Yesterday Caroline Lucas, MP for Brighton Pavillion, submitted her objection regarding the Royal Mail's proposed sorting office in Patcham. The objection is detailed in full below: 

Dear Russell (cc Liz),  

Re: BH2022/02232 - Patcham Court Farm Vale Avenue Brighton BN1 8YF

As the MP for the Brighton Pavilion constituency, I am writing to object to the planning application made by Royal Mail to develop the site at Patcham Court Farm for use as a delivery office (DO).  

1.Transport Plan (TP)   

The 605 page Transport Assessment and 85 page Travel Plan (TP) submitted by Royal Mail appear to be designed to try to avoid acknowledging that there will be an adverse traffic impact from the development in Patcham. In simple terms, the proposed delivery office will create a significant number of vehicles travelling to the area, both delivery vehicles, and staff journeys. The failure to properly address this elephant in the room raises serious questions about the overall robustness and accuracy of the documents as a whole.  

The site is 6.5 kilometres north of the city centre in Brighton. Whilst the centre of Brighton is served well by public transport in the city, and the current delivery office in North Road is within easy walking distance of Brighton station and a large number of bus routes, Patcham is not.

The Patcham Court Farm site is situated next to the A27 and A23 junction, meaning that travel to work for staff living outside of Brighton will be considerably easier by car than by current public transport options, which would mean travel to central Brighton by train or bus, changing to a different bus route serving Patcham, followed by a walk of over ten minutes.

In an email I received from Royal Mail on the 5 July 2023 they 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.

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.

At present I believe the nearest bus stop on the 5A route is in Barrhill Avenue, which according to the TP is approx 500 metres away.  This bus stop does not have a bus shelter, and to access the Patcham Court Farm site from this stop involves walking across a twitten next to the playing field, which outside of daylight hours may discourage some staff from using this route. Once reaching Vale Avenue it is necessary to cross the road due to the lack of pavement on the north side, and then cross again when reaching the site. 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.” 

This does not feel wholly accurate given the lack of pavement on a section of Vale Avenue, albeit there is a longer route around this stretch near the Patcham football ground via a wooded area. The TP refers to pavements being well-lit, but the combination of footpaths, twittens and routes from the Barrhill Avenue bus stop suggest this is not the case for the entirety of the route.

On the day I visited the site it was cold and raining, and the walking routes from the bus stops cited by Royal Mail in the TP did not feel particularly easy to access from the site.  

The reality is that, despite talk of active travel throughout the TP, 46% of the 49.7% of staff who completed the staff travel survey indicated that they would travel to work by car. If this figure reflects the likely journeys of the total 362 workforce, it means 166 staff travelling to the Patcham Court Farm site.  

Despite the TP noting 46% of staff will likely travel by car, Royal Mail’s own website states different figures:   

“We expect 35% of staff to travel by car and park on-site. 24% will use bus and 16% cycle to work. This is based on surveys of existing staff. Royal Mail will encourage staff, through a Travel Plan, to use alternative modes of travel to minimise single occupancy car journeys. Royal Mail is also in conversation with local bus service operators, to extend bus services to near the site.”   

In short, in the case of the Patcham Court Farm site, I cannot see that the public transport infrastructure serving the area is sufficient, at present, to enable staff, in particular staff living outside of the city centre – eg Shoreham, Saltdean and Lewes - a genuine alternative to car travel on a daily basis to get to work at this site. Clearly, I would hope that staff would consider public transport options, but without an open and transparent discussion on the current public transport barriers, some aspects of the TP feel like a tick box exercise and raise wider questions about the robustness of the document. Furthermore, inconsistencies in the information Royal Mail has submitted to support its planning application, and other comments it has communicated, are contradictory and also make it hard for the local community to trust the accuracy of the information and reports being shared.  

From the details I have seen, Royal Mail does not meet BHCC’s City Plan Part Two requirement in relation to safe, sustainable and active travel (policy DM33).   

A further transport consideration is the potential impact of the development on the wider road network, specifically the nearby A23 and A27. In the most recent details I have seen from National Highways, dated 9 May 2023, they do not recommend planning approval at this point. They state 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.” 

It is vital that Royal Mail provides this information. I am concerned about the attitude of the company when it comes to its willingness to engage with the local community, including sharing key information in order to satisfy the valid questions being raised by both residents and statutory bodies. 


2. Patcham’s aquifer, water quality and flood risk concerns   

Patcham has been prone to flooding in the past, and I have had contact with constituents who have been directly affected by floods in recent years. The Patcham Court Farm site is rated as SPZ1, the highest rating given to a groundwater source protection zone. It is a sensitive site, and it is essential that councillors deciding this application are fully satisfied that by granting planning permission it will not result in adverse outcomes, such as water contamination, sink holes, or exacerbating flood risk.  

In the Flood Risk Assessment (FRA) submitted by Royal Mail, dated June 2023, it is clear that there are gaps in information and conflicting information about flood risk posed by the development. The document notes that:  

“It is therefore unclear whether groundwater flooding is an issue on the site due to conflicting information. The monitoring completed on and near the site would appear to indicate that it is unlikely to be an issue, and the steeply sloping nature of the ground profile may also reduce this risk. It is recommended that groundwater monitoring be completed as part of any future ground investigation.”  

