Premdor Rockways Regeneration Masterplan
12th February 2013
Sible Hedingham Parish Council comments on Bloor Homes’ Premdor planning application - submitted to BDC 12th February 2013
The Parish Council has consulted its residents at every stage of the development of these plans, including most recently on the planning application now submitted by Bloor Homes. Overwhelmingly, the public have expressed their concerns about the size of this development and its impact on local infrastructure and village life. We have passed on those concerns repeatedly throughout several consultation exercises but do not feel that either BDC in its Masterplan, nor Bloor Homes in their planning application, have seriously addressed them, in spite of their respective Statements of Community Involvement. There is little or no evidence that any revisions have been made as a result of these consultations, and therefore the Parish Council, on the advice of the Department of Communities and Local Government and the Planning Inspectorate, feels obliged to rehearse those concerns once more.
The purpose of this document, over which we have taken some trouble, is not to attempt to stop redevelopment of the Premdor site. Whilst it does make formal objection to the planning application as submitted, it also strives to offer positive solutions to some of the challenges that the developers and planners face in realising the potential of this site to provide benefits to the community and developers in equitable measure, rendering it a truly regenerative and sustainable opportunity.
The Parish Council is confident that members of the Planning Committee will consider the submitted application in accordance with the National Planning Policy Framework, and BDC’s Core Strategy which is, effectively, its Local Plan. The NPPF states that it does not ‘change the statutory status of the development plan as the starting point for decision making. Proposed development that accords with an up-to-date Local Plan should be approved, and proposed development that conflicts should be refused unless other material considerations indicate otherwise.’
Notwithstanding the level of compliance of these plans with BDC’s Premdor ‘Master Plan’, SHPC believes that they still conflict with the following requirements of BDC’s Core Strategy, which should take precedence and form the basis of material planning considerations:
CS1: Housing Provision and Delivery:
‘On mixed use regeneration sites at Premdor/Rockways in Sible Hedingham ... The uses will include community facilities, open space and infrastructure requirements’
‘‘Mixed-use’ means that, because of the nature of the area, it should be used for a variety of purposes including housing, employment, community facilities and other development which may be needed to support the infrastructure’ (BDC Core Strategy)
In a presentation to Sible Hedingham’s Annual Parish Meeting in 2010, Planning Policy Manager, Eleanor Dash listed the Premdor Infrastructure Requirements. They included but were not limited to:
- •Additional places for early years and childcare facilities
- •Expansion of existing primary school
- •Expansion of existing secondary school
- •New GP surgery
- •Allotment provision
- •Quality Bus Partnership and Public Transport improvements
- •Highway requirements as specified by Essex County Council
SHPC do not believe that any of the above requirements are met by this application which has very little provision for employment, community facilities or any support for necessary infrastructure.
The ‘Economy’ section of the Core Strategy refers specifically to regeneration of the former Premdor site and adjoining Rockways premises in Sible Hedingham as follows:
Uses to include housing, employment, a doctors surgery, riverside nature reserve and open space and allotments’
Of these requirements, housing is clearly the major focus of the planning application. The nature reserve and open space either already exist or are dictated by the site’s inclusion of the flood plain. Whilst land is to be offered for a medical centre, its construction is by no means certain and the important provisions for employment and allotments are inadequate or simply absent.
The plans also fail to meet the following key objectives identified in the Core Strategy:
‘To reduce the need to travel by locating development in sustainable locations where it will enable people to access employment, housing, retail provision, public transport and key services; such as education, healthcare, recreational facilities and open space’
In direct contrast to this objective, the location of this proposed large housing development, where there is little or no provision of commuter public transport and few local employment opportunities or key services, will inevitably increase the need for travel by car.
Retail provision and recreational facilities are also very limited in Sible Hedingham, so new residents will be required to use their cars to access these services elsewhere. When SHPC suggested to BDC’s LDF Panel that mixed use of the site should include retail and recreational facilities they were told in no uncertain terms that they should not harbour expectations for such provision in a rural area. However, the NPPF requires planners to promote the development of local services and community facilities in villages, such as local shops, meeting places and sports venues. Also to focus significant development in locations which are or can be made sustainable and take account of and support local strategies to improve health, social and cultural wellbeing for all, and deliver sufficient community and cultural facilities and services to meet local needs.
