Bond Riverside Webinar Q&A

Here you can find the answers to the questions asked on the public webinar held for LRIE. These questions cover a varied range of subjects that are frequently asked.

If you have any questions you would like to ask the team, please email economicdevelopment@westberks.gov.uk and we will get back to you as soon as possible.

Please click on the question to see the answer below.

LRIE Webinar Q&A

Ross: It’s important to understand the distinction between the Council as landowner and the Council as Local Planning Authority. Where planning is concerned, the Council as landowner and all LRIE leaseholders must comply with planning policy like any other developer. There are no short cuts – all planning applications are determined as part of a statutory process.

Note: All Councils are required to ensure that there is no conflict of interest on planning matters when they are also landowner – that is normal practice. Planning decisions are not based on who owns a site but on area-based national and local planning policy. This applies both to planning applications and draft Supplementary Planning Documents.

Football Ground Questions

Q: Currently the football ground is not highlighted as part of the employment zone of the London Rd industrial estate. Why does this change under the new plans? What demonstrable evidence do you have that this is needed?

Q: The Football Ground predated the creation of the LRIE and is clearly not an area of protected employment – it’s classified as CS18 which clearly states “The District’s green infrastructure will be protected and enhanced.” Why is this Council including the football ground as part of the LRIE, when it clearly isn’t and shouldn’t be?

Q: A part of any new proposal will the Council now consider, as an option retaining and developing the football ground as a much-needed long term sporting venue?

Q: Where will the replacement football ground be for Faraday Road? And when will it be delivered?

Housing Questions

Q: Cllr Ross McKinnon has stated "Our aspirations for the LRIE are very clear - it is an employment site that supports many local jobs and businesses, and its regeneration must be economic development led”. This is very different to what was proposed by St Modwen and Avison Young, both of which focused on housing. Please can Cllr McKinnon confirm that (except for possibly Faraday Plaza) no further housing will be allowed as part of this latest LRIE proposal.

Finance Questions

Q: When could the tax payer expect a return on the money?

Q:How does the amount of expected revenue compare between building residential units and commercial units on the football pitch?

Q: What steps has the council taken to establish that building on the football pitch is viable?

Environment Questions

Q: Will the regeneration be carbon neutral?

Q: Thanks Eric, that doesn't answer the question on if it will be a carbon neutral redevelopment - but sounds more like a part of the larger strategy.

Q: Will it be an exemplar development for the environment? And lead the way?

Q: What will be the environmental elements mentioned as part of the regeneration?

Business Case and Needs Questions

Q: What evidence has been used by the Council to justify the need for additional commercial units on the LRIE?

Q: When will a full and detailed business case be produced with respect to this updated proposal for the LRIE and who has been tasked to produce it?

Employment Questions

Q: I wanted to draw the attention of the councillors to the shortage of laboratory space in the Oxford/London/Cambridge triangle and wondered if this could be an opportunity for Newbury to attract high value investment and jobs given our proximity to Oxford, Heathrow and our excellent road and transport links?

Q: How does the council which is an organisation that is not run like a business expect to create high paid jobs from businesses occupying the industrial units?

Q: Is there provision for affordable industrial units in your plans?

Q: Has the new plan put into place the future 'money-making' buildings and company buildings that will be needed to provide the future prosperity of the Town?

Planning Questions

Q: How has the current plan differed from the original plan?

Q: Will the road systems be capable of handling the traffic expected?

Q: Will there be homes available for the workers that will be needed?

Q: Is the Town to become a HUB or peripheral suburb to Reading?

Q: When will planning applications be submitted?

Q: Is the Council attempting to salami slice the LRIE by using a supplementary planning document (SPD) to avoid an Environmental Impact Assessment (EIA)?

Q: How much CIL tax is likely to be paid to WBC (the planning authority)?

Flooding Questions

Note: We acknowledge that people have concerns about flooding in the wider area and that these have been linked to our approach to LRIE. We will continue to listen and respond to those concerns whenever they are expressed. However, assessing flood risk is an iterative process. Any risks arising as a result of anticipated new development on LRIE will be assessed at the appropriate time. These matters were considered as part of a high level Environmental Appraisal Report of the now superseded LRIE Development Brief in 2021, available on our website. They will be considered again during the development of the site-wide Place-making Strategy as part of our refreshed approach to LRIE, again at individual planning application stage and again as part of any draft Supplementary Planning Document.

