Flooding Report

Flooding Report & Comment on the Applicants Flood Risk Analysis

Planning Application No. 12/P/01973

Land South of Ash Lodge Drive, Ash

Author: Mr. Anthony Pugh
Consultant Engineer

Topography of area

The area proposed for the development consists of a number of fields which form the bottom of a valley and has a low point of 72.5m above sea level. It is bordered to the north by residential properties, which are built on land rising to an elevation of 85m over a distance of 400m, and rising further to 118m just north of Ash Hill Road. To the south, the land is bordered directly by a disused railway line banking which is over 2m higher than the proposed development area. The land on the other side of the railway banking then rises over a distance of 1500m to the Hogs Back A31 road, which reaches to over 130m. To the east, the land rises gently to 85m over a distance of 1000m, and to the west the land is bordered by Manor Road and Ash Manor School which is at an elevation of 77-79m. The proposed development is therefore surrounded by higher land apart from a small area to the north-west corner which opens to the lowest point in Manor Road.

Soil type

The soil is predominantly London clay to a depth in excess of 2.5 metres and therefore very poor for drainage. Water collects and remains on the surface for weeks due to the impermeable nature of the ground.

Rainfall Rates

The standard rainfall rates, for this area, for calculating drainage requirements are as table 1

Table 1

Storm EventRain mm/hr 100 year return periodRain mm/hr 100 year return period + 30%
15 min winter 97 126
30 min winter 64 83
60 min winter 40 52
120 min winter 25 32
180 min winter 18.5 24
240 min winter 14.6 19


The railway embankment at the southern border is penetrated by an 18" transit pipe, which allows the surface water from the higher land to the south to pass under the embankment into the development areas main drainage watercourse, and then into culvert A14/1 which connects into the main storm drain. This then conveys the water into the River Blackwater just north of the A331/A323 junction. The size of this watercourse is approximately 2m wide x 1m deep.

Another much smaller watercourse borders the west of the land and travels south to north, eventually connecting into the drainage system near Manor Road. Another watercourse runs east to west joining the main ditch into the main storm water drain adjacent to Avon Close. These watercourses have bunds of between 200 - 400mm high formed by the soil excavated during the digging of the ditch and so the fields do not drain naturally into the ditches.

Occurrence of Flooding

The area is noted for flooding during periods of high rainfall and there are Guildford Borough Council records showing more extensive flooding on a number of occasions, most recently in 2000, 2006, 2007 & 2008. The Capita Symonds report, commissioned by Guildford Borough Council and dated January 2009, shows total flooding of the area right up to the southern border of the railway embankment, in 2000 and 2006. Following this report serious flooding occurred again in July 2007 and August 2008 when properties in Southlands Close, Southlands Road, Lea Close, Wandle Close, Loddon Way, and Colne Way, and Ash Lodge Drive were flooded.

The fields, as they stand, prevented far more extensive flooding to the local properties as they acted as a floodplain, allowing thousands of cubic metres of water to flood the fields before the water rises to the level of the properties mentioned. The writer's property escaped flooding by 25 mm (just below the doorstep) although the garage was flooded to a depth of 125mm.

The field area floods often, particularly during the autumn/winter period, and large lakes form in the fields which are then populated by geese and Mallard ducks.

Due to the low drainage capability of the soil, the area was classified in the Surrey County Council flooding assessment of 2011 as an area subject to surface water flooding.

Reasons for flooding


To illustrate the effects of surface water flooding, a storm rainfall rate for 1 hour of 24 mm has been shown. Records for 20th July 2007 show that 110 mm fell in 24 hours with a peak of 24mm in 1 hour.

Flooding from the north

During heavy rain storms, rivers of water from the Ash Street and Ash Church Road area flow rapidly downhill through residents’ gardens, down roads and alleyways towards the fields. Water bursts up through drain covers, out of road drains, and raw sewage is also thrust up into the torrent of water. The storm drain is rapidly overwhelmed, and so the water flows to the lowest point which is the fields south of Ash Lodge Drive and Loddon Way. Once the fields are flooded the water then continues to rise and starts flooding the homes. An estimation of the quantity of water arriving from this direction could be as much as 8,400 m3 per hour for a rainfall of only 24mm/hr. The 100year+30% rate of 52mm/hr would see around 18,200 m3 per hour crossing Ash Lodge Drive and Loddon Way into the fields.

View from Ash Street looking down the slope of Ash Lodge Drive towards the development site (behind the houses facing). Storm water rushes down this and other adjacent roads in torrents to flood the site.

Particularly bad is Ash Church Road which rises to a high point near St Peter’s Church and then descends to Ash railway station.

For example on Monday 11th October 2012 at 09.00 the writer was travelling to Woking for a meeting with Woking Borough Council. It was raining fairly heavily but not storm conditions. Considerable flooding was noted in Ash Street outside the police station, and as the writer travelled up Ash Church Road there were torrents of water gushing out of the drains. Rivers of water were running down each side of the road towards the junction with Grange Road and round into Ash Street by the police station. Passing over the brow of the hill by St Peters Church there was a similar situation with the water gushing out of the drains forming rivers running down both sides of the road towards the Ash railway station crossing.

The police station yard has indeed been flooded on a number of occasions and in one particularly bad event in 2006, the flow south from Ash Street, through the yard, was so great that after bursting through the rear fence of the police station yard, the floodwater then flowed rapidly across the properties in Southlands Close and eventually adding to the flooding in Southlands Road. Such was the ferocity of the flow that some properties in Southlands Close suffered under-floor damage to their suspended floors, which included electrical cabling being torn out. One owner still has the invoices for the repairs necessary totalling well over £1,000.

Southlands Road – South Ash (July 2007) – houses on the right all flooded internally

Southlands Road near Lea Close– South Ash (July 2007)

Map showing water courses and main directions of flooding into development site.

Map showing main areas of flooding following a storm event

Flooding from the South

The high ground to the south of the proposed development area has the potential to shed huge quantities of water during heavy rain storms. The water is bunded by the railway embankment, causing the southern side of the embankment to flood and the water rises rapidly in the area near the 18" transit pipe to depths often up to 1.5 metres.

Water from Hogs Back starting to flood fields bunded by disused railway embankment. – (1.2m deep near the embankment) - This picture April 2012 but it is a regular occurrence. This is the area to be used as the Bewley Homes SANG

The transit pipe acts as a restriction orifice and allows water through at a rate of approximately 3600m3/hr, depending on the head of water at the pipe entry. The writer has noted on many occasions the northern exit of this pipe completely flooded to a height of 300-400 mm above the top of the pipe. On some occasions it rises so high that it reaches the bottom step of the adjacent stile.

Northern exit of transit pipe (top of pipe submerged) – picture taken April 2012

The water flows rapidly along the large watercourse towards culvert A14/1. Approximately half way along it reaches a soil bridge area between 2 fields which is penetrated by 2 x 12 " pipes. These cannot cope with the flow and the water floods out of the ditch and into the fields. The water also floods over the top of the bridge area into the downstream side of the watercourse. This water flows at an alarming rate (in excess of the EA recommended maximum) and the bridge area cannot be safely crossed to get from one field to the other.

Water has overwhelmed twin 12” transit pipes and is now rapidly flowing across soil bridge. – picture taken April 2012 (similar pictures are available for January 2012 and December 2012)

The volume of water then travels rapidly along the open watercourse, and then enters culvert A14/1 and then into the storm drain which copes in normal rainfall conditions. However, as previously noted, in heavy storm conditions the Ash Lodge Drive storm drain is unable to cope with the water from the residential area north of the fields, and so flow into the drain is blocked (and may even reverse). The water in culvert A14/1 cannot then enter the storm drain and the level rapidly rises adding to the flooding in the fields, and also to the rear gardens, garages and drives of the properties on the south side of Ash Lodge Drive. It should be noted that this flow through the transit pipe continues for many days after the rain has stopped, due to the large volume of water held back by the bund effect of the railway embankment. Releasing this water at a greater rate would inevitably cause flooding downstream both locally and in the Blackwater floodplain between Tongham and Frimley Green.

Water flowing towards A14/1 – This water course is fast flowing, deep with steep sides and would be a source of considerable danger of drowning to children and adults.

Flooding of garden from excess flow into culvert A14/1

Flooding from the West

The greater part of Manor Road and Ash Manor School is also between 2 and 5m higher than the development fields and surface water also floods down into the area during storm conditions. The watercourse bordering the western side of the field is narrow and shallow and rapidly fills, allowing water to then flood into the field.

Greenfield Runoff Rates

The developer has recognised that this area is subject to extensive flooding, as he has proposed raising the development site by at least 300mm in an attempt to provide some protection to the new homes.

There are however serious problems with the Flood Risk Assessment and also several of the documents cross referring to this.

Firstly the developer has used the desk based calculation on the highly inaccurate IH124 procedure to obtain a Greenfield runoff figure. The IH 124 Report is dedicated to small catchment hydrology but nevertheless its formula for QBAR, which is in widespread use for SUDS applications, is based on data of 71 catchments < 25 km2, only one of which is

The fields are low lying and have lips around the perimeter of each field between 200 – 400mm high mainly caused by the soil dug to form the watercourses being heaped along the side. Also the root structure of the trees and hedgerows has caused considerable raising of the perimeters, so each field resembles a tray. There is therefore virtually no surface water runoff from any of the fields. Bewley Homes own soil infiltration tests have also shown there to be no measurable infiltration so the only way flood water levels reduce is by evaporation. This is born out by the fact that after a period of rain the fields remain in a state of flood for months.

View along Footpath 350 (watercourse behind hedgerow) note raised bank and no runoff.

View alongside field adjoining Ash Lodge Drive note raised bank and no runoff. FP350 underwater in foreground.

View alongside field adjoining Ash Manor School (watercourse to right) note raised bank and no runoff

The existing greenfield runoff figures (desk based calculation) of between 44 and 48% claimed in section 5.11 table 2 of the developer’s FRA are simply absurd. The true value is probably around 1%. Having studied the runoff in all accessible fields during a period of rain, one can find only 2 places where any actual runoff occurs. One is at the junction of FP349 and FP351, where a deep pond area discharges a trickle through a very small gulley into a ditch. This has been scraped in the soil in a futile attempt to keep FP349 passable , which is still 200mm deep in water The other is halfway along FP351, where another very small gulley 100mm wide drains a small puddle area into another ditch at a very low trickle rate.

The QBAR figures therefore claimed in the developer’s FRA are totally invalid.

Junction of FP349 and 351. FP349 is under water, note yellow GBC notice of planning application in background – picture taken 20/12/2012

This gross overstating of the existing greenfield runoff renders their whole flood risk assessment worthless.

It would require a depth of flooding of at least 200mm in the fields before any surface water runoff into the watercourses occurred. As there is virtually no greenfield runoff on the undeveloped site any runoff from the new development would be a net gain into the surface water drains causing an increase in the flood risk to the River Blackwater and the existing properties in Ash Lodge Drive, Loddon Way, Southlands Road and Colne Way.

