Report on the letters 1 July to 31 December 2018

19 February 2020


Report on the letters the group has written to Guildford Borough Council about planning applications which we considered during the period 1 July to 31 December 2018

During this period the Planning Group consisted of John Baylis, Amanda Mullarkey, John Harrison, David Ogilvie, Martin Taplin, Anthony Umney, Peter Coleman and John Wood.  In addition Ian Macpherson has been invaluable as a corresponding member.


GBC:               Guildford Borough Council

AONB:           Area of Outstanding Natural Beauty

AGLV:            Area of Great Landscape Value

NPPF:              National Planning Policy Framework

HTAG:             Holy Trinity Amenity Group

The Planning Group meets every three weeks at the GBC offices.  

During the period under review there were a potential 1,082 planning applications we could have looked at.  We sifted through these applications and considered in detail 66 of them.  The Group wrote nineteen letters to the Head of Planning Services on a wide range of individual planning applications.  The activity is summarised in tabular form here.  Seven of those letters were about signs, mainly hanging or projecting, in and around the High Street Conservation Area.   GBC have published good design guidelines for adverts and signs in this conservation area but many applications do not fit the criteria laid down.  The letters we wrote were usually because they were either larger than allowed in the guidelines or because they were internally illuminated.  The guidelines are clear that signs in the High Street Conservation Area should not be internally illuminated.  In the period under review only one application for signs was approved as submitted, three were approved after amended drawings were received to satisfy our concerns and three were refused.  One of those refused applications was appealed but the Inspector dismissed the appeal.

Of the remaining twelve applications five were approved as submitted (including the one application we wrote to support), three were approved after amending plans were received, one was withdrawn and three were refused.  All three refused applications were appealed.  One appeal was dismissed, another one has not yet been decided and the third one was withdrawn.  This withdrawal of an appeal is very unusual when it had proceeded so far down the line and in September 2019 the Council applied to have their costs reimbursed by the appellant.  The decision on the outcome of their costs application is still awaited.

Any reader who wishes to see how this six month period compares with previous periods should look at the “Summary of Outcomes” which follows the appropriate report on the Society’s website at .

It is clear from our investigations that the case officers at GBC do take our letters into consideration but naturally they do not always take the same view as us.  However, we are pleased to report that in twelve of the nineteen applications we wrote about those applications were either refused or, alternatively, were only approved following subsequent amendments to the original application to take account of our objections.

The details of our letters follow below and if any reader wishes to look at any of the applications, the plans, the design and access statements, the officer’s report to the planning committee and the decision notices they can find all the information required at .   Type in the application number at the bottom of the page that opens, click “Search” and click on “Documents” when the Summary page has been loaded.  You will then be able to click on the information you are seeking and it usually downloads a pdf document.

In recent years we have seen a spate of applications for student accommodation, particularly, but not exclusively, centred along Walnut Tree Close.  We now have:

  1. The completed multi-coloured block of 141 accommodation units at Kernel Court on Walnut Tree Close (14/P/00253).
  2. The current construction by Kernel Court Ltd and Scape Student Living Ltd for a much larger eight storey scheme on an adjacent site in Walnut Tree Close with 403 student bedrooms and 85 ‘co-living’ studio rooms.  See 18/P/01155 on page 4 of this report
  3. An application from Summix for a six storey development between the river and Walnut Tree Close for 474 student bedrooms and 2,504 sq m of ‘co-worker’ office space.  This application 18/P/01450 has been withdrawn but our full comments can be seen on pages 5 and 6 of this report.
  4. See page 8 for application 18/P/01668 concerning the Quadrant site in Onslow Street for 300 student bedrooms, a casino/night-club and other uses in a 14 storey block.  The application was refused.  The applicant appealed but subsequently withdrew his appeal as detailed on page 1 above.
  5. An application 17/P/00509 to build 527 student bedspaces on Guildford College land adjacent to Stoke Park was refused.  It was taken to appeal and the appeal was upheld (allowed) subject to conditions.
  6. Application 18/P/02226 for 361 student accommodation units on the Bishops Nissan site on Walnut Tree Close was approved after substantially amended plans were submitted.  As consent was granted only in September 2019 no work has yet commenced on this site.
  7. An application 18/P/02391 for 88 student flats at 1 & 2 Ash Grove was submitted in December 2018.  The plans caused considerable controversy, such that amending plans were submitted in April 2019.  No decision has been made on this site yet.
  8. The old Just Tyres site in Walnut Tree Close has had approved its proposed plans for 82 self contained student flats (18/P/02100).  Further details appear on page 9.
  9. An application (19/P/00407) for 360 bed spaces in Guildford Business Park was submitted in March 2019.  We have objected on account of the excessive size and other reasons but discussions with the applicants continue.

