¶ HAS20 Development Brief
The purpose of a development Brief is decribed here:
https://www.centralbedfordshire.gov.uk/info/45/planning_policy/461/development_briefs_and_masterplans.
Quoting from the CBC web page:
"Development briefs and masterplans assist in ensuring new developments are designed to the highest possible quality.”
¶ Documents
The Development Brief for the HAS20 development site in the Local Plan was prepared by Pegasus Group. A copy of the development brief can be found on the "Harlington West" marketing website under the "Development Brief" link:
Note: This is an older version, not the same version that was recently "Endorsed" by the council.
https://www.harlingtonwest.co.uk/_files/ugd/146daf_eaf7087ec70347588ad7e4334c99655e.pdf
The version of the development brief document that was decided upon has not been made available to members of the public via the planning portal.
Update:
Although it's not on the planning portal, the Latest version of the Development Brief can be downloaded from here:
https://centralbedfordshire.app.box.com/s/bi3ryro1et8fke88bd4e6k15gtcsnfjs/file/891860491708
A concept plan can also be found:
https://www.harlingtonwest.co.uk/_files/ugd/146daf_3f32fa1125634b9fb4e543ff228a28a4.pdf
Planning Portal Listing for the Development Brief: CB/21/04469/DB
Development Brief for approximately 435 dwellings and a new two form entry primary school
http://plantech.centralbedfordshire.gov.uk/PLANTECH/DCWebPages/acolnetcgi.gov?ACTION=UNWRAP&RIPNAME=Root.PgeResultDetail&TheSystemkey=625955
The Development Brief has been "Endorsed" by planning on the 15th of December,the status is now listed as "Decided".
Decision: "Development Brief Endorsed"
Conditions or Reasons: "There are no conditions"
Informative Notes: "There are no informative notes"
Unfortunately for some reason the documents that were listed for this on the planning portal around a month ago in November are no longer linked, the document list is now empty for some reason.
Below is what the document list looked like in November.
In order to view the documents, please use the direct links below which where harvested before the documents disappeared. Comments of particular substance have been highlighted in bold.
323676 (Trainee Planning Officer)
https://app.box.com/embed/preview/mn9yemjo09dzshjxcf4jswebroa7sni8?direction=ASC&theme=dark
378775 (Landscape Officer) (duplicate consultation)
https://app.box.com/embed/preview/jf2feemlvjnsodya5pgwu15fcyloylb1?direction=ASC&theme=dark
397793 (Principal Highways Officer)
https://app.box.com/embed/preview/3a3ndzpygieg7wwv0rwgo7275ky464j8?direction=ASC&theme=dark
466838 (SuDS Engineer)
https://app.box.com/embed/preview/9oy6cin3ofce2f85gdywu2ww080fr4bl?direction=ASC&theme=dark
506028 (Leisure Policy Officer)
https://app.box.com/embed/preview/wzj3xf6eom24bj5lnriljx7u44oiqrde?direction=ASC&theme=dark
518611 (Sustainable Growth Officer) (unable to comment)
https://app.box.com/embed/preview/22coxypx0k1z3tdl3all1caz3lqwbf1s?direction=ASC&theme=dark
653473 (Landscape Officer)
https://app.box.com/embed/preview/377prrsko9z8wftesz896jbrvlc6yswd?direction=ASC&theme=dark
776090 (Landscape Officer)
https://app.box.com/embed/preview/cbzfzh0i0sij4oql0s2daqzsm8s4fq2i?direction=ASC&theme=dark
821434 (Landscape Officer)
https://app.box.com/embed/preview/pp1fp5ofimlcd4xdp0tkh71hjq2uxx47?direction=ASC&theme=dark
919661 (Pollution Officer)
https://app.box.com/embed/preview/zoa0vhuckts6ujk2ugxqedlk3007n99c?direction=ASC&theme=dark
Note that the Sustainable Growth Officer was unable to comment and the SuDS Engineer needed more time, both due to being unable to access the development brief that they were tasked with commenting on.
