Allocations Submission Document

BFR1 Star lane Industrial Estate
Whilst the respondent supports the principle of this allocation, there are strong reservations as to whether the Star Lane Industrial Estate section of the allocation will be deliverable, within the expected timeframe. The allocation includes the existing Star Lane Industrial Estate and the Former Brickworks. The Council is currently considering a planning application proposal for the Former Brickworks and it is likely that these proposals could be delivered at some point. It is important to stress however that the respondent believes that planning permission on the Brickworks should not be granted, unless the approved scheme includes unfettered vehicular access to the respondent's site SER 9b. The access must be capable of catering for the quantum of development anticipated on allocation SER 9b. This access must also be agreed with the highway authority and designed to serve the brickworks development as well as up to 185 residential units on allocation SER 9b.
Star Lane Industrial Estate is made up of a number of individual business units, which are in multiple ownership. Many of the occupiers have a freehold interest and there are also a number of tenants, many of which have relatively recent leases. The prospect of these owners/tenants coming together to relocate simultaneously is extremely unlikely. It is considered that the release of the land will as a result, be delayed to the point where it is out of step with the Council's housing trajectory. The respondent has two solutions to this likely scenario. Firstly, the respondent owns the land identified in the Allocations DPD as allocation NEL 3 (new employment site at Great Wakering). Attached to these representations is a plan that illustrates an indicative employment layout on site NEL 3. Also attached is a wider indicative master plan that illustrates additional housing in the place of NEL 3, as an alternative option in case the Star Lane Industrial Estate does not come forward as expected. This option simply transfers the housing numbers anticipated on the existing industrial estate to the specific site allocated as its replacement. If somehow the existing employment landowners do get together and decide to relocate, then the respondent is able to deliver the replacement site NEL 3 as part of a comprehensive and wider master plan. This master plan illustrates how sites SER 9b, NEL 3, the Former Brickworks and the Wildlife Site with new areas of Public Open Space could be linked together.
If however, and as expected the Star Lane Industrial Estate does not relocate in a timely fashion, then the respondent's option could be rolled out as a sound alternative.

The plans mentioned have had to be emailed to the Council separately.

SER 9 West Great Wakering

The respondent fully supports the allocation SER9, in particular sub-allocation SER9b. The respondent owns the land identified as SER9b, as well as a significant land interests to the south and east of the allocation. In the interest of clarity, the respondent has included an ownership plan within a promotion document attached to these representations.

The wider ownership of land in this area, which includes the Local Wildlife Site (R25 Star Lane Pits), affords the respondent a certain amount of flexibility and opportunity, to not only deliver the new housing area, but also the required employment land, secure the wildlife area and potentially provide new areas of public open space.

Site SER9b
Allocation of this land for new housing is fully supported. The site is ideally located just south of the urban edge with a direct link to Great Wakering, High Street. There are no environmental or other reasons why this land cannot be developed for housing. The land is available, deliverable and fully developable with no impediments.

The site area extends to some 8.5 hectares. The Council anticipates that this site, along with allocation SER9a shall together deliver 250 residential units, plus a flexibility allowance of 5%. The delivery of these units is to be held back, in accordance with Core Strategy Policy H3, until post 2021, unless required in order to be brought forward earlier to maintain a 5 year supply of deliverable housing.

The Council is advised that this land will be maintained in agricultural use until it is required for housing. However, the respondent will adopt a flexible approach to land management so that the land can be made available sooner, if supply does not keep pace with the Council's housing trajectory.

Master Planning
In addition to the allocations for housing on site's SER9, additional allocations for housing and employment land are identified in Great Wakering. These sites, namely BFR1 - Star Lane Industrial Estate and Farmer Brickworks and NEL3 New Employment Land are clustered together and need to be considered jointly.

The respondent has produced some master plans for the area to illustrate the sites in context and to demonstrate indicatively, how the Green Belt release for SER9b could be developed. The master plans are provided within a Promotion Document or they will be provided separately as part these representations, to illustrate specific matters of interest.

Master Plan One
Master Plan One, illustrates how the combined sites could be built out as the Allocations DPD envisages.

The Master Plan illustrates 185 dwellings on allocation SER9b at a density of 22 dwellings per hectare (dph). Whilst the layout is indicative of a likely scheme, it is an 'every house' layout, which incorporates each and every requirement as set out in the submission document. The layout incorporates precisely the amount of semi-natural and formal open space, the required LAPs and LEAPS, as well as stated connectivity requirements and landscape buffers.

The density of 22 dph is considered to be appropriate to the site's context and proximity to the wildlife site. It is also appropriate to the Council's anticipated housing requirements for this area. It is noted that SER9 anticipates 30 dph across both allocations which combine to a total 13.5 hectares. At 30 dph, delivery on a combined SER9 allocation would be 405 units, which is clearly more than envisaged.

At 22 dph, site SER9b as shown on the Master Plan can provide 185 units on approximately 8.5 hectares and SER9a at 4.5 hectares could deliver approximately 100 units, thus a total of 285 units could be achieved. Whilst 285 is more than the 250 envisaged, when one considers the additional 5% and the likelihood of a Core Strategy review, prior to 2021 where some additional housing numbers are likely, then 285 units from these allocations is not unreasonable.

