Strategic Planning Dacorum Borough Council The Forum Marlowes Hemel Hempstead Hertfordshire HP1 1DN
26 February 2021
Dear Sirs
Dacorum Borough Council Local Plan Emerging Strategy for Growth 2020-2038 Consultation Site Specific Representations - Land at Fox Meadow, Bovingdon
Thakeham Homes Ltd (“Thakeham”) is writing in respect of Dacorum Borough Council’s (“the Council”) Local Plan Emerging Strategy for Growth 2020-2038 Consultation (November 2020 – February 2021) (”the draft Local Plan”), specifically in relation to the Land at Fox Meadow, Bovingdon (“the Site”) which Thakeham proposes should be included as an allocation for residential development in the emerging draft Local Plan. These representations also raise significant concerns with the Council’s approach to growth in Bovingdon as well the proposed site allocations. A site location plan is included in Appendix 1, together with a Vision Document (in Appendix 2) demonstrating the suitability of the Site and how Thakeham intends to deliver a tailored development for Bovingdon. A Statement of Community Involvement is included as part of this submission under Appendix 3.
About Thakeham
Thakeham is a zero carbon, infrastructure-led community creator, committed to delivering extraordinary places, where the highest attention to detail makes a positive difference.
Thakeham builds for the future, for communities and for individuals. Each development is different, with careful consideration of the area’s character, as well as the environment. As a community creator first and foremost, Thakeham’s commitment to improving on existing social landscapes and mental/physical wellbeing means its schemes are infrastructure led and zero carbon in terms of both design and construction. Thakeham engages with transport, healthcare, utilities and other stakeholders from the start of any project. Our delivery of new homes goes hand in hand with the delivery of physical, social, blue and green infrastructure, benefiting the wider surrounding area, new and existing residents, and ensuring that Thakeham creates sustainable places to live, work and relax. At every stage, Thakeham’s approach is one that ensures they leave a legacy behind that everyone can be proud of.
Thakeham House, Summers Place, Stane Street, Billingshurst, West Sussex, RH14 9GN
www.thakeham.com
Company Registration No. 07278594. Registered Office Address: Thakeham House, Summers Place, Stane Street, Billingshurst, West Sussex, RH14 9GN
Thakeham is the first housebuilder in the UK, and one of only five in the construction sector globally to have made commitments on the SME Climate Hub to join the United Nations’ Race To Zero campaign. The commitment Thakeham has made joins Thakeham’s existing commitments that from 2025 all Thakeham Homes will be carbon neutral in production and zero carbon in lifetime use.
Thakeham is one of only 12 organisations selected to become a member of the Healthy New Towns Network: a collaboration between NHS England, Public Health England, Housing Developers and Housing Associations. Thakeham is also a member of the Home Builders Federation, sitting on its Future Homes Taskforce as an exemplar business, for our leading work in Zero Carbon Placemaking. Thakeham has recently been acknowledged for its high- level commitment to advancing sustainability within the industry by the Supply Chain Sustainability School (SCSS). The award of Gold membership acknowledged Thakeham’s use of the resources as a method of ensuring continuous sustainability improvement across the wider supply chain. Further details about Thakeham’s different approach and commitments can be found in the Vision Document that accompanies these representations.
These representations are split into the following sub-sections; - Overarching Vision for Dacorum’s Growth by 2038 - Vision for Bovingdon and Bovingdon Delivery Strategy - Chesham Road/Molyneux Avenue - Grange Farm - Land at Fox Meadow
Local Plan Emerging Strategy
Overarching Vision for Dacorum’s Growth by 2038
Thakeham supports the Council’s vision for the Borough which recognises the challenges and opportunities which exist over the Plan period to 2038. As emphasised by the Vision, to achieve this it will be critical that balanced communities are delivered with the homes, jobs and supporting infrastructure.
Whilst we support the principle of the key elements the vision for Bovingdon encompasses, we question whether the current draft Local Plan will result in the achievement of this vision. It is critical that the Council’s vision is clearly translated into the draft Local Plan to ensure its policies meet the needs and aspirations of the local communities.
Policy SP2 – Spatial Strategy for Growth
Policy SP2 sets out the Council’s proposed Spatial Strategy and how this is to be delivered. Amongst other elements, the Policy identifies that the Plan will make provision for a minimum of 16,596 homes over the period between 2020 and 2038, equivalent to 922 homes per annum.
Thakeham House, Summers Place, Stane Street, Billingshurst, West Sussex, RH14 9GN
www.thakeham.com
Company Registration No. 07278594. Registered Office Address: Thakeham House, Summers Place, Stane Street, Billingshurst, West Sussex, RH14 9GN
On 16th December 2020, the Government published the results of its new Standard Methodology (following the previous consultation version in August 2020). This new Standard Methodology sets a minimum annual requirement for Dacorum of 1,023 dwellings per annum. Thakeham believes the Council must address the shortfall of 101 dwellings per year. Clearly, whilst the Council was not able to reflect this in the current consultation version of the Local Plan, future iterations will need to respond to this increased minimum requirement and ensure the Local Plan is preparing to meet these needs.
Accordingly, Policy SP2 must be updated to include a requirement for provision of a minimum of 18,414 homes over the Plan period. Additional allocations will therefore be required in order to deliver the 1,818 additional dwellings now required over the 18-year Plan period.
In updating the Spatial Strategy, and indeed the Plan as a whole, in order to meet these new housing requirements, it will be important to consider this holistically alongside the other forms of provision required to ensure that the Council’s vision is met with the necessary supporting infrastructure delivered alongside the required homes and jobs.
We support the proposed Spatial Strategy which predicates that the focus of strategic growth and investment will be at the most sustainable locations. Hemel Hempstead will be a focus of growth, supported by growth at Berkhamsted and Tring. It will be equally important that the growth be allocated to the large villages of Bovingdon, Kings Langley and Markyate. Further, that any such growth be proportionate to the sustainability and size of these settlements with respect to the Spatial Strategy.
Whilst it is agreed that, when read as a whole, the Local Plan and its supporting evidence base make a clear and compelling case for the exceptional circumstances which justify the release of Green Belt in the Borough, it is considered that this could be more clearly expressed within the Local Plan itself. The inclusion of a specific section addressing this point in Section 5 of the Local Plan would aid the clarity of the Local Plan.
Policy SP3 – The Settlement Hierarchy
Thakeham’s comments regarding Policy SP3 are largely addressed under Policy SP2 and as such are not repeated here. However, we do believe the first sentence of the policy should be updated. The first sentence is currently written:
“New development will be primarily focused at Hemel Hempstead, the market towns, and large villages.”
