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Current Position ROYAL BOROUGH OF WINDSOR AND MAINDENHEAD 2013-2033: EIP – PART 2 MATTER 11: Placemaking and Site Allocations REPRESENTATIONS PREPARED BY LICHFIELDS ON BEHALF OF INLAND HOMES 1: Have the Plan’s housing and mixed-use allocations been chosen on the basis of a robust assessment process? Proposed Changes to the Allocations in the Submitted Plan Question: 8. The Council’s Consultation Explanation Statement of November 2019 summarises that the proposed changes to the submitted Plan would delete 22 of the originally proposed allocations (Table 1) and add 13 new ones for a variety of uses. Are these changes necessary for soundness and otherwise justified? In particular: - Is it justified in principle to delete those sites now under construction and record them as commitments instead? (HA13, 15, 16, 26, 35 and 47). BackgrounD 1 These representations are made on behalf on Inland Homes. Inland Homes shares with the Royal Borough of Windsor and Maidenhead a commitment to deliver high quality new homes. 2 Inland Homes has sought to engage with the Council with regards to draft policy HO1 and site allocation proforma HA22 Land North of Breadcroft Lane and welcomes the opportunity to engage further in the local plan examination process. Current Position: LanD North of Breadcroft Lane (former HA 22) 3 Question 8 relates to the proposed allocations which have been deleted, specifically sites HA13, 15, 16, 26, 35 and 47. We would raise the same concerns that the Inspector has about thes sites in relation to site HA22. 4 RBWM are proposing a change to the Submission Version of the Local Plan, which has been submitted as Sound, to omit the allocated HA22, Land North of Breadcroft Lane and to put the site back into the Green Belt. HA22 was is allocated in the Submission Version of the Local Plan which RBWM submitted as Sound. This was due to the 2016 HEELA which considered the site to be potentially developable, as the site had durable Green Belt boundaries and was only partially constrained by the location adjacent to the railway line. 5 The site was proposed to be removed from the Green Belt as it did not serve the five purposes for including land in the Green Belt as assessed in the RBWM Edge of Settlement Analysis 2016. 6 However, it is now proposed to remove allocation HA22 from the Local Plan. Appendix C of the 2019 HEELA states that: The site is 90% within an excluded airfield safeguarding zone which leaves only a small section available for development. It is unclear if this would be mitigated through the topography of the site. Use of site for housing would conflict with the Hurley and Walthams Neighbourhood Plan. Numerous other constraints also include the green belt, a large section of priority habitat on site and the close location of the bordering railway line. This is conflicting with the Site Proforma from 2016 which only raises only four constraints: access, noise, ecology and biodiversity all of which can be mitigated. 7 None of this is new evidence or information and the Council, having regard to this, consider the proposed allocation of the site for housing as being Sound. In addition, Inland Homes have submitted significant evidence to the Council to demonstrate that the site could be developed safely with regard to the airfield safeguarding zone and that it could provide valuable and ‘accessible’ public open space to address the Neighbourhood Plan designation. The Council have produced no information or evidence to refute that. White Waltham Airfield (WWA) 8 The White Waltham Airfield (WWA) is located immediately south of the site, beyond Breadcroft Lane. The approach flight path of runway 21 and departure flight path of runway 03 crosses part of the HA22 site. Therefore, it would have been considered as part of the previous site assessment. 9 We object to the deletion of this site allocation on the basis that the latest analysis is without foundation or new evidence. This is largely due to the fact that is not possible that RBWM were not aware or did not have regard to the location of the airfield in allocating the site at the time of the 2016 HEELA and the 2018 Local Plan. 10 The RBWM letter to the Inspector dated July 2019 states how WWA have submitted representations in regard to the allocation HA22. These representations claim that development of HA22 would be inappropriate given the operational requirements of the airport for Engine failure at take-off (EFATO) safeguarding plus noise from overhead planes. This resulted in the Council agreeing an informal safeguarding zone within which the Airfield will be consulted on proposals. 11 In any event, this has subsequently been addressed with evidence submitted to officers to demonstrate no harm with regard to air safeguarding or noise. This has been demonstrated by An Aeronautical Assessment and an OLS review. Please see the Aviation Safeguarding Assessment appended. 