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Response to SADPD Crowthorne Village Action Group CVAG, protecting our village against urbanisation Response to Bracknell Forest Council Draft Submission of Site Allocations Development Plan Secretary: Carole Doran 133 Dukes Ride Crowthorne Berkshire RG45 6DP [email protected] www.cvag.org.uk 7 March 2012 Crowthorne Village Action Group, response to Bracknell SADPD. 7 March 2012 Summary ................................................................................................................................................. 5 What changes we would like to see; .......................................................................................................... 8 Conclusion .................................................................................................................................................. 8 Policy SA4 (Broadmoor Area) is fundamentally unsound ....................................................................... 10 Submission ............................................................................................................................................... 10 The building and gardens are historically significant. ......................................................................... 10 Adjoining Special Protection Area....................................................................................................... 10 Impact on SPA ..................................................................................................................................... 13 Poor choice against alternatives ......................................................................................................... 13 Unsupported by infrastructure improvements ................................................................................... 13 Policy SA5, North East Crowthorne (TRL) would eradicate the existing gap between Crowthorne and Bracknell, risks damaging the Thames Basin SPA and is unsupportable by improvements to local infrastructure. ........................................................................................................................................ 16 Submission ............................................................................................................................................... 16 Supporting Evidence ................................................................................................................................ 18 Loss of strategic gap, contrary to Core strategy. ................................................................................ 18 Unsupportable by Funded improvements to Infrastructure .............................................................. 19 Significant Loss of trees, contrary to Core Strategy and Sustainable Community Strategy................ 20 The Site is immediately adjacent to the Thames Basin Special Protection Area and the proposed mitigation is insufficient. ..................................................................................................................... 22 Not Taken into account community feelings, contrary to “Statement of Community Involvement” 23 Previous application rejected by BFC. ................................................................................................. 24 The following sections were produced in collaboration between Crowthorne Village Action Group and the Northern Arc Action Group. ............................................................................................................. 28 Major conflicts with adopted Core Strategy make Bracknell Forest's development plan unsound ......... 29 Submission ............................................................................................................................................... 29 Supporting Evidence ................................................................................................................................ 31 Policy CS9 ............................................................................................................................................ 31 'Vision to 2026' Introduction to Core Strategy ................................................................................... 32 Policy CS1 ............................................................................................................................................ 33 Policy CS2 and CS3 .............................................................................................................................. 34 Policy CS6 ............................................................................................................................................ 35 Policies CS7 and CS8............................................................................................................................ 37 The 'Major Locations for Growth' introduction to Policies CS4 and CS5, and Policy CS15 ................. 37 Additional SADPD conflict with Council's Priorities and ..................................................................... 38 Medium Term Objectives.................................................................................................................... 38 2 | P a g e Crowthorne Village Action Group, response to Bracknell SADPD. 7 March 2012 Bracknell's Development Plans are unsound in failing to meet many of the objectives of the emerging National Planning Policy Framework ..................................................................................................... 43 Submission ............................................................................................................................................... 43 Supporting Evidence ................................................................................................................................ 44 Bracknell Council’s 10,780 Housing Demand Forecast for the period 2006-2026 is fundamentally unsound ................................................................................................................................................. 55 Submission ............................................................................................................................................... 55 Supporting Evidence ................................................................................................................................ 55 Bracknell’s demand forecast for 10,780 new homes dates back to February 1st 2006 ...................... 55 Household Projections, 2008 to 2033, England .................................................................................. 56 DTZ Housing Market Assessment (Updated - October 2011) ............................................................ 57 Declining Housing Demand in Bracknell ............................................................................................. 58 Economic Development and Tech Industry are moving away from Bracknell and Thames Valley .... 58 Bracknell’s submission plans for 432 more homes than their obsolete forecast actually requires: .. 59 The consultation carried out by Bracknell Forest Council is flawed ........................................................ 61 Submission ............................................................................................................................................... 61 Supporting Evidence ................................................................................................................................ 61 Community involvement in the preparation of the SADPD has not been carried out in accordance with the Council's Statement of Community Involvement (SCI) nor its own stated aims. ................. 61 There has been inadequate consultation with adjoining authorities. ................................................ 63 In approving the SADPD, the Council has acted in breach of its own Code of Conduct. .................... 64 Annexe to section on flawed consultation. ........................................................................................ 66 Inadequate assessment of alternatives when choosing “preferred” broad areas. .................................. 67 Submission ............................................................................................................................................... 67 Supporting Evidence ................................................................................................................................ 68 Scoring was arbitrary and contained a significant number of errors. ................................................. 68 No attempt was made to utilise the empty office space in Bracknell Town Centre. .......................... 69 Related matters. ................................................................................................................................. 70 Infrastructure Delivery Plan for roads and transport (SAL 34), is unsound ............................................. 71 Submission ............................................................................................................................................... 71 SAL 34 – Infrastructure Delivery Plan (IDP) November 2011 .............................................................. 71 Strategic Road Network (SRN) ............................................................................................................ 71 Supporting Evidence ...............................................................................................................................
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