Q: What will be done to mitigate the flood risk?

Q: Has the council got any estimates of the amount of land and cost to provide critical infrastructure and attenuation ponds for the site?

Q: What measures will be taken to prevent pollution of the Northbrook stream?

Q: The vast majority of the site sits within flood zones 2/3, what is the cumulative flood risk for local residents if the redevelopment goes ahead?

Q: Has a cumulative flood risk assessment been conducted across the site, and rest of the Clay Hill and surrounding wards?

Q: Pollution is often seen in the Northbrook stream which flows through the estate and past local residents’ houses, what will be done to improve this? And stop this if the regeneration goes ahead?

Q: Is it possible to redevelop the LRIE without a masterplan outline planning permission that includes the necessary third-party land downstream to conform to common drainage law and planning policy?

Q: Does the council still believe it can regenerate the estate without going beyond the red line?

Football Ground Questions

Katharine: So to be absolutely clear there is no change to the LRIE Protected Employment Area as set out in the current Core Strategy and in the emerging draft of the Local Plan Review. The former football ground continues to lie outside the boundary of the LRIE Protected Employment Area and that is not disputed. However, it is important to remember, we heard already there is significant shortfall in the provision of employment space in West Berkshire and that was identified in the Employment Land Review of 2020 which is part of the evidence base for the Local Plan. So, nothing has changed in that respect.

Geraint: From our point of view, we are always looking around the edges of the site and the points of arrival and that side of things. The sense of arrival and the sense of perception that you get from that it’s going to be a key to changing and refreshing the estate. So, there are two particularly important arrivals. One is probably more obvious, which is the A339 and Fleming Road arrival, particularly for those arriving by car. But also for the pedestrian crossing coming across from Victoria Park. The second important arrival is the southern end of Victoria Park and the canal and coming under the A339 particularly coming that way from the town centre, but also from the bus station and the rail station. And if we are looking to promote active travel and sustainable travel as part of that strategy for the industrial estate than that arrival from the southern area gateway is obviously is going to be a key part of creating that arrival and encouraging people to travel that way.

Wayne: Just from me as well in that way looking at the chat it says ‘we did a good job on the Town Centre Masterplan’, we did that because at this stage we are a ‘sponge’ and people should absolutely feel free. We’re not some people riding in on white stallions to solve all the problems of every project we work on. We listen and genuinely we want to hear from you and you can go to Hemingway Design website and email us (info@hemingwaydesign.com) or there will be plenty of opportunities in the next weeks where we would like to speak to you. And we know that lots of good ideas would come from that, a thinking that we would have missed.

There is a distinction to be made between the Council as Local Planning Authority and the Council as landowner. In planning terms, the former football ground continues to lie outside the boundary of the LRIE Protected Employment Area and is protected. However, national and local planning policy allows for the redevelopment of sports pitches if certain conditions are met, including alternative provision. The Council as landowner is promoting alternative provision outside the LRIE but it is for the statutory planning process to determine whether or not redevelopment of the former football ground should be permitted.

The Council as landowner sees the former football ground as part of LRIE. The LRIE refreshed approach set out alternative options including retention of the site for recreation, which includes football. However, Executive on 9th June 2022 decided not to do this, on the basis that retaining the former football ground in recreational use would limit LRIE’s potential to achieve economic regeneration, investment in green growth, more and better quality jobs and making a positive contribution to carbon neutrality. You can read more about the reasoning behind this decision in Executive Report EX4219.

Q: A part of any new proposal will the Council now consider, as an option retaining and developing the football ground as a much-needed long term sporting venue?

The Council as landowner continues to view the former football ground as part of LRIE. Executive on 9th June 2022 considered and rejected the option of retaining the football ground for recreation, which includes football. This decision was made on the basis that retaining the former football ground in recreational use would limit LRIE’s potential to achieve economic regeneration, investment in green growth, more and better quality jobs and making a positive contribution to carbon neutrality. You can read more about the reasoning behind this decision in Executive Report EX4219.

Q: Where will the replacement football ground be for Faraday Road? And when will it be delivered?

The Council as landowner is promoting alternative provision for football at locations outside the LRIE site in order to enable the former football ground to be redeveloped for employment use. Our Sports and Leisure team is working very hard to deliver this alternative provision. In planning terms, the location of the replacement facility or facilities will be determined at the point when the Council as Local Planning Authority determines a planning application to redevelop the former football ground site.