The document also notes that:  

“As Vale Avenue is at a lower level than the development site, no flood risk is anticipated from this source. There is however a risk that the system could become surcharged as the pipe diameter is small, this could in turn affect the discharge of surface water from the proposed development.”  

It is vital that any development at this site does not increase flood risk, nor lead to deteriorating water quality. Councillors on the Planning Committee need to be confident on this point and should not agree this development if reports and assessments suggest the possibility of increased risks to the city’s water supply. These must be addressed before any consideration of granting planning consent.  

Campaigners note that rainwater in the area feeds through the chalk rock system, where it joins up with the water tunnel system. This subsequently ends up at the Southern Water Pumping Station at Waterhall, where it is filtered for use as the city’s drinking water.  

The Aquifer Partnership explain that 1 litre of oil is enough to contaminate 1 million litres of drinking water. Whilst chalk acts as a natural filter, it is vital to the city’s drinking water supply that steps are taken to mitigate risks that have the potential to pollute drinking water that navigates the unique aquifer system we have. With the Brighton Chalk Block Aquifer lying relatively close to the surface, contamination risks from overdevelopment of land need to be factored adequately into planning decisions made.   

The FRA states 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.”  

I cannot see a reference to what the impermeable membrane used would be in the planning documents. It is important that this level of detail is provided, especially given the local community’s heightened fears of drinking water contamination due to the presence of the aquifer serving the city. 

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.  

Brighton and Hove City Council is alert to the flood risks in Patcham. In BHCC’s Local Flood Risk Management Strategy it notes that:  

"Development should only proceed where impacts to people or the environment, including the effects of climate change, are given due consideration. Sustainable development “meets the needs of the present without comprising the ability if future generations to meet their own needs” (Brundtland Commission 1987).”  

With Southern Water’s own pollution record being far from exemplary, and with Royal Mail somewhat lacking in their attention to detail, accuracy and performance record, I do not believe the concerns my constituents have raised about the risk to water supply and flooding have been satisfactorily addressed in the documents to support the application. Furthermore, I am not convinced that the impacts, including the effects of climate change, have been given due consideration by developers. 


3. Lack of clarity on Royal Mail’s commitment to a Customer Service Point (CSP) in central Brighton    

In supporting documents Royal Mail note that:  

“Barton Willmore (as the Project’s Planner) has advised that the redevelopment of the existing RMG site will be subject to a separate planning application and should not be linked to the Proposed Development at Patcham Court Farm).”    

Yet without clarity about Royal Mail’s intentions for a future Customer Service Point (CSP) in central Brighton, it is difficult to anticipate how many residents will travel to the Patcham site to pick up missed deliveries. I am aware of the new automatic delivery model that Royal Mail has adopted, and that they anticipate that this will support the parcel delivery arm of their business model and reduce the need for in-person CSPs. However, without consultation, Royal Mail has significantly reduced the opening hours of the current CSP in North Road, in spite of the fact that there is considerable delivery disruption in Brighton at the moment. I am not confident in the steps that Royal Mail is taking to address failings within its business model, and the inconsistencies and missing detail on its intentions with CSPs makes it difficult to predict the number of in-person visits to Patcham which will be needed if / when residents miss deliveries.


4. Air Quality 

BHCC’s Senior Advisor for Air Quality, Samuel Rouse, has suggested that Royal Mail’s intention to have a fully electric fleet may not happen in time for the first year of occupation at the planned site. Royal Mail note that this is correct, and they refer to their EV plan as an “aspiration,” yet they also refer to being “fully committed” to an EV fleet.  

It is important that information about Royal Mail’s ability to meet its “aspiration” of a fully electric fleet is clarified. Without clarity on this, the supporting evidence submitted in relation to transport implications, and also air quality, are incomplete.


5. Later start times and Royal Mail’s ‘modernisation’ plans   

The revised documents submitted by Royal Mail refer to the possibility of later staff start times, which has been something discussed as part of an agreement with the Communication Workers Union (CWU) to try to end strike action over concerns about pay and condition. Whilst CWU have agreed a deal with Royal Mail, CWU note that: 

“Many workers simply do not trust Royal Mail Group because of the company’s lack of integrity and the way they are being treated.”   

Royal Mail has made no secret of its modernisation plan, and its desire to respond to greater industry demand for next-day parcel delivery. Whilst the company focuses on this aspect of its business model, it is neglecting its universal service obligation to deliver letters. I have concerns that the direction of travel towards parcel delivery will result in a large parcel delivery depot in the north of my constituency, with much of the public service element of Royal Mail's delivery obligations being lost.


In summary, I remain concerned about the disproportionate impact Royal Mail’s proposed development would have on residents in the north of my constituency, in particular those living near to the site in Patcham, and do not think that the company has done enough to mitigate those impacts. I am not confident about the robustness of the assessments submitted by Royal Mail, due to inconsistencies in the information provided and a lack of engagement with the local community.

I therefore do not support Royal Mail’s proposal, and it is important that Planning Committee councillors scrutinise details and supporting documents closely when making a decision.

I hope that the strength of feeling expressed by the local community about the sensitive nature of this site, and their opposition to it, are taken fully into consideration in the planning process, and that they are reflected in the decision.  

Yours sincerely  

Caroline Lucas MP