Bray Parish Neighbourhood Plan Steering Group

Response to RBWM Preferred Options Consultation March 2014

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Table of Contents 1. INTRODUCTION ...... 3 2. OVERVIEW AND WHAT OUR RESIDENTS HAVE TOLD US ...... 3 3. DISCUSSION POINTS OUTSIDE THE BASIC CONSULTATION - A BETTER APPROACH? ...... 5 4. COMMENTS ON RBWM’S ‘GREEN BELT PURPOSE ANALYSIS’ (NOVEMBER 2013) ...... 8 5. SPECIFIC RESPONSES ON THE GREEN BELT QUESTIONS (Q11, 13, 14 AND 15)...... 9 6. SPECIFIC RESPONSE ON BRAY PARISH HOUSING SITES AND HOUSING QUESTIONS (Q18 TO Q21) ...... 11 7. OTHER HOUSING POLICY COMMENTS AND HOUSING QUESTIONS (Q22 TO Q33) ...... 21 8. SITES REJECTED BY THE HOUSING ASSESSMENT AND THE “EDGE OF SETTLEMENT” ANALYSIS WHICH SHOULD HAVE BEEN INCLUDED IN THE CONSULTATION ...... 23 9. NEW SITES WHICH HAVE BEEN IDENTIFIED SINCE THE CONSULTATION PAPERS WERE WRITTEN ...... 28 10. CONCLUSIONS ...... 35

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1. Introduction

The Bray Parish neighbourhood Plan Steering Group has been working on the Neighbourhood Plan for the Bray Parish since November 2011 in the shadow of the development of the Borough Local Plan. Now that we have seen it we are concerned that there is not enough recognition of the major national infrastructure project, namely Crossrail which could transform the prospects for Maidenhead, and act as a catalyst for substantial redevelopment of the town centre and the surrounding areas. This is a ‘once in a generation’ opportunity which must be grasped now for the benefit of future local Residents.

The Bray Parish Neighbourhood Plan Steering Group has been working with Bray Parish Council in preparing this Submission to RBWM’s Preferred Options Consultation. The outcome of this Consultation is critical to the future of the Green Belt and the Green Gap in Bray Parish. 2. Overview and what our Residents have told us

The Jubilee River has made a big difference to Maidenhead, Bray and Windsor but recent events have shown that flooding is still a major concern for all those bordering the Thames. This is not so much from the river itself, but from its tributaries, several of which cross the Parish and are supplemented by a number of major ditches, all of which have flooded during recent months. There are many low spots across the Parish that often hold water and the ground water levels are often at the surface in many locations during the winter months so that better drainage is only likely to be a partial solution. Overflowing, flooded sewers have also occurred in several parts of the Parish. Insurance of new homes anywhere near rivers is already problematic and Government pledges to provide insurance for flood risk areas does not apply to homes built after 2009.

The issues of primary concern to our Residents relate to the ever increasing expansion of the towns of Windsor and Maidenhead into the Green Belt and the traffic congestion caused by transit traffic through the Parish

At meetings conducted last year as part of the Neighbourhood Plan process, Residents told us:

• Preserve the ‘Green Gap’ between Windsor and Maidenhead- do not build on the edge of existing settlements

• Build on previously developed land (brownfield sites) first

• Locate most new housing in the Town centres

• Do not build on the Green Belt unless there are significant community benefits and the majority of those living in the area have voted for it

• Do not build in sites prone to flooding

• Ensure adequate new Transport & Infrastructure is available where new housing is built

We accept the projections for population growth and therefore housing need, but seriously question the Edge of Settlement approach. This will create more traffic growth and therefore be less sustainable than comparable town centre developments and the whole approach flies in the face of what Residents have clearly and regularly stated – maintain a gap between the urban centres.

The main Crossrail civil engineering construction works are planned to complete in 2017. Fit-out of stations and testing will continue afterwards. It is expected that services will commence on the central London section by late 2018 followed by a phased introduction of services along the rest of the

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Crossrail route in early 2019. At peak times there will be 4 trains per hour, each capable of carrying 1500 passengers

The BLP doesn’t address the more strategic need for housing close to the Crossrail terminus in Maidenhead and we have about 5 years to put that right. As many homes as possible need to be constructed within walking distance of the station . In addition, housing developments to the South of the Borough (8,000 to 15,000 homes in North Bracknell) and the wider need to access Crossrail will substantially increase traffic into the Borough. Parking and road infrastructure to cope with this influx needs to be included in the same time frame or the inevitable congestion will grind everything to a halt!

We feel that the BLP does not go far enough in addressing these strategic issues which are outside the scope of the Bray Parish Neighbourhood Plan but have a major impact on what our Residents tell us is important and in particular on traffic within the Parish.

This paper:

1. puts forward suggestions to address some of the strategic issues in Section 2 (Discussion points outside the basic Consultation -a better approach?);

2. gives Responses to specific Questions contained in the Preferred Options Consultation in Sections 3 to 7;

3. lists 4 sites rejected by the Housing Assessment and the “Edge of Settlement” Analysis which we consider should have been included in the Consultation in section 8. These sites could deliver between 1,808 and 2,528 dwellings;

4. lists 9 new sites in Section 9 which have been identified since the Consultation papers were written. We estimate that these sites could deliver between 3,085 and 3,715 dwellings; and

5. sets out our conclusions in Section 10

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3. Discussion points outside the basic Consultation - a better approach?

Maidenhead Town Centre

A substantial re-think of the Area Action Plan for Maidenhead Town Centre is urgently needed. It requires a wider geographic scope and more houses within walking distance of the station. These could include higher-storey buildings.

The map below show 400m and 800m circles centred on Maidenhead station, corresponding to 5 min and 10 min walking at 5km per hour

Council buildings as well as leisure facilities and some businesses could be relocated further out of Maidenhead, freeing up many sites within walking distance of the station for housing. Leisure facilities in particular could be moved to areas of Green Belt.

Maidenhead Golf Club (MGC), Maidenhead Football Club, the Desborough Bowling Club, the Magnet Leisure Centre, the Braywick Sports Grounds, the Council offices, Police Station and Law Courts, all fall into this category and should be consulted on now in this regard.

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There is more detailed discussion under New Sites in Section 8 of this document on all but the MGC which follows below as part of the Crossrail conclusion.

