matter 16 hearing statement - luton borough council ... · jb planning associates matter 16 hearing...

Matter 16/956602/ James Delafield

Luton Local Plan Examination 11/16 On behalf of The Chamberlain Group

Matter 16 Hearing Statement

jb planning associates

Chells Manor, Chells Lane, Stevenage, Herts, SG2 7AA

e-mail [email protected] url www.jbplanning.com

tel 01438 312130 fax 01438 312131

1 Luton Local Plan Matter 16/956602/ James Delafield Statement on behalf of Chamberlain Holdings

jb planning associates matter 16 hearing statement 11/16

Introduction

1 This Hearing Statement is submitted on behalf of Chamberlain Holdings, who

are the owners of Britannia Estates, which is identified in the Pre-Submission

Luton Local Plan (2011-2013) as a mixed employment and housing allocation

with the potential capacity of 294 dwellings.

1) The Policies Map identifies at least two sites for Mixed Use

Development (LP15) including at Stockingstone Road (referred to solely

as a housing allocation in Appendix 4) and Britannia Estate (referred to

as mixed employment and housing in Appendix 4). Is the plan

sufficiently clear about the mix of uses that is proposed/acceptable on

these sites and should this be set out in a policy?

2 Emerging Policy LP15 relates to housing provision and sets out how the

Council are expecting to deliver 6,700 homes over the period of the Plan

(although we appreciate that this may increase to 8,500). Part A of the policy

states that allocations for housing and mixed use are set out in Appendix 4.

Within Appendix 4, Britannia Estate has been identified as a mixed

employment and housing allocation, with a potential capacity of 294

dwellings.

3 An outline planning application for the redevelopment of Britannia Estate is

being prepared concurrently with the preparation and examination of the

Luton Local Plan, and it is the intention for this to be submitted in early 2017.

The application proposals have been discussed at several pre-application

meetings with the Local Planning Authority. Whilst the proposals are still to

be finalised, at this stage it is intended that the existing leisure, specialist

education, medical and community uses at the southern end of the site will

be retained. Britannia House which is currently in B1 office use, which fronts

Leagrave Road, will also be retained and renovated. The remainder of the

commercial land to the rear of Britannia House will be redeveloped for

residential development with a capacity of up to 350 dwellings, comprising a

mix of flats, smaller houses and larger family town houses. Pre-application

discussions with Officers concerning this proposed mix have been positive.



4 Whilst we do not believe it to be necessary for the mix of uses proposed for

Britannia Estate to be set out in a specific Policy (such as is the case for the

Strategic Allocations), we are concerned that the identification of non-

strategic housing and mixed use allocations has been left to an Appendix

and cross referenced to the housing provision policy LP15. We consider that

these sites should be identified explicitly within Policy LP15 to confirm their

status in the plan.

5) Thames Water’s representation expresses concern about the

capacity of the wastewater network for the Housing Allocations at Land

at Caleb Close, 69 Felstead Way, Land to the West of Newlands Road

and Britannia Estate. Is there evidence that these capacity constraints

can be overcome? Does this have any bearing on the Housing

Trajectory in Appendix 5 given that 3 of the sites are shown to deliver

housing in the 5 year period to 2019-20?

5 Our Client’s Flood Risk and Drainage Consultant’s, SLR, has prepared a

Wastewater statement in response to this question which is enclosed as

Appendix 1. This demonstrates that wastewater flows from the proposed

development of Britannia Estates will be offset (at least in part) by the

existing wastewater flows generated from the existing built development

being redeveloped.

6 This release of wastewater capacity is expected to allow a significant initial

development phase to be constructed and occupied without off-site impact or

the need for off-site reinforcement to the wastewater network.

7 Due to the proposed phasing of the development, and release of wastewater

capacity at an early stage, sufficient time is available for engagement with

Thames Water and for their assessment and implementation of

reinforcement works prior to the majority of the development being

constructed and occupied.



8 Therefore, the ability of the site to deliver housing over the period 2017/18 to

2021/22 as identified by the SHLAA 2016 should not be affected.

