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
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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 ...... 73 Local Road Network ...... 73 Public Transport ...... 75
Infrastructure Delivery Plan for Utilities (SAL 34), is Unsound ...... 78
Submission ...... 78 SAL 34–Infrastructure Delivery Plan (IDP), November 2011 ...... 78
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Crowthorne Village Action Group, response to Bracknell SADPD. 7 March 2012
Supporting Evidence ...... 79 Section 4.3 Utilities - Water Supply and Waste Water ...... 79
Provision for Healthcare Needs in the SADPD is unsound ...... 81
Submission ...... 81 Supporting Evidence ...... 82 Policy CS2 does not adequately consider the implications of future development upon existing health care facilities...... 82 Insufficient onus placed on developers for financial contributions...... 82
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Crowthorne Village Action Group, response to Bracknell SADPD. 7 March 2012
Summary
Crowthorne, a village of just 6,000 homes, is unusual in that it sits on 3 Parish and 2 District boundaries, so no one authority has jurisdiction over the whole village. The Crowthorne Village Action Group (CVAG) is a group of concerned Crowthorne residents who view the village as whole and seek to ensure that future developments are in keeping with their surroundings. We ensure that the community at large is kept informed of new developments on both sides of the boundary, so that they can make their views known through the official channels. We have over 300 members and supporters registered to receive our regular newsletters. In 2008, with financial support from the national lottery, we organised and produced the Crowthorne Village Design Statement (VDS). This was based on the responses from 1,600 Crowthorne residents. It has now been adopted by Wokingham Borough Council as providing supplementary guidance and accepted by Bracknell Forest Council, although they have no process for officially adopting VDSs. The Inspector from the Dept. of Planning has recognised the VDS as a “material consideration” when considering appeals for developments in the village. We are non political and have no party affiliations.We have an annual AGM and our committee is elected by a vote of the members. Further background information on CVAG can be found on our website, www.cvag.org.uk .
We strongly object to the proposed allocation of major sites in the Bracknell SADPD, and in particular to the proposal to concentrate 1,500 new homes in the village of Crowthorne, with 1,000 at TRL, 400 at Broadmoor and 100 at other smaller sites throughout the village. This 25% increase in the number of homes would totally overwhelm this village, joining it to its larger neighbour, Bracknell, as well as being totally unsupportable by any proposed improvements to the local infrastructure. The Bracknell Forest Council (BFC) SADPD needs to be viewed in context with the Wokingham Borough Core Strategy, which proposes placing 2,000 new homes in a belt South East of Wokingham town centre, between Wokingham and Crowthorne and less than 2 miles from the TRL site. It should be noted that, despite BFC claiming to have consulted with Wokingham, Wokingham have lodged a strong objection to the BFC proposals which include a 1,000 home development within metres of the Wokingham boundary, which is bound to place additional load on the adjoining Wokingham infrastructure. Between them, the two district councils are in danger of creating one vast urban sprawl joining Wokingham, Crowthorne and Bracknell.
We contend that the proposed allocation of housing in the Bracknell SADPD is neither legally compliant, since it is not prepared in accordance with national and local policies, nor is it justified since the evidence base is neither sound nor credible. Detailed reasons and supporting evidence follows this summary.
The total number of houses planned is not credible since it is based on pre 2006 data and has not been amended to reflect the economic downturn.
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Crowthorne Village Action Group, response to Bracknell SADPD. 7 March 2012
The proposed allocation of sites for new housing is in direct conflict with both the adopted BFC Core Strategy and the emerging National Policy Planning Framework (NPPF). The knowledge of non-compliance with NPPF may be the underlying reason why these proposals are being rushed through, with no time available to consider concerns raised by residents or properly plan the infrastructure required.
Bracknell town centre is badly in need of regeneration, something that has been the council‟s “Top Priority” for 10 years now, with little sign of progress. Bracknell has over 1,500,000 sq ft of long term empty office space. It is beyond belief that, having claimed to have considered all possible alternatives, BFC‟s “preferred options” for new major developments include;
- Building 210 homes within the curtilage of a grade II listed building, with loss of the historic kitchen garden ( Policy SA4, Broadmoor)
- Building 1,000 homes on a site which is mainly woodland and within 16m (that‟s metres, not miles) of the Thames Basin Special Protection area, an area protected by EC directive ( Policy SA5, TRL)
- Building 400 homes and a school on a popular play and pay golf course, originally set aside to provide recreational facility in mitigation of an earlier major development and protected by a section 52 agreement with the now defunct Berkshire council, which stipulates that it should not be used for ” any purpose other than as a golf course” ( Policy SA7 Blue Mountain)
A higher emphasis and more effort should have been placed on encouraging redevelopment of the town centre and re-utilising empty office space before considering the outlying green field spaces at the borough‟s edge.
It is in direct conflict with the council‟s previously agreed priorities. The council leaders are fully aware of this discrepancy as, before voting on this phase of the SADPD, they felt it necessary to propose and pass a motion to drop from their priorities the commitment to “sustainable development.”
This SADPD appears to be developer-led. For the owners and developers it is more profitable to build in attractive wooded locations than to regenerate the urban centre. It is lamentable that the BFC planners have meekly acquiesced, hiding behind the mantra “it has to be deliverable” and now recommend these rural locations as their “preferred options.”
The TRL site (policy SA5) is immediately adjacent to the Thames Basin SPA, would require felling an estimated 20,000 mature trees and virtually eliminate the strategic gap between Crowthorne and Bracknell.
Broadmoor Hospital (policy SA4), built in the 1860s and one of three high-security psychiatric hospitals in England, is an important part of Crowthorne‟s heritage and a significant local employer. We recognise the need to redevelop to provide modern fit for purpose buildings for the care of these patients. The concern arises from the need to partially fund this new hospital by selling land for redevelopment. The area
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Crowthorne Village Action Group, response to Bracknell SADPD. 7 March 2012 in its entirety is covered by the Historic Park and Garden designation (Grade II). National policies exist to protect such areas. “Once lost heritage assets cannot be replaced and their loss has a cultural, environmental , economic and social impact. Significance can be harmed or lost through alteration or destruction of the heritage asset or development within it’s setting. Loss affecting any designated asset should require clear and convincing justification. Substantial harm or loss of a grade II listed building, park or garden should be exceptional.” PPS5 Policy HE9.1 The Broadmoor site is also surrounded on 3 sides by the Thames Basin SPA.
We are very concerned by total lack of any meaningful consultation with local residents.
The Statement of Community Involvement is intended to involve people in planning issues, in the truest sense, ie that they participate in a collaborative manner. The Statement of Community Involvement states that BFC will “hear and reasonably act upon concerns important to people”. A consultation should be a discussion, which implies it is a two way dialogue and it was on this basis that those residents who were able to respond did so. It is evident that BFC has not listened to the concerns of it‟s residents in relation to the TRL site, nor been willing to countenance reasonable alternative suggestions which they have put forward.
At the presentation held at the Morgan centre, Crowthorne, Bracknell officials declined to accept comments, saying that the meeting was “for information only” An exit poll, organised by CVAG, showed that more than 90% of the 400 respondents were opposed to development on the scale presented. Comments submitted to the BFC website were also almost universally opposed to the proposals. Whilst these responses were duly noted, no significant changes were made.
Even the elected councillors were not allowed a free vote. The initial decision, October 2010, on which broad areas to pursue was taken by the 8 person Executive alone, which includes 3 members from Sandhurst, an area which, coincidentally, was dropped from the “preferred options.” Even when, in November 2011, the full council did eventually get an opportunity to discuss the SADPD proposals, the Conservative party, which controls the majority of the councillors, issued a whip of their members, so we still don‟t actually know how the councillors really feel. However the fact that the leader of the council felt that a whip was necessary would indicate that they were not confident of getting the support of the councillors in a free vote.
CVAG has asked that BFC propose an alternative plan for TRL which would involve building on just the currently built up area, and not the extensive surrounding woodlands. It is regrettable that the planning officers have not been willing to do this.
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Crowthorne Village Action Group, response to Bracknell SADPD. 7 March 2012
What changes we would like to see;
- The total number of new homes to be planned should be scaled back to reflect of the economic down turn and restricted availability of funding.
- Of the remaining total required, space should be found for more homes in the regeneration of the town centre and reutilisation of long term empty office space.
This in turn will enable BFC to be less aggressive in its proposals for large scale strategic areas.
- Policy SA4 (Broadmoor) should be adjusted for a lower density development more in keeping with the Grade II listed building and retaining the historic garden.
- Policy SA5 (TRL) should be scaled back to building on just the current built up area, which would avoid the loss of trees, be more supportable by improvements to the Crowthorne infrastructure, and allow more room for the SANG, putting less pressure on the SPA.
- Policy SA7 (Blue Mountain) should be dropped, respecting the obligations BFC inherited from Berkshire County Council to protect it as a golf course.
In view of the work involved in analysing the many SADPD documents CVAG has co- operated with another action group, the Northern Arc Action Group (NAAG) on those areas of common concern, such as the flaws in the consultation process, the conflicts with the core strategy, the lack of infrastructure planning etc. Those common areas of the report will also be included in the submission from NAAG and are clearly identified in both to spare the inspector from having to read the same analysis twice.
CVAG would like the opportunity to meet with the inspector and answer any questions which may arise from this submission. Since a number of people have been involved in the preparation of this document, we would like to be able to nominate the most appropriate person for each topic the inspector wishes to discuss.
Conclusion
Sustainable. Adj. Able to be sustained, conserving an ecological balance by avoiding depletion of natural resources. Concise Oxford English Dictionary, 2011
It follows that sustainable development should be that which avoids, or at least minimises, destruction of scarce natural resources. Having read through this document the Inspector will have seen how BFC planners have ignored National Policy, (both current and emerging), Local Policies, the advice of the statutory bodies responsible for infrastructure delivery, and most importantly, the expressed wishes of the residents who responded at the various stages of “consultation.”
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Crowthorne Village Action Group, response to Bracknell SADPD. 7 March 2012
They have produced a plan which proposes building in an area of historic significance, the destruction of thousands of trees and the loss of a popular recreational facility, all of which, once lost, can never be replaced: a plan which compromises the separate identity of Crowthorne and other the villages around Bracknell.
It is not legally compliant, not justified and not based on sound and credible evidence.
We urge the inspector to reject this SADPD, send it back to the planners with unequivocal instructions that it be revised to produce a sustainable plan for continued growth in Bracknell Forest: One which we may be proud to hand over to future generations, one which respects the original priorities which Bracknell Council felt compelled to drop on the evening that they accepted this SADPD;
Priority 2: Protecting and enhancing our environment
To keep our parks, open spaces and leisure facilities accessible and attractive To promote sustainable housing and infrastructure development Keep Bracknell Forest clean and green Priority dropped by BF Council, November 2011
The Committee of Crowthorne Village Action Group
John Baster Francis Reilly Steve Bolton John Buckle, chairman Carole Doran, secretary Graham Elliott Suzanne Hines Andy Holley Eddie Lyne James O‟Meara Barrie Searle Len Watkins
With thanks to the members of CVAG and the Northern Arc Action Group who collaborated with us, sharing the load in the analysis of the SADPD documentation.
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Crowthorne Village Action Group, response to Bracknell SADPD. 7 March 2012
Policy SA4 (Broadmoor Area) is fundamentally unsound
Submission
Broadmoor Hospital (policy SA4), built in the 1860s and one of three high-security psychiatric hospitals in England, is an important part of Crowthorne‟s heritage and a significant local employer. We recognise the need to redevelop to provide modern fit for purpose buildings for the care of these patients. The concern arises from the need to partially fund this new hospital by selling land for redevelopment. This policy, SA4, which provides for 210 residential units and 60 retirement apartments, should be viewed in context of the existing permission for 100 homes at Cricket Field Grove and 18 homes at School Hill. The overall total will then be 388 homes, in addition to a care home and small research park.
The building and gardens are historically significant.
The area in its entirety is covered by the Historic Park and Garden designation (Grade II). National policies exist to protect such areas. Development should only be permitted in exceptional circumstances.
In October 2011 the Victorian Society included Broadmoor in a list of the country‟s 10 most endangered Victorian buildings.
This proposal is not compliant with National policy.
Adjoining Special Protection Area
This site is surrounded on 3 sides by the Thames Basin Special Protection Area (SPA). The Thames Basin SPA is home to three rare species of ground nesting birds - the Dartford Warbler, Nightjar and Woodlark. In order to protect these, the Government has designated the 'Thames Basin Heaths' as a special protection area (SPA) under the EC Birds Directive and placed mitigation zones around the heaths to lessen the impact of human activity on them.
As required the proposal leaves a 400m buffer between the site and the SPA boundary and a Site Alternative Natural Greenspace (SANG). However since the SPA, which is an attractive mixture of woodland and open heath is so close by, it is essential that, for any SANG to be effective, it must be more attractive than the adjacent woodland, otherwise people will, by choice, prefer to use the SPA for their recreation.
Risk of Non-compliance with European Directive on Birds.
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Crowthorne Village Action Group, response to Bracknell SADPD. 7 March 2012
Poor choice when compared to alternatives
The original survey of Broad Areas ranked Broadmoor 6th out of 8 for accessibility/transport with a score of -1. It was noted that enhancements were required to existing facilities to ensure a sustainable community, provide sports facilities and primary healthcare.
Core strategy CS1 which states that "Development will be permitted which....is located so as to reduce the need to travel".
Not compliant with Local Policy Not supported by robust and credible evidence
Unsupported by Infrastructure improvements
The development relies on infrastructure improvements over which the Council has no control and which are highly unlikely to be forthcoming. In particular: a) Roads and access to motorways b) Schools c) Utilities d) Health facilities e) Public transport
Not supported by robust and credible evidence
In conclusion, the selection of Broadmoor for major additional development is not the most appropriate strategy when considered against the alternatives. If residential building is to be permitted it should be carefully restrained to minimise impact on both the historic gardens and the surrounding SPA.
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Crowthorne Village Action Group, response to Bracknell SADPD. 7 March 2012
Supporting Evidence
The building and gardens are historically significant.
Copyright The Francis Frith collection
The area is defined as having "significant landscape constraints" The area in its entirety is covered by the Historic Park and Garden designation (Grade II). National policy PPS5 exists to protect such areas. Intensive residential development would contravene the guidance in PPS5.
“Once lost heritage assets cannot be replaced and their loss has a cultural, environmental, economic and social impact. Significance can be harmed or lost through alteration or destruction of the heritage asset or development within its setting. Loss affecting any designated asset should require clear and convincing justification. Substantial harm or loss of a grade II listed building, park or garden should be exceptional.”
" there should be a presumption in favour of the conservation of designated heritage assets and the more significant the designated asset, the greater the presumption in favour of its conservation should be".
PPS5 Policy HE9.1
The Victorian society is a national society providing a focus for everyone interested in Victorian and Edwardian architecture and related arts. In 2010 they had 3,291 members. In October 2011, the society included Broadmoor in their list of the top 10 most endangered Victorian buildings in the whole country.
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Crowthorne Village Action Group, response to Bracknell SADPD. 7 March 2012 said Dr Ian Dungavell, Director of the Victorian Society;
“We are worried about the damaging effect of building so many new homes in this listed landscape', “
Ref: http://www.victoriansociety.org.uk/news/category/2011-top-ten/
Impact on SPA Broadmoor Hospital Site is situated in very close proximity to the Thames Basin Heaths SPA with part of the site within 400m of the SPA. The majority of the site lies within 400m of the SPA edge and it is difficult to envisage avoidance measures that can be employed to ensure that there will not be adverse impact on the SPA as Broadmoor is surrounded by the SPA on three sides. Mitigation measures, in this case, would be unlikely to afford adequate, and essential, SPA protection against encroachment by residents or their pets.
Poor choice against alternatives The choice of Broadmoor for the site of 400 houses conflicts with PPG13 since, according to the Council's own assessment, it has only fairly poor access to one bus route. It stated "The site is not considered to be well served by public transport and therefore the car is likely to be the preferred mode of transport". Since the Council has no means of ensuring that other means of public transport are provided this is unlikely to change.
In the sustainability appraisal Broadmoor ranked 6th out of 8 sites, scoring negatively against objectives 13 (conserve and enhance biodiversity) and 15 (travel choice.
It conflicts with CS1 which states that "Development will be permitted which...is located so as to reduce the need to travel".
It conflicts with CS2 since extensions to defined settlements are ranked 4th and last in priority and the previous 3 priorities have not been exhausted.
