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See latest BRAG objection letter to RBC

The application of Ottershaw East (RU.21/0672), must consider national design guides as well as documents produced by Runnymede council. The document produced by the council is the Runnymede design SPD, which is generic and provides little detail, leaving too much open to discretion and therefore pressure from developers to push for a low-quality scheme maximising profit over sustainable design which should respond to people and places. Therefore, reference to the national design guides and good quality guides from similar local authorities should be used in addition.

The Ministry of Housing Communities and Local Government (HCLG) released a statement in July 2021 stating that “Local communities will be at the heart of plans to make sure that new developments in their area are beautiful and well-designed” There will be a “greater emphasis on beauty and place-making, and to ensure that all new streets are lined with trees.”

The current masterplan presented by Richborough Estates does not achieve this. Due to the density caused by cramming, there is no room left over for placemaking within the development, and many of the streets cannot be considered “lined with trees”. There is no attempt at placemaking and no integrated social space or play areas within the development. There is serious doubt that Richborough’s masterplan can achieve a biodiversity net gain with the concrete footprint to green space ratio on this site and an obvious lack of adequate green corridors appropriate to a site which was formerly greenbelt and is still surrounded by greenbelt in a village location

Further, Robert Jenrick the housing minister stated;

“The proposed changes to the National Planning Policy Framework will set an expectation that good quality design will be approved while poor quality will be rejected, and includes a commitment to ensure that all streets are lined with trees.”

“[The changes] will enable local people to set the rules for what developments in their area should look like, ensuring that they reflect and enhance their surroundings and preserve our local character and identity.”

“Instead of developers forcing plans on locals, they will need to adapt to proposals from local people, ensuring that current and new residents alike will benefit from beautiful homes in well-designed neighbourhoods.”

This should include real engagement with the 4 residents associations who are representing the interests of the village. The consultation exercise carried out by Richborough was a tick box exercise which ignored many of the concerns raised by residents and was not meaningful. In fact, Richborough went in a reverse direction by increasing the number of dwellings from 200 proposed in the consultation to 220 in the outline planning application.

The government has published a new National Model Design Code that outlines the design standards new developments are expected to meet. We expect that Runnymede BC will be mindful of the new standards when considering this application. Where a local authority has not yet developed a comprehensive design guide, national guides should be used in conjunction. The National Design Guide (NDG) states on p10 that all new developments should integrate into their surroundings. This is clearly not the case for the Richborough masterplan which shows a doubling of density of new housing backing onto existing dwellings with up to 6 new properties backing on to a single existing home which does not respond to plot rhythm nor integrate the new development into its surroundings. A similar high-density arrangement bordering existing homes by a developer at another site was dismissed at appeal by a planning inspector (Appeal Ref: APP/M1710/A/14/2229095). The Surrey Design SPD on p.37 states that new building should relate positively to the existing layout and maintain the quality of the environment for existing residents. Brox Road Action Group (BRAG) has looked through multiple design guides from national and other local authorities and have seen no example where the density of large new housing development or tandem backland development is so densely arranged against existing housing.

It is also noted that Richborough plans to move the SuDS offsite onto the SANG. This does not comply with good practice according to the NDG p33, “Sustainable drainage systems and trees are incorporated into streets, creating a high quality, green setting for new homes and contributing to the character of the neighbourhood.”

Example Northampton (National Design Guide p.33)

The NDG p.35 also states that streets should encourage activities such as socialising, informal doorstep play, resting and movement. The secondary streets on the masterplan prioritise parking on frontages with no green space. There are multiple areas where the Richborough masterplan does not conform to a high-quality design according to existing standards and the standards in the new NMDC will only raise the bar higher. This code will be relevant to all new developments including that proposed on Ottershaw East.

The award-winning Essex Design Guide is one which should be considered and has received significant praise throughout its history for Pioneering Local Design from organisations including CABE (Commission for Architecture and the Built Environment). It has also been an early adopter of the NMDC. Essex is a similar county to Surrey bordering London with dormitory villages just like Ottershaw. On privacy for existing residents, it states:

“Where new development backs on to the rear of existing housing, existing residents are entitled to a greater degree of privacy to their rear garden boundary. Where the rear faces of the new houses are approximately parallel to those of the existing homes, the rear of the new houses may not encroach any closer than 15m to an existing rear boundary”

There are several existing dwellings bordering the site (119, 121, 123 and 135A Brox Road) which are much less than 15M from the site boundary. One property is only 2M from the site boundary. The current masterplan proposes that multiple new dwellings back on to these properties contrary to requirements of good plot rhythm. Where existing properties are very close to the boundary, extra distances above the 20M rule of thumb should be employed “to maintain the quality of the environment for these existing residents” and prevent overlooking and privacy issues.

The Local Plan SL12 allocation for Ottershaw East stipulated around 200 dwellings but since not all the land came forward, proportionately this would mean the site capacity should be around 170 dwellings. Of this, 30% should be affordable, however, to increase the land value, Richborough’s masterplan proposes a large proportion of 3 & 4 bedroom houses with the 1 and 2 bedroom dwellings in apartment blocks leading to a high plot and floorspace to site ratio. Therefore, a disproportionate amount of the land is given over to buildings which explains the high density look of the masterplan. This is cramming. Affordable housing should not be concentrated into apartment blocks and should have adequate access to private green space. Not only should the scheme be examined for the high number of dwellings per hectare but also the high number of bedrooms per hectare which increases the concrete footprint, height, density, and massing of building on the site, crowding out the required green and amenity space. This cramming of living space onto the site along with the 25% increase in the number of proposed dwellings over the Local Plan to maximise profit makes it difficult to adhere to the good design principles as recommended in local and national design guides for a suburban village context such as Ottershaw. The new NMDC requires a much greater emphasis on placemaking and community engagement for which this scheme falls short by a large degree.

Any objective assessment of the application in its current form shows that it fails to adhere to the guiding NPPF principle;

To protect and enhance our natural, built, and historic environment.

For this reason, the application should be substantially revised or refused.

Jane Tilley

Gemma Pickett

Brox Road Action Group

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