JPD/1312 11 November 2016

Luton Local Plan Matter 16/956602/ James Delafield Statement on behalf of Chamberlain Holdings


Appendix 1

Britannia Estate

Leagrave Road, Luton

Wastewater Statement

SLR Ref: 402.05520.00001 November 2016

Version 1

rsion Chamberlain Holdings plc

Chamberlain Holdings plc i SLR Ref. 402.05520.00001 Britannia Estate, Luton: Wastewater Statement November 2016

SLR

CONTENTS

1.0 INTRODUCTION ............................................................................................................ 1 1.1 Background ........................................................................................................ 1 1.2 Planning Context ................................................................................................ 1 1.3 Purpose of this Report ....................................................................................... 1

2.0 EXISTING WASTEWATER ARRANGEMENTS ........................................................... 2 2.1 Existing Wastewater Connections .................................................................... 2 2.2 Basis of Consultation Response ...................................................................... 2 2.3 Existing Wastewater Services ........................................................................... 2 2.4 Existing Consented Trade Effluent ................................................................... 2 2.5 Existing Wastewater Disposal........................................................................... 3 2.6 Surface Water Connections to the Wastewater Network ................................ 3

3.0 WASTEWATER CAPACITY ASSESSMENT ................................................................ 4 3.1 Proposed Phasing of the Development ............................................................ 4 3.2 Wastewater Network Capacity To Be Released ............................................... 4

4.0 CONCLUSION ............................................................................................................... 5 5.0 CLOSURE ...................................................................................................................... 6

APPENDIX

Appendix A Thames Water Trade Effluent Consent TEHY0AB3

Chamberlain Holdings plc 1 SLR Ref. 402.05520.00001 Britannia Estate, Luton: Wastewater Statement November 2016

SLR

1.0 INTRODUCTION

1.1 Background

Chamberlain Holdings plc (“the Applicant”) seek to secure the allocation of land at Britannia Estate, Luton (“the Site”) in the Luton Local Plan for a mixed use redevelopment comprising residential development (up to 350 units) and some retained commercial activities.

1.2 Planning Context

The Secretary of State has appointed an Inspector from the Planning Inspectorate to carry out an independent examination of the Luton Local Plan.

With respect to the Site, a representation has been submitted by Thames Water on the pre-submission version of the Luton Local Plan, which reads as follows:

“We have significant concerns regarding Wastewater Services in relation to this site. Specifically, the wastewater network capacity in this area is highly unlikely to be able to

support the demand anticipated from this development. Significant drainage infrastructure is likely to be required to ensure sufficient capacity is brought forward ahead of the

development. Where there is a capacity constraint the Local Planning Authority should require the developer to provide a detailed drainage strategy informing what infrastructure is required, where, when and how it will be delivered. At the time planning permission is sought

for development at this site we are also highly likely to request an appropriately worded planning condition to ensure the recommendations of the strategy are implemented ahead of

occupation of the development. It is important not to under estimate the time required to deliver necessary infrastructure. For example: local network upgrades can take around 18

months to 3 years to design and deliver.”

The Inspector’s question for the Examination hearings is as follows:

“Thames Water’s representation expresses concern about the capacity of the wastewater network for the Housing Allocations at Land at Caleb Close, 69 Felstead Way, Land to the

West of Newlands Road and Britannia Estate. Is there evidence that these capacity constraints can be overcome? Does this have any bearing on the Housing Trajectory in Appendix 5 given that 3 of the sites are shown to deliver housing in the 5 year period to

2019-20?”

1.3 Purpose of this Report

SLR Consulting Limited has been commissioned on behalf of Chamberlain Holdings plc to prepare a Wastewater Statement to support the allocation and provide clarification on wastewater and sewerage in relation to the Site.

This Wastewater Statement has been prepared under the direction of a Technical Director of SLR who specialises in sewerage and associated planning matters.


SLR

2.0 EXISTING WASTEWATER ARRANGEMENTS

2.1 Existing Wastewater Connections

Adjacent to the Site, a public foul water sewer of 300mm diameter is routed beneath Leagrave Road and the railway line.

From site observations, the Site is served by existing foul and surface water sewer networks which drain to the respective public sewer networks beneath Leagrave Road.

2.2 Basis of Consultation Response

Within representations made by Thames Water, no allowance appears to have been made for existing flow contributions to the wastewater network from the extensive built development across the existing Site.

2.3 Existing Wastewater Services

Thames Water currently supply wastewater services to a number of account holders across the Site. The three main accounts are set out below:

Daily Bread Ltd. “Unit 23 Britannia Estate”

E.M. Chamberlain Estates Ltd. “Factory & Premises Britannia House”

E.M. Chamberlain Estates Ltd. “Yard, LHS Main Staircase Britannia Estate”

2.4 Existing Consented Trade Effluent

Daily Bread Ltd., situated at Unit 23, Britannia Estate, have consent to discharge trade effluent to the Thames Water sewerage network.

Consent was granted in October 2010, under Trade Effluent Case No. TEHY0AB3.

A copy of the Trade Effluent has been obtained from the Thames Water consent register (held in the public domain) and is presented within Appendix A.

The maximum quantity of Trade Effluent which may be discharged on any one day (24 hour period) is 66.6m3.