It conflicts with CS8 since existing sports facilities and amenity space will be lost.
Unsupported by infrastructure improvements
Traffic. The planned circa 400 dwelling Broadmoor development, the peak time traffic within the village could be estimated at a possible 400 to 600 extra vehicle movements adding to the congestion in the already overcrowded High Street and surrounding roads such as Dukes Ride and Waterloo Road.
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Crowthorne Village Action Group, response to Bracknell SADPD. 7 March 2012
The danger area for additional traffic from the planned Broadmoor development concerns the High Street/Sandhurst Road/Church Street/Lower Broadmoor Road junction. This junction will be further compromised by:
the planned Iron Duke development (16 dwellings) as the residents will have vehicular access at this point across a pedestrian pavement, which may result in drivers exiting and entering the development being distracted by pedestrian movement and not having full attention of other traffic. This also being adjacent to a bus stop. Crowthorne Fire Station which is also located close to this junction, and may require rapid and unpredictable access. Children who will be crossing this road at this point to attend Edgbarrow and Eagle House schools.
All the local roads are single carriage way and unsuitable for high volumes of traffic.
Pollution. Crowthorne High Street has already been measured to have levels of NO2 pollution above recommended levels, and this will be exacerbated by the extra traffic generated from SA4, Broadmoor and SA5, TRL. Whilst there are plans to monitor the situation there do not appear to be any credible plans to remedy the problem.
Education Crowthorne & Sandhurst Schools (BFC document School Places Plan 2007-2012)
Reference BFC document (9 School places Plan 2007-2012 Bracknell Forest Borough Council) http//community.bracknell-forest.gov.uk/school-places-2007-to-2012.pdf).
Secondary Schools – "There has been pressure on secondary school places in Crowthorne& Sandhurst for some time. Edgbarrow School is at capacity and forecasts over the next five years indicate a consistent 15% shortage of places. Likewise, Sandhurst School is forecast to be almost at capacity over the next five years and have a shortage of places by 2012".
Therefore school places are unsustainable. BFC is failing to support the current requirement let alone the capacity required to sustain the capacity required to support a planned increase of around 400 dwellings located at Broadmoor (the catchment area for Edgbarrow). In addition to smaller 'windfall' developments, in and around Crowthorne, such as the Iron Duke etc.
The SADPD is unsound in the case of secondary education.
Utilities Quoting from a 2011 planning application (PA 11/007984/FUL) for a 60 bed care home at 44 Sandhurst Road, which is in the Broadmoor area:
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Crowthorne Village Action Group, response to Bracknell SADPD. 7 March 2012
"Following initial investigation, Thames Water has identified an inability of the existing waste water infrastructure to accommodate the needs of this application. The development may lead to sewage flooding"
Note. This already occurs in Waterloo Road Crowthorne. During, even short, heavy rainfall, sewage backs up into toilet bowls, hand basins, baths and shower trays. Therefore it must be accepted that the sewage infrastructure would appear to be incapable of accommodating foul water from existing dwellings without the proposed planned Broadmoor development.
Therefore the sewage system must be regarded as unable to support an additional large scale development.
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Crowthorne Village Action Group, response to Bracknell SADPD. 7 March 2012
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.
Submission
Policy SA5 , the proposal to place 1,0000 homes on the site of the former TRL, would effectively eliminate the gap between Crowthorne and Bracknell, contrary to the adopted Core strategy 2008 which identifies this area as an strategic gap. Furthermore the overwhelming size of the proposed development means that this additional population could NOT be supported by Crowthorne village. BFC propose that new residents would have to travel to Bracknell for essential services such as Health and senior education. Effectively they will see themselves as part of the larger Bracknell urbanisation. This is also contrary to the core strategy which commits to preserving the individual identities of the villages.
This policy is therefore not legally compliant.
Placing a major development immediately on the 400m boundary surrounding the Thames Basin SPA will also raise issues. It has NOT been demonstrated that the proposed SANG is sufficient to mitigate against additional encroachment onto the SPA by residents and their pets.
Such a large development will place considerable additional load on the surrounding roads. It has NOT been demonstrated that adequate funding is available for sufficient improvements to mitigate this increased traffic. Therefore this policy is not justified as it is not founded on robust and credible evidence.
The site is a mixture of brownfield and mature woodland. The proposed policy covers most of the available site, and would necessitate removal of an estimated 20,000 mature trees. This is contrary to Sustainable Community strategy and the Core Strategy. Furthermore since BFC have not provided their own estimate of tree loss, the decision is not founded on robust or credible evidence.
We recognise that the TRL buildings are no longer used for its original purpose and the brownfield part of site is a prime candidate for redevelopment. The existing site is much larger than the built up area, with the remainder composed of mature woodland. CVAG have asked planners at BFC for an alternative scaled down proposal which involves building on just the brownfield element. This would have the additional benefit of reducing the additional load on surrounding infrastructure, including roads, health, education and fire brigade. BFC were unwilling to do this. Since the alternative has not been countenanced, BFC can NOT claim that “This is
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Crowthorne Village Action Group, response to Bracknell SADPD. 7 March 2012 the most appropriate approach when considered against the reasonable alternatives” and it is therefore not justified or sound.
It should be noted that in 2008, when opposing an similar application by Legal and General for 975 new homes on the same site, BFC themselves argued that, -it would seriously compromise the gap between Bracknell and Crowthorne
-it is too remote from main centres and too poorly served by public transport to be acceptable.
...., and at an appeal the inspector from the Dept of Planning agreed with them, rejecting the application. His comments echo and reinforce the concerns raised by CVAG to this proposal
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Crowthorne Village Action Group, response to Bracknell SADPD. 7 March 2012
Supporting Evidence
Loss of strategic gap, contrary to Core strategy.
The Core strategy was adopted in 2008, is a key component of the planning framework. The TRL site is clearly identified as being a strategic gap between Crowthorne and Bracknell. 119 One of the functions of the countryside is to help preserve the physical and visual separation of settlements by protecting the rural areas between them. The more effective of these areas, those which prevent the coalescence of significant settlements with particular identities, are called Gaps. The identification of Gaps is well supported by the local community as a method of preventing the erosion of the countryside and protecting the individual identities of settlements.
120 Bracknell Forest contains a number of distinct settlements separated by areas of open land. The Council attaches great importance to the function of these areas as a means of maintaining individual settlement identity. These predominantly undeveloped areas are often subject to development pressures which if left unrestrained could over time lead to the merging of settlements and the loss of individual identity. In order to protect their existing open and undeveloped character, it is important that gaps are identified to steer development away from those settlements where coalescence is a real threat.
( Bold added by author)
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Crowthorne Village Action Group, response to Bracknell SADPD. 7 March 2012
123 The following defined gaps were identified in June and July 2006 as part of a landscape assessment of the development submissions in the Borough undertaken as part of the Site Allocations DPD preparatory work:
Strategic Gaps:
Bracknell and Wokingham Crowthorne and Bracknell Sandhurst and Crowthorne Sandhurst and Yateley
The proposed 50 m boundary area is insufficient to constitute a meaningful gap. Indeed Bracknell Forest themselves recognise this when they say, in Table 4 of Appendix 2 of the Draft sustainability appraisal, Nov 2010;
Development of this site could allow for integration between Hanworth and communities off Old Wokingham Road, via the site. Therefore the option site could possibly look towards Bracknell Town Centre.
The suggestion that the SANG, which is to the East of the site, could help prevent coalescence with Bracknell, which is to the North, is rejected as geographically erroneous.
SAL51 para 3.95: However, by providing this land as SANG to mitigate the impact of the development upon the SPA, it is considered that potential issues of coalescence between Crowthorne and Bracknell can be reduced.
Therefore the identification of the TRL site as a “preferred Option” for development is directly in conflict with the core strategy and not legally compliant.
Unsupportable by Funded improvements to Infrastructure
A development of this size is totally unsupportable by any funded improvements to the infrastructure of Crowthorne.
Health. From SAL 50b Sustainability Appraisal , P21;
Good public transport access should be secured from development to the proposed health care facility in Bracknell Town Centre to effectively deliver primary health care services.
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Crowthorne Village Action Group, response to Bracknell SADPD. 7 March 2012
However overall health provision capacity is not clearly understood. This will be unclear until implementation.
Education Since there is no spare capacity at Edgbarrow school in Crowthorne, it is suggested that the secondary children will have to travel to Easthampstead park school in Bracknell. As well as requiring them to cross a busy road, their social network will focus on school friends, and this will further erode the independent identity of Crowthorne Village.
From SAL 50b Sustainability Appraisal , P22; Secondary Education
Financial contribution towards refurbishment of Easthampstead Park School.
Fire services SAL 34 Infrastructure Delivery Plan (IDP), pages 89/90;
RBFRS considers that any development in and around Bracknell will place additional burdens on its service which, subject to size and location, has the potential to become unsustainable however the inclusion of domestic sprinklers are considered by RBFRS to be an essential inclusion in all new domestic dwellings.
Sprinklers also affect utilities, requiring a minimum pressure of 2.5 bar at all times. This usually requires a larger than standard domestic main in order to guarantee the minimum pressure at all times. It is not clear if the consultee responsible for delivery of mains water, Thames Water, has been informed of this requirement.
The infrastructure delivery plan policy is not based on robust or credible evidence, and is therefore unsound.
Significant Loss of trees, contrary to Core Strategy and Sustainable Community Strategy.
The introduction to the Core Strategy, p30 states: The quality of the environment will continue to improve with the existing high levels of open space and ‘greenery’ within the settlements maintained and improved
The Bracknell Forest Sustainable Community Strategy states:
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Crowthorne Village Action Group, response to Bracknell SADPD. 7 March 2012
Preserving our green heritage will be key to the future development of the area, integrating environmental concerns into all activities.
SAL 51, Para 3.92 simply identifies this as a brownfield site whereas the reality is that the site is a mixture of previously developed land and mature woodland. The BFC case officer, in a report recommending refusal of a previous planning application on this site (07/01196/OUT), 22 May 2008, characterises the site as follows;
Pg 43 The majority of the site is presently countryside, mainly woodland.
Pg 44. Across the whole site nearly two thirds of the area does not contain buildings or permanent structures, and is presently open space, particularly in the east and south of the site. Only 5% of the site consists of buildings.
Therefore to simply describe it as a brownfield site is misleading. Nowhere in the extensive documentation produced by BFC were we able to find an estimate of the number of trees which would be lost if this development was permitted, which seems a strange omission, and perhaps an indication that they didn‟t want people to be aware. In response to an enquiry to the planning team we were told by email, 26 January 2011, (copy available if required) the following; TRL
- Trees that could be removed as result of development = 18.5 hectares
- Trees that could remain= 37.8 hectares
The Woodland Trust estimate that for wood planted every 3m, the density would be 1,100 trees per hectare. Ref : http://www.woodlandtrust.org.uk/en/planttrees/help-advice/planting- trees/pages/stocking-spacing.aspx
It is therefore estimated that the tree loss at TRL could be as high as 18.5 hectares x 1,100 = 20,350. This may be an overestimate and it would need a proper survey to verify the true figure. Nevertheless, it is certain that a significant number of trees would be lost.
Since this massive tree loss is contrary to the Core strategy and Sustainable Communities Strategy, it is not justified. Furthermore since BFC haven‟t calculated how many trees will be lost, it could be argued that the policy is not based on robust and credible evidence. Since this information is not contained in the initial sustainability appraisal evaluating the eight possible broad areas, those conclusions are not based on robust and credible evidence. Since the consultees, including the Executive, were not informed of the tree loss they were unable to take that into account in their decision, and the consultation is not legally compliant.
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Crowthorne Village Action Group, response to Bracknell SADPD. 7 March 2012
The Site is immediately adjacent to the Thames Basin Special Protection Area and the proposed mitigation is insufficient.
This site is immediately adjacent to the Thames Basin Special Protection Area (SPA). The Thames Basin Heath SPA is home to three rare species of ground nesting birds - the Dartford Warbler, Nightjar and Woodlark. In order to protect these, the Government has designated the 'Thames Basin Heaths' as a special protection area (SPA) under the EC Birds Directive and placed mitigation zones around the heaths to lessen the impact of human activity on them.
As required the proposal leaves a 400m buffer between the site and the SPA. It is proposed that this buffer area will also function as a Site Alternative Natural Greenspace ( SANG). However since the SPA, which is an attractive mixture of woodland and open heath is so close by, it is essential that, for any SANG to be effective, it must be more attractive than the adjacent woodland, otherwise people will, by choice, prefer to use the SPA for their recreation. In response to the previous round of consultation Carrie Temple of the RSPB said;
In this respect, the RSPB would like to emphasise our serious concerns for Broad Area 2 – Broadmoor, and Broad Area 3 – North East Crowthorne. Both of these sites are partly within the Thames Basin Heaths 400 metre ‘exclusion zone’ and entirely within the 5km ‘zone of influence’. Significant additional housing in these locations could result in a large increase in visitor numbers to the Thames Basin Heaths SPA and other potential urban impacts, such as cat predation, fire and fly-tipping. It will be extremely difficult to avoid or mitigate these potential impacts at such close proximity to the SPA. The RSPB has previously objected to a mixed-use application on part of the area referred to as Broad Area 2. As you will be aware, the Society appeared at the subsequent public inquiry, alongside the Council, Natural England and the Wildlife Trust, and successfully defended that objection.
In March 2009 When evaluating an appeal on a similar application at this site (975 homes) the Inspector appointed by the Secretary of State for Communities and Local Government, Phil Grainger, stated;
688. In forming my own view on this matter I have taken into account the general acceptance that increased urbanisation close to the SPA can have harmful effects. Moreover, the appeal scheme is a large development and is just about as close to the SPA as it could be. In line with the Dilly Lane judgement [NE/2 A1] I have had regard to the mitigation measures proposed. However, I have also noted that all the experts, other than the appellants’ own, who have considered the AMS have concluded that it is unsatisfactory. That includes Natural England (NE) who are the statutory advisors on SPA matters
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709. In any event, I am far from convinced that even if the proposed SANGs is regarded as being in excess of the size that is required that would in practice provide any real ‘headroom’, capable of compensating for any qualitative shortcoming
Since nothing significant has changed it is considered that there is insufficient mitigation, which is in contravention of the EC Birds directive and the proposal is not legally compliant.
Not Taken into account community feelings, contrary to “Statement of Community Involvement”
The Statement of Community Involvement states that BFC will
“give all people the opportunity to be engaged in the local planning process which shapes the environment of Bracknell Forest Borough.”
4.1 To help deliver this vision, it is hoped that the SCI will:
Enable the Council to hear, understand and reasonably act upon the concerns important to people in preparing Local Development Documents and dealing with planning applications
When BFC held an information meeting at the Morgan Centre in November 2010, the officials said they were not collecting comments from residents attending.
So that the public response could be recorded, CVAG conducted an exit poll, which was completed by over 400 residents. This found that regarding the proposals for TRL, only 2% of those surveyed thought that that the proposal was good for Crowthorne. More than 90% felt they were NOT a good idea for Crowthorne
A request by CVAG for an alternative proposal for TRL with building restricted to the currently built up area was submitted in 3 Sept 2011. This was dismissed out of hand by BFC planners merely saying that they “noted our objection”. A copy of request and response is available on request.
It is evident that BFBC has not listened to the concerns of its residents in relation to the TRL site, nor been willing to countenance reasonable alternative suggestions which they have put forward. This statement alone makes it quite clear that BFBC had no intention whatsoever of making any adjustments to the SADP, which makes the process both non-compliant and unsound.
This statement of community involvement has not been complied with , which makes the policy NOT legally compliant.
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Previous application rejected by BFC.
BFBC has done a U-turn. In 2007 it refused an application for 975 houses and now proposes a very similar plan for a slightly higher number of homes. The outline planning application submitted by Legal & General in 2007, 07/01196/OUT, and refused by BFBC, is pertinent to the proposals now put forward by BFC.
The proposal was described by the appeal Inspector in his dismissal report to the Secretary of State as follows:
As well as 975 dwellings the proposal would include ancillary local shops and offices, a primary school, a community hall, health and fitness centre and healthcare centre, a business park, 80 room hotel and gym.
The following is an extract from the Crowthorne Urban Extension Profiles dated November 2010 and sets out the proposals in relation to development of the TRL site (the full detail is in Policy SA5):
“Policy SA5 proposes land at the Transport Research Laboratory (TRL), Crowthorne for a development including 1,000 new homes (including some affordable housing); a local centre along Old Wokingham Road; a new primary school, a care home, an enterprise centre for small and new businesses, and a relocated Council depot site.”