Crossrail Infrastructure

A major rethink is required in terms of infrastructure and traffic routing around the Crossrail terminus.

At peak times there will be up to 6000 people per hour trying to get onto Crossrail alone. In addition there are at least 6 other train services from First Great Western departing from Maidenhead each hour which could add 1500 per hour to this number.

A substantial improvement is needed to the traffic routing around the station and, particularly, the parking facilities to cope with this number of people. Even if we have a significant number of Residents who walk to the station, there will still be a critical need for suitable parking for large numbers of private cars (circa 15,000?). Easy access and departure will be essential to keep congestion and delays to a minimum as well as facilitating drop off, collection, and improved, integrated public transport schemes, where buses actually stop at the stations.

M4 Spur or Link Road

Furthermore, a new southbound spur road off the M4, somewhere J8/9 and J10, is also needed, deemed as essential in the Berkshire LEP (Pages 43 and 44). This would considerably ease the potential congestion and help reduce the North / South traffic which currently transits through the Borough to access the M4, including from the 8000 to 15000 housing development in North Bracknell, a proportion of whom will want to use Crossrail. .

Maidenhead Golf Club. Site 5A

This is a particularly strategic site due to its location within a 5 min walk of the station, its height above the water table and its proximity to major roads.

It offers a dual opportunity. The location well above the water table would allow it to have a car park for 1000’s of cars with direct underground walkways to Maidenhead station and the Town Centre.

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When completed the surface could be used for additional housing or possibly returned for leisure activities.

Access to this parking area could come from the A 404(M) or with an additional exit link road from the Junction 8/9 roundabout.

Although the Borough own most of this site, they do not believe it will become available as Members of the Club are not supportive of any development at this time and they still have 26 years to run on their lease. Clearly further negotiations are needed and might be eased if another suitable site is offered to MGC Members and this could be a Green belt site. This would need to be available and ready for play before the current MGC site is vacated to halt the erosion of Club Members.

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4. Comments on RBWM’s ‘Green Belt Purpose Analysis’ (November 2013)

RBWM prepared a Green Belt Purpose Analysis which analysed the contribution made by land within the Borough to the purposes of the Green Belt (which are listed in the Government’s ‘National Planning Policy Framework’ (NPPF).

This Analysis was then used to set criteria by which each of the sites being considered for possible development were scored for its contribution to the purposes of the Green Belt. However in adopting this approach, land providing a settlement gap which checked the unrestricted sprawl of large built-up areas was ignored if it was ‘washed-over’ by the Green Belt. One example of this is Holyport.

As a result Site 7A, which fulfils three of the five purposes of the Green Belt, was scored lowly in spite of its role as a settlement gap between the Holyport Settlement Area and the eastern end of the Maidenhead ‘sprawl’. Other proposed sites in the Green Belt, such as Sites 8A, B and C contribute to the Green Gap between Windsor and Maidenhead. These sites are containing the “urban sprawl” of Windsor and any development here would harm the Green Belt in Bray Parish.

This is a fundamental element of assessing the purposes of the Green Belt sites and should not have been ignored just because the ‘settlement gap’ is not directly referred to in the NPPF. These sites should therefore have been removed from the Edge of Settlement Sites being considered.

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5. Specific responses on the Green Belt Questions (Q11, 13, 14 and 15).

Question 3 regarding RBWM’s preferred strategy of providing a sustainable balance between housing/other needs whilst protecting the Green Belt, but requiring development in some parts of the Green Belt.

We support the strategy of providing a sustainable balance between housing and social needs and economic needs, whilst protecting the quality of the environment and the Green Belt, but do not as a general principle accept that this requires development - or more particularly residential housing development - in some parts of the Green Belt.

The ‘Green Gap’ between Windsor and Maidenhead is considered crucial by local residents in maintaining the physical separation between and identity of Windsor and Maidenhead and forms an important ecological and landscape corridor shown on the map below.

The principal focus for development should be on the urban centres, with an emphasis on Maidenhead and the strategic need for housing close to the Crossrail terminus. This mirrors the view of the Inspector in his report issued in October 2007 on RBWM’s Core Strategy where he commented that ‘Maidenhead is a much larger and to my mind more sustainable location for additional development [compared to Windsor]’ and ‘Maidenhead’s selection as the terminus for the Crossrail project could further emphasise its relative importance in years to come’. Nearly seven years on with Crossrail much closer to delivery it is essential that this challenge is met.

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It is acknowledged that some development may be required in the Green Belt, but in far more limited circumstances than contemplated in RBWM’s preferred strategy, primarily (a) to accommodate ‘displaced’ outdoor leisure activities and (b) to address the overriding strategic need for housing (and supporting infrastructure) close to the Crossrail terminus.

Question 11 regarding policy option GBC 1 to maintain and support the Green Belt

The Green Belt policies in the extant Local Plan have, in general, served the community well in preserving the Green Belt and protecting it from inappropriate development and we support the general principles set out in preferred policy option GBC 1.

Question 13 regarding policy option GBC 2 on Countryside Character

We support the broad principles contained in preferred policy option GBC 2 and the objectives of steering growth towards the urban areas and promoting a strong and vibrant countryside character. Paramount is the role of local communities in developing appropriate policies through Neighbourhood Plans and defining what types of development in the countryside will be supported.

Question 14 regarding policy option GBC 3 on New Residential Development in the Green Belt

As noted in the response to Question 3 above we do not as a general principle accept the case for new residential housing in the Green Belt, and have reservations with a number of aspects of the stated preferred policy option GBC 3. To briefly summarise:

• we support some aspects of the policy – limited infilling, one for one replacement • the reference to re-use of ‘buildings’ is too broad and should be amended to ‘non-residential buildings’, which is what policy option GBC 4 covers (see also comments under Question 15 below) • support for any proposals to build additional housing on Green Belt land should be an integral part of Neighbourhood Plans

The policy needs to be viewed in conjunction with the proposals in policy option HOU 2 – specifically to the categories ‘existing developed sites within the Green Belt’ and ‘areas in the Green Belt where analysis of development suitability will be undertaken (so called ‘Edge of Settlement’ sites). Our commentary on these categories is provided in the responses to Questions 19 and 20 below - we have mixed views on ‘previously developed sites’ and offer a critique of the various Edge of Settlement sites either in or bordering Bray Parish.]

