PLANNING STATEMENT CONTINUITY HOUSE, LONDON ROAD, BRACKNELL, RG12 2XH ON BEHALF OF FLAMINGO DEVELOPMENT - Planning Alerts | UK

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PLANNING STATEMENT CONTINUITY HOUSE, LONDON ROAD, BRACKNELL, RG12 2XH ON BEHALF OF FLAMINGO DEVELOPMENT - Planning Alerts | UK
January 2021 | MR/NK | P19-2147.A

 ERECTION OF FIVE STOREY BUILDING TO PROVIDE
 21NO. ONE AND TWO BEDROOM APARTMENTS
 WITH           ASSOCIATED          PARKING      FOLLOWING
 DEMOLITION OF EXISTING BUILDING

 PLANNING STATEMENT

 CONTINUITY HOUSE, LONDON ROAD, BRACKNELL,
 RG12 2XH

 ON BEHALF OF FLAMINGO DEVELOPMENT

 TOWN & COUNTRY PLANNING ACT 1990 (AS AMENDED)
 PLANNING AND COMPULSORY PURCHASE ACT 2004
PLANNING STATEMENT CONTINUITY HOUSE, LONDON ROAD, BRACKNELL, RG12 2XH ON BEHALF OF FLAMINGO DEVELOPMENT - Planning Alerts | UK
Continuity House, London Road
Planning Statement

CONTENTS:

                                                                                                    Page No:

1.0    INTRODUCTION ......................................................................................... 1
2.0    SITE DESCRIPTION .................................................................................... 4
3.0    RELEVANT PLANNING HISTORY ................................................................. 5
4.0    PRE-APPLICATION AND ENGAGEMENT ....................................................... 6
5.0    THE PROPOSAL .......................................................................................... 7
6.0    RELEVANT POLICY ..................................................................................... 9
7.0    ASSESSMENT              AGAINST           PLANNING            POLICY           AND        MATERIAL
CONSIDERATIONS ............................................................................................ 12
8.0    CONCLUSIONS ......................................................................................... 25

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PLANNING STATEMENT CONTINUITY HOUSE, LONDON ROAD, BRACKNELL, RG12 2XH ON BEHALF OF FLAMINGO DEVELOPMENT - Planning Alerts | UK
Continuity House, London Road
Planning Statement

1.0        INTRODUCTION

1.1        This Planning Statement is prepared by Pegasus Group in support of a full
           planning application for the redevelopment of Continuity House, a site located
           on London Road to the east of Bracknell Town Centre. The proposed
           development can be described as follows:

              "Erection of five storey building to provide 21no. one and two bedroom
              apartments with associated parking following demolition of existing
              building."

1.2        The proposals have been the subject of pre-application discussions with the
           Council and engagement with a local housing management company, which
           are detailed below. The current application has been formulated following
           feedback received to these initial proposals.

1.3        This statement will introduce the proposals to the Council in the context of the
           site and relevant planning history before detailing how the proposals have
           evolved as a result of pre-application engagement. The purpose of this
           statement is to explain how the proposed development is in accordance with
           both the outline permission and relevant Development Plan policy and as such
           concludes that planning permission should be granted.

1.4        In addition to this statement, application forms and the relevant fee, the
           application is accompanied by the following plans and supporting documents:

               •     Location Plan ref. 676.LN.001 (Revision A)

               •     Proposed ground floor plan ref. 676.PL.001 (Revision Y)

               •     Proposed first floor plan ref. 676.PL.002 (Revision P)

               •     Proposed second floor plan ref. 676.003 (Revision K)

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PLANNING STATEMENT CONTINUITY HOUSE, LONDON ROAD, BRACKNELL, RG12 2XH ON BEHALF OF FLAMINGO DEVELOPMENT - Planning Alerts | UK
Continuity House, London Road
Planning Statement

               •     Proposed third floor plan ref. 676.004 (Revision J)

               •     Proposed fourth floor plan ref. 676.PL.005 (Revision G)

               •     Proposed roof plan ref. 676.PL.007 (Revision C)

               •     Proposed front elevation ref. 676.PL.010 (Revision G)

               •     Proposed rear elevation ref. 676.PL.011 (Revision F)

               •     Proposed east elevation ref 676.PL.012

               •     Proposed west elevation ref 676.PL.013 (Revision A)

               •     Cross Section AA ref. 676.PL.015 (Revision A)

               •     Cross Section BB ref. 676.PL.016 (Revision A)

               •     Proposed Block Plan ref. 676.PL.050 (Revision D)

               •     Gunn Design and Access Statement (676.SD.001H, January 2021)

               •     Eight Associates Daylight and Sunlight Impact Assessment (November
                     2020)

               •     Eight Associates Biodiversity Net Gain (December 2020)

               •     Velocity Transport Planning Transport Statement (December 2020)

               •     GeoSmart Sustainable Drainage Assessment (December 2020)

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Planning Statement

               •     Kempton Carr Croft Viability Appraisal and Report (December 2020)

               •     MMEcology Preliminary Roost Assessment (August 2020)

               •     SJ Stephens Associates Arboricultural Impact Assessment (January
                     2021) and Tree Protection Plan (ref 1625-01 Rev C).