View back across field from FP349. – FP351 is on the raised portion to the left – picture taken 20/12/2012

Aerial view from Bing maps of typical flooding after some rain. Ash Lodge Drive is at bottom of picture.

River Blackwater Flooding

Telemetry values (from over 9000 points) supplied by the EA for Tongham and Farnborough monitoring stations show that the River Blackwater floods with flows exceeding 1.25m3/sec. This affects properties along the floodplain from Tongham to Frimley both in Hampshire and in Surrey. The FRA in 4.12 agrees that the flooding occurs on the River Blackwater on a frequent basis.

From records provided by the Environment Agency the most recent flood alerts that were issued for the River Blackwater were at 22.48 on 22/11/2012 and again at 23.06 on 14/12/2012. The closest to a full flood in 2012 occurred at 13.30 on 28/04/2012 when the Tongham telemetry was showing only millimetres below the critical level for flooding.

Tongham metering station chart for the River Blackwater on 28/04/2012

Transit of water from fields to the River Blackwater

The storm drain into which the culvert A14/1 connects, travels a distance of 650m west and discharges into the river Blackwater at a point some 100 yards north of the A331/A323 road junction, by the Holder trading estate. The pipe drops in height 4.5m over that distance and flow is by gravity. It is impossible to carry out a full hydraulic analysis without full details of all the entries and pipe diameters, but it is evident from past occurrences that this drain is inadequate, as evidenced by the water flowing out of the drains into the roads and residents properties during a heavy storm. Note also that the throughput capability of the pipe will diminish as the water level in the river rises due to the increase in discharge head.

Flooding of other areas from the River Blackwater

The river is narrow and shallow and floods easily, particularly in the area adjoining Lakeside Road and the housing adjacent to the river between Tongham and Frimley Green. The large volume of water currently discharged into the river has on a number of occasions caused serious flooding of properties in and around Lakeside Road and further downstream. Reports by Guildford Borough Council indicate at least 20 properties on the last occasion (ref Guildford SFRA Capita Symonds CS20946 Appendix G-3).

In early 2009 Michael Gove wrote to Thames Water expressing his concern that the improvements carried out to the downstream River Blackwater route had done nothing to alleviate the serious flooding problem at Lakeside. Basically too much water enters the river upstream and the shallow route is overwhelmed by the volume and flooding occurs.

Effects of draining the surface water from the fields into the river

Note the Environment Agency records its flow values in m3/sec so previous m3/hr values have been divided by 3600 for uniformity.

The River Blackwater has a number of monitoring points along its route designed to give early warning of flooding to residents and businesses. The two local monitoring points are at Tongham and at Farnborough.

As stated earlier the developer’s FRA claims that the existing greenfield runoff figures (desk based calculation) are between 44 and 48% (claimed in section 5.11 table 2 of the developer’s FRA). This represents at the 100 year return period rate a total of 8,851m3/hr (2.46m3/sec) being runoff (at 48% runoff) from the total 46.1ha site in 1 hour.

To illustrate the effect of disposing of this additional water, telemetry values from both stations have kindly been provided by the Environment Agency for 15 minute intervals for the July 2007 period. These are available to view on a separate spreadsheet.

Tongham gauging station has a normal level for the river of 0.56 – 1.45 metres above which flooding is likely. (Highest was 1.79 on 20th July 2007).

Farnborough gauging station has a normal level for the river of 0.36 – 1.30 metres above which flooding is likely. (Highest was 1.94 on 14th August 2006).

From the telemetry data for 20th July 2007 it shows that the flow rate at Farnborough at the start of flooding was 1.25m3/sec at 09.45 am with a peak of 2.26m3/sec being reached.

The telemetry shows that an increase of flow during the initial flooding stage from 1.3m3/sec to 2.23m3/sec caused an increase in level of 0.32metres at Farnborough and 0.34 metres at Tongham.

Thus an increase in flow of only 0.93m3/sec caused an increase of the flood depth of over 300mm.

The developers claimed runoff of 2.46m3/sec can now clearly be seen to be false as this rate by itself is virtually double the River Blackwater critical flowrate, without taking into account all the other flows into the river from the Thames Water surface water drainage system.

Existing Surface Water Drain System based on Thames Water Drg 5136-1

The existing surface water drainage system consists of a 1,220 mm dia main drain, fed from a series of smaller diameter pipes. There is a second main drain of 900 mm dia which joins into the 1,220 mm dia drain along Ash Lodge Drive at Avon Close. The 1,220 mm dia drain then continues on its route to the Blackwater taking in further smaller diameter feeds on the way.

Culvert A14/1 joins the 1,220 mm drain at a point near manhole hole 1151 conveying the surface water from the Hogs Back area. It has been noted that this large 1,200mm x 800mm feed has been omitted from the Thames Water Waste water drawing 5136-1

In fact there are at least 4 water courses that enter this 1,220 drain system that are not shown on this drawing. Thames Water do not therefore take these figures into their calculations.

An assessment has been carried out to calculate how much water is carried in each main pipe during varying levels of rainfall.

Each area that feeds into the drains has been assessed based on the following basis:

Percentage amount of rainfall transferred to drains

Road and pavement surfacesRoofs and garage areasDrives and flagged areasGrassy Runoffs Class 4 Soil
100% 100% 100% 50%

Note that the 50% surface water value from the grassy runoff will rapidly increase to saturation excess (100%) due to the impermeable nature of the clay. Calculations for this study however have been based on 50%.

The areas calculated for each drain are as follows. (Note that the park area that slopes down from Ash Church Road to Collins Gardens has been included as this water runs down into the Collins Gardens drains).

Main Drain 1,220mm dia Areas in metres2

Road and pavement surfacesRoofs and garage areasDrives and flagged areasGrassy Runoffs x 50%Total
32,750 50,720 48,600 40,696 172,766

Secondary Drain 900mm dia Areas in metres2

Road and pavement surfacesRoofs and garage areasDrives and flagged areasGrassy Runoffs x 50%Total
16,700 21,160 22,300 25,940 86,100

The detail calculations for the above values are available on an Excel spreadsheet.

Based on the above results it is possible to calculate the flow via the drains into the River Blackwater resulting from various rates of rainfall.

As previously stated culvert A14/1 enters the main drain approximately halfway along Ash Lodge Drive. The culvert carries water from a ditch that drains the large amount of water that is held back by the natural bund formed by the disused railway embankment. The flow is fairly constant at 3600m3/hr (1m3/s). The table below therefore include a constant value add-in of 1m3/s for all the 1,220 pipe values from 20mm/hr upwards. A lower value of 0.5m3/s has been included in the 10mm/hr flow rate as this rainfall rate does not usually result in a full culvert.

Table of flow against rainfall

Flow rate in 1,200mm m3/s 0.98 1.96 2.44 2.92 3.40
Flow rate in 900mm m3/s 0.24 0.48 0.72 0.96 1.20
Combined flow after junction 1.22 2.44 3.16 3.88 4.60

The system is rapidly overwhelmed by rainfall in excess of 20mm/hr. This is confirmed during the torrential rain of August 2008 when a 30 minute rate of approximately 40mm/hr was noted with subsequent flooding of properties.

From the values noted in the flooding study the River Blackwater can take a flow of up to 1.25m3/s before flooding occurs. It can be seen from this table that the combined flow from these pipes could cause the river to flood at even the 20mm/hr rainfall rate.

What actually happens is that much of the excess surface flood water flows in torrents into the fields to the south of Ash Lodge Drive which serves as a flood plain thus saving many properties from flooding. Residents in the area will confirm the large volumes of water that sweep across their gardens and into the fields.

These fields have been 100% flooded right across to the disused railway embankment on a number of occasions, the extent being included in the Capita Symons report of January 2009 commissioned by GBC. Partial flooding occurs every year.

The continued allowing of new developments by GBC in the locality has steadily made the flooding worse. Areas that were natural flood plains have been turned over to developers with the consequential loss of natural water holding capacity and the inevitable increase of more surface water into the drains thus increasing the flood risk locally, and in areas of Surrey, Hampshire and Berkshire along the River Blackwater. Recent developments have included, Bateman Grove (20 homes), Parish Close (61 homes), Oaktrees (45 homes), Collins Gardens (13 homes), Queen Elizabeth Close (10 homes) and The Briars (53 homes). A total of 202 homes that have been added to this area.

The proposal to build on this land is not feasible even with the most sophisticated SUDS system as not only will it take away the flood plain facility, it has been shown that the development would add substantially to an already unacceptable flow into the River Blackwater causing flooding in Hampshire and as far as Frimley.

Omission of flows into the surface Water Drainage System

Due to the concern over the omission of a number of substantial flow inputs into the Thames Water drainage system shown on drawing 5136-1 an enquiry was sent to Thames Water to clarify the situation.

Extract from enquiry to Thames Water 14/02/2012

"I have been asked to contact you by Ash Residents Association with respect to the assessment of storm drain capacities and current applications for development in this area.

Because the area floods frequently and also because of the critical situation with the capacity of the River Blackwater (into which the local drains flow) I was asked to do a drains study. It is evident from past occurrences in 2007 and 2008 that the storm drains concerned have insufficient capacity during periods of very heavy rain, with storm water coming up out of the drains and raw sewage floating on top.

Having compiled the inputs and expected flows into the storm drains I have noticed that a number of inputs into the drains are not shown. One in particular that causes concern is GBC culvert A14/1 which enters the 1,220mm drain beneath Ash Lodge Drive at a point near manhole 1151. This culvert is 1,200mm x 800mm and carries flow from the region of the Hogs Back. Flow is held back by a natural bund but the water is allowed though a restricting pipe at a rate of up to 1m3/sec. Because of the large quantity of water held back by the bund this flow continues, for many days at that rate, following a storm.

"The reason I am given for their omission, is that these inputs are unadopted."

"Are the flows from these unadopted inputs taken into account when calculating the capacity of the storm drains? I am particularly concerned with the flows in the 1,220mm pipe and the 900mm pipe which run parallel with Ash Lodge Drive and join at Avon Close near manhole 9051. The drains are already capable of putting more into the River Blackwater than it can handle and hence the several recent floodings of properties alongside its course."

Response from Thames Water 23/02/2012

Extracts from Thames Water reply:

"I have to admit to having very little knowledge of the catchment to which you refer and I have had to consult with our catchment planning team for their take on the queries you raise."

" It is common that private or unadopted assets are not show on the Map of Sewers. Where we have sufficient data we represent them as unadopted sewers, but we often do not have correct location and asset data in order to map them."

"Thames Water completes various levels of hydraulic assessments on the public sewer networks under its control. This is dependant on the size of the sewer, the proposed increase in capacity as well as issues that have affected our existing customers in the vicinity (i.e. reported flooding events). In many cases we expect developers to fund investigations that we undertake to determine the impact of their proposals on the existing sewer system, as well as to identify any infrastructure enhancements that could be implemented to mitigate against a deterioration in the performance of the sewer system due to proposed development. We have not recently undertaken any detailed modeling assessments in the area of Ash that you are interested in."

