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Allocations DPD Discussion and Consultation Document

Representation ID: 19937

Received: 30/04/2010

Respondent: Inner London Group

Agent: Christopher Wickham Associates

Representation Summary:

The allocation of Stambridge Mills for residential development is fully supported. The site constitutes previously developed land, and its residential redevelopment complies with PPS3. Redevelopment will offer clear-cut sustainability and amenity benefits, and will provide a defensible Green Belt boundary. The PPS25 sequential test has been passed, and the Exception Test can be be passed. The site has good access to the highway network and good links with Rochford town centre. Sustainable transport improvements will be provided as part of its redevelopment.

Full text:

The allocation of Stambridge Mills for residential development is strongly supported. The site is identified as an appropriate location for residential development under Policy H1 of the Core Strategy Submission Document. It is considered that the approach of prioritising the re-use for housing of previously developed land is sound. It is consistent with PPS3, will reduce the need to release Green Belt land, and will allow for the removal of contamination, the re-use of existing on-site materials, and the environmental and ecological enhancement of the site and its surroundings.

The site is available, suitable and achievable, as required by PPS3. It is in the single ownership of the Inner London Group (ILG), and is available for immediate redevelopment subject to the need for planning permission and site clearance. Alternative industrial use would not be viable or environmentally acceptable. Residential development will comply with wider sustainability objectives through the retention and conversion of various existing structures at the site, and the re-use of on-site materials for the construction of the improved flood defences. It will also contribute to the supply and choice of new homes in the Rochford area, will reduce pressure for the release of Green Belt land, and will offer substantial visual amenity benefits. A strongly defensible Green Belt boundary will be achieved. The site is also located within reasonable distance of the retail, employment and service facilities in and around Rochford town centre. As part of the proposals for the site, ILG intend to offer a package of accessibility enhancements including footpath and bus service improvements.

ILG have prioritised the site for development. The emerging proposals have been the subject of supportive feedback from the Inspire East Design Review Panel. Natural England has also been fully consulted, and has confirmed that the proposals do not give rise to any substantive objection on ecological impact grounds.

The site lies within Flood Zone 3a on the Environment Agency (EA) Flood Maps, and current flood defences in the vicinity do not provide adequate long-term protection for the site or the adjoining care home and residential uses. As required by PPS25, a Flood Risk Sequential Test has been undertaken (both by ILG and by the Council). The Council has confirmed that the Sequential Test has been passed.

ILG have engaged in detailed and constructive discussions with the EA relating to the resolution of flood risk issues arising at Stambridge Mills, and have commissioned specialist advice on flood protection matters, and a full Flood Risk Assessment (FRA) has been submitted to the EA and the LPA.

Although the site is currently at risk from flooding, it is proposed that its development will be accompanied by substantial new flood defence works, and the raising of all residential accommodation above the 1 in 200 year flood level. The detailed design of these defences has been agreed with the EA. A significant aspect of the proposed strategy is the benefit provided to the wider community. The combination of improving the existing defences and constructing counter-walls to higher ground will not only protect the proposed development and ensure dry access is maintained in times of flood, but will also protect Broomhills Care Home and residential properties on Mill Lane. In addition, the proposed defences will protect Stambridge Road from flooding; this road provides an important transport route to the villages to the east of Rochford.

Having satisfied the Sequential Test, the Exception Test has been applied, and can be readily passed. Criterion a) is complied with because the scheme will reduce the need to release Green Belt land to meet housing needs, and will offer the opportunity for a substantial enhancement of the landscape in the area immediately to the east of Rochford. The re-use of existing resources, and the removal of contamination, will also bring about clear-cut sustainability benefits for the community. Furthermore, the scheme will offer specific benefits to existing residents in the immediate area through the improvements to existing flood defences. Criterion b) is complied with because the site constitutes previously developed land in its entirety. Furthermore, the site meets the PPS3 definition of "developable" . Criterion c) will be complied with because the FRA demonstrates that the proposed improvement and extension of the existing tidal flood defences will render the development safe from flooding, will not increase the risk of flooding elsewhere, and will provide enhanced protection from flooding for the existing care home and other residents in the vicinity of the site. Discussions with the Emergency Services, relating to issue of safe access and egress in the highly unlikely event of the breach of the flood defences, are ongoing.

The allocation of Stambridge Mills is therefore consistent with the requirements of PPS3 and PPS25, and is fully supported.