As a local resident living ----REDACTED----- I welcome the opportunity to comment on the outline planning application (OPA), to ensure that any benefits it may bring to Harlington and the overall design quality are maximised. I provided detailed comments on the draft Development Brief (DB), the majority of which do not seem to have been addressed in the OPA material, or the approved DB. I therefore replicate those issues again in relation to the OPA as well as including additional comments on the OPA material. I have made representations at previous stages of this process and have engaged a professional planning adviser to inform and guide me through this incredibly difficult process.
We have had a number of conversations and correspondence with CBC (both at officer and councillor level) and also with Willis Dawson and their consultants (including after much pushing (by us) a full site walkover of our property to assist in preparing the drainage solutions with them and 3 consultants. Throughout the process the “developer” has proved to be, at best, disingenuous.
It was clear from the treatment of residents concerns by the developers in preparing the development brief, that is to say to sweep them under the carpet and make little or no accommodation for them, that the outline application was unlikely to be prepared with a mindset of ensuring the village was protected and could actually benefit from the major increases proposed, and sadly this appears to be the case.
The main issues which I wish to raise relate to the scope of the OPA, the need to secure design quality and character, community benefit, very dangerous highways proposals and drainage. My comments set out below are provided in relation to each submission document, albeit there is a fair degree of cross over, particularly where comments relate to application plans then also referred to in the Planning Statement or Design and Access Statement (DAS). Before turning to my detailed comments, I wish to raise the following general issues with the application:
Whilst the OPA is comprehensive in its coverage, overall, it does not make clear the exact scope of the scheme and what will be fixed by any outline planning permission. The language used fluctuates between ‘will’ in some cases to ‘should’ or ‘could’ in others, and inconsistencies between plans and confusion over whether they are for approval or indicative only, renders it very difficult to ascertain the scope of the application. Detailed examples of this are presented in the comments below.
Willis Dawson are land promoters who, once planning permission is obtained, will likely sell it to one, or a series of housebuilders to build out (this has been confirmed by representative of Willis Dawson on site). This may follow a negotiation on the price of the land and increase in costs, which could result in a watering down of design quality. As drafted, the OPA fails to pin down the design expectations for the site and is not nearly ambitious enough, offering only a generic vision, meaning there is a very real risk that the scheme is not a positive addition to Harlington that reflects its needs and character, and rather that it is a bog standard estate. Avoiding this requires a much clearer set of principles, that can be conditioned alongside comprehensive parameter plans, that leave no wriggle room for a reduction in design quality. The DAS makes two oblique references to a Design Code potentially being provided, if required by CBC. Our view is that either the current OPA material is strengthened substantially to fix minimum requirements and make clear how good design will be achieved (which it currently doesn’t do), or that Design Codes are conditioned accordingly, preferably both. If no Design Codes are required, a reserved matters application would be drawn up in the absence of clear design parameters and principles in the DAS and as such it would be more difficult for CBC to challenge poor design and negotiate improvements.
Much of the OPA material, and particularly the DAS, simply replicates the contents of the DB, without providing any additional information. The purpose of the DB is to set the framework for development, with the OPA then providing further detail as to how the principles in the DB will be delivered. This is a fundamental omission, again reflecting potentially the applicant’s desire to do just enough to obtain planning permission before selling the site and moving on.
Planning Statement
Green Belt
The OPA site extends beyond the allocation, into the green belt, to accommodate a connection to Westoning Road and a drainage basin. As stated in representations on the DV, the full logic behind this decision is not clear, as the Local Plan allocates the site for 435 units, as opposed to the 400 now approved, so there should be sufficient capacity for drainage basins within the site itself if fewer dwellings are delivered. It is also not apparent why such a wide strip of land is needed for the footpath connection to Westoning Road and why the proposed orchard area could not be accommodated within the site allocation that will be released from the green belt. Further, the parameter plans do not show footpath access around the drainage basin and so this connection, that is partially relied upon in the Planning Statement to justify the loss of green belt (NPPF para 145) will not be fixed by the outline permission.