               •     GeoSmart Phase 1 Contaminated Land Assessment

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Planning Statement

2.0        SITE DESCRIPTION

2.1        Continuity House is located on the northern side of the A329 London Road,
           approximately 0.5km to the east of Bracknell Town Centre. At present the site
           comprises a three storey building together with parking and a pedestrian
           entrance to the building at ground floor level. The car park is accessed via
           London Road through an existing vehicle entry and exit arrangement. It
           includes undercroft areas and contains 20 parking spaces together with a
           refuse/recycling store in the north west corner of the site.

2.2        The site is located within the designated settlement boundary and is not subject
           to any other designation through Bracknell Forest Council's adopted Policies
           Map. It is bordered by a Travelodge Hotel to the west and Summit House to
           the east. It is noted that Summit House, previously an office building, has been
           granted planning permission for change of use to residential use to form 65no.
           apartments with further applications approved to form additional apartments.
           Further residential apartment buildings are located on the southern side of
           London Road including two six storey buildings accessed via Fleming Place.

2.3        To the rear, the site is bordered by the rear gardens of properties under the
           management of Silva Homes that front Fielden Place, a residential cul-de-sac.
           For reasons which will be explained below, part of this land is included within
           the application site and notice has been served on Silva Homes. Notice has
           also been served on the existing landowner and the Highway Authority.

2.4        The site is not located within a flood zone or an area at risk of surface water
           flooding, as per the Environment Agency's flood mapping. It is not within a
           conservation area nor a character area, and there are no nearby listed buildings
           that could be affected by the proposals. No trees on or adjacent to the site are
           protected by Tree Preservation Orders.

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Planning Statement

3.0        RELEVANT PLANNING HISTORY

3.1        The site was formerly a petrol station and its demolition and replacement with
           an office building was originally subject to outline planning application 610130
           which was refused permission in April 1986. An appeal against this decision
           was dismissed.

3.2        A subsequent outline application was submitted under reference 611583
           which was refused in October 1987, however an appeal against this decision
           was allowed. Following this, a reserved matters application was approved in
           January 1989 under reference 615004 thereby establishing the office use that
           remains today.

3.3        Following these applications, the planning history was restricted to ancillary
           works, such as the display of signage and the installation of a generator, until
           application 13/00870/FUL was submitted for the change of use of offices to
           a mixed use comprising offices and a community advice and support centre,
           which was considered a sui generis use. The application was approved however
           the planning permission was never implemented and has now lapsed.

3.4        Application 14/00491/FUL was submitted in 2014 for the change of use of
           the building to A5 (Hot Food Takeaway) and the change of use of the first and
           second floor to residential apartments, however the application was withdrawn
           before it was determined.

3.5        Finally, application 20/00189/PAC was submitted in March 2020, seeking
           prior approval for the change of use of the building from offices to
           dwellinghouses, to form 7no. one bedroom apartments. The application was
           approved in May 2020, thereby establishing the principle of the residential use
           of the building, and as such will be referenced where relevant below.

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Planning Statement

4.0        PRE-APPLICATION AND ENGAGEMENT

4.1        As set out within Paragraph 39 of the NPPF early engagement has significant
           potential to improve the efficiency and effectiveness of the planning application
           system for all parties, and that good quality pre-application discussion enabled
           better co-ordination between public and private resources. As stated in
           Paragraph 41, the more issues that can be resolved at the pre-application
           stage, the greater the benefits.

4.2        A pre-application enquiry was submitted to the Council in May 2020 and
           allocated reference PRE/20/00053. The enquiry concerned a proposal for
           'Change of use and extension of existing building to form 27no apartments
           with associated parking.' The proposal concerned a six storey building with a
           maximum height of 20.5m. As with the current proposal the apartments were
           proposed to the upper floors only, and 26 parking spaces were proposed to
           serve the development.