"As this is a surface water system, there will be rainfall events that will exceed the design capacity of any surface water sewer system and the hydraulic capacity of the local watercourse. This has the potential to flood the surface water outfall and thereby restrict the hydraulic capacity of the public sewer system."

Comments on reply from Thames Water

It is intimated from Thames Water Authority reply that they do not have sufficient data on the unadopted inlets to enable them to carry out any detailed modeling of the area we are concerned with, and would expect the developer to fund such investigations. It is evident from recent applications for development in the area that the Flood Risk Analysis carried out by the consultants contains none of this data - the consultants are probably totally unaware of the existing drains structure and in particular the high flow rate from A14/1. In consequence the whole process and subsequent planning approvals would be based on highly flawed information.

Raising the Site Level by 300mm

The developer has recognised that this area is subject to extensive flooding, as he has proposed raising the development site by at least 300mm to attempt to provide some protection to the new homes.

The developer has also proposed a flood relief channel, quote “To minimise the flood risk of the culverts on the northern boundary of the Site a flood relief channel is proposed, near to the northern boundary. The developer has managed to quote 3 different sizes for this channel in 3 different documents.

Design and Access Statement : size:- 3.5m wide with no depth or side slope.
Environmental Statement: size:- 4.0m wide x 0.75m deep with 1 in 2 side slope.
Flood Risk Assessment: size:- 4.0m wide x 0.75m deep with 1 in 4 side slope – a mathematical impossibility.

Taking the largest case, the total capacity of this channel along the northern boundary is less than 1,000m3. This would fill within 7 minutes with the floodwater from Ash Lodge Drive/Loddon Way and in possibly only 3 minutes with the 100 year +30% event.

If the developer raises the site level by at least 300mm the surface flooding from the north would not be able to overflow into the fields and properties along Ash Lodge Drive, Kennet Close, Loddon Way, Colne Way, Lea Close, Wandle Close, Southlands Close and Southlands Road will be extensively flooded. This is in direct contravention of the requirements of NPPF TG clause 2 which states that any development must not increase the flood risk elsewhere.

Raising the development site by 300mm would actually raise most of the site to a higher level than Ash Lodge Drive and Loddon Way. Using the developers topography survey the addition of 300mm would mean the site would be 200mm higher near Loddon Way, 50mm higher near the entrance to FP350 and 40mm higher near the Beverley Close end. This is a sure recipe for increasing the flood risk, and existing properties along Ash Lodge Drive, Kennet Close, Loddon Way, Colne Way, Lea Close, Wandle Close, Southlands Close and Southlands Road will be extensively flooded.

Depending on the rainfall it is likely that an additional 100 existing residential properties would be subject to internal flooding as a direct result of raising this development site by 300mm. Note that in all the flooding incidents so far the rainfall has only been a fraction of the 100year +30% event.

Flooding from the North (Ash Lodge Drive has overflowed into field parcel 1)

Another view of Ash Lodge Drive overflow into field

Other Causes of Flooding

Immediately to the south of the proposed development area there are a series of underground main water pipes of up to 14" in diameter belonging to South East Water. These pipes are buried direct in clay and are mainly concrete coated steel. There have been 6 ruptures within the last 4 years of which 4 caused extensive flooding of the fields. The 2 minor ruptures were alongside the disused railway embankment whilst the 4 serious rupture were all in Ash Green Lane West, 2 of which were adjacent to the corner of Ash Manor School playing fields. A long section of damaged (split open) 14" pipe lies nearby as evidence.

One of these pipes burst again at 2pm on 4th January 2012 flooding a large portion of the field adjacent to Ash Manor School playing fields.

Records of Flooding

Serious flooding occurred in Ash in Sept 1968, February 1990, October 1993, November 2000, August 2006 and July 2007. Flooding also took place at Ash Green in November 2000, and October 2006. The source for this information is Guildford Borough Council’s SFRA of January 2009. Further extensive flooding of the development area and houses to the north occurred in August 2008.

There is also record of flooding in June 1981 and August 1981,. 16th June 1999. and 7th July 2001

It is essential that the proposed development is not permitted to proceed as the value of this land in holding back floodwater cannot be under-estimated in its ability to prevent further residents property being flooded.

Summary of Key Points

  1. The Developer has failed to recognise the serious surface water flooding from the north of parcel 1, caused by the rapid overwhelming of the storm drains in heavy rainfall conditions.
  2. The Developer’s Flood Risk Assessment has grossly overstated the Greenfield runoff rate and has thus rendered information in that document invalid.
  3. The raising of the site by 300mm will block the escape of surface water flooding from the north and greatly increase the flood risk to existing properties.
  4. The application to use the field labelled Cardinal Field, south of the disused railway line as a SANG is totally unsuitable as this field acts as a functional floodplain for a series of watercourses from the south and east. As a result it rapidly floods many times a year to depths up to 1.5m and should be classed as zone 3b.
  5. The Developer’s site survey has failed to appreciate the topography of the fields in parcel 1 with their raised borders preventing Greenfield runoff.
  6. As virtually no pre-development water from parcel 1 currently enters the storm drains, the Developer cannot be allowed to put post development water into the storm drains as it would all be a net gain into the system and accelerate flooding of the River Blackwater. This would affect properties from Tongham to Frimley Green in both Guildford and Rushmoor Boroughs.
  7. The watercourse running south to north alongside FP350 is deep and can flow very fast and would be a source of considerable danger of drowning to children and adults

Documents related to flooding in the area

    1. "Surrey County Council’s Flooding and Wet-spots" lists Southlands Road – Ref GUI094 as a flood area.

    2. Guildford Borough Council’s SFRA dated Jan 2009
      Vol 1 Page 11 – "The most intensive urbanised areas are Guildford and Ash – here any further development could potentially increase surface water.

      Vol 2 Para 3.15 "Sandbag requests in 2006 were concentrated of to the west of the study area in particular around Ash Green, Ash and Ash Vale which have recorded problems with surface water runoff.

      Vol 2 Para 6.27 "There are however some areas of moderate to high development intensity within Flood Zone 3, most notably an area through Guildford town centre and through Ash and Ash Vale. The suitability of redevelopment within these areas will require careful consideration given the potentially high risk of flooding".

      Vol 2 Para 12.3 "Surface water and sewer flooding have been considered using recorded incidents of flooding provided by the EA and GBC. There are some notable “hot spots” for surface water flooding, primarily in Ash, Ash Vale and Pirbright. Areas of the catchment underlain by clay geology and clay soils are more likely to be impacted by surface water flooding however maintenance of existing small watercourses and structures such as safety screens and culverts has an important influence on local flooding mechanisms".

      Guildford SFRA Appendix G: Other sources of flooding Drawing Nos CS20946/Appendix G-3 and G-7 showing the extent of flooding covering the proposed development area.

      Local Government Planning Policy Statement 25 – Stating the considerations and requirements of both developers and planning authorities with respect to "Development and Flood Risk"

    3. Core Strategy Policy CP7 WATER MANAGEMENT extract:
      “New development on undeveloped flood plains will be avoided. Development on land at risk from flooding will only be permitted where it can be demonstrated that it will not impede the flow of floodwaters, increase the risk of flooding elsewhere or reduce the capacity of a floodplain.” ……………
      “The disposal of surface water from new development to public sewers will not be permitted.”

    4. National Planning Policy Framework TG
      As set out in the National Planning Policy Framework, inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at highest risk, but where development is necessary, making it safe without increasing flood risk elsewhere

Reference Documents:-

Capita Symonds – Guildford Strategic Flood Risk Assessment / January 2009 (for Guildford Borough Council)

Surrey County Council - List of Wet-spots in Surrey / March 2011

Attached Documents:-

Environmental Agency Telemetry Values Spread-sheet / January 201

Circulation List

Tara Taylor, Case Officer, GBC Planning Department

GBC Planning Committee 

Michael Gove, MP

Nick Sutcliffe, Local Councillor

Environment Agency

Thames Water

South East Water

Surrey County Council Highways     

Surrey Wildlife Trust

John Edwards, SCC Countryside Management & Biodiversity Manager  

Campaign for the Protection of Rural England    

Rushmoor Borough Council (Ref: 12/00928/ADJ)  

Ash Parish Council

Tongham Parish Council

Ash Green Residents Association      

Ashley Bowes, Solicitor 

James Watkins, Trinity Mirror        

ASHRA's Response

Letter of Objection

Planning Application No. 12/P/01973

Land South of Ash Lodge Drive, Ash

Ash Residents Association would like to register this letter of objection to the captioned Planning Application on behalf of the thousands of Residents of the villages of Ash and Tongham. The feeling of anger and frustration in the area, against this Application, is palpable as was demonstrated to Bewley Homes/a2dominion when they held their Consultation Events on 11th November 2011 and 14th July 2012. Over 1,400 angry residents went to these events to voice their opinion, and have signed the enclosed petition against this development.

Our objections fall into several categories and are detailed at the top of the page

Countryside & Community Identity

The land in question is particularly sensitive to development pressure, but it prevents coalescence between Ash, Ash Green and Tongham.  Allowing this development would effectively join three villages together, with subsequent loss of identity, and destroy the remaining attractive countryside in the area that should be protected. Wherever one goes in Ash, Ash Green or Tongham one gets a sense that each village, although incorporating new building over the years, still retains its own identity and friendly atmosphere.

To allow this Planning Application would, regardless of the countryside, remove this sense of identity in the communities. It would also go against one of the aims of the Government according to the National Planning Policy Framework (NPPF), in that they want to “prevent neighbouring towns merging into one another”.

In addition the proposal would form an undesirable and unnecessary intrusion of residential development into the peaceful countryside which would, if permitted, detract from the visual and rural amenities of the area. Views of open green space will be lost forever for hundreds of local residents and visitors alike, and from such sensitive places as the Hogs Back, which is already designated as an area of outstanding natural beauty. Also for the public using the disused railway line and bridle path (which is under a conservation order as country walks and cycle ways) will be rendered worthless if bordered by houses.

The NPPF states that Planning policies and decisions should aim to identify and protect areas of tranquillity which have remained relatively undisturbed by noise and are prized for their recreational and amenity value for this reason.

The building of hundreds of homes will mean the destruction of scarce, undisturbed wetland habitat, and any attempt at draining the land will reduce the water table and kill off the mature Oak trees which have shallow roots.

The unusual ancient double hedgerows which provide cover for large mammals, even if retained, will be unattractive to the species they support. There are also a large number of Oak Trees of between 160 and 200 years of age, and mature Ash and Maple trees around these fields which need to be protected. In addition we will see the destruction of bog land supporting rare grasses and plants.

The maintenance of the “Sites of Nature Conservation Interest” would be surrounded by housing, again making them unattractive to the species they support, and increased pollution and low hanging ozone in the valley area, which is already a problem in periods of long calm weather.

Inevitable defacement by rubbish, and damage to flora along the conserved railway line and bridal paths due to encroaching human habitation, will surely follow.

