MDD DPD Consultation Submission from and Newland Parish Council

General comments

Arborfield and Newland Parish Council recognise that the MDD DPD document has been well constructed and would like to thank the Officers for their efforts in producing the document. We support the general aim and welcome the balance that the document seeks to strike between recognising the architectural, historical and landscape character of the area while looking for ways to enable sustainable development.

We do however feel that the maps published on the website are hard to read when trying to review at street level. We would encourage Wokingham to provide higher resolution images of the maps so that proper comments can be made by interested parties.

We also feel that the objectives set out in 1.11 are too focused on housing development and we would like to see objectives being set more specifically about the provision of education, provision and development of public and community open spaces, expanded objectives on sustainable development (including sustainable transport options) and objectives about provision of accommodation to support the development of employment.

Specific comments

Chapter 1 -- Introduction

1.3 – The MDD DPD recognises that the SE Plan will be abolished at some point. We would like to understand what assessment has been made of the impact that this will have on the MDD DPD, and what provision has been made to review the document following its abolition. 1.4 – We would like to understand why the Neighbourhood Plan isn’t included within the Local Plans for Wokingham box in the diagram explaining the hierarchy of documents? We understand that, once adopted through a local referendum, a NP should have the same weight as the MDD DPD, we would like to ensure this is added to the MDD DPD. Arborfield and Newland Parish Council are currently working with Parish Council on a Neighbourhood plan covering the two communities and the SDL. We would encourage WBC to work with the councils to understand our Neighbourhood Plan so that the issues raised are incorporated into development of the MDD DPD. 1.6 – We congratulate WBC on having the vision to produce an MDD DPD with such a long life, however we would like to understand more about WBC’s plans to keep the MDD DPD updated during the period of its life (to 31 March 2026) 1.10 – Re SDL settlement boundaries we understood that the intention was to re-draw these once the development allocations had been made. Under this approach land not used for development would be returned to a countryside category. This point does not appear to be covered in the MDD DPD. We would also like to understand how sites for other development (outside the SDLs) can be allocated over such a long timeframe. Arborfield & Newland Parish Council – MDD DPD response – Aug 2012 1

1.11 – speaks about acceptable balance between housing and employment outside the SDLs, but we would like to see WBC looking specifically about policies to create opportunities for businesses wishing to move into the area (larger scale) or local people wanting to start up businesses (smaller scale) Also the type and nature of businesses to align with the demographics of the area, IT, Professional Services, Corporate Business and just light industrial. 1.11 – We would also like to see strategies for development of IT and communications infrastructure to enable development of businesses and act as an enabler to different transport patterns (working from home) 1.11v – As Arborfield sits on clay we believe that the MDD DPD should be more robust on building in areas prone to flooding; therefore we would propose deletion of “most” – limit development in those areas at risk from flooding 1.11 – We note that the MDD DPD strategies do not set out any plans for education, sustainable development (green towns) or open spaces/shared spaces/community spaces.

Chapter 2 – Cross Cutting Policies

CC01 – Development limits

CC01 – on some of the maps the proposed development limits appear to be inside the existing development boundary – is this logical or consistent? 2.6 – the development limits for the SDLs define “where the built development envisaged within each SDL can occur, although some non-built development will also take place within the development limits” – Within the Arborfield SDL there are significant existing open spaces which are currently within the development limits and do not appear to be identified on open space maps. We would like to see the existing open spaces in the SDL excluded from the development limits or specifically recognised as open spaces to prevent development on these areas. 2.6 – school playing fields can be outside the development limit although school buildings are seen as being within – logically this will have the effect of moving the school to the edge of the development area so that the developer can maximise built environment within the limit and not lose buildable space due to the playing fields. All development including school playing fields should all fall within the SDL and should not be outside it. 2.8 – We welcome the need to be sensitive about developments at the edge of the development limits. We feel that this intent could be further enhanced by talking about density or height restrictions. The inspector instructed that the overall density should not exceed 35 houses per hectare.

Generally there is no mention on how open spaces, or existing planting within development limits should be treated. The Arborfield SDL has the potential to become a unique green village development, but this will only be achievable if there are sufficient protections in place for the existing open spaces and planting. It is unclear how the development limits take account of access roads etc. For the SDL areas the development limits need to include the access roads and particular care needs to be taken with the junctions with existing roads to ensure that the character of the area is not damaged by over-large roundabouts or multi-lane entry/exit points from the SDL.

CC02 – settlement separation areas

Arborfield & Newland Parish Council – MDD DPD response – Aug 2012 2

The map illustrating the separation areas around the area does not extend to the West of the Eversley Road. We would ask WBC to consider extending the separation area to avoid infill development at Duck’s Nest Farm area which would create ribbon development between the Garrison SDL and the Southern edge of Arborfield Village.

