St Mary’s - Historic England Comment on Plans

08 January 2022

An unusual move from Historic England

In a rare development Historic England has formally objected to the Debenhams redevelopment proposals. Historic England is the government body that looks after England's historic environment, including listing buildings, and reviews planning applications for impact on historic assets.  Normally, if they see potential harm to heritage assets, they suggest design modifications. An objection indicates they have more fundamental objections.

In their 10 page letter  of advice to Guildford planners Historic England state “We recommend that the application is refused consent” due to the harm that would be caused to St Mary's church (Grade I) and St Nicolas Church (Grade II*), as well as more broadly, the town centre conservation areas.

The Guildford Society considers the Historic England letter neatly summarises the historic character of Guildford, the contribution of the most important buildings, and shows how the overbearing proposal would damage this. The Society argues that Guildford is a unique town. Its character, which attracts residents and visitors, needs to be respected and enhanced by development.

It is also noted that the letter says “We do not think the harm caused by the proposal can be minimised or avoided without substantial change through a significant reduction in the heights of the buildings.

We will be very surprised if the council planning department ignored this recommendation.


Historic England also recommends properly considering repurposing the existing structure and says “the existing building could be repurposed for new commercial or ‘experience/ /recreational/entertainment’ type uses along with a modest increase in height to provide some new residential units.”

This aligns with proposals the Society made for the site which involved repurposing the existing building.  The Society believes that as GBC has declared a climate emergency it needs a strategy for how it will spend its carbon budget. Redevelopment is very costly in environmental terms and wastes the significant embodied energy contained in the existing buildings  

Shared Concerns

John Harrison from Guildford Residents Association, who share our concerns on the proposed development (See Letter of Objection),  has summarised the association’s views on the Historic England letter.

“The detail and local knowledge in the Historic England letter is impressive making their objection all the more authoritative.
The letter sets out characteristics that make Guildford the town we cherish such as views into and out of the town. It describes the importance of a clear sky setting to a church tower, something that we might not appreciate until it is gone, by which time it would be too late.
The damage would result from the height and bulk of the proposed flats
including their relationship with the River Wey, so reducing these significantly, as proposed by Historic England, could be one way to reduce the harm to an acceptable level.
Whether you visit Guildford daily, weekly or monthly you should be concerned at the excessive scale of the proposal. I hope all councillors, whichever part of the borough they represent, will reflect on their duty to conserve and enhance the town at its heart.”

A Rethink Required?

The Society has argued that there are many opportunities for the site. The Native Land Proposals are but one solution for the site.  There are many possibilities for the site which need to be properly explored in a transparent manner before drastic redevelopment is countenanced. The redeveloped site should provide public realm benefits, mixed use opportunities and housing.  The development should be of a height and mass that respects the surrounding area and seeks to restore integrity to the townscape by the river. 

Please explore our previous posts on this subject see links below.  Documentation on the application can be found on the GBC Website


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