We accept that there may be new residential development on some of the ‘previously developed sites’, but consider that this policy should set the highest priority to urban growth locations, and only when these are exhausted should Green Belt ‘previously developed sites’ be released. [In the Inspector’s Report on the Reigate & Banstead Local Plan January 2014 it is stated that] ‘[such a] sequential approach is considered sound in principle and consistent with [the NPPF]’.

Question 15 regarding policy option GBC 4 on the Reuse and Replacement of Non-Residential Buildings in the Green Belt

In general we support the reuse or replacement of non-residential buildings in the Green Belt as proposed in preferred policy option GBC 4, but consider that this policy should (a) only apply to buildings that were substantially completed at least 10 years before the date of the application and (b) should be used for similar rural purposes.

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6. Specific response on Bray Parish Housing Sites and Housing Questions (Q18 to Q21)

Question 18 regarding Policy Option HOU 1 on the Amount and Distribution of Housing

No comment on the analysis. We would like to see a higher emphasis on protecting the Green Belt although recognising that there may still need to be some development, preferably of outdoor leisure facilities, on a limited number of Green Belt sites.

We also are seriously concerned that the implications of Crossrail on the centre of Maidenhead require much greater emphasis on housing, particularly within walking distance of the station than currently appears to be the case. See earlier commentary.

Question 19 regarding Policy Option HOU 2 on allocated housing development sites.

Table 4 – Sites in Urban Area. No comment. None in the Bray Parish.

Table 5 – Existing developed sites in the Green Belt

Sites identified in the Bray Parish Proposed Houses

a) Land at Water Oakley Farm, Windsor Road, Oakley 44 (28) Green

b) Windsor Garden Centre (Wyevales) , Dedworth Road, 35 Oakley Green

c) Squires Garden Centre, Maidenhead Road, Windsor 40

Land at Water Oakley Farm. This has been accepted by local Residents who, in a survey conducted by RBWM in March 2013, by a small majority (57%), indicated that some sort of development would be acceptable. The main concerns relate to the access to the site from the already congested A308, the probable historic contamination of parts of the site and that other parts are Grade 1 agricultural. The owner of the site is actively promoting it. With the adjoining site to the East, associated with Bray Studio, having received permission for residential development, there would be an opportunity to merge the access to support both sites and broaden the A308 to provide a slip lane and a middle lane. Mitigating the access in this way won’t really help with the overall congestion and the 1/2 mile queues in the mornings to get onto the Braywick roundabout.

The Windsor (Wyvale) and Squires Garden centres, in the same survey of Residents, were both categorically rejected with 84 % objecting to Windsor (Wyvale) and 92% to Squires as development sites. There appears to be an important misprint in the Housing Assessments document, page 81, which states that in the Public Opinion section that only 12% of people objected. This should be 92%.

The Windsor Garden Centre is used as an important meeting point and as such has substantial community value. Thames Water have expressed concern about the sewers and there were reports of the loos backing up in the recent flooding. It is close to The Old Farm House, a Grade II listed building on the adjoining site which would be adversely affected by any development and where

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several inches of water came up through the floor in the dining room. Access would be onto the Dedworth Road to the South and a good level of facilities and services are available nearby

Squires has a similar community value and parts of the car park were flooded in the recent weather, as a result of ground water pressure. Thames Water have expressed concern about the sewers and they were overflowing just down form the site on the Old Maidenhead Road. Access would be via the Old Maidenhead Road, onto the Ruddlesway roundabout. There is serious congestion in the mornings on the A308 heading into Windsor which often blocks this roundabout completely.

With the recent strong rejection coupled with these difficulties, we find it difficult to see how the RBWM can introduce these two locations as possible development sites .

Question 20 regarding Policy Option HOU 2 on proposed development sites in the Green Belt.

Sites in the Green Belt. There are 6 of the proposed 23 sites that fall within the Bray Parish. Three further sites adjoin the Parish boundary but would no doubt have a significant impact on the Parish.

Table 6 - Sites in the Green Belt where RBWM is considering development.

Green Belt Sites in Bray Parish where development is Proposed being considered Houses

a) Area 5E, South of Harvest Hill Road, Maidenhead 154 (150)

b) Area 7a between Ascot Road and Holyport Road, 200 Holyport

c) Area 8a North of A308, south of the Old Maidenhead 140 Road, Windsor

d) Area 8b South of A308, east of Oakley Green Road 400 and north of Dedworth Road, Windsor

e) Area 8c South of Dedworth Road, west of Broom 150 Farm Estate, Windsor

f) Area 5c, the Triangle enclosed by M4, A308(M) and 400 Ascot Road, Maidenhead

General Overview.

Detailed issues are given on each site below but at a more general level several concerns are apparent: 1) The access to all of these sites on their own is a major issue but particularly with 5e & 5c, and 8a, 8b and 8c, which would require a major rework of the roads and junctions in the surrounding areas.

2) In addition it is understood that in Dedworth / West Windsor the local schools are all close to capacity and for this number of people at least one new middle and or upper school would be required. Where would it be possible to locate this?

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3) Health services across the Parish and into West Windsor would also be seriously stretched. There is a major shortage of GP’s across the country with the Feb 14 issue of ‘Pulse’ the GPs magazine, suggesting that 10,000 more GP are needed. Local doctors in the Parish say that recruitment is very difficult and that the Borough’s plan for 12500 new homes would need about 15 new GPs.

a) Area 5e South of Harvest Hill Road, Maidenhead .

The southern and low part of the site is subject to flooding, associated with the large ditch (Drain on map) and from the Cut in the adjacent Triangle site (see f, Area 5c later in this document). The site then rises up to Harvest Hill Rd. The sections have several different owners including Maidenhead Golf Club who own one as a practice area. A Member confirms that the lower part of this site endures regular flooding.

Access to the site would be from Harvest Hill Rd which is already used as a rat run for M4 traffic going to the A404(M)

Several of the land owners including MGC would support development on this site.

Some infrastructure could be available from the adjoining houses along Harvest Hill to the north.

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b) Area 7a between Ascot Road and Holyport Road, Holyport.

