Managing Development Delivery (DPD) Local Plan Examination
Inspector’s Report on Reading Borough Council Sites and Detailed Policies DPD
WBC/31
April 2013
Report to Reading Borough Council
by C J Anstey BA (Hons) DipTP DipLA MRTPI an Inspector appointed by the Secretary of State for Communities and Local Government
Date: 11th September 2012
PLANNING AND COMPULSORY PURCHASE ACT 2004 (AS AMENDED)
SECTION 20
REPORT ON THE EXAMINATION INTO THE READING SITES AND DETAILED POLICIES DEVELOPMENT PLAN DOCUMENT
Document submitted for examination on 15 July 2011
Examination hearings held between 29 November 2011 and 15 December 2011
File Ref: PINS/E0345/429/8
Non-Technical Summary
This report concludes that the Reading Borough Council Sites and Detailed Policies Development Plan Document provides an appropriate basis for the planning of the Borough over the next 15 years providing a number of Main Modifications (MM) are made to the plan. The Council has specifically requested that I recommend any Main Modifications necessary to enable them to adopt the Plan.
The Main Modifications can be summarised as follows:
Include specific policy on the presumption in favour of sustainable development (MM1);
Revise Policy SA5: Park Lane Primary School, The Laurels and Downing Road (MM2 & MM5);
Delete Policy SA8a: Land at Kentwood Hill (MM3, MM4 & MM7);
Amend the Housing Trajectory table and graphs (MM6);
Revise boundary of the Kennet and Holy Brook Meadows Major Landscape Feature identified under Policy SA17 to exclude the Burghfield site (MM8); and
Revise boundary of the East Reading Wooded Ridgeline Major Landscape Feature identified under Policy SA17 to exclude areas of the University of Reading Whiteknights Campus (MM9).
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Reading Borough Council Sites & Detailed Policies DPD, Inspector’s Report September 2012
Introduction
1. This report contains my assessment of the Reading Borough Sites and Detailed Policies Development Plan Document (SDPD) in terms of Section 20(5) of the Planning & Compulsory Purchase Act 2004 (as amended). It considers whether the SDPD is sound and whether it is compliant with the legal requirements. The National Planning Policy Framework (the Framework) (paragraph 182) makes clear that to be sound, a Local Plan should be positively prepared; justified; effective and consistent with national policy.
2. The starting point for the examination is the assumption that the local authority has submitted what it considers to be a sound plan. The basis for my examination is the Sites and Detailed Policies Document, Submission Draft (July 2011), submitted to the Secretary of State on 15 July 2011.
3. My report deals with the Main Modifications that are needed to make the SDPD sound and legally compliant and they are identified in bold in the report (MM). In accordance with section 20(7C) of the 2004 Act the Council requested that I should make any modifications needed to rectify matters that make the Plan unsound/not legally compliant and thus incapable of being adopted. These Main Modifications are set out in the Appendix.
4. The Main Modifications that go to soundness have been subject to public consultation and, where necessary, Sustainability Appraisal (SA) and I have taken the consultation responses into account in writing this report.
5. The National Planning Framework and the Planning Policy for Traveller Sites were issued after the hearings but before the close of the Examination. The Council and representors have been given the opportunity of commenting on these documents. All comments received have been taken into account in writing the report.
6. The introduction of new national guidance during the Examination means that a significant number of minor changes to the wording of the SDPD are required to reflect the current position. The Council is responsible for making such changes in the final version of the SDPD, together with any other minor changes required.
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Assessment of Soundness
Preamble
7. The first part of the SDPD sets out the detailed planning policies that will be used to manage new development across Reading Borough over the coming years. The second part identifies the specific development sites and designations required to deliver the spatial strategy set out in the Council’s Core Strategy (CS), adopted in 2008.
8. Reading is identified in the South East Plan as a Growth Point, a regional hub and a centre for change. Its continued growth and development is vital for the prosperity of the area. The boundary of Reading Borough is very tightly drawn with over 40% of the urban area of Reading lying outside the Borough boundary. It is estimated that of the 230,000 living within the Reading urban area in 2001, some 145,000 live within Reading Borough. Various elements vital to the sustained future growth of Reading will need to take place in adjoining local authority areas. The material available indicates that adjoining authorities, through their adopted and emerging core strategies, are seeking to ensure that such elements are planned for and provided. For example the Strategic Development Location south of Reading around Shinfield identified in Wokingham Borough Council’s adopted Core Strategy provides for about 2500 dwellings and other uses and will make a significant contribution to the area’s need for homes and jobs.
9. The Borough itself contains little unconstrained, undeveloped land. As a result the CS recognises that future development of the Borough is likely to be focused on the redevelopment of brownfield land. Such an approach accords with national policy, provided that the land is not of high environmental value. The CS envisages a significant amount of growth taking place in the Borough itself. Most new development is to be steered towards the Central Area and South Reading. The CS spatial strategy also focuses development on the District and Local Centres and recognises that some employment sites have the potential for re-allocation to other uses.
10. The Reading Central Area element of the spatial strategy was largely dealt with in the Reading Central Area Action Plan (adopted in 2009), which allocated development capable of accommodating in the order of 5,000 dwellings and 200,000 sq m of commercial space. Notwithstanding this the SDPD applies to the entire Borough although some policies are clearly not relevant to the Central Area. The main elements of the strategy that remain to be dealt with in the SDPD include detailed guidance on South Reading, the allocation of development sites, the definition of various boundaries, and the re-allocation of various employment sites to other uses.
11. It is important to recognise that the Examination of the SDPD is not the appropriate format for the re-opening of debate about key issues that have previously been resolved in the CS, such as the overall level of housing provision, affordable housing on larger sites, the hierarchy of centres, retail policy, the principle of a Green Network, and the protection of Major Landscape Features. The appropriate time for the re-consideration of such matters is when the CS is reviewed. The Council has indicated that the Review of the CS is likely to take place in the near future.
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12. During the Examination the Council raised concerns about the amount and scope of some of the additional material submitted by certain representors in the period leading up to the Hearing sessions. After careful consideration the Inspector decided to have regard to most of this material as it developed arguments raised in the initial representations. However the Inspector stated during the relevant Hearing that he was not prepared to accept the detailed critique of the affordable housing policies submitted on behalf of the University of Reading. This was on the basis that these policies did not give rise to significant concerns in the representations and that affordable housing provision on larger sites had already been dealt with in the CS.
Main Issues
13. Taking account of all the representations, written material, and the discussions at the examination hearings, various main issues upon which the soundness of the plan depends have been identified. These are dealt with in turn below. Representations on the submitted DPD have been considered insofar as they relate to its soundness, but they are not reported on individually.
General Matters
Does the SDPD accord with the National Planning Policy Framework and has it been positively prepared?
14. The National Planning Policy Framework (the Framework) emphasises the importance of encouraging sustainable development through enabling economic growth and promoting housing development. Such a positive approach has been followed by the Council for many years and is inherent in the Council’s adopted development plan documents. The SDPD is in line with this approach and seeks to meet the carefully identified needs of the Borough through a comprehensive suite of policies and proposals that have sustainable development at that heart. As a result the SDPD sits comfortably with the general direction of the National Planning Policy Framework and has been positively prepared.
15. Notwithstanding this there is a need to include in the SDPD a specific policy that reflects the overarching presumption in the Framework of favouring sustainable development. I realise that the Council’s main modification (MM1) which introduces a specific policy to this effect differs from the model wording published on the Planning Portal. However to my mind it is still in line with the intentions of the Framework and does not differ from the model wording to the extent that the soundness of the policy is brought into question. The inclusion of the words ‘where appropriate’ is understandable given that from the outset it may be evident that a particular development will not improve the economic, social and environmental conditions of the area.
16. I conclude, therefore, that the SDPD has been positively prepared, and accords with the National Planning Policy Framework subject to the inclusion of MM1.
Does the SDPD broadly conform to the South East Plan?
17. The South East Plan (SEP) is the Regional Spatial Strategy (RSS) for the area.
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It provides a broad development strategy for the South East in the period up to 2026. Although the Government has announced its intention to abolish regional spatial strategies they remain part of the development plan. Consequently the requirement for the SDPD to be in broad conformity with the SEP still stands.
18. The South East Plan states that within Reading provision should be made for 12,220 new dwellings in the period between 2006 and 2026. It is evident that when all sources of new housing are taken into account, including the sites allocated in the SDPD, provision is made for about 13,200 dwellings in the Borough from 2006 to 2026. Although the regional target has been exceeded this over-provision is in line with government guidance and will ensure that needs are still met in the event that particular sites do not come forward as anticipated. The SEP does not require any other specific amounts of new development to be provided in Reading Borough, including employment land. As a result the CS and SDPD do not have to meet any regionally derived targets other than for housing. In summary, therefore, the SDPD broadly conforms to the South East Plan.
Does the SDPD provide for the level of housing and employment development envisaged in the CS? Is the SDPD effective in steering development towards South Reading?
19. The Core Strategy indicates that within Reading provision should be made for about 11,000 new dwellings in the period between 2006 and 2026. It is evident that when all sources of new housing are taken into account, including the sites allocated in the SDPD, provision is made for about 13,200 dwellings in the Borough from 2006 to 2026. This over-provision is in line with government guidance and will ensure that needs are still met in the event that particular sites do not come forward as anticipated. The distribution of new housing in the Borough over the plan period will be broadly similar to that anticipated in the CS with 50% in the Central Area, 22% in South West Reading and 29% in the rest of the Borough.