We note that there is no map safeguarding alignment for the proposed Arborfield Bypass (but that there is one for the Eversley Bypass where it is within the borough. Is this due to the pressure from Hampshire County Council, and how can this have been agreed before the Arborfield Bypass?)

CC03 – Green infrastructure

We broadly welcome the aims, esp. 2d and 2e

The intent behind “green corridors” is welcome as it should promote non car modes of transport. We would like to have a further definition of a “green corridor” to avoid a narrow track filled with brambles and nettles which will quickly become an unattractive rather than attractive “green corridor”.

The green routes map is very hard to read and we would ask WBC to review this map and provide additional information on the existing routes and proposed developments.

2.18 – it would be useful to have a map defining all the areas of existing planting (esp. in SDLs) which shall be retained in development plans to give more weight to the welcome intention in 2.18

CC04 – Sustainable Design and Construction

The Parish welcomes the Borough’s approach to sustainable design and construction and is encouraged to see the principle of future proofing the design by insisting on standards higher than are required by building regulations at present.

The Parish would like to see a more integrated approach to sustainable design which considers how location of properties relative to leisure, retail and employment impacts on the actions of the occupants of the dwelling and consequently on the environment.

CC05 – renewable energy and decentralised energy networks

2.40 – what will happen to this requirement when the SE Regional plan is abolished? The table and targets taken from the SE plan appear to be absolute generation targets (mWs) while the policy talks about securing 10% of energy from renewable or low carbon sources.

2.46 – proposes use of wood biomass from existing forests through thinning schemes. The change to the local environment from largely unmanaged to managed woodland would have a significant impact on how woodland currently shapes our environment and is likely to have an impact on flora and fauna.

Arborfield & Newland Parish Council – MDD DPD response – Aug 2012 3

The Parish would like to see significant additional evidence of how these proposed schemes would work before they are adopted in the Arborfield area.

CC06 – Noise Development traffic movement schemes would need to be agreed and or developed to ensure that the levels of noise and quality of life of the existing residents are not impeded during the protracted length of the developments.

CC07 – parking

We welcome the future-proofing approach of ensuring that charging for electric vehicles will be considered in the provision of parking spaces in all environments

We would like to see more consideration given to areas of parking for retail at the SDLs (local and neighbourhood centres) and the need to incorporate retail into the street frontage of the overall scheme rather than isolating retail as an island in a sea of parking (i.e. not like Lower Early neighbourhood centre)

We would like to understand how demand management policies and promotion of non-car modes of transport will impact the guidelines on the number of spaces required per dwelling, employment centre or retail outlet.

We would like to encourage WBC to think more holistically about sustainable design and transport and to think more actively in the MDD DPD about addressing the need to consider distances from residential to alternative transport or retail in order to encourage viable alternatives to car use.

CC08 -- safeguarding alignment

We note that there is no mention of the Arborfield Bypass on the maps or in the Appendix and would like to understand how WBC plans to safeguard a proposed route for the bypass. We would like to see this added to the MDD DPD, but recognise that there is need to consult with the community on a proposed route before the alignment can be set.

We note also that while there are express bus or mass transit schemes proposed for some areas, there are no such provisions proposed for the A327 through Arborfield which with the SDL development will leave the area significantly deficient in terms of non-car modes of transport to Wokingham and Reading. We would like to see this added.

CC09 – development and flood risk

SFRA is a comprehensive document reviewing flood risk and if incorporated in guidance should mitigate the risk of unintended flood risks being created by building in flood prone areas.

Arborfield & Newland Parish Council – MDD DPD response – Aug 2012 4

Does the MDD DPD take enough account of the impact of new development on flood risks? Especially worth noting that as the Garrison SDL lies on clay (per the SFRA) it will be necessary to ensure that there is significant flood mitigation to allow run off of surface water into holding areas before going into the drainage (as with the drainage channel through Penrose Park)

CC10 – sustainable drainage

The policy on sustainable drainage incorporates the principles set out in the SFRA and if enforced should deliver the drainage requirements for the new developments.

2.8 – experience at Penrose Park and Poperinghe Way has demonstrated that there are issues with securing adoption of sites including the SuDS and as such this section requires strict enforcement. The majority of the flooding incidents in Arborfield in recent times have resulted from poor maintenance of the SuDS incorporated in developments.