This site covers about 53 acres between the Ascot Road (A330) and the Holyport Road, adjoining Aysgarth Park on its North East border, which is the edge of the Maidenhead Urban Area, and the Holyport Conservation Area to the South West. The land has not been classified but would be a mix of agricultural Grade 3 and 3a. It has a small number of redundant farm buildings and hard standing including a water tower with is included in the Conservation Area. One existing building, (Philberds Lodge) is located off the Ascot Road with an access drive. There is consent for limited agricultural access only off the Holyport Road but access via the narrow road up Holyport Street in the Conservation Area, would be impractical. With houses on two sides and shops, schools and GP surgery close by, most general services infrastructure would be available but Thames Water have indicated problems with the sewerage as referred to on page 93 of the Edge of Settlement analysis. The site is low lying with the Western side subject to flooding. Noise and traffic related pollution levels are high due to the proximity of the M4 and A330. Existing roads already suffer from high traffic levels and will be considerably worsened by a number of factors including commuters to Crossrail from the south, where 8,000 to 15,000 new homes are planned, and the building of the Holyport Free School.

Residents attach a high scenic value to this site and consider any development would have an adverse effect on the setting of the Holyport Conservation Area and a reduction in the openness of the Green Belt, coupled with the environmental factors and Thames Water concerns, make this site unsuitable for development.

The Green Belt serves 5 purposes as defined by Central Government. However we understand that "Protecting Gaps between or to Settlements included in the Green Belt was not one of the criteria

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used by RBWM to inform the process of Stage 1 in the Edge of Settlement Analysis because it was not one of the 5 purposes the Green Belt serves".

Perhaps on reflection this could or should have been done, for it is easy to see that the Green Belt site 7A does fulfil Green Belt purposes 1 & 3 above and certainly 5. However in not taking these 3 Green Belt purposes into account, Holyport 'washed' over by Green Belt is put at an unnecessary disadvantage.

Recognising that there is no ranking of the 5 Green Belt Purposes and simply put, to prevent an urban sprawl and encroachment from Maidenhead into Holyport, which is 'washed' over by the Green Belt, these 3 Green Belt purposes could/should have been taken into account.

Holyport is both a Conservation Area and a Recognised Settlement and although the Conservation Area is shown on Map 7 neither is included on any of the Maps 2, 3, 4 & 5 in the Edge of Settlement Analysis, which if included would have illustrated the above.

We know that the Holyport Preservation Society and the Holyport Residents Association have sought the advice of The London Green Belt Council and they agree with these views

It is appreciated that as stated in the Green Belt Purpose Analysis document there is no consistent model for undertaking a Green Belt analysis. We also see that paragraph 3.6 of the Green Belt Purpose Analysis document make's clear that "Consideration of the affect on such smaller settlements is more appropriately considered through a finer grain character assessment and/or a site assessment exercise". We cannot understand why the Green Belt purposes 1,3 & 5 were not tabled first, before this finer grain analysis was undertaken and before going out to the public.

c) Area 8a North of A308 & South of the Old Maidenhead Road, Windsor.

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This site borders the Old Maidenhead Road to the North, on the West a few larger houses and to the East some houses and the Squires Garden Centre. The site is the start of the green space separating Windsor and Maidenhead and as such is perceived as very important to Residents in establishing the ‘Green Gap’. However it has a slight incline away for the A308 such that only the initial 20 metres or so are visible from the road. The houses on either side are not visible and thus in reality only the first 20m are of high scenic value.

The farmland likely to be Grade 3 or 3a but it is unlikely this area has experienced any grading. Although the fields occasionally have horses, it has not been actively farmed for many years.

Due to its elevation there is no evidence that the site suffers from any serious flooding. However due to its proximity to the river any houses would have serious problems getting insurance.

Gated access off the Old Maidenhead Road already exists. A significant increase in traffic from this road onto the A308 via the Ruddlesway roundabout would be a concern at peak times as local Residents already experience difficulty gaining access to the roundabout due to the weight of traffic on the A308 travelling from the Maidenhead gaining priority. Buses do now travel directly along the A308 from Maidenhead to Windsor.

With other houses on the Old Maidenhead Road, it has access to services infrastructure and the Dedworth amenities, but Thames Water have expressed concerns about sewerage and in the recent flooding there was sewage bubbling out of the manholes on the Old Maidenhead Road.

d) Area 8b South of A308, East of Oakley Green Road and North of Dedworth Road, Windsor

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This is actually several sites, together with some existing housing and is divided up as follows:

1) Fields south of the A308. This borders the Western edge of the urban areas of Windsor, which is also the Parish boundary to the East and the Oakley Green Road to the West. The Cardinal and Hand Clinic (on the map as Bishops Lodge) is to the South. There is a house called Rainworth with access off the Oakley Green Road but otherwise this site is just fields. There is flooding associated with the ditch heading Northwest across of this site towards the river and also on the low lying North East corner. Due to the proximity of the existing housing on the East side, access to infrastructure and amenities could be good.

As mentioned in Section (c) above this field provides the Southern part of the start of the visible green gap leaving Windsor. Existing screening limits the depth of visibility but there is still important scenic value. On the eastern boundary there is a public footpath with trees/hedging screening the site form the existing houses on the Windsor side although they might still have a valid claim for some loss of visual amenity

2) Other fields south of (1) bordering the edge of the urban area and adjoining the Limes development to the south which links to the Dedworth Road. Following on from (1) this site has the same characteristics.

3) A single long thin site called Sunnymedes, east of the Windsor Garden Centre and west of the Limes, with access off the Dedworth Rd. There are two small houses and kennels not easily visible from the road. It links with (2) above. This site is close to the housing at the Limes and thus to infrastructure and the Dedworth amenities.

4) Windsor Garden Centre (Wyevales). This is discussed elsewhere and has been strongly rejected for housing development by local Residents. If there are broader developments around it, there could be more reason to keep it as a local amenity, or allow it be become some other type of leisure facility.

5) The Cardinal Clinic and Hand Clinic /Saxon Barn. This is a large predominantly built site with access off the Dedworth Road, to the Hand Clinic side and off the Oakley Green Road to the Cardinal Clinic. There are at least two historic buildings, the Old Farm House which is used as a B & B and the Saxon Barn which is used for events. The Hand Clinic is no longer operating. As well as the Cardinal Clinic, there are several other houses on the site and two large car parking areas. The site has a large ditch down the eastern site taking water from the South side of the Dedworth Road, which is subject to flooding, extending into the fields to the North (1)

6) Land on the North Corner of Dedworth Rd and Oakley Green Road. This is an untidy overgrown site opposite the Green Oak Pub. There is a bus stop outside and it is close to the Dedworth amenities. It is overlooked by the Cardinal Clinic.