Housing Questions

The Council as landowner at this time has moved away from the residential-led housing approach put forward by St Modwen and Avison Young.The provision of housing does not feature in the refreshed approach to LRIE approved by Executive in June 2022.However, we acknowledge that housing is included in the Faraday Plaza development proposal which received planning permission on appeal in 2016.The Council as landowner wants to see more employment and jobs on LRIE but the Council as Local Planning Authority must determine any planning application on its merits and we can’t pre-judge the statutory planning process

Finance Questions

Q: When could the tax payer expect a return on the money?

Katharine: The key principle of this regeneration is to intensify uses of employment space, to safeguard and create jobs, so creating extra income is important but it is secondary to our delivery strategy.

But in terms of dates, by end of 2024 and of course subject to planning, we would expect to see a substantial proportion of the depot site occupied by new long leaseholders and they would be paying long term ground rents and they should hopefully create more jobs than the current short term business tenants.

And by the end of 2026, as outlined in our delivery strategy and subject to planning, we expect to see the playing field site occupied by new leaseholders and again paying ground rents. And – a general point really - projects like London Road Industrial Estate are really about making a return on investment through asset improvement and therefore increased asset value and income for the longer term.

So, it’s really important that older industrial estates like London Road are updated and sustained for the future in order to remain viable. I can see Simon (LEP) is agreeing with me. Beyond the target dates that have been set for the depot and the playing field sites, we would be expecting to see the wider return on investment by 2030.

Q:How does the amount of expected revenue compare between building residential units and commercial units on the football pitch?

We have not carried out a direct comparison because in early 2022, we asked Avison Young to carry out informal (i.e. not Red Book) valuations based on the 2020 Development Brief to determine potential capital receipts and help inform return on investment.The valuations were carried out on the two Council-controlled parcels of land – the former depot (industrial space) and the former football ground (market housing).The report concluded that residential land values and light industrial land values have reached parity, and this is borne out by the current markets.

Q: What steps has the council taken to establish that building on the football pitch is viable?

The Council commissioned Avison Young to carry out Soft Market Testing with potential development partners in early 2022.Interest was sought from a broad range of developers including mixed-use developers, housebuilders and employment regeneration specialists to inform deliverability. Views were invited on the former depot site for commercial use and the playing field for housing, as outlined in the 2020 Development Brief. In addition, the Council commissioned Avison Young to carry out informal (i.e. not Red Book) valuations based on the 2020 Development Brief to determine potential capital receipts and help inform return on investment. The valuations were carried out on the two Council-controlled parcels of land – the former depot (industrial space) and the former football ground (market housing).You can read more about this work and how the outcomes contributed to the refreshed approach in Executive Report EX4219, approved by Executive in June 2022.

Environment Questions

Q: Will the regeneration be carbon neutral?

Eric: The council is committed to carbon neutrality across many of the areas that it is working in. London Road is included within that and it’s in line with our wider Environment Strategy, which is to achieve carbon net zero for the district by 2030. The first step is to establish the existing carbon footprint for the site, and we are procuring energy consultants to work with us, that is out at the moment. That would then set targets for carbon reduction and develop an Energy Strategy which we can take forward in partnership with new and existing leaseholders and businesses and work together to hopefully secure and deliver. That would form part of the wider Place-making strategy and we are looking to include that in the draft Supplementary Planning Document in due course. So, very much out there in terms of our agenda, one of the key focal points, and as you are going to hear, we are investing and it is core to the Place-making Strategy.

Q: Thanks Eric, that doesn't answer the question on if it will be a carbon neutral redevelopment - but sounds more like a part of the larger strategy.

That’s broadly right. Once we know the existing carbon footprint of LRIE, we will know how much work there is to do to achieve carbon neutrality and the LRIE Energy Strategy will work towards this. It’s too soon to say for sure whether the redevelopment will be carbon neutral.

Q: Will it be an exemplar development for the environment? And lead the way?

We would hope that the development will lead by example and which is why our strategic objectives, which we aim to have achieved by 2030, include sustainable economic regeneration, green economic growth and a positive contribution to the district’s carbon neutrality aspirations. However, our overall focus is on employment and jobs so it’s important to get the balance right.

Q: What will be the environmental elements mentioned as part of the regeneration?

It’s too early to say. Environmental elements to improve the site will be considered during the development of the Place-making Strategy. These could include Sustainable Urban Drainage Systems (SUDS), tree planting, pocket parks, energy efficiency measures and road surface treatments. We will look to provide these on the land that we control and we will encourage existing and new leaseholders and tenants to do the same.