The maximum rate at which the Trade Effluent may be discharged shall not exceed 2.775m3 per hour.

The maximum rate at which the Trade Effluent may be discharged shall not exceed 0.077 litres per second.

It should be noted that the latter criteria contains a typographical error, and should read 0.77 litres per second. All other consent criteria correspond to an equivalent rate of 0.771 litres per second.


SLR

2.5 Existing Wastewater Disposal

From a review of wastewater bills provided to E.M. Chamberlain Estates Ltd. between July 2015 and October 2016, average wastewater disposal rates have been estimated for the Factory & Premises and Yard at Britannia Estate.

For the period 01/12/2015 to 13/10/2016 (317 days), Thames Water bills for the Factory & Premises correspond to a wastewater disposal volume of 3,742m3.

This equates to an average daily disposal volume of 11.80m3 from the Factory & Premises Britannia House which, in turn, equates to an average dry weather flow rate of 0.137 litres per second.

For the period 08/07/2015 to 14/07/2016 (372 days), Thames Water bills for the Yard LHS Main Staircase Britannia Estate correspond to a wastewater disposal volume of 873m3.

This equates to an average daily disposal volume of 2.35m3 from the Yard LHS Main Staircase which, in turn, equates to an average dry weather flow rate of 0.027 litres per second.

2.6 Surface Water Connections to the Wastewater Network

Based upon an initial walkover survey of the Site, it is considered likely that surface water connections from localised areas of the development may currently discharge to the wastewater network.

Disconnection of any existing surface water connections to the wastewater network will release further capacity beyond that identified within this Statement.

No allowance has been made for disconnection of surface water flows at this stage.


SLR

3.0 WASTEWATER CAPACITY ASSESSMENT

3.1 Proposed Phasing of the Development

Phasing of proposed development will be progressive, due to several commercial businesses needing to remain for the duration of their current tenancy agreements.

It is envisaged that development will commence at the northern end of the Site, gradually progressing southwards.

As a result, Unit 23 (that benefits from the Trade Effluent Consent) will be among a small number of commercial units to be demolished and redeveloped as part of the initial development phase.

As a result, the wastewater network capacity currently utilised by the trade effluent discharge from Unit 23 will be released and will provide adequate capacity for an initial phase of the proposed development.

Further capacity will be released upon demolition of other commercial units across the Site that currently contribute foul flows to the wastewater network.

3.2 Wastewater Network Capacity To Be Released

3.2.1 Termination of Consented Trade Effluent

Based upon Part H of the Building Regulations1 for residential development, typical foul flows generated per capita are quoted as 150 litres per person per day.

Applying a typical residential occupancy rate of 2.5 persons per dwelling, this equates to a wastewater discharge volume of 375 litres (or 0.375 m3) per dwelling per day.

Based upon the termination of the consented daily trade effluent volume of 66.6m3 per day, this would release volumetric capacity equivalent to 178 residential units.

Based upon a Dry Weather Flow multiplier of 3, the realistic peak foul flow discharge rate (per dwelling) equates to 0.013 litres per second.

Based upon the termination of the consented trade effluent discharge rate of 0.77 litres per second, this would release network flow capacity equivalent to 59 residential units.

3.2.2 Demolition of Other Existing Units

Allowing for the additional (albeit smaller) contribution upon demolition of other commercial units across the Site that currently contribute foul flows to the wastewater network, further wastewater network capacity will be released.

Based upon the termination of the consented daily trade effluent volume and demolition of other units, this would release volumetric capacity equivalent to 215 residential units.

Based upon the termination of the consented trade effluent discharge rate and demolition of other units, this would release network flow capacity equivalent to 71 residential units.

1 The Building Regulations 2010 : Drainage and Waste Disposal : Approved Part H (H1) : DCLG : Paragraph 2.39


SLR

4.0 CONCLUSION

Wastewater flows from the proposed development will be offset (at least in part) by the existing wastewater flows generated from the existing built development being redeveloped.

Termination of a significant consented Trade Effluent discharge from Unit 23 immediately prior to commencement of the initial development phase is expected to release significant volumetric and hydraulic capacity within the wastewater network, equivalent to that generated by an estimated 59 residential units.

This release of wastewater capacity is expected to allow a significant initial development phase to be constructed and occupied without off-site impact or the need for off-site reinforcement to the wastewater network.

Due to the proposed phasing of the development, and release of wastewater capacity at an early stage, sufficient time is available for engagement with Thames Water and for their assessment and implementation of reinforcement works prior to the majority of the development being constructed and occupied.

It should also be noted that disconnection of any existing surface water connections to the wastewater network will release further capacity beyond that identified within this Statement.