7) Other houses bordering the Oakley Green Road. There are two houses either side to the Cardinal Clinic entrance with the Rainworth B & B nearest the A308. The land in this area is subject to flooding

Summary

The fields on the South side of the A308 from the other half of the initial ‘Green Gap’ that resident’s value highly and as such the site has high scenic value. They have not been classified but would be Grade 3 or 3b. However they are not actively farmed.

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Parts of the site are subject to flooding, with a large ditch running from the Dedworth Road, down the left hand side of the drive past the Hand Clinic. This then runs diagonally across to the Oakley Green Rd and then under the A308. There was extensive flooding at times in these areas over the last few months as the ditch couldn’t manage the volumes of water. The owner of the Cardinal Clinic has photographs of the extensive flooding over the gardens adjoining fields. Ground water levels are high and almost at the surface in many places, and there were several inches of water in the Grade II* listed Old Farm House, forced up through the floorboards in the dining room. This building would be adversely affected by any additional development.

Access is available from both the Oakley Green Road and the Dedworth Road. However the Oakley Green road is unlit, has no pavements and access off it would be dangerous. The Dedworth Road access would be slightly better. Wider improvements would be needed to the surrounding junctions.

The site potentially has access to infrastructure and services and the Dedworth amenities, but Thames Water have expressed concerns about sewerage and in the recent flooding there was sewage bubbling out of the manholes on the Oakley Green Road, near the entrance to the Cardinal Clinic.

e) Area 8c South of Dedworth Road & West of Broom Farm Estate, Windsor.

This is also several different sites, together with some existing housing and it is better to break it down as follows:

1) Fair Acres Farm. There is a small field facing the Dedworth Rd, with the farm, a rented house and outbuildings all well set back. This field occasionally has jumps in it for a pony and is often waterlogged

2) Behind the buildings are fields that run up to the Alexander School. The eastern edge, backing onto the Army housing on the Broom Farm Estate, would potentially offer access to infrastructure, with the Dedworth amenities a short distance away but access from that direction would be difficult, with narrow roads

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around the Estate and potentially requiring one or two houses to be knocked down to gain entry to the site. The fields are part used as playing fields with two football pitches and in regular use by dog walkers, with pedestrian access already available from the Army Estate. If this was developed, the Army might object to the loss of this scenic and community amenity. The land starts low lying and this area is subject to flooding but slopes gently up towards the Alexander School.

3) Houses along Dedworth Rd. From Fair Acres up to the Green Oak Pub (shown as the Nags Head on the map) on the corner of the Oakley Green Rd, there are houses along the south side with a few gaps. The Old Malt House is Grade II listed and has the largest open frontage. There is a large ditch next to the Green Oak Pub that exits into a culvert under the Dedworth Rd and that can be a source of flooding in the area. Other ditches also link to the culvert where it crosses to road leading to the Hand Clinic.

4) Fields running up the east side of Tarbay Lane. These fields are used for horses but no other active farming. There are houses at various points further up Tarbay Lane, which implies some infrastructure services would be available. There are several access points into the fields but this is a small single track private lane and would need significant improvement if more than a few houses were built. However access could be achieved leading onto the Dedworth Rd via the Old Malt House. There are several are ditches either side of Tarbay Lane and these join together and run round between Winders House and the Old Malt House, and join up with the ditch that exits by the pub. There are a network of ponds and other ditches which partially drain the land but it suffers from high ground water levels. There is little strategic value in these fields.

Summary

The fields are classified as Grade 3 and have not been farmed for many years although they are let to one of the local stables and thus have horses on them most of the time.

Access to the site is possible from Dedworth Road with infrastructure and services and the Dedworth amenities nearby.

Extensive drainage works would be needed to enhance and maintain the existing ditches and ponds. Ground water levels are generally very high during the Winter months and particularly at the moment.

Thames Water have expressed concerns about sewerage in this area and the sewers just across in Oakley Green Red Road were overflowing in the recent heavy rain storms

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f) Area 5c, Triangle enclosed by M4, A308(M) and Ascot Road, Maidenhead

Question 21 regarding use of the triangle site between the M4, the A308M and the Ascot Road for housing or hospital led development.

This is a road locked site that forms a welcome ‘green gap’ entrance to Maidenhead and a similar ‘gap’ between Maidenhead and Holyport that is much appreciated by local Residents and thus is of high scenic value. Coming off the M4 roundabout, it provides a rural aspect and conveys a feeling of well-being before entering the urban environment on the outskirts of Maidenhead town centre.

The fields have not been graded and the quality of the soil is poor as the majority of the site is infill done down to 8m which has resulted in reducing the land level from the original. This infill was in the 1960's/70's using builders waste/paint with the probability of significant asbestos content due to the widespread use of materials such as artex at that time.

Access and flooding are significant additional problems with this site. With regard to access, both the two large roundabouts already have 5 arms and a 6 th is considered unsuitable on safety grounds. The Braywick roundabout (upper right on the map) already suffers from ½ mile traffic jams in the mornings, both up the A308 and coming out of Maidenhead.

This site is subject to more than 50% flooding with lakes forming centrally and the Cut overflowing along the northern boundary with the A308(M) . Any development on the site would have to establish where the displaced water would go, potentially to the detriment of nearby communities or further down-stream. It is understood that Thames Water have expressed concerns about sewerage in the area

The site would be affected by noise and air quality will be poor from the pollution from the surrounding roads. However the undisturbed nature of the site will mean that there is a high degree of bio diversity and ecological value to the site.

The use of the site as a hospital is ill conceived for similar reasons and particularly the access to the site and the congestions of surrounding roads.

Some use of part of the site for recreational and leisure activities may be possible and present less of an impact on local infrastructure. This suggestion is however untested with local Residents.

21 st March 2014 BPNP Preferred Options Submission page 20 of 35

7. Other Housing Policy Comments and Housing Questions (Q22 to Q33)

Question 22 relating to preferred Policy Option HOU3, meeting a range of housing needs.