518661 (Sustainable Growth Officer):
"Development Brief document is not available in the case documents"
466838 (SuDS Engineer):
"We have not been able to locate the brief from the details provided and would appreciate further time and instruction to review this in detail."
¶ Comments from above documents
Listed below are some of the many issues and concerns raised by the internal consultees at the council. It should be expected that any outline planning application that is submitted should have addressed these concerns.
From the comments made by the Trainee Planning Offficer, there has been 2 versions of the development brief, whch raises the question of which version is linked from the harlington west marketing site. The linked document is dated August suggesting it was the first version.
¶ 323676 (Trainee Planning Officer)
It clear from these comments that there are additional issues with the new version of the development brief.
Note the Officers comments in the following sections regarding the new version of the Development Brief:
8. Improvements to the transport network must be made to enable safe access into the site, and particularly the school, including:
9. Improvements to footway provision along Toddington Road, including the railway bridge;
10. The provision of safe pedestrian crossings and traffic calming measures on Toddington Road; 11. Pedestrian and cycle access improvements on Westoning Road;
12. Traffic calming along Westoning Road; and
13. The provision of appropriate parking in close proximity to the school
The DB refers to the policy requirements of the site allocation to maintain safe accessibility to the school. However, it appears that the newly revised Development Brief, as made aware by Highways Officers, does not provide the clarity or reassurance that these policy requirements will be met as the previous DB did. This is in refence to the following being removed from the new version:
‘a. The realignment and widening of Toddington Road to a minimum of 6.0m, including the retention of a minimum width of 6.5m though bend past the railway station access.
b. The provision of a 3.0m wide shared footway / cycleway on the northern side of the road.’
13. Drop Off / Park and Ride
Additionally, the previous version of the DB mentioned: The new primary school will be accessible from the development by both walking and cycling and will include a drop off area or a park and stride facility, in accordance with the Council’s Sustainable Modes of Travel to Schools and Colleges Strategy.
This has been deleted entirely. We object to the removal of this, which clearly forms part of the policy requirement in Policy HA20. In our previous comments on the DB, we sought to amend the above (now deleted) paragraph to refer to “drop off or park and ride” in the text, to be in accordance with the authority’s Sustainable Modes of Travel to Schools and Colleges Strategy.
5. A site-specific FRA
It is stated that a detailed hydraulic modelling of the drainage network and a hydrological analysis will be required at a later date. However, the policy requires an FRA and there is no direct mention of this.
6. A site should be provided to allow the delivery of a new 2FE primary school with appropriate contributions. It is expected that the school will operate as a ‘lower tier’ school in the first instance but must be capable of operating as a primary school, should this be required in the future.
2.1ha of land will be allocated for a primary school, children’s play areas and a variety of landscaped areas all set within new public open space.
7. Off-site contributions to the Newgrounds Sports Field, in accordance with the Leisure Strategy, in lieu of onsite provision.
Section 5.37 acknowledges and states that this requirement will be adhered to.
¶ 397793 (Principal Highways Officer)
The highways officer also points out many issues with the development brief, which is refered to as "Harlington West Development Brief prepared by Pegasus (P21-1034_11E September 2021)".
Pedestrian / Cycle Improvements, Toddington Road
.... This is as per previous iterations of plans seen by HDM, but the Movement Plan (p42) now limits a proposed pedestrian / cycle facility to between a proposed secondary access on Toddington Road and a formal crossing – a length of about 50m. The proposal for the remaining length of the site frontage to the main access is only for the widening of the existing footway to 2m.
This is disappointing and HDM strongly suggest that, to comply with the NPPF which seeks to ensure that ‘opportunities to promote sustainable modes can be - or have been - taken up’, a shared footway / cycleway should be provided along the wider site frontage, at least as far
west as the main access and preferably across the whole site frontage. ....
