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20/P/00825 | Full planning application for the creation of a floodlit artificial hockey pitch with a 6-lane all weather running track, a football pitch, relocation of cricket nets, extension to sports pavilion balcony and new javelin, discuss, shot put and long jump area alongside the creation of a new store building and additional on-site car parking. (Additional information received 04.01.21 & 07.01.21 landscape visual impact, archaeology, drainage and planning statement addendum). | Urn Field, Downside Road, Guildford
  • Total Consulted: 604
  • Comments Received: 584
  • Objections: 207
  • Supporting: 374
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Rosemary Morgan (Objects)

Comment submitted date: Thu 11 Mar 2021

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Comment submitted date: Wed 21 Apr 2021

Not Available

Comment submitted date: Mon 22 Nov 2021

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Mr Charles Wilce (Objects)

Comment submitted date: Mon 01 Jun 2020

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Comment submitted date: Fri 29 Jan 2021

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Comment submitted date: Wed 17 Feb 2021

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Comment submitted date: Mon 12 Apr 2021

In recent Bat Surveys of Urnfield by Greenage Ecological Consultants, high levels of bat commuting and foraging activity were noted along the northern boundary tree line where the Applicant is proposing to site eight 13m tall floodlights. Several of the bats recorded (including Noctule, Leilers and Natterers bats) forage in the early evening and are known to roost in trees.



The Bat Conservation Trust notes that floodlighting adjacent to tree lines can modify hibernating, commuting and foraging habitats through disturbance including light spill and noise. Their Guide for conducting Bat Surveys states that a Bat Roost Survey should be completed if floodlighting is proposed within 50m from a line of trees connecting to woodland.



Even though this area of Urnfield was highlighted by Greengage as having potential for indirect disturbance through lighting and noise (Section 4.46 of the Ecological Appraisal) and will be within 50m of the proposed floodlights, the Applicants Bat Survey did not incorporate a full investigation of the treeline but instead limited their scope to the dilapidated structure due for replacement.



It is unlawful to disturb bats (roosts, flight lines or foraging areas), especially if it can be shown to impair their ability to breed, reproduce, hibernate or migrate. Deliberate disturbance is a Criminal Offence which carries a maximum 6 month prison sentence. Therefore, as a minimum, a preliminary ground level roost assessment of the tree area within 50m of the floodlights should be completed prior to determination.

Comment submitted date: Mon 22 Nov 2021

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Mrs MC Taylor (Objects)

Comment submitted date: Fri 26 Jun 2020

I strongly object to this application.



Urnfield is situated at the top of a hill and the elevated position of the flood lights is totally inappropriate for the site which is bordering an AONB. It will create light pollution which will be seen for miles round.



The wildlife (bats, deer, owls etc ...) will suffer greatly directly and indirectly as the activities will increase day in and day out near their habitat.



It is highly likely that the facilities will be used not only by pupils local schools but also by clubs at any time of the day and throughout the whole year. This will have a negative impact for local people.



The proposed development is most detrimental to the quality of life of local residents (light pollution, noise and extra car and coach traffic) and also for people enjoying the country side.



This application has to take into consideration the well-being of all and not just the well-being of the children who will use these facilities. The local residents live near Urnfield. The majority of people who will use these facilities do not.



There are already all weather facilities on either sides of the town which can be used by schools, Surrey Sport Park and Spectrum. Guilford County School already has some facilities on site. Spectrum is not far from Tormead School.



Has an independent environmental assessment been done ?



I do not support this application as there are already all weather facilities on both sides of the town and also because of the negative and damaging impact the proposed development will have on local people, the environment and the wildlife.

Comment submitted date: Thu 28 Jan 2021

Objections to the proposed plans at Urn Field



I write to reiterate my objections about the proposed plans. I am a Merrow resident who lives very near the Downs.

The application site is within the Surrey Hills AONB and Guildford Borough council has I believe a duty to respect it.

Both schools already have a MUGA and floodlights or have planning permission for a MUGA and floodlights on their own sites. However this application is assessed, it is hardly a necessity as the pupils already have good facilities on their own sites. The schools have not provided evidence that such facilities are a must.

A balance needs to be found between what is appropriate development for the schools concerned versus the need to respect the locality which is part of the Surrey Hills AONB. This is also an Area of Great Landscape Value.

Most of the comments in support of this application are from the parents of pupils attending the schools.

Guildford County School is situated on the other side of the town where most of the students live. The parents are not local residents and will not be affected by any of the negative impacts of the application they support.

Tormead is an independent school where the students come from quite far in some cases. Tormead has coaches bringing students from Haslemere to the south, Farnham to the west, Esher to the north west and Ewhust to the south as well as others. It is therefore very likely that most of the parents supporting the application are not living locally, again they support an application but will not themselves bear any of the negative consequences.