If further housing is to be provided in Sible Hedingham, the Parish Council recommends that these and other developers are encouraged to bring forward plans which seriously address this issue of ‘sustainability’.
‘To ensure that development makes the necessary provision for infrastructure and community facilities to meet the existing and future needs ‘
Sible Hedingham’s road infrastructure is currently clearly inadequate and is already notorious for its congested roads and dangerous, pedestrian-unfriendly village centre. Neither of these issues is adequately expressed in the Transport Assessment accompanying these plans. (Further comments on the Transport Assessment are included in an appendix to this document.)
The traffic survey is based on the 2001 census data. This took place before the closure of the two largest employers in the Hedingham and Maplestead ward. From the 2011 census data, the average household in this ward now owns 1.69 cars so there has already been an impact caused by the reduction in the number of local jobs.
The new data shows that the number of households has risen by 170 but the number of extra vehicles in this ward since 2001 is 635 - or 3.7 cars for each new household - at a time when motoring costs have risen and car use in other parts of the country has fallen.
Furthermore, the Transport Assessment refers to the capacity of the A1017 to carry two-way traffic movements at the rate of 2000 per hour. Any local road user will testify that only relatively small stretches of the A1017 through Sible Hedingham enable two-way traffic. Contrary to the impression given by the report, parked vehicles obstruct traffic between Alderford Street in the south to beyond the Village Stores to the north of the village centre, causing multiple one-way situations and substantial queues.
The Parish Council advises that the planned development is not sustainable within the village’s current infrastructure and developers should be advised that further investment in road infrastructure needs to be considered.
Specific to the Premdor development, and of serious concern to many local residents, is the safety and practicality of the proposed junction of the exit road from the development onto the A1017.
No assessment of the interaction of the newly generated traffic between different elements of the junction has been undertaken. The safety audit and the design both assess the individual sightlines of the junctions and state that they are within the limits required by the standards. However, the junction must be looked at as a complete system. Both Rectory Road and Bewick Court/Premdor have approaches that have blind bends in both directions. The two junctions interact with each other. Drivers waiting to turn right into Swan Street at Rectory Road, when there is a vehicle waiting to turn right into Swan Street from Bewick Court or Premdor, will have to simultaneously monitor both directions for approaching traffic while judging whether the vehicle coming from Bewick Court/Premdor is likely to impede them. Buses stopping at the stop on the Sugar Loaves side can hold up a line of traffic which goes beyond the junction, leaving a gap to be negotiated with no line of sight to oncoming south bound traffic. In addition, at certain times there will be increased numbers of pedestrians crossing the junction or going to or from the bus stop on the Bewick Court/Premdor side, plus a vehicle waiting to turn right from Swan Street into Rectory Road. This junction is already dangerous, the narrowing of the road and the additional traffic emerging from Bewick Court/Premdor at peak times will only make it more so. The addition of a pedestrian crossing (the only remaining one of the three promised), will be insufficient to compensate for these risks. Added to this is the risk to drivers exiting the Library and the poor visibility which has not been considered at all in the MLM Transport Assessment. Our County Councillor has given his unconditional support for our request for a controlled crossing for the safety of all road users and in particular schoolchildren and for a roundabout to improve road safety at this junction and reduce overall speeds.
As the Transport Assessment itself states ‘Visits on-site with Essex County Council Officers confirmed the current junction visibility is not in accordance with recommended standards’
The Parish Council strongly advise that the design of this junction is revisited, taking into account the restricted visibility and complexity of decision-making which will be demanded from drivers and pedestrians. Further deaths and injuries from road accidents within our village must be avoided at all costs.
There is insufficient provision of parking for residents of the development. Those purchasing 3 or more bedroom dwellings may reasonably be expected to be families with children living at home.
While children are young, two spaces may be sufficient. However, when they reach employment age they will require their own vehicle due to the lack of local employment and the poor public transport, and that is when parking will become a problem. Residents will not be able to provide additional parking by losing part of their front garden because most of these residences have no front garden. Furthermore, there is zero provision for light commercial parking. Sible Hedingham has a high percentage of self employed contractors who own a van for business use. (Ref: http://www.neighbourhood.statistics.gov.uk)
Competition for parking can only spill into neighbouring roads and onto pavements. Parking that spills onto Swan Street will cause additional congestion and road hazard.