Sustainable Development

“Sustainable Development” is a term that most people don’t understand. It is bandied around by builders in the hope of giving their destruction of our countryside, some sort of acceptability and legitimacy, and making the listener think they are all for the “Green” environment. In fact the Governments definition of Sustainable Development, according to the NPPF, is “Sustainable means ensuring that better lives for ourselves, don’t mean worse lives for future generations”, and “Development means growth”. They clarify this by saying “Sustainable Development is about positive growth – making economic, environmental and social progress for this and future generations”. They say that it must improve the places in which we live our lives. The Government also state in the NPPF that planning should be a collective enterprise, including people and communities, and they are, by the use of the NPPF “allowing people and communities back into planning”.

The NPPF goes on to state that pursuing sustainable development involves seeking positive improvements in the natural environment as well as in peoples’ quality of life. Sustainable Development should make it easier for jobs to be created in the area, achieve gains for nature, and improve conditions in which people live.

We would argue that taking away the only large piece of natural space left in the area, and the building of 400 houses on it, is not going to improve the lives of the people of Ash and Tongham, or visitors to the area, nor will it improve the lives of future generations. We also argue that this development does not make economic, environmental or social progress. It will in no way improve the economy of the area and it will certainly damage the environment.

In addition the NPPF goes on to say that existing open space should not be built on unless the loss resulting from the proposed development would be replaced by equivalent or better provision in terms of quantity and quality in a suitable location. 99.9% of the residents of Ash and Tongham feel that losing a vast area of natural open space, including all of the wildlife and trees, the joining of these villages, and the increased congestion and flooding, in exchange for a small area with cycle tracks is not a fair exchange.

Global Warming

The current situation with climate change means that some winters will result in far less rainfall than normal, and in others the rainfall will be far in excess of levels we have seen in the past. Over the last two winters, 2010/2011 & 2011/2012 we have had dramatically less rainfall than average according to the Metrological Office. A drought being declared in the south east of England.

However, when it does rain, the volumes are extreme and flooding occurs in many areas. It only takes one day of heavy rainfall to flood the fields to the rear of Ash Lodge Drive, and this persists and worsens as more run-off water is received from the north and from the south of the area, as detailed in our separate flood report.

The NPPF clearly states in one of its core principles of planning that “they should support the transition to a low carbon future in a changing climate, taking full account of flood risk.


See Separate Flooding Report.

Historical records show that in the year 976 Ash was spelt Aesc meaning ‘at the ash tree’. The village of Ash grew up on an area of London Clay, and was part of the flood plain of the Blackwater River. Although the land was unsuitable for agriculture, it was important because it provided grazing for villagers’ livestock. The church of St. Peter’s stands raised above the village on a small mound of gravel on the London Clay. This is the reason that South Ash is so prone to flooding, as the fields to the rear of Ash Lodge Drive and Loddon way form the lowest point in Ash.

This area of Ash is included in the Surrey Flood Risk Strategy, as an area at risk from surface water flooding. It says a few developed areas are at high risk from flooding, notably areas of Guildford town centre on both banks of the River Wey, parts of Ash within the Blackwater Valley and some properties in villages along the Tillingbourne. Climate change is expected to cause an increase in peak river flows over the next 50-100 years and may result in some areas being at greater risk of flooding in the future. It goes on to say that with regard to surface water flooding, a large proportion of the Borough is currently undeveloped and so in those areas the surface water is unchanged from Greenfield rates. The most intensive urbanised areas are within Guildford and Ash; here any further development could increase surface water.

The developer has added to his original scope a group of existing fields for use as SANGS (Suitable Accessible Green Space).  The areas stated fail to fully meet the requirements of the site quality checklist for SANGS.  The existing fields (parcel 1) are within easy walking distance for the majority of existing residents.


In fact, the existing fields in Parcel 1 were described in the Environment Agencies letter of 30th May 2012 to Ash Residents Association as a SANG, quote:


“The risk that proposed development (12/P/00645) will flood from this watercourse is reduced by the fact that the land alongside the watercourse is designated a SANG.”


Access to the existing fields, based on a walking distance of 400 metres from any public footpath entrance, is currently available to approximately 600 homes and 3 schools which represents over 2,000 people.


The proposed new SANGS are well beyond the 400m limit for most of the existing residents (despite the developer claiming they are not) and should therefore be provided with adequate parking for visitors.  Measured distances from developers own application maps are typically 750m walking distance (not as crow flies) from the NW corner of this development to SANG main entry point (closest) and 650m from the northern end of FP350 (within the site) to the SANG main entry point.  In fact, of the houses shown on the new development plan, only about 50% of the new homes are within 400m walking distance of the SANG entrance. For any of the existing residents using the fields currently within 400m walking distance, many will have distances of at least 1 km to reach this SANG area.  None of the proposed SANGS fields are currently accessible by car and thus have no parking.


The developer, in his application, has used the centre of his site to draw a 400m radius circle to just include the entrance to the SANG as his justification for complying with the 400m rule.  This method still means that 50% of the new dwellings have more than 400m to walk to the SANG.  (If this method were used with the existing fields it would include most of South Ash and Tongham and would encompass 5,000 people having access to the existing fields.)


This SANG proposal takes away the benefit of a suitable accessible natural green space for over 2,000 people for the benefit of possibly as few as 580 people, (or 5,000 for the benefit of 1,000 if the developers method of SANG compliance were used.)


Also in the text of the developers application is a proposal to allow grazing in the fields (clauses 5.3.1 and 5.3.8 in the SANGS Management Plan).  There is no way you can guarantee that a dog off a lead will not worry or attack any livestock (including horses).

It should also be noted that one of the fields marked for SANG (Cardinal Fields) is the collecting point for a number of fast flowing watercourses from the Hogs Back, Ash Green and Poyle Road and is regularly under a considerable depth of floodwater (over 1.2m deep in places) which is totally unsuitable for a SANG, and makes it very difficult to walk and ride along the footpaths.  This area is a functional flood plain and should probably be rated zone 3b per the NPPF TG standard.

Aspect Ecology state that 24ha of land will form the SANG, with the remaining capacity available as mitigation for future development. This explains why they also state that the SANG will remain under the ownership of Bewley Homes who will manage it. The proposed large SANG area is therefore not so much to do with the Thames Basin SPA, or for the benefit of residents, but more to do with making more profit.

Barton Willmore. Environmental Statement, in their Non-technical Summary 10.2 state that "The site is at risk of surface water flooding during extreme events". This shows how very little these “experts” know about the land in question. These fields, especially the low lying ones to the north of the site, are under water for most of every winter.

It’s amazing to think that Thames Valley Archaeological Services on behalf of Bewley Homes, in their Desk based Heritage Assessment, when talking about potential archaeology on the site, state that "It is unlikely that waterlogged remains would be encountered, rather any deposits present can be expected to be typical of dryland locations"

Card Geotechnics Limited. Geo-Environmental Interpretative Report states that 12 boreholes were dug in October 2011 and no Groundwater was encountered. According to DEFRA, between September 2011 and December 2011 we were in the worst drought in Surrey for more than 30 years. Didn’t someone at Card Geotechnics think of this. If they tried to dig boreholes between May 2012 and March 2013, they wouldn't find the surface of the land through the water.

Card Geotechnics Limited. Geo-Environmental Interpretative Report also states that infiltration tests were undertaken in test pits dug between 2.5 and 2.7 mtrs., however due to the low permeability of the ground, the test were abandoned. Surely this must tell everyone that this land is not suitable for building on. Because of the clay and the flooding potential, it is unlikely that the new houses will be insurable, not only from the risk of flooding but also from subsidence. Also the increased risk of flooding to houses in the area in Ash Lodge Drive, Loddon Way, South Lane, Southlands Road, Southlands Close, The Briars, Avon Close, Wandle Close, Kennet Close is a serious one and, if this building goes ahead, could increase their insurance premiums or make their homes uninsurable.

The most ridiculous statement of all comes from Card Geotechnics Limited, once again in its Geo environmental Interpretative Report. It states that “shallow excavations are likely to remain stable in the short term. Groundwater is unlikely to be encountered within excavations on site”. This is an unbelievable statement, and this in itself shows how completely incompetent and complacent these people are. They obviously learned very little about the site, the topology and the potential for flooding. They have been given a brief by Bewley Homes and are willing to ignore warning signs.

The NPPF states that Local Plans should take account of climate change over the longer term, including factors such as flood risk, coastal change, water supply and changes to biodiversity and landscape. New development should be planned to avoid increased vulnerability to the range of impacts arising from climate change. It goes on to say that inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at highest risk, but where development is necessary, making it safe without increasing flood risk elsewhere. Local Plans should be supported by Strategic Flood Risk Assessment and develop policies to manage flood risk from all sources, taking account of advice from the Environment Agency and other relevant flood risk management bodies, such as lead local flood authorities and internal drainage boards.


The current provision of hospitals, doctor’s surgeries, public transport, infants & junior schools is insufficient to service a development of this scale.

The Stuart Michael Associates Limited Transport Assessment states that “the proposed development may include a community facility, possibly a doctors' surgery or local convenience store”. “May” being the important word here. The same wording was used when the Outline Planning Application was approved by Guildford Borough Council for the Quadrant in Ash Vale. Nothing was ultimately provided.


The local hospital is Frimley Park. This hospital is running at capacity and a visit to Accident & Emergency can be an “all-day” outing. Other hospitals have been closed down or made more specialised resulting in a huge dependence on Frimley Park Hospital for many services. In the rush hours or at visiting times negotiating Frimley town to get to the Hospital can be an extremely slow and frustrating journey as the surrounding road infrastructure cannot cope with the volumes of traffic. Car parking in the hospital is totally insufficient to cope with the number of patients and visitors and just to get into the Hospital car park, one can be in a queue of traffic going almost back to the town centre.

Doctors Surgeries

This is maybe the area where the proposed developers and their “professional” consultants, have deliberately tried to mislead everyone.

Although each Planning Application has to be examined on its own merits and evidence presented, it has not gone unnoticed that within one mile of this new application, another 4 applications have either recently been approved or are under consideration by GBC, totalling 172 dwellings.

All have been vigorously contested by the people who live in the local area. A common theme to all the objections has been the detrimental effect to the character of the area, the increased demands on local health and education resources, drainage and traffic issues. All these objections are particularly relevant to this new application.

The assertion in the Barton Willmore Non Technical Summary 12.3 is that “The Proposed Development will provide up to 400 residential units with a mix of sizes and types of dwellings providing accommodation for up to 940 people by completion. This will contribute to housing needs established by planning policy resulting in a minor beneficial effect. There will be negligible effects to population, education, health care and libraries”.

Their conclusion is drawn from their Environmental Statement:

14.72 Within 1km of the Application Site there is one GP Practice. The Border Practice is located within Aldershot, within the administrative area of Hampshire PCT (see Figure 14.5). It caters for a total of 8,624 patients and has five GPs (Ref 14.11). This results in a GP to patient ratio of 1:1705. The average GP to patient ratio across England is 1:1561. In comparison there are currently 66 GP Practices within Surrey and 39 across Hampshire that operate with higher GP to patient ratios than the Border Practice.