Business Case and Needs Questions

Q: What evidence has been used by the Council to justify the need for additional commercial units on the LRIE?

The Council commissioned Avison Young to carry out Soft Market Testing with potential development partners in early 2022.In addition, the Council commissioned Avison Young to carry out informal (i.e. not Red Book) valuations based on the 2020 Development Brief to determine potential capital receipts and help inform return on investment. You can read more about this work and how the outcomes contributed to the refreshed approach on LRIE in Executive Report EX4219, approved by Executive in June 2022.

In addition, the Employment Land Review 2020 identified a significant shortfall in the provision of employment floor space in West Berkshire, having assessed future demand, existing and committed future supply and current unmet need across the district. The ELR also identified an imbalance in provision in Newbury. Paragraph 10 of the Executive Summary of the ELR states that “the gap in the overall balance (circa 34,000 sq m) could be met through a combination of new office provision on the London Road Industrial Estate, redevelopment schemes in Newbury town centre, and/or mixed-use allocations on larger housing sites”. Para 13 of the Executive Summary of the ELR states that “None of the promoted industrial sites are in Newbury, which is an imbalance that could be made worse should the London Road site be redeveloped for non-industrial uses.”

You can find the Employment Land Review on our website at https://www.westberks.gov.uk/local-plan-evidence

Q: When will a full and detailed business case be produced with respect to this updated proposal for the LRIE and who has been tasked to produce it?

There is no need for a full and detailed business case. The Council’s Executive considered and approved the refreshed approach to the LRIE in June 2022 and we are now in the programme delivery phase.

Employment Questions

Simon: I can certainly support the question in terms that there is a shortage and there is demand. I think it’s talking to the people that provide the space, in order to see whether there is particular interest in that area. Because it’s very expensive space to build and therefore you would need to have a developer that is interested in putting that in the area. But there is no reason why it shouldn’t go into that space, but certainly Katherine from your economic development perspective, do you have any view on that?

Katharine: Yes, I was excited by this question. I thought it was an excellent suggestion, and I completely agree that Newbury is well placed to support the development sector centred around Oxford University. And of course we have Harwell Science and Innovation Campus just down the A34. We are certainly looking to take this forward, and I am looking at you Simon as the man with the money bags to help and again any leaseholders out there or anyone out there interested in taking this forward, let’s have a conversation.

Q: How does the council which is an organisation that is not run like a business expect to create high paid jobs from businesses occupying the industrial units?

Simon: You have a place-making agenda and you are the landlord, it means you want the best high quality use for the site as possible. So, I think it is the role, and we are seeing that more and more now as a LEP, that the Local Authorities are taking a lead in actually influencing and being a leader in changing those economic circumstances.

And you don’t have all your levers at your hand, but you do - in fact you are the landowner here and influencer, you can make investments in there. And we have seen this right across Berkshire. I was at a launch in neighbouring Reading and a piece of land that they have just put on the market as a large local authority looking for larger major development there.

There is a real place for LAs to be ‘Place Leaders’ now, and I think we have seen the very best examples of that happening across the country, so I would certainly advocate that it is a role for you to do that. You have an economic development department, the economy is good for the residents. Flamboyant, vibrant economy, the residents benefit as well.

Eric: I echo and emphasize what Simon is saying. The Council as a landowner is committed in working in partnership with new and existing leaseholders and tenants to help stabilise and enhance the exiting business portfolio but to also bring forward further investment on the site. It’s in line with our strategic objectives, our own job creation which again the Executive have approved this year. I very much support what Simon is saying and thank you for that. It is really helpful.

Q: Is there provision for affordable industrial units in your plans?

Katharine: I was really happy to see that question, actually. We’ll be delighted if anyone is going to come forward with some proposals for affordable industrial units and we are really looking to work with external partners. Simon, would you have anything to add?

Simon: I talked in my presentation about how you can incubate and start businesses, therefore the need for affordable start-up units, and they could be formatted in a number of ways we have seen. So, the things with ratchet rents, bring people in on a very low rent, below market and over a period of time you gradually increase their rent on yearly basis to above market to hopefully to get them to move on so new businesses could come in. So overall you get a reasonable return on your investment, getting people in and giving those businesses the start point in order to get on the business ladder, start getting their costs under control, working forward. So, I think those affordable ones enable businesses to do that, and Local Authorities are much better positioned to try and influence that to get them. You don’t get the full commercial return, but you are getting a reasonable return. I also counter in terms of cheap rents, because if rents are too cheap, you don’t sufficient income in to make the investment in the property in the first place. So, what we find with very run down units is that rental income goes down and down, and therefore there is not a business case for the landlord to invest to bring on an improvement. There is a fine balance between affordable and too cheap. It needs to work for both, the landowner and also the tenant going in as well.