Toddington Road Accesses
Page 35 identifies ‘new vehicular access from Toddington Road together with separate access for pedestrians and cyclists’. This statement doesn’t seem to reflect other plans and text in the Brief. Instead, a secondary vehicular access, also from Toddington Road, is introduced at para 5.18. No separate pedestrian and cycle access appears to be shown on the Movement Plan, other than retention of Footpath 2 connecting with Toddington Road immediately west of the property named The Bungalow. The secondary vehicular access does not feature on the Concept Plan, nor has it previously been considered or assessed by HDM.
Toddington Road
Para 5.4 states that ‘where trees and hedgerows are lost along Toddington Road as a result of proposed highways improvements, it is proposed these will be replaced to maintain a landscaped setting along Toddington Road’. This is enforced by the GI Strategy Plan (p44) which shows a wide green corridor along the frontage with swales behind. This presents a challenge for achieving 30mph speeds along Toddington Road. Retaining a rural character, with little obvious development frontage, is not conducive to encouraging drivers to reduce their speed. There is also a disconnect between proposed urbanising features of a wider footway, part shared footway / cycleway, pedestrian crossing, enhanced bus stops and traffic calming, with the objective to retain a landscaped setting. If conditions do not result in drivers travelling at 30mph or lower, the local highway authority could not support reduction of the speed limit, and the access designs would need to respect the prevailing speed of traffic.
In turn, we are concerned about the specificity of the Brief. Para 5.19 states ‘the improvements will include slight realignment of a section of Toddington Road to the southeast of the secondary access point to provide a safe and convenient pedestrian crossing point and significantly improved accessibility to the enhanced bus stops and Harlington Railway Station’. This statement fails to acknowledge that wider realignment may be required not only to physically fit features such as footways, but also to achieve necessary forward visibility along Toddington Road and to achieve safe and suitable access to the site. Without agreed details of the access strategy and treatment of Toddington Road, the Brief should not act to preclude greater realignment, carriageway widening, or other highways works that may be necessary. Concerns about safe access to the site and the impacts of development traffic on Toddington Road is another core theme that has come out of the recent public consultation.
Wording in the previous iteration of the Brief (August 2021) was more appropriate in that it said, ‘the improvements will consider the realignment of Toddington Road in order to provide significantly improved highway safety through better road alignment and increased road space’.
Westoning Road
As previously raised by HDM, it is considered that there would be notable benefits to including a vehicular access off Westoning Road, subject to being able to achieve appropriate design standards. Currently, the Brief is prescriptive in that it refers to ‘a pedestrian / cycle only link’ to Westoning Road (para 5.22) and ‘vehicular access to the school will remain from Toddington Road’ (para 2.30). An additional vehicular access to Westoning Road would avoid all development traffic using Toddington Road which, as mentioned, already presents challenges. It would also assist to address the Local Plan policy requirement for ‘...safe access into the site, particularly the school’ and ‘the provision of appropriate parking in close proximity to the school’. The current wording would also preclude the use of the Westoning Road for emergency access.
Even with adequate levels of parking for the school within the application site’s red line boundary, it can be anticipated that children at the school that don’t reside on-site could be dropped off and picked up from Westoning Road. This has also been raised as a concern in the responses to the recent public consultation, and requires careful consideration. Allowing vehicles to use the access off Westoning Road would help to ensure that vehicles are kept clear of the public highway. Furthermore, accommodating vehicles alongside pedestrians and cyclists would assist with personal security perceptions, as otherwise pedestrians and cyclists would have only limited natural surveillance along a length of c.140m. Accordingly, HDM strongly recommend that wording in the Brief should not preclude a vehicular access from Westoning Road.
