Land at Calcot Golf Course, Calcot, West Berkshire Representations to West Berkshire LDF Consultation - Options for the Future: West Berkshire Core Strategy (April 2009) Client: Calcot Park Golf Club Issued: 2nd July 2009 Prepared by: Broadway Malyan Paragraph 3.1 West Berkshire Core Strategy Spatial Vision Support or object Support Reasons for support or objection We agree that development should be concentrated in settlements with a range of infrastructure and services. Calcot is one example of a settlement which has land available for development within the settlement boundary that would achieve the aims of sustainable development. Changes being sought to resolve any objection None Policy CS2 Location of Development Support or object Support Reasons for support or objection We support the principles of locating development within/adjacent to settlements and sustainable transport modes. Our client has two sites at Calcot Golf Course; one west of New Lane Hill and one east of West Drive. Both sites are within the settlement boundary and close to public transport routes. Changes being sought to resolve any objection None Policy CS3 District Settlement Hierarchy Support or object Support Reasons for support or objection We support that the Eastern Urban Area (Calcot, Purley on Thames and Tilehurst) has been identified as one of the areas which will be the main focus of development within the District. However, we consider the Council should reassess the important open space designation as our client’s site at Calcot Golf Course, which is designated as important open space, is within the settlement boundary at Calcot and is arguably in more of a sustainable location than other sites outside of the settlement boundary in the Eastern Urban Area. Changes being sought to resolve any objection None M:\20553\0600-090630-Calcot Reps 1 Policy CS3 District Settlement Hierarchy Support or object Object Reasons for support or objection Calcot is an urban area identified for growth in Policy CS3 and therefore should be referenced on the District Settlement Hierarchy diagram. Changes being sought to resolve any objection Identify Calcot on the diagram. Paragraph 5.11 Support or object Support Reasons for support or objection We support this paragraph as good access to key services, facilities and public transport links are crucial for achieving sustainable settlements. Changes being sought to resolve any objection None Policy CS4 Sustainable Construction and Energy Efficiency Support or object Object Reasons for support or objection We object to the requirement to raise the level of sustainable construction and energy efficiency standards above those set out at regional and national levels. It was the intention of the Code for Sustainable Homes and BREEAM to set construction standards higher than Building Regulations, therefore raising this level even further is unnecessary. It is therefore not lawful or consistent with national policy to seek a higher standard than Government targets and raises serious viability issues for developments. Specifically we object to the following standard for residential development: ‘Code for Sustainable Homes Level 4 for the urban areas.’ The Code for Sustainable Homes states that Level 4 needn’t be achieved until 2013, imposing this requirement prematurely will effect the viability of schemes especially in the current economic climate. We further object to the line: ‘developments over 1 hectare or 100 dwellings to achieve 30% reductions (in CO2).’ The adopted South East Plan makes no reference of this recommendation and only specifies this requirement to be at 20%. Policy CS4 is therefore unsound as it is not legally compliant or consistent with national policy. Changes being sought to resolve any objection Amend Policy CS4: ‘Residential development should meet the Code for Sustainable Homes as set by National Standards.’ ‘20% reduction in CO2 emissions as in compliance with the adopted South East Plan.’ M:\20553\0600-090630-Calcot Reps 2 Policy CS8 Housing Distribution Support or object Object Reasons for support or objection We support that the Eastern Urban Area has been identified for locating a share of the majority of development. However, we consider there are sites available, such our client’s site at Calcot Golf Course, which do not fall within the definition of previously developed land but would be suitable for development. Furthermore, the land is surplus to requirements and will not result in the loss of playable area of fairway within the Golf Course. Changes being sought to resolve any objection Amend wording to Policy CS8 to also include ‘other suitable sites within the settlement boundary’ as suitable locations for development. Policy CS9 Strategic Sites Support or object Object Reasons for support or objection We support that the Eastern Urban Area has been identified for locating a share of the majority of development. However, there are more likely to be delivery issues with the allocation of a few larger sites. We therefore consider the policy should refer to the need to allocate a range of smaller sites to ensure delivery. In addition, if there are delays with the completion of larger sites it can make the District vulnerable to development on sites that have not been assessed through the Local Development Documents as developers may find justification for development through the lack of a 5-year housing land supply. We believe by including smaller sites it allows for a more flexible approach in the phasing of housing delivery. Furthermore, Policy WCBV1: Core Strategy of the South East Plan is specific in referring to the need to allocate smaller sites as well: “smaller allocations may be brought forward at other settlements, subject to their meeting the same sustainability considerations ” We also note Calcot is not included on the diagram to policy CS9. This should be included to provide context to the policy. Changes being sought to resolve any objection Include the words “which includes a mix of smaller and larger sites” after the first line “ The majority of new development will take place in and around the urban areas of the District”. Include Calcot on the diagram within policy CS9 M:\20553\0600-090630-Calcot Reps 3 Policy Eastern Urban Area Option 4 and 5 CS9 Strategic Sites Support or object Support Reasons for support or objection We support the option for identifying smaller sites at Calcot. Changes being sought to resolve any objection None Policy CS11 Affordable Housing (option A and B) Support or object Object Reasons for support or objection Policy CS11 is not in general conformity with the South East Plan as it states a ‘minimum’ of affordable housing will be required. However, Policy H3 of the South East Plan states that local authorities should include targets for the provision of affordable housing having regard to: “..the overall regional target that 25% of all new housing should be social rented accommodation and 10% intermediate affordable housing.” Furthermore we object to the wording of the policy “40% on greenfield land.” Housing need should determine the percentage and locations of affordable housing and not the type of land that is being developed. Changes being sought to resolve any objection Delete the words “minimum” from Policy CS11. Delete the separate requirement for greenfield sites as this is not supported by housing need. Policy CS23 Open Space Support or object Object Reasons for support or objection Whilst we note the principle of protecting and enhancing existing areas of open space we consider this should be balanced against the need for housing on a site by site basis. Furthermore, consideration should be given to the current level of accessibility of sites deemed to be ‘important open space’ and in light of poor accessibility alternative uses, such as housing, be considered. Changes being sought to resolve any objection We consider that this policy should be amended to read “…A strategy will be implemented to protect and enhance existing open spaces and to establish new areas of open space where there is a need. Account will given of the accessibility of open space and the need to deliver housing when considering development proposals.” M:\20553\0600-090630-Calcot Reps 4 .