St Mary's a missed opportunity for Guildford

29 September 2022

The Society Objects to Latest St Marys Proposals

The Developers of the ex Debenhams site have revised their plans with positive changes including some reduction in the height of the buildings and a widening of the public space by the river. 

The Society despite these positive moves still believes the that this development , if consented in its current form, will impact the Town Centre severely and although the housing is to be welcomed, the application should be refused.

A Unique but Complex Site

The St Mary’s/Debenhams Site is a unique opportunity for Guildford.  It sits in the centre of the town at the foot of the High Street and offers an opportunity for the town to open up the riverside, enhance linkages between East and West sides of the river, rejuvenate the lower high street, provide multi-use accommodation, and house a design that enhances the locality. 

We accept the site is complex being an awkward shape and in a flood zone.  The current building provokes strong opinions both for and against.  It is a surprisingly sophisticated design, having several design elements that do break up its mass and provides a differentiation across and between its facades. The 20th Century Society has commented that “Its (Debenhams Building) design merit can be appreciated in the recently submitted views from Millmead embankment (view 19), Friary Bridge (23) and Millbrook at Rosemary Alley (21) (TVIBHA).”

The 20th Century Society has written two letters supporting the retention of the current building.  The Society notes that several large vacant department stores are being revamped for a whole number of uses

The Society also believes that the era of short life buildings with lives of circa 5 to 6 decades, due to environmental and sustainability issues, may be coming to an end a development on a site of this importance has to be considered as having a life of over a hundred years.

A Missed Opportunity?

The Society has repeatedly said that the site is possibly the most important in Guildford and will shape the town for the future.  We are concerned that the public realm uses have not been fully considered and that the proposed buildings do little to enhance the site. How this proposed development fits with the emerging Town Centre Master Plan and proposals for North Street is unclear.

Native Land and their architects Squires have consistently shown relatively minor variations on one scheme since starting consulting on the site.

With further details emerging from the Shaping Guildford’s Future/Town Centre Master Plan, with the next stage being approved on the 22nd September, and other sites e.g. North Street also firming up proposals isn’t it time to consider what the Debenhams site should provide for the town and how it relates to the rest of the town?  The development should enhance Guildford with good design and a vibrant public realm.

As Guildford Borough Council (GBC) have declared a climate emergency and considering the significant embedded carbon in the existing building, re-purposing of the existing building should also be thoroughly tested as an option.  

Developing the Site

The Society does recognise the site requires re-development.  We have no issue with providing housing on the site and making provision for commercial space.  We would make the following observations on the metrics of the proposed development.

  • Density.

The National Model Design Code at Page 14 Town/City centre identifies that – “A typical dense city typology with over 120 dwellings per hectare (dph) and a strong mix of uses”. 

The proposed development will have a density of circa 300dph. We have also looked at some of the dph figures for schemes in London and it is clear Guildford is exceeding, including St Mary’s proposal, many of the densities coming forward for London schemes.

Why is the historic core of Guildford going to be subjected to such a dense development which is more suited to a major City? 

  • Viability

We won’t comment on the details of the viability assessment. But do note that The Plaza Site, Solum, North Street, and St Mary’s will all be selling units at the same time (assuming consent and Build outs happen to plan).  Although the developments are different to a degree Guildford town Centre will have a large number of single and double bed units coming to market. Compared  to the Local Plan, Guildford Town Centre will comfortably exceed its dwelling contribution on the current build trajectory. Are sales values being judged too optimistically?

We note that the southern block, in particular is laid out to be easily used as a Build to Rent property in part, as has happened at the Solum development.

The North Street Scheme has produced an updated Retail Planning Statement - Submission 2022 - Document: 22 produced by Savills.  It would be useful for GBC/Native Land to ensure the results of this study match expected occupancy at the St Mary’s site for commercial space.

Like all schemes there is very little work on costing alternative options for the site – there seems to be an automatic assumption that maximum development of the site is the best option.

Meeting Design Objectives

The Design and Access Statement highlights that the Applicants brief for the site has an overall objective of “to provide a high-quality mixed-use development transforming the Site into a new destination that compliments the town centre and seeks to benefit the public realm with new thoroughfares, curated landscaped spaces and reactivation of the ground floor with retail and commerce.”.

From the overall objective above the developer has determined twelve main design objectives. The Society won’t comment on all these objectives.  We do have comments on whether the applicant has met its own objectives in several cases:

  • To connect the Site to the Town Centre experience

The Society considers the proposed scheme fails to provide this.Although landscaping is improved to an extent at the north end of the site, the fundamental issue of providing traffic free active travel access from the high street has been ignored; despite having an extant pedestrian underpass that could be reconfigured and re-opened.

Note: The Society do appreciate the ‘Shaping Guildford’ plans may solve this issue by removing, or reducing, traffic from Millbrook but the timescales and ultimate scope of this initiative are unclear and unfunded.

  • To reinstate River Wey walk.

The Society welcomes the proposed walkway.  We would like to see more commitment and detail on how the proposed bridge is to be provided across to the site occupied by the Yvonne Arnaud theatre.

  • To improve permeability across the Site.

We agree this has been improved but is also dependent on improving access to the High Street and across to the Yvonne Arnaud site.