Railway Bridge and Station Road
Para 5.24 states that ‘consideration will also need to be given to potential improvements of the route across the railway line and further east towards the centre of Harlington’. The use of the term ‘consider’ is weak and should be strengthened, such that the Brief communicates a commitment from the developer to delivering a scheme of improvements at the railway bridge and Station Road (including the junction with Westoning Road / Sundon Road), with this identified on the Movement Plan.
The limitations of the railway bridge, Station Road and the crossroads with Westoning Road / Church Road / Sundon Road is well documented within the responses to the recent public consultation. Being the largest site amongst other committed and allocated developments, and with a direct reliance for access along this route between the site and the centre of the village, a contribution would not be appropriate and delivery of a scheme is necessary and expected.
On-site Details
Due to the numbers of units proposed to be served, a secondary access would be required for the site, either full or emergency. In addition, it would be advisable to retain a wider carriageway corridor on the first section of the access road into the site before the proposed loop (identified on the movement plan as ‘Main Route’), to allow for vehicles to pass an obstruction or works within the highway.
The on-site walking and cycling proposals are welcomed, although it is currently unclear if they will be provided as segregated routes or adjacent to road corridors.
‘CA1 – Site Entrance and Main Street’, for example refers to the provision of safe routes for pedestrians and cyclists to the primary school, but the associated cross section details 2.0m footways to either side of the road. Note that Manual for Streets recommends wider footways near schools.
Notwithstanding the indicative street cross sections (and dimensions) included within the document, any street layout should be in accordance with the Councils Highways Constructions Standards and Specifications Guidance, with any deviations from that guidance being by agreement only.
It is noted and welcomed that para 5.45 acknowledges that coaches will need to access the school and that the internal roads will be designed accordingly. At the relevant place in the Brief, it is also recommended that the following principles are included:
Delivery and service vehicles will be suitably accommodated, including appropriate turning provision where necessary; and
Parking will be provided in accordance with CBC’s adopted standards.
Consideration will be given to measures to discourage informal commuter parking associated with the Railway Station, and the location and form of parking associated with the proposed school.
¶ 466838 (SuDS Engineer)
The Suds engineer raises concens over drainage issues.
We have not been able to locate the brief from the details provided and would appreciate further time and instruction to review this in detail.
We note from the submission letter provided that Reference is made with the Surface Water Drainage section on page 41 at paragraph 5.16 to the off-site ponds on the adjacent property, Briarwood.
We have recently raised concerns with regards to the need for detailed appraisal of the existing drainage regime and how the adjacent ponds may be affected by any changes to this, including the impact on fluvial and surface water flows, as well as groundwater recharge. This must include an assessment of the water quality and ecological value and any potential detrimental impact/mitigation.
With regards to drainage of the development, we will require details of the preferred approach and that sustainable drainage systems will be fully integrated to enhance the development layout, recreational and aesthetic appeal, and wider environmental and greenspace objectives. We expect details to be provided in the design brief to demonstrate an adequate and robust approach to drainage design, implementation and maintenance/ownership details.
¶ 506028 (Leisure Policy Officer)
Concerns raised by the Leisure Policy Officer
4. Table under paragraph 5.36 for open space provision: Informal Recreation space required is 2.50ha, and it seems that the SuDS are a large portion of this. Depending on the depth of the basin and how regularly it fills with water, this may not be appropriate as informal recreation space, as it should be accessible for recreational activity at all times. An offsite contribution would be expected instead, dependent on an appropriate offsite project being identified. The majority of the open space proposed on the site is
considered to be Small Amenity Space.
5 Paragraph 5.37: the Outdoor Sport contribution would be best kept to a generic project for the DB. Leisure recommend that the wording is changed to “offsite contribution to local outdoor sport facilities in Harlington will be required”. Rest of paragraph is ok.
¶ 821434 (Landscape Officer)
Many issues reported by the landscape officer
Masterplan
*Masterplan - landscape concerns stand the planned vista to St Mary's church will be obscured by future development. Site Photo A describes the rising topography, this
increases concerns future development will be exposed in views especially from the west due, in part, to facilitating the planned view and also lack of strategic landscape mitigation internally across the site northeast to southwest to mitigate views to built elevations.