We do not consider this clearly reflects the hierarchy of these settlements and would suggest that the wording is replaced with the following which is replicated from that in Policy SP2:
Thakeham House, Summers Place, Stane Street, Billingshurst, West Sussex, RH14 9GN
www.thakeham.com
Company Registration No. 07278594. Registered Office Address: Thakeham House, Summers Place, Stane Street, Billingshurst, West Sussex, RH14 9GN
“The primary focus of strategic growth and investment will be at Hemel Hempstead, supported by growth at Berkhamsted and Tring and then the large villages of Bovingdon, Kings Langley and Markyate.”
Policy SP4 – Delivering the Housing Strategy
As discussed above, the Council’s housing requirement must be updated in the light of the revised Standard Methodology (December 2020) to include a requirement for provision of a minimum of 18,414 homes over the Plan period. Additional allocations are therefore likely to be required in order to deliver the 1,818 additional dwellings now required over the Plan period.
We consider that all references to dwellings numbers, save windfalls, should be expressed as minimum numbers in the Local Plan. It is important that the Plan includes sufficient flexibility to ensure the minimum housing requirement is met. Rather than the current proposed strategy of relying on windfalls for a significant proportion of the housing requirement, particularly at certain settlements, windfalls should instead be viewed as providing this flexibility on top of the Local Plan allocations. This alternative and more dynamic approach would ensure minimum housing numbers across the whole Borough are met.
As set out in comments regarding Policies SP2 and SP4 above, Thakeham considers that additional housing sites need to be identified in the Borough and proposes that Fox Meadow in Bovingdon provides a suitable additional site in line with the Vision and Delivery Strategy for the village. Notwithstanding that, should the Council believe it unnecessary to allocate additional land, Thakeham raises serious concerns with the current draft allocations and will show that the site at Fox Meadow offers a preferable alternative.
Vision for Bovingdon and Bovingdon Delivery Strategy
Sites are proposed in Bovingdon for at least 240 homes in the draft Local Plan (comprising existing commitments, windfalls, 40 homes on the site adjacent to Chesham Road/Molyneaux Ave and 150 homes and land for a primary school at Grange Farm, Green Lane). Within these next sections, Thakeham details its concerns with the Council’s approach to growth in Bovingdon and highlights issues with the deliverability of both of these draft site allocations. The site at Fox Meadow offers significantly greater community benefits than the current strategy (the allocation of the two afore-mentioned sites) within the Plan period.
Under the “The Vision for Dacorum's Places” on page 24 of the draft Local Plan, it states that Bovingdon will “have provided increased levels of affordable homes; have strengthened their role in providing services and facilities to serve residents and the adjacent rural communities; and have secured additional and improved local community facilities”. Apart from the land reserved for a school site no other community facilities are proposed for Bovingdon as part of the draft site allocations. Indeed, in relation to the school site, it is merely a reservation of land and there is no commitment to the delivery of a completed school, nor is there any indication
Thakeham House, Summers Place, Stane Street, Billingshurst, West Sussex, RH14 9GN
www.thakeham.com
Company Registration No. 07278594. Registered Office Address: Thakeham House, Summers Place, Stane Street, Billingshurst, West Sussex, RH14 9GN
as to when and how the funds for such a school would become available. Therefore, as currently presented, the draft Local Plan does not meet the Council’s own vision for the Bovingdon.
The Bovingdon Delivery Strategy set out in the draft Local Plan states that growth should be broadly in accordance with the settlement hierarchy. Nevertheless, the Council’s Topic Paper on Development Strategy (November 2020) states that Bovingdon represents 3.5% of the total housing stock in the Borough yet has seen just 35 new homes completed in the period 2006- 2019 (Table 3.1). This shortfall in delivery to date will be made worse by the draft Local Plan which proposes just 240 homes over an 18 year period (the equivalent of 13 new homes per annum). This equates to just 1.4% of the housing numbers in the draft Local Plan, tantamount to a decline in Bovingdon’s contribution to the overall housing stock. By applying 3.5% to the 16,899 figure, a more appropriate level of growth for Bovingdon would be 590 new homes during the Plan period. This would ensure Bovingdon consistently contributes towards the overall housing stock in the Borough.
The Bovingdon Delivery Strategy also refers to the existing primary school being constrained. Research carried out on behalf of Thakeham and other interested parties concludes;
“There is one Primary School serving Bovingdon (Bovingdon Primary Academy). This is a 2FE school with minor surplus capacity at present. However, the school draws from a wide geographical area, including home locations that are closer to other schools. Additionally, there are two schools within the Ward (Bovingdon Primary Academy, and St Paul’s, Chipperfield), with more places available than there are births annually. Birth numbers are falling in the Ward, with 2018 and 2019 seeing some of the lowest numbers in the past two decades. When applying local data to the EFM trajectory model, the indication is by the academic year 2023/24, there should be sufficient places within the Ward to accommodate the Primary pupil demand from over 600 new dwellings.” – EFM ‘Education Report Bovingdon, Hertfordshire’ July 2020. (this report has already been provided to DBC, but can be made available on request)
Therefore, it is evident that primary school provision is not a justification for artificially capping the growth of the village and so Thakeham would suggest the approach to housing numbers in Bovingdon be revisited.
Chesham Road/Molyneux Avenue (Growth Area Bv02 - Chesham Road and Molyneaux Avenue)
Availability;
Within the Site Allocations 2006-2031 document adopted in July 2017, the site is allocated under reference LA6 (Chesham Road / Molyneaux Road) for 60 dwellings. This site is due to bring forward homes from 2021 onwards, in accordance with Policies CS3: Managing Selected
Thakeham House, Summers Place, Stane Street, Billingshurst, West Sussex, RH14 9GN
www.thakeham.com
Company Registration No. 07278594. Registered Office Address: Thakeham House, Summers Place, Stane Street, Billingshurst, West Sussex, RH14 9GN
Development Sites. The document allows flexibility for these sites to come forward sooner than 2021 if required – for example if the Council cannot demonstrate a sufficient five-year housing land supply. The Council cannot currently demonstrate a five-year housing land supply (as demonstrated in a recent Appeal Decision)yet the Molyneux Avenue site has still not come forward for development. The Site Allocations document acknowledges there will need to be a lead-in period in order to allow practical delivery from 2021, as no planning applications have been submitted to date on the site (as of 25th February 2021). The delivery of this site is uncertain and unlikely to come forward this year. It is also relevant that this site’s capacity has been re-assessed as being suitable for 40 dwellings (as opposed to the original 60 allocated in July 2017). This 33% reduction in site capacity strongly suggests that physical constraints to development have been identified, which calls into question the robustness of the decision to re-allocate the site in the draft Plan.