The layout shown on the indicative Master Plans for SER9b, whilst illustrative, incorporates the design requirements set out in the Council's Concept Statement. The principle vehicular access is as required taken from the redevelopment of the Former Brickworks site. At the present time, it is not clear whether the Council has received a suitable layout, as part of the planning application for the Brickworks, which is suitable and capable of serving an additional 185 residential units on SER9b. The respondent has taken advice from Transportation Consultants in relation to alternative access strategies. It is quite possible that some of the site could be served from the High Street or from an access south of the Brickworks. A paper from the respondent's Transport Consultant is attached to these representations, which explores the options.

Star Lane Pits Local Wildlife Site (LOWS)
The LOWS is of course an important resource, which needs to be protected in the long term. The respondent has recently undertaken a Phase One Habitat Survey to assess the site's overall quality and whether these are opportunities to improve its richness through better management. A summary paper is attached to these representations from the respondent's ecologist. The respondent would be willing to develop a better management plan for the wildlife site, which enhances its quality and ensures that it is able to co-exist alongside housing development and thrive in the long term.

Employment Allocation NEL 3
It can be seen on Master Plan One that provision is made for allocation NEL 3 for a new employment site as a green belt release to replace Star Lane Industrial Estate. The new industrial site is accessed as required from a single access/egress onto Star Lane. The site area of 2.5 Ha and its general position have been interpreted from the plan in the Allocations DPD. Provision is also made for pedestrian links between the industrial land and SER9b, which in turn connect with the High Street. The pedestrian link, which is shown to the west of the wildlife site, is through scrub land and spoil heaps from the adjacent former brickworks. This land has no ecological value.

Master Plan Two
Master Plan Two is the same as Master Plan One with respect to the potential treatment of allocation SER9b. However, it has been prepared to illustrate the flexible approach that the respondent can facilitate to ensure that the comprehensive development of the area could be achieved, whilst responding to changes in circumstances.

The respondent has strong reservations in relation to the delivery of new housing on Star Lane Industrial Estate as anticipated by allocation BFR1.

These reservations reflect the site's multiple ownership and mix of freehold and leasehold tenure. It is considered most unlikely that collectively the occupiers of the estate will act as one and choose to relocate. It is also unlikely that NEL3 would be constructed without the industrial units being pre-let.

In the event of the existing industrial estate not being redeveloped when or as anticipated, Master Plan Two illustrates additional housing on north of NEL3 to compensate for the housing not coming forward on the brownfield allocation. This option is just that, an option for the Council to consider if development does not emerge as anticipated. If however the existing industrial site is redeveloped, then the respondent can deliver NEL 3 as required and as illustrated on Master Plan One. If the brownfield development does not come forward as and when anticipated, then alternative provision for housing could be made available as shown on Master Plan Two to maintain a five year housing land supply.

Both Master Plan options also include a significant area of approximately 5.4 Ha of new Public Open Space to the south of the wildlife site. The respondent would welcome a discussion as to the provision of this additional land to meet existing and planned open space needs.

Consultations
During November 2012, the respondent provided Great Wakering Parish Council with a brochure document (enclosed with these representations) which introduce the landowners and tabled two preliminary and basic Master Plans. A briefing meeting was held with the Parish Council on the 28th November 2012, at which the respondent explained the likely approach to the allocations. The Parish Council were responsive to the proposals in principle and raised no fundamental objections. Parish Councillors had some concerns regarding education provision in the village and leisure facilities and it was explained to them that suitable provision would need to be made alongside new housing development through s106 agreements.

The respondent intends to continue an informal dialogue with the Parish Council as proposals evolve.

The plans mentioned have had to be emailed to the Council separately.

NEL 3 South of Great Wakering

The respondent supports allocation NEL 3 for new employment land south of Great Wakering.

Attached to these representations is an illustrative layout and a Master Plan, which illustrates how the site could be developed and as part of wider development proposals. It can be seen from the master plan that the position envisaged for NEL is perhaps a curious one and the respondent wonders whether this was the Council's intention. There would be plenty of scope to move the site further north so that it is sufficiently distant from housing areas, but not isolated. Attached to these representations is a plan (Master Plan 3) that illustrates an alternative option, albeit with a larger allocation area.

The respondent has serious reservations in relation to the likelihood of Star Lane Industrial Estate being redeveloped within the plan period. Were the existing employment site not to come forward as expected, the respondent has prepared an alternative housing allocation on site NEL 3 to make up for the shortfall in supply.

Attached to these representations is a plan, which illustrates how this site could be used for housing if required. In addition, the plan shows other allocations as planned alongside wider public open space provision.

The alternative housing option has been moved north towards the Brickworks development as there would no longer need to be a significant buffer as there would if the site were required for employment provision.

The plans mentioned have had to be emailed to the Council separately.

ELA 1 Local Wildlife Sites

The respondent supports this allocation. However, considers it to be necessary to review the precise boundaries of site R35 Star Lane Pits, as part of this allocations process.

The present site boundaries include large areas of scrub land containing spoil heaps from the adjacent brick workings. This land, which has no ecological value, provides an opportunity for new semi natural open space and pedestrian links. The respondent's ecologist has assessed the land and confirmed that it should be excluded from site R35.

Enclosed with these representations is a plan, which illustrates the existing extent of the wildlife site and the suggested new boundary, which would allow better connectivity between the NEL 32 and SER 9b.

The plans mentioned have had to be emailed to the Council separately.