20. The Employment Land Review 2006 identifies overall needs for employment land, and forms the basis for the strategic policies in the Core Strategy. There are no specific figures within the CS as regards the amount of employment land required. Rather the emphasis is on focusing new employment development in the Central Area and along the A33 corridor, safeguarding Core Employment Areas, and managing the release of areas no longer required for employment use. The SDPD, based on the findings of the Employment Land Review Stage 2 Site Specific Analysis (2010), develops this strategy and identifies the Core Employment Areas and their detailed boundaries, and, by implication, those employment areas that may be suitable for other uses subject to the satisfaction of detailed criteria. The SDPD does not need to identify any additional employment land essentially because of the scale of existing commitments for employment floorspace within the area. Rather the SDPD seeks to secure the most appropriate development on each site, whether that includes the gain or loss of employment.
21. The CS identifies South Reading as one of the main sustainable locations for future development within the Borough because of accessibility improvements and the availability of large regeneration sites. The SDPD re-affirms and
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expands on this essential ingredient of the spatial strategy. It makes it clear that new development and regeneration here should seek to secure a range of benefits for this part of the town, where there are significant concentrations of deprivation. In particular developments on sites in the area should contribute to the creation of cohesive and integrated communities, provide employment opportunities, secure enhanced and improved community facilities and services, and provide visual enhancement. It is evident that the Council’s approach to South Reading that is implicit in the SDPD is in line with the terms of the adopted CS.
22. Consequently the SDPD provides for the level of housing and employment development envisaged in the CS and is effective in steering development to South Reading.
Are the policies and proposals in the SDPD based an up-to-date and robust evidence base?
23. The SDPD is supported by a comprehensive evidence-base. Most of the material in the evidence base is of recent origin. Where necessary the Council has sought to update the information available by additional work and/or analysis, for instance with regard to house completions, housing mix, affordable housing and employment sites. Consequently the policies and proposals contained in the SDPD are based on an up-to-date and robust evidence base. Notwithstanding this it is accepted that some of the work that informed the content of the CS will need updating as part of the CS Review
Is there a sufficient supply of housing land? Is the housing trajectory realistic and robust?
24. The Council has demonstrated in the material submitted that there is about 6.5 years’ supply of housing land when measured against South East Plan figures and over 7.5 years’ supply in terms of the CS. Consequently there is sufficient housing land identified to deal with anticipated needs and sufficient flexibility in supply to accord with the guidance in the National Planning Policy Framework. The SDPD also makes sufficient provision for housing land in the latter part of the plan period. Consequently a sufficient supply of housing land has been identified in the SDPD and there is no need to find additional housing sites. Conversely there is scope, if required, to delete particular small sites without prejudicing housing land supply.
25. Housing completions figures in 2010-11 are lower than envisaged in the submitted housing trajectory contained in Appendix 1 of the submitted plan. This is clearly not surprising given prevailing economic conditions. Although this has resulted in lower completions levels in the short term it is considered that most of the individual sites are likely to be deliverable during the plan period. Recent figures on the number of dwellings under construction, which is higher than it has been since 2008, would appear to confirm this view. Even if certain sites are not brought forward the over-provision that has been made introduces a large degree of flexibility. This together with other factors, such as assumed medium densities on allocated sites, the incorporation of realistic lapse rates, the fact that certain sites are not included in the figures, and the likelihood of windfall sites continuing to come forward, will help to ensure that housing requirements are met over the plan period.
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26. There is an element of double-counting within the projected completion figures in the housing trajectory. This means that the projected completions are higher than should have been the case. Consequently the figures need to be corrected to ensure that this part of the DPD is based on accurate information. This also gives the Council the opportunity of updating the housing figures and taking account of other Main Modifications (MM6). With these changes the housing trajectory is considered to be as realistic and robust as it can be given prevailing economic conditions.
27. The plan does not contain site areas for the housing sites, instead relying on indicative housing numbers. The text of the SDPD explains that these are indicative figures and are not to be taken too literally. This approach gives a broad indication of the amount of development that is likely to occur without being overly prescriptive.
Has sufficient regard been paid to infrastructure delivery?
28. Throughout the preparation of the SDPD there has been detailed consultation and engagement with a range of infrastructure providers/deliverers, both within and outside the Council. The information available indicates that there are no insurmountable infrastructure problems. The SDPD contains an Infrastructure Delivery Schedule setting out what will be required and when. Where there are existing issues of capacity, specifically with regard to health, education and transport, the Council is involved in continuing discussions with neighbouring authorities, the transport authority, highways authority and the health authorities, to ensure that the relevant infrastructure is provided. Consequently there is a reasonable prospect of the necessary infrastructure being in place at the appropriate time. As a result sufficient regard has been paid to infrastructure delivery.
Has account been taken of cross boundary issues?
29. The Council has sought to take account of cross boundary issues through close liaison with adjoining authorities. There is evidence of a tradition of successful joint working and there are structures in place, both at political and officer level, to ensure this continues.
30. Transport & highways. The highway modelling of the development provided for in the CS found that there would be no significant impacts on the strategic road network with minimal impacts on the A33 corridor, Junction 11 and the M4 motorway. This was essentially because the main redevelopment sites were previously in employment use. The Highways Agency has broadly accepted that the SDPD site allocations will not have a significant effect on the Strategic Highways Network. Although not specifically tested the highway modelling for the Core Strategy suggests very little specific transport impact on Wokingham Borough. Given the location of the main sites identified in the SDPD there are unlikely to be any significant transport impact on West Berkshire.
31. School provision. The Council’s Education Department is working with neighbouring authorities to meet future educational need, taking account of the implications of future population growth and growth resulting from
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proposed development. This is particularly important as at present 40% of secondary places are met from within adjacent authorities’ schools. The proposed Reading University Technical College (UTC) at the Crescent Road site which will provide vocational education for 14-19 year olds (dealt with later in this report), will help to address this imbalance.
32. Gypsies and Travellers. Core Strategy Policy CS19 indicates that in the event that there is a need to make provision for permanent sites within the Borough these will be identified in the SDPD. No sites are identified in the SDPD essentially because the 7 permanent pitches for the Borough required for the period to 2016 are to be provided within Wokingham Borough. As regards provision beyond 2016 the Council is undertaking work to determine the likely need for pitch provision, which will, if necessary lead to a separate Gypsy and Traveller DPD. Such an approach is broadly in line with government guidance as expressed in Planning Policy for Traveller Sites.
33. Retail development. It is an established principle that Reading serves as the main higher-order centre for significant parts of adjoining Districts, as well as some areas further afield. There is no indication that this is disputed by adjoining authorities. In fact there is a clear commitment in the strategies of adjacent authorities to the provision of retail development around Reading Borough that serves local shopping needs rather than those of the wider area.
34. Sites. There are a number of key sites that straddle the boundary with Wokingham Borough, including the Whiteknights Campus and the Berkshire Brewery. The information provided demonstrates that there is a consistency of approach between the authorities in dealing with these sites.
35. Major Landscape Features. The Thames Valley and Kennet and Holy Brook Meadows Major Landscape Features (MLF) identified in the SDPD adjoin adjacent local authority boundaries. Although such terminology is not used by adjoining authorities the landscape value of these areas is recognised in their adopted and emerging core strategies.
36. In summary, therefore, it is considered that due regard has been paid to cross boundary issues.
Development Management Policies
37. A number of the development management policies in the Plan are not specifically referred to in this report. This is because the report focuses on those parts of the DPD where there may be soundness issues.
Are the following development management policies in accordance with national guidance, in line with the CS, justified and likely to be effective?
DM1 Adaptation to Climate Change
38. The government’s intention of using the planning system to tackle climate change is emphasised in the National Planning Policy Framework. Policy CS1: Sustainable Construction and Design of the Core Strategy emphasises the Borough Council’s commitment to ensuring that new development is designed to take account of the effects of climate change. Policy DM1 of the SDPD provides detail on the Council’s approach and identifies a broad range of
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adaptation measures that need to be incorporated into new developments to ensure that they are well-equipped to deal with anticipated changes in the climate. These include appropriate orientation of buildings, detailed design of buildings to ensure that they have maximum resistance and resilience, suitable landscaping, and minimisation of the impact of surface water run-off. These constitute sensible adaptation measures and represent the type of approach envisaged in national policy and the CS.
39. As regards flexibility the wording of each bullet point in Policy DM1 with terms such as ‘maximise,’ ‘minimise,’ and ‘where appropriate,’ means that it is accepted that particular measures may not be appropriate in all cases. This will enable other factors, such as the viability and feasibility of schemes, to be taken into account and weighed by the Council when particular proposals are being considered. Consequently Policy DM1 is in accordance with national guidance, in line with the CS, justified and likely to be effective.
Policy DM2: Decentralised Energy
40. The government’s intention of using the planning system to tackle climate change is emphasised in the National Planning Policy Framework and decentralised energy supply is specifically referred to in paragraph 96. Policy CS1 of the Core Strategy emphasises the Borough Council’s commitment to ensuring that new development is designed to take account of the effects of climate change. Policy DM2 follows on from national guidance and the Core Strategy by providing clear guidance on the use of decentralised energy in larger developments.