There is doubt over the availability and perhaps even achievability of this site, which are tests of ‘deliverability’ in the NPPF. Proof of availability should be sought to ensure this site can come forward in the timescales expected.
Suitability;
Thakeham raises the following constraints which have a bearing on the suitability of the Chesham Road/Molyneaux Road site for residential purposes;
• Archaeology - As demonstrated in the examination documents associated to the Site Allocations document 2017, the County Archaeologist stated that due to the site’s proximity to the historic Bovingdon Airfield (which is of significance to World War Two), there is the risk of archaeological remains on site. In addition, the archaeologist noted that based on the surrounding area, there is also potential for prehistoric and Roman remains meaning that there may be archaeological findings worthy of preservation in situ. This may affect the developable area of the site as well as timeframes for delivery. • Reservoir – Due to the existence of a large steep-sided drainage reservoir within the bounds of the site, Thakeham questions the suitability of developing so close to this hazard. Thakeham questions whether reservoir breach scenario modelling is required and if so whether this work has been completed, as this may have a serious impact on the developable area. • Off-Site Highways Works – The previous site allocation (LA6) incorporated a number of highways and access principles (page 33) including off-site road junction improvements where appropriate. In the proposed policy wording in the draft Local Plan, Thakeham questions why there is no longer the requirement to provide off-site road junction improvements. • Connectivity/Sustainability: The Council itself states in the Sustainability Appraisal that there is “a busy road separating the site from the village centre which may pose an accident risk and discourage the elderly, disabled people and children from moving
Thakeham House, Summers Place, Stane Street, Billingshurst, West Sussex, RH14 9GN
www.thakeham.com
Company Registration No. 07278594. Registered Office Address: Thakeham House, Summers Place, Stane Street, Billingshurst, West Sussex, RH14 9GN
around freely in the area.” On this basis, Thakeham questions the suitability of the site, if families/elderly may be discouraged from walking into the village. • Easements – As shown in the ‘Adopted Master Plan for Local Allocation LA6 document, there is a gas pipeline which crosses the site in multiple areas which will have an easement corridor that will need to be respected and no construction will be permitted within the easement, therefore the quantum of development on the site will be limited. The Council should therefore ensure that the proposed scale of development is appropriate considering the need to avoid the easement corridor, Thakeham would also question whether any diversions would be needed which may impact the viability of the site. • Private Foul and Surface Water Pipe – Thakeham would like to highlight that whilst the Site Allocations 2006-2031 document at Policy LA6 mentioned that a combined private foul and surface water pipe crosses the site (paragraph 4.38), this constraint is not shown on the plan on page 27 of that document. Since this will require an easement, it may also impact upon the developable area.
Site Allocations 2006-2031 Policy LA6 Allocation Constraints Plan – Page 27
• Ecology – In the Council’s Sustainability Appraisal (November 2020), the site is said to be within “a high value local biodiversity wildlife corridor” (page 277). Thakeham questions whether appropriate buffers to the existing ecological habitat have been considered as part of the capacity study on the site. The developable area of the site should be updated to respect the required buffer zones. Flooding - Thakeham questions the suitability of the proposed allocation due to its risk of surface water flooding. Thakeham also raises concern that the policy wording (page 331 in the draft Local Plan) states “Surface water run-off rates as a result of development of the site should not exceed existing Greenfield run-off rates.” This policy would appear to contradict the Council’s Delivery Strategy under Paragraph 23.183 (draft Local Plan) which states one of the focus points for development in Bovingdon is “flood alleviation measures”. Notwithstanding the current surface water flood risk on
Thakeham House, Summers Place, Stane Street, Billingshurst, West Sussex, RH14 9GN
www.thakeham.com
Company Registration No. 07278594. Registered Office Address: Thakeham House, Summers Place, Stane Street, Billingshurst, West Sussex, RH14 9GN
site and its proximity to an existing reservoir, in order to align with its Delivery Strategy, the Council should insist that the greenfield run off rate be bettered, not just replicated.
• Community Cohesion/Neighbouring Site Uses – as raised in the Sustainability Appraisal of the site (Page 278) it is acknowledged that the site is located near the existing prison which could result in anxiety related to the fear of crime. Thakeham questions the suitability of the site for residential purposes given its proximity to both the existing prison and Airfield. Thakeham also questions whether there is the market demand to live in this particular location and whether this would impact upon the financial viability of the site.
To conclude, Thakeham’s assessment of the Chesham Road/Molyneux Avenue allocation demonstrates that there are serious concerns that the site does not meet the test of being deliverable as there are a number of issues regarding the availability, achievability and suitability.
As will be demonstrated within these representations, Land at Fox Meadow withstands the tests of ‘deliverability’ and provides new homes and amenities for the wider public benefit. In short, Land at Fox Meadow should be considered a more appropriate site allocation than the Chesham Road/Molyneux Avenue site.
Grange Farm (Growth Area Bv01: Grange Farm)
Suitability;
Thakeham would also like to raise the following concerns which have a bearing on the suitability of this site:
• Land for a school - as part of the draft allocation, this site is expected to safeguard land for a primary school to replace the current school. Assuming the new school is built (notwithstanding the afore-mentioned doubts over sources and timescales of funding), the location is remote from the majority of the population of the village. Further, the footpath link on Chesham Road is too narrow for parents and children,
Thakeham House, Summers Place, Stane Street, Billingshurst, West Sussex, RH14 9GN
www.thakeham.com
Company Registration No. 07278594. Registered Office Address: Thakeham House, Summers Place, Stane Street, Billingshurst, West Sussex, RH14 9GN
particularly those with prams, bicycles and scooters. On the south western part of Green Lane the pavement is not continuous and there would be no way of installing a pavement without encroaching upon The Village Green. This is likely to result in the majority of trips to the school being made by car and will exacerbate the village’s existing congestion and parking problems (as acknowledged in the Council’s Topic Paper on Development Strategy). Thakeham also raises the question of whether the allocation of Grange Farm can be justified through provision of space for a new school. The development of such a school will depend upon funding and until that funding is available the “safeguarded land” will remain unused and without benefit to the local community. At the very least, the Council should investigate (and provide an indication of) how long it may be before such funding for the new school is available. Further, does the timescale for such funding satisfy the ‘exceptional circumstances’ required to justify the release of Green Belt at Grange Farm?