SAL49, Map 2.38 Draft Submission Concept Plan for TRL
07/01196/OUT, Site master plan
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It is evident that the two are very similar in terms of housing numbers, school and ancillary facilities, with the possible exception that the L&G plan included a business park. The number of residents, the surface area covered etc is all comparable.
Since the proposals are comparable, the statements made by the case officer in recommending refusal are still relevant.
Ref: 07/01196/OUT Pg 43 The proposed development would require the felling of 34 ha of coniferous plantation, and would introduce major built development into parts of the site that are presently undeveloped, principally east of the TRL building and also in the south west corner where the housing development would extend into the forests enclosed by the now disused southern test track.
Pg 44 In view of this the proposed development is considered to be harmful to the character and function of a strategic gap, and as such is contrary to Structure Plan Policy DP7 and Core Strategy Policy CS9.
Pg 49 The proposed development would introduce major built development on large areas of open land, requiring the loss of many trees and changing the character of these open parts of the site from extensive forest into an urban neighbourhood, with built development and associated roads, car parks and other infrastructure (both on and off site) essential to a large urban area. This process of urbanisation is considered to be harmful to the character and appearance of these parts of the site, contrary to Local
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Plan Policies EN8 and EN20.
Pg 56 In conclusion this application proposes a major mixed use development in an area of countryside outside of any defined settlement. It also lies within a strategic gap separating the settlements of Bracknell and Crowthorne. It is considered that this development would prejudice the delivery of the Council’s recently adopted core strategy and would constitute unsustainable development within a relatively remote area that is poorly served by public transport.
Pg 56 At the local level this development is considered to be inappropriate and harmful to, the character, appearance and function of this countryside location and to the strategic gap between Bracknell and Crowthorne.
At a subsequent appeal the inspector appointed by the Secretary of State upheld the refusal. The SADPD inspector is encouraged to read the whole report by the Inspector, Phil Grainger BA(Hons) MRTPI, dated 17 March 2009. Following are selected excerpts which highlight his concerns about development of this site.
766. The Council consider that the appeal proposal would seriously compromise the existing gap between Bracknell and Crowthorne. Whatever view is taken of whether the site constitutes PDL,230 its appearance is far removed from the typical image of such land. Relatively little is covered by buildings and, apart from the new TRL headquarters, most of these are concentrated in one area – that known as the Crowthorne Business Estate (CBE). Moreover, most of the site is densely covered by evergreen trees, restricting views from outside the site of such buildings as do exist, and there is no public access into it.
776. For all these reasons I consider that not only would the extent of buildings (as opposed to hardsurfaces) on the site increase substantially but the perception of the site as being built-up would also increase very noticeably. In my judgement, as well as a substantial reduction in the physical gap between Bracknell and Crowthorne the perception of such a gap would also be seriously compromised if the appeal scheme went ahead.
784. Turning to transportation and sustainability matters, despite their concerns regarding coalescence the Council consider that the site is too remote from main centres and is too poorly served by public transport to be an acceptable location for development on the scale proposed. [306-309] Wokingham BC (WBC) take a similar view.
921. The proposal would also be harmful in some other respects. In particular, I consider that it would seriously detract not only from the gap between Bracknell and Crowthorne
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Crowthorne Village Action Group, response to Bracknell SADPD. 7 March 2012 but also the impression of that gap. This reinforces the conflict with various locational policies of the development plan including CS Policy CS9. This seeks to protect land outside defined settlements for its own sake, but, more specifically, also aims to protect gaps from development that would harm the physical and visual separation of settlements.
922 a . In addition, it is agreed that without improved bus services the site would not be sustainable location for development on this scale.
933. Overall I conclude that, although the provision of housing (both market and affordable) is a matter capable of counting strongly in favour of the proposal, it does not justify the form of development proposed which, in my judgement, would be seriously and unnecessarily harmful to the SPA and to the gap between Crowthorne and Bracknell.
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The following sections were produced in collaboration between Crowthorne Village Action Group and the Northern Arc Action Group.
There will therefore be some replication between both groups’ submission.
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Major conflicts with adopted Core Strategy make Bracknell Forest's development plan unsound
Submission
Bracknell Forest Council's Draft Submission SADPD contains a whole raft of conflicts with its approved Core Strategy which was approved by the Secretary of State following a public examination by an independent inspector.
While accepting as reasonable that some minor conflicts with the Core Strategy may be unavoidable, we contend that there are far too many and that some of them present major contradictions to approved policy, thereby making the SADPD fundamentally unsound and not legally compliant.
A key issue of conflict for local residents concerns CS9. All three SADPD sites at SA5, SA6 and SA7 were designated by the Council in its Core Strategy as defined gaps between settlements needing protection from development that would harm their physical and visual separation (paragraph 124, i). Such flagrant dismissal of its own Government approved policies undermines the whole process and leads to the inescapable conclusion that these proposals are developer-led.
The other most significant conflicts apply to the urban extensions proposed in Draft Policies SA4, SA5, SA6 and SA7 (Broadmoor, TRL, Amen Corner North and Blue Mountain) as follows:
CS1 – These four sites are not sustainable because they all increase, not reduce, the need to travel (paragraph 55, ii), due to their location as extensions to settlements. Development at Blue Mountain, in particular, will be less sustainable, not more sustainable, because a secondary school to serve the whole north Bracknell expansion area will be located there - the maximum distance for the maximum number of pupils to travel as only 400 homes will be located next to it, but pupils from up to 4,825 homes could use it. We contend that the school should be located on a more sustainable site, with the minimum travel distance for the maximum number of pupils.
CS2 and CS3 – in the Council's priorities for development land allocation, Bracknell town centre is top priority as the most sustainable option, and the proposed urban extensions (largely greenfield sites outside existing settlements) are lowest priority. But only 10% of new housing in the SADPD
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is proposed for the town centre, and the lowest development priority areas are given top priority in the delivery sequence.
CS6 – Policies SA5, SA6, SA7 and also SA9 will have a significant cost to the quality of life for future generations through substantial destruction of countryside which is a key attraction for residents. The cost includes 3,000 new homes on green fields, plus another 1,000 mainly on woodland, all of which will be destroyed forever and lost to future generations. We contend this cost is far too high.
Policies SA1 – 9 will have a massive combined impact on the infrastructure, despite mitigation attempts. Traffic generated by these and a further 4,000 homes planned nearby in Wokingham will be using the same road network, resulting in longer journey times, potential for gridlock at key junctions and consequent impact on air quality. Health and education provision will be strained to the limits. All will have a negative impact on the quality of life for future generations, and all are dependent on delivery by developers, whose local record to date has been poor.
Regarding paragraph 86.2 of CS6, an “education village”, especially a large secondary school, is not in proportion to the scale of development of 400 houses proposed at Blue Mountain. Similarly, the siting at Blue Mountain of a new football ground for Bracknell Town FC, including a 3,500 capacity stadium, is out of proportion to the scale and nature of housing proposed in Policy SA7. It is not needed to serve the development because Binfield is already well provided with two other football clubs and successful academies for children and youths.
CS7 and CS8 – The development proposed at Blue Mountain (SA7) would destroy a great deal of existing highest quality usable open space (CS7, paragraph 95, vi), and the minimal amount proposed in mitigation cannot compensate for this loss to the community.
Paragraph 105 of CS8 promises to protect existing recreational facilities from pressures from development that might result in their loss to the community. The proposal to close a popular public pay & play golf course, golf academy, driving range, and a large banqueting and events/community centre (concerts, dinner dances, exercise classes, social clubs, auctions, exhibitions, wedding parties etc), together with an informal recreation area for jogging, dog walking, etc, in favour of a football ground neither wanted nor needed by the village is a direct contradiction of this policy, as are other developments proposed there.
Binfield already hosts two major football clubs and academies: Binfield FC and FC Bracknell. Alternative sites for Bracknell Town FC have been suggested at
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Downshire and at Jennetts Park but neither appears to have been adequately considered by the Council.
CS4, CS5 and CS15 - between them these three Core Strategy policies indicate that development at Amen Corner South and Warfield, together with other development already planned when the Core Strategy was adopted in 2008, will deliver 11,139 net dwellings up to 2026, and that therefore additional sites - such as the four urban extensions included in SADPD policies SA4, 5, 6 and 7 – will not be required to meet the Council's SADPD housing target of 10,780.
Supporting Evidence
Policy CS9
The introduction to the Environment section in the Core Strategy states that one of the functions of the countryside is to help preserve the physical and visual separation of settlements by protecting the rural areas between them, and that the more effective of these are called gaps. Proposing substantial developments on SADPD sites SA5, SA6 and SA7 is a clear contradiction of this CS policy. Paragraph 123 below demonstrates that these sites were adopted as gaps in the Core Strategy:
123 The following defined gaps were identified in June and July 2006 as part of a landscape assessment of the development submissions in the Borough undertaken as part of the Site Allocations DPD preparatory work:
Strategic Gaps: Bracknell and Wokingham; Crowthorne and Bracknell;
Local Gaps:
Bracknell and Binfield
In paragraph 124, the Council reaffirms its intention to protect such land from development:
Policy CS9 – Development on Land Outside Settlements
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Crowthorne Village Action Group, response to Bracknell SADPD. 7 March 2012
124 The Council will protect land outside settlements for its own sake, particularly from development that would adversely affect the character, appearance or function of the land; and
i. protect the defined gaps within or adjoining the Borough from development that would harm the physical and visual separation of settlements either within or adjoining the Borough
The independent inspector who conducted the public examination into the Draft Core Strategy endorsed this strategy in her report, prior to recommending its adoption, saying:
Paragraph 35: “I agree there is a need to protect the setting and identity of settlements and avoid their coalescence.”
Regarding the area around Blue Mountain, she said:
Paragraph 122: “I accept that it is important to retain the openness of the area, particularly in the light of the CS5 urban extension. Furthermore, it would be desirable to retain the settlement pattern, such as it exists, to prevent further coalescence.”
'Vision to 2026' Introduction to Core Strategy
Even the aspirations of the 'Vision TO 2026' introduction to the Core Strategy are in conflict with SADPD policies SA4, SA5, SA6 and SA7 in that these are not sustainable locations, they all increase the need to travel for daily needs, there is no choice of public transport modes from them, and they will result in a deterioration of the environment, not an improvement, due to high use of existing open space and 'greenery' in the plans:
24 The Borough will continue to grow sustainably, in a planned manner, with new development being directed to sustainable locations and having good access to a range of local facilities, services, housing and employment. New development will be located so as to maximise the opportunity to travel by all modes and to improve relative accessibility for all. New development will be mindful of the
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character of the area in which it sits and will be designed and located such that it will enhance the quality of life in the Borough.
29 The smaller town, village and neighbourhood centres will be maintained and enhanced to play a valuable role in providing local services and reducing the need for local people to travel for their day to day requirements.
30 The quality of the environment will continue to improve with the existing high levels of open space and ‘greenery’ within the settlements maintained and improved
Policy CS1
The sustainable development principles incorporated in this are laudable but the actual policies proposed at SA4, 5, 6 and 7 do not achieve the principles in so much as natural features of the borough are harmed and the developments are not located close to a range of services and facilities, so they do not reduce the need to travel
Policy CS1: Sustainable Development Principles 55 Development will be permitted which; i. makes efficient use of land, buildings and infrastructure; and ii. is located so as to reduce the need to travel; and Protects and enhances: vi. the health, education and safety of the local population; and vii. the quality of natural resources including water, air, land and biodiversity; and viii. the character and quality of local landscapes and the wider countryside; and ix. the historical and cultural features of acknowledged importance.
The Blue Mountain (SA7) development will be significantly less sustainable, not more sustainable, because the proposed secondary school is principally intended to serve the other major developments at SA9 (2,200 homes at Warfield) and SA8 (725 homes at Amen Corner South), as well as SA6 (400 homes at Amen Corner North), together no doubt with a proportion of pupils from the 1,500 homes being built at Jennetts Park who will opt to go to a new school at Binfield rather than to their designated school, Easthampstead Park. This means pupils from up to a total of 4,825 new homes in surrounding development areas will converge on the small area of SA7.
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Bus is the only public transport option so heavy car traffic will inevitably be generated, via only one access roundabout at Binfield Rd/Temple Way from Warfield, and the Farley Hall roundabout from the Western development areas. This section of the Northern Distributor Road is likely to become gridlocked in the morning rush hour when business traffic in and out of Bracknell compounds the problem.
It should be noted that the 2,200 homes planned at Warfield will be close to Garth Hill College, currently the designated secondary school for that area as well as Amen Corner South. Locating a new secondary school in the western development area would be considerably more sustainable in travel to school terms and would release pressure at Garth Hill by removing the Amen Corner South pupils.
Although the Council has not offered any, there are alternative site options and secondary school provision should be included in the area of minimum need to travel for the maximum number of pupils. Bracknell Forest Council should be encouraged to co-operate with Wokingham Borough Council in jointly delivering an “education village” in their west/east border area, as Wokingham has approved plans to build a further 4,000 homes close to the border with SA6 Amen Corner North (previously known as Binfield West), SA8 Amen Corner South and Jennetts Park.
Policy SA4 (Broadmoor), which proposes building in the curtilage of a Grade II listed building and on the historic kitchen garden is most certainly not compliant with:
Protects and enhances: vii. the character and quality of local landscapes and the wider countryside; and ix. the historical and cultural features of acknowledged importance.
Nor with paragraph 49 of the Sustainable Growth Introduction to Policy CS1:
49 In addition there are a number of features of historic and archaeological interest including over 250 listed buildings. The Council will continue to protect its listed buildings, conservation areas and historic parks and gardens.
Policy CS2 and CS3
Paragraphs 62 and 71 of the Core Strategy below clearly set out the Council's priorities for development land:
62 The Council will allocate land for development in the sequence set out below:
1 Bracknell Town Centre;
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2 Previously developed land and buildings in defined settlements; 3 Other land within defined settlements where this does not conflict with other policies; 4 Extensions to defined settlements with good public transport links to the rest of the urban area or with firm proposals to provide such links.
An appendix on page 53 sets targets for monitoring compliance with CS2: Local Indicator: Percentage of new and converted dwellings within urban areas (defined settlements) (CS1) 95%.
71 ….... major development in the first instance should take place within Bracknell town centre as the most sustainable option.
These policies clearly state that Bracknell town centre is top priority as the most sustainable option, and the proposed urban extensions (largely greenfield sites outside existing settlements) are lowest priority. But, despite there being 1.5million sq ft of unused office space in the Bracknell area, only 10% of new housing in the SADPD is proposed for the town centre, and the lowest development priority areas are given top priority in the delivery sequence. Furthermore, none of the urban extensions proposed by the Council have good public transport links to the rest of the urban area, particularly at times of low demand.
The proposed urban extension at TRL (SA5) on its own comprises nearly 10% of the new housing and immediately places the council in breach of its own compliance metric.
Policy CS6
The 'Quality of Life' introduction to CS6 states:
“Development which is truly sustainable ensures that the quality of life we enjoy today does not come at a cost to the quality of life for future generations”.
SA 5,6,7 and 9 will have a significant cost to the quality of life for future generations through substantial destruction of countryside which is a key attraction for residents. The cost includes 3,000 new homes on green fields, plus another 1,000 mainly on woodland – a considerable amount of local countryside which will be destroyed forever and lost to future generations.
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Placing two major urban extensions, SA4 Broadmoor and SA5 TRL, immediately adjacent to the Thames Basin Special Protection Area places increased risk on the SPA, which is protected by a European Directive.
Limiting the Impact of Development 85 1. Development alone or in-combination with other proposals, will contribute to the delivery of infrastructure needed to support growth in the Borough and will mitigate adverse impacts on communities, transport and the environment.
SA1 – 9 will have a massive combined impact on the infrastructure, despite mitigation attempts. Traffic generated by these and a further 4,000 homes planned nearby in Wokingham will be using the same road network, resulting in longer journey times, potential for gridlock at key junctions and consequent impact on air quality. Health and education provision will be strained to the limits. All will have a negative impact on the quality of life for future generations, and all are dependent on delivery by developers, whose local record to date has been poor.