14.7 The Ash Vale Health Centre is the second nearest GP Surgery to the Application Site; it is located 1.6km from the Application Site. The surgery is part of a larger practice, the Frimley Green Practice. Whilst not being within the 1km search radius defined within Approaching Urban Design: The Design Process (Ref 14.7) consultation with the practice has confirmed that they do accept patients from the Ash and Tongham Area. The Surgery has a total of 17 GPs and 27,355 Patients, resulting in a GP to patient ratio of 1:1609.

We have examined the source data, and found inaccuracies in the developers’ conclusions, which are detailed below (DEVELOPER VIEW). (We have been unable to find the source data pertaining to regional etc. ratios to check them for accuracy.)

With regard to the Border Practice, there are only 4 GPs (confirmed by the Practice web site) and 8,526 patients, whilst the Ash Vale Practice has 10 GPs (one female GP has been double counted), with a claimed 15,500 patients (the balance assumed to be Frimley Green based). (REALITY)

Applying the Developers own methodology that the 400 dwellings will generate 940 new people/patients, a further 376 new people/patients will be generated from the 160 dwellings under sanction, totalling 1,316. Not all will gravitate to the Border practice, but assuming an arbitrary split of 2/3rds 1/3rd the illustrative effect is shown in the right hand columns, headed PROJECTED TOTALS.

 Developer ViewRealityProjected Totals
Border 5 8,624 1.725 4 8,526 2.132 4 8,526 878 9,404 2.351
Ash Vale 17 27,355 1.609 10 15,500 1.550 10 15,500 438 15,938 1.594
Totals 22 35,979 1.635 14 24,026 1.716 14 24,026 1,316 25,342 1.810

An altogether different picture, which we would suggest is NOT negligible.

As previously mentioned the Environmental Statement says “Consultation with the Practice Manager of Ash Vale Health Centre has confirmed that they do accept patients from Ash Vale & Tongham”. This really gives the impression to the reader that they have had meetings with this Centre, and all has been resolved.

However, the Practice Manager has stated in writing that, "We did have a short meeting and nothing was concluded. The developers’ proposals only went as far as potentially allocating a plot of land that the surgery would have to purchase and develop / fund. There is no appetite from this end to go down this route and we've not done or heard of anything else since. We did confirm that the Health Centre at present could not accommodate more patients."

Ash and Tongham are within 2 miles of Aldershot, where a significant demographic shift is occurring, with the arrival of Gurkha immigrants (who are already spilling over into Ash, Tongham and Farnborough). Rushmoor Borough Council have estimated around 10,000 people of Nepalese origin live in the area; the official population of the council area is just over 90,000. This group has an unusual demographic, with large proportions of older people and children. This has increased pressure on social, health and education services (over 7 per cent of school children have Nepali as their first language). There remain approximately 25,000 additional retired Gurkha’s eligible to apply for settlement in the UK.
Source https://www.gov.uk/government/news/1-5-million-fund-to-help-the-gurkha-community-settle-in-the-uk announcement 15 Nov 2011

Additionally 4,500 new dwellings are earmarked to be built on former army land, less than 3 kms away; the extra 11,500 inhabitants will all add to pressure on the local infrastructure... doctors surgeries, hospitals, schools, the already inadequate local road networks, water supplies etc, which when aggregated with this application, make a mockery of conclusions drawn from the statistical models presented by the developer, showing the “negligible effects” of this application, 12/P/01973.

In summary, there needs to be a much more detailed and searching examination than hitherto, to any development in this part of GBC. Ash and Tongham have more in common with Aldershot and Hampshire than they have with Guildford and Surrey. This is recognised by the South East plan (SEP) 2009 which defined the western part of the Borough covering Ash and Tongham within the ‘Western Corridor Blackwater Valley (WCBV)’ sub-region and the remainder of the borough in the ‘London Fringe’, with differential new homes targets in each. GBC have subsequently been allowed to aggregate the new homes demands of the SEP and in the absence of any formulated Local Plan, are now seemingly proceeding to burden WCBV with an unsustainable proportion, to the detriment of local inhabitants, both of the here and now, and the future.

It is heartening to see that Rushmoor and Waverley councils have been included in the current list of Consultees, but as they were not consulted about the 172 dwellings under sanction in the 4 earlier applications, they will be unaware of the whole picture.

In the meantime we would suggest a moratorium be called on all developments approved and under approval in the WCBV, until a 'joined up' strategic plan is formulated for this part of Surrey, embracing Aldershot, Ash and Tongham. Including taking into account the terrible flooding issues in the area.


Barton Willmore’s Environmental Statement under Table 14.8 shows a table of Primary/Junior Schools. It shows that there is no availability of places in all schools except Ash Grange, where it shows 136 places available. Ash Walsh Infants and Junior Schools are over-subscribed together with St. Paul’s School in Tongham.

The reason that Ash Grange is the exception is that it has just recently come out of OFSTED special measures. According to the latest OFSTED inspectors report at the end of 2012, pupils come from a diverse range of backgrounds but a high proportion come from socially disadvantaged homes. Around half the pupils are from families of, mostly settled, travellers.

Table 14.11 purports to show Secondary School available places. These numbers cannot be validated as Barton Willmore's quoted source website is non-existent. However, we do know that the figure of 23 available places for Ash Manor is dubious as the Ash Manor School website says they are over-subscribed.

An objection letter has been placed on the GBC Website against this Planning Application which was written by an ex-Govenor of Ash Manor School and a person who is currently sitting on the appeals panels for the Surrey Schools Admission Appeals Service, and as such is aware of which Surrey schools are oversubscribed. He highlights that lack of capacity of Ash Manor School to accept further pupils, and the inability to expand the site of the school in the future to create additional outdoor playing field areas, if the development of 400 houses is approved. He says that if the proposed development is approved, the Ash Manor School site will be almost completely surrounded with developed land, with no future possibility of extending the site. The outside playing field area is less than that provided at many secondary schools with a similar number of pupils. He goes on to say that when the school was created in 1986 from the merger of Yeomans Bridge School (formerly on this site) and the Robert Haining School at Mytchett, which was closed, the pupil numbers were around 500-600. Part of the school site was sold for housing development (the area which is now Bateman Grove), a decision which many now realise was somewhat short sighted, as the school has since expanded and many additional buildings have been added to cope with the current pupil numbers of around 1100. The previous Head-teacher of Ash Manor School (Mr R M Linnell, who was in post from 1992 until 2009) had said the decision to sell the land for Bateman Grove is now regretted. He also said that he and the Governors wanted to extend the school playing fields into part of Parcel 1 of proposed development land, and there were funds available for the land purchase at the then current valuations. The owner of land was unwilling to sell the land to the school. Playing fields for outdoor sports and physical education activities are an important part of the school curriculum.

He says there is now no opportunity to expand the school playing fields on to the land to the south of Ash Green Lane West, following the recent approval for 60 houses on this site (Planning ref: 12/P/00645). If more houses are built in the area there will be increased demand for places at what is now an oversubscribed 1,100 pupil school, but there will be no opportunity in the future to expand the site of the school. The demand for secondary school spaces in Ash and in neighbouring Aldershot (Rushmoor) will increase due to current and future house building. Project Connaught in the Aldershot military town area will see several thousand new houses built, for which no additional secondary schools are planned. This alone will increase demand on spaces at Ash Manor School, as more children from the Aldershot area seek places at this school. There is already a significant number of Aldershot pupils who attend Ash Manor School, as it is the nearest school for many Aldershot children. The admission policy of Ash Manor School does not have a defined catchment area (neither do most other Surrey schools), and straight line distance from the child’s home to the school is one of the criteria used in the decisions to offer places. It is not possible under previous legal judgments to use county or district council boundaries as the criteria for defining a school’s catchment area, if one applies.

He finishes by saying that as Ash Manor School is already full and at its published admission number for places, it is unable to admit additional pupils except by successful appeals. Any additional pupils from Ash and the surrounding area will have to go to schools elsewhere, where places are available. Currently within Surrey, the nearest schools with available places are at either Kings College at Park Barn, Guildford or Broadwater School at Farncombe, near Godalming. There are no direct buses from Ash to either of these schools, and it is likely that pupils going to these schools will be taken to and from school by parents in their cars, adding to traffic congestion on local roads and the main roads towards Guildford. Therefore approval of 400 additional houses on this site would create problems in accommodating the children from the new houses at Ash Manor School, the only secondary school in Ash, and I would ask that the Planning Committee reject the plans.


Stuart Michael Associates - Design & Access Statement states that “Employment opportunities are located west of the A331 in the Aldershot Industrial Park. Further opportunities are also located in central Aldershot”. This is absolutely not true. There are almost no opportunities for employment in the Aldershot area, and because of the recent intake of over 10,000 Nepalese, who are willing to work for very little, the jobs market is stagnant. This can be confirmed by Rushmoor Borough Council. In addition, the Planning Application has recently been approved by Rushmoor BC to build over 4,000 new homes in Aldershot within 3 km of Ash. This is going to put tremendous strain on the employment situation within a 15 – 20 km radius. The writers daughter has been looking for a job for a considerable time, and she has been told by the Job Centre that there are up to 50 applicants going after every job in Aldershot and the surrounding areas.


Huge Traffic jams are a twice daily occurrence on many local roads and outside local schools. In the morning rush-hour Manor Road, Ash Street and other roads are congested for hours towards Aldershot and towards Guildford. In the afternoon “school run” period there are cars parked the length of Manor Road, and in the many side roads including Ash Lodge Drive, which inhibits the traffic flow on the main bus route along Manor Road. This also makes the situation extremely dangerous for pedestrians including the children entering and exiting Ash Manor School. In addition, when there are any traffic problems on the A31 Hogs Back or the A331 Blackwater Valley Relief Road, which are a regular feature, especially in the winter months, then all of this traffic diverts though Tongham and Ash creating total gridlock.

Ash Lodge Drive (which only has one access from the east and one from the west) is already used as a “high speed rat run” during peak hours by traffic trying to avoid the congestion in Ash Street and Manor Road. The additional volumes of traffic from this proposed development will exasperate the situation and the siting of an additional proposed junction at the western end of Ash Lodge Drive will massively increase the risk to pedestrians/children.  

There will also be vastly increased traffic through The Street in Tongham, which, in the rush hour, is already heavy. The village centre includes listed buildings and local shops, so widening of the road to alleviate the congestion is not possible.

In their Transport Assessment, Stuart Michael Associates Limited state that, “from comments raised in the public meetings, Stuart Michael had noted that traffic through Tongham was occasionally impeded due to on-street parking”. This is absolutely not true. What they were told was traffic through Tongham is at a standstill in the morning and afternoon due to the volume of traffic trying to get to and from the Hog’s Back.