After looking at the Just Tyres site mentioned in 8. Above, we became concerned about the growing number of applications for student accommodation in and around Walnut Tree Close.  We wrote to the Borough Councillors about them.  There were a number of points of principle, some of them common to all, which we wanted to draw to their attention.   In particular we stated:

  1. The proper place for many of these units should be on the University’s campus where there is plenty of room for them and indeed halls of residences are shown in their original master plan.
  2. If the flooding issues can be overcome these riverside sites would be better used for conventional homes. This could include social housing which, by quirk of fate, is not required for student housing.
  3. We believed that cluster units with shared kitchens are important for reducing isolationism and are also cheaper.
  4. The applications would overwhelm the Walnut Tree Close area with a transient population of a narrow type and they greatly exceed the number of applications for residential dwellings in the urban area.  Together with the units approved for the University's Manor Park site, these new dwellings would meet most of the estimated requirements over the plan period to 2034. The wider housing priorities are being neglected.
  5. Redevelopment of riverside sites provides an opportunity for more public amenity space which these applications ignore.
  6. We have real concerns over the massing and design details which are covered in the individual letters of objection.

We urged the Members to reject the proposals that were then proceeding in order to allow more appropriate development meeting wider planning objectives that serve the community at large.  Whilst the Councillors appeared to be sympathetic, applications for these types of units appear to be continuing unabated and are often approved.

PLANNING APPLICATIONS we considered from 1 July to 31 December 2018

18/P/01124: Austen House, Station View, Guildford

We considered the proposed internal illumination of the 5m fascia sign at 6m high might be visible from far away and therefore wrote objecting. We did advise we would be happy to see halo lighting.

(Approved.  It was not thought that the signs are likely to distract passing motorists.  The fascia sign for Spaces, where small offices, conference rooms etc are provided, will be halo lit.)

18/P/01155: Kernel Court, Walnut Tree Close, Guildford

We objected to the 403 bedrooms and 85 ‘co-living’ studio rooms proposed in this application. We considered the design of the building, with its uniform vertical elements, to be utterly mundane and lacking in interest. Furthermore at eight storeys, it was much too high. The two drawings submitted with the application showing the existing and proposed Walnut Tree Close elevations forcefully demonstrated this. They showed how very much taller the student building would be than its neighbours and much taller than the five storeys shown for the present Scape 1 student block. It would tower well above the railway embankment and is as objectionable as the similar eight storey blocks along the railway proposed by Solum as it would continue the ‘wall’.

We had no objection to the massing or the design of the proposed co-living building and we fully supported the Council’s arguments regarding contributions to affordable housing. We are however of the view that university student accommodation should as far as possible be on campus.  

(Approved.  Whilst our letter of objection is on the GBC file the case officer’s report is not.  We therefore cannot give an indication why our concerns did not prevail.  We have asked the case officer to ensure his report is uploaded but so far this request has been ignored)

18/P/01167: 57 Ladymead, Guildford

This was a resubmission of application 14/P/02018 for a multi-storey car park: we had objected in a letter dated 22nd November 2014. We continued to dislike to the bright blue, red and yellow colouring proposed for the exterior. We considered this fairground style completely unsuitable on an approach road to Guildford. We would much prefer to see ‘green walls and landscaping’ rather than the garish palette of colours proposed and the minimal planting on the SE corner. We also objected to the huge ‘Allianz’ lettering and logo proposed on the front of the building. However the previous application was approved.