86 2. Where those occupying development would lead to increased pressure on local infrastructure, community facilities or resources, that impact is to be met by: …...... infrastructure & facilities, reasonably related and needed to serve the development and which will make it more sustainable. The additional provision to be sufficient and in proportion to the scale and nature of the proposed development.
An “education village”, especially a large secondary school, is not in proportion to the scale of development of 400 houses proposed at Blue Mountain. Similarly, the siting at Blue Mountain of a new football ground for Bracknell Town FC, including a 3,500 capacity stadium, is out of proportion to the scale and nature of housing proposed in Policy SA7. It is not needed to serve the development because Binfield is already well provided with two other football clubs and successful academies for children and youths. Bracknell Town FC is currently in grave danger of being relegated at the end of this season, which would be likely to reduce their crowd of supporters at home matches, understood to be typically less than 100 at present.
Policies SA4 (Broadmoor), SA5 (TRL) and infill sites add 1,400 homes to the village of Crowthorne, which is currently around 6,000 homes. Similarly, policies SA6, SA7, SA8 and infill sites add about 1,700 homes to the village of Binfield which presently has 3,555 homes. At no stage is there any suggestion that measures will be taken to ensure:
The additional provision (of infrastructure and facilities) to be sufficient and in proportion to the scale and nature of the proposed development.
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Policies CS7 and CS8
Under CS7 (Design) the Council makes the following statement in paragraph 95:
Development proposals will be permitted which: vi, provide high quality usable open spaces and public realm
The development proposed at Blue Mountain (SA7) would destroy a great deal of existing highest quality usable open space, and the minimal amount proposed in mitigation cannot compensate for this loss to the community.
Paragraph 105 of CS8 promises to protect existing recreational facilities from pressures from development that might result in their loss to the community.
105 Inherent in the Council’s strategy is that existing Recreational Facilities are to be retained and that the Council will resist the loss of existing provision. Policy CS8 contains provisions that will protect existing Recreational Facilities from pressures from development that might result in their loss to the community.
The proposal to close the popular and successful Blue Mountain public pay & play golf course, golf academy, driving range, and a large banqueting and events/community centre (concerts, dinner dances, exercise classes, social clubs, auctions, exhibitions, wedding parties etc), together with an informal recreation area for jogging, dog walking, etc, in favour of a football ground neither wanted nor needed by the village is a direct contradiction of this policy, as are other developments proposed there.
Policy SA5 (TRL) also entails the loss of an existing sports and tennis facility at the TRL, with no suggestion that it should be replaced.
The 'Major Locations for Growth' introduction to Policies CS4 and CS5, and Policy CS15
Together these detail the Council's strategy for dealing with housing growth requirements and locations up to 2026. Introducing Policies CS4 and CS5, paragraph 73 states:
73 Studies indicated that not all of the future growth requirements would be met within the existing settlement boundaries. Having regard to the above, the approach taken in the long-term strategy is to meet the remaining growth requirements by concentrating development outside the existing settlement
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boundaries in two large-scale, mixed-use, mixed density developments as set out in Policies CS4 and CS5 below.
74 The broad areas of land in each case will be identified on a Proposals Map in accordance with more detailed proposals to be set out in subsequent Development Plan Documents and Area Action Plans. Policy CS15 ‘Overall Housing Provision’ identifies the number of houses that the Borough must plan for up until 2026. Supporting paragraphs 175 to 179 identify the role of these sites in meeting this requirement. This identifies that about 725 homes will be provided at Amen Corner and about 2,200 homes will be provided at land north of Whitegrove and Quelm Park.
Policy CS15, paragraphs 175, 176 and 177 detail where and when the planned houses will be delivered. Paragraph 180 says:
180 Over the period 2006 to 2026 the Council will make provision for the phased delivery of 11,139 net dwellings.
In neither section does it suggest that additional sites - such as the four included in SADPD Policies SA4, 5, 6 and 7 – may be required to meet this target, so they were clearly not necessary. The urban extensions now proposed at Broadmoor, TRL, Amen Corner North and Blue Mountain are conspicuous by their absence from the Core Strategy, which made adequate land provision to meet more than the current housing target of 10,780.
.
Additional SADPD conflict with Council's Priorities and
Medium Term Objectives.
While not included in the Core Strategy, it should nevertheless be noted that the Council's Priorities and Medium Term Objectives (2011-2015) were amended by the full Council on 30 November 2011, immediately before the vote to adopt its Draft SADPD for submission to the Secretary of State. Before this amendment there would have been a basic conflict between the original wording Of Priority Two of the Six Over-arching Priorities and SADPD policies SA5, SA6 and SA7.
Priority Two: Protecting and enhancing our environment, was changed as follows:-
Deleted To keep our parks, open spaces and leisure facilities accessible and attractive To promote sustainable housing and infrastructure development 38 | P a g e
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Inserted Protect communities by strong planning policies
It is highly questionable why councillors should replace commitment to two fair and sound priorities (which protect Blue Mountain, Amen Corner North and the TRL) with one which seems implicitly designed to favour developers.
A full detailed list of SADPD Conflicts with the Core Strategy follows:
Policies SA4 (Broadmoor, Crowthorne), SA5 (TRL, Crowthorne), SA6 (Amen Corner South), SA7 (Blue Mountain) - also SA8 (Amen Corner South) and SA9 (Warfield) but these are already adopted Conflict with "Vision to 2026" introduction to the Core Strategy, paras 24, 29, 30, 46 Issues: they are NOT "sustainable locations" because they all INCREASE the need to travel, not reduce it NOT "mindful of the (rural) character" of all areas except SA8 "Quality of environment" will DETERIORATE not improve due to high use of existing open space and greenery in the plans
POLS SA 4, 5, 6, 7 Conflict with CS1, para 55 (ii) Issue: "Located so as to reduce the need to travel" All these policies will increase, not reduce, the need to travel due to their location as extensions to settlements. They are not sustainable for this reason.
POLS SA 4, 5, 6, 7 Conflict with CS2, para 62 Issue: BFC's development land allocation priorities
Although the areas in these policies are lowest in BFC's priority sequence, they contain the majority of the new homes proposed in the SADPD (2,070 out of 3,896 homes identified in 2.1.3 Table 2. NB - this is 432 more than the 3,464 remaining to be found out of the 10,780 target in 2.1.3 Table 1). Only a total of 1,676 homes in POLS SA 1, 2, 3 are located in BFC's top three priority areas.
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Crowthorne Village Action Group, response to Bracknell SADPD. 7 March 2012
The top priority, Bracknell Town Centre, is not included in any new housing policy, although it is assumed the circa 1,000 units with outline planning permission are included in Table 1.
POLS SA 4, 5, 6, 7 Conflict with CS3, para 71 Issue: Bracknell Town Centre role as a housing location CS3 reiterates BFC's priority in CS2 to focus development within settlements and "major development in the first instance should take place within Bracknell town centre as the most sustainable option." But the housing plans for the town centre represent less than 10% of the 10,780 target, although this is BFC's stated top priority, thus failing to meet Core Strategy objectives CS2 and CS3. In the initial SADPD consultation in Feb - April 2010, 73% of respondents opted to increase the town centre housing target, but this has been totally ignored by BFC.
POLS SA 4, 5, 6, 7 Conflict with the introduction to CS4 and CS5, para 73 Issue: "Remaining growth requirements" Para 73 indicates the remaining housing need up to 2026 can be met by concentrating development outside existing settlement boundaries in two large-scale developments: CS4 (Amen Corner South), and CS5 ((Warfield) - now in the SADPD as POLS SA 8 and 9. Therefore, there should be no need for further urban extensions in POLS SA 4, 5, 6, 7.
POLS SA 5, 6, 7, 9 Conflict with the Quality of Life introduction to CS6, para 81 Issue: Quality of life....."Development which is truly sustainable ensures that the quality of life we enjoy today does not come at a cost to the quality of life for future generations." SADPD POLS SA 5, 6, 7, 9 will have a significant cost to the quality of life for future generations through substantial destruction of countryside which is a key attraction for people living in the borough. The cost includes 3,000 new homes on green fields (POLS SA 6, 7, 9), plus another 1,000 on woodland (POL SA 5). This is a profligate use of green sites when 1.5 million sq ft of empty buildings in Bracknell town centre could be efficiently re-used for housing. A significant amount of local countryside will be destroyed forever and lost to future generations. The cost is too high.
POLS SA 1-9 will all have a combined massive impact on CS6, para 8 Issue: "Limiting the impact of development"
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Crowthorne Village Action Group, response to Bracknell SADPD. 7 March 2012
The most significant impact will be on the strategic and local roads network, especially when taken in conjunction with the 4,000 new homes to be built nearby in north and south Wokingham, using the same existing road systems as the 4,119 new homes planned in the northern arc of Bracknell Forest, and the 1,467 planned in Crowthorne.
POL SA 7 Conflicts with CS6, para 86.2 Issue: Para 86.2 addresses on and off site infrastructure provisions and contributions for "Infrastructure and facilities, reasonably related and needed to serve the development and which will make it more sustainable. The additional provision to be sufficient and in proportion to the scale and nature of the proposed development."
An "education village", especially a large secondary school, is not in proportion to the scale of development of 400 houses at Blue Mountain. The development will be significantly less sustainable, not more sustainable, because the secondary school is principally intended to serve the major developments at SA9 and SA8, plus SA6 and probably a proportion of Jennetts Park – a total of 4,825 new homes in surrounding areas.
Similarly, the siting at Blue Mountain of a new football ground for Bracknell Town FC, involving a 3,500 capacity stadium, is out of proportion to the scale and nature of housing development proposed in POL SA7. It is not needed to serve the development because Binfield is already well provided with two other football clubs.
POL SA5 Conflicts with CS7, para 95 Issue: " Development should respect local patterns of development." The high density of housing proposed at TRL does not appear compatible with current local densities.
POL SA7 Conflicts with CS7, para 95 (vi) Issue: "Provide high quality open spaces." The development proposed at Blue Mountain would destroy a great deal of existing highest quality usable open space, and is therefore in total contradiction of this policy. The loss of this amount of open space cannot be compensated for by BFC providing the minimum requirement of open space and SANG.
POL SA7 Conflicts with CS8, paras 101, 105, 106 (ii), 107 (iii) and Concurs with 106 (i). Issue: "Existing recreational facilities are to be retained and the Council will resist the loss of existing provision."
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Crowthorne Village Action Group, response to Bracknell SADPD. 7 March 2012
BFC's proposal to close a popular existing golf course, banqueting and event centre and informal recreation area for jogging, dog walking etc, in favour of a football ground neither wanted nor needed by the local community is a direct contradiction of this policy. The golf course should be protected under CS8.
POLS SA 5, 6, 7 Conflicts with CS9, para 111 Issue: "Development in areas outside settlements is generally not well located in terms of services and facilities, and is generally poorly served by alternative transport modes. In these areas, new development ...... will be restricted to that which is necessary to meet the needs of farming and forestry, essential utilities, equine- related activities or other uses with an essential need for a rural location." Under this strategy and for these reasons, the locations in POLS SA 6, 7 and parts of 5 should not be re-designated as urban extensions and not included for development.
POLS SA 5, 6, 7 Conflict with CS9, paras 119, 120, 123, 124 Issue: the identification of gaps to steer development away from settlements where coalescence is a real threat. Paragraph 123 identifies Strategic Gaps between Wokingham and Bracknell at SADPD Site SA6; Crowthorne and Bracknell at SA5; and a Local Gap between Bracknell and Binfield at SA7. The Council pledges in paragraph 124 (i) to protect the defined gaps from development that would harm the physical and visual separation of settlements. To now include its designated gaps as urban extensions in the SADPD represents a gross flouting by the Council of its own Core Strategy which was approved by a Government Inspector following a public inquiry.
POLS SA 4, 5, 6, 7 Conflict with CS15, paras 175, 176, 177 Issue: Overall Housing Provision figures shown for the period 2006 – 2026, totalling 11,139 net dwellings, foresee no requirement for building at the TRL, Amen Corner North or Blue Mountain. They should be dropped from the SADPD proposals on this basis.
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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
Submission
In setting the context of Bracknell Forest Council's plans, the introduction to the SADPD states:-
1.2.2: The SADPD has been prepared having regard to existing and emerging national planning policy. Relevant national policy includes the Plan for Growth published by the Government in March 2011, and emerging policy set out in the Draft National Planning Policy Framework (NPPF - July 2011).
We contend that comparison of the Draft NPPF and the SADPD shows that, while the Council has paid lip service to the emerging national planning policy, the SADPD actually fails to meet many of the objectives set out in the Draft NPPF. In his introduction to the Draft NPPF, the Right Hon. Greg Clarke, Minister for Planning, states:-
The purpose of planning is to help achieve sustainable development. Sustainable means ensuring that better lives for ourselves don’t mean worse lives for future generations. Sustainable development is about change for the better, and not only in our built environment.
We contend that the SADPD fails to meet the sustainable development objectives of the Draft NPPF, and is therefore unsound and not legally compliant.
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Crowthorne Village Action Group, response to Bracknell SADPD. 7 March 2012
Supporting Evidence
Documents compared: Draft NPPF 25 July 2011 - Plannings and Buildings document no.195811 SADPD 16 January 2012 - Draft submissions and others. Only items from the Draft NPP Framework not adequately answered within the SADPD are included below.
NPPF - Delivering sustainable development – section 14 “prepare Local Plans on the basis that objectively assessed development needs should be met, and with sufficient flexibility to respond to rapid shifts in demand or other economic changes” SADPD - Planning figures are based on out of date data. The housing projections are based on 2006 economic data built up from 2001 – 2005 trends. No amendments have been made to the demand forecast of 10,780 homes to reflect the current downward economic trend.
NPPF - Core planning principles “seek to protect and enhance environmental and heritage assets in a manner appropriate to their significance, and reduce pollution. Where practical and consistent with other objectives, allocations of land for development should prefer land of lesser environmental value”.
SADPD Policy SA4 (Broadmoor) plans for 210 houses at Broadmoor which in its entirety is covered by the Historic Park and Garden Grade 11 designation. It is also immediately adjacent to the Thames Basin Heath which is designated as a Special protection Area under the EC Birds directive.
SADPD Policy SA5 (TRL site) plans for 1000 houses on a partial brownfield site. This is an environmental disaster relying on the felling of an estimated 20,000 trees to meet the size of the full plan. It is also immediately adjacent to the Thames Basin SPA Heath which is designated as a Special Protection Area under the EC Birds directive.
SADPD Policy SA7 (Blue Mountain site) relies on the destruction of the best privately owned 18 hole pay-and-play golf course in the Borough and the loss of a very valuable local gap keeping separate the old village of Binfield from the urban town of Bracknell. The Inspector's report in 2008, leading to the adoption of the Core Strategy, included a recommendation that this local gap should be retained to prevent the encroachment of Bracknell on the village of Binfield.
SADPD Policy SA6 (Amen Corner North) is a Green Field site.
SADPD Policy SA9 (Warfield). Although adopted before the introduction of the of the SADPD, the significant presence of a site planned to accommodate 2200 house, together with SA8 (Amen Corner South) with 725 houses, together with the Jennets Park site with approximately 1500 houses under construction under construction, must be taken into account when assessing the impact of housing development in
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Crowthorne Village Action Group, response to Bracknell SADPD. 7 March 2012 the Borough – 5225 houses in the north and north western area of the Borough alone.
SADPD It should be noted that the Council was asked at its meeting on November 30, 2011 to approve the following amendments to its Medium Term Objectives (2010 – 2015). This effectively removed a former contradiction between Priority 2 of the overarching priorities and the SADPD policies approved above. From – Former Priority 2
“Protecting and enhancing our environment. to keep our parks, open spaces and leisure facilities accessible and attractive to promote sustainable housing and infrastructure developments to keep Bracknell Forest clean and green”
To – New Priority 2:
“Protecting and enhancing our environment. protect communities by strong planning policies keep Bracknell Forest clean and green”
We contend this change was made in the hope that the four site development plans above could proceed with minimum disruption.
NPPF “make effective use of land, promote mixed use developments that create more vibrant places, and encourage multiple benefits from the use of land in urban and rural areas, recognising that some open land can perform many functions (such as for wildlife, recreation, flood risk mitigation, carbon storage, or food production)”. SADPD - (SA7) describes the development of the open land of Blue Mountain golf course which at present provides a significant green space between Binfield Village and Bracknell Town in addition to providing a publicly available golf facility centre for the Borough and surrounding areas.
