Response to Bracknell Forest Council Site
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RESPONSE TO BRACKNELL FOREST COUNCIL SITE ALLOCATIONS DPD PARTICIPATION DOCUMENT on behalf of W J CHANNING AND SONS (WOKING) LTD APRIL 2010 Prepared by Olivia Collett BA (Hons) Dip TP MRTPI Checked by Miles Thompson, BA, MA, MRTPI This document has been prepared in accordance with West Waddy ADP’s quality control procedures and should be treated as a draft unless it has been signed and approved. The document should not be used for any other purpose than that for which it has been prepared without the written authority of West Waddy ADP. If the document is used for another purpose without consent, then no responsibility or liability for the consequences arising for such action will be accepted by West Waddy ADP. © West Waddy ADP 1 QUESTION 3 – WHICH APPROACH IS THE MOST APPROPRIATE FOR DELIVERING A ROBUST AND FLEXIBLE LAND SUPPLY? 1.1 It is considered that Option 2 would present the most appropriate approach to delivering a robust and flexible land supply, particularly in light of the current economic climate. However, this does present some other questions as sites that fall within the ‘reserve’ would be appropriate under certain circumstances e.g. site ‘x’ could be developed if site ‘y’ has not been developed by ‘z’ date. These circumstances would need to be clearly established through the drafting of this document and be contained within the Site Allocations DPD so landowners are clear on the position of their land. 2 QUESTION 7 – DO YOU AGREE WITH THE PRINCIPLES FOR SETTLEMENT BOUNDARY CHANGES? 2.1 Settlement boundary changes should be looked at carefully alongside assessing the potential for “rounding off” of settlements. Please refer to our response to Questions 47 and 48. 3 QUESTION 8 – ARE THERE OTHER PRINCIPLES THAT SHOULD BE FOLLOWED? 3.1 Yes, the suitability, availability and deliverability of sites should also be looked at. Please refer to our full response to Questions 47 and 48. 4 QUESTION 38 – DO YOU HAVE ANY VIEWS ON THE SUITABILITY, AVAILABILITY AND ACHIEVABILITY OF ANY OF THE SITES IDENTIFIED IN APPENDIX 2? 4.1 Yes. Some sites that have been identified for potential allocation have been classified as category C for availability. We consider that sites that are allocated within the DPD must be suitable, available and developable. If there is some doubt as to the delivery of these ______________________________________________________________________________________ Representations to Bracknell Forest Site Allocations DPD Land at “The Rough” W J Channing and Sons North Ascot SLW\32 1 sites within the Plan period then they should be discounted for formal allocation and if necessary only be identified as ‘reserve sites’. 4.2 A consistent approach should be taken to the identification of sites looking at the 5 categories identified within the Strategic Housing Land Availability Assessment (SHLAA) and the suitability and availability of these sites: Category 1 – Bracknell Town Centre Category 2 – PDL and buildings in defined settlements Category 3 – Other land within defined settlements Category 4 – Sites adjoining sustainable defined settlements Category 5 – Sites adjoining unsustainable defined settlements In terms of suitability, sites rated A and B should be preferable to C and in terms of availability A and B should be preferable to C. At this stage, we consider that any site classified as C should be discounted and the allocations should be looked at in the following preference: Suitability Availability A A A B B A B B C – discounted at this stage C – discounted at this stage 4.3 We have re-rated the sites listed within Appendix 2 and discounted those that are not considered appropriate for allocation in this DPD. See Appendix 1 to this document for details of those sites considered most appropriate for allocation. 4.4 This approach should be consistent throughout the DPD. ______________________________________________________________________________________ Representations to Bracknell Forest Site Allocations DPD Land at “The Rough” W J Channing and Sons North Ascot SLW\32 2 5 QUESTION 44 – WHICH IS THE MOST APPROPRIATE STRATEGIC OPTION FOR HOUSING DEVELOPMENT? 5.1 Option 2 would present the most appropriate strategic option for housing development as it will spread more evenly across the Borough with the priorities based on the relative merits of individual sites. However, this should not be limited to “broad areas”. Individual sites should be assessed on their own merit, taking into consideration the sustainability credentials of the site in relation to facilities within Bracknell Forest and at cross- boundaries to adjoining areas. 6 QUESTION 46 – HOW SUITABLE DO YOU THINK THE IDENTIFIED BROAD AREAS ARE AND THE REASONS? 6.1 If the broad areas are considered to be ‘strategic’, then these should be considered through a review of the Core Strategy – certainly looking at Options 4, 5 and 6 together, this would seem more appropriate to a review of the Core Strategy. 