• Access – whether or not the new school is built, the new residents at Grange Farm would have to use existing inadequate footpaths (as described above) to access the village’s services and facilities, the majority of which are on the High Street which is some distance from this site.
• Flooding - Thakeham questions the suitability of the proposed allocation due to the risk of surface water flooding. Thakeham also raises concern that the policy wording (page 329 in the draft Local Plan) states “Surface water run-off rates as a result of development of the site should not exceed existing Greenfield run-off rates”. This policy would appear to contradict the Council’s delivery strategy under Paragraph 23.183 (draft Local Plan) which states one of the focus points for development in Bovingdon is “flood alleviation measures”. It is well documented that the junction of Green Lane / Leyhill Road is flooded on a regular basis as shown on the EA flood map extract below. Notwithstanding the current surface water flood risk on site, in order to align with its delivery strategy, the Council should insist that the greenfield run off rate be bettered, not just replicated.
Thakeham House, Summers Place, Stane Street, Billingshurst, West Sussex, RH14 9GN
www.thakeham.com
Company Registration No. 07278594. Registered Office Address: Thakeham House, Summers Place, Stane Street, Billingshurst, West Sussex, RH14 9GN
• Contaminated Land – it is noted in the draft Local Plan policy that investigations are required to assess whether the site is suitable for its intended use. This exercise should already have been completed to ensure that this is a deliverable site in order to be proposed as a draft allocation as otherwise this could undermine the Council’s Delivery Strategy.
Achievability
The justification for Grange Farm being removed from the Green Belt and included as a draft allocation appears to be due to the fact it will safeguard land for a new primary school. Indeed, there is no stated commitment regarding the timing of and responsibility for the delivery of a completed school nor is there any certainty of the source of funding for the construction of the new school given there are insufficient housing allocations in Bovingdon to fund a new school. Therefore, as currently presented, the draft Local Plan does not meet the Council’s own vision for the Bovingdon and Thakeham questions whether it is a suitable strategy to safeguard the land without having funding for a new school at this stage.
The Bovingdon Delivery Strategy set out in the draft Local Plan makes several references to proposals at Grange Farm being linked to opportunities to deliver a package of housing, parking and community benefits. It is not clear how this will work in practice and in order to provide certainly that this is feasible, further details should be provided. Any perceived benefits need to be weighed against the advantages of the current arrangement where having the services and facilities centrally located means that linked trips can be made, thus helping the viability of the shops and cafes on the High Street.
To conclude, Thakeham’s assessment of the Grange Farm allocation demonstrates that there are serious concerns that the site does not meet the test of being deliverable as there are a number of issues regarding the achievability and suitability of the site – especially in relation to flooding, the sustainability of the site given the reliance on vehicular transport and concerns with the deliverability of a new primary school. As demonstrated within these representations, Land at Fox Meadow can meet this test and provide new homes and community uses for the wider public benefit.
Land at Fox Meadow, Bovingdon
As shown in the appended Vision Document, this Site could deliver approximately 50 new homes including much-needed affordable homes, a new community / Scout hall, junior sports pitch and play space for the benefit of the wider community.
Thakeham House, Summers Place, Stane Street, Billingshurst, West Sussex, RH14 9GN
www.thakeham.com
Company Registration No. 07278594. Registered Office Address: Thakeham House, Summers Place, Stane Street, Billingshurst, West Sussex, RH14 9GN
AECOM Report – Correction
It appears from a review of the Council’s evidence base, that the Site was not pursued as a potential allocation as a result of its assessment under site number 34/34a in AECOM’s report (Site Assessment Study for Dacorum Borough Council Volume 3: Final Site Schedules dated January 2020). The Site was incorrectly assessed within the report on the basis of the red line being inaccurate. Despite previous submissions to the Council demonstrating that the Site boundary extends to the junction of Louise Walk/Green Lane, the access land was excluded from the AECOM assessment. On Page 42 of AECOM’s assessment it concluded “The site is not directly accessible from the local road network and would require access via Site 39 'Homefield' and/or from Louise Walk (across intervening land not within the site promoter’s ownership)”. Further, this Assessment states that the site is “susceptible to surface water flooding” which contradicts the Environment Agency’s mapping. Thakeham requests that the Council corrects this and re-considers the merits of the Site as part of its next review.
Notwithstanding these errors, the overall site conclusion is “Site performs reasonably across a number of different criteria including Green Belt, agricultural land, and transport. However, it performs poorly on spatial opportunities and constraints. This is, however, easy to mitigate through appropriate amendment of site boundaries, with the southern part of the site excluded and the new boundary known as site 34a for the purposes of this study; this would also improve its performance on the transport criterion in terms of accessibility to the rest of the settlement. The allocation of 34a could be offset by compensatory improvements to that part of the site not allocated but remaining within the Green Belt and in the same ownership, in line with NPPF paragraph 138. Subject to this amendment, site considered potentially suitable for allocation with major constraints”. As demonstrated in the Vision Document, the proposed layout respects these conclusions by focusing development on the area referred to as 34a and the remainder of the Site will remain largely undeveloped due to the Site’s proposed sports use, which is protected in Paragraph 97 of the National Planning Policy Framework (NPPF).
Availability
The Site and its access via Louise Walk is controlled in its entirety by Thakeham, who will construct development on the Site, with no impediments to development.
Suitability
The Site is located in the village of Bovingdon, less than 650 metres (0.4 miles) from the village centre which offers a wide range of facilities and services including primary school, doctors’ surgery, dentist, convenience stores, independent retailers, hairdressers, post office, public houses and restaurants. It is also immediately adjacent to two local sports clubs and close to
Thakeham House, Summers Place, Stane Street, Billingshurst, West Sussex, RH14 9GN
www.thakeham.com
Company Registration No. 07278594. Registered Office Address: Thakeham House, Summers Place, Stane Street, Billingshurst, West Sussex, RH14 9GN
the cricket club. All local amenities are within easy walking and cycling distance, Bovingdon Primary School and High Street are a 10 minute walk from the Site.
The area surrounding the Site has an edge of settlement character and appearance with considerable residential influences. To its western boundary lie a tennis club and a football club with their associated buildings and car parking. The Site is not within/close to a Conservation Area nor any statutory or locally designated ecological site. As such, given the Site’s sustainable location, proximity to the centre of Bovingdon and the need for minimal infrastructure provision, the Site is considered to be suitable for residential development. This is considered in more detail below.