NPPF “enable the reuse of existing resources, such as through the conversion of existing buildings”. SADPD - Currently in Bracknell there is approximately 1.5m square feet of empty office space (SADPD Appendix R – Market perspective of Bracknell Forest office floor space, Section 3.3). There are no tangible plans for the conversion of existing buildings to other uses.
NPPF “actively manage patterns of growth to make the fullest use of public transport, walking and cycling, and focus significant development in locations which are or can be made sustainable”. “always seek to secure a good standard of amenity for existing and future occupants of land and buildings”
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Crowthorne Village Action Group, response to Bracknell SADPD. 7 March 2012
SADPD - Of the four urban extension sites identified by BFBC in the SADPD – Broadmoor (SA4); the former TRL site (SA5); Amen Corner North (SA6); and Blue Mountain (SA7) plus the already adopted sites SA8 (Amen Corner South) and SA9 (Warfield) – none are near to or close enough to places of business, shops, churches or pubs to make easy walking or reasonably safe cycling a popular option. Local buses pass reasonably close to the sites but, already on limited evening and weekend schedules, it is uncertain if, due to Council economies, future schedules will facilitate their use. This is a major contributor to making the SDAPD unsustainable.
NPPF - Plan-making – Local plans (Section 23)
The following extracts are from this section:- “Local planning authorities should set out the strategic priorities for the area in the Local Plan. This should include strategic policies to deliver: housing and economic development requirements the provision of retail, leisure and other commercial development the provision of infrastructure for transport, minerals, waste, energy, telecoms,water supply and water quality. the provision of health, security, community infrastructure and other local facilities. Local Plans (section 25) are the key to delivering development that reflects the vision and aspiration of local communities. To do this, early and meaningful engagement and collaboration with neighbourhoods, local organisations and businesses is essential.
SADPD – The current economic climate does not support the 10780 houses based on 2006 figures used in the original and subsequent SADPDs. Also, the indications are that Bracknell, while considered to be a fairly wealthy area (SADPD Appendix P – Bracknell Forest housing market assessment – DTZ report, commissioned by BFBC) has a significant population with wages well below that necessary to obtain a mortgage to meet the typical Bracknell house prices. Therefore, there is a real need for many more truly affordable house to be delivered than current plans recommend. There is only a limited amount of financial support available to provide attractive incentives for developers to build low-profit-margin affordable homes. The DTZ report – updated 2009, suggests that 72% of newly formed households in the Borough do not have enough income to support a mortgage, even for homes in the lower quartile price bracket.
None of the plans for the four principal sites includes a significant presence of shops and leisure facilities. Nor are they sufficiently close to other sources of these to encourage walking or cycling. Nor can public transport be reliably included in any plans because the Council does not have full control of the buses.
The council currently has a survey running from 16 January 2012 to 30 March 2012 investigating how and where the Council can reduce the financial support it gives to the bus services. This does not establish confidence in future services meeting the
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Crowthorne Village Action Group, response to Bracknell SADPD. 7 March 2012 conditions of the NPPF.
There are no Council-led plans included in the SADPD for working with telecom providers for the benefit of the general population of Bracknell Forest Borough. References to the Universal Service Broadband commitment is qualified by the statement that the cost of modifying the existing network is through agreement between the developer and the utility company.
The Council states that provision of health facilities is in the remit of the NHS East Berkshire Primary Care Trust. The SADPD addresses only the provision of a new “Bracknell Health Space” to be built on the edge of the town centre. It is envisaged that this will provide primary care for the whole of BFBC (approximately 115,000). There is currently a major debate about the future of Heatherwood Hospital (no A&E or maternity facilities) in Ascot , this is the major facility in near reach of the people of Bracknell Forest. If this is closed the other 3 options are (approximate mileages from the town centre), Royal Berks, Reading 10 miles, Frimley Park, Camberley 12 miles, or Wexham Park 18 miles. Access to these is difficult and expensive for those without private transport.
A newspaper report dated 23 February 2012 stated that the Ladybank Old Persons Home was finally to be closed despite a petition of 973 names to keep it open.
The provision of additional GP facilities to look after patients from the 10,780 houses in the current plans is not positively addressed in the SADPD (IDP) referring to it as the responsibility of the PCT.
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Crowthorne Village Action Group, response to Bracknell SADPD. 7 March 2012
NPPF “A wide section of the community should be proactively engaged, so that Local Plans, as far as possible, reflect a collective vision and a set of agreed priorities for the development of the area, including adopted neighbourhood plans”.
SADPD reflects only the Council's idea of what local plans should be. There were 750 responses from the public to the 2010/11 consultation phase, the majority of which disagreed with some of the development plans for either the TRL site (SA5) or Blue Mountain (SA7). None of the responses to the SADPD consultation phase have been incorporated in the final SADPD in the manner required by the Draft NPPF and as anticipated by the voting public. In addition a public petition of 1500 names was given to the Council at their meeting on 30 November 2011 protesting against the volume of houses and placement of the proposed development in the Northern Arc (Binfield with Warfield) and Crowthorne. This petition now has in excess of 2,500 names. This has been ignored. A Local Residents Survey conducted in February 2011 by local campaign groups contains detailed responses and comments concerning Bracknell‟s SADPD from over 1,600 individual residents. This was presented to Bracknell Forest Council in May 2011 and promptly ignored.
NPPF - Using a proportionate evidence base – section 27 extract
“Each local planning authority should ensure that the Local Plan is based on adequate, up-to-date and relevant evidence about the economic, social and environmental characteristics and prospects of the area. Local planning authorities should ensure that their assessment of and strategies for housing, employment and other uses are integrated, and that they take full account of relevant market and economic signals such as land prices to inform judgements about levels of demand”.
SADPD – The DTZ report (Bracknell Forest Housing Market Assessment – revised Oct 2011, commissioned by Bracknell Forest Council) observes that housing estimates may be overstated post 2008 economic changes. The Hicks Baker report (Market Perspective of BFB Office Floorspace – Oct 2011, commission by Bracknell Forest Council) demonstrates the uncertainty of the market post 2008 with a spikey, but downwards trend in take-up rates despite a significant drop on rental head rates from approximately £25/sq ft in 2008 to £17/sq ft in 1Q 2011.
Housing projections in the SADPD are based on 2006 population figures produced by the Office of National Statistics. There has been no attempt to amend the projections in the SADPD Consultation document to reflect the significant change in the UK and Global economy.
NPPF - Housing requirements - section 28 extract;
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Crowthorne Village Action Group, response to Bracknell SADPD. 7 March 2012
“Local planning authorities should have a clear understanding of housing requirements in their area”.
SADPD – There is no content in the SADPD which analyses the demographic profile of any of the proposed development sites.
NPPF - Business requirements – section 29 extract;
“Local planning authorities should have a clear understanding of business needs within the economic markets operating in and across there are”.
SADPD Statement - "In the light of the existing stock of floor space (1.5m sq ft empty) and commitments for future development, no major new allocations of employment land are made. A significant proportion of committed floor space relates to the Bracknell Town Centre regeneration scheme (long overdue for economic reasons) although the majority of this involves the replacement of existing older floor space. There is also provision in the major locations for growth, identified in the Core Strategy, for some limited employment floor space as part of mixed use schemes - SA8 Amen Corner South - adopted, SA9 Warfield – adopted, and SA5 TRL"
NPPF - Infrastructure requirements – section 31 extracts;
“Local planning authorities should work with other authorities and providers to: o assess the quality and capacity of transport, water, energy, telecommunications, utilities, health and social care, waste and flood defence infrastructure and its ability to meet forecast demands. o take account of the need for nationally significant infrastructure within their area”.
SADPD - The following is a statement made by the Highways Agency (HA) who have the remit for nationally significant highways – M3 and M4 - in Bracknell Forest Borough;
”Only a short section (less than 1km) of the Strategic Road Network (SRN) lies within Bracknell Forest Borough – part of the M4 motorway. There are no junctions providing direct access to either the M4 to the north or the M3 to the south within the Borough. Access to the motorway network is achieved to the south of Bracknell Forest via the A322 to M3 junction 3 and the A3095 to M3 junction 4, and to the north via the A329(M) to junction 10 of the M4. Although not part of the SRN, traffic flows on these link roads are critically important to the safety and efficiency of the SRN. HA evidence to the South East Plan EiP identified that the M4 between Junctions 9 and 11 was currently congested at peak hours and other times, and that the route would be unable to cope with future
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Crowthorne Village Action Group, response to Bracknell SADPD. 7 March 2012 traffic levels without flow and demand management measures. By 2016 and 2026, HA evidence shows that the M4 will be unable to cope with demand. The HA does not plan to improve M4 junction 10 in its current forward work programme. The HA will work with Wokingham, Bracknell and Reading local authorities to develop an appropriate scheme, although in the current climate this should be through developer funding. No regional or central funding is available. The Spending Review should provide more clarity, however funding for such a scheme is at present very unlikely.“
SADPD - For Transport and Telecomms see comments above.
Health and social care are addressed in the Core Strategy Policy CS6 – Limiting the impact of Development. Neither CS5 nor the SADPD make any commitment to providing appropriate facilities, only the intent to do so, preferably with developer contributions when the development has reached a critical mass making it economic or necessary to provide facilities. This policy does not reflect the Council's VISION statement.
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Crowthorne Village Action Group, response to Bracknell SADPD. 7 March 2012
NPPF - Defence and National Security – section 33 extract;
Local planning authorities should work with the Ministry of Defence’s Strategic Planning Team to ensure that they have and take into account the most up-to-date information about defence and security needs in their area.
SADPD – We can find no reference to such planning in this document.
NPPF - Planning strategically across local boundaries – section 44 SADPD – This document claims that discussions have taken place. However, the Amen Corner South plans (adopted) and Amen Corner North (SA6) plans have been made without adequate discussion and subsequent agreement with the neighbouring Wokingham Borough Council about the effects that each other's development plans will have on the local environment (ref. Wokingham Response IMD 2012 - 9 dated 21 Feb, 2102).
NPPF – Neighbourhood plans – section 49 SADPD – This subject is not addressed in the SADPD
NPPF - Development management - (sections 53 – 70) and Planning for prosperity - (sections 71 – 81) SADPD – These sections of the NPPF are not addressed in the SADPD
NPPF – Transport
“The planning system should support a pattern of development which, where reasonable to do so, facilitates the use of sustainable modes of transport. Section 84 - The objectives of the transport policy are to: - facilitate economic growth by taking a positive approach to planning for development; and to support reductions in greenhouse gas emissions and congestion, and promote accessibility through planning for the location and mix of development”.
SADPD – The locations of the four principal sites in the SADPD do not in any sustainable way lend themselves to meeting these objectives. Two developments in Crowthorne, – Broadmoor (SA4) with 210 houses (retirement homes not included) and TRL (SA5) with 1000 houses, will together put an additional 2100 cars (estimated at 1.75 average per home) onto already busy country roads and a village main street already over the acceptable limit for greenhouse gas emissions. There are no substantial plans in the SADPD to provide local road improvements to mitigate this extra local load.
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Crowthorne Village Action Group, response to Bracknell SADPD. 7 March 2012
In the village of Binfield, Amen Corner North (SA6) with 400 houses, Blue Mountain golf course (SA7) with 400 houses, adds up to 800 new houses and therefore approximately 600 (estimated at 1.75 average per home) additional motor vehicles. In addition to the 400 houses it is planned that the Blue Mountain site (SA7) will be developed to accommodate a primary school, a secondary school, a special needs school and multi-function community hub with appropriate car parking. The schools are to meet the needs of the new 2200 houses development in Warfield (SA9 already adopted), between 1.5 and 2 miles away, the new 1125 house development at Amen Corner North (SA8 already adopted) and South (SA8), 1 – 1.5 miles away. Students from the 400 houses on the Blue Mountain site will walk to school. From the other two sites walking will not be acceptable and the busy country roads are not safe for children to cycle to school. There are currently no bus services directly connecting the Warfield site to the proposed school site. The bus service which passes closest to the two Amen Corner sites travels a long route before passing the Blue Mountain site, on the north side of which is a single lane bridge controlled by traffic lights already resulting in significant tail backs during the rush hours. With the Council looking for ways to reduce its contributions to the bus service providers, the probability is that the majority of children will have to be taken to and from school by car causing further congestion and additional greenhouse gas pollution on old country roads and on the neighbourhood roads servicing the 400 house adjacent to the school. Much of this is already congested with business commuters during the morning school travel time. It is also planned that a 3,500 capacity football stadium, with adjacent practice pitches, floodlighting and full club facilities will also be built adjacent to the schools site in this rural village area, creating a different sort of congestion on the days that home matches are played. Although the SADPD includes reference to improved bus services it is not clear if the Council, in its search to reduce costs, and/or commercial vehicle operators will be able to afford access to the high quality, low carbon emission public transport facilities required by the NPPF. In these two countrified areas (Crowthorne and Binfield/Warfield), outside the urban environment of Bracknell Town, it will be impracticable and uneconomic to create safe and secure layouts which minimise conflicts between traffic, pedestrians and cyclists where many of the roads are too narrow for cycle lanes. The result is an unsustainable development plan.
NPPF – section 93
“When setting local standards for residential and non-residential development, local planning authorities should take into account: o the accessibility of the development, the type, mix and use of development, local car ownership; o an overall need to reduce the use of high-emission vehicle”
SADPD – As described above, the four major developments are out-of-town, and
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Crowthorne Village Action Group, response to Bracknell SADPD. 7 March 2012 without local amenities. As such, they must rely on the use of private car and/or a good, regular and timely bus service which does not exist at this time and is not adequately addressed in the SAPDP. To transport students, many of them by private car, from remote new developments totaling up to 3270 homes mostly through narrow country roads does not make for sustainable development.
NPPF – Section 94
”Local planning authorities should identify and protect, where there is robust evidence, sites and routes which could be critical in developing infrastructure to widen transport choice”.
SADPD - There is no substantial evidence that this will be addressed.
NPPF - Communications infrastructure;
“Section 95 - Advanced, high quality communications infrastructure is essential for economic growth. The development of high speed broadband technology and other communications networks also plays a vital role in enhancing the provision of local community facilities and services. The Government’s objective for the planning system is to facilitate the growth of new and existing telecommunication systems in order to ensure that people have a choice of providers and services, and equitable access to the latest technology.
Section 97 - Local planning authorities should not question whether the service to be provided is needed nor seek to prevent competition between operators, but must determine applications on planning grounds”.
SADPD - There are no Council-led plans included in the SADPD for working with telecom providers for the benefit of the general population of BF Borough. References to the Universal Service Broadband commitment is qualified by the statement that the cost of modifying the existing network is through agreement between the developer and the utility company.
NPPF – Minerals SADPD - This subject is not addressed in the SADPD
NPPF – Design SADPD – This subject is not addressed in the SADPD
NPPF - Sustainable communities – section 124 and all subheadings in this section SADPD - None of the four major development sites covered by this SADPD meet the requirements for sustainability set out in the NPPF. While local bus services pass reasonably close to the planned sites it is uncertain if, due to Council economies, the future schedules will facilitate community interaction. As the schedules show now
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Crowthorne Village Action Group, response to Bracknell SADPD. 7 March 2012 evening services are usually over by 7.30. If the bus service providers do not cooperate then the new developments are located far enough from the existing communities for social interaction to be difficult without recourse to the car. None of them are closer to hospital facilities than 4 miles (Heatherwood Hospital, Ascot under threat of closure). One of them (Blue Mountain - SA7) is planned to be built on a popular, pay-and-play golf course which will mean the loss of a thriving existing recreational, community and business hospitality facility and an important green space separating Binfield Village from the urban Bracknell Town. The TRL (SA5) site is a partial brownfield site, but to meet the full plan will entail the felling of an estimated 20,000 trees. In addition, the presence of 1000 new houses on this site, with the inevitable use of private cars, will overwhelm the narrow main village street, which provides limited shopping and parking facilities, and adjacent approach roads. No places of worship, a choice of shops, nor public houses are planned for any of the four major development sites – SA4, SA5, SA6, SA7, nor for the two adopted sites Amen Corner South (SA8) and Warfield (SA9). There are no plans in the SADPD to provide any additional sporting facilities. The new football ground planned for Blue Mountain only replaces that existing at the Larges Lane site currently planned for redevelopment. In reality, the planned development SA7 (Blue Mountain) will remove an existing facility, the only 18 hole privately owned, pay-and-play (ie. available to those who choose not to join expensive membership clubs) golf course in Bracknell Forest Borough, which also doubles as the essential local gap between Binfield and Bracknell.