Other ridiculous comments made by Stuart Michael Associates are:

  • Ash Lodge Drive, Loddon Way & Southlands Road are quiet residential roads suitable for a route from the site to shops etc. The reality is this route is already a rat-run for traffic avoiding the gridlock in Ash Street.
  • Ash Church Road experiences periodic queues in relation to the level crossing. Once again in reality between the hours of 07:00 and 08:45 the traffic can be at a standstill as far back as the Greyhound Roundabout in Ash, some 2km

The most ridiculous statement of all in their Transport Assessment was in point 3.56 wherein they detail alternative routes that will be available to site residents and also other local residents. They also say that if three alternative routes are used, there will be no impact on traffic at the level crossing. They seem to think that the local people in Ash and Tongham are Neanderthals and didn’t already know these routes existed. If the first route, Grange Road/Foreman Road/Ash Green Road/Harpers Road is used, it is extremely difficult to get out onto the Guildford Road, and you may as well wait for the railway crossing barrier. The second route suggested, via Wyke Lane is usually under water in the winter from adjacent fields at more than one point, therefore not a good option. The third suggested route is so far out of the way it's just not feasible.

The NPPF states that encouragement should be given to solutions which support reductions in greenhouse gas emissions and reduce traffic congestion. We think that putting around 800 additional cars in the middle of an already congested area rather flies in the face of the NPPF.

According to the NPPF, plans should take account of whether improvements can be undertaken within the transport network that cost effectively limit the significant impacts of the development. This is obviously not the case.

Once again it should also be noted that in neighbouring Hampshire, less than 3 kms away from this proposed site, Rushmoor Borough Council have approved planning for more than 4,000 houses to be built as part of the Aldershot Urban Extension. This is the first phase of the sell-off of Ministry of Defence land and is expected, in the next 20 years, to increase Aldershot’s population by 25%. This will add massive pressure to the A331 the A31 and more importantly to Ash Street. A large proportion of the traffic from this development wanting to access Guildford will pass through Ash. The traffic trying to get onto the A3 at the eastern end of the A31 Hogs Back, tails back some 5 km on a regular basis.

Rushmoor Borough Council have objected to this Planning Application because the proposal involves development that cannot be reconciled with the NPPF in that it has not been demonstrated that the significant movements generated could be accommodated adequately on the existing local and strategic transport network within Hampshire/Surrey. It would also result in a severe impact on the road safety and operation of the local transport network contrary to the NPPF.

Stuart Michael Associates Limited Transport Assessment 3.83 states that the traffic surveys were carried out during school terms. This is absolutely not true. The first traffic survey was done in August 2011. Several residents approached the people counting cars and asked what they we doing. They were told it was a traffic survey for the future Bewley Homes site. This was the first we knew about the new Bewley Homes proposals, when we knew about the survey.

Barton Willmore’s Environmental Statement says “The additional traffic flows generated onto Ash Lodge Drive and Manor Road are within the daily variation of traffic flows and therefore have not been assessed as part of the cumulative impact assessment”. It is very strange that although they put a traffic sensor across Ash Lodge Drive in the exact position of the proposed access road to the site, no data has been used anywhere in the Planning Application from this sensor.

Under their travel plan people will take far less trips by car, but rather use bicycles or walk. In fact In the Stuart Michael Associates Transport Assessment it states that it is generally accepted that trips of up to 2km and 5km can reasonably be undertaken on foot. What a wonderful picture is painted. Ash and Tongham are sleepy towns in the backwoods of leafy Surrey, where the people are so happy that everywhere is concrete and they can walk or cycle for miles to the shops and to work every day. There are no cars to worry about, so nobody ever gets run over and we have the best road safety record in the country………..this is also the opposite of the conclusion in the Guildford Local Plan Sustainability Appraisal Scoping Report where in figure 7.1 it shows that almost 60% use their car to travel to work as opposed to less than 4% using a cycle.

Also, the Traffic Assessment is just a waste of 25 pages of the report for the following reasons:

  • the busy times on the roads in locations outside London are between 07:00 and 08:00. So to base all of the figures around the times of 08:00 to 09:00 is deliberately misleading
  • mysteriously no measurements are included from the traffic sensor installed on Ash Lodge Drive, (the most important point)
  • it assumes a bus service through the site, which is dubious to say the least
  • the prediction that most of the people on the site will use their cycles and not cars
  • it does not take into account the potential traffic generated from the 4,000 houses being built in Hampshire within 3 kms.

Stuart Michael Associates - Design & Access Statement Table 22.1 Indicative Development Programme shows what Bewley Homes expect us to believe regarding the pace of their building programme, in that this is a five year project. This of course is based on the wildly optimistic notion that they will sell every house as it is finished. Whereas, in reality, houses are not selling, and it is unlikely that the situation will change in the next five years. A more realistic timetable would be ten years, and therefore the people of Ash, Ash Green and Tongham can look forward to ten years of noise, ten years of additional traffic problems due to lorries, 10 years of thick mud for miles along the roads because they are trying to build on a bog.

Their proposed main access to the Proposed Development during construction will be via Ash Lodge Drive. Hundreds of heavy lorries going in and out of a busy junction with Manor Road, close to the entrance to one of the largest schools in the Borough. In addition this junction is already disintegrating through lack of maintenance, and heavy lorries will make it impassable for cars. Of course, conveniently, they are not able to identify how many lorries will be coming and going from the site each day according to Barton Willmore.

They also state in Point 9.82 "Application Site traffic will be signposted to avoid unsuitable areas wherever possible, routes will be signed, there will be no waiting on the network and disruption will be kept to a minimum. Where in two villages with narrow roads can you avoid unsuitable areas. Anyone who believes this must be gullible.

There are proposed improvements to the Greyhound roundabout. All this appears to do is widen the entrance to the roundabout when approaching from Manor Road. How this will improve the current traffic issues is questionable, the issue is with traffic volumes from Manor Road not being able to join the roundabout due to the amount of traffic coming from Ash Street, two lanes entering from Manor Road will make little difference.

The proposals for the access road to the new site at Ash Lodge Drive will make for a dangerous corner given the lack of sight lines into the rest of Ash Lodge Drive when leaving the new development. Ash Lodge Drive is already used as a rat run, the extra cars will make it worse for all.

Surrey CC guidelines (Surrey Design – A Strategic guide for quality built environments) state:

3.4.2 There is a tendency for drivers to stop in a position that obstructs vehicles turning right into the non-priority road at ‘T’ junctions which are not formed at right angles. At priority junctions therefore, roads should meet nearly at right angles (within 10° of 90°) unless the non-priority road serves more than 100 dwellings in which case the roads should meet at 90°.
In such circumstances, the non-priority road should be straight for twice the length of the junction radius.

In this case the non-priority road is the rest of Ash Lodge Drive and is straight for the length of the junction radius not twice the length as recommended.

Again from the guidelines

3.4.3 Junction spacing is not restricted where traffic speed is less than 20mph and roads serve less than 100 dwellings subject to adequate visibility to maintain safety. Roads serving between 100 and 300 dwellings should have a junction spacing of at least 30 metres, on either side of the priority road.

In the design plans the distance between Ash Lodge Drive (remaining) and Avon Close is clearly much less than 30 meters.

Access to the South Lane entrance is already problematic. Traffic coming from the Greyhound roundabout has to negotiate a right turn on a blind left hand bend, and then a sharp right into South Lane. South Lane is already narrow and used as a rat run for traffic using Ash Lodge Drive. Adding the extra traffic will lead to more accidents. This will only be compounded if the move of the Co-Op store to the old Police Station is approved due to increased parking in the road and traffic entering / leaving the new store.


Barton Willmore’s Environmental Statement says that “The position of the primary route was explored in order to facilitate the circulation of buses through the site. The primary route forms the main spine through the site connecting Ash Lodge Drive in the northwest with South Lane in the northeast”. They confirm that it will be 6 mtrs wide.

They go on to say that Ash Lodge Drive is 6.2 mtrs wide and the minimum width of the road with bus traffic is 6 mtrs. Their Transport Assessment states that the main intention of their design is to promote a Community Travel Plan (what a lovely “green” expression) to reduce car use originating from the new housing, and potentially from other households in the wider community. Therefore they want to put more cycles on the road.

In the real world Ash Lodge Drive varies between 6 mtrs and 6.1 mtrs wide, not the stated 6.2 metres. The Department of Transport recommend that where buses and cycles use the same road, the lanes should be 4.25 metres wide (8.5 mtr road width) and the minimum preferred width is 4m (8 mtr roadwidth); this allows buses to overtake cyclists safely and reduces the likelihood of interference from general traffic in the adjacent lane. The absolute minimum width is 3 metres (6 mtr road width).

The Surrey County Council website states that for a cyclist to be safely overtaken, the width required depends upon the width of the overtaking vehicle but in general a lane width of 4m is needed. For widths of between 3 and 4m the cyclist will be 'squeezed'.

A bus identical to that on the Route 20 from Guildford to Aldershot is 2.5 mtrs wide without wing mirrors. Therefore, for two buses to pass without hitting each other, the road must be at least 6 mtrs, but that doesn't allow for overtaking cyclists, of which (according to Bewley Homes Ecological Transport Policy), there will ideally be hundreds.

The following points should be considered when judging whether it a feasible to get buses down Ash Lodge Drive, and indeed down the new “Primary Route” which is also going to be 6 metres wide.

  • What is going to happen to the cars that park in Ash Lodge Drive, outside residents' houses. Are they going to be told to sell their cars
  • How will the buses turn into Ash Lodge Drive when there are cars queuing to get out onto Manor Road, which there are from 06:45 to 08:45 every day, and at school times
  • There is a pumping station within 9 mtrs of the end of Ash Lodge Drive at its junction with Manor Road. When this is being serviced or maintained by Thames Water, there are huge Thames Water lorries parked at the end of Ash Lodge Drive, sometimes for days. Cars have difficulty getting passed, let alone buses. Also Virgin and BT have main junction boxes in Manor Road within 10 mtrs of the corner with Ash Lodge Drive. The same applies

We must say that Stuart Michael Associates Transport Assessment holds the record for the most “inaccuracies” in a few paragraphs.

  • 3.27 states the local buses go to Farnborough. This is not true.
  • 3.28 quotes distances to bus stops only from the absolute nearest point of the development, otherwise most of the houses will be outside of recommended walking distances.
  • 3.29 states that there are 6 bus routes service the site. This is not true. There are only two regular ones, and two very sporadic ones (A few buses per day each way that take massive detours). The remaining two are school buses for children. They also quote the times of the first and last bus against each route. These times are also incorrect as they have put in the times the route starts from a depot, and not the time of the first and last bus at the site.

Road Safety

Over 500 school children cross the junction at the western end of Ash Lodge Drive every day. If any additional intersection/junction is put in place, the dangers to them will be increased dramatically. Contrary to what Stuart Michael Associates stated in their Transport Assessment, in the latter half of 2012, two serious accidents involving children occurred in Manor Road, one at the junction with Ash Lodge Drive, having resulted in school children being treated in hospital for serious injuries. Adding another potential 800 cars per day to this junction could be catastrophic.