Achievability
For a scheme of this size the intention would be to make a full planning application meaning it will therefore be possible to implement the scheme immediately following the discharge of any relevant pre-commencement conditions. The Site would therefore deliver new homes within the first five years of the plan period and should be considered achievable for development in accordance with the NPPF.
Land at Fox Meadow Site Assessment
The Site has been assessed in the supporting evidence to the ‘Dacorum Local Plan (2020 - 2038) Emerging Strategy for Growth’ consultation.
A summary of the Council’s assessment of the Site is displayed in the table below (source: Dacorum Local Plan (2020-2038) Emerging Strategy for Growth Interim Sustainability Appraisal Report – Appendices (November 2020);
Thakeham House, Summers Place, Stane Street, Billingshurst, West Sussex, RH14 9GN
www.thakeham.com
Company Registration No. 07278594. Registered Office Address: Thakeham House, Summers Place, Stane Street, Billingshurst, West Sussex, RH14 9GN
Fox Meadow, Bovingdon Biodiversity ?
Water ?
Flood Risk - Climate Change √ Air Quality √ Soils ** Resource Efficiency ? Historic Environment - Landscape/ Townscape X Health and Wellbeing √ Sustainable Locations √ Community Cohesion √ Housing √ Sustainable Prosperity √
Employment and Skills √
Thakeham notes that some of the criteria has either not been fully assessed or has been incorrectly assessed. In the below points, Thakeham provides additional information in relation to Biodiversity, Water and Resource Efficiency as a result of the Council’s ‘?’ grading to allow the Council to fully assess the Site:
• Biodiversity – Thakeham is committed to delivering at least a 10% Net Biodiversity Gain on all of its development sites, working closely with charities such as The Wildlife Trust, in order to achieve these goals. Therefore, the assessment should score the site as • Water – Thakeham has committed as part of its published Sustainability Strategy that all sites will have targets to protect the resilience of the green and blue infrastructure for future generations. Thakeham is committed to designing and building water efficient developments and homes by mitigating flood risk through the installation of Sustainable urban Drainage Systems (SuDS) in a way that enhances biodiversity and protects water resources by minimising water consumption during the construction phase. Beyond this, Thakeham is researching water neutrality and is seeking to reduce the demand for potable water, by investigating rainwater harvesting at a development- scale as part of a system towards water neutrality with the aim to mitigate future water stresses and support resilience. Based on the above, the assessment should score the Site as • Resource Efficiency - Thakeham has also committed as part of its published Sustainability Strategy to move all materials and systems towards a circular economy.
Thakeham House, Summers Place, Stane Street, Billingshurst, West Sussex, RH14 9GN
www.thakeham.com
Company Registration No. 07278594. Registered Office Address: Thakeham House, Summers Place, Stane Street, Billingshurst, West Sussex, RH14 9GN
Thakeham is committed to eliminating the impact of the production of homes through targeting carbon emissions, Modern Methods of Construction, waste, and water and is developing a Responsible Procurement Policy which promotes products with the lowest social and environmental impact. Thakeham has committed to be carbon neutral in production from 2025, which includes the process of material selection, transport, construction, and disposal. This will be achieved through a variety of ways including through making informed product choices, reducing waste and transportation, stakeholder engagement to improve the availability of sustainable resources, and investments in renewable energy. Any construction waste diverted from landfill through reuse off-site, recovery, and recycling will be measure, with the target being a 100% landfill diversion rate. Therefore, the assessment should score the site as .
Thakeham disagrees with the Council’s assessment of the Site against the criteria ‘Soils’ and ‘Landscape/Townscape’ criteria and has provided an alternative assessment below.
Soils
As shown by page 43 of the Interim Sustainability Appraisal Report Appendices, the Site has been assessed as “red’” against the soils criteria on the basis the Site is identified as ‘Grade 2’ on the Natural England Agricultural Land Classification map Eastern Region (ALC008) dated 2010. Thakeham raises concern with the evidence used by the Council to assess all the sites against the criteria, as the map does not go into sufficient detail. This is accepted by Natural England as when downloading the map from the Natural England website, the following is stated ‘These maps are not sufficiently accurate for use in assessment of individual fields or sites and any enlargement could be misleading. The maps show Grades 1-5, but Grade 3 is not subdivided.’
Thakeham is of the view that in order for each site to be assessed sufficiently, a desk-based study and field survey is required to assess the factors that affect each site – for instance, climate: temperature and rainfall, aspect, exposure and frost risk, site: gradient, micro-relief and flood risk and soil: texture, structure, depth and stoniness, chemical properties. Only after an appropriate study has been taken place can the sites really be given an accurate agricultural land classification.
Thakeham would also like to highlight that the map is not displayed at a suitable scale for assessing individual sites. As shown by the extract below, Thakeham is of the view that the Site appears to be coloured Green ‘Grade 3’ but even if the Land at Fox Meadow is considered Grade 2 Agricultural Land this should also apply to the adjacent site ‘Land at Homefield’, where this is assessed as in same assessment rather than .
Thakeham House, Summers Place, Stane Street, Billingshurst, West Sussex, RH14 9GN
www.thakeham.com
Company Registration No. 07278594. Registered Office Address: Thakeham House, Summers Place, Stane Street, Billingshurst, West Sussex, RH14 9GN
Extract - Natural England Agricultural Land Classification map Eastern Region (ALC008) dated 2010.
Whilst the Council has not provided sufficient evidence to assess a site’s agricultural land classification, even if the land was assessed to be of Grade 2 quality, the loss of land at the Site would not significantly harm national, regional or local agricultural interests and it would not result in the fragmentation of any agricultural holdings that would undermine the economic viability of the remaining holding. The Site is adjacent to the existing settlement and other land, further from existing settlements, would have far greater agricultural use as part of a wider network of connected, undeveloped land. The Site is no longer suitable for agricultural use and due to its location, the Site is a better and more sustainable location for housing development and community uses such as the scout hall and playing fields.
Landscape/Townscape
As noted in the Council’s Stage 2 Green Belt Study (dated December 2016), the site forms part of a larger parcel (Parcels BV-A5) which is considered to make a weak contribution to the purposes of the Green Belt (page. 71). The Site is visually well contained with strong defensible boundaries.