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Crowthorne Village Action Group, response to Bracknell SADPD. 7 March 2012
Bracknell Council’s 10,780 Housing Demand Forecast for the period 2006-2026 is fundamentally unsound
Submission
Advice from Government, on revocation of the RSS, is that Local Authorities are required to set a locally-derived housing target which is fully justified and founded on a robust evidence base.
Bracknell Forest Council have failed to provide a robust evidence base, they have failed to heed warnings from their own consultants and from the Office of National Statistics. In so doing the Council have failed to revise downwards their original 2005/6 target of 10,780 new dwellings to reflect reduced demand and reduced inward migration to Bracknell resulting from:
The fundamentally different economic environment post 2008.
Bracknell Council‟s continued failure to regenerate the Town Centre and make Bracknell an attractive location for employers and employees.
Bracknell Council‟s demonstrable failure to attract new business in having over 1.5 million square feet of empty office space (Hicks Baker Report).
Therefore, we contend that the housing target on which Bracknell‟s draft SADPD submission is based is overstated and not fully justified, it is not founded on a credible evidence base, and as such is fundamentally unsound.
Supporting Evidence
Bracknell’s demand forecast for 10,780 new homes dates back to February 1st 2006
Source: BFC EXECUTIVE - SUPPLEMENTARY PAPERS - 19 OCTOBER 2010 (page 333)
2.1.13 The district level housing distribution was agreed in the form of a revised Policy H1 at the SEERA Planning Committee of 1 February 2006, which then formed the basis of the Draft Plan for Submission in March 2006 (the 'Option 1' figures): Policy H1 – Housing Distribution Bracknell: 539 dwellings per annum (annual average).
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Crowthorne Village Action Group, response to Bracknell SADPD. 7 March 2012
Total average (2006-2026) – 10,780
This clearly shows that Bracknell‟s housing demand forecast was made during a buoyant economy, based on data and trends from 2001-2005, calculated at least 18 months before the banking collapse of 2007/8 and subsequent global recession and financial crisis. The trajectory of the economy has maintained a downward path through the past 5 years. At no time has Bracknell Forest Council made a downward revision of their housing demand forecast to reflect this economic reality.
Household Projections, 2008 to 2033, England
Published26 November 2010 Type(s) Statistics Site Corporate Price Free
Summary
This Statistical Release presents National Statistics on the projected number of households in England and its regions to 2033. The figures in this release are based on the 2008-based population projections and replace the 2006-based household projections released in March 2009.
The household projections are produced by applying projected household formation rates to the population projections published by the Office for National Statistics. The assumptions underlying national household and population projections are demographic trend based.
They do not attempt to predict the impact that future government policies, changing economic circumstances or other factors might have on demographic behaviour. They provide the household levels and structures that would result if the assumptions based on previous demographic trends in the population and household formation rates were to be realised in practice.
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DTZ Housing Market Assessment (Updated - October 2011) This report by DTZ, commissioned by Bracknell Forest Council warns, in its Executive Summary, that the forecast may be overstated:
‘DTZ expect that these household projections, based on 2008 population estimates, may over-estimate household formation because they do not take account of the fundamentally different economic environment post 2008.’
‘It is too early to say whether there has been a significant decline in employment within Bracknell – particularly because of the change in methodology used by the ONS in collecting employment data but indicators suggest unemployment levels are rising although still comparatively low. There is some consensus amongst economic forecasters that the recovery will be gradual rather than a rapid rebound. It is important to stress that economic forecasts are highly uncertain. This could have the following implications: Lower job growth could result in reduced in-migration as fewer workers relocate to Bracknell to take up jobs
Reduced in-migration would be likely to result in lower levels of household growth.’ ECONOMICS
The economic performance of any area has an important impact on the performance and character of the housing market. However the broader national and international financial and economic environment will shape the patterns of demand for and supply of housing in Bracknell in the following ways:
Employment growth is a major driver of in-migration both within the UK and internationally. If the rate of employment growth in Bracknell and the West Central Berkshire market in future years is less than it would have been in the absence of the recession, or wages less attractive in an EU context because of the depreciation of the £, then the area may attract fewer in-migrants, which would reduce housing demand and relieve housing pressures.
NOTE: Emphasis added.
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Crowthorne Village Action Group, response to Bracknell SADPD. 7 March 2012
Declining Housing Demand in Bracknell
Source: BFC Appendix E
Summary of Responses to Site Allocations DPD Preferred Option Nov 2010-Jan 2011
In this document Bracknell Forest Council make the following claim:
The Bracknell Forest SHMA shows that the number of households increased by 28% between 1981 and 1991, 16% between 1991 and 2001 and 9% between 2001 and 2008. This reflects the popularity of the area as a place to do business and reside in.
The statement is not true. What this actually shows is a clear trend of declining growth in demand for homes in Bracknell.
28% between 1981 and 1991, Annual average growth 2.8% 16% between 1991 and 2001 and Annual average growth 1.6% 9% between 2001 and 2008. Annual average growth 1.28%
This is the result of a sustained failure to regenerate the town centre and an exodus of significant employers such as Oracle and Siemens; evidenced by 1,500,000 square feet of empty office space currently available in the Bracknell. This amount of empty office space puts Bracknell‟s job market totally out of balance with the Council‟s projected housing demand. And it‟s not just office space, for example BMW have announced that 200 car workers will lose their jobs when the BMW parts warehouse is relocated from Bracknell to Northampton later this year.
Economic Development and Tech Industry are moving away from Bracknell and Thames Valley The Government‟s programme to create new jobs, diversify the economy and support sustainable economic growth is rightly focused on deprived areas in the UK rather than the affluent Thames Valley. By way of example the following Press Release clearly highlights this situation. The resulting impact on Bracknell‟s ability to attract employers and employees is self evident.
Thursday 4 November 2010
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Crowthorne Village Action Group, response to Bracknell SADPD. 7 March 2012
Prime Minister David Cameron has set out the Government’s ambition for London’s East End to become a world-leading technology city to rival Silicon Valley.
The Prime Minister set out the Government’s ambition for London’s East End to be transformed into a world-leading technology city to rival Silicon Valley. This ambitious agenda is part of the Government’s programme to create new jobs, diversify the economy and support sustainable economic growth.
Vodafone, Google, Facebook, Intel and McKinsey & Co are just some of the leading companies that have responded to the Prime Minister’s vision for technology in East London. Over a dozen leading companies and universities are today announcing new commitments to invest in the long-term future of the area, creating the right environment for the thriving start-ups already flourishing in London’s Old Street and Shoreditch areas to grow into the next generation of global businesses.
Source: http://www.number10.gov.uk/news/prime-minister-announces-east-london-tech-city/
Bracknell’s submission plans for 432 more homes than their obsolete forecast actually requires:
The tables below state 3,464 „remaining to be found‟ and then identify locations for 3,896 homes, an excess of over four hundred homes. This is more than enough to save a precious green field site from unnecessary development.
Source: 2.1.3 (Page 7 of the draft submission)
Table 1. How will the Housing Requirement be met?
1,953 Homes completed between 2006 and 2011 2,437 Homes with planning permission, (small, medium & large sites) at 30th September 2011 2,926 Homes accepted in principle and homes planned at Amen Corner and at Warfield 3,464 Remaining to be found
10,780 Total(1) 1. All figures are net
Table 2. Where we are proposing to build the rest
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150 Small windfall allowance (30 per year, last 5 years only) 198 Homes on small sites on the edge of settlements 1,478 Homes on land in existing settlements (previously developed land and other) 2,070 Homes on extensions to Bracknell or other larger settlements 3,896 Homes on possible sites(1) 1. All figures are net
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Crowthorne Village Action Group, response to Bracknell SADPD. 7 March 2012
The consultation carried out by Bracknell Forest Council is flawed
Submission
Community involvement in the preparation of the SADPD has not been carried out in general accordance with the Council's Statement of Community Involvement (SCI) nor its own Code of Conduct. While legal requirements for publicity of the various stages of consultation were no doubt met, few residents were in fact made aware of them and response was difficult. No real notice has been taken of those residents' concerns that were made known to BFC. The process of deriving the final document from the original draft has been far from transparent and was never debated by the council.
There has been inadequate consultation with adjoining authorities which has led to one, Wokingham Borough Council objecting to the submission of the SADPD.
In approving the SADPD, the Council has acted in breach of its own Code of Conduct.
In several instances, these failures constitute a breach of legal compliance requirements.
Supporting Evidence
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.
The Bracknell Forest Borough Statement of Community Involvement was adopted by the Council on 12 July 2006. In it, BFC's vision is stated as: “To give all people the opportunity to be engaged in the local planning process which shapes the environment of Bracknell Forest Borough”. It is also stated in “Growing Places”, a document produced by BFC for its first consultation exhibitions, which looked at the original 8 sites: “If all these sites were developed they could provide around 10,000 homes, which is nearly 6,000 homes more than required. This means that residents have a choice and can tell us through this consultation, how Bracknell Forest should grow in the future.” This vision has not been achieved and residents' stated choices have been ignored. The consultation is flawed for the following reasons:
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Crowthorne Village Action Group, response to Bracknell SADPD. 7 March 2012
The initial consultation between February and April 2010 was not well enough publicised for a document of this importance. BFC received only around 750 replies (SAL31)1. By contrast, a survey2 organised by a coalition of three residents' groups, had 1681 responses. Of these, 69% stated that they did not have any notification of the consultation from BFC. Workshops organised by Urban Initiatives on behalf of BFC in May 2010 in Binfield and Sandhurst gave rise to a large number of adverse comments on the proposals by invited participants. At the Sandhurst meeting there was strong disagreement with the consultants' assessment of the neighbourhoods concerned. At the Binfield workshop the residents were asked to indicate on an aerial map of Blue Mountain and Amen Corner where they thought it would be best to site the houses, the schools and the "Football Academy". This was the first time that a football academy was mentioned. Some residents walked out, others refused to co-operate and used the time to debate the issues. A report on the workshops presented to the council (SAL18), while accurately reproducing written answers to questions in the appendices, does not take these into account in the main body of the document, nor was any account of these taken in subsequent developments. Providing responses to the draft document was not simple. The on-line system was difficult to use, even for the computer-literate, and required residents to have access to the internet. Only 7% of the respondents to the survey quoted above found responding was easy, and a number said the difficulty put them off submitting their views at all. Little thought and no encouragement was given to paper responses. No real notice was taken of public reaction. Most of the responses made to BFC were negative and between 78% and 97% of respondents to the survey opposed six major proposals made in the SADPD. Exit polls taken in Crowthorne at BFC exhibitions showed that, of more than 400 residents approached, over 90% were opposed to the proposals. A petition of over 1,500 signatures presented to the council also showed that many residents were opposed to the proposals. Since then another 1,000 residents have added their names to the petition. In spite of this, no significant changes were made to the final document. Responses given to the negative comments in SAL31 are merely box-ticking and make no attempt to address the concerns of residents. The early versions of the document and public responses to them were not debated by the full Council. When the SADPD was discussed for final approval the Council was told it would be too expensive to make any changes at that stage. The process by which the original eight sites were reduced to four was not transparent and has little or no rational justification. The four sites were chosen only by the Executive (three of whom represent wards in Sandhurst parish, where the only site proposed was dropped). The full Council of 42 members was never given a choice of all the sites and 30 November 2011 was the first and only opportunity councillors had to debate and vote on the site allocations. Even then their hands were tied by a party whip on the vote - see below. Until that point, all information, discussion and voting had been restricted to the Executive. At no stage has BFC listened to what its residents have said regarding locations for growth. Section 25 of the Draft National Planning Policy Framework (NPPF)
1 SALn refers to a BFC document - see http://www.bracknell-forest.gov.uk/SALibrary 2 Bracknell Forest Housing Development Plans - Local Residents Survey Results, May 2011. A summary of the findings follows this section 62 | P a g e
Crowthorne Village Action Group, response to Bracknell SADPD. 7 March 2012
says that “meaningful" engagement and collaboration with neighbourhoods is essential. "A wide section of the community should be proactively engaged so that Local Plans, as far as possible, reflect a collective vision and a set of agreed priorities for the development of the area". Examples of the ways in which this requirement has not been met are: a) At the presentation held at the Morgan centre, Crowthorne, officials declined to accept or record comments saying that the meeting was “for information only” and that comments should be made via the usual planning routes. b) CVAG have asked that BFC propose an alternative plan for the TRL site which would involve building on the brownfield part of the site only, not the extensive surrounding woodland. No such proposal has been made or discussed. In the final consultation period in 2012, local residents were given just six weeks to read, understand and respond. Due to the large number and complexity of the documents this is insufficient, and, although an extension was granted at the request of residents' groups, few individuals have been able to make responses.
There has been inadequate consultation with adjoining authorities.
According to the BFC submission “The SADPD has been prepared having regard to existing and emerging national planning policy. Relevant national policy includes the Plan for Growth published by the Government in March 2011, and emerging policy set out in the Draft National Planning Policy Framework ((NPPF) July 2011). Once adopted the NPPF will replace existing national planning policy set out in Planning Policy Statements and Planning Policy Guidance. However, at the time of writing this document, these remain in place.”
The NPPF states “there is a duty to co-operate on planning issues that have cross administrative boundary implications, particularly those which relate to strategic priorities. Local Planning Authorities are expected to demonstrate evidence of having successfully co-operated to plan for issues with cross-boundary impacts when their local plans are submitted for examination”.
Nevertheless, Wokingham Borough Council has decided to object to the submission on the grounds that it considers that policies SA5, SA6, SA8 and SA13 are not justified or effective. This is due to the lack of consideration of reasonable alternatives, issues with the evidence base, inconsistencies with the approach to the allocation of sites on the Proposals Map and matters arising from the Duty to Co- operate regarding the delivery of infrastructure3. A further result of this lack of
6 CPC Response – SADPD Preferred Options, V3, 5th January 2011 63 | P a g e
Crowthorne Village Action Group, response to Bracknell SADPD. 7 March 2012 consultation is that each Borough now has a preferred site on opposite sides of the Old Wokingham Road.
Crowthorne Parish Council had similar concerns during the initial consultation period as highlighted by the following section in their response: "e. Lack of consultation with adjacent Local Authorities Paragraph 14 of the BFC Core Strategy commits to “regular cross-boundary discussions on spatial planning”. It has now become clear that this has not taken place to any extent with Wokingham BC, as evidenced by public statements made by members of that Council. CPC request BFC to immediately initiate effective cross- boundary committees to meet, consider and report back on all spatial issues arising from proposed developments in Wokingham and Bracknell and their combined effect, not least of all on the village community of Crowthorne. Again no further consultation should take place until such a cross boundary report and recommendations is received and approved by both councils."
These concerns have not been addressed, again illustrating a lack of effective co- operation.
In approving the SADPD, the Council has acted in breach of its own Code of Conduct.
At the Council meeting on 30 November 2011, a Conservative party whip was imposed to ensure acceptance of the SADPD, contrary to paragraph 5.5 of section 16 of the Council's Code of Conduct, which states;
"Don't impose the Party Whip in connection with a planning matter."
Paragraph 1.5 of the document confirms that;
"This Code of Good Practice applies to All Members, at all times, when involving themselves in the planning process".
Paragraph 1.4 states;
"Planning decisions taken by local authorities in Committee are liable to be quashed if it can be justifiably alleged that a Member participating in the decision- making process has predetermined the issue (i.e. approached the matter with a closed mind) before the Committee or if a fair minded observer, knowing the relevant background, would consider that there was a real danger of bias".
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The imposition of the whip implies predetermination. The Council Leader's subsequent statement, that this is a policy matter not a planning matter, is at best naive and at worst misleading.
Furthermore, the statement by BFC Chief Executive Timothy Wheadon, in his letter agreeing to the extension of the consultation period, that "the proposals have been in the public domain since the Executive meeting on 15 November" confirms that they were a final version and that the decision to be taken by the full council on 30 November 2011 had been predetermined.
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Crowthorne Village Action Group, response to Bracknell SADPD. 7 March 2012
Annexe to section on flawed consultation.
APPENDIX B - RESULTS TABLE - ALL SURVEY RESPONSES Total Responses: 1681 (includes 727 from paper survey) Question Yes No No Opinion Did you see or receive any notification from 28% 69% 3% Bracknell Forest Council regarding the public consultations on the proposed Site Allocations for new houses?