SHPC recommend that these factors should be taken into account in this instance and the developers should be encouraged to bring forward revised plans to address them, in excess of current BDC/ECC standards for parking provision which appear inadequate in this context.
‘To provide and retain employment to support the District’s economy in sustainable locations and to provide local employment opportunities, to seek to reduce travelling outside the District to work and to improve skills attainment’
The NPPF charges local planning authorities with the delivery of sustainable development as follows:
"To help achieve economic growth, local planning authorities should plan proactively to meet the development needs of business and support an economy fit for the 21st century. (1.20)"
By contrast, employment and business provision on this site has been systematically reduced and the area shown in the plans for its provision no longer matches the area set aside for Business and Community uses in the draft Site Allocations & Development Management Plan (SIB2E).
The area agreed within the Master Plan for a future surgery is 0.25 ha. The area, which also includes a small business hub, is shown as just 0.237 ha. To provide gardens and garages for plots 109 – 118, this area has been reduced and this is not acceptable. The design of Plot 116 is particularly odd looking to provide access to the rear of these properties and would not be in keeping with the street scene. By removing the majority of these properties from the plan entirely it would be possible to ensure that the correct amount of land is set aside for community use and at the same time to provide gardens of the minimum required size for those remaining. This would ensure that the plot for the proposed medical centre was of the agreed 0.25 ha and provide space for a larger business hub.
In a letter to Statutory Consultees in June 2012, BDC Planning Officer Emma Gooding, promised that the site would deliver ‘A community employment hub with office and light industrial space to help small and growing rural businesses’. The light industrial space has been withdrawn altogether and the ‘hub’ reduced to a small building offering, according to the Design and Access Statement, ‘reception, administration and flexible meeting spaces with ancillary space for storage’. Hardly sufficient to provide jobs for a potential increase in population of around 300+ people, let alone any regeneration of the local economy.
SHPC recommend that planning consent should be conditional on a full application for the work hub being submitted within a specified time limit. The construction must be completed before the commencement of stage two of the development to provide potential employment to new residents.
The Design and Construction Checklist suggests that local labour will be recruited in the construction of the development but it is not clear how this will be measured or monitored and so it is unlikely that such an undertaking can be enforced.
‘To make it safer and, easier for the community to travel to jobs and key services by improving sustainable forms of transport such as public transport, walking and cycling and seeking to reduce
The Design and Construction Checklist states that the site is in close proximity to bus stops. However, this fails to address the issue of the poor public transport service. Careful analysis of the Transport Assessment provided reveals that school buses have been included, as have services irrelevant to Sible Hedingham and one that is discontinued, so distorting the true picture. Furthermore, it ignores the fact that there are inadequate evening and weekend services, so access to leisure and recreational facilities in surrounding areas is severely limited. (Further comments on existing public transport are included in the appendix to this document.)
The offer of a contribution towards the proposed Sible Hedingham to Sudbury commuter service as a result of the SHPC business case is welcomed. However this contribution will only provide 1 year’s bus service which will be insufficient to determine the viability of a bus service. The service will only see peak demand if the first resident and the last resident move into the new development within the year of the bus trial. Residents who move in before the trial will find alternative solutions by the time the trial starts. Demand for the service will not reach its peak if residents are moving in after the trial. Suggested contributions for two existing bus shelters are not warranted as these particular bus shelters do not require upgrading. Apart from the upgrade of the existing shelter in Station Road, this contribution should also be used to fund the proposed service.
This development plan will worsen the dependence on private car journeys for this area. This is against Department of Transport priorities of "tackling congestion on our roads, continuing to improve road safety, encouraging sustainable local travel and promoting lower carbon transport, such as walking and cycling as well as introducing more environmentally-friendly buses and trains."
The reality is that there are very few employment, retail or recreational opportunities within walking, cycling, bus or train journeys of this development.