Q: Has the new plan put into place the future 'money-making' buildings and company buildings that will be needed to provide the future prosperity of the Town?

The Place-Making strategy, particularly focusing on the public realm and amenities and the strategies that we come up with, is designed to attract those buildings and those employers. Exactly what those are, the point is that whether they are office, industrial, or warehousing, those businesses and their employees are seeking the same types of facilities and amenities, and the same things from their time at work. So, we would be providing that structure and that takes some ability to attract those businesses, but it will happen over time. We wouldn’t want to produce something so rigid that is identifying what all those businesses and buildings would be now, in the next 6 months for our study.

Planning Questions

Q: How has the current plan differed from the original plan?
There have been several different proposals for the regeneration of LRIE over the years. This includes the procurement of St Modwen as development partner, which ended in 2018 after legal proceedings, and the 2020 adoption of a residential-led Development Brief prepared by consultants Avison Young. Further details about the historic approaches are available on our website at https://www.westberks.gov.uk/lrie . In summary, the refreshed approach differs from the previous proposals in that it includes:

A focus on attracting investment in employment space and jobs that aligns with Carbon Net Zero ambitions;

A commitment to working in partnership with leaseholders to grow current LRIE businesses in a sustainable way and encourage new businesses;

A sustainable design-led approach to place-making to create an appealing destination for businesses that includes seeking external funding for public realm improvements;

A move away from the residential-led approach set out in the 2020 Development Brief.

You can find out more in Executive Report EX4219, approved by Executive in June 2022.

Q: Will the road systems be capable of handling the traffic expected?

The local road network has already benefited from the A339 widening and LRIE access scheme completed in 2017.The objectives of this scheme, which attracted £1.9m in funding from the Local Economic Partnership, were to enhance the economic vitality of West Berkshire by facilitating growth, to establish a direct access to LRIE from the A339 to make new investment possible, to make best use of transport networks and to improve air quality around congested junctions. The highways impact of any new development on LRIE will be assessed as part of the planning application.

Q: Will there be homes available for the workers that will be needed?

The Local Plan Review currently underway is looking at the need for housing as well as employment space across West Berkshire up to 2037.You can find out more about the Local Plan Review on our website at https://www.westberks.gov.uk/local-plan-review-2037

Q: Is the Town to become a HUB or peripheral suburb to Reading?

The Council is committed to ensuring the future prosperity of Newbury and its other town and district centres, to meet the needs of existing and future residents and businesses. We have set this out in our Newbury Town Centre Vision and Masterplan approved in February 2022, which was developed by Hemingway Design with input from thousands of residents, businesses and stakeholders.

Q: When will planning applications be submitted?

The refreshed approach to LRIE approved by Executive in June 2022 sets out a target of mid 2023 for submission of a planning application for the depot site and end 2024 for submission of a planning application for the playing field site. However, the exact timing of submission would be a matter for whichever leaseholder or developer is successful in securing all or part of each site, subject to planning permission.

Q: Is the Council attempting to salami slice the LRIE by using a supplementary planning document (SPD) to avoid an Environmental Impact Assessment (EIA)?

No – there is no ‘salami’ here to slice as we’ve moved on from proposing wholesale redevelopment for LRIE as set out in the 2020 Development Brief. The refreshed approach approved in June 2022 focusses on seeking new leaseholders to develop the depot site and playing field site which we control, and on working with existing leaseholders on the rest of the site.

To be clear, an Environmental Impact Assessment (EIA) is a statutory document required for certain applications during the planning application process. Any environmental impacts as a result of anticipated new development on LRIE will be assessed at the appropriate time. The Council as landowner has already commissioned a high level Environmental Appraisal Report of the now superseded LRIE Development Brief in 2021, available on our website. Environmental impacts will be considered again during the development of the site-wide Place-making Strategy as part of our refreshed approach to LRIE, again at individual planning application stage (when an EIA may be required) and again as part of any draft Supplementary Planning Document.