Do you think that housing development should be 78% 13% 9% spread evenly across the borough?
Do you support Bracknell Forest Council's use of 3% 87% 10% population and economic forecasts, and other data from 2006 and earlier, to project the requirement for 10,750 new houses?
Do you think the number of houses proposed by 92% 4% 4% Bracknell Forest Council should be reduced to reflect the economic recession?
Do you think the local infrastructure (roads, public 1% 97% 2% transport, health, education, etc.) can support this level of population increase?
Do you support Bracknell Forest Council's current 2% 97% 1% proposals to build on countryside (green field sites), and on green gaps between established communities?
Do you think it is a good idea to redevelop empty 96% 2% 2% office blocks and commercial sites for housing in preference to building new houses on countryside and green gaps?
Do you currently have access to the internet at 90% 9% 1% home?
Did you find Bracknell Forest Council's 7% 51% 42% 'Consultation Portal' website easy to use?
Did you submit your comments using the council's 22% 68% 10% Consultation Portal?
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Crowthorne Village Action Group, response to Bracknell SADPD. 7 March 2012
Inadequate assessment of alternatives when choosing “preferred” broad areas.
Submission
We believe that during the indicative options consultation, July 2010, BFC was deficient in not evaluating sufficient alternatives or providing a balanced assessment of those sites which were considered. The preferred options are therefore not justified as they are not founded on robust and credible evidence.
The indicative options document, July 2010, assessed 8 Broad Areas. However the evaluation was subjective and not objective. Having produced reams of paper to analyse the broad areas there seems to have been no scientific reasoned scoring for comparative evaluation. Broad areas 1 & 7 were eliminated with a statement that “they performed less well against sustainability objectives”, In fact the reverse was true and they performed better against the sustainability objectives. These were the only areas with both good access to public transport and good access to areas of employment.
It transpired that significant parts of Broad area 6, weren‟t actually available so shouldn‟t have been included. At that stage the process could have been suspended whilst alternative areas could be evaluated. For example the council was offered farmland south of Sandhurst by the owners who wished to put it up for development. In their response (SAL31, Pg 13) the planners assert that it was in a less sustainable location. Since they never actually evaluated this area, there is no evidence to support this statement and it cannot be considered robust or credible.
When CVAG requested an alternative plan for Broad area 3, TRL, based on developing the currently built area at a similar density to the surrounding developments, none was ever produced. At no time was the possibility of using the vast amounts of empty office space in Bracknell centre for housing considered.
This lack of choice and non responsiveness to community requests is indicative of the way the whole process has been managed.
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Crowthorne Village Action Group, response to Bracknell SADPD. 7 March 2012
Supporting Evidence
Scoring was arbitrary and contained a significant number of errors.
For Broad Area 3, the TRL site, in table 23 sustainability appraisal, Assessment of effect on community is scored as ++ , when the appendix says. “Development of this site could allow for integration between Hanworth and communities off Old Wokingham Rd.” This massive development would actually have a negative effect on the community of Crowthorne and should have been scored -- - . Whilst not part of the sustainability appraisal, it should be noted that the core strategy has a commitment to maintaining the independent characters of the communities surrounding Bracknell, so integrating Crowthorne with Hanworth should not be seen as a positive.
Broad area 3 TRL is actually scored positively for transport because it may be possible to provide a bus in the future. However, no such bus service exists and there is no guarantee it ever will exist. It should therefore be scored negative, the same as for other broad areas. The assertion that “it is unlikely that the car will be the preferred method of transport” is totally unsubstantiated and should not have been included.
Broad area 7, Chavey Down was scored negative because people would have to use their cars. The same applies to both Broad Area 3 TRL and Broad Area 2. Broadmoor. They should have received the same negative score, but did not.
Broad Area 5, East Binfield (Blue Mountain) was scored POSITIVE against „Accessibility of Services‟ on the basis of the following analysis: ‘Access to rail – poor. Access to distance buses – poor. Highways Agency concerns on A329M & M4”. While on the same page Broad Area 1 Sandhurst: “Access to essential services – good. Car required for access to Bracknell” (ignoring Access to Camberley – good) resulted in a NEGATIVE score. The bus service from BA5 Blue Mountain to Bracknell currently runs every 2 hours from 9:30am to 4:30pm, resulting in most residents in the area being forced to use their cars for shopping in Bracknell and commuting.
Broad Area 4, West Binfield (Amen Corner North) „analysis‟ states “Public transport to town – good. Non car mode to town – relatively poor”. Illogical, it cannot be both! “Access to Rail – poor. Highways Agency concern on A329M and M4” results in a bizarre POSITIVE score.
In their analysis they declare “no issue” with regards to Waste across all Broad Areas ignoring the fact that Thames Water, in their submission, raised concerns over capacity for such a large concentration of new houses: “As set out in our recent comments on the Bracknell Forest Site Allocations DPD Preferred Options, we have concerns in relation to the capacity of the existing sewerage network to accommodate the level of growth proposed”. Please see the Infrastructure section in this document for more detailed information.
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Crowthorne Village Action Group, response to Bracknell SADPD. 7 March 2012
Detailed analysis of the broad areas shows that Broad area 2, Broadmoor and Broad area 3 TRL are only ranked equal 5th and 7th out of 8, so should certainly not be “preferred”.
No attempt was made to utilise the empty office space in Bracknell Town Centre.
In the SADPD-associated document Summary of key issues raised to Preferred Option Consultation and Council’s Response, it is stated that "The Council's Employment Land Review has concluded that there is a significant over- supply of employment space (in the form of offices) in Bracknell". The document in question is BRACKNELL FOREST EMPLOYMENT LAND REVIEW. Final Report. December 2009. The relevant sections are:
"4.36 The total office space on the market in Bracknell Forest, for all unit sizes and the whole of the Borough, at Q3 2008 is estimated at approximately 80,000 sq m. This represents a vacancy rate of 18% - more than twice the normal or equilibrium vacancy of 7-8%. This figure excludes a large amount of space which at Q3 was being redeveloped or refurbished. If we include these buildings under construction and refurbishment, the two main schemes being Maxis and Capitol, availability rises to 130,000 sq m and the vacancy rate to 30%." and "4.43 Office floorspace and office development sites are heavily oversupplied, both in Bracknell Forest and the wider sub-region. In the short term, there appears to be no requirement for new office sites in the Borough, either on quantitative or qualitative grounds. Because this oversupply is a sub-regional problem, local authorities may have to work together across the sub-region to solve it."
In addition, in the document SAL36 - Market Perspective of Bracknell Office Floor Space 2011 dated October 2011, Section 3.3 says:
"We estimate that there is currently almost 138,500 sq. m (1.5 million sq. ft) available within the Borough." showing the situation is largely unchanged. Finally, a report prepared by Fryer Commercial for Beneficial House, dated June 2011, repeats the 1.5M Sq. ft number and contains the following statements: "5.01 Relative to demand office supply has far outstripped demand in the Bracknell area for the entire 21st century."
"6.03 The overriding conclusion is that Bracknell possesses too many office buildings, some of which will never be let as offices."
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Crowthorne Village Action Group, response to Bracknell SADPD. 7 March 2012
At least some of these empty office buildings represent an unused resource which could be used for sustainable housing and would score very well against the selected areas in the SADPD on almost all counts. At no stage was this ever considered as a possible option.
Related matters.
The choice of “preferred” broad areas was further flawed as BFC's co-operation with neighbouring authorities was ineffective. The council have not taken due care in consulting with Wokingham, when planning their final North West/West corridor of development. This has given rise to a recent critical complaint from Wokingham‟s executive: they are also allocating two of their major „urban extensions‟ close to the Bracknell border, one at south Wokingham starting opposite Loch Fyne for 2,500 homes, and the other in north Wokingham for 1,500 homes - another 4,000 homes generating cars on the other side of the A329M.
The full evaluation should have been presented to the Executive so they could assess its correctness prior to asking them to approve the consultation. On 19 October 2010 the executive voted to approve the Preferred option, reducing 8 indicative options to 4 preferred options. The sustainability appraisal, which contained the detailed appraisal comparing these sites was not published until November 2010, and was not available to the executive when they were asked to make that decision. Had they seen the full appraisal document, they may not have approved the proposal to proceed with this consultation.
It is therefore not surprising that the planners, knowing that their argument was weak, chose not to allow the full council to inspect, challenge or vote on the “preferred options”.
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Crowthorne Village Action Group, response to Bracknell SADPD. 7 March 2012
Infrastructure Delivery Plan for roads and transport (SAL 34), is unsound
Submission
SAL 34 – Infrastructure Delivery Plan (IDP) November 2011
The Infrastructure Delivery Plan (IDP) was developed by Bracknell Forest Council to identify key infrastructure/s required to support development in the Borough up to 2026. Although it is a standalone document, its primary role is to act as a supporting document to the Site Allocations Development Plan Document (SADPD), Warfield SPD, Amen Corner SPD and is a material consideration in the determination of planning applications.
Section 4.1 of IDP - Highway Network
Strategic Road Network (SRN)
Our assertion is that:-
1. The IDP is Unsound as the improvements to the Strategic Road Network cannot be delivered as: BFC have not clearly demonstrated that key partners i.e. developers, have signed up for such infrastructure provision, as required by PPS12 paragraph 4.45 and The Draft National Planning Policy Framework (25 July 2011) para 39
2. The IDP is Unsound as there has been a lack of consultation / co-operation with Wokingham Council, as required under the Localism Bill (section 110) and The Draft National Planning Policy Framework (25 July 2011) para44 as evidenced by Item No. IDM 2012 9 from Wokingham BC 21 Feb 2012, making the IDP neither justified nor deliverable.
3. The IDP is Unsound as there has been a lack of consultation / co-operation with the Royal Borough of Windsor and Maidenhead (as required under the Localism Bill (section 110) and The Draft National Planning Policy Framework (25 July 2011) para 44 meaning there is a lack of supporting evidence that neighbouring boroughs will not be effected.
Strategic Road Network (SRN)
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Crowthorne Village Action Group, response to Bracknell SADPD. 7 March 2012
Since the first consultation (Feb – April 2010) the Highways Agency have expressed concern that the SRN (mainly the M4 and the M3 for BFC) which it is responsible for, will not be able to cope with the increase in vehicle numbers resulting from the proposed development sites in Amen Corner South (SA8 - 725 dwellings proposed), Amen Corner North (SA 6 - 400 dwellings proposed) Blue Mountain (SA 7 - 400 dwellings plus 3 schools plus relocation of a football ground.) Together with the 2,200 dwelling planned for Warfield (SA 9) there will be an additional 3725 dwellings with, in all probability, 2 cars per dwelling.
In addition the HA have expressed concern that the developments at TRL (SA5 – 1000 dwellings) and Broadmoor (SA4 – 278 dwellings) will contribute to the overburden of traffic, not just for the M4, but also on the M3 to the South of the Borough.
With employment opportunities within Bracknell reducing and the ability to work from home not available to all, the potential for another 3000 (conservative underestimate) cars each day on Bracknell‟s northern roads becomes a reality. This does not factor in the 4000 houses that Wokingham plan to build on the other side of the A329 (M) to Binfield, close to Junction 10 of the M4, nor the Jennetts Park development of 1500 dwellings (yet to be fully completed) on the A329(M). Assuming a conservative one car per house, that will be an additional 9225 extra cars on the roads to the North of the Borough.
Many of these cars will be travelling to Wokingham, Maidenhead, Reading and further afield. The Highways Agency has been consulted at each stage of the BFC SADPD process. At each stage of the process, the Highways Agency has raised concerns that Junction 10 of the M4 will not be able to cope with the increase in traffic brought about by so many new houses. Transport plans have been drawn up and money spent by BFC on consultants to advise on transport forecast modelling and journey times etc. However, the fundamental problem identified by the Highways Agency i.e. that Junction 10 of the M4 and junction 4 of the M3 will not be able to cope and that thousands of local, regional and national commuters will have their journeys severely delayed and compromised has not been fully addressed by BFC or their consultants.
The Highways Agency suggested a possible junction improvement which might go some way towards alleviating the gridlocked traffic at junction 10 of the M4. The Highways Agency stated that they have no plans to carry out the work themselves and that they had no money available to finance the project. They suggested that BFC consult with Wokingham BC to discuss the apportionment of costs and the delivery of the scheme. It would appear that this has not happened, despite the stated willingness of Wokingham BC to co-operate.
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Supporting Evidence
The IDP – Section 4.1- prepared by BFC states that:
“HA evidence to the South East Plan EiP identified that the M4 between Junctions 9 and 11 was currently congested at peak hours and other times, and that the route would be unable to cope with future traffic levels without flow and demand management measures. By 2016 and 2026, HA state that the M4 will be unable to cope with demand”
“The HA advises that it considers that the committed/proposed development in the DPD will almost certainly affect the safe and efficient operation of the SRN, specifically junction 10 of the M4”
“The HA does not plan to improve M4 junction 10 in its current forward work programme. The HA will work with Wokingham, Bracknell and Reading local authorities to develop an appropriate scheme, although in the current climate the HA argue that this should be wholly through developer funding. No regional or central funding is available. However, funding for such a scheme is at present very unlikely.”
The IDP states the cost for M4 Junction 10 improvements is approximately £8.2million (HA estimate), the cost of which would be apportioned between Bracknell, Wokingham and Reading. However:-
“The HA requests that infrastructure to support the development sites in the DPD should include improvements to M4 junction 10 to alleviate the impact and reduce forecast congestion at the junction. The HA proposes that the cost of the improvements to M4 Junction 10 will be apportioned between Bracknell Forest, Wokingham and Reading and would be developer funded.”
Local Road Network
Our assertion is that:-
1. The IDP is Unsound as the improvements to the Local Road Network cannot be delivered as: BFC have not clearly demonstrated that key partners i.e. developers, have signed up for such infrastructure provision, as required PPS12 paragraph 4.45 and The Draft National Planning Policy Framework (25 July 2011) para 39
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Crowthorne Village Action Group, response to Bracknell SADPD. 7 March 2012
2. The IDP is Unsound as it is not based on good, sound evidence. Supporting documents SAL 38 – 41 only relate to the impact at the 2nd “local” traffic peak and ignores the motorway peak times.
3. The IDP is Unsound as there has been a lack of consultation / co-operation with the neighbouring boroughs of Windsor and Maidenhead and Wokingham, as required under the Localism Bill (section 110) and The Draft National Planning Policy Framework (25 July 2011) para 44 meaning there is not a good evidence base that traffic improvement proposals will alleviate the potential gridlock.
"From: Ben Savage
Dear Concealed
Further to your Information request FOI63818, please find your questions and our response below:
Questions: what contact you have had with Bracknell Forest Council regarding the effect of their Site Allocation Development Plan on traffic and roads in the area, and what agreements, if any, have been reached on these matters
Response: I have been advised that there has not yet been any contact
This concludes your request FOI63818"
BFC has spent many £‟000 commissioning reports to guide and support the SADPD DS. WSP were commissioned to update their earlier work and produced SAL 38 Transport Validation Report (June 2011).
“The purpose of this report is to provide an understanding of the potential future situation in the study area and examine the transport implications and potential infrastructure requirements of the proposed LDF Core Strategy and SADPD proposals ,in comparison to a ‘Reference Case’ scenario.”
It is clear from the date, June 2011 that the sole purpose of this report is to justify the decisions already made and not to guide BFC in the appropriate choices of sites.
However, the modelling is based on a base year of 2007 and population data was taken from the 2001 census. The routes reviewed were chosen by BFC and only included observations during their chosen peak times and during the summer months of June and July. The accuracy of those figures is to be questioned as many
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Crowthorne Village Action Group, response to Bracknell SADPD. 7 March 2012 people are on holiday during those chosen months and schools start their summer holidays too.
A recent survey of traffic speeds on Nine Mile Ride / Old Wokingham Road (speed permissible 40mph), at the junction closest to the proposed TRL (SA5) indicated that eastbound traffic (heading towards Bracknell) was reduced to between 9 and 16mph during the morning rush hour (8am – 9am). This is without the additional 1000 dwellings proposed for TRL.
Under NPPF guidelines,
“Public bodies have a duty to cooperate on planning issues that cross administrative boundaries, particularly those which relate to the strategic priorities identified above. The Government expects joint working on areas of common interest to be diligently undertaken for the mutual benefit of neighbouring authorities”
Aside from travel to and from work, Binfield does not have a major supermarket, the main large supermarkets being at Warfield (Tesco) or Bracknell centre (Sainsbury‟s, Waitrose (opened Nov 2011) and Morrisons. Therefore, any trip for a main family shop necessitates a car journey.