4.3        The response to the enquiry was received in August 2020 and accepted the
           principle of development and the design concept of the proposal. However it
           was considered that the proposals would represent an overdevelopment of the
           site which would result in harm to the street scene. Specifically, the response
           highlighted particular concerns relating to the height of the building and
           bringing the building line forward. A height in between that of the Travelodge
           and Summit House was recommended, requiring the loss of a full storey. The
           detailed design of the building was considered acceptable on its merits.

4.4        A concern was also raised with regard to the relationship with the neighbouring
           properties to the rear on Fielden Place due to an overbearing impact, and a
           loss of privacy and light to Summit House at the side although officers did
           recognise that       efforts   had   been   made to   manage views   rearwards.
           Furthermore, concerns were raised with regard to the proposed parking
           provision although it was accepted that the development would result in
           minimal traffic impact. Finally, it was also recommended that an Arboricultural
           Impact Assessment, a Bat Survey and a SuDS Drainage Scheme would be
           required in support of a proposal.

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Planning Statement

4.5        In addition to the pre-application enquiry with the Council, prior to the
           submission of the application discussions with Silva Homes have taken place
           in respect of the proposal who are the management company for the dwellings
           to the rear on Fielden Place. In particular discussions have taken place with
           regard to the approach to the trees to the rear of the site which are within Silva
           Homes' ownership, which have resulted in the application 'red line' has been
           extended to include this land and notice served.

5.0        THE PROPOSAL

5.1        Following receipt of pre-application advice, a revised proposal has been
           prepared incorporating significant amendments to take into account the
           concerns raised. Firstly, it is now proposed to demolish the existing building
           and replace with a new build scheme rather than extend the existing building,
           as due to the revisions required to take into account the concerns an extension
           is no longer feasible.

5.2        Firstly, the overall height of the building has been reduced to 16m, which has
           been achieved through a reduction in storeys from six to five with a substantial
           reduction in units from 27 to 21. The mix now proposed is for 14no. one
           bedroom and 7no. two bedroom apartments.

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Planning Statement

5.3        As previously, an inset roof is proposed above the main element, which will
           have a height of 13m. The main element would be constructed from facing
           brickwork, with feature brick elements, with the roof finished in metal cladding.

5.4        As is evident from the floor plans, side elevations and sections, the full depth
           of the building would only be realised at first floor level, with the rear projection
           being stepped away from the rear boundary above. The second, third and
           fourth floors would all be located further from the boundary than the floor level
           in response to concerns with regard to overbearing, and the use of obscure
           glazing and metal privacy fins is proposed to the rear to ensure no loss of
           privacy. Windows to the side elevation have been designed to ensure no loss
           of privacy to Summit House.

5.5        25 parking spaces are to be provided to serve the development including two
           accessible spaces, with the in and out access to the site remaining. Servicing
           would be taken from the existing layby to the front of the building. A refuse
           and recycling store is proposed in the same north east corner location as the
           existing, with a secure cycle store in the south east corner of the site.
           Balconies and terraces will be provided.

5.6        As set out on the accompanying plans the development would incorporate
           green roofs to the rear as an ecology enhancement. Following discussions with
           Silva Homes, it has been agreed that the removal of the tree to the rear of the
           site, outside the applicant's ownership, will be removed with a replacement
           provided.

5.7        As set out above, a number of supporting documents have been provided which
           are specific to certain elements of the scheme. These will be referred to within
           the relevant assessment sections below.

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Planning Statement

6.0        RELEVANT POLICY

6.1        The development plan for Bracknell Forest Council currently consist of the Core
           Strategy (2008), the Site Allocations Local Plan (2013) and saved policies of
           the Bracknell Forest Borough Local Plan (BFBLP) (2002).

6.2        The Council are working on a new Local Plan however the current timetable
           sets out that this will be subject to further consultation in Spring 2021 before
           submission for examination later in the year. The status of the plan has not
           changed since the pre-application response was issued, and this highlighted
           the council's view that it can currently be given no weight in decision making.

6.3        The National Planning Policy Framework (NPPF) is a material consideration in
           the determination of planning applications. The NPPF sets a presumption in
           favour of sustainable development which, for decision-taking, means approval
           proposals that accord with an up-to-date development plan without delay.

           Core Strategy

6.4        Policy CS1 sets a number of sustainable development principles, including
           that development will be permitted which makes efficient use of buildings, land
           and infrastructure, and that is located to as to reduce the need to travel.

6.5        Policy CS2 directs new development towards the settlement boundary, with
           particular reference to 'Previously development land and buildings in the
           defined settlement.' Development will be permitted within the defined
           settlement where this is consistent with the character, accessibility and the
           provision of infrastructure and services within that settlement.

6.6        Policy CS6 requires new development to contribute to the delivery of
           infrastructure needed to support growth in the Borough.