Chapter 3 – Topic Based Policies

Green Belt

Not specifically relevant to the Parish

AWE

Not specifically relevant to the Parish

Residential Uses

TB05 – Housing Mix

While eminently sensible to provide an appropriate mix of affordable housing, it is not clear from the draft how WBC will take account of the “underlying character” of an area when deciding what the mix should be. 3.23 suggests a borough wide mix will be applied regardless of “underlying character”, we would therefore ask WBC to consider this policy more fully to take account of existing affordable housing. Also that WBC do take into account of the rural nature of the Arborfield SDL and lack of planned services, it would be reckless and create an unsustainable development, by ignoring the “underlying character” of areas. This would urbanise the rural nature of parts of the Wokingham borough and would be contrary to CP1 of the Core Strategy.

3.25 requires all homes to adopt lifetime homes standards, this is to be welcomed as promoting accessibility, but care needs to be taken that this requirement does not load additional costs onto the purchasers of the properties (esp. if making development in the borough unsustainable), or making it impossible for developers to fund infrastructure development due to lower profit margins.

Arborfield & Newland Parish Council – MDD DPD response – Aug 2012 5

TB06 – development of private residential gardens

This policy would appear to make it quite likely that development will be allowed in private gardens as the list of qualification criteria that will allow a scheme to be granted is extensive. The test for refusing the scheme “cause harm to the local area” is not so clearly defined.

The Parish is not able to support this policy as it is currently worded as we believe it will make it much harder for the Parish to control the development of gardens in our rural parish. The whole purpose of the original consultation for the Core Strategy was to develop the SDL within the borough to limit/avoid the constant development of back gardens, where WBC failed to control and failed to manage funding for local amenity and infrastructure. WBC have spent many years promoting the SDL’s as the alternative to back garden development and promising to irradiate this if the electorate got behind the Core Strategy. It is fundamental to spirit of the Core Strategy and should be strongly worded to limit the back garden development and not to promote it.

TB07 – internal space standards

No comment TB08 – open space, sport and recreational facilities

There appears to be no map setting out existing open spaces and protecting them.

We would like to understand what protections will be in place to ensure that existing open space (for example Arborfield Park, or the rugby pitches in the garrison) will not be taken into account to enable the SDL developers to reduce the amount of space that they need to allocate as open space in the SDL development?

TB09 – Residential accommodation for vulnerable groups

No comment

TB10 – traveller sites

1(b) As there appears to be a presumption that the traveller sites will be allowed outside the development limits we would like to understand what protections will be in place to govern the number of traveller sites that are given permission outside the development limits.

1(a) we would like further explanation on how “identified need” will be determined and in particular what account is taken of any undeveloped sites (for which permission has been granted) when giving permission for new developments?

1(f) landscaping requirements must be legally binding.

1(h) how can business uses be encouraged within a traveller site? This should not be encouraged

Arborfield & Newland Parish Council – MDD DPD response – Aug 2012 6

Further comment is likely to be required on the GTAA when published in Oct 2012.

TB11 – core employment areas

Reflective of the demographics of the existing area

TB12 – employment skills plan

We would like to understand how incorporation of employment skills plans into section 106 agreements may reduce funding available from developers for infrastructure or CIL?

TB13 – science and innovation park

No comment

TB14 – Whiteknights Campus

No comment

TB15 – Major town and small town/district centre

No comment

TB16 – development for town centre uses

The sequential test requirements will be applied to the developments in the SDL and as such are to be welcomed.

TB17 – local centres

No comment as none currently defined within the parish

TB18 – garden centres etc

The test to ensure that a “separate commercial use” is not being established on site is to be welcomed to ensure that the garden centres remain primarily for gardening and do not adversely impact on the rural nature of their settings.

TB19 – signage

Arborfield & Newland Parish Council – MDD DPD response – Aug 2012 7

We feel that the signage proposals are broadly sensible.

TB20 – service arrangements

We would like WBC to consider whether these provisions should also be extended to include education establishments which cause the greatest complaints about traffic and parking in the area. The design of all schools needs to include an onsite drop-off zone that is substantial enough to cope with the school head count, while preserving the provision of adequate playing fields and playgrounds for the expected school roll.

3.95 The policy needs to be strengthened to reflect greater restrictions to out of hour’s deliveries adjacent to residential properties. We would encourage Officers to look at the conditions attached to the Tesco development on the Oxford Road in Reading for good guidance and then apply them to this policy.

TB21 – landscape Character

3.112 B (IV) Why are ancient woodlands not to be shown on the maps? This was normal in previous policies

Also as raised above we would like to encourage WBC to map areas of mature planting and open spaces.

TB22 – SULVs

No comment as none impacting on the parish

TB23 – biodiversity and development

Sites of local importance does not take sufficient account of mature planting which is important in all local areas and helps to shape the character of an area and to give a sense of place. These sites should be expanded, especially in the SDLs to take account of the existing planting and open spaces

Apart from this comment the other policy areas are clearly sensible and to be welcomed if they are enforced through the development proposals

TB24 – heritage assets

3.119 – seeks to keep buildings in their existing use where possible. We would like WBC to allow the policy to give more consideration to allowing change of use where that will be the best way to preserve the fabric of the building.