As stated in AECOM’s Site Assessment Study (dated January 2020) instructed by the Council as part of its evidence gathering, no Landscape/Townscape issues are identified with the Site (Fox Meadow) “The site is not within the Chilterns AONB and would be unlikely to impact the setting of the Chilterns AONB due to distance and intervening features. The site is within LCA 107 of the DLCA; the condition of the LCA is described as moderate, and the strength of character is described as moderate. The site is on flat ground and comprises a single field of pasture. The site adjoins residential land uses in Bovingdon to the north-west and is enclosed by mature tree belts to its north-east and south-east. Overall, the site is judged to perform well on this criterion.” Page 42.
Thakeham House, Summers Place, Stane Street, Billingshurst, West Sussex, RH14 9GN
www.thakeham.com
Company Registration No. 07278594. Registered Office Address: Thakeham House, Summers Place, Stane Street, Billingshurst, West Sussex, RH14 9GN
The same report does raise concern with the southern-most parcel as it could represent “an extension of the existing settlement into open countryside”. Thakeham would like to draw the Council’s attention to the amended masterplan submitted within the Vision Document, in which the southernmost parcel incorporates a junior football pitch and single storey community scout hut and associated parking. Thakeham is of the view that this proposal respects the report’s concerns.
Site Comparison to Proposed Allocations
A summary of the Council’s assessment of the Site compared to the proposed site allocations is displayed in the table below;
Chesham Road/ Fox Meadow, Bovingdon Grange Farm Molyneaux Avenue Biodiversity ? X X
Water ? ? ? Flood Risk - ? - Climate Change √ √ √ Air Quality √ √ √ Soils ** ** X Resource Efficiency ? ? ? Historic Environment - ? - Landscape/ Townscape X X X Health and Wellbeing √ √ √ Sustainable Locations √ √ √ Community Cohesion √ √ X Housing √ √ √ Sustainable Prosperity √ √ √ Employment and Skills √ √ √
A comparison between the Site and the proposed allocations against the assessment criteria is detailed below.
Biodiversity As outlined in the Sustainability Appraisal, the proposed site allocations are either adjacent a Local Wildlife Site (Grange Farm) or within “a high value local biodiversity wildlife corridor” (Chesham Road and Molyneaux Avenue – page 277). The Site is located in a less-sensitive biodiversity area and will deliver biodiversity enhancements on site and should therefore be marked Water Thakeham has committed to working towards water neutrality. Based on these commitments, the Site should be marked
Thakeham House, Summers Place, Stane Street, Billingshurst, West Sussex, RH14 9GN
www.thakeham.com
Company Registration No. 07278594. Registered Office Address: Thakeham House, Summers Place, Stane Street, Billingshurst, West Sussex, RH14 9GN
Flood Risk Unlike the two proposed allocations in Bovingdon, the Site is not at risk of surface water flooding. Given the extent of surface water flood risk of the proposed site allocations as set out in the Council’s own evidence base, Thakeham is of the view the other sites should be marked . As the Site is in Flood Zone 1 with no surface water flooding risk, it should be marked Soils Grange Farm and the Site have been assessed as “ ’” against the soils criteria on the basis that both sites have been identified as ‘Grade 2’ on Natural England’s map. Thakeham raises concern with the evidence used to assess the sites, as the map does not go into sufficient detail and that other factors as outlined above need to be considered. Due to the size of the Site and its proximity to existing an residential area and the village centre, even if the land was assessed to be of Grade 2 quality, the loss of land at the Site would not significantly harm national, regional or local agricultural interests. Based on the above, Thakeham is of the view that the Site should be marked . Due to the size of the Grange Farm site this would lead to a larger scale loss of potentially higher grade agricultural land and as it is both a larger piece of land and further from the existing village centre of Bovingdon, it be a greater loss of agricultural land. Therefore, Thakeham is of the view that Grange Farm should remain Resource As referred to above Thakeham has publicly committed to reducing Efficiency construction waste, working towards a circular economy. Based on Thakeham’s commitments, the Site should be marked Historic Given the scale of the proposed development at Grange Farm and that there Environment is a Grade II Listed Building (White Hart Cottage) in close proximity to it north-west boundary, Grange Farm should be assessed as as its’ development will have an impact on the setting on the Listed Buildings. Given the evidence above regarding archaeology risk on Chesham Road/Molyneux Avenue, the site should also be marked based on its proximity to the historic Bovingdon Airfield and risk of archaeological remains (prehistoric and Roman) being on-site. Landscape/ Whilst Thakeham notes all sites are in the Green Belt, the Site has been Townscape assessed to make a weak contribution to the purposes of the Green Belt and is visually well contained with strong defensible boundaries. The Site adjoins residential land uses in Bovingdon to the north-west and is enclosed by mature tree belts to its north-east and south-east. Given the sensitivities of the Green Belt designation, Thakeham is of the view the Site’s assessment should remain but is of the view that Grange Farm would lead to a significant encroachment into the Green Belt and wider countryside and should therefore be marked
Thakeham House, Summers Place, Stane Street, Billingshurst, West Sussex, RH14 9GN
www.thakeham.com
Company Registration No. 07278594. Registered Office Address: Thakeham House, Summers Place, Stane Street, Billingshurst, West Sussex, RH14 9GN
Health and The Site is the only site allocation that would deliver tangible health and Wellbeing wellbeing benefits in the short term (given the uncertainty regarding the deliverability of a new primary school at Grange Farm). The Site will provide community space to enable clubs and classes as well as a new football pitch which will benefit the health and wellbeing of the wider village. Thakeham is of the view that as Chesham Road/Molyneaux Avenue does not provide any facilities, it should be marked Sustainable Whilst all three sites have been assessed the same, Thakeham would like Locations to raise that Grange Farm is located the furthest from the village centre of Bovingdon in the least sustainable location of the site options and therefore is likely to have a higher reliance on travel by private car and generate considerable traffic movements. Thakeham would also point out that the Council’s own assessment of Chesham Road/ Molyneaux Avenue in the Sustainability Appraisal states the busy road may pose an accident risk and discourage people from walking into the village. On that basis, Thakeham is of the view that Grange Farm and Chesham Road/ Molyneaux Avenue should be marked Community As Grange Farm is only delivering land for a primary school opposed to a Cohesion new school, the site should be assessed as as land only will not deliver any community benefit during the Plan period. Thakeham’s site, with its new community facilities and improved links to adjacent sports facilities is the only site out of the three that facilitates community cohesion.