Supportive as this Policy is deemed to meet the needs of the Bray Parish and won’t need to be included in the Neighbourhood Plan

Question 23 relating to preferred Policy Option HOU4 and lowering the thresholds for affordable housing

Preferred Policy HOU4

The preferred approach is that development proposals involving the provision of 5 dwellings and above (gross) or sites of 0.16ha or more (where there is a net gain in the number of dwellings) will provide up to 30% of the gross number of dwellings provided as affordable housing. The tenure, size and type of affordable housing unit will be negotiated on a site by site basis, having regard to housing needs, site specifics and other factors

The first part of this policy appears too specific and the second suggests it’s all negotiable. Why bother with the first part? It could be in the notes for ‘guidance’. In locations near the town centres and other urban areas there could be a greater emphasis on affordable housing. This policy should not compromise the look and feel of surrounding housing.

Question 24 relating to preferred Policy Option HOU4 and allowing people to own a share of their home.

Supportive as this Policy is deemed to meet the needs of the Bray Parish and won’t need to be included in the Neighbourhood Plan

Question 25 relating to preferred Policy Option HOU5 and exceptions to affordable homes in rural areas.

Preferred Policy HOU5 Affordable Housing Rural Exception Sites

The preferred policy approach is that development proposals for limited affordable housing within the Green Belt will be permitted as an exception where all of the following criteria are met:

a) A demonstrable local community need for affordable housing has been established; b) The number, size and tenure of the dwellings are suitable to meet the identified need; c) The site and the development proposal are well related to existing housing and not in the open countryside; d) The proposal is designed to respect the characteristics of the local area including the countryside setting; e) Adequate schools, health, shops and other community facilities are within reasonable travelling distance; f) Essential services such as power, water, sewerage, drainage and waste disposal are either available or can be provided to serve the site; g) The initial and future occupation is controlled to ensure the dwellings remain available to people in housing need, with a strong and demonstrable local connection.

We would like to see the following amendments or new clauses added to this policy and will either hope to see them in this policy in future iterations or will consider including them in the Bray Parish Neighbourhood Plan.

21 st March 2014 BPNP Preferred Options Submission page 21 of 35

Proposed Amended Criteria

a) A demonstrable local community need for affordable housing has been established and is agreed in consultation with the Parish Council; b) The number, size and tenure of the dwellings are suitable to meet the identified need and this need cannot be met elsewhere; g) The initial and future occupation is controlled though a legal agreement to ensure the dwellings remain available to people in housing need, with a strong and demonstrable local connection, in perpetuity.

Proposed New Criteria

h) There is no conflict with other Policies in the Local Plan

The intention of this policy would appear to limit the number of affordable homes required in developments in rural areas. This would generally be supported in the Bray Parish.

Question 26 relating to preferred Policy Option HOU6 and sites for gypsies and travellers

An additional 20 pitches, 7 by 2017, 7 between 2017 to 2022 and 6 between 2022 to 2027

Conditionally supportive, depending on what sites are selected.

Question 27 relating to preferred Policy Option HOU7 and the protection of residential land and housing stock and, Question 28 relating to preferred Policy Option HOU8 and housing layout and design, and Question 29 relating to preferred Policy Option HOU9 and housing density Question 30 relating to preferred Policy Option HOU10 relating to conversions Question 31 relating to preferred Policy Option HOU11 relating to development in residential gardens Question 32 relating to preferred Policy Option HOU12 relating to extensions and outbuildings Question 33 relating to preferred Policy Option HOU13 relating to residential amenity

Supportive as these Policies are deemed to meet the needs of the Bray Parish and won’t need to be included in the Neighbourhood Plan

21 st March 2014 BPNP Preferred Options Submission page 22 of 35

8. Sites Rejected by the Housing Assessment and the “Edge of Settlement” Analysis which should have been included in the Consultation

Table summarising potential additional dwellings from Rejected Sites

No Site Name Area Min.Dwellings Max Dwellings (Hectares) 7. 1 WMMA 2002 2 Marlow 0.16 (High 20 20 Rd Commonwealth War Rise Flats) Graves Commission 7. 2 Area 6B Maidenhead – Area 26.4 ( Smaller 1135 1320 east of A308 Bray Wick Style Houses) 7. 3 Area 7 E Maidenhead – Area 3.9 (Larger 86 156 between Monkey Island Style Lane and Bray Lake Houses) 7. 4 Area 9A Windsor – Area at 51.6 (say 50% 567 1032 Lower Farm & St Leonard’ developed Farm/west of Wilton with Larger Crescent Style Houses) TOTAL DWELLINGS 1808 2528

Housing densities in this table have been taken from the document “Windsor and Maidenhead – Capacity Assessment”, June 2013, section 2, Conclusions, Studio REAL advice.

7.1 WMMA2002 2 Marlow Road Commonwealth War Graves Commission Building

21 st March 2014 BPNP Preferred Options Submission page 23 of 35

RBWM Conclusion :

BPNP Comments : It is known that this structure is felt by the War Graves Commission to be unfit for modern office use and that they are looking for alternative accommodation. If alternative appropriate office space could be identified in Maidenhead amongst the empty office buildings or new ones which will be constructed as part of the re-development of Maidenhead Town Centre, then this site too, would be potentially available for housing.

BPNP Recommendation : address the War Graves Commission’s issue and remove the uncertainty which would allow the site to be included.