Key Service Villages
‘To maintain and develop the function of the key service villages to support the adjoining rural areas, by encouraging the retention and provision of employment, shops and services and the regeneration of appropriate sites’
Both SHPC and our residents have repeatedly requested the provision of additional services and shops on the Premdor site. All these requests have been dismissed out of hand and the local planning authority has made no effort to research or approach potential providers. This is in direct conflict with the NPPF’s view that ‘Planning must be a creative exercise in finding ways to enhance and improve the places in which we live our lives.’ It goes on to say that this should be a collective enterprise and must include communities in the process. The view of this community is that a sustainable, genuinely mixed development with improvements to community infrastructure would be positively welcomed. The development which is currently proposed does not meet that requirement and is overwhelmingly opposed by the community. SHPC has already made clear to BDC and the developers that it is unlikely to support any development which fails to take account of residents’ opinions. According to the NPPF, the community is entitled fully to participate in the ‘collective enterprise’ of planning, which surely means rather more than consulting and then ignoring the public view.
‘To maintain and support services, community facilities and appropriate employment in the rural communities to meet their local needs’
During the consultation stage of the Premdor Masterplan, the local secondary school put forward a scheme to provide a shared sports facility between the school and the community, to be hosted on the school’s site. It was suggested that the developers of Premdor, together with the Parish Council might make a financial contribution to the scheme, which would have provided significant local employment as well as much-needed recreational facilities. This suggestion, like many others that were offered, was also turned down out of hand.
SHPC suggest that the developers may wish to reconsider joining this community enterprise which is still being pursued.
‘To enable the provision of accessible and varied opportunities for leisure and recreational activities, including the provision of accessible green spaces, as part of a network of multi-functional green infrastructure, in order to promote healthy lifestyles and social inclusion’
SHPC support the Biodiversity & Landscape Management Plan, but request further discussion regarding SHPC involvement and its liability for future maintenance. We should also like further discussion about the choice and provision of play equipment.
SHPC also have the following comments to make regarding the design of the development. In the event of a successful planning application it would like conditions to be applied to ensure that these shortcomings are addressed by the developer.
Recent public consultations with our residents have clearly highlighted concerns about further flats being built in the community.
Despite assurances when asked by both SHPC and residents that flats would not be built above three storeys and would not be located in the area of the site in close proximity to the existing flats in Summerfields, the plans show social housing including flats backing onto Brook Terrace and the existing flats in Summerfields. Concerns were expressed by residents about the possibility of placing social housing here due to the problems already caused by the Wimpey flats. Bloor Homes gave assurances that this would not be the case 'as it is not good practice'. Four storey blocks of flats are not in keeping with the village setting and these should be removed from the design.
For a large modern development not to have any solar panels and/or heat pumps included within the design is unacceptable. This is 20th century housing on a 21st century development.
In accordance with the SH Village Design Statement rainwater harvesting and grey water re-cycling should be included within the design.
The Design and Construction Checklist statement that local or re-cycled materials will be used "where possible" is not sufficient and full details should be agreed in advance.
Problems already exist with the lack of bicycle storage provided for flats and given the provision of a cycle way it is essential that cycle stores are provided in communal areas.
Doorstep glass recycling is not carried out by BDC. There should be an area for glass re-cycling bins located on the land allocated within the site allocations DPD for community use.
Impact on the listed building
The design of the dwellings proposed on plots 4 and 5 are not in keeping with the street scene and will detract from the setting of the listed building.
Wildlife & Tree Surveys
The ecological survey is out of date and a new survey must be undertaken to reflect the current conditions and how the development will comply with the protection of wildlife during and after construction.
There appears to be extensive removal of trees on the site and in particular the removal of T6A which has been identified as 'High Quality'. SHPC would therefore oppose excessive removal of tress and in particular T6A.
Impact on existing businesses
Residential dwellings are proposed very close to existing businesses on Rippers Court. Guarantees should be sought from the developers to indemnify existing businesses against the cost of future remedial measures to mitigate noise, etc including being prohibited from continuing their business by means of restrictions on hours of working or noise constraints.
It appears that residents of some properties will be expected to wheel their multiple bins a distance of up to 100 metres from their property boundary to a central refuse collection point. This is unacceptable and will not make these homes a pleasant place to live. The properties close to these collection points will also be unpleasant places to live.
Provision for the storage of refuse and recycling for the flats, in particular, appears inadequate.
The Sible Hedingham Village Design Statement states that Sible Hedingham's history as a brick-making centre should be reflected in the choice of building material for new developments.