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Planning Statement

6.7        Policy CS7 requires high quality design for all development in the Borough,
           states that development will be permitted that builds on local character,
           respecting local patterns of development, provides safe communities and
           promotes biodiversity. This policy is now supported by the Design SPD.

6.8        Policies CS10 and CS12 seek to secure sustainable development and offset
           energy demand via on-site renewable energy generation.

6.9        Policy CS17 requires residential development on suitable sites to provide
           affordable housing. In a decision on affordable housing policy on 29 March
           2011, the Council confirmed the affordable housing threshold to be 15 units,
           above which provision of 25% affordable housing will be sought.

6.10       Policy CS19 seeks to protect small business units (500m² or less) and non-
           office employment uses.

6.11       Policy CS23 states that the Council will uses its planning and transport powers
           to reduce the need to travel and increase the safety of travel.

6.12       Policy CS24 allows for development to be permitted where mitigation against
           transport impacts is provided, which shall be achieved through the submission
           of a transport statement.

           Local Plan

6.13       Policy EN20 states that development should be in sympathy with the
           appearance and character of the local area and should not result in an adverse
           impact on the amenities of surrounding properties. This policy is now supported
           by the Design SPD.

6.14       Policy M9 seeks to ensure that new development has sufficient car and cycle
           provision. This is supplemented by the adopted Parking Standards SPD
           which sets out the requirements for vehicular and cycle parking for both
           residential and commercial uses.

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Planning Statement

           NPPF

6.15       Paragraph 108 states that it should be ensured that appropriate opportunities
           to promote sustainable transport can be – or have been – taken up, given the
           type of development and its location. Safe and suitable access to the site needs
           to be achieved for all users.

6.16       Paragraph 109 sets out that development should only be prevented or
           refused on highways grounds if there would be an unacceptable impact on
           highway safety, or the residual cumulative impacts on the road network would
           be severe.

6.17       Paragraph 117 promotes an effective use of land in meeting the need for
           homes and other uses.

6.18       Paragraph 118(c) gives substantial weight to the value of using suitable
           brownfield land within settlements for homes and other identified needs.

6.19       Paragraph 122 states that planning decisions should support development
           that makes efficient use of land, taken into account the need for different types
           of housing and the availability of land suitable for accommodating it, local
           market    conditions    and     viability   and   the   availability   and   capacity   of
           infrastructure and services.

6.20       Paragraph 123 places importance of planning decisions avoiding homes being
           built at low densities and ensuring that developments make optimal use of the
           site's potential. Local planning authorities should refuse applications where
           they fail to make effective use of land and in this context, authorities should
           take a flexible approach to applying policies or guidance relating to daylight
           and sunlight, where they would otherwise inhibit making effective use of a site.

6.21       Paragraph      127     states    that   planning    decisions    should      ensure   that
           developments will function well and add to the overall quality of the area for
           the lifetime of the development, are visually attractive as a result of good

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Planning Statement

           architecture, are sympathetic to local character and create safe, inclusive and
           accessible places with a high standard of amenity for existing and future users.

7.0        ASSESSMENT AGAINST PLANNING POLICY AND MATERIAL
           CONSIDERATIONS

           Principle of the Development

7.1        The site is located within the defined settlement boundary of Bracknell, in a
           sustainable location approximately 0.5km from Bracknell Town Centre, walking
           distance from Bracknell Railway Station and conveniently located for a variety
           of bus routes. The redevelopment of Continuity House for residential purposes
           is therefore in accordance with the sustainable development and locational
           principles highlighted within Core Strategy Policies CS1 and CS2.

7.2        The development would result in the loss of an office unit, however Policy CS19
           only offers protection for small business units of 500m² or less, and non-office
           employment uses. The existing building has a floor area in excess of 500m²
           and its existing use is as office, therefore the loss of this use would not be
           contrary to Policy CS19. In any event, the principle of a change of use of the
           site to residential has been established via approved Prior Approval application
           20/00189/PAC.

7.3        As such, the principle of the development of the site for residential purposes is
           acceptable, and significantly encouraged by the NPPF policies already cited.

           Impact on the Character of the Area

7.4        As set out above, concerns were raised within the pre-application response
           that the proposal would constitute an over-development of the site. This
           concern was primarily due to the 20.5m height that was proposed and also due

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Planning Statement

           to the building extending beyond the existing building line on London Road.
           This was considered contrary to Policies CS7, EN20 and sections of the Design
           SPD relating to heights and building lines.

7.5        In response to the pre-application advice, the size of the proposed building has
           been reduced from six to five storeys which has resulted in a height reduction
           of 4.5m from 20.5m to 16m. As such, the number of apartments proposed has
           been reduced by six, from 27 to 21. The height reduction ensures that the
           building respects the height of adjacent buildings, taking into account the slope
           of the ground that falls from east to west along London Road and as advised,
           now has a height that sits in between the Travelodge and Summit House as is
           evident from the proposed street elevation as is evident from the below image.
           It would also be of comparable height to Apex House opposite. The reduction
           in height has also reduced the bulk and mass of the building, resulting in a less
           prominent addition to the street scene than that originally proposed. The height
           proposed being within the heights of adjacent buildings is consistent with the
           sentiment expressed by officers during pre-application discussions.

7.6        The amended scheme has also addressed the concern with regard to the
           previously forward building line. The main front elevation of the building would
           now sit level with the Travelodge in the same manner as the existing building.
           Although the balconies may project slightly forward, these are not the main

January 2021 | MR/NK | P19-2147.A                                                 Page | 13
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Planning Statement

           part of the building and their projection would not be significant, in a similar
           manner to the nearby flats at Kelvin Gate.

7.7        The pre-application raised no concerns with the design of the building, and a
           similar design is proposed with an inset roof above the main building. It is
           considered that this adds interest and results in a high quality design which is
           also highlighted through the use of different materials. The use of a mixture of
           brickwork and cladding will be in keeping with similar development on London
           Road which also use a similar mix of materials, such as a Fleming Place.

7.8        As such it is considered that the proposed building builds on local character
           and respects the character and appearance of the area through a high quality
           and sympathetic design. The concerns raised with the pre-application have
           been addressed, primarily through a reduction in height and setting the
           building back to ensure the existing building line is respected. An apartment of
           the building of the size and type proposed is entirely in keeping with the pattern
           of development in this location. The proposed redevelopment of the existing
           building rather than convert it in accordance with the extant permission,
           provides the opportunity to increase the efficiency of residential delivery at this
           sustainable site whilst providing a building of more visual interest and energy
           efficiency.

7.9        As such, the proposed development would be in accordance with Core Strategy
           Policy CS7, BFBLP Policy EN20 and the relevant sections of the Design SPD.

           Impact on Residential Amenity

7.10       As set out, the site is bordered by residential properties fronting Fielden Place
           to the rear, and by Summit House, a former office building that is in the process
           of being converted to residential unts, at the side. The pre-application response
           raised concerns with regard to the relationship of the new building with these
           properties. However, the relationship with the Travelodge, which is a hotel and
           not a residence, was not raised as an issue.

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7.11       With regard to Fielden Place, the pre-application response highlighted that the
           building has been carefully designed to minimise direct overlooking, however
           'the additional height and bulk of the building, together with its closer proximity
           to the rear boundary would result in an overbearing relationship with the two
           storey properties.' In response to this concern, the 4.5m reduction in height
           would significantly reduce the overbearing impact to the rear from that
           originally proposed and, as previously, the rear elevation has been carefully
           designed through stepping back the rear elevation, the use of obscure glazing
           to windows, skewing the building line and privacy fins to outdoor amenity areas
           in order to minimise any loss of privacy through overlooking.

7.12       The below images demonstrate how these measures have addressed the
           overlooking concern including the stepping back. The red dotted line highlights
           the privacy fin and the blue shading highlights windows utilising obscure
           glazing up to 1.7m from floor level.

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Planning Statement

7.13       To address the neighbouring amenity issues in detail, the proposals are now
           accompanied by the Eight Associates Daylight and Sunlight Impact Assessment
           which assesses the impact of the proposed development on the daylight and
           sunlight received by the neighbouring buildings in accordance with BRE
           Guidance. In respect of daylight this addresses the loss of light from the sky
           by an analysis of the Vertical Sky Component (VSC) of the windows in
           comparison to the existing. In terms of sunlight, the Annual Probably Sunlight
           Hours (APSH) to both windows and gardens is assessed.

7.14       Regarding the properties on Fielden Place, the analysis shows that all windows
           meet with both the VSC and APSH recommendations and as such there would
           not be an unacceptable loss of daylight or sunlight to habitable windows.

7.15       In respect of gardens, the layout of these properties has been taken from land
           registry records in order to present an accurate analysis of the impact. As
           shown, the land to the rear of 28-31 Fielden Place has been split up into four
           separate gardens (Gardens 2-5). In summary, all gardens meet the
           recommendations for daylight hours with the exception of Garden 4, however
           as proposed 31m² of the total 94m² garden would continue to receive
           acceptable levels of sunlight. The area most affected by the development
           adjacent to the fence is significantly shaded as existing, and as such it is not
           considered that the additional impact from the development on this part of
           garden would be so harmful to amenity that refusal of the application would
           be warranted. The flexible approach taken by the assessment is consistent with
           the flexible approach encouraged by Paragraph 123(c) of the NPPF.