41. At present the first paragraph of Policy DM2 is confusing as it is not clear how it relates to the following two paragraphs. However a minor change proposed by the Council makes it clear that the first paragraph only relates to the size of developments set out in the following two paragraphs (i.e. 20 and 10 dwellings respectively, or 1,000 sq m). It is considered that these threshold figures in the second and third paragraphs are justified in the evidence-base and realistic. They will ensure that above these levels of development careful consideration is given to the use of decentralised energy. There is sufficient flexibility in the wording to ensure that the policy is not unduly restrictive and that matters such as suitability and feasibility can be taken into account and weighed in the overall balance. Furthermore the policy is not prescriptive about technologies as it allows choice as to the type of decentralised energy to be used. Consequently Policy DM2 is in accordance with national guidance, in line with the CS, justified and likely to be effective.
Policy DM3: Infrastructure Planning
42. The National Planning Policy Framework indicates that local development frameworks should include as much detail as possible on planning obligations. In line with this Core Strategy Policy CS9: Infrastructure, Services, Resources and Amenities is an over-arching policy that makes it clear that appropriate infrastructure provision will be required in association with new development. Policy DM3 endeavours to elaborate on the approach inherent in national policy and the Core Strategy by prioritising the infrastructure provision required. The priorities identified are sensible and reflect the Council’s priorities for the Borough. The Community Infrastructure Levy Regulations do
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not seek to restrict the identification of such priorities.
43. There would appear to be little reason to delete reference to the provision of police service infrastructure given that development may give rise to the need for additional police infrastructure/accommodation. Clearly however, as with all cases, it would need to be clearly demonstrated why that provision is required and that the tests in national guidance have been met. As the monitoring of Section 106 agreements is likely to place an additional burden on the Council it is reasonable to require contributions under the terms of this policy.
44. It is recognised, unlike some of the other Development Management policies, that there is little flexibility in the wording of the policy. However it is likely that detailed negotiations will be required in all cases to determine what level of provision or contribution is justified. The supporting text recognises that it may not always be possible to mitigate all relevant impacts, for instance for reasons of viability. Consequently there is little doubt that the Council will be obliged to apply the policy flexibly, taking account of all material considerations. Consequently Policy DM3 is in accordance with national guidance, in line with the CS, justified and likely to be effective.
Policy DM4: Safeguarding Amenity
45. Paragraph 17 of the National Planning Policy Framework makes it clear that planning should always seek to secure a good standard of amenity for all existing and future occupants of land and buildings. Policy DM4 of the SDPD seeks to ensure that both existing and future occupiers of residential properties have reasonable living conditions. This is in line with core objective 2 of the Core Strategy which seeks to improve the quality of life for those living in the Borough. The policy makes it clear that account will be taken of the various listed criteria when the acceptability of new development is being assessed. Such an approach accords with good planning practice and will be invaluable tool in safeguarding and promoting a good standard of residential amenity.
46. The policy is based on the premise that planning judgements as to the impact of new development will be required. Consequently the policy is inherently flexible and any harmful impacts identified will have to be fully justified. It is considered that the wording of the policy addresses all those instances that are likely to arise, including the siting of new residential development close to existing employment areas and businesses. Consequently Policy DM4 is in accordance with national guidance, in line with the CS, justified and likely to be effective.
Policy DM5: Housing Mix
47. The National Planning Policy Framework in paragraph 159 encourages local authorities to plan for a mix of housing and a range of tenures that the local population is likely to need over the plan period. Policy CS15 of the CS seeks to secure a broad mix of dwellings as part of developments but does not specify what is meant by an appropriate mix. Policy DM5 is designed to provide additional guidance on this matter in accordance with government guidance and states that on sites of 10 or more dwellings outside the central
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area and defined district and local centres over 50% of dwellings will be 3 bedrooms or more and the majority of dwellings will be in the form of houses rather than flats.
48. The information in the Council’s Housing Mix Background paper indicates that the amount of small 1 and 2 bedroom units completed in recent years, along with those already planned, is expected to lead to a general shortfall of larger dwellings (3 bedroom or more) over the plan period. A dominance of flats in recent and planned developments is also identified. Such a problem is not uncommon elsewhere in the country. In the light of this it is not unreasonable for the Council to seek to re-balance housing supply by encouraging a good proportion of family housing within the Borough within new developments.
49. It is considered, however, that the current wording of Policy DM5 is too stringent. The discussion during the hearing indicated that the Council intended to apply this policy flexibly and that the policy was the starting point for discussion. In the light of this the insertion of the phrases ‘ the Council will seek to ensure that’ and ‘having regard to all other material considerations’ would introduce the requisite amount of flexibility. The reference to ‘Lifetime Homes’ standards should be similarly amended. As these matters do not affect the soundness of the plan they can be dealt with through the Council’s minor changes.
50. Consequently Policy DM5 is in accordance with national guidance, in line with the CS, justified and likely to be effective.
Policy DM6: Affordable housing
51. The National Planning Policy Framework indicates that the need for affordable housing should be identified and policies brought forward to address this need. On the basis of the material available, including the preliminary information from the updating of the housing need assessment in the Berkshire Strategic Housing Market Assessment, it is evident that there is a considerable need for affordable housing in the Borough. It is apparent that the Council is committed to addressing this need by ensuring that there are appropriate planning policies relating to affordable housing in their development plan documents. Policy CS16 specifies that on developments of 15 dwellings and above provision will be made for 50% of the total number of dwellings to be in the form of affordable housing. This Core Strategy policy was found sound on the basis of the evidence submitted at the time and is not for review as part of this examination
52. Policy DM6 of the SDPD deals with sites of less than 15 dwellings and has differential targets depending on the number of proposed dwellings (i.e. 30% provision on sites of 10-14 dwellings, 20% on sites of 5-9 and a financial contribution on sites of 1-4 dwellings to provide an equivalent of 10% elsewhere). The Framework does not contain a national minimum threshold for affordable housing although it recognises that policies should be sufficiently flexible to take account of changing market conditions over time. As it is anticipated that a sizeable proportion of new housing in the Borough will take place on sites of fewer than 15 dwellings provision in accordance with Policy DM6 would make a significant contribution towards meeting the local need for affordable housing.
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53. In arriving at the differential targets in Policy DM6 the Council carried out an in-house viability assessment in 2010 and 2011. This covered a wide range of schemes across the Borough in different economic circumstances. The assumptions and findings were broadly endorsed by an independent firm of chartered surveyors in 2011. On the basis of the viability assessment that has been carried out and the verification exercise it is reasonable to conclude that the differential targets in Policy DM6 are reasonable and soundly-based.
54. As regards viability considerations on particular sites, Policy DM6 makes it clear that this will be taken into account in determining an appropriate level of affordable housing provision. Notwithstanding the evidence justifying the differential targets the Council accept that market conditions and abnormal costs may mean that the targets cannot be achieved on particular sites. It was explained at the hearings that when specific proposals are being considered the Council’s Valuation Section is involved in analysing the material submitted on a site and testing the assumptions. As part of the process meetings between the parties involved are usually held when the various issues in question are discussed. It is understood that in the order of 90% of cases are satisfactorily resolved and may involve the Council in reducing or waiving targets on particular sites. In cases where arbitration is required or specific expertise is involved the Council has the option of employing independent experts as advisors. Consequently it is considered that Policy DM6, having regard to the way it is operated by the Council, contains an appropriate level of flexibility to deal with changes in the market or difficulties on particular sites.
55. The Framework indicates that planning authorities should identify the size, type tenure and range of housing that is required in particular locations, reflecting local demand. The Berkshire Strategic Housing Market Assessment and the Core Strategy make it clear that the priority for affordable housing within the area is for social rented accommodation. The South East Plan indicates in Policy H3 that 25% of all new housing in the Region should be social rented accommodation with 10% intermediate affordable housing. This translates into a split of 70% social rented and 30% intermediate. Given this background it is legitimate for Policy DM6 to seek a similar 70/30 split. Furthermore it is clear from the policy wording that these figures are not set in stone. The policy recognises that account will be taken of current evidence of identified needs in determining the type of units to be provided. Consequently there is sufficient in-built flexibility in the policy to ensure that it can be effectively applied.
56. Consequently Policy DM6 is in accordance with national guidance, in line with the CS, justified and likely to be effective.
Policy DM10: Private and Communal Outdoor space
57. Although the National Planning Policy Framework does not contain specific amenity space standards it emphasises the value of open space in creating well-planned and sustainable communities. The need to provide a good standard of amenity for existing and future occupiers is also endorsed in the Framework. Policy DM10 is in line with this approach giving general guidance on the sorts of private and communal open space that will be required and how they should be designed and located. As specific standards are not set out
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in the policy there is appropriate flexibility to take account of the particular characteristics of the development and the location.
58. Consequently Policy DM10 is in accordance with national guidance, in line with the CS, justified and likely to be effective.
DM11: Development of Private Residential Gardens
59. The National Planning Policy Framework in paragraph 53 states that local planning authorities should consider the case for setting out policies to resist inappropriate development of residential gardens, for example where development would cause harm to the local area.