Drawing No: 7670/115 Proposed material unsuitable Cat: C1,C2, C3 & C4.
Plots 19-22,23,24,26 & 27. 4,5 & 6. 9,10,11,12, 13 & 14. 29,30,31 & 32 coloured finish not acceptable.
The benefits of this ‘regeneration’ site for the local community have in the past been much trumpeted which may account for some of the disappointment and dismay of local residents. Whilst SHPC feels that it still has the opportunity to influence the direction of the proposed development, it will continue to champion the views of its residents. Perhaps there is still time to pause for thought. We should not be unduly influenced by pressure exerted by developers and owners of the site. After all, once this site has been given permission for a large-scale housing development, there will be no going back, we and generations that follow us will be stuck with it for the foreseeable future. We all owe it to our constituents to get it right.
5th February 2013
The following notice is being delivered to all houses in Sible and Castle Hedingham with the Parish magazine:
Sible Hedingham Parish Council has received notice of a Planning Application from Bloor Homes for redevelopment of the Premdor Regeneration Site.
The application includes plans for 194 new homes and can be viewed in full on Braintree District Council’s website at http://www.braintree.gov.uk/ (the reference number is 13/00035/FUL)or in the Parish Office, 75 Swan Street, Sible Hedingham.
You are also invited to the Baptist Church, Swan Street, Sible Hedingham on Friday 8th February when the plans will be on display and parish councillors will be available to discuss and hear comments from the public, between 5pm and 7pm. These comments will be taken into consideration at the monthly Parish Council meeting at 7.30 on Monday February 11th at the Village Hall, Parkfields when the Council’s recommendations to BDC regarding the application will be determined. The public are also welcome to attend this meeting and a period of 15 minutes will be allowed for public comment on this, and other agenda items.
If you wish to submit your views on this planning application to BDC’s Planning Committee, who will make the final decision, you can do so in writing via Braintree District Council’s website at http://www.braintree.gov.uk/ (using ref 13/00035/FUL), or by email at firstname.lastname@example.org or by letter to Development Management, Braintree District Council, Causeway House, Bocking End, Braintree, Essex, CM7 9HB. The deadline for comments is 14th February 2013.
Sible Hedingham Parish Council would be pleased to receive copies of any comments submitted to Braintree District Council.
8th July 2012
Braintree District Council and Bloor Homes have announced a new Master Plan for the Premdor/Rockways regeneration site in Sible Hedingham. BDC and the new developers displayed the plan for public consultation in the Village Hall on Tuesday, 12th June 2012. The Parish Council was also able to view the plan for the first time on the morning of 12th June when they met representatives from Bloor Homes and Emma Goodings, a member of the BDC Planning team. District Councillors for Sible Hedingham ward declined an invitation to attend the meeting but Cllr Hylton Johnson visited the exhibition later in the day.
The Masterplan proposes the building of 236 new homes on the site.
A copy of the exhibition panels can be viewed here. Please be aware that this document, as supplied by Bloor Homes, is a large one and may take some time to download.
You will need Adobe Acrobat Reader which, if you do not have available, you can download here.
Sible Hedingham Parish Council is seeking the views of all interested residents on this major development so that it can make appropriate representations to Braintree District Council. The Masterplan, once adopted by Braintree District Council will form the basis of all future planning decisions for the Premdor/Rockways site.
A large number of residents met to express their views at a Public Meeting on Monday 25th June in the Village Hall, Parkfields, Sible Hedingham. Others are submitting them via this website. Click on the Survey tab in the lefthand menu to complete the questionnaire.
To view comments from the meeting and responses to the SHPC survey, please click on the links below:
The Parish Council has now finalised a statement to be submitted to BDC’s Local Development Framework Sub-Committee. This will be accompanied by the two above documents in order to provide feedback directly from Sible Hedingham residents to the BDC sub-committee. The Parish Council's statement and accompanying table which provides comparisons between facilities in Sible Hedingham and those available in other BDC parishes can be viewed by clicking on the links below:
Sible Hedingham Parish Council do not believe that the Regeneration Masterplan is in accordance with commitments in BDC's adopted Core Strategy to enhance the village and to provide employment, community facilities and necessary infrastructure to support a substantial increase in its population. BDC's Core Strategy can be viewed on the link below: