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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: 508
  • Comments Received: 582
  • Objections: 204
  • Supporting: 375
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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

To view this comment please refer to the Documents list.

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

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Comment submitted date: Fri 30 Apr 2021

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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

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.

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.

Mr Francis Taylor (Objects)

Comment submitted date: Fri 26 Jun 2020

Whilst it is commendable for schools to improve their sports facilities, the proposal for this location is totally inappropriate.



The Urnfield grounds border an AONB and the adjoining woodlands provide a habitat for protected dormice and bat species in addition to many other animals including deer.



Any proposed development such as this one which would significantly increase the current use by various schools and sports clubs and would have an overall detrimental effect on this locality.



The tranquillity of this rural area would be hugely damaged. For those living in the vicinity, their lives would be significantly affected by noise, traffic and lighting. For the landscape and the wildlife, this development would be very intrusive.



The AONB landscape is a precious asset for us all and not just those living in this area. Should such intrusion be allowed then it would be only a matter of time before more development would be proposed and this, of course, would be easier to justify. Therefore this proposal must be rejected and the AONB should be protected as much as possible. An Environmental Impact Assessment would demonstrate the extent of intrusion. Such a study should be carried out by an independent and impartial body before any decision is made.



As it stands, the benefits of the proposal do not outweigh the loss to our public landscape. On this basis, I strongly object to the proposal.

Comment submitted date: Mon 29 Jun 2020

I wish to submit an addition to my previous comments in which I have objected to the proposed development at Urnfield.



The site is either within or immediately on the border of an Area of Outstanding Natural Beauty. I have checked the government website for information on AONB's and wish to add the following comments.



Under the Countryside and Rights of Way Act 2000, it appears that the local authority has a responsibility to consider the potential effect of the proposed development within the AONB and on land outside its boundary. It would also seem that Natural England should be consulted for proposed developments in an AONB.



AONB's were set up to protect the land to conserve and enhance its natural beauty. The Urnfield application is to enable the intensification of use of the existing sports facilities and with this in mind the criteria for assessing an AONB should be carefully considered. These criteria are as follows:

- Landscape quality

- Scenic quality

- Relative wildness

- Relative tranquillity

- Natural heritage features

- Cultural heritage



There are only 34 AONB's in England so that makes the application for this site very sensitive. The UK is under constant development pressure and therefore the value of AONB's increases all the time as examples of natural British landscape.



The Roman burial ground mentioned by other people in their comments would come within the criterion of Cultural heritage.



The adjoining woodlands with their protected species (dormice and bats are protected by law) should come within the criteria of relative wildness and relative tranquillity. The wildlife would be adversely affected if noise levels, artificial light levels and the intensity of use were to increase significantly. On the matter of wildlife, Surrey Wildlife Trust would probably have strong views about the negative effect on certain animal species, especially the bats which can become confused by artificial night-time lighting.

Comment submitted date: Thu 28 Jan 2021

There has been a significant increase in the number of walkers and runners on Merrow Downs since the start of the covid pandemic. People have discovered the delights of walking on the downs and through the ancient woodland leading up to Newlands Corner. I know, as a local resident, that this application would bring about a big increase in noise levels when the sports facilities are being used. At the moment, noise levels are very noticeable when football matches are held at Urn Field at the weekend. This would only increase with greater use and would detract from the atmosphere of this landscape. The sight of floodlights together with the noise levels would permanently detract from the quality of this part of the AONB and Area of Great Landscape Value. There really should be no need for weekend use. In addition, the flood lighting design needs very careful attention to detail in order to minimise any visual intrusion and light pollution. Any failure here would be extremely disappointing in view of the national importance of AONB's. I sincerely hope GBC will treat this issue with the importance it deserves.

Comment submitted date: Wed 07 Apr 2021

I wish to add the following to my previous comments of objection to application 20/P/00825.

Although I support sport as it has many benefits for all, I still object to the application by Tormead.

The creation of an artificial hockey pitch and running tracks and the floodlights are the main questionable issues of this application which do not demonstrate the exceptional need required to justify development in the AONB.

The Urnfield sports ground forming the edge of this part of the Surrey Hills AONB, is not an appropriate location for the development of an intensively used sports facility. An all weather hockey pitch and tracks with floodlighting would have to be used as much as possible in order to pay for the investment, hence the after school/evening sessions. It is therefore highly unlikely that its proposed use would be restricted to Tormead and County School to use only within normal school hours. This matter of use outside school hours should be carefully considered as it would significantly affect local residents in terms of road use, noise and general nuisance. It has also negative consequences on the wildlife.