It is envisaged that the localised wastewater network constraints can be overcome, and that sufficient time is available to the Applicant and Thames Water to engage, design, and implement any off-site network upgrades.


SLR

5.0 CLOSURE

This report has been prepared by SLR Consulting Limited with all reasonable skill, care and diligence, and taking account of the manpower and resources devoted to it by agreement with the client. Information reported herein is based on the interpretation of data collected and has been accepted in good faith as being accurate and valid.

This report is for the exclusive use of Chamberlain Holdings plc; no warranties or guarantees are expressed or should be inferred by any third parties. This report may not be relied upon by other parties without written consent from SLR.

SLR disclaims any responsibility to the client and others in respect of any matters outside the agreed scope of the work.

Chamberlain Holdings plc SLR Ref. 402.05520.00001 Britannia Estate, Luton: Wastewater Statement November 2016

SLR

APPENDIX

Chamberlain Holdings plc SLR Ref. 402.05520.00001 Britannia Estate, Luton: Wastewater Statement November 2016

SLR

APPENDIX A

Thames Water Trade Effluent Consent TEHY0AB3

AYLESBURY 7 Wornal Park, Menmarsh Road, Worminghall, Aylesbury, Buckinghamshire HP18 9PH T: +44 (0)1844 337380 BELFAST 24 Ballynahinch Street, Hillsborough, Co. Down, BT26 6AW Northern Ireland T: +44 (0)28 9268 9036 BRADFORD-ON-AVON Treenwood House, Rowden Lane, Bradford-on-Avon, Wiltshire BA15 2AU T: +44 (0)1225 309400 BRISTOL Langford Lodge, 109 Pembroke Road, Clifton, Bristol BS8 3EU T: +44 (0)117 9064280 CAMBRIDGE 8 Stow Court, Stow-cum-Quy, Cambridge CB25 9AS T: + 44 (0)1223 813805 CARDIFF Fulmar House, Beignon Close, Ocean Way, Cardiff CF24 5HF T: +44 (0)29 20491010 CHELMSFORD Unit 77, Waterhouse Business Centre, 2 Cromar Way, Chelmsford, Essex CM1 2QE T: +44 (0)1245 392170 DUBLIN 7 Dundrum Business Park, Windy Arbour, Dundrum, Dublin 14 Ireland T: + 353 (0)1 2964667

EDINBURGH No. 4 The Roundal, Roddinglaw Business Park, Gogar, Edinburgh EH12 9DB T: +44 (0)131 3356830 EXETER 69 Polsloe Road, Exeter EX1 2NF T: + 44 (0)1392 490152 FARNBOROUGH The Pavilion, 2 Sherborne Road, South Farnborough, Hampshire GU14 6JT T: +44 (0)1252 515682 GLASGOW 4 Woodside Place, Charing Cross, Glasgow G3 7QF T: +44 (0)141 3535037 HUDDERSFIELD Westleigh House, Wakefield Road, Denby Dale, Huddersfield HD8 8QJ T: +44 (0)1484 860521 LEEDS Suite 1, Jason House, Kerry Hill, Horsforth, Leeds LS18 4JR T: +44 (0)113 2580650 LONDON 83 Victoria Street, London, SW1H 0HW MAIDSTONE 19 Hollingworth Court, Turkey Mill, Maidstone, Kent ME14 5PP T: +44 (0)1622 609242

NEWCASTLE UPON TYNE Sailors Bethel, Horatio Street, Newcastle-upon-Tyne NE1 2PE T: +44 (0)191 2611966 NOTTINGHAM Aspect House, Aspect Business Park, Bennerley Road, Nottingham NG6 8WR T: +44 (0)115 9647280 ST. ALBANS White House Farm Barns, Gaddesden Row, Hertfordshire HP2 6HG T: +44 (0)1582 840471 SHEFFIELD STEP Business Centre, Wortley Road, Deepcar, Sheffield S36 2UH T: +44 (0)114 2903628 SHREWSBURY Mytton Mill, Forton Heath, Montford Bridge, Shrewsbury SY4 1HA T: +44 (0)1743 850170 STAFFORD 8 Parker Court, Staffordshire Technology Park, Beaconside, Stafford ST18 0WP T: +44 (0)1785 241755 WARRINGTON Suite 9 Beech House, Padgate Business Park, Green Lane, Warrington WA1 4JN T: +44 (0)1925 827218 WORCESTER Suite 5, Brindley Court, Gresley Road, Shire Business Park, Worcester WR4 9FD T: +44 (0)1905 751310

jb planning associatesChells Manor, Chells Lane, Stevenage, Herts, SG2 7AAe-mail [email protected] url www.jbplanning.comtel 01438 312130 fax 01438 312131

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