60. It is evident that the development of garden land has been a significant local issue in Reading over recent years and that a number of permitted schemes have impacted negatively on the local environment. Consequently Policy DM11, which carefully spells out those factors to be taken into account in assessing such development, is to be welcomed. The criteria are considered to be sensible and comprehensive and the policy will be a vital development management tool over the coming years. A criteria-based policy rather than a blanket ban is considered the best way forward. A blanket prohibition would not sit comfortably with the Council’s approach to housing land supply, a significant component of which is the development of small sites within the urban area. In the past such sites have also mainly provided family-sized accommodation, a high priority for the area. As there is a clear need for family-sized accommodation in the Borough the emphasis in the policy on the provision of family-sized housing is justified. Given that the policy allows acceptable development to occur it is inherently flexible.
61. Policy DM11, therefore, is in accordance with national guidance, justified and likely to be effective.
DM13 Vitality and Viability of smaller centres
62. This policy endeavours, in line with the National Planning Policy Framework, to safeguard the retail nature of existing smaller centres in the Borough. This approach is consistent with the objectives of Policies CS26 and CS27 of the CS, which seek to maintain the vitality and viability of defined centres. In common with established good practice it defines key retail frontages and the proportion of non-A1 uses to be allowed, provides guidance on the proportion of A5 takeaways to be allowed, and seeks to ensure no net loss of centre uses to non-centre uses at ground floor level. Furthermore it encourages the provision of centre uses on the ground floor in all new development within or adjacent to centres. These measures are considered to be well-thought out, sensible and based on robust survey work. They should make a significant contribution in safeguarding and enhancing the role of the smaller retail centres whose success is a vital ingredient of the Council’s plans for the Borough.
63. The Meadway, defined as a district centre in CS Policy CS26, is an ageing shopping precinct that is experiencing high levels of vacancies both within the ground floor units and in the upstairs residential units. Consequently there are strong grounds for its redevelopment to bring it up to the standards and
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quality expected of a modern-day district centre. Those parts of the policy of relevance to its redevelopment are worded so as to ensure that there is an appropriate mix of centre uses. In the meantime in common with all other smaller centres there is a need to ensure that its vitality and viability is maintained and wherever possible enhanced. It is not considered that the various policy ingredients of Policy DM13 are unduly onerous as they relate to The Meadway. For instance seeking to ensure that the proportion of A1 uses does not fall below 50% within the Key Frontage is far from overly harsh and will not prevent the provision of a wide range of facilities. To add further flexibility the Council made it clear during the hearings that vacant retail units will count towards the proportion of A1 uses, if A1 is the permitted use. This is to be clarified in the Council’s minor wording changes as is the applicability of the policy to comprehensive redevelopment schemes.
64. Consequently Policy DM13 is in accordance with national guidance, in line with the CS, justified and likely to be effective.
DM15: Protection of Leisure Facilities and Public Houses
65. This policy endeavours to ensure that local communities have ready access to leisure facilities, including public houses. Such an approach accords with government guidance as expressed in paragraph 70 of the National Planning Policy Framework and Core Strategy objectives 2 and 6. As leisure uses are often of crucial importance to the health and diversity of district and local centres it is not surprising that the policy is more stringent in this regard. Notwithstanding this the Council accepted at the hearing that in applying the policy account would be taken of any detrimental impact on the centre as a whole, for instance the harm to vitality and viability brought about the long- term vacancy of a facility. This is to be clarified in the Council’s minor wording changes.
66. Consequently Policy DM15 is in accordance with national guidance, in line with the CS, justified and likely to be effective.
DM16: Provision of Open Space
67. Paragraph 73 of the National Planning Policy Framework states that access to high quality open spaces and opportunities for sport and recreation can make an important contribution to the health and well-being of communities. CS Policy CS29: Provision of Open Space specifies that all new development should make provision for its open space needs through appropriate on or off- site provision or contributions.
68. Policy DM16 builds on Policy CS29 and, amongst other things, identifies local open space standards to guide provision and in broad terms highlights where there are existing open space deficiencies within the Borough. These elements are derived from the work carried out to inform the Council’s Open Spaces Strategy (2007). The local open space standards have been arrived at after careful consideration of alternatives, and will be a useful tool in guiding provision. As regards the identification of general areas of open space deficiency across the Borough it is considered that this is also based on a reasonable analysis of the available information. Notwithstanding this there will still be a need to demonstrate in relation to specific proposals across the
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Borough that due account is taken of existing and future open space provision.
69. Policy DM16, therefore, is in accordance with national guidance, in line with the CS, justified and likely to be effective.
DM17: Green Network
70. Paragraph 114 of the National Planning Policy Framework makes it clear that local plans should plan positively for the creation, protection, enhancement and management of networks of biodiversity and green infrastructure. Policy CS36 specifies that features of biodiversity and geological interest will be protected and that wildlife links will be safeguarded and enhanced. Policy DM17 is in line with this overall approach as it endeavours to create a Green Network across the Borough, linking together ecologically important areas.
71. The Green Links shown on the Proposals Map, which include both existing and potential links, have been established as a result of a specific desk-top study carried out by the Thames Valley Environmental Records Centre. Consequently they are based on a reasonable evidence base and justified. Notwithstanding this it is considered that as the potential links are only indicative and are meant to be interpreted flexibly there is a need to distinguish them from existing links on the Proposals Map. The distinction between the two would also need to be explained in the text as well as the different approaches to development that each would entail. The text should also make it clear that the green links do not mean or imply public access. As these matters do not relate to soundness such changes would be encompassed within the Council’s minor changes.
72. Policy DM17, therefore, is in accordance with national guidance, in line with the CS, justified and likely to be effective.
Is there an effective policy framework for dealing with Heritage Assets?
73. There are no specific policies relating to Heritage Assets in the SDPD. Although there were policies relating to listed buildings, conservation areas and archaeology in the Pre-Submission Draft (February 2010), these were deleted from the Revised Pre-Submission Draft (February 2011) as a result of the publication of Planning Policy Statement 5 (PPS5); Planning for the Historic Environment in 2010.
74. It is not considered that there would be a policy vacuum as regards the treatment of Heritage Assets in the Borough. The National Planning Policy Framework contains firm, detailed guidance on conserving and enhancing the historic environment. In addition Policy CS33: Protection and Enhancement of the Historic Environment of the Council’s Core Strategy covers all aspects of the historic environment. This policy makes it clear that historic features and areas of historic importance and other elements of the historic environment including their settings, will be protected and where appropriate enhanced. Furthermore there is specific guidance as to how development proposals affecting historic assets will be assessed. The text relating to Heritage Assets in the SDPD contains a comprehensive explanation of the Council’s approach and will supplement Policy CS33. The combination of national and local policy will ensure appropriate protection and enhancement of the historic
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environment. Consequently there is an effective policy framework for dealing with Heritage Assets.
Site Specific Policies
75. A number of the site specific policies in the Plan are not specifically referred to in this report. This is because the report focuses on those parts of the DPD where there may be soundness issues.
Has the process involved in selecting sites been robust?
76. The Council’s approach to selecting sites, whilst undertaken against a background of targets, has essentially involved considering a range of alternatives for each site then selecting a preferred option, having regard to the sustainability appraisal. It is considered that this approach has been effective in identifying the most appropriate use for sites and has been robust.
Are the various site specific policies in accordance with national guidance, in line with the CS, justified and likely to be effective?
SA2a: Worton Grange
77. Policy SA2a allows for a mixed use scheme on the Worton Grange site or warehousing. It is considered that both these schemes would benefit South Reading, albeit in different ways. The mixed use scheme would improve the local environment, enable the provision of better links with Whitley, provide affordable housing, and secure community uses and additional small-scale retail and leisure uses to meet local needs. The warehousing would provide additional much-needed jobs within Reading’s greatest concentration of deprivation. Consequently both approaches have merit and the Council is justified in advancing these alternatives.
78. Based on the discussion at the hearing and the material submitted, it is considered that a mixed use scheme on the site would appear to be more likely than a warehousing scheme. Given the wide scope that exists within the policy wording for a mixed use scheme there is little reason to believe that a worthwhile scheme could not be drawn up for the site and implemented in the short to medium term.
79. The owners of the site argue that Policy SA2a should not rule out the possibility of a large food-store being provided as part of a mixed use scheme. To this end it is contended for the owners that the policy should delete reference to a ‘limited’ amount of retail use.
80. The retail policies in the CS (Policies CS25 and CS26) establish the Council’s approach to the scale and distribution of retail development across the Borough. Major retail development is to be concentrated in the centre of Reading with development of a lesser scale and commensurate with their size, focused on identified District, Major Local, and Local, Centres. No provision is made in the CS for the creation of additional centres or out-of-centre food stores within South Reading, or anywhere else in the Borough for that matter. Such an approach is broadly in line with the guidance in the National Planning Policy Framework which seeks to ensure the vitality of town centres and the identification of a network and hierarchy of centres.
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81. Policy SA3 of the SDPD re-affirms the approach inherent in the CS by making it clear that the main focus for additional retail, leisure and culture uses in South Reading will be in or as an extension to the Whitley District Centre. When taken together with Policy SA2a it is clear that the amount of further retail development that will be allowed on the strategic sites will be limited to that required to serve the new housing, with a recognition that account should also be taken of any currently underserved areas.
82. In summary, therefore, the strategy for retail development across the Borough and within South Reading is already set in the CS. The examination of the SDPD is not the appropriate place for a re-examination of this strategy. The time to revisit the overall approach to retail development, and the associated evidence-base, is when the CS is reviewed.