Any draft SPD will have to go through the statutory planning process at various stages including public consultation before being adopted by the Council as local planning authority.

Q: How much CIL tax is likely to be paid to WBC (the planning authority)?

The amount of Community Infrastructure Levy that applies to a development proposal is a matter for the Council as Local Planning Authority to determine and would be calculated at planning application stage. We’re not at that stage yet.

Flooding Questions

Q: What will be done to mitigate the flood risk?

In terms of flood risk, as we know assessing flood risk is an iterative process and it does occur at various stages whenever development is proposed. We have started considering it already as part of our high level Environmental Assessment Report, which we did at the end of last year based around the superseded Development Brief. Obviously, we have moved on. So it will be considered again, in terms of flood risk and mitigation, during the development of the Place-Making strategy. This is why we have appointed some SUDs sub-consultants who’ll be working with Hemingway on that. Also, flood mitigation would be considered during the individual planning application stage and also as part of any draft Supplementary Planning Document, which would of course have to go through public consultation. So, there are lots of stages in which that will be considered.

In addition, as landowner we are committed to working with those leaseholders and tenants who are already on the site to promote the use of things like SUDs (sustainable urban drainage systems) and we would also like to be working with development bodies like the Environment Agency and Thames Water to see whether there are any further improvements that can be made. And this too will be addressed as part of the Place-Making strategy.

Q: Has the council got any estimates of the amount of land and cost to provide critical infrastructure and attenuation ponds for the site?

No. These matters will be considered during the development of the Place-making Strategy but we won’t know the exact requirement for infrastructure and drainage until individual development proposals come forward.

Q: What measures will be taken to prevent pollution of the Northbrook stream?

The Northbrook Stream flows through the site in a culvert beneath Fleming Road, the Thames Water-owned plot and Ampere Road. Any risk of pollution to the Northbrook Stream as a result of anticipated new development on LRIE would need to be assessed at the appropriate time (see note above).

Q: The vast majority of the site sits within flood zones 2/3, what is the cumulative flood risk for local residents if the redevelopment goes ahead?

Information about the cumulative impact of development on flood risk within the catchment area that includes LRIE may be found on the Council’s website under Strategic Flood Risk Assessment. Any increased risk as a result of anticipated new development on LRIE will be assessed at the appropriate time (see note above).

Q: Has a cumulative flood risk assessment been conducted across the site, and rest of the Clay Hill and surrounding wards?

Information about the cumulative impact of development on flood risk within the catchment area that includes LRIE may be found on the Council’s website under Strategic Flood Risk Assessment.

Q: Pollution is often seen in the Northbrook stream which flows through the estate and past local residents’ houses, what will be done to improve this? And stop this if the regeneration goes ahead?

The Northbrook Stream flows through LRIE in a culvert beneath Fleming Road, the Thames Water-owned plot and Ampere Road. Anyone who has concerns about pollution in the Northbrook Stream should raise these with the responsible authorities, which in this case are Thames Water and the Environment Agency. It is for those authorities to investigate the concerns and follow them up with those responsible. Any risk of pollution to the Northbrook Stream as a result of anticipated new development on LRIE would need to be assessed at the appropriate time (see note above).

https://www.thameswater.co.uk/help/emergencies/pollution

https://www.gov.uk/report-an-environmental-incident

Q: Is it possible to redevelop the LRIE without a masterplan outline planning permission that includes the necessary third-party land downstream to conform to common drainage law and planning policy?

Yes. We’ve moved on from proposing wholesale redevelopment for LRIE as set out in the 2020 Development Brief. The refreshed approach approved in June 2022 focusses on seeking new leaseholders to develop the depot site and playing field site which we control, and on working with existing leaseholders on the rest of the site. There is no evidence that third-party land downstream is necessary to conform to common drainage law and planning policy. Flood risk and drainage were considered as part of the high level Environmental Appraisal Report of the now superseded LRIE Development Brief in 2021, both available on our website. The report did not identify any ‘in principle’ issues that would prevent development of the LRIE site and stated that flood risk and drainage issues could be satisfactorily addressed at detailed design stage during the planning process.

Q: Does the council still believe it can regenerate the estate without going beyond the red line?

Yes. The Council as landowner intends to work in partnership with new and existing LRIE leaseholders and tenants to bring forward investment on the site in line with its strategic objectives of regeneration. There is no evidence that additional land is required outside the red line (which indicates its freehold ownership of the site).