NOTICE OF INDIVIDUAL EXECUTIVE MEMBER DECISION

ITEM NO. IMD 2008/21

TITLE Wokingham Borough Council response to consultation from Forest Borough Council on Issues and Options for the Development Management Housing and Commercial Policies and Sites Development Plan Document

DECISION TO BE MADE BY Gary Cowan, Executive Member for Local & Regional Planning

DATE OF DECISION 27 March 2008

REPORT TO BE PUBLISHED ON 17 March 2008

INDIVIDUAL EXECUTIVE MEMBER DECISION

REFERENCE IMD: 2008/21

TITLE Wokingham Borough Council response to consultation from Borough Council on Issues and Options for the Development Management Housing and Commercial Policies and Sites Development Plan Document

FOR CONSIDERATION BY Gary Cowan Executive Member for Local & Regional Planning

DATE 27 March 2008

WARDS Finchampstead South, Hurst, Westcott and Wokingham Without

REPORT PREPARED BY Graham Ritchie on behalf of Heather Thwaites, Acting Corporate Head of Strategy & Partnerships

SUMMARY Wokingham Borough Council (WBC) needs to agree its response to the consultation underway by Bracknell Forest Borough Council (BFBC) on the Issues and Options for the Development Management Housing and Commercial Policies and Sites Development Plan Document (the BFBC DPD).

The BFBC DPD applies to the whole of Bracknell Forest and amplifies the guidance set out in its approved Core Strategy which was the subject of consultation with this authority. It will when finalised provide more detailed policies on the issues for the management and delivery of new housing, retail and employment development. It will also identify sites for these activities beyond that committed for Amen Corner, and north of /, Bracknell. Further details on the Issues and Options consultation are available at www.bracknell-forest.gov.uk/dmh. The BFBC DPD is out for consultation from 15 February to 28 March 2008.

This response to the BFBC DPD is based upon the issues this Council raised for the production of BFBC’s Core Strategy.

REASONS FOR DECISION Wokingham Borough Council (WBC) during the various stages of consultation on the Bracknell Forest Borough Council (BFBC) Core Strategy emphasised the need to consider the impacts of development outside of the BFBC administrative area, especially within Wokingham Borough. These primarily related to transport, education and the need to maintain the separation of settlements. Since BFBC have started to refine their proposals for its area, it is necessary that WBC uses every opportunity to positively influence the strategy and to secure benefits to minimise adverse impacts on Wokingham Borough’s residents.

ALTERNATIVE OPTIONS, IF ANY WBC could decline to comment at this stage. However, this means that the WBC will have lost a key opportunity to influence proposals at Amen Corner. It may also make it harder to discuss with BFBC the issues of how any capital works within the Borough required by the development may be financed.

RECOMMENDATIONS That the Executive Member agrees the responses to the questions detailed in the accompanying Appendix as the WBC response to this consultation by BFBC.

FINANCIAL IMPLICATIONS

Revenue

How much will it Cost Is there sufficient budget (or grant / Save funding) available? – if not quantify the Supplementary Estimate OR if savings, also quantify. Current Financial Year £0 From existing Development Plans (Year 1) team budget Next Financial Year £0 From existing Development Plans (Year 2) team budget Following Financial £0 From existing Development Plans Year (Year 3) team budget

Other relevant financial information relevant to the Recommendation/Decision At the current time it is unknown if work may need to be commissioned to support the views of WBC in responding to the BFBC DPD. In the event that work needs to be commissioned which cannot be financed from the Development Plans team budget, a report will be presented to the Executive for their consideration.

The development envisaged by this document could have financial implications for WBC but this cannot be quantified at this stage

Please note: The Recommendation must request the Supplementary Estimate required in this year, noting the ongoing commitment in future years.

SUMMARY OF CONSULTATION RESPONSES

Corporate Head of Finance Comments incorporated into report. Monitoring Officer To be advised Leader of the Council To be advised

Impact on Equality The consultation documents themselves will be reviewed by Bracknell Forest Borough Council to ensure that they do not have direct impacts on any one age, faith, gender, etc. It is not considered that the views of Wokingham Borough are likely to significantly differ from those of Bracknell Forest Borough with regard to ensuring that any direct impacts are minimised.

Impact on Sustainability As with the equality assessment, Bracknell Forest Borough Council will review the impacts on sustainability of this document. They will need to ensure that the final version of the document minimizes the impacts on the various factors that they consider necessary. This review of sustainability of the Development Plan Document is a statutory requirement.

List of Background Papers None

Held by Graham Ritchie Service Development Plans Telephone No (0118) 974 6457 Email [email protected] Date 5 March 2008 Version No. 2

NB All reports seek to identify environmental, community safety, customer care and equal opportunities implications. Consultation with residents and organisations which has or is about to take place, will also be reported.

SUPPORTING INFORMATION The proposed responses to the questions posed within the BFBC DPD are included in the accompanying appendix.

