Appendix 4 – February 2019 Submission
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APPENDIX 4 – FEBRUARY 2019 SUBMISSION 1 February 2019 Crowthorne House Our Ref: 08.166/VR Nine Mile Ride Wokingham Berkshire Francis Whitaker RG40 3GZ Dacorum Borough Council, T 01344 753220 The Forum, F 01344 753221 Marlowes, Hemel Hempstead, Hertfordshire HP1 1DN Dear Francis, Proposals for the Allocation of Land at Shendish Manor I write on behalf of W Lamb Ltd who represent the owners of landholdings at Fairfields and Shendish Manor, Hemel Hempstead (‘land at Shendish’). The landowners control a significant area of land to the south of Hemel Hempstead, south of Apsley Railway Station up to the A41 (see Appendix 1A which outlines the site with a red line). On behalf of W Lamb Ltd, we last promoted the site for allocation through our representations to the Dacorum Borough Council Issues and Options Local Plan Consultation in December 2017. Since September 2018, we have mobilised a new Project Team, and the proposal has changed from that which was submitted in December 2017. The purpose of this letter is to identify these changes for your attention within the context of the wider issues and proposals put forward in our representations, which remain appropriate for consideration through the Council’s Local Plan preparation process. Green Belt We are now proposing a much reduced area for Green Belt release that broadly matches the “refined sub area” (D-S3) identified for further consideration in the Council’s Stage 2 Green Belt Review (the Stage 2 Study). This reflects the conclusion in the Stage 2 study that this further refined sub-area does not compromise the ability of the wider Green Belt to meet its purposes. We have taken particular note of the conclusion on page 131 of the Stage 2 Study that this area must not be viewed in isolation and “any potential inclusion of this part of the site in further work should be weighed up against heritage considerations such as essential setting and significance, also encompassing a more detailed examination of landscape, ecological, heritage and the designed, functional and visual setting for Shendish and its parklands”. Boyer Planning Ltd. Registered Office: Crowthorne House, Nine Mile Ride, Wokingham, Berkshire RG40 3GZ. Registered in England No. 2529151. VAT 587443501. Offices at Bristol, Cardiff, Colchester, London, Midlands and Wokingham. Page 2 of 12 We have carried out the detailed further work suggested on heritage, landscape and ecology to ensure that these considerations are compatible with the conclusion of the Stage 2 study that, this more limited area can be released without detriment to the Green Belt purposes. This has resulted in a more rounded and complete assessment to justify removal of the refined D-S3 parcel from the Green Belt. A key part of the case for the removal of this site from the Green Belt is its exceptional accessibility. You will be aware of the provisions of NPPF paragraph 138 which states that where Green Belt release is necessary “plans should give first consideration to land which has been previously developed and / or is well served by public transport”. A fundamentally important asset of the site is that it immediately adjoins Apsley railway station and therefore has exceptional accessibility with considerable potential to promote a “modal shift” and promote sustainable travel. The site is also served by local bus services along London Road which are located directly outside the proposed site access. New residents will be able to take up a number of significant opportunities for sustainable travel. The site is therefore in a uniquely sustainable and accessible location. We have also been keen to respond positively to the statement in NPPF para 138 that plans “should also set out ways in which the impact of removing land from the Green Belt can be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land”. We have therefore defined a development area and suggested allocation boundary that will incorporate the existing historic tree clumps and tree belts, and will be designed to enhance the openness and setting of the land adjacent to the site that remains in the Green Belt. Developable / Allocation Area The developable area of the site broadly matches the area we have proposed for Green Belt release and the definition of this area is based on detailed technical assessments (as set out below). The proposed allocation area has been based on detailed consideration of how topography, landscape and the setting of historic assets combine to dictate a logical development boundary. The site is accessible via a proposed principal access off London Road and two secondary access points off Rucklers Lane. We identified a similar development area in our December 