TB25 – archaeology

Arborfield & Newland Parish Council – MDD DPD response – Aug 2012 8

No comment

TB26 – buildings of traditional local character and areas of special character As per 3.119

Annex 2 Night time noise does not appear to be taken into account from Supermarkets, restaurants, disco’s sports clubs etc

Annex 3 (vi) Makes ref to an Eversley by pass where it passes through the Borough. We understood that Hampshire CC had removed the bypass from their plans.

Chapter 4 - Site Allocations

The CS requirement for housing including reserve housing is exceeded by the calculations in chapter 4. This proposed policy grossly exceeds the housing requirements set out in the CS and approved by a government Inspector. This needs to be rectified by WBC as a matter of urgency.

Wind farm policy should reflect the following which is based on a recent high court judgement which is a clear recognition of citizen’s rights. a) Landscape and Visual Impact

Wind farms should be located sufficient distance from town and villages so as not to be too prominent, for example, outside of 2km from defined settlement boundaries (those in the development plan).

In general, there should be a presumption against wind turbine developments on the grounds of potential negative cumulative visual impact, unless wind farms should be located such that they would not merge with the existing developments thereby resulting in a negative cumulative visual impact:

 Settlements of more than 10 dwellings should not have wind turbine developments in more than 90° of their field of view,  Individual dwellings should not have wind turbines in more than 180° of their field of view.

Impact on the Historic and Natural Environment

Wind turbine development should not take place in locations where:  The context of a historic garden, park, Grade 1 listed building, or designated conservation area would be visually compromised the visual significance of historic/architecturally important buildings would be compromised. Wind turbine development should be avoided where there is likely to be “conspicuous” impact;  the development would be in or in proximity to a site of nature conservation interest and of a Site of Special Scientific Interest;

Arborfield & Newland Parish Council – MDD DPD response – Aug 2012 9

Residential Amenity

Amenity of existing residential occupants must be maintained at an acceptable level, therefore the following criteria shall be applied:-

No wind turbine developments shall be constructed in close proximity of a residential property (the accepted distance for separation is 700 metres) however, noise and amplitude modulation issues can be present up to 2km away. Therefore, unless through assessment, it can be demonstrated that there would be acceptable noise levels within the 2km radius of a residential property, the minimum distance should be 2km:

No wind turbines shall be constructed within a distance of a factor of ten times the diameter of the blades of a residential property to mitigate against flicker, unless intervening topography/structures negates the impact.

Wind farm developments must demonstrate that they would have no unacceptable impact due to noise, amplitude modulation, low frequency sound or vibration on residential amenity.

Related Infrastructure

The presumption is for connecting cables to be placed underground and use made of existing or replacement pylons (of the same size and scale) along existing routes to carry the additional base load cabling.

Construction Vehicles

Access for construction and maintenance vehicles is an issue in rural areas, particularly where highway improvements are required. In such circumstances commuted sums would be required for highway improvements and reinstatement. In addition, it may be appropriate for proposals to be subject to routing agreements and bonds for construction traffic, which should be agreed prior to determination of a planning application, in order to mitigate against the impact of construction vehicles on rural communities.

Local Economy

Whether individually or cumulatively, wind farm developments should not have a negative impact upon the local economy, particularly upon tourism.

Decommissioning

The decommissioning of wind farm sites should include the removal of all infrastructure whether above or below ground (including the turbine bases and access roads within the site). This will be achieved via Sc 106 planning obligations or planning conditions attached to the permission. In addition, a bond should be in place with the relevant local authority to ensure the cost of re-instatement does not fall to the taxpayer.

Water

Arborfield & Newland Parish Council – MDD DPD response – Aug 2012 10

This policy is very welcome but the statement be carried out to an appropriate degree at all levels of the planning process is far too vague and the words need to be strengthened so they cannot be misinterpreted.

The same comment can be made for the statement Flood resilient and resistant measures should be incorporated into the design of development proposals the word should would be better if must was used.

Sustainable Drainage The paragraph beginning with ‘The surface water drainage techniques for a site including SuDs have to be decided at an early stage’ should read ‘must’ be decided at an early stage. A ref to pre all or outline might be helpful. The paragraph beginning with Planning Conditions or agreements may be used where appropriate to secure implementing sustainable drainage the word ‘may’ should be changes to ‘must’

Arborfield & Newland Parish Council – MDD DPD response – Aug 2012 11