Site ID: 761

Showing comments and forms 1 to 1 of 1


Site Assessment Pro Formas

Representation ID: 8076

Received: 02/09/2021

Respondent: Howbury Hall Estate

Agent: Phillips Planning Services

Representation Summary:

The Council’s Site Assessment Pro Forma published June 2021 in relation to Site 761 includes a high level assessment of the site. Having considered the summary provided a number of clarifications are provided.

Ecology (2b, 2c, 2d)

Criterion 2b queries whether protected species may be impacted. In this respect it may be noted that the site comprises intensively farmed and so regularly ploughed / cultivated land and as such land generally accepted as unlikely to comprise important habitat / impact protected species.

In response to 2c and 2d, boundary landscaping is to be retained and very significant scope exists to provide wider buffers to these boundaries than currently exists as a result of the farming. There is also potential to provide links across the site as part of detailed design.

The allocation of the land could therefore deliver net biodiversity gains and enhanced linkages to the surrounding green infrastructure network.

Heritage (4a)

Criterion 4a states that “The proposal has the potential to cause harm to heritage assets” with these impacts potentially ranging from ‘low to high’.

This is a generic comment which appears in relation to most sites that have been assessed.

It is not clear what heritage assets the comments are referring to.

The nearest statutory heritage assets to the site, are 52 Green End to the north, the listed buildings at the Howbury Hall estate to the west and the Scheduled Ancient Monument and listed buildings on the southern side of the A421.

Development at the proposed site would not have any adverse impacts on the setting of any of these assets which are very clearly significantly removed from it and have no direct visual relationships in terms of setting.

It is respectfully submitted that there are no heritage constraints to the allocation of this site.

Employment (5a)

It is stated at Criterion 5a that it is unknown as to whether the proposal would be ‘likely to increase future economic and employment opportunities’.

The site is promoted as an ‘employment site’ which could provide up to 800,000 sq ft of floorspace. Accordingly, it is considered clear that it is likely that the site would provide significant economic and employment opportunities.

The site is located directly on a main junction of the A421 and economic development here would fit squarely with the emerging local plan strategy of focusing such growth at the edge of the urban area and within this corridor.

Highways (15e and 15f)

The Proforma suggests that it is not clear if the site can connect to the highway without constraint.
However, as part of the original Call for Sites submission a Highway and Access Assessment including a detailed access plan was provided by TPA consultants.

This demonstrates how the existing roundabout which adjoins the sites southern boundary could be readily improved to provide appropriate access to the site.

In terms of linkages an additional plan is also now included with this submission showing the location of the site relative to a number of existing footpaths and cycleways and existing bus services in the area. As will be noted good quality connections already existing between the site and existing foot, cycleway and public transport infrastructure.


The submitted site offers substantial potential for allocation for employment generating uses and roadside services including electric vehicle charging as proposed.

The emerging local plan strategy seeks to focus development within the urban area, directly adjoining the urban area and along the A421 corridor. This site lies close to the existing urban area and so benefits from excellent proximity and access to the A421 corridor. It’s allocation would fit squarely with this emerging strategy.

There are no technical constraints to the development of the land.

The site is owned and controlled by the Howbury Hall Estate. No third party land or agreements are required to facilitate the development as proposed.

Ease of deliverability can therefore be readily assumed.

Should the Council have any further questions or queries regarding this site please do not hesitate to contact us.