The letter from the Head of Ash Manor School to all parents, when a young boy was knocked down at the junction of Manor Road and Ash Lodge Drive in September 2012 and two air ambulances were scrambled, said "I would like to take this opportunity to remind all students to take care when crossing the roads around the school, which we know are very busy". Barton Willmore state that "it is concluded that, given the small amount of additional traffic which could potentially use the local highway network as a direct consequence of the proposed development, it is unlikely that road safety conditions will deteriorate. Barton Willmore obviously don't take school children into account.

In addition, any traffic exiting the new development via the proposed South Lane junction and wishing to travel towards Aldershot, accessing the A31 or the A331, would naturally travel down Grange Road to Ash Street. However, because Ash Street is congested from 07:00hrs to 08:30hrs, all of the traffic will turn left  before it reaches Grange Road, travel down Southlands Road and along Ash Lodge Drive. Ash Lodge Drive is, as already mentioned, a "rat-run" for traffic trying to avoid the gridlock in Ash Street, and this development will probably increase it three or four fold. It should be noted that this exact route (Southlands Road - Ash Lodge Drive) is the one taken by hundreds of school children every morning walking to school.

According to the NPPF plans should take account of whether safe and suitable access to the site can be achieved for all people. This is obviously not the case, and the first fatality at one of these junctions will no doubt be blamed on Guildford Borough Council.


As with any new large development, it goes without saying that the levels of crime will increase proportionately. Ash and Tongham are already the paupers when it comes to availability and response from the police whenever there are incidents. In fact in 2012 Ash Police Station was closed because of lack of funding. If there is any kind of incident in Ash or Tongham it is necessary to get police response from Guildford, and this can take an inordinate amount of time, especially on a Friday night or at weekends when the police are stretched dealing with events in Guildford.

The NPPF states that plans should create safe and accessible environments where crime and disorder, and the fear of crime, do not undermine quality of life or community cohesion. We suggest that building another 400 homes between already existing towns will certainly create the opposite effect.


Wildlife in, around and over this area is magnificent, even though the current development plans have instigated, and resulted in, many efforts to destroy or disrupt the natural habitat of so many animals.

Barton Willmore state in table 8.5 of their Environmental Statement that “no reptiles were found on the site during the survey”. Aspect Ecology Baseline Ecological Statement also states that they found no reptiles during their survey. This is very strange because, while they were carrying out the survey, one of the local residents who is a keen wildlife expert, spoke to the person carrying out the survey, and took her to see where the grass snakes and adders were. However, when these reports were published, those same grass snakes and adders were never found.

The residents of Ash and Tongham have been aware for the past 30 years + that there are a large number of bats roosting in some of the houses directly adjacent to the site, and also in the trees on the site. However, when reading the Planning Application and its various documents, there are a lot of contradictions when it comes to this protected animal. For instance in the Aspect Ecology Limited Baseline Ecological Assessment they state that the majority of the trees on the site are in good health. The trees provide a valuable habitat resource within the site. A number of trees exhibit features such as rot holes, cracks, splits, loose bark and Ivy cover, providing roosting opportunities for bats. They go on to say that certain trees are suitable for bat roosting, and they found 6 different types of bats which were mainly found near the tree lines on the site. They could not be certain if bats were roosting because their survey was carried out from ground level.

Bats are European Protected Species and as such it is an offence to deliberately disturb bats, or disturb bats while occupying a structure or place that is used for shelter or protection.

However, Barton Willmore, say in their Environmental Statement that “No bat roosts were identified within the site and as such, effects will be limited to commuting and foraging activity”. So they can tell from another companies report, from a survey carried out from the ground, that all six bat species found were not roosting but were only foraging and passing through. This is brilliant work.

Perhaps they should look at this photograph of a tree with several bat roosts in it. This was taken beside the main footpath on the site in August 2012.

They also state that the effects of 5 - 10 years of construction on the bats will be of "minor significance".

We are advised by residents that pipistrelle bats roost in No’s 2 and 3 Wandle Close, on the very edge of the site boundary. These have been visited by the Bat Conservation Trust. They say that other bats are extremely likely to be roosting in adjacent areas and fields.

Aspect Ecology Limited in their Baseline Ecological Assessment under Section 5.3.8 states that "Red listed" Cuckoo was recorded and "Amber listed" Kestrel and Nightingale.

If "red listed" birds were found, how can they, in Section 5.3.9 state that none of them were of any particular importance at a national level.

With regard to wildlife, Barton Willmore make some interesting comments in their Environmental Statements.

  • the branches of trees and shrubs. 107 doormouse nest tubes were deployed within the Application site, along the hedgerows, which were checked for evidence of use by doormice on a monthly basis. What actually happened in October 2011, after the boxes were inserted, was the land owner arranged to have the hedgerows decimated by a massive industrial hedge trimmer connected to a tractor, and consequently many of the boxes were damaged, and the mouse habitat was almost completely destroyed. As a consequence of this wanton destruction, Ash Residents Association asked GBC to put a Tree Preservation Order on the trees in order to stop further damage, which they did
  • Wildlife habitats to be retained will be fenced off to reduce disturbance effects from noise and lighting. And how are the bats, birds and mammals going to react to that
  • Under 6.3 they state that during demolition and construction there will be negligible residue effects on ecology and nature conservation. How can they build 400 houses with negligible effects on ecology and nature conservation? They are destroying a massive area of green-space and habitat

A well know local resident is a keen wildlife expert and he travels the fields daily. What follows are lists of the birds, mammals, reptiles and insects that he sees when walking the fields, footpaths and bridleways that criss-cross the area. Wildlife in area in the last 12 months (2012).


SpeciesQuantityPeriod viewed
Fox 1-2 Daily
Red Deer Up to 6 Almost daily
Shrew Numerous Daily Spring to Autumn
Vole Numerous Daily Spring to Autumn
Water Vole Occasional sightings Spring to Autumn
Grey Squirrel Numerous Daily
Field Mouse 1-2 Occasionally
Stoat (2 locations) 1-2 2-3 times/year
Weasel 1-2 2-3 times/year
Bat Noctule Numerous before dawn Daily Spring to Autumn
Bat Whiskered Numerous before dawn Daily Spring to Autumn
Bat Myotis Numerous before dawn Daily Spring to Autumn
Mole 4 locations Just the molehills


SpeciesQuantityPeriod viewed
Adder (2 locations) 1-2 During spring/summer
Slow Worm 1-2 Spring to Autumn
Grass Snake 1 (4 witnesses) 25/3/2012 at 15.20pm


SpeciesQuantityPeriod viewed
Canadian Geese Numerous Daily in flooded areas
Mallard Ducks 6-10 Spring in flooded areas. 4 breeding pairs sighted 23/04/2012 in flooded areas of centre field north of old railway track.
Red Kite 1 hunting above field Occasionally
Sparrow hawk 2-3 Daily
Kestrel 2-3 2-3 times/week
Buzzard 1 2-3 times/week
Tawny Owl 1 Before dawn occasionally
Wood Pigeon Numerous Daily
Magpie Numerous Daily
Carrion Crow Numerous Daily
Hooded Crow 5-6 Daily
Jay Numerous Daily
Starling 20-30 Daily spring to autumn
Cuckoo 2-3 Spring/summer
Wren Numerous Daily
Dunnock Groups of 30 - 50 Daily Spring/summer
House Sparrow 6-10 Daily
Long Tailed Tit Numerous Daily
Blue Tit 6-10 Daily
Great Tit 6-10 Daily
Marsh Tit 3-4 2-3 times/week
Bull Finch 1-2 2-3 times/week
Garden Warbler 1-2 Summer
Lesser Whitethroat 1-2 Summer
Chaffinch 1-2 Daily
Robin 5-7 Daily
Short Toed Tree Creeper 2 Occasionally
Green Woodpecker 4 - 5 Spring/summer
Black Woodpecker 2 Spring/summer
Great Spotted Woodpecker 3 - 4 Spring/summer
Lesser Spotted Woodpecker 2 Spring
Blackbird 10-15 Daily
Swallow 10-15 Spring/summer
Swift Numerous Spring/summer
Mistle Thrush 5-10 Daily
Song Thrush 3-5 Daily
Fieldfare 10-15 February
Nightjar 1 28 & 29 June 2012 06.45am
Hen Pheasant 1 08/02/2012
Cock Pheasant 1 23/04/2012
Pied wagtail 3-5 Spring to Autumn
Chiffchaff 3-5 Spring to Autumn
Skylark 5-10 Spring to Autumn
Yellowhammer Pair 19/04/2012
Jackdaw 1 05/08/2012 @ 17.53pm (photo)

The list includes a number of birds on the RSPB's Red List of endangered species. They are:

House Sparrow
Marsh Tit
Lesser Spotted Woodpecker
Song Thrush

The swallow is amber listed


SpeciesQuantityPeriod viewed
Azure Dragonfly 1-2 Late spring/summer
Emporer Dragonfly 1-2 Late spring/summer
Brown Hawker Dragonfly 10-20 Summer in fields
Common Blue Damselfly 1-2 Late spring/summer
Emerald Damselfly 1-2 Late spring/summer


SpeciesQuantityPeriod viewed
Red Admiral Numerous Late spring/summer (photo)
Peacock 2-5 Late spring/summer (photo)
Small Tortoiseshell 2-5 Late spring/summer
Painted Lady 2-5 Late spring/summer
Meadow Brown Numerous Late spring/summer (photo)
Large Skipper 2-5 Late spring/summer
Holly Blue 2-5 Late spring/summer
Common Blue Numerous Late spring/summer
Small Blue Numerous Late spring/summer The Small Blue is a Priority Species for conservation due to the continued loss of habitat and resulting drop in population.
Gate Keeper 2-5 Late spring/summer (photo)
Pearl-bordered Fritillary 2-5 Late spring/summer
Brimstone 2-5 Late spring/summer
Ringlet 2-5 Late spring/summer (photo)
Speckled Wood 2-5 Late spring/summer (photo)
Small Skipper 2-5 Late spring/summer (photo)
Essex Skipper 2-5 Late spring/summer
Comma 2-5 Late spring/summer (photo)
Orange Tip 2-5 Late spring/summer (12/05/12)
Brown Hairstreak 2-5 Summer (22/07/2012) photo
Wood White 2-5 Late spring/summer (29/06/12) Conservation priority high
Cinnabar Moth 1 29/06/2012

The pink, frayed flowers of Ragged-Robin are an increasingly rare sight in the wild. Human activity, including the drainage of land for agriculture, the loss of ponds through development and the removal of wet woods, has resulted in the disappearance of many of the UK's wetlands. The Wildlife Trusts are working closely with planners, developers and farmers to ensure our wetlands are protected.

Ragged-Robin – Picture taken in field adjacent to Ash Lodge Drive to the East

Trees & Hedgerows

The popularity of the area is well known, not only for local residents walking dogs, walkers, joggers and organised ramblers, but people drive to the area to use it in pursuit of many different leisure activities. Riders can be seen regularly exercising their horses, and teachers with groups of schoolchildren use the fields for nature and wildlife education.