Approach to Landscaping
Paragraphs 7.13 -7.17 assess the scheme against the requirements of Local Plan policy HAS20 in terms of landscape mitigation and buffer planting. The policy requires that a landscape buffer is required to reinforce site boundaries and create a new edge to the settlement and defensible green belt boundary. The Planning Statement notes that buffer planting is shown on the Indicative Landscape Masterplan (ILM) and as such the policy is adhered to. Two points arise here: firstly and most importantly is that the ILM is indicative only and so fixes nothing. The Green Infrastructure Parameter Plan, which we presume does provide the fixed parameters of the OPP, does not show any buffer planting along the western edge of the scheme, therefore none will be required by any permission. And secondly, it is not clear if the ILM is in fact indicating additional tree planting beyond proposed native shrub planting, which would not perform well as a visual buffer.
Paragraph 7.58 refers to the potential to achieve a net gain in trees which is supported and needs to be fixed in the outline permission. The reference to new tree planting on the Indicative Masterplan (IM) is insufficient for the reasons set out above in relation to the ILM.
Paragraph 7.64 notes that the Green Infrastructure Parameter Plan demonstrates that multifunctional green infrastructure will be integrated with the development in accordance with Local Plan policy EE1. We would disagree with this statement as the plan refers only to ‘open space’ and does not demonstrate the multi-functionality of this space, which again should be fixed at outline stage.
Emergency Access
Paragraph 7.90 refers briefly to emergency access ‘perhaps’ being required via the secondary vehicular access at the south-eastern corner of the site. Elsewhere in the application, reference is made to the footway/cycleway to Westoning Road potentially offering an alternative emergency access. Neither option would appear to be feasible. Neither the parameter or the indicative plans indicate a vehicular connection between the south-western residential parcel and the remainder of the site and a vehicular connection to Westoning Road would not have been justified in terms of impacts on the green belt and so would not be possible. The position on emergency access must be resolved at outline stage, as serving a 400 home scheme from a single access point would be a very dangerous proposition, if that access were to become blocked in an emergency.
Pedestrian / Cycle Access
Paragraph 7.96 ‘acknowledges’ that additional improvements to pedestrian facilities along Station Road may be needed. It is not clear whether these are part of the package of mitigation proposed as part of the application and should therefore be clarified.
Paragraphs 7.98-7.100 refer to a ‘walking and cycling access strategy’ and an examination of how Harlington residents will access the site. Some conclusions are drawn in paragraph 7.100 which do not necessarily make sense, and it is also not evident how they were arrived at. Given that it seems that the mitigation proposed along Station Road and Westoning Road is predicated on these assumptions, we would suggest that the logic behind these statements is interrogated by the LPA and LHA as part of their assessment of the OPA.
Ecology
In paragraph 7.122 (and also in the DAS), the applicant continues to state that access to the Briarwood ponds was not possible. As set out in my response to the DB, to my knowledge, permission to access the land has never been requested other than a single mobile phone call which despite our chasing up no further request was ever forthcoming. It is strongly recommended that these surveys be undertaken in the next appropriate season, as the presence of Great Crested Newts, or other protected species, would have a significant bearing on the scheme layout, potentially requiring the provision of additional habitat.
Paragraph 7.139 lists a number of ecological enhancement measures, the majority of which are not shown on the parameter plans and would therefore not be fixed by the permission. It is suggested that either the plans are amended or that delivery of these measures is conditioned.
Paragraph 7.166 refers to the approach to noise mitigation and suggests that noise from the railway will be reduced sufficiently by orienting plots so that gardens are provided behind units. This may result in an odd layout, particularly for the small parcel fronting Toddington Road, with the potential view from the access being to the rear of properties facing the railway. A better solution by far would be mitigate noise impacts along the railway edge (noise barrier, bund or similar) so that the scheme design is unfettered and that an optimum layout can be achieved.
