01/08/2023

Dear Michael, 

Re: Royal Mail planning application at Patcham Court Farm  

Planning application reference: BH2022/02232 

As you may be aware, I have now submitted a formal objection to Brighton and Hove City Council in relation to the planning application Royal Mail has submitted for a delivery office at the Patcham Court Farm site. From the details I have seen, there still appear to be multiple inconsistencies in the assessments and supporting documents, and information is complete in a number of areas. As some of my constituent’s concerns are linked to serious environmental impacts, it is important that these aspects of the plans are addressed. 

In relation to information that is not yet available to scrutinise, and other points raised with me in recent weeks, I do have some further questions, which I would appreciate some clarity and answers on. Please would you let me know the following: 

National Highways 

In the most recent information I can see online, a document / letter from National Highways, dated 9 May 2023, states that:   

“We previously responded to the consultation on this planning proposal on 09 Feb 2023 setting out further information that we require in order to form a view on the potential impacts upon the strategic road network. Our response recommended that planning permission should not be granted for a period of three months to allow the applicant time to respond. 

“We have not yet received the further information we requested. This NHPR extends our holding recommendation until 09 Aug 2023 and repeats our request for additional information.”  

Please would you comment on this and confirm the current position regarding dialogue with National Highways, and the information they say they need. 

Public Transport and Transport Plan (TP) 

In an email I received from Royal Mail on the 5 July 2023 you noted that:

"We remain committed to working with Brighton and Hove Buses to provide public transport provision for employees to get to the new Royal Mail site in Patcham. We are continuing our dialogue with Brighton and Hove Buses"  

Yet my understanding from the contact that I’ve had with Brighton and Hove Bus Company is that although there have been some discussions between the two parties about bus services in the Patcham area, the last discussion was in September 2022. This discussion did not result in clear plans being developed – eg to agree to extra bus stops, or introducing additional services. 

Please would you clarify exactly what the is meant by Royal Mail being “committed” to working with the bus company, and what this means in clear language and measurable action.  

Furthermore, I gather that discussions did not look at how services would need to cater for varying working patterns of staff at the site (particularly very early mornings), and they appear to have been limited to potentially diverting a couple of morning and evening peak 5A services to head up Church Hill. My constituents have expressed concern that, at no time have they been informed that diverting buses up Church Hill has been a consideration. It’s not mentioned in the Transport Plan (TP) as an option, and from the contact I’ve had with the bus company, it doesn’t sound like any conversations have progressed far, and contact has been relatively minimal. My constituents are quite anxious about Church Hill being mooted about as an option – please would you confirm whether this is a non-starter from Royal Mail’s perspective, or it has been a viable consideration at any point.  

Inconsistencies are many in various supporting documents Royal Mail has submitted, and details the company has communicated by other means – eg in leaflets and online. Examples include: 

• The TP noting 46% of staff will likely travel by car, but Royal Mail’s own website stating that “We expect 35% of staff to travel by car and park on-site.” Which figure is correct?
  

• The TP states that: “There are pedestrian footways on both sides of Vale Avenue, which measure approximately 1 metre in usable width and approximately 3 metres in total width including grass verges that abut the carriageway.” There are pavements on both sides of Vale Avenue directly near the site, but not on both sides on the route people would need to take from the Barrhill Avenue bus stop – this is misleading
• The noise assessment is based on 11 HGV movements, yet the transport assessment says there are 14. My constituents have expressed concerns that Royal Mail’s communications representative has said there are 14. Whilst they understand that 14 is actually the number in, there are another 14 out, so HGV movements is being misrepresented and should be 28. Please would you confirm the correct figure, and if there has been miscommunication provide an explanation for this?
  

In addition to clarifying and responding the above inconsistencies, please would you update me on the current position, and timeframe, for Royal Mail’s aspiration to transition to a fully electric fleet of vehicles.  

Flood risk 

In the Flood Risk Assessment (FRA) submitted by Royal Mail, dated June 2023, it notes that:  

“It should also be noted that the site is located above a Source Protection Zone 1 aquifer. As the infiltration rate is poor, and as the site is located above a Source Protection Zone 1 aquifer, infiltration for this site has been discounted and all proposed SuDS features are to be lined with an impermeable membrane to prevent infiltration.”   