The use of the Urnfield site during daytime is not an issue but the proposal for floodlighting, even though the applicant has reduced the height of the floodlights from 15m down to 13m, should be abandoned and sport played during daytime light only.

The development proposal has to be put into the context of the designated Area of Outstanding Natural Beauty for Surrey Hills. It would appear that it is a point which Hockey England does not take into consideration regarding the floodlighting. The protection of an AONB is a planning matter to be taken seriously. The AONB exists in perpetuity for the protection of high quality natural landscape while also allowing for public access for passive recreation. Under the Countryside and Rights of Way Act 2000 local authorities have "a permissive power to take action to conserve and enhance the natural beauty of the AONB's in their areas". I do not believe that the interests of the applicant outweigh the aims of an AONB. The Surrey Hills AONB is one of a small number of AONB's dispersed throughout England and Wales and it needs to be protected.

As a local resident who walks daily on Merrow Downs, I can confirm that many people, and not just locals, come to walk on the Downs and enjoy the landscape and the peacefulness of the outdoors.

The proposals could be more environmentally friendly if the proposal for floodlighting is abandoned and a grass hockey pitch is constructed instead of an all weather surface. A grass playing field surface would be considerably more friendly for insect life than an artificial surface with high specification lighting and would ensure minimal disturbance to the wildlife in this area.

The Campaign for the Protection of Rural England (CPRE) has recently been on the national news commenting on the reduced light pollution during lockdown. The proposed floodlights at Urnfield would only add to light pollution on Merrow Downs and also allow an unwanted visual urban element to creep into and detract from the natural beauty of this area.

I therefore object to the floodlight and all weather surfacing proposals of this application and urge Guildford Borough Council to respect the AONB designation and protect the Surrey Hills AONB in their area. Furthermore, it would be welcome if the applicant could also respect the AONB designation and agree to retract the floodlight/artificial pitch from their application. I am sure they would expect to see unspoilt AONB's whenever they visit other parts of the country.

Mr A Atkinson (Objects)

Comment submitted date: Wed 10 Feb 2021

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Comment submitted date: Tue 06 Apr 2021

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Mr Trevor Brook (Objects)

Comment submitted date: Thu 04 Jun 2020

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Comment submitted date: Tue 26 Jan 2021

This is in addition to my sightlines study and objection of 4th June 2020.



Neither the shameful contribution by an employee of Sport England encouraging breaking national planning rules nor any of the submissions from school parents offer the necessary exceptional justification needed for approval of sport lighting in a Green Belt and AONB, where NPPF require the highest level of protection of landscape and scenic beauty (Guildford Policy P1 section 3).



To avoid further damaging our depleted wildlife, any lighting in this well established "high commuting and foraging" bat area at post-sunset peak feeding times must be of a colour temperature of 2,700 Kelvin or lower. Notwithstanding lights on the building itself, sport lighting (typically 5,000K plus) situated in the fields is clearly ruled out.



With underused facilities nearby, another sports field with lighting in this elevated location would be wrong in so many ways.

Comment submitted date: Tue 30 Mar 2021

This responds to the revised lighting plans of 23 March 2021. I still object to the application.



The concept of "floodlit artificial hockey" is fundamentally flawed at a bat habitat site since no sport lighting could ever use the required 2,700 degrees or lower lighting colour temperature required in a bat habitat.



Apart from artificial surfaces removing a large expanse of insect-friendly grass habitat bounding woodland, higher colour temperature luminaires fatally disrupt both bats and the very insects which bats need for their survival.



Neither grass nor artificial surfaces are black bodies, which means that a high proportion of light from the 30,000 Watt installation impinging on the ground of the "main pitch" and "spillage" areas is reflected upwards, in direct conflict with dark skies policies.



For a sense of scale, 30,000 Watts of LED lighting at 4,000 degrees Kelvin is roughly a thousand times more intense than a bright workshop lamp, tolerable at the town site of County School, A31 Farnham Road, (E4 zone: Urban - High district brightness Town/city centres with high levels of night-time activity) but not on the very summit of the North Downs AONB.



Andrew Poplett of Signify/Philips Lighting claims his design meets ILP guidance for E2 zone (E2 Rural - Low district brightness Village or relatively dark outer suburban locations). This is clearly insufficient for Urn Field which is E1 zone (E1 Natural - Intrinsically dark National Parks, Areas of Outstanding Natural Beauty etc.) demanding SQM (Sky Quality Measurements) of 15 to 20.



Whether painted Moss Green or not, these proposals can never approach the exceptional requirements for development in an AONB.

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an Idox solution

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