Application Plans
The OPA is inconsistent in how it refers to the status of the submitted application plans. It is assumed that the plans for approval and that will fix the parameters of the scheme are those referred to as parameter plans (i.e. Land Use, Green Infrastructure, Building Heights and Access and Movement) plus the detailed access plans. However, the DAS appears to note that some of the parameter plans (access and movement for instance) are indicative only. Further, reliance is placed on the detail provided within the Indicative Masterplan and Indicative Landscape Masterplan, when presumably these are provided just to show one way in which the scheme could come forward and are not fixed. Future reserved matters could propose an entirely different scheme, as long as they align with the parameter plans. It is imperative that the applicant is clearer on what it is actually seeking permission for. It may be that a document can be prepared that sits alongside the parameter plans to articulate in words the key fixes within the OPP. For instance, the width of buffer planting and wildlife corridors, minimum areas of each open space typology, offsets from utilities infrastructure, setback from the water course etc., as well as the key design principles with which any reserved matters application must accord.
Land Use Plan
Green Infrastructure
Movement and Access
Building heights
Proposed Access Plan
Indicative Masterplan
Indicative Landscape Masterplan
Design and Access Statement
Overall, and as outlined above, the DAS does little to describe or fix design principles that will ensure that the scheme maximises the stated opportunity for it to be ‘one of the best places to live in the district’. The vision and much of the DAS simply replicates the DB and does not take this further into clear design principles. It also tends to be vague about what is committed to and what is aspirational, with lots of use of ‘should’ rather than ‘will’. I am therefore concerned that the high quality design that is so important for a scheme of this size, which will so significantly increase the size of the village, is neither demonstrated nor appropriately fixed by the DAS.
The DAS offers no guidance as to the appropriate location for key design features such as gateway and marker buildings, key corners, groupings or frontages, which are essential to establishing character and a sense of place in new development. Given the concerns about the design, we would recommend that the scheme be comprehensively reviewed by a Design Review Panel prior to determination.
Vision Principles
The Vision Principles are taken from the DB and as per our comments on that document, are generalised principles that could apply anywhere. What is not evident is a set of clear design principles in the DAS which develop these further, draw on the site context review in the previous section and clearly define what it is that the scheme will deliver in terms of design quality and character.
Local Facilities and Amenities
This section replicates the DB exactly and identifies the location of local facilities but does not review their location/accessibility relative to the development nor their capacity or need for improvements (which the scheme could then contribute to). Introducing an additional population of c.1000+ to the existing village requires serious consideration as to what local facilities Harlington needs as it grows. A larger population will support a greater number and range of local facilities and it is therefore key that the developer work with the Parish Council and other stakeholders to develop a plan that actively benefits existing and new residents and provides effective links between the ‘new’ and ‘old’ halves of the village.
Various oblique references are made in other parts of the documentation to contributions being made to existing or off site facilities (sports ground, library for instance). These need to be captured in one document, such as a draft S106 Heads of Terms, so the contribution the scheme makes to the local community can be understood by local residents and the LPA. At present, it would seem that the scheme does little to benefit the village, beyond highway improvements which are principally needed to facilitate the development itself.
Local Character Analysis
An analysis of the local Harlington character is crucial to the success of the new development, highlighting key elements of that local character that will inform the new layout, design typologies and architecture, essential to integrate the two parts of the village. In this context and again albeit this just replicates the DB, this section is welcomed. However, the analysis is brief, touching predominantly on architectural character and details, whilst not considering other key aspects of design such as layout, street typologies, building forms and heights. It is imperative that the DAS identify those elements that best characterise the village, and can therefore be taken forward as design principles for Harlington West. A much more thorough analysis is therefore required as it is not clear what, if any, design principles are informed by local character.
Continuing this point, paragraph 3.29 notes that the average density of Harlington is 18-20dph. This is half as dense as the Harlington West scheme (40dph) which begs the question how will the development reflect the character of Harlington but still achieve this density level.
Utilities
Paragraphs 3.88-3.90 refer to retention of the 132kv powerlines and the Sense of Place Guidelines which is welcomed. It does not however draw any conclusions as to how they apply to Harlington and the plans do not identify the location of pylons which are the key factor in influencing neighbouring design.
There appears to be some uncertainty about the realignment of the sewer that crosses the site, with a very high level feasibility study having been undertaken. Have the costs of this undergrounding been factored into the scheme costs?
