Option E11 Stambridge Mills

Stambridge Parish Council supports that this site be identified as suitable for housing allocation rather than light industrial use due to the current state of the site.

The site is located within Flood Zone 3 and is physically remote from the existing urban area/nearest settlement including public transport network. The redevelopment of the Mill would be contrary to PPS3 and PPS25. There are alternative sites for housing available in the District that are sequentially preferable and are also more sustainable. The Council's evidence base does not support the use of the exceptions test in this instance. The site is neither developable or deliverable for housing. This objection is supported by the Environment Agency.

Background

Both the Core Strategy and the Site Allocations DPD identify Stambridge Mills for re-allocation to residential uses. For the reasons set out in the submissions made by Countryside Properties to the Core Strategy (re-iterated below), we do not consider that the site is necessarily suitable, desirable or deliverable for residential development. We consider that the site can remain as an important source of local employment, and this should be reflected in both the Core Strategy and the Site Allocations DPD.

Representations

The Council will be well aware of the objections made by various parties to the Core Strategy proposal to redevelop this site on Flood Risk grounds. We do not consider that the exceptions test in PPS25 is passed in this case, since there are options for development on land outside flood zone 3 (we do not agree with the approach put forward by the Council in Core Strategy Topic Paper 1, that defence of the Green Belt is an adequate rationale to build homes on land at risk of flooding).

Even if an exception can be justified under PPS25, 250 homes at a density of just under 140 dph is a very high density for a site in such a relatively remote and unsustainable location (page 120 of the Core Strategy gives the site area as 1.8ha). It is difficult to see how this intensity of development is justified, when the recommended density for town centres is only 75+ dph.

If retained, therefore, the quantum of development proposed needs to reflect the relatively isolated and unsustainable location of the site.

Please see our previous comments.

Please see our general comments.

This is an existing employment site, which is in a fairly isolated location within the Green Belt and as such it would be difficult to create a defensible boundary if this site is developed for residential.

In addition, this site is subject to a high risk of flooding (Zone 3), and its redevelopment for residential would replace a less vulnerable use (employment) with a more vulnerable use (residential).

The preference would be to safeguard the site for employment and see it redeveloped for light industrial use.

RE: ALLOCATIONS AND DEVELOPMENT MANAGEMENT DEVELOPMENT PLAN DOCUMENTS



Thank you for giving Anglian Water the opportunity to comment on the above document.



Please find our comments summarized on the attached document.