(Approved, as this application largely followed the previously approved scheme which had lapsed through time.  It was acknowledged that the design of the building was contemporary and it would not necessarily be similar to other built form in the area.  However, on balance it was considered that the scheme did no material harm to the character and appearance of the area.  The “Allianz” lettering has been reduced in size.)

18/P/01174: 22 St Omer Road, Guildford

We did not like this application for demolition of an existing chalet bungalow and construction of three identical 5 bedroom detached homes because they would not be in accord with the character of the area as set out in the Residential Design Guide. Furthermore, whilst the parking is off-road it is directly on to the street with no fencing or hedging, which is contrary to the character of all the other houses in the area. The underlying problem with this application is that it seeks to over-develop the site.  Replication of the proposal along the whole road would destroy its current character.

(Refused and appeal dismissed)

18/P/01213: Walnut Tree Close Footbridge, Guildford

We considered this application for a replacement bridge was a great opportunity being missed. Bridges can be very attractive features of towns but this proposal was functional and brought no pleasure to the eye.  The application showed the bridge as just an unattractive white concrete plank. The white colour is out of keeping with the brick facades of the Billings buildings.  The picture on the front of the Planning Statement showed the present bridge has a much more pleasing treatment of the balustrades and is not white. We considered the proposal was a backward step in these respects and we recommended that the Council seek to improve the detailed design and the visual appearance of the proposal so as to make it worthy of the town.

(Approved.  The applicant was GBC itself and as a result it was put before the planning committee for consideration but also because there were more than 20 letters of objection contrary to the case officer’s recommendation.  In his report the case officer did not mention any of the reasons for the various letters of objection and therefore he did not attempt to refute the concerns of the general public and ourselves who had taken the trouble to write.  This is unacceptable.)

 18/P/01450: The Riverside Business Centre, Walnut Tree Close, Guildford

This major planning application primarily comprised 474 student rooms contained in four blocks of development of five or six storeys raised above an under-croft (to accommodate flood water from the adjacent River Wey).

We strongly objected to the application and strongly disagreed with the views of the Design South East Review Panel Members. We considered the ‘ends’ of the four blocks facing the River Wey were far too close to the river. It made the proposals overbearing and unacceptably dominant in the attractive context of the natural feature of the River Wey and the amenity of its much-used towpath.  

The proposals failed to meet the essential policy requirements of Policy D4. The overall height of this development was out-of-scale with the general pattern of the existing buildings in this area of Walnut Tree Close. Specifically, we were firmly of the view that buildings on or close to the river frontage should be lower in height, perhaps by way of being stepped down towards the river. The excessive height, the harsh and unattractive design, in particular the black metal cladding, made the development look more like a prison than a scheme of residential development.

We were also concerned about the imbalance in the social character of the area in consequence of the increasing amount of student housing which is being concentrated in the area of Walnut Tree Close.

Compared with the adjacent and refused application 13/P/02216, this current application is almost twice as high and, overall, is for a much larger and more intensive form of development than the earlier one which was refused.  Given the objections to 13/P/02216 which led to clear reasons for refusal, we considered those same reasons must apply with equal, if not more, force in respect of this present application.


18/P/01445: 1 Bishops Wharf, Walnut Tree Close, Guildford, GU1 4RA

This application was for a large painted sign on the gable end at the south end of Bishops Wharf. This signage is at the location of the proposed new Walnut Bridge and may give the wrong impression regarding where the bridge leads to. The lettering is too large and due to it being painted on brickwork, it will be very difficult to remove in the future should the owner’s requirements change. 