83. Clearly changing Policy SA2a to delete reference to a limited amount of retail development in itself appears fairly innocuous. However it removes an important component of the policy and implies that any large-scale retail development at Worton Grange should be determined on its merits having regard to national policy. Clearly this would remove the local dimension that is inherent in the CS retail policies and undermine the Council’s approach to retail development across the Borough. Consequently the current wording of Policy SA2a is justified and there are reasonable grounds for believing that a mixed use scheme will be achievable.
84. In summary Policy SA2a is in accordance with national policy, in line with the Core Strategy, justified and likely to be effective.
SA2b: Berkshire Brewery
85. During the examination work commenced on the construction of a large distribution centre for Tesco on the main Berkshire Brewery site with a completion date later this year. As one of the policy options for the site is B8 use the terms of the policy have been met in this regard. The employment that will be generated by the development is clearly in line with the Council’s objectives for South Reading contained in the Core Strategy. No doubt when the plan is adopted the Council will consider whether the main site should be shown as a commitment rather than an allocation.
86. As regards the remainder of the site (the former bottling plant, known as the R13 site) the extant permission for office development is in line with the terms of Policy SA2b. In the event that such development does not materialise the policy allows for a wide range of other employment generating uses on the site. The allocation of this part of this site for main town centre uses, including retail and leisure, would not be in line with the CS which seeks to steer such uses to identified centres
87. In summary Policy SA2b is in line with the Core Strategy and is both justified and effective.
SA2c: Land to the North of Manor Farm Road
88. The Council has established through the Employment Land Review Stage 2 Site Specific Analysis (2010), that the land north of Manor Farm Road is not required for ongoing employment use. Consequently it is clear that the area
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offers an opportunity for a comprehensive residential-led development, with support for proposals that maintain and enhance the vitality and viability of the Whitley District Centre. This will bring a number of benefits including:
more housing choice;
the provision of better linkages between the recent housing development at Kennet Island and the established residential area of Whitley to the east;
convenient access to better services and facilities for the residents of Kennet Island and the wider area;
a reduction in potential tensions between different land uses in the area; and
improved social cohesion within the South Reading community.
89. As with any area with a multitude of ownerships it is crucial to ensure that development on the land North of Manor Farm Road takes place in a well- planned manner rather than piecemeal. This is particularly important when the nature of the area is changing from a predominantly employment area to one that is primarily given over to housing. Consequently the general thrust of Criterion (i) is understandable. However it was accepted by the Council at the hearings that the policy and the supporting footnote would be changed to make it clear that judgements, as to acceptability of the development of particular sites within the area, will be taken at application stage. These minor wording changes will ensure that there is sufficient flexibility in the policy to allow sites to come forward provided a good quality living environment is secured and that there is a satisfactory relationship with adjoining sites. It is accepted that there is a reasonable prospect of delivery of the various sites over the plan period given that the Council owns a number of them and others are being are promoted through the SDPD process.
90. In summary it is evident that the development of the land North of Manor Farm Road as envisaged in Policy SA2c has much to commend it, is appropriately justified, and stands a reasonable chance of delivery. Furthermore it is in line with the CS objectives for South Reading.
Policy SA5: Park Lane Primary School, The Laurels and Downing Road
91. The primary objective of this allocation is to enable the provision of a new single site school and various community facilities on one site. Funding for the new school depends on the realisation of land values from the redevelopment of surplus educational sites, including the Downing Road Playing Field for residential use.
92. The Downing Road Playing Field is currently used as a school playing field and very occasionally for community use. Although there is no public access paragraph 74 of the National Planning Policy Framework makes it clear that existing open space and sports and recreational land, including playing fields, should not be built on unless it has been clearly shown that it is surplus to requirements or alternative provision is to be made. Policy CS28: Loss of Open
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Space of the CS is broadly in line with this approach.
93. It is considered that the evidence submitted by the Council does not clearly establish that the playing field is surplus to requirements in terms of national planning policy. In particular there is little in the evidence-base to indicate that there is an excess of playing field provision in this particular area. In fact the reverse would seem to be true as the Council state that there is some demand locally for additional pitches, albeit of an unspecified variety. Similarly there is no specific information provided to indicate that replacement playing field provision is planned. It is recognised that the size of the Downing Road Playing Fields is likely to constrain the type and amount of sport pitches that could be accommodated. However without detailed information as to the sort of pitches required in the area it is unreasonable to conclude that the playing field has no potential value.
94. Consequently Policy SA5, which allocates the playing field for residential development, without first demonstrating that it is surplus to the open space requirements of the local area, is unsound. It is not justified by the evidence and is contrary to the objectives of Policy CS28 and national planning policy relating to open space.
95. In response to the concerns I raised about this matter the Council has made significant changes to Policy SA5 and the supporting text. These changes make it clear that if the development of the playing field is required to support the scheme it will only be released for development if the loss of the open space is justified under relevant national and local policy. Consequently there is no automatic presumption in favour of residential development on the field. These changes are set out in MM2 and MM5 and address my concerns about this matter.
96. As the housing requirement for the area is exceeded there is no need to identify other housing sites to make up for the 45-55 dwellings that may be lost if the Downing Road playing field is not developed. The housing figures and trajectory are to be amended to take account of this change (MM6).
97. Policy SA5, therefore, provided it is amended in accordance with the relevant Main Modifications, is in accordance with national policy, in line with the Core Strategy, justified and likely to be effective.
SA6: Whiteknights Campus, University of Reading
98. Policy SA6 recognises that the Whiteknights Campus will continue to be the focus for the development of the University of Reading. This is in line with the objectives of the Core Strategy. The policy acknowledges that a range of uses, including additional accommodation, infrastructure and services and sports and leisure facilities, may be brought forward and will be expected to satisfy various criteria. The identified criteria do not appear to be unduly onerous and are unlikely to fetter the future development of the University. Consequently the policy is reasonably worded and is likely to prove effective in securing the University’s future development. During the hearings the Council agreed some minor wording changes to the policy that recognises the University’s international importance and that additional staff accommodation may be required.
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99. As to the green links and landscape designations that affect the Whiteknights Campus these matters are dealt with elsewhere in the report, under Policies DM17 and SA17.
100. In summary Policy SA6 is in line with the Core Strategy, justified and likely to be effective.
SA7: Crescent Road Campus (excludes adjacent playing field)
101. Paragraph 72 of the National Planning Policy Framework makes it clear that local planning authorities should give great weight to the need to create new schools to meet the needs of communities. Policy CS31 of the Core Strategy indicates that new schools will be acceptable in locations where there is a choice of means of travel.
102. The Crescent Road campus, which is in an accessible urban location, was formerly used by Thames Valley University but is now vacant. From the material submitted and the discussion at the hearing it is evident that plans are now well advanced to use part of this campus as the proposed Reading University Technical College (UTC), providing vocational education for 14-19 year olds. The Department for Education (DfE), and Partnership for Schools, is committed to establishing the UTC at Crescent Road. In October 2011 the Secretary of State for Education approved an application to enter the pre- opening stage which should lead to a confirmed funding agreement for the Reading UTC in 2012, and the possibility of its opening later in the year. Negotiations between the DfE and the owners on the acquisition of the land were ongoing at the time of the hearings.
103. Although Policy SA7 indicates a preference for the continued use of the campus for Further and Higher Education (FHE) other education uses are not ruled out, if the site is no longer required for FHE. The policy also allows for residential development in the event that the site is not needed for any form of education. Consequently the policy has a considerable amount of in-built flexibility that would enable educational uses, including the Reading UTC, to proceed. As it appears that not all the site would be required for the UTC it may be the case that some of the campus is available for residential development. Again the policy is sufficiently flexible to accommodate such an eventuality provided convincing reasons are advanced. Given the substantial progress that has been made towards securing a UTC on the site there are strong grounds for believing that the policy will be successfully implemented.
104. Policy SA7, therefore, is in accordance with national policy, in line with the Core Strategy, justified and likely to be effective.
Policy SA8: Land at Kentwood Hill
105. The land between Kentwood Hill and Armour Hill comprises allotments, unused and overgrown land, and a playing field. Consequently with the exception of the allocated site, which is in use as a builders’ yard, the area is predominantly undeveloped and constitutes one of the largest remaining open areas within Tilehurst. The Council believes that as the builders’ yard use on the allocated site has now become established, residential use of the site would be difficult to resist. Whilst this argument is not without merit there are
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other relevant material considerations.
106. Both the site allocated in the SDPD and the enlarged site advanced by the site owner would result in piecemeal and uncoordinated development that is not well related to the surroundings. This would be contrary to the National Planning Policy Framework which makes it clear in paragraphs 16 and 17 that local plans should set out a positive vision for the future of the area. At present the builders’ yard, which it is understood does not cause significant problems for the neighbourhood, is set behind green corrugated iron fencing and appears relatively inconspicuous from the surrounding area. Set amidst unused/overgrown land and allotments it does not appear unduly intrusive or out of place. In contrast a housing scheme on the allocated site would be much more prominent and appear stark and incongruous given the open nature of the surrounding land. Consequently the existing arrangement of land uses is to be preferred in terms of their environmental impact.