The IDP states that funding for local road “improvements” will be funded between BFC and the developers.
Public Transport
Our assertion is that:-
1. The IDP is Unsound as there is a lack of supporting and credible evidence to justify the rankings and conclusions given. SAL 22 is factually inaccurate and appears to be subjective.
2. The IDP is Unsound as the improvements to the public transport availability cannot be delivered as: BFC have not clearly demonstrated that key partners i.e. bus providers and developers, have signed up for such infrastructure provision, as required PPS12 paragraph 4.45 and The Draft National Planning Policy Framework (25 July 2011) para 39
3. The IDP is Unsound as there has been a lack of consultation / co-operation with the neighbouring boroughs of Windsor and Maidenhead and Wokingham, as required under the Localism Bill (section 110) and The Draft National Planning Policy Framework (25 July 2011) para 44 - 47 meaning there is no cohesive public transport plan for the area.
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SAL 22 (dated November 2010) is the Transport Accessibility Assessment, written by BFC. It seeks to assess the suitability of the original 8 sites proposed for development against their chosen criteria, such as public transport access to the Town Centre, potential to support bus improvements, cycle and pedestrian provision, access to railway station. It then scores each site against their chosen criteria and then ranks the sites for suitability for development.
However, although the results in table 11 – Ranking of Broad Development Areas, show the final scores for each area, we are not shown individual scores vs each criteria. In addition, there are inaccuracies in certain assumptions and statements e.g. section 6 para 6.1.7 ranks BDA 5 (this is the Blue Mountain site) as ranked 3rd because it “is served by 4 bus routes” and is “less than 10 minutes walk from a planned local centre”. This area has only 3 bus routes and even a fit, young healthy person would be hard pressed to walk to the proposed Amen Corner Development in 10 minutes. (The walk to Bracknell Town Centre takes 35 -40 minutes on a good day)
It should be noted that if BFC were including route 190 in their calculation of 4 bus services, they obviously do not fully understand the concept of a bus service, as the 190 turns off at the Coppid Beech Hotel, into Amen Corner and the Western Industrial estate and does not go near Binfield village centre.
Until summer 2010, Binfield had 3 bus routes – the 153 (to Winkfield via Bracknell Town) and 53 (to Wexham Park Hospital via Bracknell Town). These went through Binfiled village centre. In summer 2010, an additional bus route was added (number 151), which went from Bracknell to Wokingham via Temple Way, to include residents on the Temple Park estate (opposite SA7 - Blue Mountain). (The estate was built in 1990, so the provision of a bus service took 20 years) However, the first bus into Bracknell on that route does not get into Bracknell until 9.15 am and the last bus leaves Bracknell at 4.35pm, making it a useless service for anyone wishing to use it to travel to work in Bracknell or to travel to Bracknell station to catch a train to work.
In December 2011, Bracknell BFC proposed cuts of £6M to the budget, which would include ending funding for the 151 route, reducing funding for the 153 route and reducing the 53 route to an hourly service from a half hourly service.
Binfield does not have a major supermarket, the main large supermarkets being at Warfield (Tesco) or Bracknell centre (Sainsbury‟s, Waitrose (opened Nov 2011) and Morrisons. Therefore, any trip for a main family shop necessitates a car journey, not a bus ride.
Given the concerns of the Highways Agency of the increase in traffic from the Binfield / Warfield developments at Junction 10 of the M4 and the concerns of neighbouring boroughs for the local road network, why are BFC reducing the availability of public transport from the very area in which they plan to build the most new dwellings?
Broadmoor and Crowthorne sites were ranked 5th and 6th in the SAL 22 assessment, but were still included as two of the final sites for development, despite other sites scoring higher on the BFC chosen scoring system. Their conclusions for Crowthorne (site 3 in this early report) are:-
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6.1.9 Site three is ranked 5th with an overall score of 1.5. The site is conveniently located for cycle and pedestrian infrastructure and is quite close to Crowthorne High Street. However it is disadvantaged by its distance from Bracknell Town Centre which can be accessed via A3095 but suffers from congestion in the peak periods. Due to the sufficient number of planned dwellings the site could benefit from public transport improvements including increased frequency on route 194
The report states that area 2 – Broadmoor in this report:
6.1.10 Site two is ranked 6th with a score of -1. The site is conveniently located for access to the local centre. However it is disadvantaged by poor public transport access and its location of more than 5km from Bracknell Town Centre and the congestion problems experienced along the route. Due to the sufficient number of planned dwellings the site could benefit from public transport improvements including increased frequency on route 194.
If the availability of good public transport links were actually a significant criteria in deciding which sites to put forward for development, why were these two sites included in the first place?
Transport should be significant as SAL 50b Sustainability Appraisal , P21 talking about SA5, the TRL, says;
Good public transport access should be secured from development to the proposed health care facility in Bracknell Town Centre to effectively deliver primary health care services.
Bracknell FC is dependent on private bus service providers to be willing to provide the services that are required. It took them 20 years to persuade a bus company to provide a service to the Temple Park estate (600 houses) and they have provided no evidence from bus service providers that they are prepared to invest in new routes or improved services.
It is noteworthy that all BFC‟s justifications for selecting the 4 sites that they did and for rejecting the other 4 sites from the original 8, seem to centre around the sites‟ ease of access to Bracknell Town Centre, the distance from Bracknell Town Centre and the bus service available from the Town Centre to the site (and return). Ease of access to other areas e.g Maidenhead, Windsor, Wokingham, Reading and Guilford for work or shopping / recreation, do not feature in Bracknell‟s concepts, yet are an everyday requirement for a lot of BFC residents.
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Crowthorne Village Action Group, response to Bracknell SADPD. 7 March 2012
Infrastructure Delivery Plan for Utilities (SAL 34), is Unsound
Submission
SAL 34–Infrastructure Delivery Plan (IDP), November 2011
The Infrastructure Delivery Plan (IDP) was developed by Bracknell Forest Council to Identify key infrastructure required to support development in the Borough up to 2026. Although it is a standalone document, its primary role is to act as a supporting document to the Site Allocations Development Plan Document (SADPD), Warfield SPD, Amen Corner SPD and is a material consideration in the determination of planning applications.
Our assertion is that:-
1. The IDP is Unsound as BFC have not complied with PPS 12, para 4.9 “Local planning authorities should ensure that the delivery of housing and other strategic and regional requirements is not compromised by unrealistic expectations about the future availability of infrastructure, transportation and resources” There is no documented or published evidence that BFC have worked with Thames Water to identify current capacity or possible upgrades required.
2. The IDP is Unsound as BFC has not considered PPS 12, para B3. “The provision of infrastructure is important in all major new developments. The capacity of existing infrastructure and the need for additional facilities should be taken into account in the preparation of all local development documents.” There is no documented or published evidence that BFC have worked with Thames Water to identify current capacity or possible upgrades required.
3. The IDP is Unsound as BFC have not consulted with other Authorities e.g. Wokingham BC, as required by PPS 12 para B6 “In preparing local development documents, authorities should consider the requirements of the utilities for land – both in their own and in other authorities’ areas – to enable them to meet the demands that will be placed upon them.” Or as required by The Draft National Planning Policy Framework (25 July 2011) para44 -47
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Supporting Evidence
Section 4.3 Utilities - Water Supply and Waste Water
In this section of the IDP, BFC put forward their plans for the supply of fresh water and the disposal of sewage for the proposed new development sites.
In this section they state that Thames Water: “would prefer development to take place within Bracknell Forest in areas that drain to these STWs”. The Sewage Treatment Works TW refers to are Bracknell STW in Binfield and Ascot STW. BFC omit to go on and quote the next sentence in Thames Water‟s response which is: “However, the level of growth put forward in the Warfield DPD, together with the other sites identified in the Site Allocations Document could require upgrades to the STW in the future. As set out in our recent comments on the Bracknell Forest Site Allocations DPD Preferred Options, we have concerns in relation to the capacity of the existing sewerage network to accommodate the level of growth proposed”
BFC claim in the Key Issues and Rationale section that: “It is generally easier to provide upgrades for a small number of larger clearly defined sites than a larger number of smaller less well identified sites. As previously stated, …………,Thames Water’s preferred location for future development would be to the north of Bracknell”. Again, Thames Water‟s concerns that the current system cannot cope with the level of development proposed in the North of the Borough have been ignored and left out of the IDP rationale.
Earlier in section 4.3, under Exisiting Provision, BFC have stated that “Where new WwTW are provided, they are designed to have capacity to treat approximately an additional 10% population equivalent without further upgrade. This is not the position with existing WwTW which may or may not have any additional capacity”
It has not been established what additional capacity is available at Bracknell STW and Ascot STW, but the proposals for house building in the north of the Borough will more than double the current number of households requiring effective wastewater/sewerage management.
Thames Water‟s response to previous consultations has stated that they have “concerns regarding waste water services in relation to this site. Specifically, the
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Crowthorne Village Action Group, response to Bracknell SADPD. 7 March 2012 sewerage network in this area is unlikely to be able to support the demand anticipated from this development”. They gave this response, individually, for sites at Warfield (SA9), Binfield Blue Mountain (SA7) and Amen Corner (SA8), TRL site in Crowthorne (SA5) and Broadmoor (SA4).
Thames Water cautioned that expansion of the Bracknell STW may well be needed, as would work to increase capacity at Easthampstead STW for the developments at Crowthorne and Broadmoor. They went on to say that: “The timescales for delivery of the new infrastructure should not be underestimated. Local network upgrades can take 18 months – 3 years to design and build; strategic solutions 3 – 5 years to design and build; and new resources (such as STW and water supply reservoirs) can take 7 – 10 years to plan, design and build.”
As recently as December 2011, Thames Water were asked to conduct an initial investigation for a proposed 60 bedroom care home for the elderly in Sandhurst Road, Crowthorne (Bracknell Planning Application 11/00794/FUL). Thames Water‟s response, in a letter dated 5th December 2011, state:-
“Following initial investigation, Thames Water has identified an inability of the existing waste water infrastructure to accommodate the needs of this application. The development may lead to sewage flooding"
This currently occurs in Waterloo Road Crowthorne, which joins Sandhurst Road. During even short, heavy rainfall, sewage backs up into toilet bowls, hand basins, baths and shower trays.
Therefore, it must be accepted that the current sewage infrastructure would appear to be incapable of accommodating foul water from existing dwellings, without the additional proposed 1278 dwellings at Broadmoor and TRL developments.
Initial investigations by Thames Water have not taken place at Bracknell STW to assess to ability of the existing waste water infrastructure to accommodate waste water from an additional 3725 homes proposed for areas SA6, 7 & 8.
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Crowthorne Village Action Group, response to Bracknell SADPD. 7 March 2012
Provision for Healthcare Needs in the SADPD is unsound
Submission
Existing healthcare provision is inadequate for the current level of population. For example, the average GP practice size in Bracknell Forest is over 8000 patients, compared with the national average for England of 6500 [Source: ONS 2007]. There is no acute hospital provision as such in Bracknell itself, and it is reported that parts of Heatherwood Hospital are being „rationalised‟, or permanently closed down (see „Planned Provision‟, Infrastructure Development Plan (SAL34) p94).
For example, it has now been recommended that the „Ascot Birth Centre‟ at Heatherwood Hospital should close permanently. (Bracknell Standard, Thursday 1st March 2012). Women in labour will therefore face a much longer (at least twice as long with each of the three options) and less predictable journey to an alternative facility at a time of considerable stress.
Berkshire East PCT rank in the bottom third of all English PCTs when it comes to waiting times (both inpatients and outpatients) [Source: NHS 2010].
Given this existing situation, it is vital that proposals for development present a sound argument for provision of adequate healthcare infrastructure to meet the long term requirements. The impact of increased population on the existing facilities should also be given proper attention.
Given that the council have no funds available to pay for infrastructure themselves, it is also vital that the council ensure that the plan puts developers under reasonable obligation to contribute sufficiently towards it.
In 2007 a joint statement from Heatherwood and Wexham Park hospitals and the East Berkshire PCT pointed out failures in the soundness of the proposed Core Strategy and Sustainability Appraisal.
Bracknell Forest Council appear to have failed to fully implement the changes put forward in the joint statement which would in the view of the PCT have made the plan sound.
Against that background and in light of the uncertainty over deliverability of future health care provision in the borough, we contend that the Council has failed to provide a justified development plan founded on a robust and credible evidence base, and that the plan is ineffective due to doubts over deliverability and the Council's inability to be sure that they can take account of changing circumstances in local health care facilities.
Furthermore, conflicts remain with the Core Strategy, as pointed out in 2007 by the healthcare professional organisations named above, and render the Draft SADPD not legally compliant and therefore unsound.
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Supporting Evidence
Policy CS2 does not adequately consider the implications of future development upon existing health care facilities.
The PCT statement has an issue with CS2 because it doesn‟t adequately address the impact of development on existing health care.
TESTS 4, 6, 7, 8, 9 & 10/CS2/PARAGRAPHS 55 – 59/ 0328/ 1.1 Policy CS2 identifies the Council's sequential approach in line with that set out in national policy. Other policies in the Core Strategy then go on to identify broad locations where development will be focused. However, Policy CS2 does not adequately consider what implications the distribution of future development is likely to have upon existing primary health care facilities in the Borough.
There appears to have been no attempt to include such a consideration in CS2.
Insufficient onus placed on developers for financial contributions.
The PCT statement makes repeated requests for developer obligations (relating to contributions for infrastructure) to be made explicit in the documents.
TESTS 4, 6, 7, 8, 9 & 10/CS2/PARAGRAPHS 55 – 59/ 0328/ 1.2 The Council should look to make specific reference to maintaining or enhancing essential infrastructure, which includes healthcare facilities, where identifying land for development. The PCT suggest that the sequential approach set out in Policy CS2 is linked to Policy CS6 whereby it is clear the Council will expect all major new housing developments to mitigate against its impact upon healthcare provision by seeking financial contributions.
THEME 2 – QUALITY OF LIFE/ TESTS 3, 5, 7, & 9/CS6/PARAGRAPHS 77 – 81/ 0328/
1.0 Has CS6 been subject to sustainability appraisal; does it represent the most appropriate in all circumstances; & is it reasonably flexible to deal with changing circumstances? 1.1 Whilst it is clear the Policy has been subject to sustainability appraisal, the PCT are not satisfied that the Policy as worded sufficiently encompasses local primary healthcare facilities with references to ‘infrastructure’ and ‘facilities’. As such, the Policy (and supporting paragraph 81) should be enhanced by referring specifically
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to healthcare facilities as part of infrastructure necessary to support growth or major developments in the Borough (and neighbouring areas where it would impact upon provision in Bracknell).
1.2 Paragraph 81 rightly refers to the instances for which the Council will seek to obtain financial contributions for qualitative improvements to existing healthcare facilities. However, the PCT suggest this text should also emphasise that housing development, as a form of enabling development, is recognised as a legitimate funding source for such facilities and services.
1.3 Paragraph 81 sets out that Policy CS6 seeks to secure provision of ‘related infrastructure and facilities’ either as part of a development or through contributions on a different site. It is not sufficiently clear from the text as worded that contributions could be collected towards provision to be made by financing qualitative improvements to an existing facility. The PCT therefore suggest that the wording of the Policy and supporting text is amended to refer specifically to healthcare and that a mechanism for funding is through the use of planning obligations.
2.0 Does CS6 reflect the principles of Circular 05/05 paragraphs B21-B24? 2.1 The PCT are satisfied that Policy CS6 and the supporting text reflects in broad terms the principles of paragraphs B21 to B24 of Circular 05/2005 and note the Policy does not specifically reference the Circular as providing the policy framework on acceptable means of collecting Planning Obligations and guidance for their collection.
2.2 Paragraphs B21 to B24 of the Circular, which deal with ‘pooled contributions’ is reflected in the wording of the policy which sets out contributions be collected “in-combination”. Whilst paragraph 83 does interpret the Circular, the PCT suggest the Policy does not adequately set out that the Council will seek contributions for specific future provision “necessitated by the cumulative impact of a series of developments” as stated in paragraph B23.
CS6 does not appear to have been modified sufficiently to meet the PCT‟s soundness requirements. Whilst infrastructure in general is mentioned it does not hold either the council or the developer responsible specifically for funding additional healthcare provision.
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