flats more daylight, or that all flats be made dual aspect. 


5.0  Air pollution 

Aside from the clear implications of air pollution with regard to the climate crisis, around 5% of all early deaths in Guildford are attributed to air pollution. The plans suggest the  building will be very close to the edge of the road, and offers no buffer zone from the traffic pollution. We would like to see a much smaller building, set back from the road by a good 6-7 metres, with some greenery to mitigate somewhat the air pollution. Pedestrians would also benefit from this if the hedging was placed on the outer edge of the pavement (pedestrians walking into town from the Millbrook car park are currently exposed to a lot of fumes). 


Even with a trend towards EVs, the issues of particulate pollution are not resolved, and given the current take up, we cannot envision that, without measures being taken by GBC or SCC, that air pollution will decrease by any significant amount in the next 5 years. Even with a large take up of EVS, the problem of the dangerous particulate pollution remains. 






5.1 Traffic pollution


In particular, the lower storeys facing the main road will be susceptible to pollution from passing and idling traffic, and road noise. During the travel impact assessment survey (Ref 8.3.6 Transport Assessment), there were up to 23 vehicles queuing northbound at the Millbrook pedestrian crossing, directly adjacent to the Site.


NO2. Nitrogen Dioxide levels in the town centre have been found to be at 4 times the “safe” levels set by the WHO - at 10 µg/m3. The readings from areas close by show the lowest number as 19 µg/m3  - already double the suggested safe limit. However, on some days, that has risen to 53μg/m3)


The report itself recognises this “Regarding the residential receptors to be introduced at the Proposed Development, the annual mean NO2 concentrations are predicted to exceed the air quality objective at the proposed

residential facades facing the A281 Millbrook.”


Before more residents move into the area, the council must tackle the poor air quality issues. This is an extract from the WHO website about the effects of NO2 pollution - 

“Epidemiological studies have shown that symptoms of bronchitis in asthmatic children increase in association with long-term exposure to NO2. Reduced lung function growth is also linked to NO2 at concentrations currently measured (or observed) in cities of Europe and North America.”

Particulate matter: 

For PM2.5 (fine particulate matter) the readings were between 10 μg/m3and 15μg/m3, as such two to three times over the recommended WHO safe limit (5 μg/m3). 

For PM10 (coarse particulate matter) - the report shows levels between 15μg/m3 and 24μg/m3 for PM10. The WHO recommends a max of 15 μg/m3. Fine particulate matter causes 33,000 deaths every year in the UK. If the limit of 5 μg/m is stuck to, as much as two thirds of lives lost from poor air, could be saved. 

There are other pollutants from exhaust pipes which also have a bearing on health, such as sulphur dioxide, which should also be considered too. 


  • We would ask that before planning permission is given, a clear plan for reducing air pollution is set out, taking into consideration that EVs are a longer term aim, and do not solve PM pollution. 


6.0 Materials

6.1 Demolition


It is hoped that as much of the demolished materials as possible can be recycled into the new building. We are pleased that it is envisaged that concrete materials recovered from the demolition process will be crushed and stockpiled on-site with the intention of re-using on site however the 7900 Tonnes of crushed concrete produced will far outweigh the need for it in the new build as backfill, so it is likely the vast majority will be re-used away from site.


6.2 Transportation of building materials


The Environmental Statement section 5.57 shows that the Site is forecast to generate 20 HGV/LGV movements a day for 3 ½ years. The location of this Site lends itself very well to moving materials by barge which is a much more sustainable transport method.


  • Consider moving materials by barge to reduce environmental footprint


6.3 Proposed materials


Individual building design and materials should also aim to minimise energy use, embedded carbon, plastic and other environmentally-/ecologically-damaging materials, while promoting physical and mental health where possible.


Special attention should be paid to the thermal mass of the materials use. As stated above, with the climate warming, good insulation is essential. 

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