7.16       In terms of Summit House, the pre-application response raised concerns with
           regard to loss of privacy as well as a loss of daylight and sunlight, and an
           overbearing relationship between the two buildings. The accompanying
           daylighting assessment demonstrates that all windows at Summit House meet
           the VSC recommendations with the exception of eight windows on the side
           elevation of the building. However, all the affected windows serve dual-aspect
           rooms and are secondary side facing windows, with the primary windows
           remaining unobstructed. The secondary side facing windows in this urban areas
           would not be expected to receive significant daylight, and the unobstructed

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Planning Statement

           front facing windows will avoid any harm caused by a loss of daylight. All
           windows meet the APSH recommendations. As such, the analysis has
           demonstrated that there would not be an unacceptable loss of daylight or
           sunlight to habitable rooms at Summit House.

7.17       The floor plans set out how the privacy issue has been addressed. No primary
           windows would face directly towards Summit House at first, second or third
           floor level. Whilst at fourth floor level windows would face to the side, these
           would be inset and at a higher level than side facing windows at Summit House
           as is evident from the elevation drawings. Privacy screens would ensure no
           overlooking from terraces. As such there would not be a loss of privacy to
           Summit House as a result of the proposals.

7.18       The assessment makes reference to further properties including Travelodge
           and also residential properties opposite. No concerns are identified that could
           be considered a loss of amenity to neighbouring properties. The report
           concludes that the development would have a minor impact on neighbouring
           amenities, and such an impact would not be unacceptable as per BRE guidance
           or Policy EN20.

7.19       As such, it is considered that the amendments made and the additional analysis
           provided by the Daylight and Sunlight Impact Assessment have demonstrated
           that the development would not result in an unacceptable loss of amenity to
           neighbouring residential properties either through loss of light, an overbearing
           impact or a loss of privacy through overlooking.

7.20       Regarding future occupiers of the building, the floor areas proposed are
           considered to provide an acceptable standard of accommodation. Balconies and
           terraces would provide outdoor amenity areas.

7.21       It is considered that the proposal has demonstrated that the development will
           not result in an unacceptable loss of amenity for any of the surrounding
           residential properties whilst providing an acceptable level of amenity for future
           occupiers. It is therefore in accordance with BFBLP Policy EN20 and the NPPF.

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           Parking and Transportation

7.22       The application is accompanied by a Transport Statement from Velocity
           Transport Planning which highlights the primary highways considerations of
           the site and how the proposals have responded.

7.23       As highlighted above, the site is in a highly sustainable location, 0.5km from
           Bracknell Town Centre which provides a wide range of shops, amenities and
           other facilities. A range of schools and local employment opportunities are also
           within walking distance of the site. It is within walking distance of Bracknell
           railway station and London Road is well served by a number of bus routes with
           bus stops on either side of the road in close proximity to the site. It is also well
           connected to a network of cycle routes.

7.24       Due to the sustainability merits of the site, it is not considered that residents
           of the development would be reliant on the private car. It should therefore be
           ensured that appropriate opportunities to promote sustainable transport are
           taken up in accordance with Paragraph 108 of the NPPF.

7.25       The pre-application scheme proposed 26 parking spaces for 27 apartments,
           broadly in line with Parking Standards for Bracknell Town Centre which require
           0.9 spaces per unit. Despite the sustainable location of the site, the pre-
           application response highlighted concerns that the parking provision would be
           insufficient and that observations have shown a demand of 1 – 1.5 spaces per
           unit.

7.26       The revised proposed have reduced the number of apartments to 21, which
           will be served by 25 vehicle parking spaces. Proportionately, this has increased
           the provision to 1.19 spaces per unit, thereby providing parking in accordance
           with the likely demand highlighted within the pre-application response and
           exceeding    the     parking   requirements   for   town   centre   locations.   The
           accompanying Transport Statement sets out the evidence that the parking
           strategy has been based upon and demonstrates that this level of parking
           would exceed the likely parking demand within this area of Bracknell.

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Planning Statement

7.27       In terms of management, parking spaces would be allocated to residents rather
           than specific units with the exception of one instance of tandem spaces for two
           vehicles which will be allocated to a specific two bedroom apartment. This
           enables the parking capacity to be maximised so that spaces are not vacant in
           the event an occupier does not own a car. In any event, there is capacity for
           parking provision of at least one space per unit and visitor parking. The spaces
           provide the required manoeuvring 6m distance and two accessible spaces are
           shown in accordance with the standards.