As outlined above, set backs from noise sources, powerlines and easements should be set as clear parameters with which future reserved matters applications must accord.
We welcome the reference on page 43 to being a good neighbour and respecting the privacy of existing dwellings around the edges of the site. We recommend that this comprise one of the design principles set by the DAS and conditioned.
Movement and Access
It is not clear from the DAS whether the intention is to bring buses into the site to provide public transport access to residents. No mention is made of the need for contributions from the development to improve public transport provision, although this is one of the vision principles. Reliance on a public transport service that provides only 6 buses a day is not acceptable and the scheme should make an appropriate contribution to facilitate an increase in bus frequency.
The street typologies make no reference to on-street parking or inclusion of SUDS, both of which should be clarified. The proposed 2m footway on the main street is unusually narrow for a primary street and should be 3m minimum on one side of the street.
No reference is made to EV charging provision for residents or the school.
Homes and Buildings
This section contains many statements that suggest design elements ‘could’ be included. It therefore does very little to fix the design principles that will ensure quality is achieved.
Paragraph 5.95 states that the design allows for good emergency services access. As above, this has not been resolved and cannot therefore be stated.
Character Areas
The DAS (as per the DB) proposes four character areas as a means to establish different character and design across the site. The proposed character areas are not well defined on the plan at page 69 and seem to indicate that in some instances, parcels fall within two or even three character areas, without any guidance as to which should take precedence and what the design response should be. Character areas are defined by the edges and primary street loop but as most parcels have a wildlife corridor edge (which for some reason stops between the station and the LEAP/NEAP) and a main street edge, I would question how useful a concept this is and whether it will result in any variation in character. An alternative would be to establish character areas that are based on parcel extent, so there is no doubt as to which they fall within.
The guidance for each character area focuses almost exclusively on the design of either the main street or the green edge, with little or no focus given to the built form that will front on to it. It is imperative that further guidance is provided as to the building form, layout, density, height, typology, styles, access arrangements that befit each character area. For instance, how will the houses fronting Toddington Road and the main street be laid out, how will the entrance into the site be defined? It is appreciated that the Design Codes will provide detailed design requirements, but the DAS must set the core design principles with which any future code and outline planning application must accord. Without reference to such high-level design principles in the DAS, there is every chance that any aspirations to design quality will be significantly watered down by the time reserved matters applications are prepared and approved.
The enhanced frontage character area appears the least well resolved, providing no indication as to how the houses will back onto the green space to the rear, the need or otherwise for acoustic barriers and the appropriate building heights. The precedent photographs do not encourage design quality and the second bullet point under 5.113 introduces a reference to farm building layouts which appears from nowhere and is entirely unrelated to the context analysis. The reference to historic clusters in Harlington is welcomed, albeit again this does not connect back to the context analysis nor is it clear which particular clusters it means and what elements are to be replicated. This Character Areas section would be significantly strengthened if it drew more strongly from the local vernacular and context and used this to inform the various character area principles.
Public Spaces
Paragraph 5.121 notes that four of the required open space typologies are to be provided off site but no indication given as to how this is to be achieved i.e. by a contribution, actual provision on an identified site? Will contributions be made towards schemes in Harlington that will benefit the existing community. Again, the overall approach to S106 contributions heads of terms needs to be more clearly articulated, so the community and the LPA can understand what benefits the scheme will bring to the village.
As also set out earlier, the quantum and location of each of the open space typologies needs to be fixed by the OPA to ensure they are delivered in the reserved matters applications. Paragraph 5.129 notes that there is an over provision of open space across the site. Whilst this may be true if all the typologies are combined, it is not correct that there is an overprovision within each individual typology, particularly as four of the categories will need to be provided for offsite.
The plan at page 90 illustrates 400m and 800m distances from the play areas, indicating that parts of Harlington village fall within these walking distances, and presumably inferring that they are therefore accessible to the existing community. This is misleading as the railway forms a barrier between the two, meaning walking distances (via the railway crossings) are much further in reality.
Creating a Safe Place to Live
The key attributes to creating safe places set out in this section are welcomed and should form the basis of one element of the DAS principles that are then conditioned, thus ensuring their delivery in the reserved matters schemes.