  • To address the relationship with neighbouring listed buildings (Town Mill and Yvonne Arnaud Theatre);

The Society believes the proposed mass and scale of the buildings cannot be claimed to respect the neighbouring listed buildings. (See our comments under 9. Below).

In terms of the relationship several Policies and Guidance documents are relevant.

  • Local Plan Policy D3 is relevant: - (1) The historic environment will be conserved and enhanced in a manner appropriate to its significance. Development of the highest design quality that will sustain and, where appropriate, enhance the special interest, character and significance of the borough’s heritage assets and their settings and make a positive contribution to local character and distinctiveness will be supported.
  • The National Model Design Guide at C2 Para 14 states - “The character and distinctiveness of a place is created by the richness of the buildings that have been built up over time. Not just the individual buildings or monuments, but how they relate to each other and how they have contributed to the evolution of the place has a whole.”

We don’t consider the proposed design has taken this properly into account.

  • The Guildford Town Centre Views Supplementary Planning Document states - Consideration will need to be given to how new development might better reveal heritage buildings and to reduce mass and bulk on views and on skylines. Where new development is proposed to amend or replace negative detractor buildings, improvement and enhancement will be sought. Reductions in bulk and mass of negative buildings may be achieved through changed massing, varied roofscapes, detailing and materials.  

Although the break in the new development offers a glimpsed view of St Mary’s Church we believe the new development harms the views and skylines.

We don’t consider the proposed building design and mass scale can be considered to meet the three policies/guidelines.

The Views of the development should also be considered relative to other major developments in the town.  The North Street development has provided information as to how their development relates to the Plaza Site, Solum etc. The same should be done for the St Mary’s site so a full understanding of the context of the development can be achieved.

  • To incorporate flood mitigation measures.

Agree this has been met but only at the expense of heightened river walls with an impact on the riverscape as seen from Millmead etc. The walls also result in a large amount of embodied carbon, see our comments in the section below.

An issue that doesn’t appear to be addressed is the issue of a potential raising of the Town Bridge which blocks the river at times of flood.  If raised this would involve access slopes on Millbrook, which would impinge on the eastern aspect of the site.

  • To break down the singular mass of the existing building.

We do note the mass of the building has been reduced by splitting into two blocks but in practice from many angles this gap between the buildings is not apparent.  The height, of the blocks, for which we welcome the reduction for the northern Block, and their overbearing form will cause a major impact on the town.

The current (Debenhams) building has far less mass and scale that the proposed building as shown especially in the Townscape, Visual Impact and Built Heritage Addendum (TVIHBHA).

Many of the individual views show where the proposed development is out of scale with its surroundings, impacts views from the town out to surrounding hill line, or is very visible from outside the town.

We believe the views presented at 09, 10,11,12,13,15,18,19,20,21,22 23,24,25 31 show the large impact on the central area of the town. 

At Appendix A we show the issues with just two of the views 9 and 11 as examples.

The National Model Design code at B2iii para 114 states - The identity of an area type may be influenced by building heights, including its overall scale, its skyline, key views and vistas and the relative prominence of landmark buildings. Building height may also have an impact on local environmental conditions in neighbouring properties, amenity spaces and public spaces in terms of daylight, sunlight, overshadowing, wind and micro-climate. The placing of tall buildings needs to maximise user comfort of spaces between buildings by taking into account their impact on orientation and overshadowing of public and private spaces, quality of external spaces at ground level, wind tunnel effect, noise pollution and enable safe dispersion of pollutants. 

Although not an especially tall buildings the proposed development particularly the Southern Block does not conform to these principles.

  • To provide a highly sustainable building and increase bio-diversity across the Site.

We have concerns that sustainability for the building is not demonstrated these relate to three aspects of the development.

  1. Materials and embodied carbon.  The demolition of the building will result in 1000 tonnes of Structural Steel, 2000 tonnes of mixed metal, and circa 8000 Tonnes of crushed concrete.  The new building will require 15,000 tonnes of new concrete, 3000 tonnes of Steel (mainly Rebar). 

This has a considerable environmental footprint both to demolish and rebuild; particularly in its use of concrete.

  1. We see no evidence that the design allows for change and adaptation over its life.  It is notable that the proposed development at North Street proposes ground floors which are double height and adaptable for the variety of uses.
  2. The Society has asked how the buildings can be upgraded/retrofitted over time no clear answers have been provided.  This is particularly important is factory-built modules are used for Kitchens, Bathrooms or complete flats.


As part of the Climate Emergency, called by the council, surely more sustainable building methods should be considered.  There have been several examples of wood being used both in the UK and on the continent for example.

Other Observations.

Design South East Reviews.

The Design and Access statement provides from Page 15 a response to the Design South East recommendations.  These recommendations should be published in full.  It is notable that the applicants for the North Street site have the confidence to publish Design South East recommendations in full.

Historic England

We have yet to see any response from Heritage England on the revised proposals.  They were critical of the original plans and it is not apparent their concerns have been met.

Demolition Plans

It is notable that the proposed Lorry Routing uses a route down Portsmouth Road and back to Shalford to avoid right turns into the site.  With potentially 3-4 HGV’s using this route at peak this could add to congestion at the Broadford Rd Bridge.  Has any consideration been given to using the river for transport?



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