Thakeham has demonstrated in these representations that the proposed allocations do not provide as many community benefits as the Land at Fox Meadow. Following the proposed amendments above, Thakeham is of the view the Council’s assessment of the sites should be as follows; Chesham Road/ Fox Meadow, Bovingdon Grange Farm Molyneaux Avenue Biodiversity √ X X
Water √ ? ? Flood Risk √ X X Climate Change √ √ √ Air Quality √ √ √ Soils X xx X Resource Efficiency √ ? ? Historic Environment - X X Landscape/ Townscape X xx X Health and Wellbeing √ √ X Sustainable Locations √ X X Community Cohesion √ X X Housing √ √ √
Thakeham House, Summers Place, Stane Street, Billingshurst, West Sussex, RH14 9GN
www.thakeham.com
Company Registration No. 07278594. Registered Office Address: Thakeham House, Summers Place, Stane Street, Billingshurst, West Sussex, RH14 9GN
Sustainable Prosperity √ √ √ Employment and Skills √ √ √
General Planning Policies within the draft Local Plan
Thakeham would also like to take this opportunity to comment on the Council’s Guiding Development policies within the draft Local Plan. Thakeham has commented below on the following policies;
• Policy SP7 – Delivering Infrastructure • Policy SP10 - Climate Change Mitigation and Adaptation • Policy DM2 – Affordable Housing • Policy DM8 – Custom and Self Build Housing • Policy DM10 – Accessible and Adaptable Homes • Policy DM23 - Energy and Carbon Emissions Reductions in New Development • Policy DM22 – Sustainable Design and Construction • Policy DM36 – Tree Retention and Protection • Policy DM41 – Height of Buildings
Policy SP7 – Delivering Infrastructure
The draft Local Plan states under Policy SP7 ‘Delivering Infrastructure’ Item 1 that
“All new development will be required to provide for the necessary on-site and, where appropriate, off-site infrastructure requirements arising from the proposal in order to:
a) meet the needs arising from the development so as to avoid placing additional burden on the existing infrastructure;
b) avoid or mitigate adverse social, economic and environmental impacts arising from the proposed development; and
c) make good the loss or damage of social, economic and environmental assets arising from the proposed development.”
As an infrastructure-led developer, Thakeham supports the inclusion of Policy SP7 which provides clear guidance on how the Council will seek to ensure the delivery of the necessary infrastructure to support new developments. It is important that this approach is translated into the site allocations themselves, and the requirements for the developments, to ensure that the aspirations of Policy SP7 are delivered in practice. We suggest that appropriate wording should be added to the Policy to ensure infrastructure is provided as early as possible in the delivery of new communities.
Thakeham House, Summers Place, Stane Street, Billingshurst, West Sussex, RH14 9GN
www.thakeham.com
Company Registration No. 07278594. Registered Office Address: Thakeham House, Summers Place, Stane Street, Billingshurst, West Sussex, RH14 9GN
Policy SP10 - Climate Change Mitigation and Adaptation
Items 1 and 2 under Policy SP10 state that “All development is required to mitigate and adapt to climate change and to actively pursue the reduction of carbon dioxide emissions.” and “The policy will be applied to ensure that all new development in the Borough is net zero by 2030.”
Thakeham supports the Council’s decision to declare a climate change emergency in July 2019 and supports its commitment to take action to make the Borough carbon neutral by 2030, 20 years before the Government’s Target.
Thakeham builds for the future, for communities and for individuals. Our approach sets us apart from our competitors. We deliver our schemes with a focus on sustainable development, looking ahead of current housing standards. Thakeham recognises fully the significance of climate change and is taking a highly proactive approach in responding to reducing carbon emissions. We have committed that by 2025, every Thakeham home will be Zero Carbon in lifetime operation.
Policy DM2 – Affordable Housing
Point 4 of Policy DM2 ‘Affordable Housing’ states that “All affordable housing should be genuinely affordable, with the expectation being that the cost will need to be substantially more than 20% below local market prices and rents”.
Whilst Thakeham supports the delivery of policy-compliant affordable housing on-site, it does not think it is appropriate for the Council to set the value of affordable dwellings as this has the potential to impact the viability of a scheme. National planning policy defines affordable housing, and the policy must accord with those definitions, which may change throughout the plan period.
Policy DM8 – Custom and Self Build Housing
Item 2 under Policy DM8 states that “On housing developments with 40 or more new houses, 5% of the house plots should be made available on site as serviced building plots to enable the delivery of self and custom build properties”. In order to allow flexibility to reflect the changing demands for self-build and its potential impact on a site’s viability, Thakeham would like to request that the requirement is amended to “up to 5% of the house plots” and also that the threshold to which this policy applies is increased.
Thakeham is concerned that the area of land which would be required to deliver such plots on smaller sites, coupled with 40% affordable housing, would be disproportionate and could impact the viability of a scheme. Further there are logistical, as well as Health and Safety, implications of trying to accommodate self-build plots on a small site. Thakeham would suggest
Thakeham House, Summers Place, Stane Street, Billingshurst, West Sussex, RH14 9GN
www.thakeham.com
Company Registration No. 07278594. Registered Office Address: Thakeham House, Summers Place, Stane Street, Billingshurst, West Sussex, RH14 9GN
that self and custom build provision would be more appropriate on larger schemes – those with 100 dwellings or more.
Policy DM10 – Accessible and Adaptable Homes
Table 9 of Policy DM10 ‘Accessible and Adaptable Homes’ sets out the percentage of each housing type and tenure under Building Regulations to be included within housing developments. Whilst Thakeham supports the provision of affordable, accessible and adaptable dwellings, we raise concern that the requirement specifically for M4(3) units is high and the level should be agreed on a site by site basis, considering current need, location, scheme viability and impact on density.
Policy DM23 - Energy and Carbon Emissions Reductions in New Development
As a developer that is at the forefront of targeting zero carbon on all its developments from 2025, Thakeham supports the Council’s general approach to making the Borough carbon neutral by 2030. We do however suggest a slight adjustment to Policy DM23 - under point 1a the policy states;
“For all new major residential development, i. an energy performance standard equivalent to at least 19% carbon emissions reduction on the Dwelling Emission Rate (DER) against the Target Emission Rate (TER) based on Part L of the Building Regulations (2013) whilst meeting the Target Emission Rate (TER) solely from energy efficiency measures as defined within the SAP calculation model”.
Thakeham is of the view that this target should be updated to 31% in line with the Future Homes Standard in order to future proof policy so that it is robust and does not need to be reviewed in the short-term.