Tree Retention and Removal
We are concerned with the level of tree and hedgerow loss from the development along particularly along Toddington Road and also to facilitate the footway/cycleway connection to Westoning Road. It is appreciated that some tree loss is inevitable to construct the main site access, but the extent shown will have a significant negative impact on the character of Toddington Road, which has a consistent green edge along both sides as it enters Harlington. It is also not clear why the full width of tree/hedgerows between the proposed orchard and north western residential parcel is required, particularly as the area to the north will be planted with orchard trees. Presumably only a narrow gap is required to allow access for the pedestrian / cycle link and this area can be well overlooked by the houses immediately to the south if designed appropriately.
Indicative Drainage
The Indicative Drainage Strategy Plan does not identify the existing ditch around the south western edge of the site. It is not made clear how the proposed swales (which are not fixed on the parameter plans) will interact with the existing drainage system and if they are of sufficient capacity for the site. Very little detail is provided of the type and design of swale that would be appropriate, given the reliance that is placed on them by the whole drainage strategy.
Sustainability Principles
This section, and the accompanying Sustainability Statement are surprisingly light on commitment or ambition. Whilst some vague options to consider sustainable construction and waste, none are committed to, nor are there any principles relating to climate change adaptation or renewable or low carbon technologies on site or other sustainability considerations. It is imperative that all development is held to the highest sustainability standards and a much clearer strategy to deliver a truly sustainable development at Harlington should be required.
In terms of the Sustainability Statement, it is similarly lack lustre in its ambition with the main provision being and improvement to the existing pedestrian walkways on Westoning Road and Toddington Road, as well as cycle routes and walkways across the development.
The reference to EV charging at paragraph 3.12 is non-committal. What are the actual provisions, are they for each home, or only in parking spaces?
Paragraph 3.35 notes that the installation of a heat network is considered unsuitable but no alternative options are proposed. What is the applicant proposing? Will it be a decentralised energy system?
Built Form
Whilst the Design Code is the appropriate place to detail the architectural style and character and materiality of the new development what the DAS lacks is an overall design vision and set of design principles (that are conditioned) for the future Code to then develop further. What is it about this scheme that sets it apart from other urban extensions and makes it a part of Harlington? What is distinctive in the way the streets will be laid out, the buildings positioned, the architectural styles selected? It is imperative that the Brief goes further in articulating these elements of design, or at the very least, the principles that sit behind them.
The placemaking section is not aspirational or clear enough in its intent, or show how quality would actually be delivered. The language is underwhelming, for instance ‘a suitable frontage’ and ‘an appropriate entrance’. Whilst we understand the need to provide a range of densities across the site, it would be helpful for the brief to set out what this means in built form terms and how this relates to the various densities identified in the context section. To achieve the required housing numbers, does the scheme require predominantly terraced and flatted development for instance?
A further opportunity is missed in this section to identify the most important parts of the development that require a particular design response, such as the entrance to the site from Toddington Road.
Phasing and Delivery
It would be helpful for the DAS to provide guidance in relation to construction access and how the scheme will be delivered during the interim stages when development and construction traffic will be using the same access point. The OPA must also consider (in principle terms) how the primary school will operate and be safely accessed if it is delivered in advance of the residential parcels towards the northern part of the site and for a time operate within a construction site
The development’s success relies heavily on the delivery of offsite highway improvements on Toddington Road and Westoning Road. These should therefore be implemented at an early stage of development, preferably prior to any occupations and this timing should be fixed by the OPA. Consideration should also be given to the early delivery of advanced planting as part of the landscape corridors, to establish the green edge to development as soon as possible.
Key Placemaking Checklist
All placemaking considerations have been identified as having been considered by the OPA. However, several items to not seem to have been addressed, including consideration for street enclosure, key groupings and focal points (refer to in earlier comments on this) or the integration of sustainability principles. The latter point is a substantial omission from the Brief. No reference at all is made to climate change adaptation and sustainability measures. How will the scheme incorporate low carbon or renewable technologies, what measures will be in place to ensure a fabric first approach to reducing energy need, how will waste, energy and water demands be reduced? These issues must be at the forefront of the design process with standards set by the DAS to ensure the sustainable parameters for development are absolutely clear.