7.2 Area 6B Maidenhead – Area east of A308 Bray Wick

21 st March 2014 BPNP Preferred Options Submission page 24 of 35

RBWM Conclusion :

BPNP Comments : This statement is not independent and objective for these reasons: • Too many different types of area have been included in one blanket conclusion

• Area is thought to be “too hard” to address

The conclusion reached for other, similar, sites was “Reject in Part: Accept in Part” and this is what should have been concluded here. There are parts of Area 6B which could be addressed easily and should be Accepted:

• Playing Fields • All weather pitches • Running Track • Rugby Ground • SportsAble • Golf Driving Range • Car Park

There are parts that should be Rejected:

- Land Fill site and Bund between the site and the Cut - Cemetery - The 38 Acre Field (North West of the Upper Bray Road)(Part of a Green Gap) - Braywick Nature Reserve - Land to the North West of Hibbert Road (part of a Green Gap) - Land between Hibbert Road and the tributary of the Cut (Part of a Green Gap)

There are parts that require further consideration:

- Braywick Lodge - Braywick Nurseries

BPNP Recommendation : That, working with BPNP, a full re-evaluation of what is in reality a series of very different sites be undertaken and that detailed consideration is given to relocating the easily addressed facilities possibly on one of the Green Belt sites currently proposed for housing. The objective is to include as much of the site as possible in the Housing Sites Assessment paper

21 st March 2014 BPNP Preferred Options Submission page 25 of 35

7.3 Area 7E Maidenhead – Area between Monkey Island Lane and Bray Lake

RBWM Conclusion

BPNP Comments : Again this is a site with many different components which should be considered separately and for which the conclusion “Accept in Part: Reject in Part” would be appropriate. The site encompases a narrow strip running towards the A308. This is not useful and is next to a site of Special Scientific Interest (SSI). The Water Treatment Plant can be excluded.

Focussing on the Minerals processing plant, this is currently fed from the Bray Triangle which is getting close to the end of the three year extraction period. The last area for extraction locally is the land south of the A308, behind the old Queens Head Pub from which extracted minerals could be transported for processing by conveyor belt. If the planning of this extraction was managed correctly, this site could become available within the Period of the BLP. When all the local minerals have been exttracted, the local Parish Council, Residents and, we hope, the Borough would not allow minerals to be trucked into the site for processing. This activity would cause uneccessary large lorry movements both along the A308 and up and down Monkey Island Lane. Access to the site off the A308 would be an major issue as it is already heavily congested.

BPNP Recommendation: Include part of the site, at least the minerals processing plant in the BLP

21 st March 2014 BPNP Preferred Options Submission page 26 of 35

7.4 Area 9A Windsor – Area at Lower Farm & St Leonard’ Farm/west of Wilton Crescent

RBWM Conclusion:

BPNP Comments : Again this is a site with many parts. It is on the edge of the Windsor conurbation but development would not significantly impact the openness of the Green belt. Even though there is a Listed Building we believe that this can be accommodated.

BPNP Recommendation : include in Housing Sites Assessment

21 st March 2014 BPNP Preferred Options Submission page 27 of 35

9. New Sites which have been identified since the Consultation papers were written These are sites which have not been included in the various RBWM papers but many are located in or close to Maidenhead Town Centre and would offer easy pedestrian access to shops, transport and leisure facilities. We do not wish to suggest that businesses must move out of the centre of Maidenhead but we do wish to encourage the very best use of our limited land assets.

Table summarising potential additional dwellings from New Sites

Min. Max. No. Site Name Area Ha. Dwellings Dwellings

8.1 Maidenhead Town Centre - AAP n/a 1900 2400

0.72 (Smaller 8,2a Ray Mill Road East 31 36 Style Houses) 1.6 (Smaller Style 8.2b College Avenue 69 80 Houses) 0.99 (Medium 8.3 Town Hall 116 122 Rise Flats) 0.95 (Medium 8.4 Maidenhead Football ground 110 116 Rise Flats) 13.25 (Smaller 8.5 Broom Farm Estate 570 662 Style Houses) 0.63 (Medium 8.6 Desborough Bowling Club 73 77 Rise Flats) 1.0 (Estimated) 8.7 Police Station Law Courts (Medium Rise 116 122 Flats) Conversion of Offices into 8.8 Estimated 100 100 Dwellings TOTAL DWELLINGS 3085 3715

Table summarising potential additional dwellings from Possible Sites in Bray Parish

Min. Max. No. Site Name Area Ha. Dwellings Dwellings Oakley Green, Former 1.5 (Larger Style 8.9 35 63 Mushroom Farm Houses) TOTAL DWELLINGS 35 63

Housing densities in both tables have been taken from the document “Windsor and Maidenhead – Capacity Assessment”, June 2013, section 2, Conclusions, Studio REAL advice.

21 st March 2014 BPNP Preferred Options Submission page 28 of 35

8.1 Maidenhead Town Centre – Area Action Plan

We understand that the new Developer involved with this project has provided updated projections of the potential dwellings which could be delivered by the regeneration of Maidenhead Town Centre.

Original projection: 700 dwellings Revised projection 1400 dwellings Updated projection: 2400 dwellings

We understand that this latest figure includes 500 homes on the Magnet Leisure Centre site and 500 on land currently used by Thames Water for a sewage works at the south end of Stafferton Way that may also become available during the plan period. There is some risk on this latter number as it may not become available in the plan period.

Magnet Leisure Centre

This structure has recently been declared out of date and unfit for purpose. Leisure facilities are important for Maidenhead but these facilities could be usefully included in the specification of the re-development of Maidenhead Town Centre, leaving the current site potentially available for housing. Alternatively it could be relocated to the edge if the town, relieving traffic congestion in the Town Centre

BPNP Recommendation : that RBWM make every effort to encompass as much of Maidenhead Town Centre in the regeneration project thus maximising the potential for more dwellings in the most sustainable locations.

21 st March 2014 BPNP Preferred Options Submission page 29 of 35

8.2 Clare’s Court School

The School’s recently unveiled plans to consolidate parts of the School on the Ridgeway site leaves their land at Ray Mill Road East and College Avenue potentially available.

2a Ray Mill Rd East site

2b College Avenue site

BPNP Recommendation : evaluate these two sites for inclusion in the Housing Sites Assessement.

8.3 Town Hall

This is a prime site in the middle of the Town and RBWM could relocate to more modern and efficient offices, possibly in an existing office building, many of which are empty in Maidenhead or Windsor. This could easily happen within the period of the BLP.

21 st March 2014 BPNP Preferred Options Submission page 30 of 35

Thought would be required about the re-location of the Desborough Suite and facilities which are needed in the centre of Maidenhead. Norden Farm, whilst being culturally excellent and required as part of the cultural scene in Maidenhead, is not served by public transport and its location does not meet the whole spectrum of needs of the general public in Maidenhead. Perhaps a replacement for the Desborough Suite could be included in the specification of the re- development of Maidenhead Town Centre.

BPNP Recommendation : evaluate this site for inclusion in the Housing Sites Assessement.