6.2 The broad areas contain parcels of land that have not been identified through the SHLAA process and so no assessment has been carried out on the availability or achievability of bringing these sites forward through the LDF process. If these sites are not deliverable the DPD would be contrary to PPS3 and risk being unsound as it is not consistent with national policy. 6.3 Some of the individual sites contained within the eight broad areas identified also rank as category C for suitability or availability and should therefore also be discounted for allocation at this stage. 6.4 In addition, some of the broad areas identified would result in encroachment into the countryside and/or the coalescence of settlements. It is considered that there are more suitable sites in sustainable locations that are ‘rounding off’ and that these should be considered in advance of broad areas, in accordance with the tables shown at appendix 1, 2 and 3 of this document. ______________________________________________________________________________________ Representations to Bracknell Forest Site Allocations DPD Land at “The Rough” W J Channing and Sons North Ascot SLW\32 3 7 QUESTION 47 – DO YOU AGREE WITH THE PRINCIPLES FOR ASSESSING ROUNDING OFF SITES? 7.1 No. The suitability and deliverability of sites should also be looked at. For example, of the four potential sites identified 3 of these fall within the Council’s definition of an “unsustainable settlement”, classified as a category 5 settlement. The rounding off of settlements should also be considered prior to identifying any specific broad areas as these broad areas might be in less sustainable locations and also encroach on the open countryside and potentially lead to the coalescence of settlements – Options 4, 5 and 6 are examples of these. 8 QUESTION 48 – SHOULD WE ADOPT A DIFFERENT APPROACH TO THE ALLOCATION OF ROUNDING OFF SITES? 8.1 Yes. As identified above, the suitability, availability and developability of sites should also be a principle for assessing “rounding-off” sites. 8.2 Paragraph 5.34 of the Participation Document states that four sites were submitted through the SHLAA process that are on the edge of, but just outside, a defined settlement. This is incorrect because it omitted our client’s site. West Waddy ADP submitted through the SHLAA process land at “The Rough” in North Ascot, which is identified within the SHLAA as a sustainable settlement (category 4). 8.3 In looking in detail at the scoring within the SHLAA, the Council has assessed land at “The Rough” as category C for suitability and A for availability. Using the Council’s criteria for assessing the suitability, we disagree with the ratings given. Land at “The Rough” is less than 800m from the Green Meadows Surgery doctors surgery, which sits on Winkfield Road. The rating must therefore be changed, by removal of the cross, to then give a total score of 9. The site should properly fall within category B for suitability – as shown revised in Appendix 3. 8.4 It is considered that there are sites that have constraints, such as the Green Belt, that are in more sustainable locations than some sites that are not. On this basis there should be a localised Green Belt review for “sustainable” Category 4 settlements. This should also look at the degree to which sites still meet the five purposes of including land within Green ______________________________________________________________________________________ Representations to Bracknell Forest Site Allocations DPD Land at “The Rough” W J Channing and Sons North Ascot SLW\32 4 Belts (under paragraph 1.5 of PPG2). These sites should be released for development before releasing land on the edge of unsustainable settlements or which are further out into the countryside. Land at “The Rough” in North Ascot is one particular site which does not meet the five purposes of including land within Green Belts in the following way: Green Belt Purpose 1 – to check the unrestricted sprawl of large built-up areas Land at “The Rough” is contained by development on the northern, eastern and southern boundaries. It is therefore a pocket of open land effectively lying within the built up area of North Ascot. Development would not therefore result in unrestricted sprawl of the urban area but would be a logical ‘rounding off’ of North Ascot. North Ascot is not a large built up area and therefore removal of “The Rough” from the Green Belt would be localised. Green Belt Purpose 2 – to prevent neighbouring towns from merging into one another Any proposed residential development of this site would not extend any further west of the existing limit of residential development established at New Road and Beechwood Close to the south and Forest Road to the north and could be visually contained by the retention of a buffer strip of planting to the boundary. Development would not therefore result in actual or visual coalescence with Winkfield Row to the west.