The Urn Field site is currently a relatively tranquil locality, although it is semi rural because the site is situated at the very edge of the built up part of Guildford Borough. Whilst the presence of trees will go some way to hide the new facilities, during the winter months there will be significantly reduced screening of this site (as it is now with deciduous trees).

The 15 m tall columns will be seen above the line of the trees at all times of the year. Furthermore, the impact of light pollution from the floodlights will be noticeable whatever anyone claims about how well the pollution can be controlled. There will always be a significant amount of reflected light and it is hardly likely that the light levels will be turned down to respect the rural character.

Is there a real need to have the lights at all? Is there evidence that the schools need to use the hockey pitch after school in winter time?

These columns will be a permanent feature visible by all during day light and in the evening when the lights are on.

According to Maddox in their recent report point 2.8, the cricket nets need to stay where they are so they are not visible from a number of surrounding locations " ........ the nets create a visible structure which at the end of the site would compromise the surrounding landscape." So if the nets need not to be seen, how can the applicant justify the 15 m tall columns for the flood lights which will be seen at all times throughout the year and the light pollution created by these lights? Also, does this mean that it is alright for the nearby residents to see the cricket nets ? Perhaps the applicants could answer this question. The need to use floodlights deserves to be carefully assessed as it has long term adverse impacts on this rural environment.

Certainly, the view along Downside road will be changed significantly with floodlights forming the background scenery behind the houses.

The same is to be said along Little Warren road with the cricket nets and the floodlights.

I would like to mention that there is no effective existing hedge to protect the residents nearest to the old tennis court. From the path which runs along the garden of the last property bordering the Urn Field boundary down to the Downs, the Urn Field site can be seen in full view. The wire fence offers no protection to the neighbours. Where there is vegetation it is mainly ivy and brambles. The same applies along most of the side. This can hardly be considered as existing hedges which will offer visual or audible protection. One would expect that a planted buffer zone of trees should be offered to protect the nearby houses.

Point 2.3 of Maddox report, 30 students from Woking Football Club will no longer be coming which means 25 return journeys less per day. But this will be the case only if they are not replaced by another group of people which is something the applicants do not say.

If it costs 150 per hour to hire a pitch (Maddox, point 2.10), it will therefore be very tempting for the applicants to rent the facilities to other parties to recuperate the high cost of the construction. This means that it is highly likely that the facilities will be used more and more as time goes.

The wildlife is hardly mentioned, there will be destruction during the construction phase of the application and disturbance for years to come as the use will not doubt will increase to the detriment of the animals (deer, foxes, badgers, bats, owls, invertebrates, reptiles and all other birds).

Using Covid 19 (Maddox report point 2.10) is a very strange argument in favour of the planning application. "It is impossible to guarantee this isolation at a venue that is also frequented by the general public " This seems to imply that Urn Field will be safer than other venues. Can they justify their statement ?

Two different schools will use the facilities plus all the other groups from elsewhere, plus the parents bringing or collecting their children, this seems equivalent to the general public to me as no one will know where everyone has been during the course of the day or the days before. There will also be sharing of facilities in the pavilion. It is unlikely that there will be more control of the virus at Urn Field than anywhere else.

During lockdown Urn Field is closed and no one benefits from the sport field.

For the above reasons I strongly object to this application.

The proposed application is not eco friendly at all and is, in my opinion, not a necessity.

Urn Field needs some updating but the application should be sympathetic with the environment, it should support the wildlife, it should respect the local residents. It is also within the Surrey Hills AONB which is a point hardly ever mentioned by the applicants. This application, as it stands, is certainly not sympathetic. Instead it destroys the environment with the construction of an artificial all weather hockey pitch and the use of flood light will be intrusive. The noise level, the traffic and the usage of the site will all increase.

Comment submitted date: Mon 22 Nov 2021

Planning application 20/P/00825 Urnfield development

I am a local resident.



I have read the new documents submitted recently and still object strongly to the proposal of the construction of the all-weather artificial pitch and tracks as well as the eight floodlights.



The site is in an AONB which is meant to be protected from unsuitable development and the applicant has not given any exceptional reasons to justify such development.



The development is for convenience only. There are available alternative sites such as Surrey Sports Park and the Spectrum. Having an all-weather pitch and tracks with floodlights is not an essential requirement as such for the applicant. Having all facilities on the same site is not a requirement either, it is just a convenience.



This development is not "in the public interest" as stated by the applicant, it is only in the interest of the applicant and, contrary to what the applicant says, it will generate harm to the AONB.



1 Floodlights

As I have said in a previous letter, the floodlights are only needed in winter time for the students who wish to do training after school hours, it is for the few who are part of the teams and will play matches. The floodlights will NOT benefit the whole school.