8.4 Maidenhead Football ground

This site is right in the centre of the Town. We do not see any reason for this to remain located in this position where, replaced with housing, Residents would have pedestrian access to all the facilities within the Town. Our expectation is that most of the fans arrive in the Town or at the site by car and a location outside of Maidenhead Town Centre would not increase traffic flows in the area. Peter Griffin, the Maidenhead United Chairman, was quoted as saying that the door is definitely open for further discussion with the Borough on the Club’s involvement with their proposed development plans.

BPNP Recommendation : evaluate this site for inclusion in the Housing Sites Assessement through relocation, possibly in the Green Belt.

21 st March 2014 BPNP Preferred Options Submission page 31 of 35

8.5 Broom Farm Estate

The MOD are selling off land which they are no longer using to capacity and much of this is being used around the country for housing as it is classed as “brown field”. It is known that there are now much lower numbers of army personnel and it is believed that the Broom Farm Estate is no longer fully utilised. This offers a potential opportunity for development within the existing boundaries of Windsor.

BPNP Recommendation : evaluate this site for inclusion in the Housing Sites Assessement

8.6 Desborough Bowling Club

This site is right in the centre of the Town. We do not see any reason for this to remain located in this position where, replaced with housing, Residents would have pedestrian access to all the facilities within the Town. Our expectation is that most of the members arrive at the site by car and a location outside of Maidenhead Town Centre would not increase traffic flows in the area

BPNP Recommendation : evaluate this site for inclusion in the Housing Sites Assessement through relocation, possibly in the Green Belt.

21 st March 2014 BPNP Preferred Options Submission page 32 of 35

8.7 Police Station and Law Courts

The Maidenhead Police Station and Law Courts are in a location which is outside the main body of the Town and which are very difficult to anyone to access whether by car: there is no parking: there is no easy access by foot, there is no easy way to access the site. Many people take their life in their hands by crossing busy main roads and dual carriageways where there is no formal crossing to get access.

We note that the Neighbourhood Policing Teams are already located in offices next to Sainsbury’s, exactly where they should be located in the centre of the Town and amongst the people. It would make a great deal of sense to include these facilities in the Maidenhead Town Centre Rejuvenation plans, thus leaving the current site available for housing.

Advantages would include:

-Easy access for all -Just on the edge of a 10 minute walk to Maidenhead Station -Public Transport nearby -Parking nearby -Better integrate the Police and Law Courts into the Community

BPNP Recommendation : evaluate this site for inclusion in the Housing Sites Assessement through relocation in the Toiwn Centre.

8.8 Conversion of Offices into Dwellings

More exhaustive studies across the many towns and villages should be conducted by the Borough, to expose all buildings and land appropriate for change of use to housing, including prospects for redevelopment of existing housing sites to achieve more homes on the same area of land.

21 st March 2014 BPNP Preferred Options Submission page 33 of 35

For Maidenhead town centre, the maximum number of dwellings within walking distance of the Crossrail station would not only contribute to the housing requirement but also help return the town to being a thriving retail centre.

Heavy criticisms that there are too many empty office blocks, has been made by our parishioners. A viable scheme converting Berkshire House offices to 68 homes, has received planning permission, a theme which should be encouraged.

Without including the large new blocks under construction, well over 180,000 sq. ft. of offices now stand empty in the centre and close by, varying in size lots and quality of opportunity for viable change of use including:

• Forlease Road, • 25-29 Queen Street • Braywick House, Windsor Road • Nicholson’s House • Nicholson’s Walk, Switchback Park • Sygnus Court, Market Street • Foundation Park • York Stream House • CITA (Jolly Green Giant)

….and more. These are only the obvious targets within Maidenhead.

Even if half were perhaps maintained as work space, hoping for an upturn in the market, and the balance converted as per the above example, using a rough average of 1000 sq. ft. per unit, 100 dwellings would be achieved in the near future.

8.9 The Old Mushroom Farm on the corner of Oakley Green Road and the A308

This site is previously developed land in the Green Belt and is well screened from the A308 thus helping to preserve the Green Gap between Windsor and Maidenhead. The site offers no amenity to Residents and there would be a planning gain from development into housing.

BPNP Recommendation : evaluate this site for inclusion in the Housing Sites Assessement

21 st March 2014 BPNP Preferred Options Submission page 34 of 35

10. Conclusions

The Bray Parish Neighbourhood Plan Steering Group feels that the development of the Borough Local Plan is the only real opportunity in the next 15 years to turn Maidenhead Town Centre into the vibrant destination of choice for people to live and work that the Borough’s Residents deserve. The next few years are critical to ensure the town is ‘open for business’ when Crossrail arrives in 2019. If not now, when? 2030? Your Residents are crying out for a new Town Centre now!

The 2007 Inspectors report on the last Local Plan attempt, and the Regional Spatial Strategy (RSS) of the same year both recognised that development needs to be prioritized in Maidenhead for the same reason - Crossrail

The Maidenhead Action Plan needs to be broadened to encompass homes and infrastructure around the station. Many more homes could be built in central Maidenhead, and the table above shows that, in addition to the new Maidenhead Action Plan figure of 2400, up to a further 1315 could be built within walking distance of it.

The last few months have shown that many of the Edge of Settlement sites are prone to flooding and building on the others is likely to make the situation worse as there will be nowhere for the water to go. Thames Water have also expressed concern about sewerage on many of the sites. However we have identified some further sites that were rejected from the consultation but we believe some of these could be included which might provide up to a further 2528 homes

BPNP also bring to the attention of RBWM one possible Brown Field site in the Green Belt, the old Mushroom Farm in Oakley Green where an additional 63 homes might be built subject to local consultation.

Certain leisure and public buildings would have to be moved further out to accommodate this and leisure facilities in particular could be considered for location on some suitable Green Belt sites.

Infrastructure for access to Maidenhead Rail Station needs to be an integral part of this plan with a radical re think now to establish how 1000’s cars are going to get into the Borough and park each day when Crossrail is up and running. Serious consideration must also be given to how substantially increased transit traffic will be managed, when both the A330 and A308 are already at capacity.

Residents want to feel proud of Maidenhead. Now is the chance to make this happen.

Using the Green Belt to solve the perceived shortage of housing is not a Long Term Sustainable option. If we took this option, in 2030, how much of our precious Green Belt would remain?

21 st March 2014 BPNP Preferred Options Submission page 35 of 35