Appendix

DETAILS OF RESPONSES TO QUESTIONS Q1 – No additional spatial objectives for the Sustainability Appraisal are required for this document.

Q2 – Density approach 1 (seeking a minimum of 30 dwellings per hectare with flexibility for higher where design, layout, accessibility and other factors indicate support) is considered the most appropriate for Bracknell Forest.

Q3 – BFBC should aspire to the delivery of 60% of the required housing on previously developed land, subject to the findings of its Strategic Housing Land Availability Assessment (SHLAA) that such a proportion is achievable. If the SHLAA indicates that a 60% proportion is not achievable (having regard to availability and deliverability of land), an appropriate alternative target should be selected.

Q4 – The 2001 Census indicated (Table KS16) that around 2.1% of the household spaces of BFBC were vacant. The since cancelled Tapping the Potential suggested that 2% was the minimum vacancy rate to allow the normal operation of the housing market. Therefore, it is considered appropriate that BFBC should seek to protect losses from the existing housing stock. However, due to the current low household vacancy rate the value of producing a Empty Homes Strategy is queried.

Q5 – WBC considers that BFBC should promote good design across Bracknell Forest with specific area guidance produced in conjunction with the local community and other relevant stakeholders.

Q6 – WBC agrees that a design led approach to addressing the issues of safety and security is appropriate.

Q7 – WBC considers that for inclusive design, it is appropriate to have regard to the latest guidance to ensure that the issue is addressed. It is therefore necessary to have regard to the guidance on factors such as lifetime homes.

Q8 – WBC considers that option 2 regarding areas of special character is most appropriate for BFBC. This indicates that the policy for character areas will have regard to the assessments currently underway and that its implementation will be supplemented through Supplementary Planning Documents.

Q9 – WBC considers that for extensions, option 2 is the most appropriate as it enables the production of additional guidance to amplify the implementation of the policy.

Q10 – For Green Infrastructure, WBC considers that option 3 (developing a separate policy and then seeking to protect the existing network and address deficiencies) is the most appropriate.

Q11 – BFBC should protect existing important areas for biodiversity and seek to increase the ability of development sites to support a range of species as suggested in option 4.

Q12 – Open spaces should be considered on a site by site bases through the site allocation process with more detailed policies within the DPD. Q13 – WBC questions whether the findings of the SHLAA can justify the very exceptional circumstances to warrant a review of the Green Belt, without clear evidence that insufficient available and deliverable land is available to meet the requirements of the emerging South East Plan.

Q14 – WBC considers that the responses of the water and sewage companies should be used as the basis for determining the appropriate approach to addressing the impacts of development on this infrastructure.

Q15 – WBC considers that depending upon the risk of flooding in parts of Bracknell Forest, it may be appropriate to provide additional guidance on the implementation of PPS25.

Q16 – WBC considers that BFBC should have regard to the wide range of evidence on the needs for market housing and should seek to provide a mix that best reflects local circumstances, including the needs for elderly population and those with specific needs.

Q17 – BFBC should seek to protect existing low cost market housing sites and increase provision. BFBC should consider the results of an affordable housing viability study to establish whether there may be other sources of low cost market housing in addition to park homes.

Q18 – BFBC should follow option 2 and set the thresholds and percentage for affordable housing based upon the viability study.

Q19 – BFBC should set the mix of affordable housing between rented and intermediate categories based upon the findings of the viability study. The viability study may indicate that a higher proportion of affordable units can be supplied with an enhanced emphasis on the intermediate sources of supply.

Q20 – BFBC should seek to deliver a range of affordable housing sizes (option 1) having regard to the findings of its viability study.

Q21 – The overall target for affordable housing should be based on the findings of the viability study as envisaged in option 1.

Q22 – BFBC should have regard to the findings of an Employment Site Assessment to consider both the overall need for employment floorspace within the borough and the opportunities for redeveloping existing sites. Only where this indicates a shortfall should a formal allocation be made, including through other Development Plan Documents e.g. Amen Corner Area Action Plan.

Q23 – WBC recognises that it may be appropriate for BFBC to provide further guidance on the development of large sites outside defined settlements. This guidance can include when proposals for redevelopment/extensions may be acceptable without harm to the character of the area. WBC however cautions the application of such guidance to smaller sites. When Wokingham District Council was producing its Local Plan, it was unable to demonstrate that it was appropriate to apply such a policy to a Secondary School within the Green Belt. BFBC should therefore only consider sites that are larger than this.

Q24 – WBC agrees that the general approach proposed by BFBC to retail development is appropriate. With respect to the Retail Study commissioned by BFBC, it is considered that some involvement of WBC is appropriate in considering whether changes to the centres in are necessary. This is because the settlement of Crowthorne is split between the two authorities and it may be appropriate to consider the overall impact of development within the area of the future need for retail space.