I will also reiterate that the trees around are deciduous and offer little protection for the local residents and the general public against the light pollution.

The computer generated drawing page 5 of the lighting report provided by Edward Pearce for their client Tormead is inaccurate and consequently misleading. The residents who live towards the Epsom Road are at a lower level than Urnfield and would therefore be looking up towards the floodlights. This means that in winter time, when the floodlights are operating and the trees have lost their leaves, the light would have greater visual impact from these view points.

The other sport sites with floodlights are not in an AONB and are not in an elevated position.



2 Well being

The facilities already available at each school (including MUGA and floodlights) plus the facilities at Urnfield which can be used during school hours are beneficial to all. On the other hand, no one, whatever their age, needs an artificial pitch, tracks and floodlights for fitness or a healthier lifestyle.



3 Covid 19

Covid is NOT a planning matter and should not be used in support of the application.

The applicant has stated that "bubbles of students have to be isolated from each other and members of the public".

The reality is that the pupils using Urnfield come from two schools situated in different parts of the town. A fair number of these pupils travel to and from school by public transport (trains and buses), consequently there is no such "bubble" as they are then part of the general public. There are also other groups using Urnfield, PE staff, drivers, cleaning staff, maintenance staff. This is equivalent to the general public.

Urnfield is no more and no less safe than any other venue open to the general public.

Is the applicant implying that using other facilities such as Surrey Sports Park are unsafe ?



4 Safeguarding

It is quite surprising to read that the applicant has written : "Safeguarding: external facilities offer a considerable safeguarding challenge, as they are accessible to the general public at the same time as being used by schools".



5 Environmental impact

The applicant writes: " Use of external suppliers results in additional journeys (due to needing multiple vehicles to travel to several locations), which has a negative environmental impact."

What about the negative impact of the artificial all-weather hockey pitch and tracks and floodlights ? Can the applicant say what is good for the environment and the wildlife about the destruction of a large grass area and the construction of an artificial turf pitch in its place and also erecting eight floodlights ?

In the light of the recent COP26 recommendations and the Environment Act 2021 this application should receive a refusal because of the sensitivity of the site location and its negative impact on the local biodiversity.

The negative impact on the wildlife is totally ignored in this application.



6 Other users of Urnfield

Woking Football Club is the only club using Urnfield which is mentioned. There has never been any information at all about any of the other community groups, it would be useful to know the following :

Who are they ?

How often and when do they come ?

How many attend each session ?

How do they travel ?



7 Hiring of the all-weather pitch and track

The applicant has not said that they would not let the artificial pitch for hire so one can only conclude that it is highly likely to happen. This will have an impact on the traffic and the noise.



8 Parking

The applicant writes (3.11) " No parking is proposed on Downside Road". However, the schools have no control over where parents will park their cars and those who wish for a quick get away at the end of a session or a match will no doubt park in Downside Road.

The applicant also writes (2.3) "As discussed below, there will be no increase in traffic to the site..." and (3.3) "We anticipate that there will be no increase in the number of journeys to and from the site." But at the end of the same section the applicant writes: "On this basis, we do not expect a significant increase in the number of journeys to the site". This implies that there will be an increase in the traffic to and from the site. Can the applicant give a truthful answer regarding the traffic.

In the same section (3.3) the applicant writes "- 1 additional school session during the school day - 2 additional journeys;

- 1 additional after-school training session - 30 additional journeys

- 3 additional school weekend fixtures - 60 additional journeys; and -

Less: 25 Woking FC journeys per day, 5 days per week = 125 journeys."

These figures are confusing and clarification is needed. The last point is clearly for the whole week, "minus 125 journeys". What about the first two points, "the additional school session" and "the additional training session", are these taking place daily or just once a week ? this is important to know as it will make a considerable difference to the numbers as 2 will become 10 extra journeys and 30 will become 150 journeys. Please can the applicant clarify this point and give accurate figures per day or per week.



9 Cricket nets

Could the applicant provide a technical drawing with measurements of the cricket nets as "they create a visual structure" ?

Could the applicant also provide a plan of the crickets nets should they be relocated on the eastern boundary. The plan should also include the Golf Club house which is supposed to see those nets. No one lives at the club house, on the other hand, there are residential properties next to where the applicant wishes to have the nets.



10 Conclusion

The artificial pitch is not environmentally friendly and the eight floodlights are not acceptable as a permanent feature in an AONB. The artificial pitch and the floodlights are not in the interest of the public. There are no exceptional circumstances to justify the proposal. Therefore, I urge the Council to refuse permission for the application as it is at the moment.

