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The Clewer Group

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The Clewer Group The Clewer Group CHAIRMAN: BASIL WILLIAMS 59 CLEWER PARK, CLEWER VILLAGE,WINDSOR, BERKSHIRE SL4 5HD Tel: 01753-860295 E-mail: [email protected] Ms Charlotte Glancy Programme Officer, Banks Solutions 7th August 2020 Dear Ms Glancy, Written Statement on behalf of the Clewer Group and Clewer MAP We have pleasure in submitting our comments in respect of the Borough Local Plan 2013-2033: Response to Inspector’s second Guidance note. These relate to specific circumstances and issues affecting the area covered by the Clewer Group and Clewer MAP. Whilst we support a number of changes which have been made to the BLP, we wish to highlight some of our greatest remaining concerns, chiefly with regard to infrastructure and Green Belt sites AL21 and AL22. MATTER 10: INFRASTRUCTURE Policy IF3 Local Green Space 2. LGS Designations now number more than fifty in the Borough and many others are expected as more neighbourhood plans are adopted, including the Windsor Neighbourhood Plan which has now successfully undergone Examination and is awaiting referendum (delayed due to Covid-19). In our BLP SV Changes Consultation comments, we asked to see these existing spaces added to the noted “Poundfield” (Para 14.8.4) together with a “holding statement" in 14.8.2 stating: “More areas of designated LGS are expected to be identified and confirmed as more neighbourhood plans are adopted during the BLP period. The Borough will maintain a list of designated Local Green Spaces in the…(document name, eg.OSS 2019,) and update this annually.” We would ask for this matter to be comprehensively addressed by the Borough, and the inclusion of our proposed “holding statement”. We could find no reference in the OSS 2019 to LGS as this document confines its discussions to typologies which do not by definition include this non-specific overarching designation. We believe this is a significant oversight which must be addressed as a matter of urgency, given that OSS 2019 is referenced in both the BLP SV and supporting Infrastructure Delivery Plan. We also strongly advocate retention of the 2008 Open Space Audit within the BLP Evidence Base as it is both the principal evidence for BLP SV open space and related green and blue infrastructure policy, and as the primary reference supporting the much less substantial OSS 2019. This would ensure that key information will be available to Officers, developers, neighbourhood plan groups and all members of the community, as well as soundness of the BLP SV and its Evidence Base going forward. Policy IF4 Open Space 5. We feel that recognition and inclusion of open space within the Borough’s infrastructure planning and delivery is particularly welcome. We are also extremely glad to see confirmation that the quantity of open space will be increased as necessary to address deficiencies and future needs associated with new development (Para 14.10.6). This is critical in meeting the needs of a growing community and will provide a crucial point of reference within ongoing strategic and spatial planning. We are deeply concerned, however, that the overwhelming impression in the consideration of open space, trees, woodlands, hedgerows, nature conservation, biodiversity and the overarching approach to developing green and blue infrastructure remains one of “relative superficiality”. This is reflected in paragraph and policy wording in a way which suggests a lack of more specific understanding of the individual and interconnected nature of these collective aspects and will, if not addressed, substantially undermine prospects for current and long-term provision and protection across RBWM. MATTER 11: PLACEMAKING AND SITE ALLOCATIONS Issue 5: Are the Plans housing and mixed-use allocations outside of the Placemaking areas justified and deliverable? Allocations in Windsor (AL21,22,29,30,31) Development in the Green Belt, eg AL21 and AL22, including infrastructure capacity of the A308 We remain exceptionally concerned by the potentially overwhelming impacts that various proposals which have come forward for AL21 and AL22, exemplified by the latest application for demolition of the remaining garden centre (Dedworth Road) and construction of an ALDI supermarket, would have on the historic environment including significant designated and non-designated heritage; surrounding road network, traffic and air quality; open space, natural environment, biodiversity, green and blue infrastructure; and overall character of the wider West Windsor area comprising Clewer, Dedworth, Oakley Green and Fifield. In our comments for the BLP SV “Changes” consultation, we indicated that the Borough’s aspiration to meet 100% of its OAHN should mean that provision of housing is not in fact required on either of these two sites, with “windfall sites” such as the Thames Valley Hospice in Clewer Green already set to provide additional development with concomitant implications for highways, air quality and all aspects of green and blue infrastructure including public open space. We reiterate our strongly held view that to pursue development of AL21 and AL22 would be contrary to national Green Belt policy and its application in this part of the Borough, as well as an unnecessary exploitation of high quality agricultural land for housing without any clear justification anywhere in the evidence supporting the BLP SV. We are appalled by the inconsistent approach to Green Belt development in the BLP, and the capacity of the A308 and wider road network necessary to cope with additional traffic loads from this and other parts of the Borough has never been soundly demonstrated. Yours sincerely, Basil Williams, Chairman, The Clewer Group Susan Shearer, Co-ordinator, Clewer MAP .
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