Policy DM22 – Sustainable Design and Construction
Whilst Thakeham supports the Council’s general approach to mitigating for the impacts of climate change, we have concerns over point 3c in the Policy, namely to;
“Incorporate green infrastructure to sequest carbon, to include two or more new trees (a tree shall be considered to count if it ordinarily reaches a mature height of 6 metres or more) per dwelling or per 100 sq m floor space (for non-residential developments) on-site.” This policy could conflict with Policy DM11, which seeks to set minimum housing densities, as increasing the number of dwellings on a site reduces the land available for tree planting.
Thakeham House, Summers Place, Stane Street, Billingshurst, West Sussex, RH14 9GN
www.thakeham.com
Company Registration No. 07278594. Registered Office Address: Thakeham House, Summers Place, Stane Street, Billingshurst, West Sussex, RH14 9GN
Thakeham is of the view that focussing on quality, location and species of the tree is likely to deliver better results than focussing on quantity. We would further question how the landscape design of a smaller scheme would work – for instance, if it was required to deliver 100 trees on a development of 50 homes. Thakeham believes more achievable targets for example ‘like- for-like’ replacement on all trees required to be removed for development, one new tree per dwelling or a specified percentage in line with achieving Biodiversity Net Gain would be more appropriate mitigation options. Thakeham supports a target of achieving at least a 10% Biodiversity Net Gain on all new housing sites. Thakeham also notes that item 4. c of the policy states “Deliver an overall net-biodiversity gain and positive measures to support wildlife”. Thakeham is of the view that this item should be updated in line with Policy DM30 ‘Biodiversity Net Gain’ which requires a 10% biodiversity net gain to be achieved and managed.
In addition, Item 4. d states “Use permeable ground surfaces” however Thakeham would like to request that flexibility is added into the policy wording as permeable surfaces are not always a suitable option due to site-specific ground conditions and/or sites with limited area for surface water attenuation.
Policy DM36 – Tree Retention and Protection
Whilst Thakeham supports the Council’s general approach to requiring developers to protect and enhance existing trees and promote tree planting, we question the suitability and achievability of item 1 in the policy which states “Developers will be expected to protect and retain existing trees and hedgerows as part of development proposals, and to replace them where their loss is justified. All development will be expected to incorporate two or more new trees per dwelling or per 100 sq m floor space (for non-residential developments) on-site. Where a tree is lost through development at least three new 'like for like' trees must be provided.”
Thakeham is of the view that focussing on quality, location, and species of the tree is likely to deliver better results than focussing on quantity. Further, we would question how the landscape design of a smaller scheme would work if it was, for instance, required to deliver 100 trees on a development of 50 homes. Thakeham also questions the practicability of replacing a tree with three new ‘like for like’ trees as quite often, poor quality trees tend to be earmarked for removal. Thakeham believes either more achievable targets like one for one replacement on all trees/one for one new tree to dwelling ratio or a specified percentage for achieving biodiversity net-gain would be more a more appropriate mitigation. Thakeham supports a target of achieving at least a 10% biodiversity net-gain on all new housing sites.
Thakeham House, Summers Place, Stane Street, Billingshurst, West Sussex, RH14 9GN
www.thakeham.com
Company Registration No. 07278594. Registered Office Address: Thakeham House, Summers Place, Stane Street, Billingshurst, West Sussex, RH14 9GN
Policy DM41 – Height of Buildings
Thakeham would like to highlight inconsistencies between the wording within Policy DM41 and wording in Table 27 of the supporting text to the Policy. Table 27 states that building heights of up to three storeys will be acceptable in all areas of the Borough, however Item 1.e.i. of Policy DM41 limits this to two storeys ‘elsewhere in Dacorum’.
We suggest that Item 1.e.i. of Policy DM41 is updated in line with Table 27 to state 3 storeys. Whilst Thakeham understands the importance of ensuring new developments are of an appropriate scale and massing, it is of the view the Council should not limit 2.5 or 3 storey dwellings, where these can provide additional habitable space, in order to create efficient use of land and allow the Council to meet its density requirements set out under Policy DM11.
Conclusion
These representations incorporate Thakeham’s comments on both the draft Local Plan Guiding Development policies and the proposed site allocations within Bovingdon. As demonstrated above within these representations, Thakeham raises concerns to the Council’s approach to growth in the Borough, especially in Bovingdon, as well as identifying issues with the deliverability of the Council’s proposed Bovingdon site allocations.
Thakeham respects the sensitive nature of the removal of Green Belt sites and is of the view that, whilst removal is justified by the pressing need for new housing, sites need not only to provide new homes, but also new community facilities. Thakeham considers that the proposed Borough allocations are insufficient to meet the required housing need under the Government’s standard methodology, and that additional sites need to be allocated for residential development across the Borough but specifically in Bovingdon to ensure Bovingdon continues to contribute to the overall housing stock in the same proportions as it has to date. Other than the provision of a new school (whose funding and timescale is unknown), there are no new community facilities proposed for Bovingdon in the current draft Local Plan. The two proposed allocations conflict with the vision for Bovingdon that is set out within the draft Local Plan.
As concluded by the Council’s own assessment, the Site performs well on a number of identified criteria. Whilst the Council seems to be of the view that other sites are less constrained and perform better against the Sustainability Appraisal assessment, Thakeham has demonstrated in these representations that the two proposed Bovingdon allocations do not provide as many benefits as the Site, which considerably out-performs the two proposed site allocations.
Land at Fox Meadow, Bovingdon is available, suitable and achievable and able to deliver housing within the first five years of the plan being adopted. As demonstrated in the appended Vision Document, the Site can deliver a new high-quality sustainable development, with both
Thakeham House, Summers Place, Stane Street, Billingshurst, West Sussex, RH14 9GN
www.thakeham.com
Company Registration No. 07278594. Registered Office Address: Thakeham House, Summers Place, Stane Street, Billingshurst, West Sussex, RH14 9GN
new homes and community benefits. Thakeham is an environmentally focused developer that is committed to delivering high quality, sustainable developments.
Including the Land at Fox Meadow as an allocation within the emerging Local Plan would enable the Council to plan positively to help meet the housing needs of the Borough by delivering sustainable development with significant community benefits which will meet the Councils’ Vision and spatial strategy aspirations.
We trust that these representations are clear, and we would be grateful for confirmation of receipt of our submission. In the meantime, please do not hesitate to contact me if you have any queries or require any further information.
Your faithfully,
Megan Green MRTPI Senior Planner
Thakeham House, Summers Place, Stane Street, Billingshurst, West Sussex, RH14 9GN
www.thakeham.com
Company Registration No. 07278594. Registered Office Address: Thakeham House, Summers Place, Stane Street, Billingshurst, West Sussex, RH14 9GN