The landscape officer refers to the relocation of the school, there does not appear to be any publically available documents to show this.
Relocation of school and inclusion of low density residential development onto western site boundary is a positive.
Location of swale to northern site boundary - if located outside the school site - will require access for maintenance so would form an informal footpath access, lacking surveillance. Therefore, ideally the swale / SUDS should be located within the school grounds.
General impression areas shown as green corridors / swales have become further compressed as the masterplanning process has developed.
Concerns footpath/cyclewayaccesstoWestoningRoadwouldlacknaturalsurveillance.
'Indicative Attenuation Basin' needs to be integrated more sympathetically within Masterplan.
VISION
Principle 3: Additional landscape buffering @15ms to reinforce boundaries , protect open views and form defensible edge to Green Belt boundary is a positive but potentially will need to be wider in parts to ensure adequate screening / planting mitigation and accommodate access, SUDS, etc. - suggest 15m is a minimum width of buffer.
Principle 6: SUDS within landscaped green blue corridors is a positive - could also include tree lined streets, soft verges / bio retention areas.
Supporting text:
5.4 Concerns regarding loss of existing mature trees, mostly 'Category B' Oaks, to facilitate highway works required along Toddington Road. The loss of trees and opening up of views to future development would have an urbanising effect on the rural approach to Harlington. The extent of any loss and character of future highways measures must be considered carefully to ensure a sympathetic design along this sensitive site boundary.
5.9 Suggest a stronger commitment to integrating street tree planting and rainwater gardens is needed.
5.10 Surface water drainage strategy includes substantial length of piped s.w. within green corridors / POS which is disappointing - question why can't this drainage be integrated within a surface based SUDS feature? Tree lined streets and bio retention areas?
Main attenuation basin could be designed as a series of smaller connected basins to increase 'interest' in terms of landscape, biodiversity and amenity.
5.14 SUDS /swales to site peripheries need to ensure adequate space allowed to form Green / Blue Infrastructure corridors and accommodate multi functional requirements (as per D.B. reference to CBC Design Guide, section 2.) Suggest need to link with Green infrastructure section (pg 45).
5.16 Briars Wood - reference to designing s.w. drainage / SUDS to avoid any impact on Briars Wood is welcomed - this off-site ecological / biodiversity asset must be protected from impact of future development. A more significant buffer may be required along this sensitive boundary to ensure appropriate means of managing surface water can be incorporated - plus spatial offset to limit impact of lighting, disturbance on biodiversity.
Green Infrastructure (pg 45) should be 'Green Blue Infrastructure'
Caution text describes biodiversity corridor within PRoW corridor but substantial part of this
path lies within built development, associated disturbance, lighting,domestic pets, etc.
Character Area CA2 describes wildlife corridors as part of SUDS / GBI strategy but will potentially also accommodate footpaths / cycle routes, lighting, which would detract from habitat value of corridors.
General concerns widths of Green Blue corridors to site peripheries especially and including swales @ 3 - 3.5m wide, footpaths / cycle ways @ 3ms wide would need to be an absolute minimum width of 15ms wide to include woodland and shrub margins. Varying widths of woodland and margins also aid habitat / biodiversity connectivity. Typologies describing GBI
corridors would be helpful.
Typologies for GBI within street scenes would be helpful.
¶ 919661 (Pollution Officer)
The pollution officer states that an air quality impact assesment will need to be submitted.
I have nothing to add from my comments at Pre-application stage. I have pasted these below .
As set out in the noise report submitted with the request for pre-application advice, consideration to layout, design and orientation should be demonstrated with any application in relation to the railway. Noise from any plant machinery or equipment associated with the school premises shall also be presented. Additionally, an air quality impact assessment should be submitted in support of the proposals.