Mrs Katherine Atkinson (Objects)

Comment submitted date: Tue 16 Jun 2020

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Comment submitted date: Wed 13 Jan 2021

Further comments on Planning Application 20-P-00825 Urn Field



I should like to raise a number of objections to the Planning Statement Addendum and to the Landscape and Visual Assessment as follows.



Planning Statement Addendum - Concerns



Paras 2.1 and 2.2 - Hours of use and non school clubs



"The site has been used by a number of community sports clubs for many years, at both weekends and weekday evenings...unreasonable to remove access to these community sports clubs..."

"The only element of the proposals that has the potential to lead to an intensification of use is the proposed floodlighting. It is therefore, proposed that a restriction is placed on the use of the floodlights, with these limited to use prior to 8:00pm each day."



The rationale for floodlighting is that it extends the period during which school and community groups could use the facility, so it is reasonable to expect that even an extension of operational hours to 8pm would significantly increase the use of the site. Indeed, that is surely the underpinning logic of the application (why invest in the site if it is not to be used more?)



Para 2.3 Levels of use / traffic



"We anticipate that there will be no increase in the number of journeys to and from the site".

"Community use is expected to continue at current levels (both at evenings and weekends)"

"...we anticipate the following 'new' sessions as a result of the proposal:

- 1 additional school session during the school day - 2 additional journeys;

- 1 additional after-school training session - 30 additional journeys;

- 3 additional school weekend fixtures - 60 additional journeys; and

- Less: 25 Woking FC journeys per day, 5 days per week = 125 journeys."



This data is full of inconsistencies.



Firstly, on the figures set out by the Applicant, there clearly is an increase in the number of journeys to and from the site.



Secondly, if the plan is only to have one additional after-school session per week, then there is surely no justification for expensive and unsightly floodlight towers. Either the floodlights are required for significant additional use, which should be recognised by the Applicant, or the development is not required as there is no significant additional use.



In addition, para 2.10 - alternative facilities - states

"there is a significant economy in taking all pupils to a single location, rather than hiring multiple coaches to travel to different external providers".



Is the ambition for consolidated provision across a range of sports in one site really coherent with the claim of only 1 additional after-school session per week? Either the usage figures or the rationale for the development are ill founded or incorrect.



Para 2.10 - alternative provision



Covid-19 is not a material planning consideration. This development is permanent and the pandemic is not.



Para 2.4 - Light spill and visual impact



The Landscape and Visual Assessment concludes, in relation to the adjacent and much loved Merrow Down in section 7.12:



"It is therefore judged that the proposals do introduce a new lit element into a darker part of the sky but in the context of the existing urban edge and the lit uses associated with it. The judgement on the impact on this part of the AONB is that there will be a medium impact on this high sensitivity receptor in this location."



Later on in the report it is recognised that this would constitute a permanent change to the landscape.



Something assessed as a "medium impact" on a "high sensitivity" receptor contravenes the legislation set up for AONBs and is contrary to Guildford Borough Local Plan Policy P1 section 3:



"Great weight will be given to the conservation and enhancement of the natural beauty of the AONB and development proposals must have regard to protecting its setting.

4.3.5 The NPPF is clear that AONBs should be afforded the highest level of protection in relation to landscape and scenic beauty. All development proposals within and adjacent to the AONB will be expected to conserve or enhance its special qualities."



The concept of "setting" as acknowledged in Policy P1 is important as it implies that development not within the boundary of a designated landscape can have a detrimental impact on that landscape. This supports the view that it is "not ok" to develop inappropriately on the edge of these nationally important landscapes, outside the boundary, let alone within it. This application should be rejected on those grounds if we are to preserve our precious AONB for the future.



Other comments on the Landscape and Visual Assessment



7.24: "It should be noted that there will be limited use of the public areas of Merrow Downs and the golf club when it is dark."



The report is incorrect in referring to light spill from the Golf Club as this is highly localised to the entrance from the car park and the sunken terrace area at the back of the club house. These do not impinge on the dark skies enjoyed on Merrow Downs, as many people witnessed recently when out watching the alignment of Jupiter and Saturn on the Downs. This planetary event (visible at about 5pm) would have been ruined by the proposed floodlighting.



Secondly, the assumption that use of the Downs ceases at dusk is incorrect. In midwinter you will find many people walking their dog or going for a walk at 4pm when floodlighting would be needed. It is dark but it is not night time.



The Edge of the AONB



This is a common argument made by developers - that developing the edge of a nationally designated landscape is somehow more acceptable than developing in the middle of it (or in a "more remote" area). The flaw in this logic is fairly obvious; once development "nibbles" in to an AONB then future developers use exactly the same argument to continue to develop into the AONB, and so on. AONBs have a boundary for a purpose, and arguing that one part of the designated landscape is somehow less valuable than another will sentence the AONB to a slow death.



I urge you to recommend refusal of this development application.

Thank you.

Comment submitted date: Thu 04 Feb 2021

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Comment submitted date: Mon 29 Mar 2021

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Comment submitted date: Thu 18 Nov 2021

Not Available

Ms Anna Tatcii (Objects)

Comment submitted date: Tue 10 Aug 2021

I am a local resident.



Reading through the many documents uploaded to the website, I noticed the Planning Statement Addendum from Maddox Associates in January which continues with inaccurate statements regarding car parking on the site:



2.6. The current hardstanding area (former tennis court) has been used as a carpark for over 30 years, without any complaints from neighbours. The 'current' use includes some use of the site after dark, as the site already has (limited) floodlighting which is used to support football training during winter evenings.



This area has never been in regular use as a car park - if you visit the site you will notice that there are no wear or track marks on the grass between the current car park and the hardstanding area. It has been used once, maximum twice per year for 'large' one-off events such as Sports Days which is the reason why there have been no complaints from neighbours. There is much general concern regarding the impacts from light and particularly noise on neighbouring families if this quiet location were to become the primary site car park, along with the associated loss of privacy and residential amenity.



When needed, it is the area directly in front of the Pavilion that is currently used for overflow parking, not the hardstanding area. With installation of an all-weather green mesh base this arrangement could become permanent, sensitively extending the existing car park without any loss of green space. This area is much closer to the entrance and more central in the site so would seem a better option from noise, safety, lighting, neighbourly amenity and practical parking points of view. The hard-standing area could then be retained in its current capacity as overflow for large 'one-off' events, mitigating the impacts from intensification of use.



I object to the current application in this regard and hope you will be able to take the above into consideration when you come to review it.

Ms Alivia Kratke (Objects)

Comment submitted date: Fri 21 May 2021

Ms Kelly Jethwa

Case Officer

Guildford Borough Council

Millmead

Guildford, GU2 4BB





Dear Ms Jethwa,



PLANNING APPLICATION 20/P/00825

Urn Field, Downside Road, Guildford



I wish to register a formal objection to this planning application.



The Urn Field site is located in the Green Belt and lies within an Area of Outstanding Natural Beauty.



I note the application will entail the erection of six 15m floodlit columns, operating up to a (proposed condition) of 8pm each day, to illuminate the pitch to 350lux. The Landscape and Visual Appraisal Addendum notes they will be visible in both day and when lit. This will thus affect the wider AONB and Green Belt outside the curtilage of the property.



Harm to the Green Belt



Whilst paragraph 141 of the National Planning Policy Framework allows for opportunities for outdoor sport and recreation in the Green Belt, this is qualified that such opportunities should "retain and enhance landscapes" and provide "visual amenity". The purpose of the Green Belt in paragraph 134 is to "assist in safeguarding the countryside from encroachment". These tests are not met, and the development of these floodlit columns will clearly damage the landscape, harm visual amenity and reduce the openness of the countryside.



The applicant has not sufficiently demonstrated that it has exhausted all other reasonable options for meeting the need for development on the Green Belt. While I am fully supportive of the health benefits of the facilities proposed there is no evidence of the need for this facility to be artificially lit.



Harm to an Area of Outstanding Natural Beauty



The Guildford Local Plan commits the Council to "conserving and enhancing AONB to maximise its special landscape and scenic beauty" with "great weight [to] be given to the conservation and enhancement of the natural beauty of the AONB".



Furthermore, any development proposals must be assessed against the provisions of the Surrey Hills AONB Management Plan which is emphatic that "great weight will be attached to tany adverse impact that a development proposal would have on the amenity, landscape and scenic beauty of the AONB and the need for its enhancement" (Policy 1).



The Landscape and Visual Statement is clear that far from enhancing Merrow Downs the floodlights will diminish the area as "when dark the floodlights will have a low to medium effect on the landscape of Merrow Downs". The report continues that the "change is permanent" and local people (more familiar with the Guildford area than the Midlands based authors of the report) would dispute the claim made that the Merrow Downs is not a dark or tranquil location. This is a Dark Sky area that spans many miles of Surrey Hills AONB countryside with the floodlights immediately visible in the Merrow Downs and potentially seen from St Martha's, Newlands Corner, and even further afield.



Six 15m high columns (each nearly the height of a double decker bus) on the already elevated Urn Field site will be highly visible from the Merrow Downs. Para 1.9 of the Landscape and Visual Statement recognises this: "It is considered that when dark the floodlights will have a largely low effect raising to medium for those that experience a direct view". The proposal therefore appears in direct contravention of Policy 6 of the Surrey Hills AONB Management Plan that: "Development that would spoil the setting of the AONB by harming public view into or from the AONB will be resisted". Para 1.10 of the statement confirms that there will be an "'introduction of a new lit element into a darker part of the sky" with the dark skies in this specific location materially and permanently damaged.



Paragraph 180 of the National Planning Policy Framework requires intrinsically dark landscapes to be protected and the associated nature conservation enhanced. Yet the Visual Statement confirms: "When dark the lights will remain visible". Points raised repeatedly in the correspondence to flag the planning protections in place to protect AONB areas from light pollution have not been taken into account by the applicant in their recent statement addendum.



Questions should also be asked of the applicants claim in their statement that "a lower mounting height can create a higher level of light spill and require additional lighting points". The applicant also provided evidence of other sports pitches (Merrow Tennis Club, Royal Grammar School, etc) that manage to operate effectively with columns much lower than 15m high. I would ask the Council to seek further additional advice from a lightning engineer to test the assertion made by the application that the lighting impact will be focused on "very small portion of the AONB".



Effect on biodiversity and nature



The applicant recognises in the addendum that the flood lighting will lead to an intensification of the site. The recommended condition of limiting the use of the floodlighting to 8pm would not compensate for the light pollution over the winter months and the irremediable damage to the ecology of the area (with a high presence of badgers, nesting birds and bats identified).



Precedent



For the reasons set out above, this application should be refused. If approved, it will set a dangerous precedent for the lack of protection afforded to AONB dark skies and permanently erode the amenity, landscape and scenic beauty of Merrow Downs and the surrounding AONB areas.



Site visit



I would encourage the Planning Committee to undertake a site visit to assess for themselves the impact on the AONB skyline and consider the permanent damage that will be done to the area if this important site is overdeveloped in such a way.



Yours sincerely,



Alivia Kratke

22 Chesham Mews, Guildford, GU1 3NL

Comment submitted date: Mon 09 Aug 2021

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Ms Jacqueline Bray (Objects)

Comment submitted date: Sat 26 Jun 2021

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Mrs MC Taylor (Objects)

Comment submitted date: Thu 25 Mar 2021

20/P/00825 Urnfield

I have read the new information regarding the above planning application put on your website on the 23rd March 2021.

I am a local resident.

It is worth remembering that both schools already have a MUGA or have permission for a MUGA and floodlights on their own sites so that they can have after school activities.

Although there is a proposed reduction in height, I still object to the eight 13m tall floodlights and I am concerned about the artificial hockey pitch and running tracks. The floodlight columns will be seen by the local residents at all times and so will the light in the evening. The all weather area is not environmentally friendly at all.

I also question whether there is a real need for floodlights.

Urnfield is a school sports ground as far as I know. Hockey and athletics groups/clubs who wish to train have facilities at Guildford Spectrum and Surrey Sports Park.

As per the curriculum, the sport activities for all students, whatever their standard, are done during school hours either on their own school ground or at Urnfield and therefore do not need any floodlights. I doubt that schools have compulsory sport lessons after the school day which would require floodlighting.

The afterschool activities which will take place at Urnfield are therefore likely to be for the applicant's students who are in a team and who will probably take part in matches or competitions. These activities are therefore not for the benefit of all but for the selected few.

The only people who will benefit from the floodlights are the ones who will be using the newly built hockey pitch or the running tracks when training or competing after school hours. People playing other sports (rugby/football/cricket) will not benefit from the floodlights.

Why ruin part of an AONB for the benefit of a few, why upset or even destroy its wildlife ?

I consider that the use of eight 13m tall floodlights is not necessary. In my opinion, the applicants have not yet proven that floodlights are a necessity for the benefit of all their students. I would welcome a detailed explanation from the applicants giving the reason why floodlights are needed for their students and why they need to use Urnfield from October to March after the school day.

If the use is not just for their own students more details are then needed. Such information would be useful to assess the need of the floodlights. We must not forget that the groups hiring the new facilities mean more traffic, more noise and more disturbance to the neighbourhood. How often and how many clubs/groups will hire the pitch or tracks ?

Is this application turning Urnfield Sports ground into another Spectrum or Surrey Sports Park?

In my opinion, the construction of an artificial hockey pitch as well as the running tracks will destroy part of the field. Good quality grass which can withstand regular usage and good management should be considered by the applicant instead of creating an artificial man made pitch and running tracks which are not environmentally friendly at all. Using a grass pitch and tracks during the school day by the students of the schools do not require floodlights and would have no negative effect on the area. I do not think that an artificial pitch is a must for school students especially as they already have facilities or permission for such on their own sites.

It is interesting to read on the website of Tormead Junior : "Tormead is proud to be an Eco Green Flag school and has attained four Green Flags to date. Working towards our fifth Green Flag ...........We hope to have a life-long impact on our girls and families as we strive to improve and conserve our world."

I totally agree with the above. I therefore find it difficult to understand how these values seem to be totally ignored by the applicant when Tormead asks for the construction of an artificial hockey pitch, running tracks and floodlights in an AONB. The application does not appear to "conserve our world" but destroy a local area instead.



I am not against updating the pavilion for better facilities, this will be for the benefit of all who use Urnfield, but destroying part of an AONB is unacceptable as nothing should compromise such an area. I believe that the negative consequences of this application on the wildlife and the environment and also on other matters are far greater than any benefit. I still believe that there is no need at all for floodlights.

We all have a moral duty to respect and protect our local area and that includes schools. An AONB is a national designation which has planning laws which need to be respected in order to protect it. It is everyone's responsibility for the benefit of all.

As the site is in an AONB, should not there be a public inquiry ?

Comment submitted date: Fri 21 May 2021

Re. Urnfield Sports Field



Following the recently submitted information from the agent (May 2021), I would like to comment on a few points.



I would also welcome detailed information regarding the use of Urnfield by the applicant (Tormead and Guildford County) AFTER school hours regarding the need for floodlights.



1. TRAVEL PLAN required by Highways

The agent has written :

"This is an incredibly unique site and it is therefore very difficult to monitor travel patterns and to enforce any measures to reduce car travel ...". This is a truthful and clear comment.



The agent has also written :

1. "There will be a modest increase in the number of individual users". What does "modest" mean in term of numbers ?

2. "Tormead's use will increase - more individual users per day than the current SCL use". No number has been provided or the times when these individual users will be using Urnfield.

3. "A small increase in parent/supporter journeys is expected which offsets the reduction in SCL journeys such that no significant change is expected". SCL users have provided numbers, Tormead has not.

4. "In future, a larger proportion of journeys are expected to be made by larger vehicles (eg, coaches) rather than cars". Can the applicant guarantee that this will be the case otherwise this statement has no value.

5. "There is no increase in site area or changing facilities; there is only one additional pitch added, so a significant increase in concurrent users is unlikely". The pupils do not need to use the changing facilities at Urnfield. It is not unusual practice for school pupils to change into their PE kits at school before getting on the minibus or coach for their sport activities. This statement has little value as there could be "concurrent users". The "significant increase" is described as "unlikely" but it is not ruled out.



All the statements in this document are far too vague and general; they do not provide any substantial information. To be useful, there should be numbers added, and whether these additional numbers will be during the school day or after school, at the weekend and who will be the users of the new facilities , how they will travel etc ... Apart from SCL, none of the other users have provided numbers. The word "increase" is mentioned several times but is then softened with other words which means that the statement gives no specific information. Is there an increase or not ?



2. BUSES

During school hours, the pupils will be taken from their respective schools to Urnfield and back again by coach or minibus. They will not use public transport during the school day.



The use of public transport will therefore have to be out of school hours which is most likely to be at the end of the day for activities outside school hours or at the weekend.



The agent has written "the site is within a 5 minute walk of 7 bus routes".

The first part of this statement "within a 5 minute walk" is inaccurate. It takes over 9 minutes to walk at reasonable speed without carrying any bags down the narrow path along Urnfield, across the Downs, along Down Road and left into Epsom road to the nearest bus stop. Another way is along Downside Road, down Warren Road, down Tangier Road and left into Epsom Road to the nearest bus stop, and again at reasonable speed without carrying any bags this takes 13 to 14 minutes. It also takes over 5 minutes to get to the bus stop along Warren Road for bus number 23.



No pupil walking could be at a bus stop along Epsom Road within 5 minutes as stated by the agent when leaving Urnfield especially when carrying a school bag and/or sports bag. A parent collecting the pupil by car is more likely to take place instead of walking and then using the public transport.



. Bus 300 This is the Merrow Park and Ride bus which starts in the Park and Ride car park and goes directly to the town centre WITHOUT STOPPING at any bus stops along Epsom Road on the way down to the bus station.

. Bus 37 This bus starts at Guildford bus station and goes away from the bus station towards Merrow, Bushy Hill, Merrow Park, Burpham, Burpham Sainsbury's, Weylea Farm before going back to Guildford bus station. This bus 37 does NOT go directly to the bus station from Epsom Road.

. Bus 478 There are two buses a day running during school days, both are during school hours.

The agent has written "the site is within a 5 minute walk of 7 bus routes". The second part of the statement " 7 bus routes" is also inaccurate as there are 4 bus routes and not 7.

. Bus 23 from Warren Road There are 4 buses a day (one every two hours), 3 of those are during school hours leaving just ONE bus after school.

. Bus 463 and bus 479 provide a service but the gap between buses at different times varies between half an hour and 2 hours.

. Bus 36 After school hours, there are two buses per hour from Epsom Road down to Guildford bus station.



The agent has written "It is, therefore, true that there are good bus services nearby." This is his opinion, it is not a fact.



The timetables of all buses are available on internet. Bus services are reduced at the weekend.



It is definitely NOT a 5 minute walk and there are NOT 7 bus routes.



It is a shame that such simple facts are inaccurate.



Considering the public transport situation, it is very likely that most pupils who finish their activities/training after school will be collected by car.



The lack of detailed information in the travel plan and the inaccurate facts regarding the buses are disappointing.



3. USE OF URNFIELD AFTER SCHOOL HOURS / FLOODLIGHTS

I would be very grateful if Guildford Borough Council would ask both schools (Tormead and Guildford County) as well as existing other users to give detailed information regarding their use so far of Urnfield AFTER school hours. Such information would be very useful to establish if there is a real need for floodlights as these will have such a negative and lasting impact on the wildlife as well as the neighbourhood. All the negative points have already been mentioned in detail in numerous letters of objection.



The agent says "Tormead's use will increase". It is therefore important that Tormead school gives precise information about their use of Urnfield in the past and what they intend to do in the future. This statement has implication both in term of increased traffic and the floodlights.

The applicant has not yet provided any detailed and transparent information nor given good reasons to justify the floodlights for school purposes.



Would it be possible to have accurate and detailed answers to the following questions for the last five years (2020 will be different due to lockdown):

1- how many groups of pupils have used Urnfield AFTER school hours each day ?

2- how many pupils did it involve each day ?

3- how long did each group need for a session ?

4- how many pupils have at the end of a session gone home by public transport ?



The following questions are about future use.

5- how many groups including numbers of pupils will be using Urnfield after school hours and how long for ?

6- how many will be using the new artificial pitch after school hours each day ?



As I have mentioned in a previous letter, the use of Urnfield AFTER school hours is most likely not to be for all pupils as compulsory PE lessons are done within the school day. The selected few, the ones who are in a team are the ones who will using Urnfield after school and who would like to have the use of floodlights during the winter months. But do they really need them ? The wish of a few people for their own benefit is not enough to justify the lasting negative consequences. The applicant has not yet given good reason for those floodlights.



I doubt very much that the night time graphics provided on the visual addendum dated May 2021 are what the reality will be.



During the winter months, training by school pupils can be done during daytime at the weekend and therefore do not require floodlights. In any event, pupils can train at their own school where they have already floodlights or have permission for floodlights.



Urnfield is a Sport field which should be used exactly in the same way as it is at the moment. It is well used by school pupils and sports clubs but at the same time its use respects the environment and does not destroy the wildlife habitat or pollute the night sky etc .... Once an artificial pitch is built with floodlights it can easily turn into a facility which can be hired and operated as a commercial enterprise. Should this be the case, then the application should be revised to reflect this as it has traffic implications.



We should not forget that an ANOB is protected by law and that the applicant (Tormead School and Guildford County School) should respect such planning law just like anyone else.



The applicant should accept that the site is in an AONB where floodlights are not acceptable due to their negative impacts and submit an amended application where the floodlights will be removed. This, in my opinion, is the right thing to do.



Not all information for the application is available yet and until transparent answers on all points raised are given by the applicant this application should not be approved.

John Oliver (Objects)

Comment submitted date: Tue 30 Jun 2020

To view this comment please refer to the Documents list.

Comment submitted date: Fri 30 Apr 2021

To view this comment please refer to the Documents list.

Ms Jane Vessey (Objects)

Comment submitted date: Sun 24 Jan 2021

I object to the planning application on the basis of the proposed floodlighting. Whilst I can see the benefits of improved sports facilities, I do not accept that the construction of 15m high pillars and proposed floodlighting meet planning requirements for a site which is designated as Surrey Hills AONB and Green Belt, whether it is on the edge or middle of the AONB area is irrelevant, it is still an AONB.



Due to the elevation of the site this would cause serious light pollution over the surrounding area as well as the columns changing the landscape, and being highly visible from Merrow Downs, and much further afield.



The development will impact local wildlife. The Bat Survey identified a number of bat species using this area for foraging and commuting activity and recommends that column heights are minimised and bat sensitive lighting is used, ideally warm white and <2700 Kelvin. The data sheet from Philips describes the proposed lighting in the application as cool white and 5700 Kelvin. I cannot see that the proposed lighting is anywhere close to what is required.

Comment submitted date: Thu 08 Apr 2021

With reference to the ILP report of January 2020 (Guidance Note 01/20) Urnfield is Zone E1 as it is AONB. Please can the applicant confirm that the lights will conform with all the luminance limits for this Zone. These limits are significantly lower than those required in Zone E2, which was referred to in the document submitted by Signify on March 23rd 2021.

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