Drainage Plans & Notes
Throughout the entire process we have attempted to correspond openly with Willis Dawson and at all stages have offered our full cooperation to ensure that the ponds on our property do not suffer a major detrimental effect from the development. Despite this they have constantly sought to keep all correspondence purely between them and CBC which I can only conclude is an attempt to stop us seeing any information until it is too late. The conclusion they have reached that the development will have no negative impact is completely flawed. The ponds already suffer from very low levels of water in the summer and so any reduction in water flow could be catastrophic to local ecology. If CBC are unable to ensure that plans make at the very least zero impact on water flow then we request time to engage a truly independent expert to asses the plans, failing that we will be forced to consider legal action.
Highways Issues
The single most important issue raised by most residents in the proposals for changes to the highways. The developer has clearly paid for the traffic consultant to produce (in their own words) a report that supports the development. It is clear to aybody that regularly uses the roads in and around the village that the plans are bad thought out and WILL lead to accidents and jams – no doubt which will then require fixing at the public expense.
There will be a minimum of 700 new vehicles brought to the village by this development and many extra trips to the proposed school in addition - the developer must deal with the increased danger and pollution issues this will bring. No outline consent should be given until all this issues are addressed in a binding manner.
The WSP report is full of inconsistencies and lacks any proof that the plans will deal with the dangers that the development will cause. There should be an INDEPENDENT traffic study produced (we would be willing to fund this as the consequences of getting this wrong are very serious & significant).
If CBC grant consent relying on just this flawed report knowing full well how many users of these roads have raised concerns then they are in serious danger of, at minimum, bad public relations through the press and possibly also direct legal action.
The development should, at the very least, not increase risk & pollution and in reality should be striving to improve the situation. The village already has roads that would not meet current standards and the proposals only worsen this. For example the proposal to widen the footpath on the railway bridge and reduce the already substandard road width is a nonsense. As a regular user of this bridge I can assure you that wing mirrors already get very close to pedestrians.
The developer is providing little or no concrete proposals to improve village facilities and so it is clear to anyone that the traffic increase will be very very significant.
In addition this is already a very heavily used road during peak time and the failiyre to provide a large roundabout at the scheme entrance will cause very extsnive and long queuing on Toddington Road and within the new development
On a more personal note whilst we welcome the reduction of the road speed from 40 to 30 MPH the location of the sign appears to be adjacent to our or our neighbours property. The developer is extending the village to no meet these 2 properties (and the proposed new house on the site adjoining Rosehaven) and as such it would be ore appropriate for the 30 mph to start before our house (now being the new entrance to the village). This would also have the advantage of making the blind bend here more safe. Having cars accelerating past the 2/3 houses here is clearly not acceptable nor, with the blind bends, is it safe.
There also needs to be a detailed plan for how construction traffic will be permitted to use Toddington Road for what is envisaged to be 5+ years of works. The road is too narrow and has blind bends as well as old houses built near the road which shake with large lorries. This road is completely unsuitable for construction vehicles and an alternative plan must be thought through.
Statement of Community Engagement
We are disappointed to note that our numerous comments on the Development Brief have not been addressed or even summarised in the SCE. As a result, many of our comments are replicated again in relation to the OPA, which has unfortunately not sought to respond to them.
In summary, we welcome the opportunity to comment on the draft OPA. The principle of development at Harlington West is established and, as a local resident, my comments therefore focus on ensuring the scheme is built to the highest quality and in a way that integrates most effectively with the existing village. This is a significant opportunity to bring much needed housing and other benefits to the community but one that must deliver a development that is very much part of the village, that responds to its history and design, is a genuinely sustainable scheme and that provides real community enhancement.
It is all to clear that the “developer” (the term they prefer since it disguises their real intent) has no interest in providing a well planned, high quality addition to the village that provides benefits to new and existing residents but rather seeks only to minimise cost and with it maximise profit from selling the site at the detriment to all others.