107. The designation of the allotments area as open space (excluding the established builder’s yard) on the Proposals Map will provide clear policy protection for this area under the terms of Policy SA16. The Council may wish in the future to consider a more comprehensive approach that deals with all the land between Kentwood Hill and Armour Hill (including the builder’s yard, unused land, the allotments and playing field) having regard to the needs of the area. However this is not matter that requires endorsement in the DPD given that it has been found that the current disposition of land uses in the area is acceptable.
108. In summary as the allocation of Land at Kentwood Hill within Policy SA8 is not justified by the evidence and contrary to national planning policy it should be deleted. The deletion is set out in MM3, MM4 and MM7 and addresses my concerns about this matter.
109. As the housing requirement for the area is exceeded there is no need to identify other housing sites to make up for the 10-16 dwellings lost as a result of the deletion of the land at Kentwood Hill. The housing figures and trajectory are to be amended to take account of this change (MM6).
SA8f: Bath Road Reservoir, Bath Road
110. This former reservoir lies within an established residential area. Consequently its development for housing would be in keeping with the prevailing land use in the local area. Policy SA8f allows for residential development subject to the satisfaction of a number of criteria. These safeguards are derived from a number of sources including the Inspector’s findings from the recent appeal, site factors, and the representations made by interested parties during the preparation of the SDPD. These safeguards are comprehensive in nature and realistic and will ensure that this sensitive site is developed appropriately.
111. The flexibility in the wording of the policy, for instance with regard to the use of the Grade II listed water tower, will ensure that matters such as feasibility and viability are taken into account. Notwithstanding this in order to safeguard the future of the water tower it is reasonable for it to be linked into the comprehensive development of the site. It is evident that the figure of ‘up to 80 dwellings’ on the site is for guidance purposes only and that scheme
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density will be judged on its merits, having regard to other relevant planning policies, rather than by adherence to a rigid formula. Consequently it is considered that the policy is justified and likely to prove effective. Given the specific nature of Policy SA8f, and the progress that has been made in drawing up a scheme in accordance with the policy requirements, there is insufficient justification for drawing up a specific planning brief at this time.
112. In summary Policy SA8f is justified and likely to be effective.
SA8g: Part of former Battle Hospital, Portman Road
113. The development of this site for residential purposes will complete the redevelopment of the former Battle Hospital as a large area of new housing. Consequently it is an appropriate land use. The criteria to be satisfied in connection with its development of this site and specified in Policy SA8g are reasonable having regard to the nature of the site and the surroundings. There is also in-built flexibility in the policy. There is no absolute requirement for the provision of live/work units whilst the policy does not specify that the site needs to be developed comprehensively. Furthermore it is evident that the figure of ‘45-95 dwellings (net gain)’ on the site is for guidance purposes only and that the density of the scheme will be judged on its merits having regard to other relevant planning policies. In summary, therefore, the policy is adequately justified and likely to secure the appropriate development of the site.
SA8i: Lowfield Road
114. The residential allocation of this site is understandable given past usage, the location of the site, and the nature of the surroundings. A suitably designed scheme that pays regard to the adjacent open area would make a positive contribution to the local area. Proposals for alternative uses, including an expansion to the cemetery, would not be ruled out given that the loss of the proposed 21-34 dwellings would not have significant implications for the housing figures. As a result it is considered that the policy is justified and effective.
SA8j: Napier Court, Napier Road
115. This site is within a sustainable location close to the centre of Reading, and across the road from the King’s Meadow. The adjacent site to the west was allocated for residential and/or offices in the RCAAP. Having regard to these factors, and the recent satisfactory resolution of flood risk issues, the site is well-suited to residential development. The criteria to be satisfied in connection with the development of this site and specified in Policy SA8j are reasonable having regard to the nature of the site and the surroundings. There is also in-built flexibility in the policy as it lists those factors that should be taken account of rather than specifying them as requirements. It is evident that the figure of ‘200-250 dwellings’ on the site is for guidance purposes only and that the density of the scheme will be judged on its merits having regard to other relevant planning policies. As regards building heights it is considered that this is best dealt with at the planning application when the overall merits of a particular scheme can be assessed. In summary, therefore, the policy is adequately justified and likely to secure the appropriate development of the
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site.
SA9b Elvian School, Bath Road
116. This former school site is within an accessible suburban location and is well suited to redevelopment for a mixed use development, including housing. Policy SA9b allows for residential and education or alternative community use on the part of the site excluding the playing field. Consequently there is flexibility within the policy should there no longer be a need for a new school building on the site.
117. Policy SA9b makes it clear that the intensification of sporting use on the playing field may be appropriate as long as any loss of playing fields is outweighed by sport and recreation improvement. This approach is in accordance with paragraph 74 of the National Planning Policy Framework and Policy CS28 of the Core Strategy and will ensure that due regard to paid to the recreational and sporting needs of the area before decisions are taken on any development of the playing fields. The other criteria, including the need to demonstrate that there will be no material increase in traffic along Bath Road, are reasonable given the nature of the site and its surroundings. Notwithstanding this it is evident that the Council will need to take account of viability considerations in any discussions about the development of the site.
118. Policy SA9b, therefore, is in accordance with national policy, in line with the Core Strategy, justified and likely to be effective.
SA11: Settlement boundary
119. Policy CS6 states that no development will be permitted outside the settlement boundary as defined on the Proposal Map. This approach, which is in accordance with established planning practice, clarifies where development will and will not be allowed. In particular it will ensure that, in accordance with national planning policy, brownfield land will continue to be the main focus for future development.
120. Policy SA11 of the SDPD identifies the settlement boundary on the Proposals Map. Essentially the approach adopted by the Council in defining the settlement boundary involves identifying those areas that are functionally part of the settlement and those that are more rural in character. On the basis of my site visits this distinction has been consistently applied by the Council and therefore the settlement boundary is soundly based and justified. In essence the only sizeable areas of land that lie outside the settlement boundary are the farmland and flood meadows next to the River Thames, and the Kennet Meadows and the grassland to the south (which includes the Burghfield site). Each of these areas clearly has a more rural character and is not functionally part of the settlement.
121. Policy SA11, therefore, is in accordance with national policy, in line with the Core Strategy, justified and likely to be effective.
SA12: Core Employment Areas
122. The Core Strategy makes it clear that the employment areas to be safeguarded from other development (i.e. the Core Employment Areas) will be
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defined in the SDPD. The National Planning Policy Framework indicates that the likely prospect of future employment use is a key aspect of deciding which areas should be retained in employment use.
123. The Council’s approach is in line with what is advocated in the Framework. Specifically the Council has identified the Core Employment Areas (CEAs) through the Employment Land Review Stage 2 Site Specific Analysis (2010). This Analysis is a detailed and thorough assessment of each employment area within the Borough against a series of criteria including the quality of the environment, access, market conditions, ownership, constraints, accessibility and policy considerations. Consequently the 13 CEAs identified in the SDPD are founded on a robust analysis that takes account of all relevant factors, including the prospect of future employment use, and are therefore justified. As these areas are crucial to the future of Reading’s economic growth the firmly worded nature of Policy CS11 is understandable. As part of the adopted CS, Policy CS11 it is not subject to the current examination.
124. There is insufficient justification to allow the establishment of car dealerships within CEAs. There are various other opportunities for such uses around the Borough, including sites on arterial routes, town centre fringe locations, and within employment areas not identified as CEAs.
125. In summary the Council’s approach to the Core Employment Areas in the SDPD is in accordance with national policy, in line with the Core Strategy, justified and likely to be effective.
SA15: District and Local Centres
126. In accordance with the guidance in the National Planning Policy Framework, District and Local Centres are identified and listed in Policy CS26 of the Core Strategy. Essentially Policy SA15 defines the boundaries of these centres on the Proposals Map. On the basis of the material submitted and my site visits these boundaries have been appropriately drawn. The relatively generous centre boundaries defined ensures the inclusion of all those uses that contribute to a centre’s health. The wider boundaries will also maximise the opportunities for identifying sequentially preferable sites when applying the sequential test set out in the Framework.
127. Policy SA15 recognises that certain centres, namely The Meadway and the Whitley District Centres and the Dee Park Local Centre, will be the main focus for intensification, change and additional community facilities. These centres are located within some of the areas of greatest deprivation within the Borough and their improvement will enhance social inclusion within the Borough in accordance with Policy CS3. Such an approach is consistent with the Framework which encourages a positive approach in tackling locations of deprivation.
128. Policy SA15, therefore, is found to be in accordance with national policy, in line with the Core Strategy, justified and likely to be effective.
SA16: Public and Strategic Open Space
129. Paragraph 73 of the National Planning Policy Framework states that access to high quality open spaces and opportunities for sport and recreation can make
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an important contribution to the health and well-being of communities. Policy CS28 of the CS is a general policy designed to prevent the loss of any open space in the Borough, whether public or private, unless exceptional circumstances are demonstrated. Amongst other things Policy CS28 could be used to prevent the loss of playing fields, be they in public or private ownership. The supporting text to Policy CS28 indicates that areas of important public open space in the Borough and the boundaries of the Strategic Open Space at the Kennet and Thameside Meadows will be identified in the SDPD. Policy SA16 of the SDPD endeavours to fulfil this requirement and identify such areas on the Proposals Map.