Q25 – WBC considers that option 3 may be the most appropriate for considering how accessibility of a proposal should be assessed. This includes applying both a broad approach amplified by local circumstances. Such a flexible approach can take account more easily changes in quality and frequency of public transport services.

Q26 – In order to ensure sufficient land is available for development, BFBC should consider allocating reserve housing sites rather than expediting the development of sustainable sites earmarked for later development. Expediting later sites will only be appropriate where they are not subject to infrastructure delivery constraints. This is the approach that WBC has followed in the past. WBC questions whether a shortfall in completions is relevant unless there is clear evidence that its implications will not be addressed through increased delivery as assessed over the subsequent five years. If the five year assessment indicates that sufficient land is available and deliverable, there should be no need to consider release of sites. WBC agrees that the Annual Monitoring Report process is an appropriate mechanism to consider whether sufficient land is available.

Q27 – WBC is not aware of any other sites that should be considered through the SHLAA.

Q28 – WBC would welcome discussions with BFBC on the suitability of sites close to the administrative boundary for residential development. a) This includes those outside of the search sequence detailed in the Core Strategy e.g. TRL, Old Wokingham Rd, Crowthorne – ref 33) b) Sites within the search sequence of the Core Strategy e.g. land at Amen Corner (sites 27, 195, 203 & 220) where the authority has already expressed concerns about traffic and other implications. c) Deliverability of sites crossing the boundary e.g. site 222 (ARL) north of A329(M). For such sites, WBC would welcome details of BFBC’s own assessment as this could influence the consideration by WBC where major infrastructure improvements to enable delivery are associated with the elements of the scheme within Bracknell Forest. In all the instances of sites close to or straddling the boundary, any assessment by BFBC on availability, suitability and deliverability may impinge upon WBC ability to allow development within its area. This includes where land in either authority is necessary to maintain a strategic gap between settlements or where there is only a finite highway/infrastructure capacity. Furthermore, depending upon the location of the site, its development may require infrastructure or other improvements within Wokingham Borough. It is therefore necessary that such issues are addressed before the SHLAA is finalised. Likewise, WBC fully expects to discuss with BFBC any potential implications for Bracknell Forest arising from the results of its own SHLAA. WBC would also welcome the opportunity to discuss with BFBC the potential of identifying and delivering cross-boundary avoidance measures for the Thames Basin Heaths Special Protection Area since this could be an issue for the deliverability of housing sites.

Q29 – WBC considers that BFBC could consider either the expansion of the existing permanent gypsy and traveller site or the provision of a new one. The appropriateness of either option should be influence regarding whether the need is of the same ethnic group as inhabit the existing site e.g. Romany or Irish gypsies. With regard to transit gypsy pitches and travelling showpeople, BFBC should allocate sufficient land to meet the needs as identified in the forthcoming work by SEERA.

Q30 – BFBC should consider the future planning of mobile home parks based upon the outcomes of its Affordable Housing Viability Study. If this indicates that such units can contribute towards affordable housing provision, BFBC should then consider how any identified need can be delivered.

Q31 – BFBC should await the results of its employment land audit before deciding upon which approach should be followed for development at existing defined industrial estates/areas and business parks.

Q32 – WBC considers that development at Crowthorne Business Estate (and Broadmoor Hospital) should be restricted to a defined area, height, volume, footprint, scale consistent with its comments on the two current applications by Legal & General (07/01196/OUT & 07/01207/OUT). The suitability of various uses at these sites should be assessed having regard to the findings of the Employment Land Audit, SHLAA and any other relevant research undertaken by BFBC.

Q33 – BFBC could consider amending its approach to major developed sites within the Green Belt provided any changes are consistent with PPG2, Annex C.

Q34 – For small scale employments sites within settlements of BFBC, the approach for development should be based upon the findings of the Employment Land Audit.

Q35 – For town centres, BFBC should consider whether a specific role is required for each one and the primary, secondary and retail core areas should be defined to accord with PPS6 (paragraphs 2.16 & 2.17).

Q36 – For district centres, it is appropriate for BFBC to apply a consistent approach and seek to retain retail uses to accord with PPS6.

Q37 – For local centres, it is appropriate for BFBC to apply a consistent approach and seek to retain retail uses to accord with PPS6.

Q38 – For other centres, it is appropriate for BFBC to apply a consistent approach and seek to retain retail uses to accord with PPS6.

Q39 – The categorisation of retail centres within Bracknell Forest should have regard to the findings of the Retail Study, draft South East Plan and the Structure Plan. This may therefore imply that Bracknell town centre should be in a different category to other town centres within the borough.

Q40 – WBC objects to any proposals to increase growth of Bracknell town centre which would result in impacts on the vitality and viability of centres outside of Bracknell Forest borough, primarily Wokingham town. Revisions to the boundary of the centre and approaches to development within it could be acceptable where they do not harm the vitality and viability of other centres. Regard should also be had to any changes to PPS6 during the preparation of the document.