2017 representations but we have now extended this slightly to include the field adjacent to the west of Fairfields House as this additional land is well contained by a strong vegetated boundary. This area that we are proposing for allocation in the Local Plan will accommodate approximately 500 homes. Appendix 1 identifies and defines this area. Sites of this scale are necessary to reduce the Plan’s reliance on major strategic sites that have major infrastructure requirements and long lead in times as well as protracted build out periods. Our client’s site is available and deliverable and can make a contribution to the Council’s 5 year land supply. We are keen to demonstrate this through the submission of further information including a trajectory for the delivery of the site. Allocation of the site would therefore add diversity to the Council’s housing land supply and ensure greater overall deliverability of homes within the Plan period. Page 3 of 12 Illustrative Masterplan and Development Area Appendix 1 shows the proposed development areas and green infrastructure design for the site. A green buffer is proposed around the western boundary of the site to enhance the openness and setting of the land remaining in the Green Belt to the west. Technical Assessments A suite of technical assessments have been produced to support the conclusion that the site is suitable for the allocation of approximately 500 homes. Below is a list of the technical assessments and a full copy of each report is enclosed for your information and assessment: Ecological Appraisal, prepared by Hankinson Duckett Associates Arboricultural Walkover Survey, prepared by Hankinson Duckett Associates Heritage Desk-Based Assessment, prepared by Cotswold Archaeology Transport Appraisal, prepared by i-Transport Environmental Noise and Vibration Assessment, prepared by AIRO Preliminary Landscape Appraisal, prepared by Capita Drainage and Utilities Assessment, prepared by Glanville Illustrative Masterplan, prepared by Bluepencil Designs A summary of the technical assessments above and an overview of the preliminary development proposals is provided as Appendix 2 to this letter. Conclusion Land at Shendish Manor offers a deliverable proposal for around 500 homes as a sustainable urban extension. A range of technical assessments have been undertaken which have informed a detailed masterplan for the site, which combine to demonstrate its sustainability credentials, and that the scale of development promoted is both realistic and achievable. We will be making a formal submission to the Borough Council once the Regulation 19 Consultation is launched in due course, but in the meantime I trust that the above summary and enclosed detailed information is of interest and can be taken into account in the Council’s site selection work. Please do not hesitate to contact me if you have any queries or would like to discuss any aspect of this submission in further detail. Yours sincerely Vanessa Rowell Senior Planner Tel: 01344 753 089 Email: [email protected] Page 4 of 12 APPENDIX 1A - RED LINE BOUNDARY Key Red Line boundary NORTH Existing Buildings Project: Shendish Manor, Hemel Hempstead Client: W. Lamb Ltd Drawing Title: Red Line Boundary Plan 001A Drawing Number: 18010-01OPA Date: 15.01.2019 Scale: 1:5000@A3 w: bluepencildesigns.com t: 01621841053 Page 5 of 12 APPENDIX 1B - DEVELOPMENT AREA PLAN Page 6 of 12 APPENDIX 1C – CONSTRAINTS PLAN Page 7 of 12 APPENDIX 2 - SUMMARY OF TECHNICAL ASSESSMENTS Page 8 of 12 Ecology Appraisal The report concludes that beyond the normal requirements to avoid impacts on protected species and maintain key elements of the habitat resource of the site, there appears to be no overriding nature conservation constraints that would preclude the proposed allocation of the proposed area. There are no habitats of International, National, Regional or County nature conservation importance within the site itself. The site broadly comprises two distinct habitat areas. The northern area of the site is dominated by an existing golf course comprised of amenity and rough grassland, scrub, woodland and scattered trees bordered by woodland and treelines. The southern area of the site is dominated by a series of rough grassland fields with scattered trees and scrub areas of broadleaved woodland. The existing areas of highest ecological value within the proposed development area will be retained, enhanced and protected as part of the development. Located outside the site is the Roughdown Common SSSI, located approximately 980m to the north of the site at its closest point. It is not expected that residential development within the land proposed for allocation would result in any adverse impact on this designated site and the planning authority would not