130. On the basis of my site visits the boundaries that have been defined for the Kennet and Thameside Meadows appear to be soundly based. In particular due account has been taken of physical features and natural boundaries, existing land use and local character. As regards the identification of the important areas of public open space the Council has undertaken a thorough assessment of all available land, including allotments. This has resulted in the identification of a large number of areas to be protected under the terms of Policy SA16. Although areas less than 0.5ha and school playing fields have not been included these remain protected under the terms of Policy CS28. Consequently Policy SA16 fulfils the requirements of Policy CS28 and is adequately justified.
131. Policy SA16, therefore, is in accordance with national policy, in line with the Core Strategy, justified and likely to be effective.
SA17 Major Landscape Features
132. Paragraph 109 of the National Planning Policy Framework indicates that valued landscapes should be protected and enhanced. Policy CS37 of the Core Strategy broadly identifies the Major Landscape Features of importance within the Borough. These are the Thames Valley, the Kennet and Holy Brook Meadows, The West Reading wooded ridgeline, the East Reading wooded ridgeline, and the North Reading dry valleys.
133. Policy SA17 of the SDPD defines the detailed boundaries of the Major Landscape Features on the Proposals Map. The methodology used in defining these boundaries is explained in the Council’s Landscape Background Paper. Essentially boundaries are defined by reference to particular physical features. In the case of the Thames Valley and Kennet and Holy Brook Meadows it is the flood plains of the watercourses. The other three features have been defined using topographical mapping, with the North Reading dry valleys including the valley sides and bottom, and the East and West Reading Ridgelines being the area over the 75m contour.
134. For the most part the detailed boundaries of the Major Landscape Features have been defined in accordance with these criteria and are therefore justified in terms of the evidence base. However there are a couple of instances where the boundaries are not consistent with the methodology specified above. In particular:
i. The Kennet and Holy Brook Meadows. The land south of Island Road, which is clearly raised out of the floodplain, does not match the reasoning for inclusion within the Kennet and Holy Brook
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Meadows Major Landscape Feature. Consequently the Proposals Map should be revised to exclude the land south of Island Road from this Major Landscape Feature. ii. The East Reading wooded ridgeline. The Whiteknights Campus north of Pepper Lane, which lies below the 75m contour, does not match the reasoning for inclusion within the East Reading wooded ridgeline Major Landscape Feature. In view of this the Proposals Map should be revised to exclude the Whiteknights Campus from this Major Landscape Feature.
135. Consequently the inclusion of these two areas within the Major Landscape Features is not justified by the evidence. Unless the Proposals Map is amended to exclude these areas Policy SA17 is unsound. The exclusion of these areas from the Major Landscape Features is set out in MM8 and MM9. These modifications address my concerns about this matter.
136. Policy SA17, therefore, provided it is amended in accordance with the relevant Main Modifications, is in accordance with national policy, in line with the Core Strategy, justified and likely to be effective.
Is the approach to particular sites and areas that are not allocated justified?
Burghfield site, Island Road (Cemex)
137. Cemex’s Burghfield site is not allocated for development in the SDPD. It is shown as lying outside the settlement boundary and within the Kennet and Holy Brook Meadows Major Landscape Feature (MLF). Elsewhere in the report it is recommended that the site remains outside the settlement boundary but is excluded from the MLF.
138. The owners of the site argue that the whole of the site should be allocated for employment development, specifically a large distribution centre, whilst a small part of the site should be allocated for a concrete batching plant.
139. An important component of the evidence base for future employment land provision is the Employment Land Review 2006. The Review found there to be no need for any additional employment land in the Borough over and above existing permissions, suggesting instead that there should be a managed loss of industrial and warehousing floor-space. This was the basis for the employment policies in the Core Strategy. Consequently no additional employment sites are identified in the SDPD with the focus on retaining identified Core Employment Areas (Policy SA12) to meet the area’s employment needs. Although certain regeneration sites are identified for employment use, such as the Berkshire Brewery and Worton Grange sites, these were previously in use for employment.
140. The allocation of the Burghfield site for a distribution centre does not sit comfortably against this policy background. It is considered that the examination of the SDPD is not the appropriate place for a re-examination of the overall strategy for employment development across the Borough. The time to revisit the approach to employment development is when the CS is reviewed over the next couple of years. Clearly the material produced for the
- 26 - Reading Borough Council Sites & Detailed Policies DPD, Inspector’s Report September 2012
owners of the site relating to the need for an additional site for a large distribution depot in the Borough will need to be taken into account by the Council in the CS review. As regards the concrete batching plant there are a number of areas of existing employment land in the Borough that would appear suitable for such a use. These areas need to be examined to establish whether they are suitable before additional land for general industrial development is released. If it is found that there is no suitable accommodation available no doubt this will be given weight by the Council if faced with an application for a concrete batching plant on the Burghfield land.
141. For these reasons the Council is justified in not allocating the Burghfield site for development.
White Knight Laundry
142. The main reason that this site is not allocated for development is because of likely flood risk. The Environment Agency’s 2010 flood map indicates that about 65% of the site is within Flood Zone 2, whilst 35% is in Flood Zone 3. As there are sufficient alternative sites at low flood risk to meet housing need in Reading, and no other overriding need for the development of the site, it fails the sequential test. Consequently as the allocation of the land would be contrary to local and national policy on flood risk the Council is fully justified in its approach. Notwithstanding this the option is open for any applicant to submit a Flood Risk Assessment to demonstrate that the site can be developed safely without increasing flood risk.
Kennetside Area
143. There are several sites within the Kennetside Area that are likely to be subject to change and re-development during the plan period. However it is considered that the main issues that are likely to arise with their development, such as the impact on local character, residential amenity, flood risk and biodiversity, can be addressed through the array of development plan policies. As a result there is insufficient justification for a specific policy covering the area.
Other Matters
144. A wide range of matters were raised in the representations and at the hearings that do not relate to the soundness of the plan. In many cases they constitute improvements to the plan, particularly in terms of the clarity and wording of individual policies and the supporting text. In response the Council proposed various minor changes, many of them derived from representors’ suggestions.
145. Having considered all the other points raised, no further Main Modifications are required to ensure that the plan is sound within the terms of the National Planning Policy Framework.
Legal Requirements 146. Several parties expressed concern about the public consultation undertaken by the Council in bringing forward the SDPD. As the requirements of the Statement of Community Involvement have been met there is no basis to question the legal requirements in this regard. Concerns were also expressed
- 27 - Reading Borough Council Sites & Detailed Policies DPD, Inspector’s Report September 2012
about the Council’s interpretation and application of policies in the CS and the Reading Central Area Action Plan. However this is not a matter for consideration as part of this examination.
147. My examination of the compliance of the Reading Sites and Detailed Policies DPD with the legal requirements is summarised in the table below. I conclude that the DPD meets them all.
LEGAL REQUIREMENTS
Local Development The Reading Sites and Detailed Policies DPD is Scheme (LDS) identified within the approved LDS (March 2011) which sets out an expected adoption date of March 2012. The DPD’s content and timing are generally compliant with the LDS. Statement of Community The SCI was adopted in 2006 and consultation has Involvement (SCI) and been compliant with the requirements therein, relevant regulations including the consultation on the proposed Main Modifications. Sustainability Appraisal SA has been carried out and is adequate. (SA) Appropriate Assessment The Screening Report demonstrates why an AA is (AA) not necessary. National Policy The DPD complies with national policy except where indicated and main modifications are recommended. Regional Strategy (RS) The DPD is in general conformity with the RS.
Sustainable Community Satisfactory regard has been paid to the SCS. Strategy (SCS) 2004 Act and Regulations The DPD complies with the Act and the Regulations. (as amended)
Overall Conclusion and Recommendation 148. The Plan has a limited number of deficiencies in relation to soundness for the reasons set out above which mean that I recommend non-adoption of it as submitted, in accordance with Section 20(7A) of the Act. These deficiencies have been explored in the main issues set out above.
149. The Council has requested that I recommend main modifications to make the Plan sound and capable of adoption. I conclude that with the recommended Main Modifications set out in the attached Appendix the Reading Sites and Detailed Policies DPD satisfies the requirements of Section 20(5) of the 2004 Act and meets the criteria for soundness in the National Planning Policy Framework. Christopher Anstey
Inspector
This report is accompanied by the Appendix containing the Main Modifications
- 28 - APPENDIX – MAIN MODIFICATIONS
The modifications below are expressed either in the conventional form of strikethrough for deletions and underlining for additions of text, or by specifying the modification in words in italics.
The page numbers and paragraph numbering below refer to the submission DPD, and do not take account of the deletion or addition of text.
Policy/ Ref Page Main Modification Paragraph
MM1 15 Insert new Chapter 2 as follows:
2. Presumption in Favour of Sustainable Development
2.1 The Government has placed the presumption in favour of sustainable development at the heart of its approach to planning, and this is articulated in the National Planning Policy Framework, published in March 2012. It was considered necessary to include a policy on this presumption within the development plan.
SD1: PRESUMPTION IN FAVOUR OF SUSTAINABLE DEVELOPMENT
A positive approach to considering development proposals will be taken that reflects the presumption in favour of sustainable development contained in the National Planning Policy Framework. Where appropriate, the Council will work proactively with applicants jointly to find solutions which mean that proposals can be approved wherever possible, and to secure development that improves the economic, social and environmental conditions in the area.