7.28       It is considered that the parking strategy provides sufficient parking for a
           development in this location whilst also not over-providing parking and
           discouraging residents and their visitors to use sustainable transport modes to
           access the site, in accordance with Development Plan policy and the NPPF. The
           parking provision, together with the Council's Residents Parking Scheme, will
           ensure that there would be no overspill of parking onto surrounding roads, to
           the detriment of highway safety.

7.29       Covered and secure cycle parking has been provided on a per-bedroom basis
           with 28 such spaces proposed. A further 6 short stay spaces would be provided
           on Sheffield Stands adjacent to the cycle store. The cycle provision complies
           with the Council's standards.

7.30       The existing 'in and 'out' access will remain to serve the development. The pre-
           application response raised no concerns regarding the use of this access for a
           residential site in principle however it was requested that swept path analysis
           for refuse and delivery vehicles be provided. These are set out in the Transport
           Statement and, as highlighted, some works to the public highway are required
           to ensure that Council refuse collection vehicles can access the site.
           Alternatively, if highway works were not possible, then a private company
           could be appointed who use smaller refuse vehicles which, as demonstrated,
           can access the site with no works necessary.

7.31       Pedestrian access would remain via the adopted footway that crosses the front
           of the site. As good visibility exists, it is not considered that any further
           demarcation of access at the site is necessary in order to ensure pedestrian

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Planning Statement

           safety.

7.32       Refuse storage is proposed in the same north west corner of the site as the
           existing, and would not conflict with manoeuvrability around the site.

7.33       The pre-application response did not raise any concerns with regard to the
           traffic impacts of the development, and as the number of units has been
           reduced from 27 to 21 the resultant impact has also been reduced. In any case,
           the Transport Statement highlights that the proposed use would result in a
           reduction in trips compared to the existing.

7.34       As such the proposed development would not result in an adverse impact on
           highway safety, and would promote the use of sustainable transport modes on
           an appropriate site. The proposal would therefore be in accordance with Policy
           CS23, CS24 and M9, and Paragraphs 108 and 109 of the NPPF.

           Trees and Landscaping

7.35       The pre-application response acknowledges that the site has limited tree
           planting as existing and it was recommended that the planning application be
           accompanied by a tree survey and arboricultural impact assessment to deal
           with the potential impact on trees.

7.36       The development would ensure the retention of T2 on the site frontage to the
           south east. The submitted assessment demonstrates tree protection measures
           to ensure the long term retention of this tree.

7.37       Outside the site ownership to the rear, but close to the site boundary are two
           Ash trees references T9 and T11. A significant portion of T9 overhangs the site
           and the tree is of poor form and structure as past pruning works have resulted
           in the creation of a small, high crown. The accompanying assessment sets out
           that there is a risk of failure at present due to the form and structure of the
           tree and as such there is a threat from the tree, both to the existing building
           and to future residents of the proposed building.

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Planning Statement

7.38       As set out above, discussions have taken place with Silva Homes with regard
           to the approach to T9. It has been agreed with the adjoining landowner that
           the tree will be removed, and replanting will be provided. Given the existing
           condition of the tree, it is considered that removal of the tree is required to
           alleviate the risk of failure regardless of the proposed development and it
           removal and replacement with a more appropriate species would have
           arboricultural benefits. T11 will be protected by the proposed tree protection
           measures.

7.39       Providing the measures with the Arboricultural Impact Assessment are
           followed, the arboricultural impact of the development is acceptable.

           Biodiversity

7.40       The pre-application response set out that a bat survey is recommended for any
           application due the presence on the existing building of pitched roofs that may
           have the potential to support roosting bats.

7.41       The application is accompanied by a Preliminary Roost Assessment from
           MMEcology which confirms that the building has negligible potential for
           roosting bats. As such no emergence and re-entry surveys are required and
           the proposed development can be carried out with no constraints in relation to
           roosting bats.

7.42       The application is also accompanied by a report from Eight Associates
           concerning Biodiversity Net Gain which makes a number of recommendations
           to improve the ecological value of the site such as the installation of bat and
           bird boxes and the green roof that is already detailed on the application plans.
           If additional detail is required, this can be secured via condition.