12 The Assessment clearly confirms that it was possible to develop at a scale that would sit under WWA’s OLS, by way of mapping a development height envelope. This modelling exercise confirms that there is vertical room across the site for development, without penetrating the OLS. 13 In addition, the Assessment confirms that the proposed development area will not pose a significant safety risk in the context of EFATO. The Assessment also confirms compliance with Civil Aviation Authority Guidance. 14 Of the potential impact identified, it has been demonstrated that the aerodrome safeguarding issues identified can be mitigated through scheme design, construction management practices and on-going site management once operational. 15 On this basis, and with consideration of the issues raised in WWA’s objection letter, it is considered that development at the HA22 site could co-exist with WWA, with appropriate mitigation in place. Other Factors 16 With regard to the conflict in wording from the 2016 and 2019 HEELA, we also consider that the position of the Green Belt assessment of the site (Edge of Settlement Analysis 2016) cannot change within a few years. Similarly, the position in ecology cannot change in this time frame. We would also like to note that the railway line is already allowed for in the allocation. 17 The 2019 HEELA states that “Use of site for housing would conflict with the Hurley and Walthams Neighbourhood Plan”. However, the RBWM letter to the Inspector dated July 2019 states that: “…. the Parish Council is prepared to accept the site allocation of HA22 for housing subject to the 15 affordable dwellings being passed to the Parish Council at nil cost, to be owned and managed by through a Community Interest Company which is wholly owned by the Parish Council Land Trust”. 18 This demonstrates that the Parish council are accepting the principle of development on the site. 19 However, Inland is of the view that the specific requirement of the Parich Council to hand over land for the affordable housing is an unreasonable planning policy request, but one where there is a planning policy solution. The site can remain allocated, with the need to accord with planning policy on affordable housing, but with an additional wording to allow the Parish Council to be the first bidder for the dwellings through any subsequent S106 Agreement. Conclusion 20 The proposed change to the Submitted Local Plan is not required for soundness and is not justified. This was identified as and remains a highly suitable site for development and it has been demonstrated that it is not constrained. It was consider appropriate for Green belt release and, as such, as there are exceptional circumstances, this should continue to be removed from the Green Belt. There remains a need to identify sufficient land to meet the housing requirement and this site has been demonstrated to be deliveable. In support the identified housing need, it is considered that the HA22 site allocation should remain in the Local Plan. 21 The removal of this allocation from the Plan would mean that the Plan is not positively prepared and it would also not be Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in this Framework. Aviation Safeguarding Assessment Cannon Lane Inland Homes 07 August 2020 ADMINISTRATION PAGE Job Reference: 9806A Date: 04 August 2020 Prepared for: Inland Homes Author: Michael Sutton Telephone: Email: First Reviewer: Kai Frolic Second Reviewer: Danny Scrivener Date: 04 August 2020 Telephone: Email: Issue Date Detail of Changes 1 04 August 2020 Initial issue 2 07 August 2020 Second issue – Minor amendments Confidential: The contents of this document may not be disclosed to others without permission. Copyright © 2020 Pager Power Limited Pager Power Limited, Stour Valley Business Centre, Sudbury, Suffolk CO10 7GB T: E: [email protected] W: www.pagerpower.com Aviation Safeguarding Assessment Cannon Lane 2 EXECUTIVE SUMMARY Background Pager Power has been retained to assess the potential risks of a proposed development area located southwest of Maidenhead, Berkshire, UK, upon aviation activity associated with White Waltham Airfield and to determine whether the two can safely co-exist. The report specifically addresses the objection letter from the airfield pertaining to compliance with physical safeguarding and lighting requirements, as well as the current use of the proposed development area for Engine Failure After Take-Off (EFATO) purposes. The Proposed Development Area The proposed development area is located approximately 180 metres north northeast of the Runway 21 threshold at White Waltham Airfield. Although in the early stages of planning, it is understood that the developer is considering development of residential buildings with a maximum of three storeys across the majority of the proposed development area.
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