Planning law requires that applications for planning permission must be determined in accordance with the development plan unless material considerations indicate otherwise11. Planning applications that accord with the policies in the development plan (including, where relevant, with policies in neighbourhood plans) will be approved without delay, unless material considerations indicate otherwise. Proposed development that conflicts with the development plan will be refused, unless other material considerations indicate otherwise.
Where there are no policies relevant to the application or relevant policies are out of date at the time of making the decision then permission will be granted unless material considerations indicate otherwise – taking into account whether:
o Any adverse impacts of granting permission would significantly and demonstrably outweigh the benefits, when assessed against the policies in the National Planning Policy Framework taken as a
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Policy/ Ref Page Main Modification Paragraph whole; or
o Specific policies in that Framework indicate that development should be restricted.
Aim of the Policy
2.2 This policy aims to ensure that decisions are taken in line with the presumption in favour of sustainable development as set out in the National Planning Policy Framework (NPPF). In doing so, it helps to achieve all of the core objectives of the Core Strategy.
Reason for the Policy
2.3 The policies and proposals in the SDPD, as well as in Reading’s other development plan documents, reflect the presumption in favour of sustainable development set out in paragraphs 11 to 16 of the NPPF, and the inclusion of this policy avoids any doubt about whether the LDF complies with the presumption.
How will the Policy be achieved?
2.4 The policy will be delivered through decisions on applications for planning permission, which will be taken in line with the considerations set out in the policy, where the starting point is the development plan.
How will the Policy be monitored?
The policy will be monitored through monitoring of the other policies within the Local Development Framework.
11Section 38(6) of the Planning and Compulsory Purchase Act 2004 and section 70(2) of the Town and Country Planning Act 1990.
Renumber subsequent sections, policies, paragraphs and footnotes.
2
Policy/ Ref Page Main Modification Paragraph
MM2 88-90 Section 13.2 13.2.1 Park Lane Primary School in Tilehurst, Reading is a 2 Form Entry (2FE) Primary School. The school currently operates from a split campus across four separate sites. This arrangement is unsatisfactory from an education point of view and it is proposed to consolidate a new school, library and health centre on a single site at the Laurels, funded in part by the potential sale of surplus sites at Park Lane and Downing Road.
SA5: PARK LANE PRIMARY SCHOOL, THE LAURELS AND DOWNING ROAD
The existing Park Lane Primary School and associated playing fields, hard play areas, car parking and associated facilities will be reprovided on a single extended site at the Laurels, School Road, Tilehurst.
If required to support the scheme, tThe Downing Road Playing Fields will be released for residential development subject to it being demonstrated that the loss of the open space is justified under relevant national and local policy. Development should provide 45-55 units together with appropriate public open space, including a play area, will be developed for residential (45-55 units) and open space. Appropriate public open space provision, including a play area, should be provided as part of any development to mitigate the loss of the private playing fields and to provide an appropriate setting for the existing public footpath that forms the western boundary of the site. Resolution of highway and access issues on Downing Road will be required. Hedgerows and trees should be retained.
As a result of the reprovision of the Park Lane Primary School on a single site, the existing Park Lane School Site and its Annex off Downing Road and the Downing Road Playing Fields will be released for development as follows:
The main Park Lane School Site will be redeveloped for residential purposes (15-20 dwellings) with access off Downing Road and Chapel Hill. Development should address the practicality of retaining elements of the existing building within any new scheme.
The Park Lane School Annex will be reused/ redeveloped for community or residential purposes, subject to safeguarding the amenity of occupiers of adjacent properties.
◦The Downing Road Playing Fields will be developed for residential (45-55 units) and open space. Appropriate public open space provision, including a play area, should be provided as part
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Policy/ Ref Page Main Modification Paragraph of any development to mitigate the loss of the private playing fields and to provide an appropriate setting for the existing public footpath that forms the western boundary of the site. Resolution of highway and access issues on Downing Road will be required. Hedgerows and trees should be retained.
No changes to paragraphs 13.2.2 to 13.2.7
13.2.8 The Downing Road Playing Field is a fenced area of private, recreational space. It is proposed for residential development and open space. Its disposal is essential to realise the significant community benefits of providing a new primary school on a single site to serve the Tilehurst area.The release of open space will need to be clearly justified in terms of both national and local planning policy. Policy CS28 of the Core Strategy states that development of open spaces would only be permitted if replacement open space, to a similar standard, can be provided at an accessible location close by, or that improvements to recreational facilities on remaining space outweighs the loss. In relation to current national guidance, the Downing Road Playing Field would only be released for residential development if it has been demonstrated through a robust and up-to-date assessment, carried out by the Council or an applicant and involving consultation with the local community, that the open space is surplus to the requirements of the local area, and that there is an excess of playing field provision in the catchment or replacement playing field provision could be made. The disposal of the Downing Road Playing Field has been approved by the Secretary of State for Education (under Section 77 of the School Standards and Framework Act 1998). Some public open space provision, including a play area, should be provided as part of any development to mitigate the loss of the private playing fields and to provide an appropriate setting for the public footpath adjoining the western boundary of the site. Any application involving the loss of the primary school playing field may attract objections from Sport England unless it is demonstrated that there is an excess of playing field provision in the catchment or replacement playing field provision is provided. In addition, an area of open space is to be retained as part of any development. There may be scope to provide replacement provision at the Blagrave Recreation Ground area and the enhancement of playing pitch provision in that location. Developers should examine the possibility of serving some of the development via a separate access from Beverley Road. The site is proposed for residential development although the provision of specialist accommodation, e.g. care home, elderly units, would be appropriate in this very accessible location.
13.2.9 If loss of the playing field is adequately justified,
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Policy/ Ref Page Main Modification Paragraph some public open space provision, including a play area, should be provided as part of any development to mitigate the loss of the private playing fields and to provide an appropriate setting for the public footpath adjoining the western boundary of the site.
13.2.10Developers should examine the possibility of serving some of the development via a separate access from Beverley Road. If the loss of the playing field is justified, the site is proposed for residential development although the provision of specialist accommodation, e.g. care home, elderly units, would be appropriate in this very accessible location.
Renumber subsequent paragraphs. MM3 94 SA8a Delete the allocation of SA8a: Land at Kentwood Hill, as follows:
SA8a LAND AT KENTWOOD HILL Development of existing buildings 10-16 and yard for residential. dwellings Development should: Mitigate significant impacts on, and provide management of, important biodiversity assets on land adjacent to the proposed development site including badger habitats; Retain woodland and important trees covered by a Tree Preservation Order; Retain hedges and landscape setting to existing Kentwood Hill frontage of the site; Take account of potential archaeological significance; Maintain important views through the site to the Thames escarpment and Chilterns AONB from the adjoining playing fields; and Require a Transport assessment and adequate footway / cycleway provision to be provided linking in to existing routes.
Renumber subsequent SA8 allocations, within policy SA8 and on the Proposals Map
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Policy/ Ref Page Main Modification Paragraph MM4 111 Figure 11 Delete the entry for SA8: Land at Kentwood Hill in line with MM2:
SA8 Land at Kentwood Hill Short
MM5 132 Figure 14 Make the following changes to the table in line with MM1 and MM2:
SA5 Downing Road, Park Residential development Lane School and the dependent on justification of Laurels loss of playing field. If loss justified, allocation is for 60-75 dwellings, but this figure is excluded from the total below.60-75 SA8 Land at Kentwood Hill 10-16 TOTAL 1,106 – 1,6231,036 – 1,532
MM6 134-136 Figures 15, Amend the Housing Trajectory table and graphs to take account 16a and 16b of the following: Updates to incorporate the results of 2011 monitoring of planning permissions; Correction to remove some double-counting of figures; Remove the figures from SA5 (Park Lane School, The Laurels and Downing Road) and SA8a (Land at Kentwood Hill) in line with MM1 and MM2 above.
Full copies of the revised Figures 15, 16a and 16b are included at Appendix 1. MM7 Proposals Amend the Proposals Map to remove the site allocation of SA8a Map (Land at Kentwood Hill) in line with MM2. See Appendix 2. MM8 Proposals Amend the Proposals Map to change the boundaries of the Major Map Landscape Features under SA17 to remove the former Burghfield Landfill Site from the designation. See Appendix 3. MM9 Proposals Amend the Proposals Map to change the boundaries of the Major Map Landscape Features under SA17 to remove areas of the University of Reading Whiteknights Campus from the designation. See Appendix 4.
6 APPENDIX 1: DETAILS OF MODIFICATIONS TO FIGURES 15, 16A and 16B
Figure 15: 2006-2026 Sites and Detailed Policies Document Housing Trajectory (table)
1 Figure 16a: 2006-2026 Sites and Detailed Policies Document Housing Trajectory (South East Plan figures) (graph)
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3 Figure 16b: 2006-2026 Sites and Detailed Policies Document Housing Trajectory (Core Strategy figures) (graph)
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5 APPENDIX 2: AMENDMENTS TO THE PROPOSALS MAP - MM6 Deletion of SA8a: Land at Kentwood Hill
6 APPENDIX 3: AMENDMENTS TO THE PROPOSALS MAP - MM7 Change to the boundary of Major Landscape Feature, former Burghfield Landfill Site
7 APPENDIX 4: AMENDMENTS TO THE PROPOSALS MAP - MM8 Change to the boundary of MLF Whiteknights Campus
8 APPENDIX 5: PROPOSALS MAP KEY
9