Crisscrossed as it is with public footpaths and bridleways, it is the only major natural amenity left in Ash. The proposed development will destroy the existing hedgerow framework which must be protected.

As well as being appreciated by hundreds of walkers every day for countless decades, the trees are clearly visible from the Hogs Back (Surrey Hills), an Area of Outstanding Natural Beauty.

Barton Willmore state in their Environmental Statement, that “during construction, approximately 200 metres of existing hedgerows. tree belts will be removed. As identified in the tree survey, all trees to be removed have been assessed as low quality, and the hedgerow removal limited to poor hedgerow”. It is truly amazing how their design means only the poor quality hedgerows and trees need to be removed.

Contrary to Barton Willmore's comments that the hedgerow are of poor quality, Aspect Ecology state that “The hedgerows are considered to form an important habitat for a range of wildlife species including bats, birds, and invertebrates, and are of high ecological value at a local level”. Aspect Ecology go on to say that all of the hedgerows within the site consist of at least one woody UK native species covered by the UK Biodiversity Action Plan priority habitat description for hedgerows.

Ian Keen Limited in their Tree Survey state that several trees are, "Resource for woodpeckers", "Good resource for wildlife", "Potential resource for bats", and according to their report, they only recommend the removal of two trees from the actual proposed site. Ian Keen also say that "whilst the majority of trees upon the site are of little individual merit, collectively the make an important contribution to the visual amenity of the area and play host to a variety of wildlife.

This is amazing as Barton Willmore seem to be of the opinion, and would have us believe, that large numbers of the trees are dead or dying and subsequently can be removed.

Barton Willmore’s Environmental Statement, Non-technical Summary 4.10 states that a linear park is proposed, located at the heart of the Development, which accommodates the existing hedgerow/tree belt and creates a "green spine" through its centre. Children’s play spaces will be located within the park along with balancing ponds and an existing public footpath.

This linear park will run down the side of an extremely fast flowing and deep stream. Any child playing in or near this park would be in extreme danger.

Adjacent to this stream is where the “linear park” and “children play area” will be sited.

Forestry and Countryside

According to a Government requested independent report which published its findings in July 2012, the Government need to protect more countryside and plant additional trees to increase woodland. These findings are to be adopted by the Government.

As at 4th July 2012, Hampshire County Council have already announced 3 sites for additional planting of trees for the development of new woodland.

Barton Willmore’s Environmental Statement states that “the Application Site itself is dominated by species-poor grassland, considered to be of low ecological value”. In fact, the whole area covered by this Application was domiciled and SNCI in the 1990's. However, because there was a huge profit to be made by selling the land to builders, the owners ploughed the fields up in order to destroy (they hoped) any rare plants etc. However, because the owners have made little use of the land since, occasionally grassing the fields and once or twice planting rape, the rare plants are still evident.

Aspect Ecology Limited Baseline Ecological Assessment mentions by name many plants found in the field to the north east of the site. However, they fail to mention the Meadow Barley, Saxifrage & Sneezewort that are evident there. This could be because these rare species are the reason for the SNCI domicile on the area to the north west of the site.

Barton Willmore’s Environmental Statement, Non-technical Summary 6.4 talks about a range of potential effects being identified on habitats and fauna, and therefore potential for MINOR effects in relation to the Thames Basin Heaths SPA. In mitigation they plan on planting a few trees and shrubs. They are taking away a massive area of green space used by people enjoying the countryside and all sorts of wildlife, and in exchange planting some shrubs.

The National Planning Policy Framework

There are a number of points in the NPPF which need to be highlighted, because they enforce our concerns and belief that this proposed development would be a disaster for the area, is totally unnecessary and would do irreparable damage to what is a lovely natural enclave. Firstly it is stated in the 12 principals of NPPF Core Planning that planning should:

  • be genuinely plan-led, empowering local people to shape their surroundings, with succinct local and neighbourhood plans setting out a positive vision for the future of the area
  • not simply be about scrutiny, but instead be a creative exercise in finding ways to enhance and improve the places in which people live their lives
  • take account of the needs of the residential and business communities
  • take account of the different roles and character of different areas, promoting the vitality of our main urban areas protecting the Green Belts around them, recognising the intrinsic character and beauty of the countryside and supporting thriving rural communities within it
  • support the transition to a low carbon future in a changing climate, taking full account of flood risk
  • encourage the effective use of land by reusing land that has been previously developed
  • promote mixed use developments, recognising that some open land can perform many functions (such as for Wildlife, recreation, flood risk mitigation, carbon storage or food production)

Housing requirements and numbers

It is true that since 2007 the number of houses built in the Guildford Borough, including Ash & Tongham, has fallen below the level specified in the Local Development Framework. However, it is also the case that the whole building industry went into sharp decline at exactly the same time due to the world financial crisis, and not only have the number of completions fallen, but the number of Planning Application have fallen by the same percentage. We have looked at other Boroughs in the south of England and they all produce the same statistics. Therefore to argue that Guildford Borough Council or Ash & Tongham have not met the building requirement set out in the LDF is ridiculous.

It should also be noted, and should be a prime consideration when looking at this Planning Application, that in the last 12 months Guildford Borough Council’s Planning Committee has approved the building of 172 new dwellings in Ash and Tongham. This far exceeds what would be necessary to meet the housing needs of such a small part of the Borough.

The Barton Willmore. Environmental Statement states that the Application site was given the designation "Coutryside beyond the greenbelt" in order to accommodate the future development needs of the Borough. On the contrary, this land was protected under the Local Plan 1993 Saved Policy RE4 which prohibited the building of housing on the land.

Barton Willmore also state that the site will be “successfully absorbed within the surrounding landscape”. The landscape is green at the moment. How can 400 houses be absorbed into this.

Stuart Michael Associates in their Design & Access Statement. Accessment & Context, say this will “create a development that strengthens & enhances the local distinctiveness of Ash & Tongham”. This development does nothing to strengthen or enhance local distinctiveness, rather it will destroy the uniqueness of two villages by merging them into one. The NPPF quite clearly states that we should prevent neighbouring towns and villages merging into one another.

In addition Stuart Michael Associates in their Design & Access Statement. Site Constraints & Opportunities state that "The site is generally well contained, with only partial views from properties and road in the immediate vicinity". - "Near distance views from Ash Lodge Drive, Manor Road, South Lane & Poyle Road adjoin areas of vegetation associated with the boundaries of the site" - "Over longer distances views to the south, particularly from the Hog's Back & Surrey Hills AONB, the site becomes more effectively contained by an established landscape". Do they really expect intelligent people to believe this statement? There will be clear views of the whole site from Ash Street looking down the hill. Also the houses will be visible from the Hog's Back AONB, especially the three storey buildings along the primary route. In addition there will be good visibility of the site from all roads around the site, especially in winter when there is little foliage on the trees.

The Barton Willmore Environmental Statement makes the ridiculous statement that at worst the existing houses in Ash Lodge Drive, Loddon Way, South Lane, Avon Close will only suffer moderate adverse residual effects from this building works. The same building works that will go on at the rear of their houses for a minimum of 5 years, and possibly 10.

It should be noted, at this point, that the Local Plan Sustainability Appraisal/Strategic Environmental Assessment Scoping Report December 2012 produced for GBC by URS states that “Male life expectancy in Onslow, Ash Wharf and Ash South and Tongham is 5.8 years shorter than that in the least deprived areas. Guildford Borough has the widest gap in life expectancy between the most and least deprived income groups of all the Surrey districts.... In addition to this, Ash South and Tongham, Ash Wharf, and Ash Vale are within the top national quartile in terms of mental health problems”. The removal of the remaining open space will make the situation worse. The same report states that “Sandy soils and London clay to the north of Guildford and east of Ash and Tongham create a distinctive landscape of wooded and heathland commons. These provide a valued habitat to support biodiversity around Ash Green and at Ash Common.

The NPPF states that local planning authorities should identify and bring back into residential use empty housing and buildings in line with local housing and empty homes strategies and, where appropriate, acquire properties under compulsory purchase powers. The empty houses in Guildford currently total 1,312, the fifth highest out of the 11 local government districts in the county. Local Council Owned 111, Housing Association Owned 23, Privately owned 1,176, others 2. Empty more than 6 months 587.  There are probably enough empty homes in the Borough now to meet any existing shortfall in housing.


According to the NPPF applicants will be expected to work closely with those direct affected by their proposals to evolve designs that take account of the views of the community. Bewley Homes have continued to ignore local objections

Point 69 in the NPPF says: The planning system can play an important role in facilitating social interaction and creating healthy, inclusive communities. Local planning authorities should create a shared vision with communities of the residential environment and facilities they wish to see. To support this, local planning authorities should aim to involve all sections of the community in the development of Local Plans and in planning decisions, and should facilitate neighbourhood planning. None of the Residents Associations or local communities feel they have had enough contact with the Borough Planners and feel excluded from all planning and decision making. We hope that when the new Local Plan is prepared in 2013, local people are consulted, and their input listened to.

The plans produced by Bewley Homes include land that is owned by the residents of No’s. 2 to 16 Loddon Way and 53 to 71 Ash Lodge Drive. They own 7 feet (2.15 mtrs) of the field at the rear of their properties. This was purchased in early 1987 from Day & Company, who was the original builder of the Ashley Park Estate. This land was a "ransom strip" along the edge of the overall development site. All of the owners of these houses hold their deeds for this land.

When reviewing this Planning Application we find it amazing how, in every document, whether it concerns the environment, wildlife, transport, traffic, doctors, schools, flooding, road safety, demolition, construction, or anything else, every single "receptor" in every graph shows the effects of this proposed development as being minimal or negligible. An example of this is in the Barton Willmore, Environmental Statement, where they state that up to a 30% increase in traffic flow is "negligible".

The first round consultation to determine the new Guildford Local Plan (formally the Local Development Framework), take place in February-April 2013. It will set out potential development options right across the Borough for public comment, starting with a long list of everything external consultants have considered possible. Until this process is completed, it is premature to assume that this land will be part of the Framework and available for development. The strategy highlights are to "maintain the open rural character, the identities of and green separation between settlements. Also, to respect the settings of, and relationship between, settlements and buildings in the landscape. Nothing should be decided regarding this land until the Local Plan has been completed. These documents need to take in all of the facts, and decided whether anything should ever be built on this essential flood plain.

Circulation List

Tara Taylor, Case Officer, GBC Planning Department

GBC Planning Committee 

Michael Gove, MP

Nick Sutcliffe, Local Councillor

Environment Agency

Thames Water

South East Water

Surrey County Council Highways     

Surrey Wildlife Trust

John Edwards, SCC Countryside Management & Biodiversity Manager  

Campaign for the Protection of Rural England    

Rushmoor Borough Council (Ref: 12/00928/ADJ)  

Ash Parish Council

Tongham Parish Council

Ash Green Residents Association      

Ashley Bowes, Solicitor 

James Watkins, Trinity Mirror        

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