           Surface Water Drainage / Flood Risk

7.43       The pre-application response confirmed that a SuDS scheme would be required
           as the proposal is for major development, and that this should aim to reduce

January 2021 | MR/NK | P19-2147.A                                                  Page | 21
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Planning Statement

           runoff rates. The application is accompanied by the GeoSmart SuDS report
           which confirms that 34.2m³ of attenuation is needed to be provided to ensure
           there is no flooding in all storm events. An attenuation tank is therefore
           proposed to provide the required amount of attenuation, with surface water
           then discharged to a nearby sewer via the existing connection at a rate of 2
           l/s. Foul water will be discharged into the nearby sewer via the existing
           connection.

7.44       The report confirms that there would be no change to the impermeable
           footprint of the site, therefore the proposed attenuation would improve the
           situation in comparison to the existing.

7.45       The report also confirms that the site has negligible risk of fluvial flooding,
           surface water flooding or groundwater flooding. Due to the location of the site
           within Flood Zone 1 and it size below 1ha, a site-specific Flood Risk Assessment
           is not necessary. The low flood risks of the site were confirmed as part of the
           prior approval.

           Contamination

7.46       The pre-application response raised no concerns with regard to contaminated
           land. Notwithstanding this, the site is within a 250m buffer zone of a landfill
           site and has a previous use as a petrol station, as was noted in the prior
           approval application. That application was accompanied by a Contamination
           Report which concluded that the site is appropriate for residential use.

7.47       Similarly, the application is accompanied by a Phase 1 Contamination Report
           which again confirms that the site is suitable for residential development
           subject to confirming     that the fuel infrastructure on      site has been
           decommissioned and remediated as appropriate. It is recommended that
           during the demolition phase and prior to any construction works that below
           ground investigations are completed across the site to confirm there is no
           historic contamination.

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Planning Statement

           Sustainability

7.48       The pre-application response states that a Sustainability Statement and Energy
           Demand Assessment are submitted to ensure compliance with Core Strategy
           Policies CS10 and CS12. It is requested that these details are secured by means
           of planning conditions.

           Affordable Housing and Viability

7.49       The proposed development would provide a net increase of 21 units and as
           such would exceed the council's threshold for affordable housing to be
           provided. As set out within Paragraph 194 of the core strategy, which supports
           Policy CS17, consideration will be given to the economics of provision and the
           relevant circumstances of the site.

7.50       This is consistent with the NPPF which, at Paragraph 57, states that it is up to
           the applicant to demonstrate whether particular circumstances justify the need
           for a viability assessment at the application stage. The weight to be given to a
           viability assessment is a matter for the decision maker, having regard to all
           the circumstances of the case including whether the evidence is up-to-date.

7.51       The application is accompanied by a Viability Report that has been prepared
           by Kempton Carr Croft in response to the affordable housing requirements.
           This demonstrates that the proposed development cannot support any element
           of affordable housing contribution, either on-site or off-site, as the level of
           profit is already below the necessary required by lenders in order to fund the
           scheme. If any further reduction in profit occurs, then the scheme will become
           unviable and it will be unlikely that it would be able to proceed.

7.52       This report comprises an up-to-date assessment (completed 18th December
           2020) and demonstrates that to meet the Council's affordable housing
           requirements would render the development unviable. It is considered that this
           robustly justifies why a contribution to affordable housing should not be sought
           on this development.

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Planning Statement

           Impact on Thames Basin Heath SPA and Infrastructure Contributions

7.53       As the site lies within 5km of the Thames Basin Heath SPA, the planning
           application will require an Appropriate Assessment which the Council will carry
           out in consultation with Natural England. As the proposal is for over 10
           dwellings, the Council will need to confirm whether SANG capacity is available
           for the development or if capacity from a third-party provider needs to be
           purchased.

7.54       In either event, the SANG solution, together with a SAMM payment, will be
           secured via a Section 106 Agreement. This will also be utilised to secure
           necessary infrastructure contributions.

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Planning Statement

8.0        CONCLUSIONS

8.1        Continuity House is sustainably located, and re-development of the site is for
           residential   purposes   is   in   accordance   with   the   Council's   sustainable
           development and locational principles. The application follows a pre-application
           enquiry which raised concerns with the proposal, particularly in regard to the
           impact on the character of the area and residential amenity.

8.2        The development proposal now submitted has responded to these concerns,
           and reflects significant alterations to address them. These include a significant
           4.5m reduction in height, substantial reduction in unit numbers, redesign of
           the rear of the building to remove bulk, and also through the provision of
           additional information as requested. It is considered that it is now
           demonstrated that the proposal is in accordance with relevant development
           plan and national planning policy, and as such it is respectfully requested that
           Bracknell Forest Council approve the application, thereby granting planning
           permission for the development and making an efficient use of a sustainable
           brownfield site.

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