(Approved, following receipt of amended plans which have significantly reduced the size of the sign we were concerned about.)

18/P/01569: Land to the rear of 20 Guildown Avenue, Guildford

This application proposed erection of a detached two storey dwelling. There are several mature trees on this plot that are an integral part of the application and a vital part of the character and views of Guildown. We requested that the Council ensure that these trees be fully protected with TPOs.

(Approved.  The Council’s arboriculturalist has assessed the trees and concluded they are not worthy of a TPO.)

18/P/01481: 6 Tunsgate, Guildford

We welcomed this proposal to create an outdoor seating area associated with Kalm Kitchen Cafe as part of a strategic plan to introduce such use in several specifically designated areas in the newly paved Tunsgate, in a coordinated and carefully controlled manner.  We noted a continuing need for control of matters such as advertising, whether in the form of banners, umbrellas or otherwise, and the use of outdoor heaters in terms of numbers (if any permitted), style, size, hours of operation and in particular fuel source in order to minimise the creation of greenhouse gasses.

‚Äč18/P/01368: 219 High Street, Guildford

This application proposed various signage for Chilli Pickle and we objected to the “fairground lighting” above the door of the property.


18/P/01565: Tunsgate Square Shopping Centre, 98-110, High Street, Guildford

We have been consistent in our view that in the interests of retaining historic character, hanging signs in the central ‘cobbled’ section of the High Street should be no greater in size than 600mm x 600mm. This application seeks consent for two hanging signs for “Tunsgate Quarter” each of 600mm x 800mm. We recognised there is a case for two signs but remained of the view that each sign should be no greater than 600mm x 600mm.


18/P/01568: North House and South House, Albury Road, Guildford

We objected to this application for a block of 20 flats on environmental grounds and because of the absence of a firm commitment in respect of affordable housing.  The Design and Access Statement stated the “amount to be determined”. This is not acceptable. The application is for market housing and as part of this development there should be provision on this site a minimum of 6 affordable units.

We also considered this proposed development over four floors to be one floor too high.   We felt there was a need to introduce more planting along the frontage to Albury Road.

(Refused and appeal commenced.  The case officer’s report makes interesting reading about the contribution required for affordable housing.  The Local Plan now requires a 40% contribution and this would therefore mean 8 units should be designated affordable.  The problem here is that the applicant is McCarthy and Stone and the development is specifically aimed at the older person and the development would include communal internal and external facilities.  This is considered to make the provision of affordable units impractical. It was therefore considered that in this case a payment in lieu would be appropriate and GBC calculated that a payment of £1.76m would be required.  The applicant had produced a Financial Viability Assessment to show that a payment in lieu would not be financially viable.  It was considered by McCarthy and Stone that a maximum of £20,807 could be offered.  The Council did not accept this and so commissioned their own independent viability assessment which concluded that there would be a minimum surplus of £530,773.  It would seem that the two sides could not agree and therefore the application was refused, not only on these grounds but also by reason of the excessive scale, height and bulk of the proposed building, the poor form and design etc and that the development would result in material harm to the character and appearance of the site and immediate area.   It will be interesting to see what conclusions the Inspector comes to.)

18/P/01668: 1-5 The Quadrant and The Casino Nightclub, Onslow Street, Guildford

We objected to this application for a 14 story building in the strongest possible terms. It proposed a development which was grossly excessive and completely out-of-character with Guildford both in terms of its enormous height and the way in which it overhangs the boundaries of the site. Even in comparison with the massive Solum development, this proposal is far too high and it will have a serious adverse impact on views from both within and across the town centre and from viewpoints outside the town including the Surrey Hills AONB.

The use of extensive glazing on the elevations of parts of the upper floors would not only be incompatible with the historic character of the town but, in the hours of darkness, light from this glazing will cause light pollution and result in the structure standing out in an inappropriate way.