Please would you confirm the specific type of impermeable membrane will be used. Given residents’ concerns about the fragility of the aquifer, it is important that supporting information about materials being used is specific and detailed, and my constituents are concerned about many omissions and missing information which makes it impossible to be clear that all risks have sufficiently been mitigated against.  

In a response dated 21 April 2023 to a letter I sent to Southern Water with questions about the Patcham Court Farm plans, they refer to the objection they made on the 15 August 2022. Since that time Southern Water have met with Royal Mail, who have subsequently undertaken a hydrogeological risk assessment (HRA) to try to ensure risks to groundwater are mitigated or eliminated. However, some of my constituents are querying why samples were taken from just one location at the site. This has resulted in a California Bearing Rating (CBR), which assesses the ratio of bearing load, at over 15%, whereas a similar assessment back in 2005 resulted in a 2% CBR being recorded. My constituents have told me that back in 2005 samples were taken from across the site, which may account for the discrepancy, and which they believe brings into question the robustness of the HRA submitted by Royal Mail.  Please would you clarify any clear reason for samples being taken at just one location at the site. 

Please would you also update me on any recent contact with Southern Water, and confirm specific information they require from Royal Mail before they are in a position to grant approval. The attached letter from Southern Water states that:  

“Based on the information provided we believe the development could pose a significant risk to our Brighton A and B groundwater abstractions as the impacts from site demolition, construction and operation have not been considered in full. At present Southern Water OBJECT to this application and seek further reassurances that our groundwater abstraction source will not be impacted by the proposed development.” 

They go on to note that:  

“Construction of the development shall not commence until details of the proposed means of foul sewerage and surface water disposal have been submitted to, and approved in writing by, the Local Planning Authority in consultation with Southern Water.” 

Please would you confirm further details of the steps being taken to ensure that these concerns are addressed at speed. These details should be available for public scrutiny prior to any planning decision being made, and I have concerns that with this information absent it is preventing the Patcham community having a genuine say in a major development where they live.  

Customer Service Point 

In a recent response I have received from Royal Mail, I have been told that: 

"With regards to your question about where a future SP might be located in Brighton, we are still looking at alternative options in central Brighton and note that this will not be required for a few years.”  

Please would you confirm what alternative options in central Brighton are being looked at. Please would you also confirm whether a service point in Patcham has been ruled out as an option. If not, the inclusion and impact of a service point at the proposed new site in Patcham should be made clear in the TP. With vagueness from Royal Mail about the location of a CSP in central Brighton, and the recently reduced hours at the existing CSP in North Road, it is difficult to be confident about Royal Mail’s intentions on this point, and it is a relevant factor which should be made clear in the planning application as it will impact on vehicle journeys. 

Leaflets and community communication 

Please would you share a copy of the leaflet Royal Mail, or the PR company being used, distributed to residents in streets closest to the Patcham Court Farm site. I have heard from residents expressing concerns that the leaflet was misleading in a number of areas, and I would like to see a copy of what was distributed by Royal Mail to my constituents, or on Royal Mail’s behalf by the PR company. One criticism has been that the leaflet implied plans are going ahead, and rather than making clear that people can comment via the statutory consultation, the leaflet directs people to raise questions with Royal Mail directly. I would like to see the wording of the leaflet myself to get a clear sense of this. 

My constituents have been told to raise questions via SEC Newgate, a PR company working on Royal Mail’s behalf. I have been told that Vincent Carroll from the PR company has refused to meet with campaigners, and has said instead that emails sent to the royalmailpatcham@secnewgate.co.uk email address would be answered promptly. Yet my constituents suggest that this is not happening, and many are still waiting for replies weeks later.  

With the statutory consultation period only being open for a limited period of time, this is of significant concern. It is important that my constituents' questions are answered promptly. Please would you confirm whether Royal Mail is aware of the criticism of SEC Newgate, and clarify what ownership and oversight Royal Mail has directly over the enquiries and questions from residents. My constituents need genuine engagement from Royal Mail about the plans, and I am concerned that the use of a PR company, and in particular, a PR company and points of contact who are not replying to questions and enquiries within a reasonable time, is acting as a barrier to this.  

As you will be aware, there is a significant level of concern in the Patcham area about Royal Mail’s plans, and I hope that you will respond to the above points swiftly, given that the statutory consultation period closes soon.  

Many thanks for your assistance with this. 

Best wishes,