Allocations Submission Document

The allocation of the Star Lane Industrial Estate for residential development is supported as a matter of principle. The southern (brickworks) section of the Star Lane Industrial Estate is the subject of a current full planning application for residential development. This part of the site is considered to have a capacity for circa 120 dwellings.

Objections are however raised to the overly prescriptive nature of Policy BFR1. Specifically, the Concept Statement includes a series of quantitative requirements for the provision of affordable housing, Lifetime Homes (LTH) standards, public open space and play space which are not considered appropriate or reasonable.

Affordable housing and LTH requirements are principally addressed through Core Strategy Policies H4 and H6 respectively. Both policies recognise that the level of provision will need to be reduced where full compliance would threaten the viability of a particular development. Similarly, the level of provision of open space including play space will need to have regard to site characteristics and context, scheme layout and design constraints, and the need to achieve a viable development outcome. Whereas, the development of greenfield sites may allow a more prescriptive approach to these standards, brownfield sites give rise to generally higher costs in terms of historic acquisition values and site clearance/preparation.

It is also disputed whether it is reasonable to require high levels of open and play space provision in the context of full compliance with private amenity space standards. Adopted SPD2 (Housing Design) confirms that children's play spaces are not usually considered necessary because of the reasonable garden sizes required by the LPA. Access to off-site open space facilities will also be a consideration along with the maintenance and supervision issues which can arise from play spaces within residential developments.

Therefore, while this site can reasonably provide areas of public open space including play space, Policy BFR1 is not considered to be sound on the basis of its over prescriptive approach to the application of planning standards. It is noted that the Implementation, Delivery & Monitoring Chapter of the document states, in respect of Policy BFR1, that the Council will adopt a flexible approach to the requirements of the Concept Statement where compliance would threaten the viability of the scheme. This approach should be embedded within the policy itself.

The allocation of land, under Policy SER9, to the west of Little Wakering Road (SER9a) is unsound because, compared to land to the west of Alexandra Road, it is relatively remote from village services and facilities, and does not provide a defensible Green Belt boundary along its extensive western edge. Development in this location would be harmfully intrusive into open countryside. Furthermore, the allocation of two separate sites under this proposed policy (i.e. land to the south of High Street (SER9b) and land to the west of Little Wakering Road (SER9a)) would create a segregated form of development and would therefore have a negative impact on community cohesion.

Rather than releasing Green Belt land at SER9a, the land to the west of Alexandra Road should be allocated as an extended part of site SER9b. The land to the west of Alexandra Road, which was considered by the Council at Discussion & Consultation stage as part of Option WGW3, would form a logical and contiguous extension to SER9b. This land would also be sited closer to the village centre than either SER9a or SER9b, and would provide a highly defensible Green Belt boundary on all sides by virtue of the existing development and other features.

Option WGW3 included three separate and unrelated plots in the general location of West Great Wakering. These plots were (i) land to the west of Alexandra Road, (ii) land to the south of Star Lane brickworks, and (iii) a small plot to the north of the Star Lane Industrial Estate. The latter now forms part of plot SER9b. The overt disadvantages of releasing land to the south of Star Lane brickworks had a distorting impact on the overall case (or score) for this option. The sustainability appraisal in respect of WGW3 is therefore misleading and flawed.

By virtue of its contiguous relationship with SER9b, development of the land to the west of Alexandra Road would not be segregated or dispersed in terms of community cohesion. It would form part of SER9b, and would offer easy accessibility to the village centre and other facilities. Development here would assist in community integration, and would support local businesses. No other available Green Belt site in the west Great Wakering 'search zone' scores as well in sustainability and integration terms. Self-evidently, site SER9a is unsustainable by comparison.

The Sustainability Report issued at 'Discussion & Consultation' correctly states that 'the site to the west of Alexandra Road would relate well with Option WGW1 and provide an alternative access route from the site'.

The allocation of the Stambridge Mills site for residential development is supported as a matter of principle. The Stambridge Mills site is the subject of a current full planning application for redevelopment to provide 96 units. The Sequential Test and Exceptions Test have been passed.

Objections are, however, raised to the overly prescriptive nature of Policy BFR3. Specifically, the Concept Statement includes a series of quantitative requirements for the provision of affordable housing, Lifetime Homes (LTH) standards, public open space and play space which are not considered appropriate or reasonable.

Affordable housing and LTH requirements are principally addressed through Core Strategy Policies H4 and H6 respectively. Both policies recognise that the level of provision will need to be reduced where full compliance would threaten the viability of a particular development. Similarly, the level of provision of open space including play space will need to have regard to site characteristics and context, scheme layout and design constraints, and the need to achieve a viable development outcome. Whereas, the development of greenfield sites may allow a more prescriptive approach to these standards, brownfield sites give rise to generally higher costs in terms of historic acquisition values and site clearance/preparation.

It is also disputed whether it is reasonable to require high levels of open and play space provision in the context of full compliance with private amenity space standards. Adopted SPD2 (Housing Design) confirms that children's play spaces are not usually considered necessary because of the reasonable garden sizes required by the LPA. Access to off-site open space facilities will also be a consideration along with the maintenance and supervision issues which can arise from play spaces within residential developments.

Therefore, while this site can reasonably provide areas of public open space including play space, Policy BFR3 is not considered to be sound on the basis of its over prescriptive approach to the application of planning standards. It is noted that the Implementation, Delivery & Monitoring Chapter of the document states, in respect of Policy BFR3, that the Council will adopt a flexible approach to the requirements of the Concept Statement where compliance would threaten the viability of the scheme. This approach should be embedded within the policy itself.