In addition to other uses the development proposes 10 floors of student housing. We considered these student units will be provided with inadequate communal facilities and that many of the units are substandard as they will only receive natural light from a totally inadequate light well. Given the amount of student accommodation currently being constructed or proposed in the area of Walnut Tree Close we are very much concerned that a further increase in student accommodation as proposed in this application will lead to an imbalance in the nature of housing in the area. A further deeply troubling concern is the juxtaposition of a considerable amount of student accommodation in such close proximity to a casino and nightclub. That specific concern is in addition to our view that, in principle, we consider a Casino to be an inappropriate use for Guildford Town Centre.

We also commented forcefully on inadequate bike storage in the basement and on serious risks from flooding.

(Refused and an appeal was commenced.  A long way down the track the appellants withdrew the appeal and in September 2019 the council made a costs application against the appellants.  It will be interesting to see the outcome.)

18/P/01724: 22 St Omer Road, Guildford

We considered the large windows in the front gables of these proposed two new houses were overly large and out of scale/proportion to the overall design of the dwellings. The windows should be of no greater size than those which light the roof of the recently-built dwellings to the west of this site.

(Approved following amending plans reducing the size of the windows.)

18/P/01877: 10 Friary Street, Guildford, GU1 4EH

The application for Gourmet Burger Kitchen was for two internally illuminated static fascia signs but the drawings showed halo lighting. We therefore requested a condition that the lighting should be in accord with the drawings.

(Approved and the condition we requested was implemented.)

18/P/02100: Just Tyres, Walnut Tree Close, Guildford, GU1 4TX

This application was for a proposed change of use from mixed use industrial (assumed use class B2) and car wash (use class Sui Generis) to 82 self contained student accommodation.  The Society objected to this proposal for a number of reasons including the fact that by approving the scheme the opportunity for conventional residential development, which could include affordable housing, would be lost.  The case officer considered that as there was no Master Plan for Walnut Tree Close all GBC could do was to look at the application before them.   We considered that cluster units were preferable to the self-contained units proposed.   Another principle objection was that we considered the proposed building is overbearing because it is too high and it is out of character by virtue of its scale, mass and materials.  It was this application which led us to write to the Councillors as detailed on page 3.

(Approved, following receipt of unsolicited amending plans reducing the scale of the development a little.)

18/P/02138: B & Q Europa Park Road, Guildford

We considered the three proposed barrier 4 x 2 m signs for B & Q outside the plot curtilage and the proposed 7m tall totem sign were all oversized, would distract motorists and would add to the litter of signage on the approaches to Guildford.

(Part approved and part refused.  We did not take issue with the approved part. The part refused was appealed and the appeal was dismissed.)

18/P/02140: 25 & 25A Horseshoe Lane West, Guildford

This was an application for four dwellings in the garden of a house. It is an awkward and out of character development with a circuitous access road around two existing houses. The gardens are very small, and some will cause serious overlooking problems or will be entirely overshadowed by large retained trees. A much better scheme with more efficient land use could be achieved with the complete demolition of the two houses.

(Approved. Our concerns were raised in full in the officer’s report but it was clear that he did not agree with us, apart from having two houses moved slightly further away from the protected trees.)

18/P/02261: Wren Kitchen, Woodbridge Road, Guildford

We objected to this application for signage because the graphics are extremely large and are purely advertisements that do not identify the occupants of the building.  The size would be a dangerous distraction to motorists and they may also set a precedent that would add to the littering of the approaches to Guildford and be detrimental to the character of the area. They would disfigure the building and reduce the light designed to enter it.  Some time previously we objected to a large advertisement on the opposite side of Woodbridge Road for similar reasons. That proposal was refused consent by GBC and the Council should continue to resist large advertisements that would have an adverse effect on the townscape.



18/P/00026: Cavender, 17 & 19 Epsom Road, Guildford

The location of this application is within a Conservation Area. Under the Council’s Guidance for Advertisements and Signs, certain kinds of illumination may be acceptable in Conservation Areas, but our understanding is that internal illumination is not. Such is proposed here and we objected to the application on these grounds.

(Refused and an appeal has been dismissed.)

18/P/00144: 8 Flower Walk, Guildford

We objected to the proposed development of a block of four flats to the rear of the site because the site is within a conservation area and the block would be completely out of keeping with the character of the dwellings in Flower Walk. The block is incompatible with the two proposed detached dwellings closer to the Flower Walk frontage. The block creates the visual impression of a later unsatisfactory scheme of back land development and garden grabbing. The block will also detract from the setting of Hitherbury House where great care is being taken to retain the character of this arts and crafts building.

(Refused and an Appeal has been dismissed.)

18/P/00429: 8 Flower Walk, Guildford

This application was very similar to the application 18/P/00144 above and only very minor amendments were evidenced.  We therefore repeated our objections to the proposed block of four flats to the rear of the site.

(Refused and an Appeal has been dismissed.)

18/P/00553: The Legion, Millbrook, Guildford, GU1 3XJ

We objected to this proposal for the conversion of an existing bar/ nightclub building to create twelve residential units for reasons of overdevelopment and poor design likely to result in inferior living conditions for future occupants.  We were concerned that the way the ground floor flats are accessed directly from the pavement undesirable for reasons including those identified by the police. The fact that these doors are fully glazed increases our concern.

The large areas of ground floor glazing on the Millbrook elevation may lead to a sense of being “in a goldfish bowl” or being more vulnerable notwithstanding that the glazing may be opaque: movement or eg a TV/computer screen would still be discernible from outside, especially at night. The developer promises there will be satisfactory sound attenuation on this busy road, but we question whether this will be achieved in practice on a busy urban road with a bus stop opposite. The property is close to a Pelican crossing which will give rise to frequent “bleeping” and the additional noise of accelerating vehicles.  We believed these units are more like hotel rooms and too small to provide long-term good quality living conditions.

(Approved following amending plans being received reducing the number of units from twelve to nine.)

18/P/00609: Guildford Harbour Hotel, 3 Alexandra Terrace, Guildford

We had objected to this application for an additional apartment on the 3rd and 4th floor and this time we considered proposed revisions. These revisions were considered to provide a minimal reduction and we repeated our original objections.


18/P/00634: Land to the rear of, 12 Sydney Road, Guildford, GU1 3LJ

The proposal was for the subdivision of land and for the erection of a pair of semi-detached two storey properties, together with associated works including alterations to the boundary wall.  We agreed with the Officers findings in the pre-application response of 11/12/2017, and in particular with the statement that “the principle of development here is not appropriate or acceptable, in terms of the Conservation Area Appraisal which identifies the wall and the coach house on Warren Road as features of significance that should be protected”.

(Refused and appeal dismissed)

17/P/02088: 63 Cranley Road, Guildford

We wrote that replacement of a single dwelling in this residential area by a block of flats needs to be done with great respect for the spacious character of the area, the scale of its buildings and its green nature. We objected to the proposed removal of the tree in the front garden. Our objection would be met if the applicant undertakes to plant and maintain another tree of eventual similar size.

(On 1 April 2019 the application was disposed of under Article 40(13) of the Town and Country Planning (Development Management Procedure) (England) Order 2015. No further action will be taken and no formal decision will be made on it by the Local Planning Authority.  Article 40(13) is when it has been decided by the authority (or the appropriate period specified or referred to in article 34(2) or (3) has expired without their giving a decision) and the time limit specified in article 37(2) has expired without any appeal having been made to the Secretary of State.)

17/P/02193: Unit 4, 75-78 Woodbridge Road, Guildford

This proposed a new restaurant with ancillary takeaway. We were concerned about the parking provision. People wishing to pick up a takeaway will be tempted to park in the road causing an obstruction to the bus lane. They will not find the five parking spaces round the back.

(Refused but upheld at Appeal.)

John Wood

December 2019

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